ML20151M716

Notifies That Concerned Citizens of Lake,Geauga & Ashtabula Counties,Ohio Omitted from Svc List for Distribution of Fema,Epa & Other Documents Pertaining to 2.206 Petition Re Emergency Info Preparedness Handbook

ML20151M716
Person / Time
Site:	Perry
Issue date:	07/25/1988
From:	Bimber R, Kline C, Oconnell R CONCERNED CITIZENS OF LAKE, GEAUGA & ASHTABULA COUNTI
To:	Murley T Office of Nuclear Reactor Regulation
References
2.206, NUDOCS 8808050293
Download: ML20151M716 (5)

Text

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. July 25,1988 /)de n odLd Dr. Thomas Murley, Director RE: Cleveland Electric illuminating Company Of fice of Nuclear Reactor Regulation Perry Nuclear Power Plant, Units 1 & 2 U.S. Nuclear Regulatory Commission Docket Nos. 50-440 & 50-441 W;shington, D.C. 20555 2.206 Petition filed 9/22/87 and amended 10/8/87 and 4/8/87 by concerned Citirens of Lake, Geauga, and Ashtabula Counties, Ohio on the subject of the Erurgency information Preparedness Handbook

Dear Dr. Murley:

For some reason, NRC Region til in Glen Ellyn, Illinois has omitted the petitioners, Concerned Citizens of Lake, Geauga, and Ashtabula Counties, Ohio f rom the service list for distribution of FEMA, EPA, and other documents pertaining to the above-captioned 2.206 Petition, as clearly evidenced by W.D. Shafer's letter to CEI date stamped 5/16/88, e copy of which is enclosed. Petitioners, therefore, were not mailed this letter nor were we mailed the following documents:

1. FEHA memorandum for NRC's Frank J. Congel f rom Richard W. Krim date stamped 2/26/88 regarding the above-captioned 2.206 Petition (copy enclosed)

2. FEMA Response to Request for Assistance by the U.S. NRC to the 2.206 Petition frem the Concerned Citizens concerning the ElH for the PNPP, February 16,1988 (copy of first page only enclosed), a 15 page document with 2 attachments, the second of which is an EPA letter (date stamp is obscured) f rom Steve Rothblatt to Dan B"ient of FEMA (copy enclosed) .

3 FEMA memorandum for NRC's J. Philip Stohr f rom Richard Krimm date s'.amped 4/19/88 (copy enclosed) .

Petitbners obtained this information purely by chance through a citizen's contact j with the Pubile Utilities Comission of Ohio. Otherwise, petitioners would not even have been aware of the existence of these documents.

In light of the reconrnendations made by FEMA and the EPA in the enclosed, above-mentioned documents, Concerned Citizens of 1.ake, Geauga, and Ashtabula Counties, Ohio wish to again amend our 2.206 Petition of 9/22/87 per this letter to incorporate the FEMA and EPA recomendations contained in the above-mentioned information which is not enclosed herein in its entirety. memorandum Further, the petitioners recently discovered that a 6/22/88 FEMAA8807050044 for NRC 's Frank J. Congel f rom Richard W. Krirmi exists. Again, petitioners never received this memo either.

The petitioners look forward to rec'eiving a copy of FEHA memorandum 8807050044 cnd all future documents pertinent to our 2.206 Petition.

Thank you so much for your time and consideration.

Sincerely yours, MLL.LU

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f TheresaBurking Connie Kline Russ Bimber Ron O 'Connel l 38531 Dodds Landing Dr. 10471 Prouty Rd. 315 Garfield St. 11701 Colburn Rd.

Willoughby Hills, OH 44094 Painesville, OH 44077 Geneva, OH 44041 Chardon, OH 44024 (Lake County) (Lake County) (Ashtabuia Cnty.) (Geauga County) 88080DOD93 0D0725 PDR H

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U.S.N.R.C' NUCLEAR RE A'CIOR REGULATION W JL:28! All:56 4 4

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(o.... MAY 16 '.988.- .

Docket No. 50'-440 The Clevela'nd-Electric Illuminating Company ATIN: Mr. Alvin Kaplan Vice President Nuclear Group 10 Center Road Perry, OH 44081 Gentlemen:

Enclosed for yeur information and action are: (1) FEPA's Februa*y 26, 1988 review of the petition filed under 10 CFR 2.206 by the Concerned Citizens of Ashtsbula County, Concerned Citizens of Geauga County and Concerned Citizens of Lake County, Ohio, concerning the Perry Nuclear Power Plant; and (2) the April 19, 1988 clarification of two issues in FEMA's review.

The transmittal of the February 26, 1988 review was delayed pending issuance of the clarification from FEW In the interim, the petition was amended on April 8, 1988, to limit concerns

( only to alleged deficiencies in the revised public information contained in the 1988 calendar. The petitioners have identified five issues.

We encourage you to continue to work closely with State and local agencies as you have done in the past to resolve these issues as appropriate.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of thvs letter and the attachment will be placed in the NRC's Public Document Room.

Sincerely,,

D Q k V' W. D. Shaf r, Chief Emergency Preparedness and Radiological Protection Branch

Enclosures:

As stated See Attached Distribution

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w~ ra e'on,a dhbObb-i

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The Cleveland Electric Illuminating 2 Company MAY 161988 i

l Distribution.

cc w/ enclosures:

F. R. Stead, Director, Perry -

Plant Technical Department M. D. Lyster, General Manager, Perry Plant Operations Department Ms. E. M. Buzzelli, Manager, { g , g_c M[

Licensing and Compliance Section 1

/Wfu 1 4 ,.

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DCD/DCB (RIDS) $ NJ M L, Licensing Fee Management Branch <

Resident Inspector, RIII .

Harold W. Kohn, Ohio EPA -

Terry J. Lodge, Esq.

James W. Harris, State cf Ohio 1 Robert M. Qui.111n, Ohio Department of Health State of Ohio, Public utilities Commission Murray R. Edelman I

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.[ LTNITED STATES ENY1RONMENTA1 PROTECTION AGENCY REGION 5 De SOUTH DEARBORN ST.

C #[ CHICACO lltJNO15 6HN sanno tw artwmom e, D $ %) S

Mr. 04n teneat Federal [sergency Managerent Agency Natural and Technological Hazards Division 175 West Jackson. 4th Meer Chicago. Illinois 60604

Dear Mr. Besent:

In response to your re4 West of hovember 23. 1987, the Radiation Program staff of the United States Environtrental Protection Agency (U5[7A) Region y Of fice offer the following coraents relating to three stater:ents of radiological significance from the Request for Action under 10 CFR 2.206 for the Perry hwclear Powtr plant:

On pages 1415 of the tegwest the assertion is made that page 15 of Perry's boeuet entitled ' Emergency Preparedness Inforration" contains several s misleading statements elated to the health ef fects of iortting radiation and should be rewritten. We larself cgneur. with these assertions. On pajeJgfithe b20tltListejles of nonioniting radiation ~are casually- -

assectated with tonizing redisOWin a way~in which a layTeader could by'1ed to believe that they have identical health significance. Also, the

[' fiction 15 put forward that low exposures to lonjging radiation (background levels) are ' normal', while high esposures 'may be harmful to human health'. This could easily be misinterpreted as stating that low exposures are safe. This misinterpretation may be carried further by the statement:

'But to be safe, the law requires that people are not esposed to too much radiation'. when the only nwnerical example of too much radiation put forth is 25.000 all11res (ares). We feel that this section of the booklet doel.need to be rewritten so as to' convey'to' the lay pubile a more accurate _

n pitture thershold_ofhealth current redist]ca_protectico_ph1]clophy effects (i.e.11near,Je_na._

aeds), principit of_ keeping aspossrs.as w.as reasonably achievabit, known health effssts.cf_10rl1 3102 f a816tf 0ntf L)

However, we feel that the lack of rigor 1R the current version of the booklet will not feminently compromise the tepler.entation of the emergency pl a n. As such, we believe that the matessary codificattens of this booklet could take place within some reasonable time frase without consequence.

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On page 14 of the reswest, exception is taken to the statement on page 15 of the Imergency Preparedress booklet: 'By law a nuclear power plant say not espose the public to more than five ellltrees per year. The Perry plant will give you a dose of cre or two ellitress per year.' We telte.e that the license show1d farr.fsh the reference for this statement, as our own research into the legal limit for n; station bas _AQLJialded.a--

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c{ nits tent' ans weri The D$(PA eI61rorrental standard for nuclear fWel cycle facilities' is 25 rrer/yr to the general public (40 CFR 11010), but this is a limit from all nwelear fwel cycle operations (i.e., frem both reactors in the case of the Perry station). The kwelear Regulatory Commission (kRC) imposes an objective on the dest;n of a nuclear power plant that it be tuilt to limit popw14 tion esposwees to between five and ten silliress par year due to gaseous releases, however this desion ebfective is astigmed specifically to each olent dwrtrg its sitting and Ilcensing. (10 CFR $0. A;;endfs ! Paragraphs 81 and 82) y% W

PKaisy, on page 15 of the rteest the estertion is rate that 'Ct1 plans to recomunend evacuation only to prevent projected public esposures which will exceed j plant workers." ... within six hours, the. annual limit of 5000 elllittes for nuclear .

' (U5tPA Regfon V staff would like to obtain the reference for this statement.) *And aey exposure already received during the emergency, without limit is ignored. This Is allowed by (PA 520/1 75 001, which has fneverbeenjus,tifled.

s pubitshed later." It was supposed to be justified by Appendfz C. to be It 18 v3ffdtunately true that Appendix C of EPA 520/175 001. ' Manual of Protective Action Guides and Protective Actier.s for Nuclear Incidents'.

is stilleatst. unpub}l_shed h final fors, although a draf t form of Appendla C does The criticism of this fact is justified, and will be

( cosseunicated to tWapp'ropriate USEPA sta f f. However, the bult of the criticism in this paragraph appears to be directed at an fsproper and inflexible interpretation of the Protective Action Guide (PAG) presented in EPA 520/175 001 avoiding unnecessary esposure from a passing pluse.which Moreover, applies to the genera the criticism is directed solely at the utility, when in fact. State and local response agencies carry the primary responsibilit/ for using the PAC to reccarand and implement protective measures such as sheltering and evacuation. A det:11ed understanding of the PA5 say help to clear up this issue.

The PAC for the general population / plume esposure from which the Statt and local agencies draw guidance applies to actual or projected exposures to the general population comencing at the bentenine of the accident. It does not cover population esposures occuring before the beginning of the accident which are limited to between 5 25 mi11tres per year by environ.

eental standards and design objectives.

The PAG is expressed As a range 3

cf real or projected esposures over which the need for protective actfees shculd be considered. The P A3 is empressed as a range, rather than t

( siegle value. in order to give the States _flesibility in their accident re s pons e. The purpose of the PA6 it to guide decisions about protective actions 50 that they may be ispleeented before the exposures actually occur, i.e.. while the esposures are still only projected to occur. This is cor81 stent with the philosophy of keeping esposures as los as reasonably achievable, and at the same tiet. allows local constraints such as esse and economic irpact of evacuation to be taken into account by response agencies.

The range of projected population espesures over which this PAG applies is 1000 to 5000 millirem. The PA3 recosviends that evacuation be considered wren projections reach 1000 cres (although evacuation could be recorviended at lowe* projections de;eading on local and plant conditions) and that evacuation ce recemended when projections reach 5000 arem er higher.

It is thus, untrue that IPA 520/1 75 001 allows unlietted population exposure ar4. if it is b:rne la eind that the State respor.se agency has the prirary res r < fity for deciding to recorrend protective actions, then it follows tPat sne criticism of the utility in this ratter is largely sisdirected.

Please contact us if we can be of further assistance in this matter.

Sincerely yours.

( W, M #

I eve Rothblatt. Chief Air and Radiation Branch (5 Ae.26)

- Enclosere 1

~.

i Federal Emergency Management Agency Washington, D C. 20472 FEB 2 6 1989 PEPORANDUM FOR: Frank J. Congel Director Division of Radiation Protection and Emergency Preparedness Of fice of Nuclear Reactor Regulation U. 5. Nwclear Regulatory Cocynission FROM: a Assistant Associate Director Of fice of hatural and Technological H42ards Programs

$UBJECT: 10 CFR 2.206 Petition, Public Inforcation Brochure, Perry huclear Power Plant This is in response to your November 3, 1987, memorandum requesting assis-tance in reviewing a petition filed uncer 10 CFR 2.206 by the Concerned Citizens of Lake County, Concerned Citizens of Geauga County, and Concerned

( Citizens of Ashtabula County, Ohio. The petition primarily contained a request that the Director of Nuclear Reactor Regulation order the Cleveland Electric illuminating Company (CEI) to correct certain deficiencies and misinformation contained in the undated Emergency Preparedness Information Handbook (E!H), and to redistribute the Corrected handbook to the population within the Plume Exposure Pathway Emergency Planning Zone for the Perry Nuclear Power Plant.

The Federal Emergency Management Agency (FEFA) Headquarters and Region V reviewed the petition and associated eaterials. Owr review is attached to this memorandum. The new Perry E!H entitled,1988 Calendar. Emergency Preparedness Information, dated December 1987, has also been reviewed.

The 1988 ElH calendar was forwarded to FEFA on December 14, 1987, and has replaced the E!H addressed in the petition. The attached review reaches conclusions, summarized below, on the issues raised by the petition:

The 1988 E!H calendar does respond to key issues raised in the petition; therefore, FEMA does not reccrnmend that the current ElH be immediately revised and redistributed. However, FEMA does recomend that certain changes be considered in the next annual revision of the ElH; The review does contain a recomendation that the Nuclear Regulatory Com.

sission order the CEI to work with the State and local authorities to address I

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within 120 days the planning issues involving the role of ' receiving schools' in evalwatton procedures and the lack of persanent installation of emergency y information signs in Lake and Ashtabula Counties; and, 2

(

• The CEl, State, and local authorities should be con ended for encoura ing the reading of the ElH to blind persons; however, in the next annwal lH update these authorities may want to consider other means of providing inferration to the viswally handicapped such as large print, braille raterials, audio cassette tapes, and other awdf o eedia. --'

The FEMA review addresses only of fsite issues in the 2.206 petition and does not address any issues FEMA believes should be reviewed by the Nuclear Regulatory Comis s ion. In adattion, the section on radiation and its health ef fects N in the petition has been reviewed and comr4nted on by the Environmental ,,

Protection Agency, Region V. ,

If you have any questions concerning this review please do not hesitate to Contact e4 at 646 2671.

ozwn3( w y ;\

At t a chr.e nt F~vun

W W" W i.

FEDERAL EMERGENCY MANAGEMENT AGEN:Y Response to a Request for Assistance by the U. 5. Nuclear Regulatory Commission to a Petition filed under 10 CFR 2.206 from the Concerned Citizens of Ashtabula, Geauga, and Lake Counties, Ohio concerning the Emergency Preparedness Information Handbook for the Perry haclear Power Plant Februa ry 16, 1988

Introduction:

r This review addresses issues raised in the 10 CFR 2.206 petition from the

\ Concerned Citizens of Ashtabula, Geauga, and Lake Counties in Onio, concern-ing the Perry huclear Power Plant's Emergency Preparedness Infonnation Hand.

book. The petition requests that the Nuclear Regulatory Comission (NRC),

Director of Nuclear Reactor Regulation, order the Cleveland Electric illumi-nating Company (CEl) to correct certain detkiencies and misinforr.ation contained in it's undated Emergency Preparedness Informi. tion Handbook (here.

af ter referred to as E!H) and to redistribute a corrected handbook to the population living within the Plume Exposure Pathway feergency Planning Zone (EP2). Coments re'lected below are addressed in tSe order that the issues are raised in the 2.206 petition. Ples'e . note that this review is based on information contained in the 1988 E!H calendar (distributed in Decemoer 1987) while the petition addresses the earlist green, undated ElH.

E!H Cover:

A two page map of the Perry ten mile EPZ is included in the 1988 ElH calendar.

This map is siellar to the foldout map in the earlier "white' and ' green" versions of the Perry ElH. The ten sile EPZ map in the 1988 E!H is also entitled ' Pick-Up Points Referral Points and Care Centers'. It shows evacuation routes, county boundaries, some geographic features, locations of some towns, etc., but it is not so detailed that it would confuse the reader. Printing the ten mile EP2 map on the cover would be impractical and redundant.

The 1988 Perry ElH Calendar does have a date printed on page one. Tnis corrects the concern raised in the 2.206 petition.

, ifNITED STATES ENYlAONMENTAL FASTICTION AGEhCY I 5 REGION $

De 30VTH DEARBORN $7.

C [ Chic AC O,ILUN015 54604 aanrto me amamc , w

$ I LO T Mr. Den meentl*

Federal toergency Managerent Agency Natural and technological M42 arcs Division 175 West Jackson,4th Moor Chicago. Illinois 60604

Dear Mr. Besent:

in responle to your rereest of November 23, 1987, the Radiation Program staff of the United States Environrental Protection Agency (U$tPA) Region y Of fice of fer the following cernents relattrig to three stater _ents of radiciogical significance free ths Request for Action Under 10 CFR 2.206 for the Perry Nweleir Ponte Plant:

On pages 1415 of the teqwest the asserticr. is made that page 15 of Perry's booklet entitled ' Emergency preparedness Inforratten* contates several misleadf eg statements related to the health effects of toniting ratistion, and~Should be re_uritten. . eW lattely eg.ngwr with these assertions.. On pa9tiUJef the Acatlti elaspas of nontentring radiation ~are casually.-

associated with tonising radhdon in a way in~shich a 14fhader could be led'to believe that they have identical health significance. Also, the

['. Action is put forward that lov esposures to 1ontging radiation (backg.'ovnd levels) are ' normal'. while high exposuras 'may be harmful to hanan health'. This toyl.d easily be misinterpreted as stating that low esposwees are safe. This misinterpretation may be carried further by the statement:

'Ist to be safe, the law reqvfres that people are not esposed to too much radiation' when the only numerical example of too such radiation put forth is 25.000 milltres (area). We feel that this section of the book 1st.

~

deel.need te be rewrtitan pithee of. cderent so as to'convef to the lay fl414119fLAtatattlefL)h1]oggphf_ (publicn a port accurate i.e.11_nAear thrilhohl health.sffects andel. Stiatipit_af_kaap1Ag tiposure.44. lou (3 reasonably schf evablir kngwn hegith gf_f4C11_of_10lL133nt rldI4tI9ha.tita)

However, we feel that the lack of rigor in the current verston of the booklet will not f aminently compromise the toplementation of the emergency plan. As such, we believe that the neussary modtf tcations of this bootiet could take place within some reasonable'tise frase without consequence.

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s On page la of the reewest. exception is taken to the statement en page 15 of the Emergency Preparedeels booklet: 'By law, a nuclear power plant may not espose the pubite to more than five st11 trees per year. The Ptery plant sill give you a dose of one or two sillf ress por year.' We telieve

( that the license should ferr.f sh the reference for this statament. as our own research into the legal limit 3r_osaratiefthat_acLJitlteta__

cini'fifeW~4sswerJ ~ The U1tPA'eElronmental standard for nuclear fuel c,vele

~

f ac111tles is 25 arer/pr to the general swolic (40 CFR 1g0.10) but this 1s a Itatt from all nuclear fuel cycle operations (i.e., from both reactors in the case of the Perry station). The kvclear Aeguistory Commission (htc) foposes an objective on the design of a nuclear power plant that it be twtit to Itatt population esposures to between five end ten allitress per year due to gaseous releases, however, this design objective is assigned specifically tc each plant durirg its liiting and licensing. (10 CFR 50. A;pendia 1. Paragraphs Il and 82) f &oj 1%

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- 2 eq.crnsmruturwA Us rate tha t '((I plans to recosynend evacuation only to prevent projected p4blic esposures which utl1

( excted ... within six howes. the . annual 1(att i plant workers.'

% for this uuteen.)(U$[PA Regfon V staff would like to obtain the reftetut

• And any exposure already received during the emergency,

[ "never been junified.ithout This liiitisisallowed ignored. by (PA $20/1-75 001. watch has s published later." It was supposed to be justified by Appendix C. to be It is vf3ttanately trus that Appendix 0 of (PA (20/175 001 ' Manual of Protective Action Guides and Protective Actions for Nwelear Incidents',

is st11Luntwbitshed 14 final form. although a draf t form of Anendia t does entst. The crittette of tAis fact is justif tec. and will be

( -

conspunicued to'the appropriate U$[PA staff. However, the bult of the criticism in this paragraph appears to te directed at an taproper ano infleaible interpretation of the Protective Action Guide (PAG). presented in CPA 510/17b.001 which applies to the general pwb1fc for the purpose of avoiding unnecessary esposure from a passing p1 wee. Moreover, the criticism is directed solely at the utility, when in fact. State and local response ager.ctes carry the primary responsibility for vsing the PAC to reccar-end and laplement protective measures such as sheltering and evacuation. A det411td understanding of the PAG say help to clear up this issue.

The PAG for the general population /p1 wee exposure from which the State and local agencies draw guidance applies to actual or projected espesures to the general population enumengthg at the benfanine of the accident. It does not cover popWlatloa esposures occurf ag before the beginning of the accident which are llatted to between 5 25 at11tres per year by environ.

mental standards and design objectives. The PAG is espressed as a rang 3

cf real or projected esposures over which the need for protective actices sh:uld be considered. The PAG is empressed as a range rather than a stegle va C response.lve in order to give the States flexibility in their accident,The purpose actions so that they may be implemented before the exposures actually occur, t.e., while the esposures are still only projected to occur. This is cor.listent with the philosophy of keeping esposures as icw as reasonably achievable, and at the same time. allows local constraints such as ease 4md economic trpact of evacuation to be taken into account by response '

agencies, The range of projected population esposures over which this PAG applies is 1000 to 5000 millires. The PAG recommends.that evacuation be considered uren projections rent 1000 mrea (although evacuation could be reconviended at lower projections deseading on local thd plant conditions) and that evacuation ce recewnded when projections reach 5000 seem or higher, it is thus vntr6e that IPA $20/175 001 allows un11 sited population esposure ar,4. If it is borne in eind that the State respor.se agency has the prfrary responsibility for deciding to recoerend protective act10nc then it follows that the criticism of the wt111ty in this e.atter is largely sisdirected.

Please contact us if we can be of farther assistance in this matter.

Sincerely > curs.

i

( Noveltulth5Tatf.Mief 1

Air and Radiation Branch (5 Ah!6)

Enclosure !

9 Fcdercl Emergency Management Agency k #

Washington. D C. 20472 7

FEB 26 mg HEPORANDur FOR: Frant J. Congel Otrector Otvision of Radiation Protection and Eciergency Preparedness Of fice of Nuclear Reactor Regulation U. 5. Nuclear Regulatory Cocinission FROP: a Assistant Associate Director Of fice of hatural and Technological Hazards Programs

SUBJECT:

10 CFR 2.206 Petition, Public Inforeation Brochure, Perry huelear Power Plant This is in response to your November 3,1987, memorandum requesting assis.

tance in reviewing a petition filed under 10 CFR 2.206 by the Concerned Cittrens of Lake County, Concerned Citizens of Geauga County, and Concerned

( Citttens of Ashtabula County, Ohio. The petition primarily contained a request that the Director of Nuclear Reactor Regulation order the Cleveland Electric illuminating Company (CE!) to correct certain deff etencies and misinformation contained in the undated Emergency Preparedness Information Handboot (ElH), and to redistribute the Corrected handboot to the population within the Plume Exposure Pathway Emergency Planning Zone for the Perry Nuclear Power Plant.

The Federal Emergency Management Agency (FEPA) Headquarters and Region V reviewed the petition and associated materials. Our review is attached to this memorandum. The new Perry EIN entitled,1983 Calendar, Energency Preparedness Information, dated December 1987, has also been reviewed.

The 1988 ElH calendar was forwarded to FEMA on December 14, 1987, and has replaced the ElH addressed in the petition. The attached review reaches conclusions, susunarized below, on the issues raised by the petition:

The 1968 ElH calendar does respond to key issues raised in the petition; therefore, FEMA does not recommend that the current E!H be immediately revised and redistributed. However FETA does recommend that certain changes be considered in the next anmal revision of the ElH; The review does contain a recommendation that the Nuclear Regulato'ry Com-alssion order the CE! to work with the State and local authorities to address 1

\

within 120 days the planning issues involving the role of ' receiving schools

• 7 in evaluation procedures and the lack of permanent installation of emergency g information signs in Lake and Ashtabula Counties; and.

2

(

• The CEl, State, and local authorities should be comended for encoura ing the reading of the ElH to blind persons; however, in the next annual lH update these authorities may want to consider other cleans of providing information to the visually handicapped such as large print, braille \

materials, audio cassette tapes, and other audio riedia. ->

The FEMA review addresses only offsite issues in the 2.206 petition and does not address any issues FEMA believes should be reviewed by the Nuclear Regulatory Consni s si on. In addition, the section on radiation and its health ef fects N in the petition Pas been reviewed and ccamented on by the Environmental Protection Agency, Region V. ,

If you have any questions concerning this review please do not hesitatt to Contact me at 646-2871.

Attachment FCKA Revien '

b. . L- # 41 J

s u'l0ll . (% . IJ .(.'D h /\

• FEDEkAL EMERGENCY MANAGEMENT AGENCY Response to a Request for Assistance by the U. $. Nuclear Regulatory Commission to a Petttion flied unde; 10 CFR 2.206 from the Concerned Citizens of Ashtabula,'Geauga, and Late Counties. Chio concerning the Emergency Preparedness information Handbo0k for the Perry Nactear Power Plant Febevery 16, 1988 Introdwetion:

r This review addresses issues raised in the 10 CFR 2.206 petition fera the 1

Concerned Citizens of fat:ble, Geauga, ar.d Lake Counties in Ohio, concern.

ing the Perry Nuclear Power Plant's Emergency Preparedness Information Hand.

book. The petition requests that the Nuclear Regulatory Cornission (NRC).

Director of Nuclear Reactor Regulation, order the Cleveland Electric 111umi.

nating Company (CE!) to correct certain deficiencies and misinformation contair.ed in it's undated Emergency Preparedness Information Handboot (here.

after referred to as E!H) and to redistribute a corrected handbook to the popJiation living within the Plume Exposure Patre ay Emergency Pla^ning Zone (EPZ). Coernents reflected below are addressed in the order that the issues are raised in the 2.206 petition. Please note that this review is based on information contained in the 1988 E!H calendar (distributed in December 1987) while the petition addresses the earlier green, undatM ElH.

E!H Cover:

A two page map of the Perry ten mile EPZ is included in the 1988 EIN calendar.

This map is similar to the foldout map in the earlier ' white" and ' green" versions of the Perry ElH. The ten alle EPZ map in the 1988 ElH is also entitled 'Pict.Up Points. Referral Points and Care Centers'. It Shows evacuation routes, county boundaries, some geographic features, locations of some towns, etc., but it is not 50 detailed that it would confuse the re ade r. Printing the ten mile EPZ map on the cover would be impractical and redundant.

The 1988 Perry E!H Calendar does have a date printed on page one. This corrects the concern raised in the 2.206 petition. h i

l t

6-Enclosure 2 J84g T

Fede'ral Emergency Management Agency Washington, D.C. 20472 C APR I 91988 te ORA' M 1 POR: J. Philip Stohr Acting Director Division of Radiation Protection and Ehergency Preparedness Office of Nuclear Reactor Pegulation U.S. Pluclear Regulatory Cmnission W

"E: c and . Krim Assistant Associate Director Office of Natural and "'echnological 52.acards Progra .s SUIUFIT: Clarification of Two Issues in the Federal Fhergency

%nage,ent Agency's (FE'M) Response to the Perry 'hclear Power Plant 2.206 Petition

'Ihe purpose of this me7orante is to clarify Fr%'s position regarding two issues addressed in our response to the Perry nuclear Pcwer Plant 2.?06 petition on the D,ergency Informtion %ndbook. '!ha first issue involves the receiving schools and evacuation procedures involving school children.

f'x 'Ihe second issue involves the placenent of instructional signs in lake and Ashtabula Counties.

It is FE%'s position that the existire school evacuation plannir6 proce11res involving the receivir.g schools should be reviewed to consider alternative planning approaches, as outlined in our Febntary 26, 1988, response to the thaelear Regidatory Ucrnission (imC). In our view these approaches should be considered for incorporation in the next revision of the offsite plans for Perry. In our February 26,1988, review we were trying to enphasize that we believe this issue is 17ertant enough to warrant having all affected parties,

'S ,\

the State of Chio, the local jurisdictions, and the Cleveland Electric Illini-neting Cmpany, revisit this issue within the next four months with a goal of either arriving at a schedule for implementing plan changes or adopting a position on the issue.

Reganiing the placement of energency infomation signs, FFMA does not concur with the current approach of storing the signs in take and Ashtabula Counties '

because of the potential for vandalis1. 'Ihe difficulty of installing ther:

at the time of an accident overrides the storage approach. OJr position remains that the signs should be installed within the next four months or a schedule should be provided for their installation.

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