ML20010J570
| ML20010J570 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/29/1981 |
| From: | Henderson O ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20010J560 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8110050363 | |
| Download: ML20010J570 (65) | |
Text
. . - . -.- . . - . - - ~_ - - _. - ....
'a R11.1,TED RORRESPONDENCII [
j
! i b ,
f UNITED STATES OF AMERICA
,, NUCLEAR REGULATORY COMMISSION r
l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
i PENNSYLVANIA POWER & LIGHT COMPANY )
)
- and ) Docket Nos. 50-387 l ) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )
)
- (Susquehanna Steam Electric Station, )
i Units 1 and 2) ) M r o>
i
/
l C07//47ti N\
H I
9-
. .) 198[' . -n ,
-t
- (" ....,,;#7 s
M r- . '. e/p I APPLICANTS' TESTIMONY OF l ORAN K. HENDERSON C0 > i
( ON CONTENTION 20 i
4 l
t I
i September 29, 1981 kOhoon PDR
. . _ . . . _ , . . _ , . ~ . . . . ~ . . . _ _ . _ _ _ _ _ . . _ , _ , . . _ , . . . . . _ _ - . _ , _ . _ _ - _ ._, . _ , _ . ~ ~ _
a CONTENTION 20 AND RESPONSES CONTENTION (1) (a):
[1][a] NUREG 0654 REV. 1 (section A. 1,b.) recommends that each organization and suborganization having an operational role shall specify its concept of operations, and its relation-ship to the total effort. Luzerne County Civil Defense's local plan gives merely an outline of concept, leaving blank important information (page 6 of the Luzerne County plan) about telephone and dispatcher communications.
RESPONSE
The August 1981 "Luzerne County Radiological Emergency Response Plan for Incident at the Susquehanna Steam Electric Station" l
(draft) provides an overall concept of operation, detailed notification procedures and the communications sequences (see paragraph VI, pages 11 through 14). Appendix 3, " Interrelationships of Organizations" (pg.3-1) depicts Luzerne County's relationship to the total effort.
Annex B, " Communications" includes a detailed description -
of the Luzerne County's existing communications capabilities. This annex establishes the procedure for the maintenance of current telephone numbers for key personnel and organizations in the Emergency Operations t
{
Center. (see paragraph IV, F, Annex B, - pg. B-2)
(1) (a) continued:
Moreover, the Luzerne County plan (page 5; section 5) states that the " county conducts program of public education, training and exercise of emergency forces and posts route signs and evacuation." But the plan fails to mention when, j where and how the public education and exercises will take place. Nor does the plan mention where signs will be posted.
RESPONSE
The above quoted statement no longer appears in the Luzerne County Radiological Emergency Response Plan (RERP). The present Luzerne County RERP tasks the County Civil Defense Director in coordination with
_ - - - = - - - - _ - - - --
4 5 RESPONSE (1) (a) continued:
I 4
T , Pennsylvania Emergency Management Agency (PEMA) to develop a public information program, (paragraph III A, Annex D, "Public
) Information", pg. D-1). Paragraph V.I. 9. (pg 10) of the basic
] plan assigns to the County Public Information Officer responsibility t
1 for the " operation and distribution of public information materials prior to an emergency." Annex S, " Exercises and Drills",
1^
reflects the frequency of drills, and exercises and provides for county and municipal government participation in coordination with i
State and the facility.
1 4
The Luzerne County RERP does not reference the posting l of signs. Paragraph IV, D. 7. of Annex F " Police Services" l
! provides that Police will assist municipal Transportation Coordinators 1
in obtaining " signs, barricades and other required equipment."
(see page F-3). However, the requirement for any special signs has not been established in the Luzerne County RERP, nor, is such a requirement shown in NUREG 0654.
l (1) (a) continued:
i The plan further states that the " radiological thyroid blocking chemicals are stocked." The plan fails to mention where and how the public will be informed of thyroid blocking chemicals or where they will be stored.
RESPONSE
The Luzerne County RERP acknowledges that State government is responsibic for the procurement, distribution and storage of thyroid blocking agents (see paragraph II, App 8, to Annex M, " Radiological Exposure Control", pg M-8-2. The RERP l - - - - . - - - ... -
RES*PONSE (1) (a) continued:
identifies those emergency forces, key personnel and institutionalized personnel within the plume exposure pathway emergency planning zone who will be provided potassium iodide (Kl). (see paragraph II. A., App 8, to Annex M, pg M-8-2).
CONTENTION (1) (b)
(b) .... The state, and (Luzerne County plans) - do not meet the recommendations of NUREG 0654 REV. 1 (section A.l.
(c) ) that recommends each plan to illustrate these interrelationships in a block diagram.
RESPONSE
The Luzerne County RERP includes a block diagram of the principal Federal, State and volunteer organizations having an emergency role and describes each agencies relationship to the total effort. (see App 3, " Interrelationships of Organizations" pg. 3-1.)
t l
l I .
CONTENTION (1) (c)
(c) NUREG 0654 (Section A. 1,d) recomme Js that ea'ch organization shall identify a specific individual by title who shall be in charge of the emergency response. The Luzerne County Civil Defense plan states no such individual.
RESPONSE
The Lucerne County RERP acknowledges that the overall decisionmaking responsibility remains with the County Commissioners.
The County Commissioners have appointed a Coordinator of Civil Defense, responsible to them, for the overall coordination of activities in response to an incident at the Susquehanna Steam Electric Station.
(see paragraph V, basic plan, pg 5) i l
l l
l
CONTENTION [2] [a]
[2] [a] .NUREG 0654 (section A. 2, a) recommends that: "Each organization shall.specify the functions and responsibilites for major elements and key individuals by title of emergency response, including the following: Alerting and Notification; Communications, Public Information; Accident Assessment; Public Health and Sanitation; Social Services; Fire and Rescue; Traffic Control.....
RESPONSE
The Luzerne County RERP assigns specific responsibilities to all elements and key personnel involved in its response mechanism (see paragraph v. A through I, pg 5-10). Appendix 2 (pg 2-1) further delineates in chart form the primary and support responsibilities for accomplishing those specific functions cited in NUREG-0654, element A.2,a.
[2] [a] continued Luzerne County Civil Defense plan (page 11) states "see Annex E" for communications and goes on to state (page 11) they will notify Luzerne County Chamber of Commerce to pass to business and industry in affected area." Plan does not state how Chamber of Commerce would assume this responsibility. There is no such organization called Luzerne County Chamber of Commerce. Moreover, the plan does not suggest what will happen if a nuclear incident occurs when the Chamber of Commerce is not there to pass to business and industry, i.e. if accident occurs after 5:00 p.m. when
, offices would be closed.
RESPONSE
The Luzerne County RERP no longer refers nor relies upon the Chamber of Commerce for dissemination of information to business and industry. The RERP provides for direction and control through the
! Emergency Operations Center (EOC). The EOC has the capacity for 24-hour extended operations. (see Annex A, pg. A-1.) The Luzerne County RERP l provides for activation of the siren warning system followed by announce-ments over the Emergency Broadcast System (EBS) upon receipt of an emergency notification classification of Site Emergency or higher. (see paragraph VI. G.3. pg 13). Business and industry would be advised of the emergency incident through these means.
._ .. . _ = _ _ -. .. . . . . _ . - - _ . . .-
1 CONTENTION [2] [b]
[b] Public Information in Luzerne County Civil Defense plan is merely an outline (page 17 of LCCD plan).
It lists in 4 brief lines:
- 1. Develop media release (Plan does not state who will do this nor for what purpose)
! 2. Brief local media (Plan does not state
! what media will be briefed about)
- 3. Operate various control (What does this have centers to do with public information)
- 4. Monitor Media (Plan does not state what media will be monitored about)
RESPONSE
The Luzerne County RERP no longer contains the four lines cited in the above contention. Annex D, "Public Information" to the i
Luzerne County RERP assigns the Civil Defense Director and Public Information Officer responsibility for the development of a public information program designed to inform the public of plans and procedures for notifying them in the event of an incident at the SSES (see paragraph l
l III. A. pg D-1). Annex D, "Public Information" to the RERP provides sample messages to be disseminated under specific circumstances. (see pgs D-1-1 through D-6-1). Provisions are included in Annex D for annual news media orientations to acquaint the news media with the County plan and procedures for the release of information during an emergency (see paragraph IV. C. pg D-2). The Luzerne County RERP provides for the t
activation of a rumor control center in order to respond to inquiries received from the public during an emergency situation at the SSES (see paragraph IV. F. pg D-2).
The Luzerne County RERP no longer includes any statement regarding media monitoring.
CONTENTION [2] [c]
[c] Public Health and Sanitation is not mentioned in LCCD plan.
i
RESPONSE
The Luzerne County RERP uses the term Medical / Health group. (see paragraph V.I.5. pg 9). Additionally Appendix 2 (pg 2-1) to the RERP assigns emergency medical services responsibilities to 1
the Medical / Health Chief.
[2] [c] continued Fire and Rescue: Utility plan (page 5-8) states there will be one drill per calendar quarter and (page 8-3) states local fire and rescue companies will be invited '
to participate in a training program. LCCD plan (page 13) merely outlines " Fire & Rescue Group" in 3 sentences, stating " units evacuating from affected area will report to facilities in Annex D." Annex D is not included in plan, nor is there any clear delineation of who the fire companies are.
RESPONSE
The Pennsylvania Power & Light Company Susquehanna Steam Electric Station Emergency Plan revised, designates off site emergency forces including fire companies (see pages 2-2 & 2-3) Paragraph 3),
and establishes notification procedures. (see pg 3-3). Paragraph 5.3.3 (pg 5-12) again lists those off site emergency orces including fire companies and refers to letter of agreement which may be found in Appendix A.
1 The PP&L Emergency Plan (Rev 4, 5/8/) provides for orientation i
and training of off site emergency forces "on at least an annual basis" (paragraph 8, see pg 8-3). At the same citation the plan specifies selected topics to be included in the training and orientation.
Paragraph 8.1.2 " Drills and Exercises" (pg 8-4) describes the scope and frequency of drills.
CONTENTION [2] [d]
[d] Traffic Control: Luzerne County Civil Defense pla.
gives an outline of traffic control under " Police Group". It does not list what " units" are available for traffic control.
- RESPONSE
Annex F, "*)olice Services" to the Luzerne County RERP assigns municipal police in support of State Police (see paragraph IV. D.6. page F-3) . Paragraph IV. D.4. page F-3, assigns
]
! municipal police traffic control responsibilities within their a
respective municipalities. The State Police have responsibility for traffic control on main evecuation routes (see paragraph II.
C. page F-1).
7.ppendix 1, to Annex F, lists all police agencies within the plume exposure pathway emergency planning zone and includes manpower and vehicles available (see page F-1-1 through F-1-4).
l a
CONTENTION [2] [e]
(e] . .
.Luzerne County Civil Defense plan gives a mere l outline of responsibilities of medical groups.
(page 15 of LCCD plan- ) There are no names of medical organizations who would be involved in an evacuation.
Under LCCD's " general evacuation," it states they will evacuate Saint Stanislaus Home to and evacuate invalids whose evacuation requires use of ambulance.
The LCCD plan does not tell us who the ambulance associations are nor if they are equipped to handle such an emergency.
RESPONSE
Annex G " Medical Support" to the Luzerne County RERP states that "a Medical and Health Group Chief has been appointed to assist the County Director / Coordinator with medical support."
(See paragraph II. A. , pg G-1.) Appendix 1 contains a listing of hospitals and nursing homes located within the plume exposure pathway emergency planning zone (see page G-1-1) . Appendix 3 lists supporting hospitals in Luzerne and adjacent counties (see pages G-3-1 through G-3-4). Appendix 8 lists municipalities within the plume exposure pathway EPZ and designates a specific support hospital (see page G-8-1) . Appendix 9 lists ambulance services within the plume exposure pathway EPZ (see page G-9-1).
Appendix 1, to Annex I " Transportation" lists all support ambulance resources together with number of pe sonnel and vehicles (see page I-1-2). Based upon current assessment of ambulance requirements for use during an emergency relocation of patients, sufficient ambulance resources are available and identified in the Luzerne County RERP (Appendix 1, to Annex I pg I-1-2).
The Luzerne County RERP includes provisions for designating the relocation site assigned the Saint Stanislaus Medical Center (Appendix 6, Annex G pg G-G-1) and although the appendix is incon71ete coordination is underway to designate the Saint Joseph Hospital, Carbondale, Pennsylvania as the relocation site.
. -1R-
CONTENTION [2] [f]
[f] NUREG 0654 (Section A. 2a) cites the description of these functions shall include a clear and concise summary such as a table of primary and support responsi-bilities. None of the above, from Communications to Emergency Medical - Fulfills this recommendation.
RESPONSE
Appendix 2 "Luzerne County Primary and Support Responsibilities Chart" lists all of the functions identified in Section A. 2.a. of NUREG 0654 and in matrix format designates primary and support roles (see page 2-1).
5
1 CONTENTION [3] [a] l
[3] [a] NUREG 0654 REV. 1 " Notification Methods and Procedures" (page 43) recommends "the content of initial and follow-up messages to response organization and the public has been established and means to provide early
- notification and clear instruction to the populace."
RESPONSE; l
] The State RERP cites specific requirements for content of the initial notification message from the facility (see paragraph 1.B. Appendix 3 pg 3-1). The Bureau of Radiation Protection is i responsible for communications wit 5 the facility after the initial i
] message is received and its plan provides for acquiring the essential l information recommended in NUREG 0654 (see Appendix 8, paragraph 5.2.B.
I pgs 17 & 18).
1 The Luzerne County RERP, Annex D, "Public Information" provides a series of draft messages to be released through the Emergency Broadcast System under specified emergency circumstances (see Appendix 1 (D-1-1), Appendix ? (D-2-1), Appendix 3 (D-3-1),
Appendix 4 (D-4-1), Appendix 5 (D-5-1) and Appendix 6 (D-6-1).
J CONTENTION [3] [a] (continued) -
Luzerne County Civil Defense plan (page 6) cites under" both selective evacuation and general evacuation that County will notify Chamber of Commerce to pass on notification to business and industry." There is no
, clear outline'of how this will be accomplished and no
! letters of agreement appear between Civil Defense and Chamber of Commerce.
RESPONSE
See response [2} [a] above.
u i
, , . , . , - - - - - - - . - - - = - - . - , -v, , . , .,.-w,w,-ecy-e,e-e---,,w-s.,,,e- #,,.,--mr%-wew-e.--.-,, ,,,--9,,,. - ,--
CONTENTION (3] [a] (continued)
Cited under general evacuation (Luzerne County Plan, page 6), political subdivisions will be responsible for door to door notification within political boundaries.
There is no mention of how this notification would be executed within political subdivision [s] nor who would be responsible for such notification if a general evacuation is called. There are no letters of agreements with political subdivisions to assume that responsibility of notification.
RESPONSE
NUREG 0654 recommends that means be established for the prompt notification of the public however, it does not make reference to a door to door notification system (see E.6. NUREG 0654).
The Luzerne County RERP states that municipal emergency response plans contain procedures for door to door notification.
(See Para IV. E. Annex C). Each municipal RERP includes provisions for notifying the public through the use of vehicle mounted public address systems and/or knocking on doors, as appropriate.
Annex E " Fire and Rescue" of the Luzerne County RERP assigns fire companies responsibility for implementing municipal emergency plans in providing warning to the public. (See paragraph II. B. page E-1 and paragraph IV. D. page E-2.)
- 2. Each municipality has plans dividing the municipalities into aler* sectors designed to facilitate prompt notification of the public in the event of a nuclear incident.
Letters of agreements between parent counties and municipal governments are not recommended by NUREG 0654.
- - ~ . .- . - .__ . - _ , . _ - - - - - -. - . . . .-
CONTENTION [3] [b]
[b] NUREG 0654 (sectiori S. 1, page 43) recommends that procedures for notif cation include means for verification of messages. Luzerr.e County plan makes no mention of any verification of messages.
RESPONSE
The Luzerne County RERP provides a detailed discussion of procedures for the receipt of emergency action information from SSES. Included is a requirement to obtain name and telephone number of individual initiating the emergency information in order that a return (confirming) telephone call can be made. (See paragraph
, D. 1. page 12) .
CONTENTION [3] [b] (continued) i Luzerne County plan does not meet the requirements of NUREG 0654 (appendix 3 page 3-2) which states " plan should give a description of the information that would be communicated to the public under given circumstances, for continuing instruction on emergency actions to follow, and updating of information.
RESPONSE
See 3a above.
l
)
1 t
5
-.e.,- - - - , , ,-,,--,,,-w,----,,--, --,-,,----,,,,,-,-,,,----,,,-,,,---,e,,,,m -
, ,wm--a , -g,---n .m _ vem.n,n-----,,-- - - - - - - - ~ - - - - - , - ~ ~ . - + - - - - -
CONTENTION [4] [a]
[4] [a] NUREG 0654 (section G 1 page 49) recommends that c'ch organization shall provide a coordinated periodic J'_ssemination of information to the public. It shall include:
a) education information on radiation b) protection measures c) special needs of the handicapped.
Neither the State plan or the Luzerne County Civil Defense plan gives any mention to periodic dissemination of information to the public.
RESPONSE
One of the principle purposes of the PEMA RERP (Annex E, " Fixed Nuclear Facility Incidents" February 1981 to the Commonwealth of Pennsylvania Disaster Operations Plan, 1977) is to establish requirements for and procedures to implement a public education program. (See paragraph IV L page 6.) Further, "The Commonwealth will conduct, on a continuing basis, an education program to familiarize the public with factual information concerning nuclear radiation." (See paragraph VI, S. page 11.) The primary and support matrix (attachment 1 to the basic RERP) reflects PEMA as having overall responsibility for public education and information and the following entities as having a supporting role: Facility, Departments of Agriculture, Health, Education, Environmental Resources (BRP), !
and Risk and Support Counties. !
Appendix 15 (page 15-1) "Public Education and Information" describes in detail pre cedures for accomplishing the public information program cited above, and provides for an annual update (see paragraph IV. C. App 15).
The Luzerne County RERP requires each municipality to maintain a listing of ocrsons requiring special medical care. (See paragraph V. 9. page 7). The County RERP includes a primary and support l 1
l
CONTENTION [4] [a} (continued) matrix (Appendix 2, page 2-1) which assigns primary responsibility to the County Commissioners and the Public Information Officer for overall public information. Annex D "Public Information" establishes procedures for accomplishing a program to inform residents, tr".nslents and handicapped persons. (See paragraph III. D. para D-1). Paragraph IV. A. provides for annual updating l of this information.
CONTENTION [4] [a] (continued) l Luzerne County Civil Defense plan doesn't meet l
NUREG 0654 section G 2 [ requirement] to see that the public information program should include provision I for written material that is likely to be available in a residence during an emergency.
RESPONSE
The Luzerne County RERP provides that the Luzerne County Civil Defense (LCCD) Director / Coordinator will coordinate the distribution and that municipal civil defense coordinators will distribute printed materials to " local residents, hotels, motels, campgrounds, and other transient population areas." (See paragraph IV. B. to Annex D, page D-2.'
CONTENTION [4] [a] (continued)
Nor does the Luzerne County plan meet NUREG 0654 (Section G 4. a.) recommendation designating a spokesperson who should have access to all necessary information.
RESPONSE
(
Paragraph V. A. (page 5) to the Luzerne County RERP states that the County Commissioners have appointed the LCCD Director /
Coordinator "as their spokesperson." The Emergency Management Services Code provides that the coordinator shall be responsible for planning, administration and operations of the emergency management organization
1 CONTENTION [4] [a] (continued) subject to the direction and control of the governing body.
Consequently, due to the coordinator's position in the chain of l communication, he would have access to all necessary information. ;
CONTENTION [4] [a] (continued) j Luzerne County plan gives no provision for the I planning standard of NUREG 0654 (section G) , which l states " procedures for coordinated dissemination of
, information to the public are established."
l l RESPONSE:
The Luzerne County RERP establishes procedures to be followed in the dissemination of information to the public.
(See Annex D, "Public Information," page D-1 through D-3 and Appendices 1-6, thereto.) ,
CONTENTION [4] [a] (continued)
Luzerne County plan gives 4 brief lines to "Public Information".
RESPONSE
Annex D, "Public Information" provides two and one half pages to public information. (See Annex D, page D-1 through D-3.)
i
- - - . - _ - . _ . . _ _ . , _ _ . _ . _ . , _ _ . . _ _ _ _ . ,_ - - - . _ . . _ . , , . _ _ _ _ _ _ _ _ _ _ _ . - - . . - , . . , _ _ _ . - _ , . . , _ _ . , ~ _ - - . _ , - .
J i
1 i
CONTENTION [5} [a}
[5] [a] NUREG 0654 REV. 1 (H 7, page 54) states that "each organization, where appropriate shall provide
- for offsite radiological monitoring equipment in i the vicinity of the nuclear facility." The Luzerne l County Plan makes no provision for such equipment.
l
RESPONSE
The Luzerne County RERP states that it will rely upon 4
the Bureau of Radiation Protection (BRP), the Department of Environmental Resources (DER), for field monitoring (offsite)
)
and for accident assessment. (See paragraph II. A. Annex M, 1
" Radiological Exposure Control".) This Annex and accompanying appendices treat the distribution and use of radiological instruments
- under county control.
I l
i 1
(
i I
I i
, . . . - ,,.. - v_ - ,_ ,,..--_,,_ - - - _ , . _ , - , ., ,,..._.__,. _ ...- _ _ ,.,. ,..,,. . -. _ ... - .--_.-_,, ._,- --. -. - .. -.,.
=_- -. _ _ .. _ - .
CONTENTION [5] Jhl.
[b] NUREG REV. 1 (H 10, page 54) recommends that "$ach organization shall make provisions to inspect, inventory and operationally check emergency equipment / instruments at least once each calendar quarter and after each use.
There shall be sufficient reserves of ins *rument/
equipment to replace those that are removed from emergency kits for calibration or repair." The state plan does not meet this requirement since it does not mention inspection, inventory, or checking of such equipment, nor does it mention reserves. . .
RESPONSE
The BRP, DER plan (August 1981) Nuclear Power Generating Station Incidents (App 8 to the State RERP) provides that emers_ncy equipment will be inspected and operationally checked each calendar quarter (see paragraph 8.4.3 page 24) . It al'so provides that each BRP office area will maintain 2 complete sets of equipment operationally and an additional set in reserve.
(See paragraph 8.4.2 page 24. )
1 l
j
CONTENTION [5] [cl i
[c] NUREG 0654 REV. 1 (H 11, page 54) recommends that "each plan shall, in an appendix, include identification of emergency kits by general category (protective equipment and emergency supplies)." The state plan and [Luzerne] county plan both fail to meet this requirement since they do not include this information in an appendix or elsewhere.
RESPONSE
Appendix 8 to the state RERP, identifie3 emergency monitoring equipment maintained by the State. (See paragraph 8.4.2 page 24.)
The Luzerne County RERP reflects the number and type of radiological equipment in Luzerne County. (See Appendix 6,
" Radiological Equipment Resources Inventory" to Annex M. page M-6-1.) The RERP provides for identifying resources required to implement the plan and for reporting shortfalls to PEMA for action.
(See Annex Q. )
Neither the State or Luzerne County RERPs identify in a single appendix a categorization of emergency kits however, the RERPs contain various appendices which treat with supplies and equipment and meet the guidance contained in NUREG 0654.
1 CONTENTION [6] [a]
[6] [a] NUREG 0654 REV. 1 (I 7, page 57) recommends that "each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of this concept of operations for the facility." The Luzerne County plan makes no provision for such monitoring. The state plan provides for such monitoring, but omits specifics such as type of equipment, number of fixed monitoring sites or their location. With respect to in-place surveillance, the state plan (DER, p.
XIV-1) states that " Generally these include air samplers and TLD's" which is too vague to comply with the NUREG requirement.
RESPONSE
The State RERP lists the quantity and purposes of equipment available to the BRP, DER, other state agencies and resources outside the Commonwealth. (See paragraph 3.1 -
- 3. 8, Appendix 8, pages 8-11. )
The Luzerne County RERP relies upon BRP for field t monitoring and accident assessment. (See paragraph II. A. Annex M, Page M-1.)
Fixed monitoring sites are treated in paragraph 9.9.2.
(page 36) of Appendix 8, State RERP and states that maps showing the location of monitoring devices are available in the BRP office.
l l
l l
. l CONTENTION [6] [b]
, [b] Referring to the. . . state, NUREG 0654, REV. 1 j (I 9, page 58) states "each organization shall i have a capability to detect and measure radiciodine concentrations in air in the plume exposure EPZ as low as 10-7 uCi/cc (microcuries per cubic 1 centimeter) under field conditions." . . .[The]
l state (plan does not] mention whether [it has]
i this capability, i
j RESPONSE:
Appendix 8, State RERP, states that BRP Field i
teams are equipped with air samplers capable of detecting and measuring radiciodine concentrations in air as low as 10-7 microcuries per cubic centimeter. (See paragraph 3.6. pg. 10, Appendix 8.)
i h
i 1
1 '
i 1
r i
l i
i 1
l
CONTENTION [6] [c]
[c] NUREG 0654, REV. 1 (I 10, page 58) rccommends that the. . . state " establish means for relating the various measured parameters (e.g. contamination levels, water and air activity levels) to dose rate for key isotopes" and provide "for estimating integrated dose from the projected and actual dose rates cnd for compar-ing these estimates with the protective action guides."
The requirement states that the " detailed provisions shall be described in separate procedures."
[The plan] fail [s] to meet this requirement by being too vague about the procedures to be used, failing to mention specific isotopes, and not referring to detailed provisions in separate procedures. The state plan (DER, p. XIII-2) says
" estimates of direct population exposure from the passing cloud and from ground deposition are made from in place air samples (sic) and from energy compensated TLD's."
RESPONSE
Appendix 8, State RERP, describes in detail procedures for relating contamination levels to dose rates and comparing estimates to protective action guides. (See paragraph 9, Appeidix 8, pg. 26-35.) Para 10.2, Appendix 8 (pg. 40-43) discussee further procedures and considerations for determining protective action to be taken.
l CONTENTION [7] [a}
[7] [a] The Luzerne County plan would not adequately protect l
the public in the plume exposure pathway EPZ, as recommended by NUREG 0654, REV. 1 (J), in part because the county plan has in some cases assigned tasks to organizations that do not exist or cre not aware of having been assigned such tasks:
- 1) The County plan states (pp. 6, 11, 12) that in the event of a decision to take cover or evacuate the county will notify the "Luzerne County Chamber -
of Commerce" to pass notifictaion to business and industry. No organization by this name exists.
RESPONSE
The Luzerne County RERP (August 1981) assigns tasks to organizations actually in existence or are activated under emergency conditions. The Luzerne County (Wyoming) Chamber of Commerce is provided no assignment.
CONTENTION [7] [a] (continued)
I
- 2) The County plan states (p. 7-8) " individuals with no transportation may request same through local fire companies. Commercial buses will be dispatched to local fire stations in the affected area to trarsport these individuals." The county did not consult either the fire companies or bus companies before including this procedure in the plan, or inform them of having included it.
RESPONSE
The Luzerne County RERP (August 1981) no longer uses the above cited language. Appendix 4, " Pick Up Points for persons Without Automobiles" to Annex I " Transportation" provides a partial l
i listing of pick-up points, and by footnote acknowledges that additional listings will be made upon receipt of municipal plans.
l l
) CONTENTION [7] [a] (continued) l t Maps are not provided by. . .the. . . county
[or] state showing, " preselected radiological j sampling and monitoring points, relocation centers 7 in host areas, and shelter areas" as recommended j by NUREG 0654, REV. 1 (J 10a, p. 61).
RESPONSE
l Annex W " Maps" to the Luzerne County RERP lists ,
maps that are included or under development for inclusion by PEMA. Upon receipt of maps identified in Annex "W", the above i
cited recommendation of NUREG 0554 will have been met.
Radiological sampling and monitoring points
- see para 6.a. above.
l 2
J I
l
)
4 1
4
. I 1
CONTENTION [7] [b] i
[b] In the state plan (PEMA, p. 10) assigning to the state Department of Health the responsibility to
" Develop procedures for stockpiling, in adequate
" supply, [ distributing), and administering thyroid blocking agents and such other radiological health materials as may be required" does not meet the requirement either as it states that 1) thyroid blocking chemicals are to be stocked (p. 5),
- 2) the county medical officer will coordinate the distribution with the state Department of Health (p. 7), and 3) the county medical group will assist the state Department of Health to their distribution (p. 15) but gives no more specifics.
RESPONSE
The State RERP provides for the predistribution of postassium iodide to risk counties (see para IX, App 1 to App 9).
The cited reference indicates that the site selection for the SSES is being developed. (pg 1-10.) Appendix 1 includes information regarding the use of thyroid blocking agents, Depart-ment of Health policy, decision criteria for its use and its distribution scheme.
The Luzerne County RERP designates the category of emergency workers for whom potassium iodide will be stockpiled and establishes the number of units required by each municipality 4
and activity (see Appendix 8, Annex M) .
26 -
CONTENTION [7] [c]
[c] Neither the state nor (Luzerne] County plan meet the recommendations of NUREG 0654, REV. 1 (J 10f, p. 63) that " State and local organizations" plans should include the method by which decisions by the State Health Department for administering radioproductive drugs to the general public are made during an emergency and the pre-determined condition under which such drugs may be used by offsite emergency workers". Neither plan addresses these decision-making issues at all.
RESPONSE
See 7b above.
l t
i
CONTENTION [7] [d]
[d] The state and [Luzerne] County plan meet the recommendation of NUREG 0654, REV. 1 (J 10g, p. 63) that they specify the "means of relocation." The County plan (pp. 7-8) states " individuals with no transportation may request same through local fire companies. Commercial buses will be dispatched to local fire station",. . .[but does not] specify the logistics of the procedure.
RESPONSE
See 7a above.
CONTENTION [7] [d] (continued)
It states (p. 7) " schools will be evacuated by school authorities with school bus transportation to designated schools outside the 10-mile area,"
but does not name the schools outside the 10 mile EPZ, name the designated schools to which the children are to be evacuated, or specify whether the capacity of the school buses are sufficient to evacuate the students without making return trips.
RESPONSE
Appendices 1 and 3 to Annex N list the risk and host schools respectively. Appendix 1 to Annex I lists the transportation resources available for evacuation of schools. The plans do not indicate whether a single or multiple lifting is required. The specifics of school evacuation will be contained in the school plans currently under development as required by paragraph II, B. Annex N.
l t
l !
CONTENTION [7] [e]
[e] .The state and [Luzerne] County plans do not meet the recommendation of NUREG 0654, REV. 1 (J 10h,
- p. 63) that they include " relocation centers in host areas" since neither plan names specific relocation l centers. The County plan (p. 7) states " Red Cross
, will open reception centers at ,
, , and mass cara centers in County to accommodate 18,000 persons."
i The capacity of 18,000 persons is inadequate
' since the population of the 10-mile EPZ is 47,171 (PEMA, appendix la, p. 1). The plan does not state that the Red Cross is capable of staffing adequate relocation centers.
RESPONSE
The State RERP designates support counties for the purpose of providing mass care facilities for Columbia and Luzerne Counties in the event of an incident at the SSES. (See Attachment 1, Appendix 6, State RERP, pg. 6-4).
The Luzerne County RERP identifies the population within the plume exposure pathway emergency planning zone and establishes a total population of 51,604. (See Annex J
" Evacuation", pg. J-3.)
Both the State and Luzerne County RERPs include I
the assumption that at least 50% of the population will make independent arrangements for relocation accommodations in the event of a requirement to evacuate. (See State RERP paragraph i
V. B. 6. pg. 8 and Luzerne County RERP paragraph VII. A. pg. 11.)
Based upon State's experience in disaster emergency operations this assumption is extremely conservative and overstates relocation accommodation needs.
The State RERP also references its " Mass Care Opertional Program" Emergency Management Directive No. 32 (See Section I, paragraph 12, pg. 2). This directive includes letters of agreement for support from the American Red Cross in periods of disaster and
CONTENTION (7] [e] (continued) outlines roles and operational procedures. The Red Cross structure provides for the introduction of resources from throughout the organization and is not limited to manpower and/or equipment from its local Chapters.
The Luzerne County RERP provides for relocation of approximately 6,520 persons to facilities within Luzerne County and 19,290 to predesignated Mass Care facilities in Lackawanna, Schuylkill, Union and Wyoming Counties. This total of 25,810 approximates the assumed 50% of the population assumed to require mass care support. (See Annex L, para IV. C. pg. L-1.)
CONTENTION [7] [f]
[f] Neither the state or [Luzerne] County plan includes
" projected traffic capacities of evacuation routes under emergency conditions" as recommended by NUREG 0654, REV. 1 (J 10i, p. 63).
RESPONSE
NUREG 0654 recommends that Licensee's (see Standard J. 8.) plan contain evacuation time estimates as well as State and county plans (see Standard J. 10. 1.). The cited Standards
! provide that estimates be made in accordance with Appendix 4, 1
NUREG 0654. PP&L has conducted, under contract, an evacuation time estimate study. This study is being made available to State and County governments for their use. See paragraph VI, Appendix 6, page.6-3 to the State RERP and Appendix 3, Annex J, J
page J-3-1 of the Luzerne County RERP.
CONTENTION [7] [g]
[g] Neither the state or [Luzerne] County plan includes
" identification of and means for dealing with potential impediments (e.g., seasonal impassability of roads) to use of evacuation routes, and contingency measures,"
as recommended by NUREG 0654, REV. 1 (J 10k, p. 63).
The only such references in the state plan are (PEMA,
- p. 13) " identification of and means for dealing with potential restrictions to the use of evacuation routes to include alternates" is assigned to the Department of Transportation, and DER, Bureau of Radiation Protection's plan states (p. VIII 4) " bad weather will also obviously influence the feasibility of evacuation, thereby making sheltering and other options attractive."
The county plan only states (p. 7) that " based primarily on police and PennDot advice, modifications and detours will be made to evacuation routes as situations develop."
RESPONSE
The State RERP assigns the Pennsylvania State Police (PSP) responsibility for traffic control on major evacuation routes to support the orderly movemen' of people. (See paragraph
- 18. b. pg. 23.) PSP also has the responsibility for highway surveillance and the selection of alternate routes in the event restrictions develop. (See paragraph 18. e. and f. pg. 23).
The Luzerne County RERP acknowledges the PS" role cited above and the assistance to be provided to the PSP by the Pennsylvania Departments of Transportation and Military Affairs (See paragraph IV, Annex K " Traffic Control".) Annex K further assigns responsibilities for clearance of obstacles (see paragraph V. D. 4., pg. K-2) and the provision of wrecker service (see paragraph V. D. S., pg. K-2).
CONTJNTION [7] [h]
[h] Neither the state or [Luzerne] County plan include
" time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various conditions) for the plume exposure pathway emergency planning zone" as by NUREG 0654, REV. 1 (J 101, p. 63). The state plan only assigns to PEMA the function " continue to assess time estimates for protective action responses and update procedures with an objective of reducing actual response times to the extent possible" EMA, p. 12). ,
RESPONSE
See 7. f. above.
l l
i
(
i i
CONTENTION [7] [i]
[i] The plans of the. . . state do not adequately meet the recommendation of NUREG 0654, REV. 1 (J 10m,
- p. 64) that they contain "the bases for the choice of recommended protective actions from the plume exposure pathway during emergency conditions. This l shall include expected local protection afforded in residential units or other shelter for direct and inhalation exposure, as well as evacuation time estimates."
RESPONSE
1 Appendix 8 to the State RERP provides a discussion of the options for protective action and factors to be considered in making a selection (see paragraph 10.2.2 page 41) . Annex 10-A to Appendix 8 provides guidance on protective measures to reduce exposure (see pages 45-48).
i l
1 1
I
i CONTENTION [7] [j]
[j] Neither the state or (Luzerne] County plan meet the recommendation of NUREG 0654, REV. 1 (J 12, p. 65) that "each organization shall describe the means for registering and monitoring of evacuees at location i
centers in host areas." The state plan (PEMA , p. 10) only assigns to the state Department of Environmental Resources the responsibility to " provide for the monitoring of evacuees at relocation centers." The 4 county plan mentions (p. 14) initiating a " human locator system for transients in area" but does not mention registering or monitoring other evacuees.
RESPONSE
The State RERP assigns PEMA the responsibility for developing a plan for radiation monitoring of the public. (See para-
! graph III. B., Appendix 16, " Radiological Exposure Control.). Para-graph IV. B. Appendix 16 assigns County emergency management organizations responsibility for conducting personnel and equipment monitoring of the general public arriving at mass care centers.
The Luzerne County RERP includes detailed instructions for its radiation monitoring of personnel and equipment role. (See Annex M " Radiological Exposure Control" . )
i
. - _ - _ . - . .- .- ~~ .. - _ _ . _ . _ _ , . - . . . , , . - .,_ , - . . - . . - - . _ - -
CONTENTION [7] [k]
[k] The state plan does not adequately specify protective actions for the ingestion exposure EPZ. In particular, it fails to meet the following recommendations of NUREG 0654, REV. 1 (J ll, p. 64).
- 1) The recommendation that "the plan shall identify procedures for detecting contamination" is not met by the plan stating " collection and analysis of environmental materials will be useful in evaluating the ingestion pathway." (DER, p. XIV-2.)
RESPONSE
Appendix 7 to the State RERP acknowledges that listings of dairy herds and' milk / food processors are maintained separately and not included in the RERP (see second paragraph, page 2, Appendix 7).
The State RERP provides that Department of Agriculture field personnel will collect samples of milk, produce and other food products and the BRP will conduct laboratory analysis (see paragraph VI. A. Appendix 7, pg. 20). Procedures for gathering milk samples is discussed in paragraph VI. E. pg. 24. Appendix 7 acknowledges the Department of Agriculture's responsibilities l
to provide linkage with the agriculture community to minimize radiation hazards associated with the food ingestion pathway EPZ (See paragraph III. C. 3. c. pg. 8). The Department of Agriculture assigns to its Bureau of Foods and Chemistry responsibility for maintaining an operations map of the food ingestion pathway and to advise responsible agencies on actions to preclude movement of contaminated food. (see paragraph III. C. 3. d. pg. 8.)
{
CONTENTIOb [7] [k] (continued)
- 2) It is recommended that the plan " identify p.ocedures. . .for imposing protective procedures such as impoundment, decontamination, processing decay, product diversion, and preservation."
The plan discusses the protective procedures mentioned but fails to specify mechanisms for imposing and enforcing any of them. It states,
" protocol for the implementation of any protective action involving dairy products or any agriculture .
product will require the evaluation of the circumstances with the appropriate agency of the Pennsylvania Department of Agriculture." (DER,
- p. IX-1.)
RESPONSE
The State RERP recognizes that confiscation and disposal of milk and food may be necessary. (see Appendix 8, paragraph 9.8.5.C., page 33). Appendix 7 discusses communications and protocols for notifying milk (pg . 24) and food (pg. 26) producers of protective actions to prevent contamination.
m
1 CONTENTION [17] [k] (continued)
- 3) For the 50 mile ingestion. pathway EPZ,
[there is no] mention [of] " maps for recording survey and monitoring data, key land use data,
, (e.g., f arming) , dairies, food processing plants, water sheds, water supply intake and treatment plants and reservoirs" except to state that "a map of dairy herd locations is given in the specific site plan" (DER, p. XIV-2), which is not included.
RESPONSE
The State RERP states that Department of Agriculture maintains dairy herd and milk processor / food processor data which are recorded on an operations map (see paragraph III.
C. 3. C. page 8, Appendix 8). Standard J.ll, NUREG 0654, recommends that a 50 mile ingestion pathway map be maintained J
and that references be made in the plan as to the availability of the map.
l 1
e i
I l
i l
l l
l l (
i
CONTENTION {7) [k] (continued)
- 4) The plan does not include or mention "up-to-date lists of the name and location of all facilities which regularly process milk products and other large amounts of food or agricultural products originating in the ingestion pathway emergency planning zone, but located elsewhere."
RESPONSE
The State RERP states that the Department of Agriculture " maintains dairy / herd lists and milk processor / food processor data which is recorded on an ingestion pathway operations map." (See paragraph C. 3. c, Appendix 7, p. 8.)
CONTENTION [8]
[8] Section K - Radiological Exposure Control
[a] 3.b. No mention of how this should be done in. . .
[the state or Luzerne County] plans. In stt - plans it is generally stated that the Depatcment of Environmental Resources shall be in charge of radiological protective and health matters but nothing specific.
RESPONSE
Standard K. 3.b. NUREG 0654 recommends that' plans provide for the reading of dosimeters at appropriate times and that dose
~
records be maintained. Appendix 16 " Radiological Exposure Control,"
to the State RERP provides guidance for emergency forces.
It provides that each emergency worker will be provided two self-reading dosimeters and that they will be read once each 30 minutes (see paragraph V, App 16). It also prescribed procedures for individual dose records (see page 16-7).
The Luzerne County RERP provides that each emergency worker will be issued a CD V 730, CD V 742 and TLD dosimeters and states that the CD V 730 and CD V 742 are to be read every 30 minutes (see paragraph V. C. 5 page M-4 of Annex M
" Radiological Exposure Control.") Appendix 4 to Annex M is a sample dosimetry report form designed to record pertinent data.
i l
l l
...-. - .~ - .- . . _ _ - ._ _. _
CONTENTION [8]
i
[b] 4. No such decision chain in any of the plans.
RESPONSE
Standard K. 4. NUREG 0654 recommends that State and local organizations establish a decision chain for authorizing emergency workers to exceed EPA protective action guides. The State RERP provides that only elected officials in authority may l authorize emergency workers to exceed protective action guidelines i
i (See Appendix 16 page 16-7) .
The Luzerne County RERP specifies that decision makers (elected officials) on the scene may authorize emergency workers to exceed EPA radiation exposure limits under specific criteria. (See IV. C. 5., Annex M, pg. M-5).
i i
4 l
l
CONTENTION [8]
[c] 5.a. The DER, Bureau of Radiation Protection, is to provide guidance in all such mattes, but there is no specific plan. No mention in. . .
[Luzerne] county plans.
RESPONSE
Standard K. 5. a. NUREG 0654 recommends a determination of the need for decontamination by specifying action levels. The State RERP provides for decontamination procedures when reading of 0.05 M/Rh is obtained (see paragraph 9, Attachment 1 to Appendix 16).
The Luzerne County RE also provides for decontamination when a reading of 0.05 M/Rh is discovered. (see paragraph IV. C. 3, Annex M.)
l 4
CONTENTION [8]
[d] b. Same as above.
RESPONSE
Standard K. 5. b. NUREG 0654 recommends the establishment of means for decontamination.
Appendix 5, "Offsite Radiological Decontamination Procedures" to Annex M (Luzerne County RERP) establishes decontamination procedures for personnel with wounds, for supplies, instruments and equipment, and for disposal of waste.
These procedures are drawn from the State RERP. (See pages 16-4 through 16-6, Appent'i:- ?.6. )
1 1
?
I
1 CONTENTION [8]
[e] 6.a.b.c. No mention.
RESPONSE
Standard K. 6. NUREG 0654 recommends that Licensee provide onsite contaminat'.on control measures for:
- a. area access control
- o. drinking water and fcod supplies
- c. criteria for permitt.ng return of areas and items to normal use.
Provisions for items a. and c. above are found in the SSES Emergency 'lan Implementing Procedures 016 and 027. Provisions for item b. above are found in the SSES Plant Operating Procedures.
].
CON'lENTION [8]
] [f] 7. No mention.
I
RESPONSE
Standard K. 7. NUREG 0654 recommends Licensee provide onsite decontamination capability. The SSES Emergency Plan Implementing Procedures 015 makes such provisions.
3 t
l 1
t 8
4 1,
I i
i
)
e i
4 4
4 i
i i
).
d
,w-,-4-w,,-,y-wy,v.-mww~.---- --vy-y,.m, me--,,,-er,.,c -me sws ,-er e , g a , e- w www--w+-,,,W.,eerw++--,e-rr--v-ew+-w -
.e&-,- w'- wev------+--'+r*
3 CONTENTION [9]
[9] The state and [Luzerne] County plans do not adequately make arrangements for medical services for contaminated injured individuals. Specifically, they do not meet the following recommendations of NUREG 0654, REV. 1 (pg. 69):
[a] "L1) Each organization shall arrange for local and backup hospital services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.
RESPONSE
The State RERP includes a listing of hospitals capable of providing for radiation treatment. The list pertaining to the SSES is shown as under development. (See pg. R-3, Appendix 9.)
The Luzerne County RERP includes a listing of support hospitals in Northeastern Pennsylvania capable of providing for radiation treatment (see Appendix 3 to Annex G) .
s
I CONTENTION [9]
[b] L3) Each state shall develop lists indicating the location of public, private and military hospitals and other emergency medical facilities within the state or contiguous states considered capable of providing medical support for any contaminated individual.
RESPONSE
i Appendix R, to Appendix 9, State RERP, is a detailed listing of hospitals capable of providing radiation treatment.
(See listing pages R-1 through R-27. )
4 i
i 4
1
. . _ _ . _ - . _ , - _ . - , _ _ - . ~ . . . . _ . ~ . . . , _ _ - - - . . _ . . _ _ - _ _ _ _ - . . _ . . _ _ , _ _ _ _ _ _ - - _ . _ _ - - - - . . . - -
i CONTENTION [10]
[10] [a] The Luzerne County plan fails to adequately meet the reentry and recovery planning recommendations of NUREG 0654, REV. 1 (M, p. 70). Beyond stating that Pennsylvania Department of Environmental Resources Bureau of Radiological Health "will establish and disseminate appropriate re-entry criteria" (p. 18),
the only other reference to reentry and recovery in the county plan (p. 7) " reentry to evacuated areas will be denied to all but residents who will be accompanied by mobile patrol, Pennsylvania drivers license will be used as identification, and police cordon blocking entry to evacuated area will make maxinum:
use of local police to facilitate identification of area residents" and (p. 19) " reentry will be based on advice (sic) of BRH, DER. Evacuated area will be denied to individuals not holding Pennsylvania drivers ,
4 license showing them to be a resident of the area.
Residents of the area will be allowed entry accompanied by mobile patrol only with the exception granted by Chief Police Group Luzerne County CD. Emergency services of the area for a period of time before reentry to the general public is authorized." [ sic]
RE SPONSE :
The Luzerne County RERP includes policies and procedures for an oederly reentry following the termination of a general evacuation. (See Annex P, " Reentry.")
I t
CONTENTION [101
[b] The plans of the. . . state do not [ meet] the NUREG 0654 REV. 1 recommendation (M 3, p. 70) that "each . . . state plan shall specify means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur."
i i RESPONSE:
The State R3RP includes Appendix 17 " Reentry
- and Recovery" which assigns PEMA responsibility for notifying i
State agencies and political subdivisions to implement reentry and of any staffing or operational changes. (See para III. A. 2.)
i ,
CONTENTION [11]
[11] [a] NUREG-0654 REV. 1 recommends (N, p. 71) that " periodic
- exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic
, drills are (will be) corrected." The Luzerne County 1 plan fails to meet this requirement, as it makes no mention of exercises or drills, except to list an annex entitled " Training and exercises," which is not included.
! RESPONSE:
The Luzerne County RERP provides for its participation in exercises and drills, identifies and defines their purpose,
- describes their frequency, and establishes a basis for updating plans as a result of critiques and evaluations (see Annex S, " Exercises and Drills") .
.i i
1 i
1 I
I i
+
l
, - - . . --,..,---,-n,,-w--.- , , , , - - , _ , - , , , . , - - . , . . , , , , - . , , - - , - - _ . , , , - - , , , _ , , , , - - - - , - . . - ,
CONTENTION [11] [b]
[b] NUREG 0654 REV. 1 (N lb) recommends that "each organization should make provisions to start an exercise between 6:00 p.m. and midnight and another between midnight and 6:00 a.m. once every 6 years." The plans of the. . . state fail to make this provision. NUREG 0654 REV. 1 (N lb, p. 71)
" exercise should be conducted under various weather conditions." The plans of the. . . state both fail to specify this. NUREG 0654 REV. 1 (N 1 b) states "some exercises should be unannounced." The state plan makes no mention of having some unannounced exercises. . .
RESPONSE
The State RERP provides that exercises may be conducted between 6 p.m. and midnight and between midnight and 6 a.m. It also provides for the scheduling of unannounced exercises and under various weather (simulated) conditions. (See para I.
A. d. , Appendix 14 " Exercises and Drills") .
I CONTENTION [11] [c] ,'
[c] The state plan (PEMA, REV. 6/80) states (p. 14-1) that " communication with federal emergency response organizations and states within the ingestion pathway shall be tested annually," whereas NUREG 0654, REV. 1 (N 2a) recommends this to be done quarterly.
RESPONSE
Paragraph II. A. b., Appendix 14, State RERP provides for quarterly testing of communications, between Federal and State emergency response organizations within the ingestion exposure EPZ. (See pg. 14-2.)
6 d
I CONTENTION [11] (d]
(d] NUREG 0654 REV. 1 (N 2a, p. 72) states that "communica-tions between the nuclear facility, state and local ,
j emergency operations centers, and field assessment teams shall be tested annually.". . .
[T]he state plan. . .[does not] mention the involve-ment of field assessment teams in exercises or drills.
RESPONSE
j ' Paragraph II. A. c., Appendix 14, State RERP i
includes field assessment teams involvement in annual communications 4 drills. (See pg. 14-2.)
4 i
l s
A 4
i l
l 6
1 i
i -
53 -
i
,,v+ -
, + - -- - -,ww-,- w e- - m cw-9=w^g- --p-..wme w w-% -,mg-y.,yy y - , ,-wwp---,y,-y-- p w-ow w - r-,m yne--er%ym yww w--y. w ,, yygn -y-w -g yp ,w,peve m e --e-.wy.ry--e-----ve-
CONTENTION [11] [el
[e] NUREG 0654 REV. 1 (N 2a, p. 72) states " communication drills shall also include the aspect of understanding the content of [ messages]. ". . .[T]he state's plan
.[ doer rot] mention including this aspect in drills.
RESPONSE
Paragraph II. A. l., Appendix 14, State RERP provides for communications drills that test the adequacy of communication links and " response agency understanding of emergency action levels and message content." (See pg. 14-2.)
i i,
I l
l L
1 1
l CONTENTION [12]
[12] Section O - Radiological Emergency Response Training
[a] 1. State Plan just gives general objectives in Appendix 10. In the [Luzerne] County plan, Annex M is listed " Training and Exercises" but there is no Annex M. (See p. 21.)
[b] 1.b Same as above for state and county plans.
[c] 4.a-j Same as above for state and county plans.
[d] 5. Same as above for state and county plans.
RESPONSE
Standard O. 1. NUREG 0654 recommends training for appropriate personnel. Standard O. 1. b. recommends specific individuals to receive training. Standard O. 4. (inclusive) cites by category personnel to be trained and recommends periodic retraining programs. Standard O. 5. recommends intial and annual retraining of personnel.
The State RERP specifies responsibilities for training and fully meets the recommendations outlined in NUREG 0654 and cited above. (See Appendix 10 " Training".)
The Luzerne County RERP discusses various training courses and estimates numbers of personnel to be trained each year. It fully meets the recommendations outlined in NUREG 0654 and cited above. (See Annex R " Training" . )
l l
l i
l I _ _ _
1 CONTENTION [131 (13] Section P - Responsibility for the planning effort:
j Development, Periodic Review and Distribution of Emergency Plans
[a] 1. [Luzerne] County plans same as in section 0 1
j RESPONSE:
i Standard P. 1. NUREG 0654 recommends training of individuals responsible for the planning effort.
The Luzerne County RERP includes provisions for its p'anning staff to receive FEMA training. (See para II. A.
Annex R.)
i 4
i i
f i
i n
i l 1
(
e ,- -. .,, . - - , . . _ . , .._.. -.,__,..- ,,, , , , _ - _ , , . , . . . - . _ . _ - _ . . . . . _ _ , . _ _ . . , _ _ . , ,m., , _ ,.., _., , , _ - _,, , _ . . , _ .
CONTENTION [13]
[b] 2. [Luzerne County plans do~not] mention t
RESPONSE
j Standard P. 2. NUREG 0654 recommends that the individual responsible for the planning effort be~ identified by title.
The Luzerne County RERP provides for the Director,
- LCCD, to be responsible for planning (see para V. A. pg. 5).
I I
)
e CONTENTION [13]
[c] 3. [Luzerne County plans do not] reation
RESPONSE
Standard P. 3. NUREG 0654 recommends an individual responsible for planning und coordine. tion of planning be designated.
The Director, LCCD, is responsible for the development, coordination and updating of the Luzerne County RERP. (See para V. A. pg. S.)
CONTENTION (13]
[d] 4. M 'e plan fails to mention that they will
" certify it to be current on an annual basis."
RESPONSE
Standard P. 4. NUREG 0654 recommends that the plan be reviewed and updated annually.
The State RERP provides for an annual review and updating as required. (See para II. , pg. 3.)
CONTENTION [13]
(e) 5. [N]o mention in state plan
RESPONSE
I Standard P. 5. NUREG 0654 recommends forwarding copies of the plan and changes thereto to appropriate individuals.
The distribution list in general categories is included in paragraph X (pg. 30). The State RERP also acknowledges that a more detailed listing is maintained by PEMA (also pg. 30). l Para X. D. (pg. 31) provides for dissemination of revised pages properly marked to all holders of the plan.
l l
b i
~
1 CONTENTION [13)
[f] 6. [N]o mention in state plan
RESPONSE
Standard P. 6. NUREG 0654 recommends a listing of supporting plans.
The State RERP lists requisite supporting plans in Section I " Authority and References" (see paragraphs 8,9,10,11,12 and 13, page 2.).
l f
1 1'
i CONTENTION [13] !
, [g] 7. [N]o mention in state plan
RESPONSE
Standard P. 7. NUREG 0654 recommends that each plan l contain procedures for implementing the plan. r r
! The State RERP includes an identification of procedures for implementation of the plan. (See Appendix 18 j " Implementing Procedures", page 18-1.) ,
I 1
I r
\
I l
I
- I I
i 1
l .
I r
i
{ A 4,
}
1 l
s.--____._._,._,.- _. . _ . _ . - , , _ _ _ . . _ _ _ _ _ _ _ _ . . _ . _ _ _ . , _ . . _ . _ - _ . _ _ _ _ . _ _ _ _ _ . _ _ .._..._. _
CONTENTION [13]
[h] 8. [N]o mention in sta*.e plan
RESPONSE
Standard P. 8. NUREG 0654 recommends each plan include a table of contents.
The State RERP includes a " Table of Content".
(See pg. i-iii. )
s CONTENTION [13]
[i] 9. No mention of this in. . . [ state or Luzerne County] plans.
RESPONSE
Standard P. 9. NUREG 0654 recommends that Licensee conduct an independent review of its emergency preparedness program annually. There is no basis for including this requirement in the State or Luzerne County plans.
k