ML20235K857
| ML20235K857 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/11/1987 |
| From: | Flynn H Federal Emergency Management Agency |
| To: | |
| Shared Package | |
| ML20235K809 | List: |
| References | |
| OL, NUDOCS 8710050256 | |
| Download: ML20235K857 (150) | |
Text
{{#Wiki_filter:__ __ ( l. UA UNITED STATES T AMERICA
<*" NUCLEAR REGULAM COMMISSICN
*- BTORE 'IHE A'IOMIC SAFLTl AND LICENSING BOARD
)
In the Matter of )
)
Public Service Co. of New Hanpshire, ) Ibcket No. 50-443-OL et al. ) 50-444-OL
) Offsite Emergency (Seabrook Station, Units 1 & 2) ) Planning Issues
)
FEMA PP2-FILED TESTIM The Federal Emergency Management Agency (FEMA) hereby serves on the parties to this proceeding its prefiled testimony on contentions on the New Hanpshire Radiological Emergency Response Plan. FEMA notes, for the record, that its review of issues addressed therein is ongoing. A 1 . .,w Q' . m / l1.
/'.
' -d ,
- 11. Joseph Flynn Assistant' Genera). Counsel Federal Emergency Management Agency Washington, D.C.
September 11, 1987 LO B710050256 87093043 {DR ADOCK O j _______._m_ _ _ _ _ _ -
UNITED STATES T AMERICA' NUCLEAR REGULA'IDW COMMISSICN
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BEFORE 'IHE A'IC4IC SAFEIY AND LICENSING BOARD
. )
In the Matter of )
)
. Public Service Co. of New Hampshiro, ) Docket No. 50-443-OL '
et al. ) 50-444- OL ;
)
- _Offsite Emergency (Seabrook Station, Units 1 & 2) ) Planning Issues
)
DIRECT TESTIf0NY T EDMD A. 'IHOMAS, EDWARD A. TANZMAN, AND BPUCE J. SWIREN CN 'IHE NEW HAMPSHIRE RADIOLOGICAL EMERGENCY RESPONSE PLAN PRESENTED CN BEHAIF T 'IHE FEDERAL EMERGENCY MANAGEMENT AGENCY Tha witnesses whczn the Federal Emergency Management Agency (FEMA) is sponsoring on the admitted contentions having to do with the New Hampshire Radiological Emergency Response Plan (NHRERP) in the Event of an Accident at Seabrook Station are: Edward A. Thcznas, Chief Natural and Technological Hazards Division Federal Emergency Management Agency Region I Boston, Massachusetts Edward A. Tanzman Energy and Envitramental Programs Attorney Energy and Environmental Systems Division Argonne National Laboratory Argonne, Illinois and Bruce J. Swiren Emergency Manngement Specialist Natursl and Technological Hazards Division Federal Emergency Management Agency Region I Boston, Massachusetts m
Our Statements of Professional Qualifications are attached to this Direct Testinony and are incorporated herein by reference. In general, the purpose of our testimony is to address the admitted contentions and supporting bases. As explained below, our testimony is limited to certain contentions and bases. As noted in the Statement of Position, the Nuclear Regulatory Commission (NRC) is sponsoring the testinony of Dr. Thmas Urbanik on certain contentions having to do with the validity of Evacuation Time Estimates, and so FEMA is not sponsoring testinony on those contentions, namely: Revised Hampton Contention III to Revision 2 Revised Hampton Contention VI to Revision 2, Basis A (Rev.1) SAPL Contention 18 SAPL Revised Contention 31 SAPL Contention 34 SAPL Contention 37 FEMA considers its statement about the transient beach population largely to involve matters of policy. Edward A. Thmas is the FEMA official in Region I who is responsible for explaining, applyirg, and carrying out FEMA's policies as they apply to the Radiological Emergency Preparedness Program. For this reason, Mr. Thomas is the single witness as to those contentions having to do with the lack of shelter for the transient beach population, namely: Revised Hanpton Contention VIII to Revision 2 SAPL Contention 16 NECNP Contention RERP-8 Durirg the period of time when Bruce Swiren was employed by HMM Associates, he worked on obtaining revised or renewed Letters of Agreement i O
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^ O frm hospitals, ambulance companies, towing empanies, and bus companies. In l
order to' avoid even the possibility of the appearance o'i a conflict of interests, Mr. Swiren has removed himself as a witness on contentions and bases having to do with these letters of agreement and the determination of the number of Teamsters to be made available by their employers in the event of an emergency. For this reason, Edward ' A. Thomas 'and Edward A. Tanzman' will testify on those contentions and bases, namely: Revised Hanpton Contention IV South Hampton Contention 3; Bases 1, A, B, C, E, and Further Bases A.l. , A.2. , and B Town of Kensington Contention 6 NECNP Contention NHLP-2, Basis D NBCNP Contention NHLP-6, Bases d and e and HP-1-e SAPL Contention 15 SAPL Contention 25 All three of us will address the remaining admitted contentions and bases. The attached document entitled " Current FEMA Position on Admitted Con-tentions on New Hanpshire Plans for Seabrook" (hereinafter referred to as the " Statement of Position"), dated June 4, 1987, has previously been made a part of the record of this case. That Statement of Position was attached as Appendix A to the Response of the Federal Emergency 1 Management Agency to Massachusetts Attorney General James M. Shannon's Off-Site Emergency Preparedness Interrogatories and Request for Production ; of Documents to FEMA (Set No. 2) and is herein identified as Exhibit A. The language of the contentions and their bases is set forth in that Statement of Position and so is not repeated herein. Exhibit B to this testimony, entitled " Current FFMA Position on South Hanpton Contention 8 and NECNP Contention NHLP-4", and dated June 26, 1987, is a supplement to FEMA's Statement of Position and is also a part of i the record of this case. j l i W .i
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1 Exhibit C is a copy of a letter dated August 7,1987 from H. Joseph Flynn to Thomas G. Dignan, Jr. It reflects FEMA's position on the issues discussed
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therein. We individually incorporate by reference those portions of Exhibit A, B, and C which are pertinent to our respective testinony.
'Ihe positions which FEMA has taken on the NHRERP, the exercise of the l NHRERP, and the contentions which this Atmic Safety and Licensing Board has admitted were arrived at through e collegial process of review by FEMA's Regional Office in Boston, consultation with FEMA's Regional Assistance Ccenmittee (RAC) and Argonne National Laboratory, and review by FEMA's l- State and Local Programs and Support Directorate in Washington, D.C.
l The RAC is an interagency committee constituted in each of the 10 standard Federal regions pursuant to 44 C.F.R. @351. The caromittee is cmposed ( of representatives of FEMA, the NRC, the Environmental Protection Agency, l the Department of Energy, the Departnent of Health and Human Services, the Department of Transportation, the Department of Agriculture, the Department of Cornmerce and the Department of Interior. FEMA and the RAC have provided coments on New Hampshire draft planning for Seabrook dating back to submissions in 1982. However, the current plan, which is under litigation, dates back to 1985. In December,1985, the State of I New Hanpshire submitted the NHRERP (Revision 0) to FEMA. New Hampshire submitted I extensive changes to the NHRERP (Revision 0, Tupplement 1) in February,1986, ! which included:
- 1. Volume 5 NHRERP, " Letters of Agreement in Support of the NHRERP";
- 2. Volume 7 NHRERP, "Seabrook Station Alert and Notification System Design Report";
O 3. Evacuation Time Estimate (ETE) Study materials (Progress Reports Nos.1-6) frcan KLD Associates; (v)
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'v' 4. Revised procedures for the New Hampshire Department of Resources anLEconcmic Developent;
- 5. Compensatory Plan outlining the means used by the State to prcLect citizens in v. owns within the Seactook EPZ when municipal govenments cannot or will not carry out tasks assigned by the local plan, and;
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- 6. Draft publ.1e inforination material. >
The February,1986, revisions were served on the parties on March 11, 1986. The State of New Hampshire filed additional plan changes in April,1986, (Revision 0, Suppidment 2 of the NHRERP) consisting of the following:
- 1. KLD Progess Report No. 7; ,
- 2. A revision to the Department of Public H alth and Safety (DPHS)
Procedures, including replacement and new appendices to the DPHS Procedures;
- 3. Rockingham County Canplex procedures, including those for the Rockingham County Nursing Hom, Rockingham County Jail Facility
.m.
and Rockinghan County Dispatch Center; and
- 4. Procedures for the decontamination of personnel at the Manchester Decontamination Center, along with Appendix F to those procedures.-
A full-scale exercise of the NHRERP was conducted on February 26, 1936. During the first several months of 1986, FEMA and the RAC wre involved in extensive reviews of the December NHRERP (Revision 0), th February revisions (Supplements 1 and 2 to Revision 0), and the February exercise. In April, 1986, FEMA sent the following documents to the State of New Hampshite:
- 1. FD4A's report of the deficiencies observed during the Febru-ary 26, 1986,. exercise of the state and local plans to protect the public in the event of a radiological emergency at Seabrook;
- 2. Final Draf t Reret : 'f the Etcrcise of the energency plans for Seabrook held. Feb.uary 26, 1586;
- 3. Final tuview k' ti e RAC of the state and local plans subnitted by New Haneshire in December,1985; and
- 4. Draft RAL' Review of the state and local plans submitted by New Hampshire in February,1986.
(3\ 7 Tnese documents have been served on the parties to this proceeding. Luf x
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j l (,) On June 3, 1986, the State filed another revision of the NHRERP (Re-vision 1) responding to the cmnents of the PAC concerning the plan and
. the exercise of the plan. The LTE Study prepared by KLD Associates, which had recently been released in a final draft, was incorporated into the NHRERP at that time.
On June 23 and 24,1986, the RAC met with representatives of the State of New Hampshire and the Applicant and explained in further detail the concerns identified in the documents described above. On September 8, 1986, the State of New Hampshire submitted another revision of the NHRERP (Revision 2, dated August, 1986) addressing the concerns identified by the RAC. FEMA submitted the FEMA /RAC Review of Revision 2 of the state and local plans to the State of New Hampshire on December 12, 1986. This document is the basis for nest of the positions taken by FEMA in this licensing proceeding and has also been served b V on all the parties. On April 15 and July 2,1987, the NRC filed FEMA's positions on the parties' various Motions for Summary Disposition of Contentions. On June 4,1987, FEMA filed its Statement of Position as part of a response to Interrogatories frtn the parties. This reflects FEMA's current position, even though the State of New Hampshire submitted a Summary of Personnel Resource Assessment for the New Hampshire Radiological Emertjency Response Plan in late August,1987, an$ additional information in early September. The review period for material which a state submits to FEMA as part of a radiological emergency response plan is normally at least 60 days. These materials are not reflected in this testinony principally because they were not received early enough to have been reviewed by FEMA and the RAC and because the State of New Hampshire has advised FEMA that the material sutmitted in September is not part of the tERERP. u,
(9v; Edward A. Thomas Chief of the Natural and Technological Hazarr3s Division l Federal Emergency Management Agency, Region I EDUCATION NEW ENGIAND SCHOOL CF LAW, Boston, Massachusetts J.D. Magna Cum Laude 1986 i . BOSION UNIVERSITY, Boston, Massachusetts i Pattially completed work for MA in Urban Planning (1973-1975) HYDICIDGIC ENGINEERING CENTER Certificate in Hydrological and Hydraulic Concepts (1975) FOBIHAM UNIVERSITY, Bronx, New York Bachelor of Arts in History,1969 PBCFESSIONAL FEDERAL EMERGD4CY MANAGEMD4T AGDiCY, Boston, Massachusetts EXPERIDJCE Division Chief for Natural and Technological Hazards, December 1981 - Present. Manages emergency preparedness programs to assist State and local governmen.3 prepare for floods, earthquakes, nuclear accidents, and dam failure. Manages the Radiologi al Emergency Preparedness Program in FEMA's Region I (New England). Chairman of the Regional Assistance Comittee. (n) Oversees the review of State radiological emergency response plans and the field exercises of those plans for the 6 operating nuclear power plants in New England and for Seabrook Station. Had overall responsibility for conducting, reviewing and following up on 22 full-scale exercises and several remedial exercises. Has testified before Congressional committees and served as an expert witness in administrative hearings and other legal pro-ceedings concerning the National Flood Insurance Program. Division Chief for Insurance and Mitigation, April 1979 - December 1980 Managed the National Flood Insurance Program in New England. Working with state bankers, insurance agents and government officials to pru ote the concepts of safe and proper flood plain development. Supervised staff of appteximately 20. Appointed chairman of intergoverTunental flood plain manage-nent task force. Established streamlined procedures for administering agency post disaster hazard reduction efforts. I i i (3 l I g
l l l f% t A U.S. DEPARIMENT CF HOUSING AND UFBAN DEVEIDPMENT, Boston, ! Massachusetts Regional Director, Federal Insurance Administration, June 1974 - April 1979 Primary resp nsibility was the management of the flood loss
. reduction activities of the National Flood Insurance Program.
Managed activities of between four and sixteen staff. Created
- new and successful means of achieving program goals with limited staff. Successfully demonstrated post-disaster hazard mitigation program that was used as national model.
Housing Specialist, June 1969 - June 1974 Coordinated HUD Holising Program in several areas of Massachusetts. Responsible for coordination between HUD local officials, attorneys, bankers, developers, citizens and the media. Prepared environmental impact analyses. Mediated disputes between conflicting interests. PBCFESSIONAL ACTIVITIES Guest lecturer on housing, planning, emergency preparedness and environmental affairs at many institutions including Harvard University, MIT, Boston University, Hampshire College, and University of Connecticut. O Q Appeared on TV and radio hundreds of times. Has made professional presentations to over one thousand groups on subjects related to emergency planning. SELECTED RADIOIDGICAL EMERGENCY PREPAREDNESS REPORPS Principal author of or major contributor to:
"Self-Initiated Review and Interim Finding for the Pilgrim -
Nuclear Power Station, Plynouth Massachusetts," dated August 4,1987.
" Analysis of Emergency Planning Issues at Pilgrim Nuclear Power Station Raised in a Petition to the Nuclear Regulatory Comission, dated July 15, 1986," dated July 29, 1987.
" Current FEMA Position on Admitted Contentions on New Hanpshire Plans for Seabrook," dated June 4,1987.
" Final Exercise Assessment Joint New Hampshire State and Local Radiological Emergency Response Exercise for the Seabrook Nuclear Power Plant February 26,1986," dated June 2, 1986.
" Analysis of Issues Related to the Evacuation Time Estimate for the Maine Yankee Nuclear Power Station,"
dated February 1985. Uf)
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" Analysis of Issues Related to the Evacuation Time Estimate for the Pilgrim Nuclear Power Station,"
dated May, 1984.
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" Analysis of Emergency Planning Issues at Pilgrim Nuclear Power Station Raised by the Massachusetts Public Interest Research Group-(MASSPIBG)," dated November 3,1983.-
SELECTED OIHER PUBLICATIONS "The U.S. Supreme Court and the Taking Issue" (with John Kusler, i Esq.) in Natural Hazards Observer, September 1987 1
" Floodplain and Wetland Coordination" National Wetlands News-letter March-April 1987
" National Flood Insurance Program" (with Alexandra Dawson, Esq. )
in Wetland, Tideland, Floodplain, and Groundwater Regulation, l Massachusetts Continuing Legal Education Foundation,1986 l " Legal Iending and Flocd Insurance" - University of Maine Center for Real Estate Education, July 1980
" Flood Plain Management Aspects of the Naticnal Flood Insurance O- Program" - Proceedings of the New England Rivers Conference, October 1978
" Lawyers Perspective on the National Flood Insurance Program" -
Note in Massachusetts Lawyers Weekly 1976
" Regional Policy Statement on Flood Plain Management in New England" - New England River Basin Comission, February 1978 (Significant Contribution to a Task Force Effort)
PBCFESSIONAL ORGANIZATIONS Massachusetts State Bar Massachusetts Bar Association American Bar Association Boston Bar Association O (ic ) I
BFUCE J. SWIRD4 f O Technological Hazards Program Specialist i FEDERAL EMERGDJCY MANAGEMDfI' AGDiCY REGICN I EDUCATICN , M.S. Biology, University of New Hampshire 1974 B .S. Sciences and Humanities, Temple University, Philadelphia, PA 1973 Professional ' Experience March 1987-Present Federal Emergency Management Agency (FEMA), Region I, l July 1983-Dec.1985 Boston, MA Mr. Swiren coordinated the review and evaluation of state and local energency response planning for re-sponding to nuclear pcwer plant accidents in New England, and provided guidance to state and utility planners for improving their capabilities in respond-ing to a radiological emergency. Provided assistance to state and utility planners in designing exercises to test the capabilities of state and local emergency response organizations to protect the health and safety of the public. As the lead FEMA planner for the Seabrook Nuclear Power Plant, provides technical O support and has administrative responsibility for FEMA's activities on this large project. December 1985 - HMM Associates, Concord, MA - Senior Emeroency Planner December 1986 Principal author of the 1986 draf t Massachusetts State Plan, and associated procedures, for responding to a nuclear power plant accident at the Seabrook Nuclear Power Plant. Assisted in the upgradirg of the letters of agreement in New Hr.mpshire's Emergency Response Plan for respond-1 ing to an accident at the Seabrook and Vernont Yankee l Nuclear Power Plants 1982 - 1983 Federal Emergency Management Agency, Region III, Philadelphia, PA 1 l Coordinated the programmatic and field activities of the individual assistance grant program in the mid-Atlantic states under the auspices of the Federal Disaster Relief Act, administered by FEMA. Provided guidance l and training in the application of Federal regulations l to State officials. During Residentially declared l disasters arranged for the deployment of disaster assistance centers in the field and supervised the individual and family grant program. 1 ( /< l l
, m I Bruce J. Swiren Page 2
, .1980 - 1982 Federal Emergency Management Agency, Region III Philadelphia, PA As the lead FEMA planner for the Susquehanna and Beaver Valley Nuclear Power Plants, and the alter-nate for Three Mile Island, provided written and oral testinony to the Atomic Safety and Licensing Boards for the Three Mile Island and Susquehanna Plants.
1975 - 1980 United States Environmental Protection Agency (EPA) Region III, Philadelphia, PA As Environmental Protection Specialist provided reg-ulatory and technical guidance to federal agencies, state and local governments, and the public in the areas of hazardous and solid waste disposal. . As the lead program specialist to the Camenwealth of Pennsylvania, assisted Pennsylvania officials in the development of Pennsylvania's State Plan for the management of hazardous waste generation, storage and disposal. Provided regulatory and technical guidance to federal agencies, state and local governments, and the public in the areas of pesticides use and disposal. Assisted state officials in the mid-Atlantic region in the development and implementation of a State level regulatory program for pesticides use and disposal. Conducted use investigations of agricultural and institutional applications of pesticides to determine the level of canpliance with federal regulations. I l O
Edward A. Tanzman tp)
- Energy and Environmental Programs Attorney Energy and Environmental Systems Divsion (EES) i Argonne National Laboratory (ANL) 1 Education Background J.D. 1976, Georgetown University Law Center;
. special course work in legislative policymaking; Notes and Comments Editor of The Tax Lawyer law review B . A. 1973, Political Science , University of Chicago, with Honors in the College and in Political Science Professional Experience 1979-Present Energy and Environmental Programs Attorney Energy and Environmental Systems Division, Argonne National Laboratory l Provide analysis of how state and federal laws affect energy technologies, hazardous waste litigation, and possible arms control regimes. Current activities include: reviewing compliance of state and local governments with federal nuclear power plant radiological emergency preparedness require-ments; analysis of the Soviet offsite response to the Chernobyl accident; evaluatirg an emergency plan to protect communities surrounding a federal
-O facility from hypothetical toxic gas releases fran that facility; helping a j federal agency prepare for hazardous waste litigation; and, analyzing potential legal problems created by on-site inspection to verify American cartpliance with possible arms control treaties. Past research has included evaluating impacts of energy policies on minority groups, analysis of legal problems by the proposed Satellite Power System, studies of socioeconomic problems created by energy booms, analysis of regional institutional conflicts created by projected future energy growth, study of how eminent domain proceedings are used to aoguire energy transportation corridors, analysis of federal hazardous waste regulation, and analysis of legal trends toward state regulation and taxation of the energy industry.
Past experience with FDiA's radiological emergency preparedness program has included participation in approxhnately 30 exercises of radiological emergency preparedness (REP) plans. Mr. Tanzman also served as lead writer for reports of 2 of these exercises. This included consolidating all observer comments for integration into the final report document. On other exercises, he served as a contributing writer. As a result of his participation in the February 1986 exercise at the Shoreham Nuclear ~ Power Plant, he was deposed in Docket 50-322-OL-5. (J3) 1
l] EDWARD A. TANZMAN 2 V Professional Experience (Cont'd) Mr. Tanzman has also prepared regional analyses of plans and preparedness for approval under 44 TR 350. He has also served as an instructor for the Radiological Emergency Preparedness Evaluator Course at FEMA's National Emer-gency Training Center in Emmitsburg, Maryland. July 1980- Counsel, Palau National Congress, Republic of Palau, February 1981: U.S. Trust Territory of the Pacific Islands (Leave of absence frm Argonne National Laboratory) Served as lawyer for the legislative branch of the government of the Palau Islands (located 500 miles east of the Republic of the Philippines) during its transition from U.S. administration to constitutional republic. Responsibilities included draf ting legislation, researching and writing legal opinions, serving as parliamentarian, providing staff assistance to legislature officers and cmmittee chairman, and supervising a staff of seven assistants. 1976-1979: Legislative Assistant to U.S. Senator Jchn A. Durkin (N.H. ) Responsible for Senator Durkin's Energy and Natural Resources Ccmmittee assignment. Activities included suptvising a staff geologist and planner in _T all aspects of the Senator's Cmmittee work, notably debate over the President's (d National Energy Plan. Sp cific duties included hearing, markup, and floor debate preparation, legislative draf ting, and constituent work. l
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Publications: Journal Articles l Tanzman, E. , Constitutionality of Warrantless On-Site Arms Control Inspections in the United States, forthcoming in Yale Journal of International Law (Fall 1987). Tanzman, E,,, Cmmerce Clause Limitations on State Regulation and Taxation of the Energy industry,13 Loy. U. Chi. L. J. 277 (1982); also published as ANL/EES 'tM-192 (July 1982) and reprinted in VII Public Utilities Law Anthology l (1982-83). l 1
- Tanzman E. , and B. Graham, Note, The Limits of the Section 7602 John Doe Surmons, 28 Tax Lawyer 377 (1975). i n
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( ( I l l Edward Tanzman 3 j v Publications: Reports
- Tanzman, E. , Y. Klein, E. Levine, D. Poyer, A. Teotia, D. Wernette, and R. Winter, The Impacts of the Residential Energy Tax Credit on Minorities, Department of Energy, draf t report (August'18,1983).
Tanzman, E., B. LaBtie, and K. Lerner, Overview of Hazardous Waste Management Regulation at Federal Facilities, Argonne National Laboratory ANL/EES-TM-182 (May 1982). , Santini, D. , J. Clinch, F. Davis, L. Hill, E. Lynch, E. Tanzman, and D. Wernette, A Preliminary Evaluation of Crisis Eelocation Fallout Shelter Options, Argonne National Laboratory, ANL/EES 'IM-227, Volume I (March 1982) and Volume II (December 1982). Tanzman, E., and K. Lerner, An Assessment of Eminent Domain as it Relates to Land Use Issues in Energy Transportation Corridors, Argonne National Laboratory, ANL/EES-TM-194 (September 1981). Whitfield, R., L. Habegger, E. Levine, and E. Tanzman, Environmental and Econmic Comparisons of the Satellite Power System and Six Alternative Energy Technologies, Argonne Naticnal Lacoratory, ANL/EES-TM-136 (April 1981). O I Barisas, S. , S. Ballou, P. Dauzvardis, M. Davis, M. Gabriel, J. Gasper, D') J. Levenson, P. Michel, W. Parker, K. Robeck, D. South, and E. Tanzman, Regional Issue Identification and Assessment, Second Annual Report - Regions V and VII, Department of Energy, review draft (January 1981). Santini, D., E. Tanzman, arrl C. Hotchkiss, Education and Other Financial Problems of Areas Experiencing Energy Inducted Bocm Growth, Argonne National Laboratory, ANL/AA-25 (July 1980). Wolsko, T. , C. Brown, R. Cirillo, J. Gasper, L. Habegger, K. Hub, E. Levine, D. Newsm, M. Samsa, E. Tanzman, J. VanKuiken, and R. Whitfield, A Preliminary Ccruparative Assessment of the Sol 6c Power Satellite (SPS) and Six Other Energy Technologies, Argonne National Laboratory, ANL-Ah-20 (April 1980). Publications: Conference Papers Fingleton, D., E. Tanzman, and K. Bertram, Development of a Model Emergency Response Plan for Catastrophic Releases of Toxic Gases, presented at the 79th Annual Meeting of the Air Pollution Control Association, Minneapolis, W, June 22-27, 1986. Tanzman, E. , PURPA and Associated Federal Regulations that Impact Energy Production, presented at the University of Wisconsin - Extension professional development seminar entitled " Disposal of Municipal Refuse By Utilization As A Fuel," Madison, WI, January 16, 1985 and January 30, 1984. O b ( / Y)
4 Edward Tanzman i v) Tanzman, E., Community Planning for Nuclear Pcuer Plant Emergencies, presented to the Science and Technology Ccmmittee of the Chicago 53ar Association, Chicago,IL, April 5, 1984. Santini, D. , G. Shaw, and E. Tanzman, Fiscal Impacts of Enetyy Facilities on County Governments: Sme Implications for Revenue and Expenditure Modelling, Proceedings of the Pittsburgh Modelling and Simulation Conference, Pittsburgh, PA, May 1-3, 1980. Presentations: Tanzman, E. (Organizer and Moderator), A. Adler, M. Anderson, C. Archambeau, F. Frank, and S. Garfinkle, National Security Classification and the Individual Researcher, symposium presented at the Annual Meeting of the American Association for the Advancement of Science, Chicago, IL, February 18, 1987. Newscu, D. , V. Wingert, J. Keller, E. Tanzman, K. Lerner, and G. Kaszynski, Radiological Emergency Preparedness Exercise Evaluation, presented to the National Emergency Training Institute, Emmitsburg, MD July 27-31, 1987, January 12-16, 1987, and September 15-19, 1986. Tansman, E. Overview of Present Policy and Technology, presented to the Chautatxgua Workshcp entitled Hazardous Waste Management: Technical and Societal Issues, Argonne, II, March 26, 1986. l,__T V Tanzman, E. , U.S. Suprene Court Treatment of Econanic Problems Posed By the Energy Industry, presented to a ecmnittee of the Young Lawyers' Section of the Chicago Bar Association,1982. Donnelly, P.F . , Evans, A.E. , Kier, P. , and Tanzman, E., Energy and Environment, presented to Northern Illinois University School of Law, November 12 and 14, 1979. Tanzman, E., Hydro and Wind, presented at the Engineering Foundation Conference on The Systems App:xach to Emtgy Supply and Demand Controversies, August 15, 1979. Tanzman, E. , National Energy Policy, presented to the Faculty Institute On Energy Planning at Argonne National Laboratory, July 23, 1979. Professional Organizations: Bar of the U.S. District Court for the Northern District of Illinois District of Columbin Bar Illinois State Bar Adjunct Faculty - National Emergency Training Center, Emmitsburg, MD. A V (/6)
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i i i l l CURRENT FEMA POSITICN Of ADMITIED CCNTENTICN OJ NEW HAMPSHIRE PLANS FOR SEABROOK (" Statement of Position") O- 1 l l J EXHIBIT A O l ( / 7)
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2 M 0 W i CURRENT FEMA POSITION UN ADMITTED CONTENTIONS ON NEW HAMPSHIRE PLANS FOR SEABROOK I O ('5) ) -- . - - - - - . - - - - _ _ - - _ - - - - - _ - - - _ _
l l 4 l 0 10- TABLE' OF CONT E NT S Pace Rye Contention 2 1 Hampton Falls Contention 2 ' 2 Hampton Falls Contention 4 3 South Hampton Contention 1 4
- South Hampton Contention 2 5 South Hampton Contention 3 '6-7 South Hampton Contention 6 8 Revised Hampton Contention III 9 Revised Hampton Contention IV 10-21 Revised Hampton Contention VI 22-28 Revised Hampton Contention VIII 29 Kensington Contention 1 30-31 Revised Fensington Contention .
32 Revised Kensington Contention 4 33 Revised Mansington Contention 6 34-35 Revised Kensington Contention 10 36
.NECNP Contention RERP-2 37 .
NECNP Contention RERP-8 38-39 NECNP Contention NHLP-2 40-43 NEG1P Contention NHLP-6 44-57
. SAPL Contention 7 58-59 SAPL Contention 8 & 8A 60 SAPL Contention 15 61-69 SAPL Contention 16 70 SAPL Contention 18 71 SAPL Contention 25 72-74 Revised SAPL Contention 31 75 SAPL Contention 33 76 SAPL Contention 34 77 SAPL Contention 37 78 O ,
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l. O t 4 V' Rye Contention 2 The proposed Radiological Emergency Response Plan for the Rye is , unworkable because of the lack of provisions for any means of protecting a the safety of Rye's special needs populations. Rye has at least four (4) major special needs groups, not including special needs people living at home, for which no provisions are made in the plan; and, while the plan attempts to make ' provision for Rye's special needs facilities (5 schools), nevertheless, those provisions are inadequate particularly with regard to transportation and sheltering. i B ASIS: No Provisions in the Rye RERP for the Rannie Webster Nursing and Elderly Home. Ft.MA fiesponse FEMA and the Regional Assistance Committee have reviewed the special facility plans submitted by the State of New Hampshire in Rev. 2 of their RERP for Seabrook, including plans for the Rannie Webster Nursing Home. The December, 1986 RAC Review of the New Hampshire Plans indicates at
- p. 67 that this section of the State Plan is adequate.,
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2. HAMPTON FALLS CONTENTION 2 The plan designated as Hampton Falls fails to provide reasonable (m 4 assurance since it. cannot provide for continuous 24-hour operation for a protracted period, of local responsibilities, as required by NUREG-0654, A.4. B ASIS: Hampton Falls has one full-time police officer. It has no RADEF Officer or Transportation Coordinator. It has a volunteer, non governmental Fire Department, most of whose members work out: of town. The Police Chief has two back-ups who are employed at other jobs. There is no demonstration that the duties assigned to . local authorities in Hampton Falls by the plan can be met on a continuous 24-hour basis, or that other resources will' be available to meet these
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tasks. 1 FEMA RESPONSE In its Dec.1986 review of Rev. 2 of the New Hampshire Radiological Emergency Response Plans for Seabrook, FEMA and the Regional Assistance
. Committee .(RAC) reviewed all municipal- (EPZ) plans f or their capacity to provide for 24-hour continuous operation for a protracted period. Specif-ically Planning Standard A.4 f rom FEMA-REP-1 defines this requirement. .c On.page 6 of the Dec.1986 RAC Review of .Rev. 2 Hunicipal Plans, FEMA
( found that some key emergency response positions do not have a back-up listed for second shift responsibilities. In Appendix A of the Hamnton Falls P1an, there are no back-up personnel listed for the positions of Civil Defense Director, Transportation Coordinator, RADEF Officer, Police Chief, Health Of ficer, Road Agent, and Town Clerk. For the positions of RADEF Officer and Transportation Coordinator, there are no primary desig-nations either. Based on these review findings, FEMA does not have assurance that the Town of Hampton Fells can implement 'its plan. Since Hampton Falls has indicated that it will not actively partici-pate in the planning and response for a possible accident at Seabrook Station, it is necessary to apply Planning Standard A.4 to the State's ability to fully compensate for the Town of Hampton Falls' emergency response functions, in its June 1986 RAC Review of Rev. 1 of the NH Compensatory P1An for Seabrook Station, FEMA found that the plans did not adequately identify the personnel to carry out the State's Compensatory Plan. The State responded to this by indicating that a resource allocation study was being conducted to identify the personnel and equipment necessary to implement local and State plans, covering all functions. Rev. 2 of the NH Plans still do not contain the results of this personnel allocation study. FEMA's findings are found on page 3 of the December 1986 RAC Review of the New Hampshire Compensatory P1an for Seabrook. Until New Hampshire develops this information as part of its planning base, FEMA has no basis to change its determination that the State has not demonstrated that it has adequate per sonnel resources to compensate for
? the 'non-participation of Hampton Falls personnel . [See RAC Review of the Compensatory Pl an, pages; 3(A.4); 6(H.4), 7(H.10)).
(11)
- 3.
HAMPTON FALLS CONTENTION 4 ip
~h , of The Hampton Falls RERP does not adequately meet the requirements 10 C. F. R. I 50.47(a)(1). I SC.47(b)(5), 5 50.47(b)(6) and NUREG-0654 planning standard E because there are no mutually agreeable basis for notification of response organizations and much of the communications equipment referred to in the Hampton Falls RERP is nonexistent.
B ASIS,: NUREG-0654 II E.1. states that "Each organization shall establish procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classification level and action level scheme set forth in Appendix 1." (emphasis added) Planning Standard E in general requires that procedures and the means for notifying local response organizations, emergency personnel and the public have been established. The Hampton Falls Selectmen have not agreed that the initial point of contact in an emergency should be the policeman on duty or on call, as the plan stetes at p. II-2. Neither have they agreed that the Fire Chief should have the primary responsibility for activaticn of the public alerting system, as shown in the diagram at I-18. The First Chief works out of town and would not be able to fulfill that function on a continuous 24-hour basis, af, required by NUREG-0654 A.4. The Selectmen are not willing to rely on v61unteer firemen as back-up. Neither do . the Selectmen agree that the Chairman of the Board of Selectmen should be in direct charge of all emergency operations for the 7 Town. This gentleman is in the New Ilampshire Air. National Guard and may have conflicting re'sponsibilities. The H.F. plan states at p. II-4 that the initial notification is to be made to a police officer "via pocket voice pagers". The town has no such pagers. The town also has no means of activating the alerting system as alluded to at p. II-6. The town also is not in possession of " tone alert radio receivers" as stated at page II-7. No Civil Defense Radio Network nor Radio Amateur Civil Energency Services (RACES) have been provided noia identified to the town. For all the above-steted reasons, there is no basis for reasonable assurance that the local semergency response organization, emergency personnel, or the public will receive notification of an emergency. In the absence of such reasonable aesurance, it cannot be assumed that the public is adequately protected. , [ Limited as to adequacy of compensatory measures and equipmenti. Board Order, April 1,1986. FEMA RESPONSE: This Contention deals primarily with the ability of the town to be notified and the adequacy of the equipment to accomplish this. As discussed h6 :4m in FEMA's responses to the Motions for Kensington Contention 2 and 10 the Rockingham County Dispatch Center can provide notification to Hampton Falls over existing equipment. Additional communications equipment and O the generator already purchased would further enhance thO capability. Ses PAGE N A fig hARtirte,TTico op TResPc#1ss. ( 21)
i r~' 1 b' 3A
)
l
- 1. On page 3, under " FEMA RESPONSE", the following is added: "Under the State's Compensatory Plan, the Town of Hampton Falls would be first contacted by the Rockingham County Dispatch Center. If no contact cari be made or the town Indicates that it has no response capabilities, then the State will conduct all required notifications l , for the Town of Hampten Falls through the local compensatory staff at the IFO facility. The IF0 facility has all the necessary components 4 of the communication network to do this. (See Rockingham County 1 Dispatch Center Procedures, Volume 4B, pages 3, 5, 6, 9, 12; see IFO Controller Procedures, Volume 4, pages 11-1 through 11-7; see Local .i Liaison Procedures, Volume 4, pages 13-1 through 13-4 and Attachment 13-A.)" !
r\ i 1 l l l (0') l (nj I _ _ _ _ _ _ _ _ - _ _ _ _ - i
I 4. TOWN OF SOUTil HAMPTON O South Hampton Contention 1 The RERP for South Hampton fails to provide "ressonable assurance"
. because, contrary to NUREG-0654 A.3, the plan includes no written agreements referring to the concept of operations or signatures . of local agencies . ,
)
BASIS: j Although a signature page was provided in the September, '1984 dra ft of the South Hampton RERP, it has now been eliminated. . No agreements with the town's teachers, or voluntary town workers, have been obtained, [ Limited as to ' local agencies 'having en emergency response role within the EPZ) Board Ordef, 4/1/E6. > FEMA' RESPONSE: This Contention deals primarily with the deficiency noted in FEMA's June 2,1986 RAC Review of Revision 1 of New Hampshire's Seabrook planning regarding. letters of agfeement with towing companies. In the December 15, 1986 RAC Review of Revision 2, fella found this deficiency to have been adequately corrected. ~
]
O
~
l 5. SOUTH HAMpTON CONTENTION 2 The RERP for South Hamptor, fails to provide reasonable assurance because, contrary to NUREG-0654 A.4, the town- lacks the capacity for j twenty-four hours continuous operation for a protracted period. B ASIS : All town personnel are volunteers, with insufficient backup to provide twenty-four hour coverage. This is tiue of both the police and tire departments, whare even the chiefs are part-time, end many officers are not availnble bscause of other jobs. I i As modifies to provide "for twenty-four hour continuous operation for a necessary protracted period after declaration of any emergency"], f Board Order 4/1/86. {
, FEMA RESPONSE in its Dec.1986 review of Rev. Z of the New hempsnire Radiological Emergency Response Plans for SeabrooK, FEMA and the R6gional Assistance Committee (RAC; reviewed all municipal (EPZ) plans for their captity to provide for 24-hour continuous operation for a protracted period. Specif-ically Planning Standard A.4 f rom FEMA-REP-1 defines this r+quirement.
On page 6 of the Dec.1986 RAC Review of Rev. 2 itunicipal Plans, FEtiA f ound that some key emergency response positions do not have a back-up O listed for second shift responsibilities. in Appendix A of the South Hampton Plan, there are no back-up personnel listed for the positions of Tronspor-tation Coordinator, RADEF/ Health Of ficer, Town Clerk, and Highway Agent. Based on these review findings, FEMA does not have asturance that the Town of South Hampton can implement its plan. . Since Soutn Hampton has indicated that it will not actively partici-pate in the planning and response for a possible accident at Seebrook Station, it is necess'ary to apply Pl anning Standard A.4 to the State's ability to fully compensate for the Town of South Hampton's emergency response functions. In its June 1986 RAC Review of Rev. I of the NH Compensatory P1ar, for Seabrook Station, FEftA found that the plans did not adequately identify the personnel to carry out the State's Compensatory Pl an. The State responnec to this Dy ; indicating that a resource allocation study was being conducted to identify the personnel and equ pment necessary to implement local and State plans, i covering all functions. Rev. 2 of the NH Plans still de not contain the Pesults of this personnel allocation study. FEMA's findings are found on page 3 of the December 1986 RAC i> view of the New Hampshire Compensatory Pl an for Seabrook. Until New Hampshire develops this inform 6 tion as part of its planning base, FEMA has ne basis to change its determination that the State has not demonstrated that it has personnel resources to compensate for the non-participation of South Hampton personnel . [See RAC Review of the Compensatory Pl an, pages; 3(A .4), 6(H.4), 7(H.10). w>
6. SOUTH .HAMPTON CONTENTION 3 The RERP for South Hampton fails to provide reasonable assurance because, contrary to NUREG-0654 C.4, it contains no letters of agreement from volunta'ry police officers , voluntary firemen , other emergency
-- workers, school teachers, transportation companies and bus drivers. It also contains no agreements from Midway Excavators and personnel at the Tweksbury Pond Campground.
~
B ASIS: The number of available personnel st the Tweksbury Pond Camp ground, which has a peak population of 1,500 (about twice that of the size of the town) is exaggerated. [ Limited as to agreements with Transportation companius and midway excavators) board Order, 4 /1/86. Ef1A RESPONSE : FEMA has addressed South Hampton Contention 3 and its basis that the South Hampton plan contains no letters of agreement with transportation companies or wi?h Midway Excavators by applying Pl anning St Andards A, C and J (Evalucti9n Cetteria A.3,C 4,J.10,g, and J.10/k) in FEMA-P.EP-1.
~
_jQ The Deceeber 15, 1986 RAC review of the State and municipal plans reflects
%,,/ FEM #s views on this issue. Specifically, FEMA's review comments on the f4ew Hampshire State plan on this issue are provided on pages 74, 74-b, ana 85 of Section I, on page 1 of the letters of agreement subsection of Section IV, and on page 50 of the Compensatory Plan subsection of Section IV. F EMA's review c0mments on the municipal plans on this issue are provided on pages 5 and 6 of Section II.
FEt1A relied upon the following documents in forming its conclusions on this issue: Revision 2 to the New riampshire State plan; Revision 2 to the municipal plans. Ti1e letters of cgretment with transportation ccepanies are present in Vblume 5 of the State plan, and the RAC conclud*d that the letters ara ade-quate, The South Hanpton pisn does not itself contain copies of letteri of I agreement with transp?rtation companies. However, they are incorporated by reference. Appendix D cf the South Hampton plan is a cross-reference inden to appropriate sections of the plan where descriptive material' applicable to specific NUGEG-0654/ FEMA-REP-1 Criteria elements are fcund. For those crituia elements pertaining to letters of agreement (i.e., A.3 and C.4), Volume 5 of the New Haspshire State plaa is referenced (page 0-1, Appendix 0 of South Hampton plan). The letters of agreement with transportation companies are present in Volume 5 of the State plan. The RAC has concluded that the letters of agreemert are sufficient to provide enough buses and drivers (see December 15, 1986 kAC review pages 74 and 74-b of Section I, and page 1 of Letters of Agreement subsection of (' t c ;
l 7. SOUTH HAMPTON CONTENTION 3 (Cont. ) Section IV). However, in the case of' complete evacuation it would be necessary to use drivers provided by the Teamsters local no. 633, and it might be nec.essary to use.some of the military vehicles listed in Apendix C of.Vol. 2 of the State plan. The total number of buses providable under the letters of agreement are slightly in excess of the number required for full
. evacuation. The approximate equality of buses and bus requirements in the most severe emergency implies that any problems in getting buses from companies to communities could exhaust bus company resources, requiring use of the National Guard. The Teamsters will have to provide drivers to those bus companies ,
i without enough drivers for their buses. A letter of agreement with Teamsters Local No. 633 is provided in Volyme 5 of the State Pl an. In FEMA's April 15, 1987 Affidavit in Opposition to Summary Disposition of Certain Contentions, item 31 of that. document, FEMA noted that there were not any assurances that
-the employers of the Teamsters drivers made available by that letter of agree-ment will be will'ing to allow them to leave their jobs to respond to an emergency.
There is no letter of agreement with Midway Excavating Company in either the South Hampton plan or the State plan, even though it is listed as a con- l tractor in Appendix C (page C-3) of the South Hampton plan. The listing of ; Midway F.xcavating as a potential resource for the Highway Department implies that this contractor could be used for assisting in the removal of impediments to evacuation. Even though Midway Excavating Company may not be available to l the town of South Hampton, it appears that there would be sufficient other
~
sh . resources available from the State to remove impediments to evacuation. Letters of agreement between the State and 16 other towing companies are present in Volume 5 of the State plan. Because of these letters of agreement, the listing of equipment provided in Appendix C of Volume 2 of the State plan, the discussion of State D0T highway maintenance equipment in section 2.6.5 of
- the State plan, the RAC concluded that the plans adequately treated the issue of resources for removing impediments to evacuation (see page 85 of RAC review of State plan, Section-1).
(17) l
.8 .
f " \ TOWN OF SOUTH HAMPTON South Hampton' Contention 6
- The RERP for South Hampton fails to provide reasonable assurance because, contrary to NUREG-0654 H.3, the town of South Hampton doec not have a EOC capable for use in directing and controlling response
. functions.
B ASIS: The plan describes the South Hampton EOC as located in the fire station , states that it has ample space to accommodate all key town officials, and a generator to supply backup power. The town does not have an EOC, and the location pictured (the fire station) does not have edequate accommodations, especially in the winter, and it has neither a generator not the two-way radio cominunications with the school or with State Civil Defense as indicated in the plan. FEMA RESPONSE: This Contention deals with the adequacy of the town's EOC for directing and controlling response functions. The town's fire station should make a suitable EOC, when fitted with the generator and communications equipment ( already purchased and available according to affadvits submitted by the applicant and tne State of New Hampshire. O ne
9.
) REVISED HAMPION CCITTENTICN III 'Io REVISION 2 L/
The Evacuation Time Estimate Study (ETE) prepared by KLD Associates , Inc., Revision 2 Volume 6, is based upon inaccurate and biased factual data and unreasonable or misleading assumptions, falls to comply with NRC regulations, and falls to provide reasonable assurance that adequate protective measures can and will be taken, or that adecuate facilities , equipment , or personnel will be provided to the Town of Fampton, in the event of radiological emergency. 10 CFR 550.47(a)(1). (b)(1)(10); NUREG-0654, App.4. FEMA RESPONSE: The validity of the Evacuation Time Estimates (ETEs) prepared by KLD Associates and incorporated into the NHRERP was challenged by the follcwing Contentions: Hampton Revised Contention III. SAPL Contention 18 SAPL Revised Contention 31 p SAPL Contention 34 -
! SAPL Contention 37
< J' At FEMA's request, the RAC reviewed the ETEs, cifically evaluating them against the guidance set forth in NUREG-0654, FEMA REP-1, Rev.l. The RAC found the CIEs sufficiently ccmplied with the guidance contained in
. AppendixEof NUREG--0654, FEMA REP-1, Rev.1 so as to serve as an adeqJate basis for protective action decisiormaking. FEMA concurs in that view.
The views of the RAC were expressed in further detail in the December 15, 1986, RAC Review of Revision 2 of the NHRERP. The witness who will address these issues at the licensing hearing is Dr. Thcmas Urbanik, a recognized expert in the field. He has reviewed the ETEs and has also concluded that they are adequate under the standards set forh in NUREG-0654, FEMA REP-1 Rev. 1. 'Ihe NRC statf has consulted with Dr. Urbanik on other evacuation time estimate ctudies and will sponsor his testimony. S Hampton Revised Contention IV to Revision 2. Basis (E) and Further Basis (A)2 (ETE issues) Hampton Revised Contention VI Basis A (Rev. 1) p . d , 1 W :)
10.
> TOWN OF HAMPION l REVISED CONTENTION IV 'IO REVISION 2 Revision 2 fails to provide for adequate emergency equipment, fails to demonstrate that adequate protective responser can be implemented in the event of radiological emergency, and fails to correct deficiencies in emergency response capabilities apparent from the emergency exercise .
IG C.R.R. 5 50.47(1)(6)(10)(14).
. BASIS:
The bases for Contention IV set forth in CONTENTIONS OF THE TOWN OF !!AMPTON TO RADIOLOGICAL EMERGENCi RESPONSE PLAN FOR THE TOh N OF HAMPTON. NEW HAMPSHIRE 7NOVE_MBER. 1985, ano revised Contention IV set forth in CONTENTIONS OF THE TOTN OF HAMPTON TO REVISED RADIOLOGICAL EMERGENCY RESPONSE PLAN AND TO CO.YPENSATORY PLAN FOR THE TOhN OF HAMPTON. NEh HAMPSHIRE are hereby realleged anc incorporated by reference herein. B ASIS: NUREG requires that each local RERP include written agreements with any organization serving an emergency response role within the emergency planning zone. NUREG page 32(3). The State has entered into three agreements with transportation companies to provide buses and vans to the Town of Hampton in the event of evacuation. Under the Compensatory Plan , however, only two bus companies - will provide the transportation for Hampton in the event of emergency. Compensatory Plan, page 7A-24. The transportation provided to the Town of Hampton under the Compensatory Plan and Revised RERP fail to provide reasonable assurance of adequate protective measures mandated by 10 C.F.R. I 50.47( A)(1) for the following reasons: FEMA RESPONSE FEMA has addressed Hampton Revised Contention IV and its basis of inadequate evacuation transportation resources for residents, transients, and those with special needs, by applying Planning Standards A, C,,J, and O g3 (Evaluation Criteria A.3, A.4, C.4,f.9, J.10.j, and 0.4) in FEMA-P.EP-1. a . 2., The December 15, 1986 RAC review of the State and municipal plans re-flect FEMA's views on this issue. Specifically, the RAC's review conrnents on the New Hampshire State plan on this issue are provided on pages 10, 64, 74, 74-a, 74-b, 74 c, 127, 128, and 129 of Section I, and on page 1 of the Lett(rs of Agreement subsection of Section IV, and on pages 3 and 49 of the Compensatory Plan subsection of Section IV. The RAC review conTnents on the municipal plans on this issue are provided on page 17 of Section II.
'Ihe RAC relied upon the following documents in forming its conclusions on this issue: Revision 2 to the New Hampshire State Plan; Revision 2 to the municipal plans.
v (w)
11. 1 "IDWN OF HAMP' ION REVISED COtTI'EN'IION IV TO REVISION 2 (Cont.) I Q Because of the need for resolution and clarification of several items, FEMA does not yet have :=plet: assurance of the adequacy of evacuation transportation resources and procedures. Responses to specific portions of Hampton Revised Contention IV are provided below. ( A) Under the Compensatory Plan, the Berry Bus Company shall provide
- the 'Ibwn of Hampton with 40 buses. Page 7A-24. Under the terms of the Letter of Agreement with Berry Bus, however, see attached Berry Bus is only obligated to provide 31 buses in the event of emergency, or 9 fewer buses than even the State acknowledges are necessary in the event of radiological emergency.
FENA RESPONSE: ( A) The Istter of A;;reement with Berry Transportation Company dated 8/7/86, located in Wlume 5 of the State Plan, indicates that it can provide approximately 62 buses and 9 drivers during an , emergency. Ibwever, the buses from Berry Transportation Company are not specifically assigned to provide transportation for the
'Ibwn of Hampton. As noted in the RAC Ibview (page 1 of Letters of Agreement subsection of Section IV), the State appears to have eliminated the prior allotment of buses to ccrnmunities in its compensatory plan and in letters of agreement. The RAC has con-cluded that, overall, the ntsnbers of buses and drivers available f}
(/ according to the letters of agreements are sufficient for the n?eds of Hampton and other ccrnmunities (see RAC Review pages 74, 74-a, 74-b, 74-c of Section 1, and page 1 of Latters of Agreement subsection of Section IV). (B) The Compensatory Plan provides only one bus to evacuate Aslan's Pride School . Happy Apple NurseryRather . and the Taylor School than provide e van emergency. Compensatory Plan page 7 A-7. to evacuate each of these schools in the event of emergency, the Compensatory Plan therefore requires a single bus driver to maneuver through heavy evacu ation traffic an to proceed to each of the three schools to evacuate the children. Substantic! delar, if not impossibility, of requiring c single bus driver to evacuate three schools is unreasonable knd would likely result in substantial delay in removing these children from the EPZ. FEMA RESPONSE ( B) The revised plan (see page IV-34 of Hampton Plan, Wlume 18) indicates separate evacuation vehicles (vans) for Aslan's Pride School, and the Taylor School. Happy Apple Nursery referenced in the contention, is not listed as one of the special f acilities in Hampton.
,O LJ (w
12. 70kN OF HAMPION P1 VISED CJtfTENTION IV TO REVISION 2 (Cont.) (C) The Compensatory Plan and the Revised Hampton RERP acknowledge that 23 emergency and special neede vehicles will be recuired to evacuate the Town in the event of emergency. Coc:pensatory Plan, ; page 7A-7; Revised Hampton RERP, page II-30. The letter agreements for Hampton's transportation needs, however, fail to allocate a single etcergency or special needs vehicle for the Hampton population. FEMA i15P h T: (C) The revised State and Hampton local plans indicate the estimated need for two (2) special needs buses, six (6) bus conversion kits, f our (4 ) vans, and tw: (2) reclinin; seat coaches for the T:wn cf Hampton (see Appendix I, page I-3 of Wlume 2 of State Plan, and page IV-34 of Town of Hampton Plan), in addition to 77 regular school buses. These vehicles will be provided for Hampton fra, the resource pool of bases and E".S vehicles cocumented by letters of agreement in Wlume 5 of the State Plan. The provision of these vehicles will be coordinated by the energency Medical Services (EMS) Coordinator located in the State EOC. (See EMS Coordinator Proce-dures in Wlume 4B of State Plan). The PAC has concluded that there are adequate letters of agreement to account for the estimated needs of buses and ambulances (see page 10 of RAC Peview, Section I). (D) The Revised Hampton RERP does not provide transportation fo.- any vacationers, transients or other non-resident individuals who may lack their own transportation and may be present in the Town at the timi. of emergency. In view of the substantial number of tourists and - transients coming to Hampton throughout the year, and particularly during the summer months, it is only reasonable to assume that a significant number of additional public transportation vehicles will be reouired to promptly carry out an evacuation. FEM PISPONSE
.2r-26 s' - 2.9 (D) As noted on pages M-tEandMf the Hampton P1an, transients without access to shelters or vehicles in which they may evacuate when sheltering has been recomended will be provided for by the
. Public Works Director who will provide transportation for those transients to a suitable sheltering location. If eva:aation has been reca mended, the plan also states that each municipality has provisions for evacuating residents, including transients. In add-ition, the State is prepared to provide emergency transportation resources to those comunities that have exhausted the local response capability. Rwever, the PAC has concluded that the issue of the adequacy of transportation for transients will remain open pending infor ation to be supplied by the State on the nu.ber cf transients
[. needin; transp:rtatir (see FAT Review cf element J!.9 en page 64 s (~2) b_ __
13. TOW OF HAMPION REVISED CONTENTION IV 'ID P1 VISION 2 (Cont.) of State plan review, Section I, and page 17 of local plan review, 1 Section II). . (E) Under the Compensatory Plan, the Timberlane Bus Company of f Salem , New Hampshire shau provide the Town of Hampton with 35 buses in the event of emergency. Salem is located approximately 40 miles from the Town of Hampton. Since under the Revised Hampton RERP, individuals evacuated from Hampton will be taken to Nashua, immediately adjacent to S alem. Revised RERP, page 11- 17 , the Timberlane buses attempting to reach Hampton for evacuation purposes will be required to maneuver through evacuation traffic leaving Hampton. The likelihood of
,subst antial delsy , if not impossibility , of evacuation vehicles reaching Hampton therefore raises significant questions on the feasibility of the evacuation transportation provided to the Town under its Revised RERP.
The Revised Hampton RERP therefore fails to provide reasonable assurance of prompt access for emergency vehicles to the EPZ and fails to consider the potential impediments of evacuation traffic in promptly providing evacuation vehicles to the Town. NUREG-0654, page 63. i FEMA RESPONSE (E) The August 1986 Letter of Agreement between the State and the Timberlane Transportation Campany of Salem, which is located in Volume 5 of the State Plan, indicates that approximately 40 j buses and 40 drivers will be available during an~ emergency. These buses are not specifically assigned to provide transpor-tation for the Ibwn of Hampton. As noted in the RAC Review - (page 1 of Letters of Agreement subsection of Section IV), the State appears to have eliminated the prior allotment of buses to ccmnunities in the Compensatory Plan and in letters of , I agreement. The RAC has concluded that, overall, the numbers of buses and drivers available according to the letters of agreement are sufficient for the needs of Hampton and other communities (see RAC Paview pages 74, 74-a , 74-b, 74< of Section I, and page 1 of Letters of Agreement subsection of Section IV). However, further clarification is still needed regarding the availability of teamsters frcrn their employers during work hours. It should also b6 noted that Nashua is no longer a host cermunity for Hampton, as referenced in the con-tention. Individuals evacuated frcrn Hampton will be taken to the Beception Center in Ibver. By way of further basis: (A) Dnergency Resources and Equi;rnent . O m
(
- 14. !
, j
'KM4 OF HAMPTON FIVISED CONTENTION IV 'IO REVISION 2 (Cont. )
l k_) <e Revision 2 fails to allocate adequate buses or EMS vehicles to the
- Town of Hampton to reasonably support an evacuation on grounds
, including:
- 1. The State indicates that the bus companies under Ietter Agreement will provide 553 buses and 496 drives to support an evacuation in the event of radiological emergency. Vol. 4. App.1-1 and 2. These I figures are inaccurate and mislesding. Many of the buses to be provided by a particular bus company lack sufficient drives and, conversely, other bus compani>c are prepered to provide drivers, but have no buses for them to d rD e . Id. FEMA correctly notes that c,nly " bus-and-driver pairs" under agrecsment should be counted to determine the maximum number of emergency vehicles available to support an evacuation. FEMA, Final Exercise Assessment. 6/2/86, at p. 39. The state. however, can
'only demonstrate 541 bus!and-driver pairs. Vol. 4, App.1-1 and 2. or 13 bus / driver pairs lers than the 444 necesECTy minimum required to carry out an (vacu ation , Vol. 4 App.1-6, even using the St at e's own-unreasonably low EPZ population figures.
FDtA PISPONSE: A
'Ihe MC hat, concluded that, although there are numerous inconsis-Q l.
tencies in bus needs estimates, overall the numbers of buses and drivers available according to the Letters of Agreement in Volume 5 of the State Plan are sufficient (see pages 74, 74-a, 74-b, 74-c of RAC Review of State Plan Section I, and page 1 of Letters of Agreement subsection of Section IV). As indicated on page 74 of the RAC Review (Section I), the Air National Gaard, National Gaard and DOT vehicles are listed in Volume 2,7 App. C. Schoo'. buses are listed in Volume 2, App.y ~E which lists capability of 574 buses but only 446 bus and driver pairs available at bus'ccrnpanies to af fryvacuation. ':he 574 g buses listed plus the private vehicles of the ps~rsons in WL*PZ plus the reserve resources of the Air National Guard Army, and Highway Depart:nent totalling 851 vehicles offer a large -r44ecar.cy ftd.1 of resources. ; As further described on page 74-b of the RAC Peview (Section I), the " Transportation Pesources Requirements" totals from \bl. 2, Rev. 2 - 8/86, pace R indicate that the bus requirements are
.F 3 well in excess of the number of bus ccxnpany drivers that have agreed to drive, but scrnewhat less than the number of buses avail-able according to the letters of Agreement.
The Plan properly allows for the f act that not all bus ccxnpanies p have as many drivers willing to serve as they have buses that (j would be made available. A Letter of Agreement with Teamsters
/ ~>. 9 )
15. A TOW OF HAMPION REVISED COtEE!TrION IV 7 REVISION 2 (Cont.)
! \
'J Local ib. 633 of New Hampshire provides for the Local to provide as many as 1,500 personnel, a value well in excess of any foresee-
~
able needs. g urs& 0 % 2 / 5 b P o R. D. RR. t en e A Ts o u o f HGS 1?CM -
- 2. The bus-and-driver pairs under Letter Agreement with the State represent an " absolute usaximum," FEMA, Final Exercise Assesstr.ent, 6/2/86, at p. 39, and do not provide reliable figures to measure avails le evacuation buses or personnel. FEMA, Final Exercise A ssessment ,
6/2/86, App. I at p. 233. Both common sense and conversations between FEMA and the bus companies indicate that in fact the actual bus-and-driver availability would be substantially less than as specified in the Letter A greements, id, which could reasonably be expected to be reduced by reason of bus breakdown, driver unavailability, drivers who may get lost enroute to the EPZ, or who may becocne imbedded in outgoing evacuation traffic thereby substantially delaying or prohibiting a driver from timely reaching the EPZ. RAC Review , August, 1986, Section VI, p.12. FEMA RESPONSE r~S - V 2. See response to Item #1 above. Sm Pm im Fon dLA Rt P ic A Ti ot3 eF 3GEP c M.E .
- 3. In an apparent effort to address FEMA's concerns on the inadequacy of available personnel and transportation resources, the State ~
has entered into an agreement with the Teamsters Union, apparently for the purpose of providing additional bus drivers for evacuation. Vol. 4. App . 1-11. Revision 2, however, fails to demonstrate that the Teamsters under agreement are in fact adequately trained to drive the school buses and emergency vehicles for the mobility impaired to properly effectuate an evacuation, fails to specify how these backup drivers promptly will be notified and coordinated with available buses, and fails to support the purported agreement with the Teamsters with Letter Agreements executed { by the individual members of this union. l FEMA RESPONSE:
- 3. The Letter of Agreement with Teamsters Iocal No. 633 is present in
\blume 5 of the State Plan and documents the Union's agreement to provide approximately 1,500 personnel to drive transportation vehicles i as needed during emergencies. In regard to training, the 6/2/86 i agreement between the State and the Teamsters indicates that "the thw 73 Hampshire Civil Defense Agency will provide training to the Incal 633 N.
t 3 r)
n 15A N,].
- 1. On page 15, at the end of the first paragraph, the following is added:
"However, in FEMA's April 15, 1987 Affidavit in Opposition to Summary
. Disposition of Certain Contentions, item 31 of that document, FEMA noted that there were not any assurances that the employers of the Teamsters drivers made available by that Letter of Agreement will be willing to allow them to leave their jobs to respond to an emergency. Furthermore, see the FEMA response to item 3, below."
- 2. On page 15, under " FEMA Response to Further Basis (A)2:", the following is changed: (a) replace the period after the word "above" with a comma; and (b) insert "for general discussion of bus-and-driver availability and redundancy of resources. With respect to the possibility of drivers getting lost enroute to the EPZ, improved bus route maps are now available.
The RAC found these maps to be generally adequate (NUREG elements J.10.a and J.10.g, RAC review Section IV, State Compensatory Plan subsection, pages 9 and 11. The use of these maps will be tested during the next exercise. The possibility of incoming buses becoming
' imbedded' in outgoing evscuation traffic will be reviewed as part of the Evacuation Time Estimate Testimony of Dr. Thomas Urbanik, an NRC Staff witness."
h (V p) ( N
16. s D \ TOW OF HAMPION REVISED CONTENTION IV TO REVISION 2 (Cont. ) membership regarding potential emergencies in New Hampshire." The State training program is described in Section 3.2 of the provide l As indicated on page 3.2-6 of the State Plan, NHCDA will . Stat l annual instruction to the drivers of bus and ambulance transportation resources. The training will consist of "an overview of the RERP and emergency response organization, notification, emergency classification levels, protective actions, location of staging areas, basic radiation concepts, and radiological exposure control, including the.use of dosimeters" (pages 3.2-7 and 3.2-9 of State Plan). Although the RAC had no specific coments on the training program for bus drivers, Planning Standard O I, Radiological Dnergency Response Training) was rated as adequate by the RAC (pages 127,128, and 129 of Section 1 of ' State Plan review) . No details were found in the plan as to how Teamsters' bus drivers will be notified and coordinated with available buses. However, there is a contact person for Teamsters Local No.633 and telephone neber listed on paceMf Appendixtof NHCDA Procedures in 7 I., g Volune 4 of the State Plan. Although the procedure for the EOC
/~'N Resources Coordinator (Wlme 4 State Plan) and the' Director of Pupil Transportation Safety (Volune 4B State Plan) intlicate that they will request bus empanies to conduct a fleet inventory and driver avail-ability poll, no other procedures could be found which describe how individual Teamsters drivers are contacted and matched with available buses which require drivers. Although the RAC did not comment on this in its review, this information should be provided in the plan to ensure that Terr.ustars' drivers can be contacted, mobilized and matched with available buses in a timely manner. Ad/tzwu,, 2d IN4., Y/'dl ' / /LLhwe .0w d/tivero/ a_e d Jy@u b
& A-b L w h ' M d.Y'hfe,pu/f .lyst<u'n ,
(B) Emergency Exercise. The February 26 exercise only confirmed the consistent position of the Town of Hampton and other interveners that evacuation of the EPZ around Seabrook Station is not feasible and that the personnel and equipment allocated to support an emergency response are inadequate. For example , the State could not satisfy even the limited demand for buses of communities participating in the exercise, FEMA, Final Exercise Assessment, p. 40, could not provide adequate EMS or ambulance sernce, FEMA, Final Exercise Assessment, pp. 42, 44, no buses were allocated for summertime employees, RAC Review, August 1986, Section VI at p. 9, the State failed to demonstrate that adequate backup buses were available to support an evacuation, FEMA, Final Exercise Assessment, 6/2/86, p. 4 2, and the State did not alJocate transportation for those individuals who O may have a vehicle in the household, yet the vehicle may be unavailable O 1)
17. ! TOW OF HAMPION REVISED 02EDRION IV TO REVISION 2 (Cont.) G at the time of an emergency. RAC Review , Auc'ust 1986, Section 1,
- p. 71. Revision 2 fails to correct these anc related deficiencies.
Additionally, if the State was unable to reasonably carry out e limited and
. preplanned evacuation exercise, with no requirement for coordination with Massachusetts , and in the dead of winter, an actual evacuation of the ,
summertime beach population is wholly unrealistic and unworkable. FD4A RESPONSE: (B) The Final Exercise Assessment of the February 26, 1986 Dcercise documented many deficiencies in the State's ability to provide evacuation transportation resources in a prompt and coordinated manner. Remedial actions to correct these deficiencies will have to be successfully denenstrated in a future exercise. (C) Special Needs Population. Revision 2 calculates the special needs population for the Town of Hampton based upon an " annual survey." Vol. 18, p. 11-30. This O' " annual survey" is in fact a mere " postage paid mail back card" sent out by the State purportedly to all persons residing within Hampton. Id. Less than 2 percent of the Town responded. Vol. 18, p. IV-34. The survey is a grossly inadecuate vehicle to compute the special needs and transit dependent populations of the Town of Hampton and unreasonably I places the burden upon handicapped, mobility-impaired, and other transit 1 dependent or special needs individuals to affirmatively request I transportation or be ignored under the State's emergency plan. The State itself recognized the inadequacy of its own survey since it increased by 50 percent the transportation allocation for the special needs populations for all towns, in view of the "stnall sample sizes" received from each community. RAC Review. August.1986, Section VI, p. 6. As the RAC pointed out, however, no statistical justification has been provided by the State for this 50 percent increase. Id at p. 5. The special needs populations for the Town of Hampton, and for other EPZ towns, therefore represent an unknown quantity for evacuation planning. PEthn RE.TPCWSG : (C) The RAC Review indicates that there needs to be clarification in the Plan on the basis for determining the number of people in the EPz< = ccmunities requiring transportation during an evacuation. The RAC Peview also indicates that numerous inconsistencies need to be resolved. The RAC Feview (page 74-a of Section I) noted that the special needs survey of transit dependent residents is different from the telephone survey which was used for computation in the m)
)
- 18. -
TOW OF HAMP70N REVISED COffrENTION IV 10 REVISION 2 (Cont.) Evacuation Time Estimates (ETE) Study. The special needs survey gives the lowest number of residents requiring transportation. There are scme very large differences in special needs survey estimates of requirements by ecmmunity (see Vol. 4, Rev. 2 - 8/86,
. pages 18B-2 through 188-27) and the ETE telephone survey estimates (see Table 11-7, \bl. 2) . The Plan should state the basis of its use of a particular set of numbers, give date when the estimates were developed, and explain whether and why those numbers take precedence over any other set of numbers which were constructed for essentially the same purpose. The plan reviewers do not now have enough information to judge the accuracy or priority of a given set of numbers.
I i Specific comments on Volume 6 (ETE Study) will be provided by an expert witness to be sponsored by the NRC. I (D) Compensatory Plan. FEMA has recommended that the State Compensatory Plan be revised "to anticipate the non-participation of any of the local jurisdictions in the Seabrook plume EPZ." FEMA, Final Exercise Assessment, 6/2/86, p. 44. 9 Based upon the FEMA recommendation , non-participation of the Town of Hampton end numerous other towns and from the avowed l within the EPZ to implement the NHRERP, the State has promulgated a l compensatory plan consisting of only five pages. Vol. 2. App. G. As presently drafted. the Compensatory Plan wholly fails to allocate adequate personnel, equipment, or resources to implement an evacuation on grounds including:
- 1. The plan erroneously assumes the cooperation and participation of Hampton school officials . although no letter agreements confirming this participation have been obtcined. Vol . 2 App. G-2.
FEMA RESPONSE: (D) Appendix G of \blume 2 of the State P1an does not re esent the total State Ccapensatory Plan, but only represents a outline of the concept of operations. The details of how th Compensatory Plan operates have been incorporated into the plan procedures (Volumes 4, 4A, and 4B) . O m
19.
,3
< TOWN OF HAMP10N REVISED COtEE?EION IV TO REVISION 2 (Cont. ) ,
b :
- 1. It is correct that the Compensatory Plan assumes the cooperation of Hampton School officials in implementing their response plans and in providing information on school attendance (page G-2 of Appendix G to \blume 2 of State Plan). It is also correct that the plan contains no letters of agreement with Hampton School
- officials confirming this cooperation. However, FEMA REP-1 does du, not p letters of agreement with school officials since schools are considered public agencies.
l
- 2. Aside from vague reference to the coordination of " law enforcement sctivities and traffic control," Vol. 2, App. G-3, the compensatory plan whoUy fails to specify where this additional law en forcement personnel wiU be obtained to make up for those local police who will not participate in the implementation of the NHRERP, including the Hampton Police Department. Either the plan erroneously assumes local participation in the face of the express vote of the Town of Hampton not to so participate, or the plan relies upon the inadequate number of personnel in State Police Troop A to carry out local law enforcement duties. With its 35 troopers, however, Troop A does not even have sufficient personnel to staff access control points for the EPZ, as required under Revision 2, let alone take over the traffic mcnagement cnd security dutics presently assigned to Hampton and other local police
( department s . FEMA, Final Exercise Assessment, 6/2/86 at p. 4f, FEMA REST)ONSE:
- 2. The New Hampshire State Police Troop A procedures include prcr visions to mobilize additional personnel to compensate for municipalities that may be unable to respond to the emergency.
As noted in the procedures for the Troop A IEO Representative (page 6, step #6, Troop A Procedures in Volune 4B of State Plan),
"If additional personnel and equipment are required, contact the State Police EOC Liaison to initiate state police alerting procedures to call in troopers from other parts of the State."
The procedures also indicate that if still further assistance is required, the State EOC representative is to be contacted to request support frcxu other State resources. The PAC Review indicated that this revised procedure was adequate (see page 49 of Compensatory Plan subsection of Section IV). The procedure for mobilizing additional support, therefore, appears to be adequate, although the adequacy of overall resources still requires resolution. For example, the State indcated (page 3 of Ccxnpensatory Plan subsection of Section IV of RAC Review) that "A resource allocation study is currently being conducted. This study will (1) identify the personnel and equipment
)
required to implement the local and State plans and procedures lfic. '
i j
- 20. l i
-)
( TOW OF HAMPION REVISED COtEEtGION IV' TO REVISION 2 (Cont. ) ( I and (2) assure that adequate resources are available to cover all emergency functions. Once this study is completed,. rosters and equipment lists in the plans and procedures will be reviewed and updated acebrding to the results of this analysis." The PAC concluded that the adequacy of resources depends on the outcane of the cited study. (E) Transit Dependent Individuals. Revision 2 adopts a " concept of pre-designated bus routes" to evacuate transit dependent residents and transients without private Section I, p. 73. transportation. RAC Review. August.1986, Apparently this procedure has been. adopted to purportedly increase the I speed of evacuation, by eliminating the need for door to door pick ups of These transit dependent individuals as provide din the prior NHRERP. pre-designated bus routes, however, will require individuals, including the " mobility-impaired ," to leave their homes during a radiological emergency, to locate the pre-designated bus routes, and to remain outdoors subject to increased radiological exposure, awaiting evacuation
.G butes which FEMA has already indicated rnay reasonably be expectedThTs not
/ FEMA, Final Exercise Assessment, 6/2/16, at p. 40.
V to arrive . procedure unreasonably compromises the public health and will not adequately protect the Hampton population . from radiation injury. Additionally, the transportation allocated for the Town of Hampton under Revision 2 Vol. 18, p. 34, does not include buses forVol. the 4,substantial App. I-8. number of transients, including the beach population. , pm aEsPousE (E) The concept of pre-designated bus routes for the evacuation of residents and transients without transportation does not eliminate the need for door-tcM$oor pickups for "mability-impaired" indi-viduals with special needs. As indicated on page II-31 of the Hampton Plan, the Public Works Director is responsible for main-taining a current listing of the residents that require evacuation by special vehicle or that require physical help to evacuate. The Public Works Director is responsible for ensuring transpor-tation is provided for these people. As indicated in the Hampton Plan (page II-31), the transportation requirements are transmitted , to the town IFO local liaison for assignment and dispatch of the ! appropriate transportation resources. As noted in the Public ; Works Directors' procedures (page IV-32 Hampton Plan), town ,! emergency workers will be assigned to report to the homes or other locations of people with special needs to assist them in I O Wd l 1 I
21. TOWN OF HAWION PEVISED COtTTENTION IV TO REVISION 2 (Cont. ) 7s U) boarding vehicles. Directions will also be provided for EMS vehicles reporting to homes of people requiring ambulance
- transport.
Should tcwn officials not participate, these activities would be performed by the State under the Compensatory Plan. In regard to the adequacy of transportation for transients in Hampton, see the previous FEMA response to Item "(D)" of the original basis of Hampton Contention #4. D [G r ( w uc
L 22. REVISED HAMPTON CONTE 1 TION VI TO REVISION 2 77 () Revision 2 fails to dernonstrate that adequate personnel are available to respond. or to augment their initial response on a continuous basis, in the event of radiological emergency. 10 C.F,R. f 50.47(b)(1)(10).
, BASIS:
The baces for Contention VI set forth in CONTENTIONS OF THE
~ TOWN OF HAMPTON TO RADIOLOGICAL EMERGEMCY RESPONSE PLAN FOR THE TOWN OF HAMPTON. NEW HAMPSHIRE. NOVEMBER.1985, and revised Contention VI set forth in CONTENTIONS OF THE TOWN OF HAMPTON TO REVISED R RADIOLOGICAL EMERGENCY RESPONSE PLAN AND TO COMPENSATORY PLAN FOR THE TOWN OF HAMPTON. NEW HAMPSHIRE, are hereoy realleged and incorporated bv reference herein (see p. 3).
FEMA RESPONSE This contention, taken overall, concerns the capacity for the Town of Hampton and the State to provide sufficient personnel resources to support an initial and on-going emergency response. The requirement is defined in Planning Standard A.4 of FEMA-REP-1. In the December 1Q86 RAC review of the REV. 2 Municipal plans, on m page 6, FEMA found that some key emergency response' positions do not 7 have any back-up for second shift response. 'Mresd. fatA of the Hampton g{f g i } V Plan does not show any alternates for the positions of Civil Defense Director, RADEF Officer, and Health Officer. In addition, the Town Manager is listed as the incumbent official for three emergency response positions, those being Town fianager, Civil Defense Director, and Health Officer. Based on these review findings, FEMA does not have assurance ' that the Town of Hampton can implement its plan. Since Hampton has indicated that it will not actively participate in the planning and response for a possible accident at Seabrook Station, it is necessary to apply Planning Standard A.4 to the State's ability to fully compensate for the Town of Hampton's emergency response functions. The same comments apply here as for the Contentions South Hampton 2, Kensington 1, and Hampton Halls 2. are asFEMA's follows:responses to the specific basis contained in this Contention f~% G w
23. HEM VI (Cent.) . . . (A) Revision 2 provides that 28 local traffic guards are required for the Town of Hampton and Hampton Beach, Vol. 6, p. 8-11, although the Hampton Police Department only has a total of 24 full time officers in the O) ( entire force. Vol. 18, p. IV-41. Even adopting the State's implicit, and unreasonable, assumption that the entire Hampton police force would be immediately available to respond to a radiological emergency, the force simply does not have adequate personnel to man the traffic control points.
. Vol. 6, p. 8-11, Vol. 18, p. IV-4 3, to provide EOC security, Vol. 18,
- p. IV-42, to provide security patrols throughout the Town, Vol. 18,
- p. IV-43, to provide those people within Hampton at the time of emer-
., gency with backup public alerting, Vol.18, IV-41, or to close and patrol the town beaches. Vol. 18A App. G-3. FEMA RESPONSE Basis A (Rev . 2) This basis asserts that the town's 24 full-time police officers are not sufficient to perform all the duties assigned to them. Since the town has indicated that it will not commit its full or part-time police officers (which together are sufficient to perform all assigned emergency response functions), and the State has committed to compensate for local emergency response responsibilities (Volume 2, Appendix G of State Plan), this basis is without merit.
/% (B) In an effort to compensate for the lack ~of local personnel to ;] adequately respond to a radiological emergency, Revision 2 provides that the New Hampshire State Police will provide " assistance to local police departments for law enforcement and traffic control." Vol. 1, p . 1.3-20.
State Police Troop A is the only State Police force in reasonable proximity to the EPZ. Since Troop A , however, has only 35 troopers, and 44 officers are required to staff the access control points for the EPZ, FEMA has properly concluded that Troop A does not even have sufficient personnel for access control, FEMA, Final Exercise Assessment, 6/2/86,
- p. 46. Necessarily, Troop A has no addinonal personnel to assist local municipalities , such as Hampton , Vol. 1, p. 1.3-20, lacks resources to provide any traffic control beyond access control within the EPZ, will be unable to respond to requests from DOT to provide road barriers, signs, or road clearance during evacuation , or otherwise to perform the excessive number of duties assigned to the State Police under Revision 2.
Vol. 2, p. 1.3-20 and 21. FEMA has therefore properly noted that "even with help from other troops, the State Police force could be seriously depleted and law enforcement possibly impaired." FEMA, Final Exercise Assessment. 6/2/86 at p. 46. FEMA RESPONSE Basis B (Rev. 2) The problem of obtaining sufficient State Police resources, in a timely manner, to perform assigned duties plus any necessary compensa-O tory actions, remains. The logistics would seem to require a full ( mobilization of State Police Troops at the ALERT level to allow for extra travel time to the Seabrook area.
?,,
HAME' ION VI (Cont.) g B ASIS: (A) Population estimates. In establishing adequate levels of local f 3 personnel to respond in the event of a radiological emergency, the () Hampton RERP relies upon a " peak seasonable population" of 110,000 for
~
the Town of Hampton. This population estimate is purportedly "the maximum population which may be expected in the Hampton area at any time during the peak summer months," Hampton RERP. pg.1-11 and was computed utilizing second hand information prepared by non-local sources. The Hampton RERP thereby violates FEMA regulations since " estimates of transient population shall be developed using local data such as " peak tourist volumes." NUREG. Appendix 4 - 3. By letter of October 29, 1985, the Town of Hampton specifically advised the State that the Hampton RERP peak population estimate of 110,000 was substantially below traffic counts and local business figures. As set forth on the attached Affidavit of Glen French, President of the Town of Hampton Chamber of Commerce, the local Chamber of Commerce routinely relles upon population estimates of between 150,000 to 200,000 people per day for the Town of Hampton during the summer season. As many as 250,000 people can be expected within the town on each day over the Fourth of July weekend. The State therefore relies upon a peak population estimate less than one-half of actual figures , as determined by local officials uniquely cualified to make these computations based upon parking, both legal and illegal, business receipts, and seasonal shifts in the demand for municipal services. At a minimum, NUREG, Appendix 4 - 3 requires the State to fully explore with local officials the basis for the disparity in State and ( ) local population figures. The State, however, terminated all discussion - Gi on this issue. Necessarily , the State's reliance upon unreasonably low population estimates raises substantial questions on the adequacy of local personnel allocated to the Town under the RERP to respond to a radiological emergency. FEMA RESPONSE Basis A (Rev .1) See FEMA response to Contention SAPL 34 (B) Police Departments. The Hampton RERP provides that a total of 80 police officers and personnel will be available to respond to a radiological emergency. Hampton RERP. Appendix C-1. These figures are misleading and fail to account for the fact that 50 of the 60 police personnel are "special officers" hired by the department on a part time or seasonal basis. These special officers therefore lack the experience , skill, and training necessary to promptly implement adequate protective responses in the event of radiological emergency. FEMA RESPONSE q Basis B (Rev.1) With proper training, the 50 special officers should be able to function adequately in their emergency response duties. However, this basis is now without merit, since the Town of Hampton does not plan to participate in the emergency planning process. 5/ , \
h"A* fit 21 VI (Cont.) 25. 1 O 4
-V (C) Department of Public Works. The Hampton REFP provides that a total of 60 personnel are available from the Hampton Public Works Department to implement protective responses in the event offigurcs. radio!crical are Hampton RERP, Appendix C-3. These emergency.
misleading. Of the 60 department personnel, 24 of these individuals constitute " temporary" employees, who, by reason of inadequate training and experience, cannot reasonably be expected to promptly and appropriately implement necessary evacuation procedures. Similarly, an additional 19 members of the Public Works Department are routinely employed in waste water treatment and sewer maintenance. Accordingly, these individuals cannot reasonably be expected to implement the traffic control, evacuation transportation, or maintenance of evacuation routes which represent the primary responsibilities of the llampton Public Works Department in the event of evacuation. Hampton RERP. IV 29. The remaining department personnel consist of the director and 16 highway personnel upon which would fall p rimary responsibility for initiating and implementing protective responi es in the early stages of a radiological emergency. See NUREG. pg. 20. These duties include:
- 1. Responsibility for evacuation of all individuals without automobiles , families without the use of the vehicle , and people with special transportation needs. NUREG, Appendix IV - 27(7). Plainly the r i limited staff of 17 in the Public Works Department who are familiar with V highway and transportation problems are wholly inadeouate to insure the transportation. of the thousands of individuals who may be located on the beach at the time evacuation is implemented, even assuming this was the sole function to be performed by the department in the event of a radiological emergency. The additional and sub stantial duties of the department to canvas the town and direct evacuation of special needs individuals , families, vacationers, and other non-auto owning individuals, merely underscores the gross inadequacy of local public works personnel to meet their responsibilities under the RERP. 10 C.F.R.. .
Section 50.47(b)(1).
- 2. Under the Hampton RERP, the Public Works Department is responsible for ensuring that "all evacuation routes are serviceable throughout the course of an evacuation . " Hampton RERP II - 31.
Clearly the available Public Works Department personnel are inacequate even to carry out this single function mandated by the Hampton RERP. More significantly, the Hampton RERP unreasonably assumes that maintaining accessibility of evacuation routes will " entail normal adverse weather route maintenance o nly . " RERP. pg. II - 31. The RERP therefore unreasonably fails to account for accident s , breakdowns, driver di. obedience, panic, and gas shortages which must be reasonably anticipated in the event of mass evacuation. The Hampton REBP therefore fails to provide reasonable assurance that the town has
,, adequate staff to carry out its evacuation responsibilities, NUREG.
pg. 31. Assienment of Responsibility, and the RERP relies upon an (]
- unreasonable and unrealistic model in determining staff capability to implement the plan. NUREG. pg. 61. Protective Response.
I ll .:. > 1
. I
IRM7IOM \C (Cont.) 26. FEMA RESPONSE
\. s Basis C (Rev . 2)
With proper training, Department of Public Works personnel (botn full
, time and part time) should be able to function adequately in their emergency response duties. However, this basis is now without merit, since the Town of Hampton does not plan to participate in the emergency planning process, (D) Selectmen. The Board of Selectmen for the Town of Hampton are provided ultimate authority to direct radiological emergency operations for the Town. Hampton RERP 1 - 16. The RERP igr.cres the fact, however, that Selectmen are only part-time officials who may have full-time jobs even outside the Town of Hampton. It is reasonable to assume that at least certain members of the Board of Selectmen would be unavailable to promptly respond, implement , and direct an appropriate protective response.. Additionally the Hampton Selectmen are annually elected which may thereby seriously compromise effective RERP education and training for newly elected officials. ~
O ~ FEMA RESPONSE Basis D (Rev.1) Same response as for basis B and C above. 1 l O gu 71
f MI0t! VI (Cont.) 27. EASIS: p. V (E) The Revised Hampton RERP relies upon the cooperation and participation of Town of Hampton employees and officials , including Selectmen, RERP IV-2, police , IV-41, and fire officials, IV- 16 , to implement protective actions in the event of emergency. By vote of the
, Hampton Town Meeting on March 8, 1986, and by Resolution adopted by the Board of Selectmen on March 24, 1986, however, the Town of Hampton has declined ' and refused to participate in the preparation or implementation of the Hampton RERP prepared by the State. Necessarily the State cannot rely upon Hampton personnel to carry out the State plan for the Town. Accordingly, the Hampton RERP fails to provide reasonable assurance that Hampton personnel will implement or carry out protective acticps during an emergency.
(F) Under the Revised Hampton RERP, the duties and responsibili-ties of the Town Manager and the Town Civil Defense Director have been expanded. Revised !!ampton RERP IV, pages 7-16. The Revised Hampton RERP. however, falh to account fore the fact that, within the Town of Hampton, the Town Manager is presently serving as acting Civil Defense Director. Accordingly, the emergency administrative responsibilities placed upcn this ringle individual for the Town of flampton are wholly unreasonable and far enceed the abilities of one person, however, capable. For example, among other duties, the Town Civjl Defense Director is required to assess and monitor the Town transportation needs in the event of emergency and acquire additional vehicles should allocated transportation prove inadequate. Compensatory Plan IV-13, 14. At the same time, the Town Manager is responsible to [A insure that' all Town Departments are adequately staffed and that appropriate and adequate staffing is provided throughout the emergency. Compensatory Plan IV-9. Since these responsibilities may continue on a 24 hours b asis , it is unreasonable to assume that the Civil Defense Director / Town Manager can continue to provide adequate transportation and personnel for the duration of an emergency as required by 10 C.F.K. !
$ 50.47(b)(1).
Additionally, even assuming that separcte individuals are designated I as Town Manager and Civil Defense Director for the Town, the Town believes that the numerous duties imposed on each of these individuals under the Revised Hampton RERP place an unreasonable and unrealistic burden on Town personnel in violation of 10 C.F.R S 50.47(b)(1). For example, the Town's Civil Defense Director is not only required te insure { adequate t transportation foF evacuees. but must fa rt h'er monitor all ) manpow er an d equipment requirements for the entire Town during an j evacuation of tens of thousands of peopla and determine "if these needs can be augmented with State resources." Revised Hamptofi"RERP IV-14. No provision is made in the Revised RERP in the event such State , resources prove unavailable and by default , these responsibilleies for ! acquiring additional vehicles or personnel would fall upon the Town Civil Defense Director. FEMA RESPONSE O Bas \>s E and F (Rev. 2) 1 See FEMA response at beginning of C9ntention. ' (%)
29. FINLW V' (Cont.) (G) The State Compensatory Plan relies upon local school officials, (3 under direction of a single local liaison, to evacuate the Hampton school students. In violation of NUREG - 06564, page 32, no letters of () agreement have been filed indicating any willingness on the part of these individuals to participate in, or accept responsibility for, these mandated responsibilities under the Compensatory Plan , Compensatory Plan, page
. 13A-14. Additionally, At is unreasonable to as officials responsible for evacuating the schools are of sufficient numbers, have adequate training, or will otherwise t,e available to evacuate the more than 2,600 Hampton school children in the event of radiological emergency. See Compensatory Plan, page 7A-7.
FEMA RESPONSE Basis G (Rev . 2) FEMA REP-1 does not reauirs letters of agreement with government . agencies, and thus FEMA does rot require letters of agreement with schools, or their staff. While schools are in session, it is the normal responsibility of the staff to provide for the safety of the student population. (H) The Compensatory PIEn provides that only a sing 16 Sate Police l vehicle will be provided to the Town of Hampten to " maintain security and to report on local road and traf fle condition." Comper.satory Plan, Troop A. New Hampshire State Police Emeigency Response Procedures: page 2. Since even the State acknowledges that Hampton may have an " upper peak O C/ seasonal population of 110,000" Revised Hampton Plan 1-11, it is wholly unreasonable to expect tnat a single police cruiser can maintain security and remain adequately apprised of toad ccaditions throughout the Town in the event tens of thousanda of individuals are attempting te evacuate Hamptmi. ihe Compensatory Plan further provides that troopers should not
' expedite the flow of traffic leaving the EPZ. . .at the expense of secess control functionc. " Compensatory Plan, Troop A Eriergency 1(esponse Procedure , page A-1. Accordingly, since vehicle breakdowns, accidents, stalled cars, and other impediments to evacuation must reasonabic be anticipated given the number of vehicles and evactecs, the Compensatory Plan makes no provision for State Police or other adequate personnel to maintain the accessibility of the evacuation roads.
Finally , the 28 treops assigned to access contrcl for Hampton are inadequate to insure reasonably prompt evacuation of the tens of [ thousands of vehicles leaving Hampton, as well as additional vehicles ' parsing through the Town from surrounding communities at the time of emergency, C6mpensatory Plan, Appendix C. page C '!O. There is no showing thut State Polica Teoop A has sufficient personnel to meet its responsibilities for acceos control, security and other duties for the Town of Hampton end other communities within the EPZ, or to augment this response on a 24 hours basis. 10 C.F.R. 5 50.47(1) . FEMA RESPONSE V Basis H (Rev. 2) See FEMA response at beginning of Contention. W /) } . _ - . - - _ _ _ _
' 29.
PEVISED RAMPION COf7IUTIION VIIf TO REVISION '2
- Revision 2 fails to provide adequate emergency eauipment, facilities ,
or personnel- to support an emergency response and fails to demonstrate
\' .) .'
that adequate protective responses can be implemented in the event of radiological emergency. 10 C.F.R. 6 50.47(1)(8)(10) . B ASIS: The bases for Contention VIII set forth in CONTENTIONS OF THE TOWN OF HAMPTON TO RADIOLOGICAL EMERGENCY RESPONSE PLAN ~ FOR THE TOWN OF HAMPTON, rJEW HAMPSIIIRE. NOVEMBER.1985, and Revised Contention VIII set forth in CONTENTIONS OF THF. TOWN OF HAMPTON TO REVISED RADIOLOGICAL EMERGENCY RESPONSE PLAN AND TO COMPENSATORY PLAN FOR THE TOWN OF HAsiPTON.. NEW HAMPSHIRE, are hereby realleged and incorporated by reference herein.
. FEMA RESPONSE:
See FEMA Response te, NECNP-RERP-8. O - I O m,
30, 1 K,ENSINGTON CONTENTION 1
- The December,1985 draft radf ological emergency response plan for the '
Town of Kensir;gton does not assure that eacn principal response organization has staff to respond and to augment its initial response on a continuous basis, as required by 10 C.F.R. 50.47(b)(1), because there are not alternates in several of the key emergency response positions and other departments are inadequately staffed to respond to an emergency as outlined in the plan. BASIS: There are currently no alternates for the positions of Civil Defense Director, Fire Chief, and RADEF Officer. With many of these individuals working out of the area on frequent occasions, continuous protection cannot. be provided without alternate individuals to act. in their pla:e. Additi on-ally, there is no transportation coordinator. FEMA RESPONSE In its Dec.1986 review of Rev. 2 of the New Hampshire Radiological Emergency Response Plans for Seabrook, FEMA and the Regional Assistance Committee (RAC) reviewed all municipal (EPZ) plans for their capacity to provide for 24-hour continuous operation for a protracted period. Speci f-ically P1anning Standard A.4 from FEMA-REP-1 defines this requirement. On page 6 of the Dec.1986 RAC Review of Rev. 2- Municipal' Plans, FEMA f ound that some key emergency response pos'itions do not have a back-up listed for second shift responsibilities. In Appendix A of the Kensington P1 an, there are no back-up personnel listed for the positions of Civil Defense Director, Transportation. Coordinator, RADEF Officer, Police Chief, Health Officer, Road Agent, or Town Clerk. Based on these review findings, FEMA does not have assurance that the Town of Kensington can implement its plan. Since Kensington has indicated that it will not actively participate in the planning and response for a possible accident at Seabrook Station, it is necessary to apply P1anning Standard A.4 to the State's ability to fully compensate for the Town of Kensington's emergency response functions. In its June 1986 RAC Review of Rev.1 of the NH Compensatory P1an for Seabrook Station, FEMA found that the plans did not adequately identify the personnel to carry out the State's Compensatory P1 an. The State responded to this by indicating that a resource allocation study was being conducted to identify the personnel and equipment necessary to implement local and State plans, covering all functions. Rev. 2 of the NH Plans still do not contain the results of this personnel allocation study. FEMA's findings are found on page 3 of the December 1986 RAC Review of the New Hampshire Compensatory P1an for Seabrook. Until New Hampshire develops this information as part of its planning base, FEMA has no basis to change its determination that the State has not demonstrated that it has adequate personnel resources to compensate for the non-participation of Kensington personnel. [See RAC Review of the O Compensatory P1 an, pages; 3(A.4); 6(H.4), 7(H.10)). p/)
6
- 31. .
l . KENSINGT6N CONTENTION 1 (Cont. )
. BASIS:
The' Kensington Volunteer Fire Department'is served by individuals who work'out Of town. - There is no assurance that fire department: personnel will be reachable or capable of responding in a timely manner in tne event of a radiological emergency. 1 The Police Chief in Kensington does not reside within the town and l there is no-assurance that he will be reachable or capable of responding promptly in the event of a radiological emergency during his off-duty hours. FEMA RESPONSE The availability of emergency response personnel to respond to an emergency does not necessarily depend on their working or living in the affected community, in this case Kensington. As loag as designated emergency response personnel can be reached by telephone or radio at their-place of work and' home and be able to staff their' posts in time to carry !- out their assigned duties, there is no reason to presume these personnel will not be reachable or able to respond. Since local community E00's - lr4..-ace-activated at.the Alert classification level, thereMe enough _ gQ time to mobilize and deploy emergency response staff to their respective
/"% posts. 'As discussed earlier in the response to this Contention, FEMA's Q concern is primarily with the number of local emergency responders.
In a fart breaking situation, the capacity exists to implement protec-tive actions such as sheltering without the local response organization being fully staffed. BASIS: The Kensington Road Agent is responsible for assuring a successful, smooth evacuation by clearing roads of snow, stalled cars, accidents, and otherwise assuring that the roadways' remain open for evacuation. Kehsington's Highway Department does not have sufficient personnel or resources to fulfill these responsibilities, and the comon arrangements for y hoc assistance by private contractors are insufficient to assure that these responsibilities will be met. Kensington has only one Road Agent, and relies on local con-tractors to assist as needed during winter storms. The Road Agent is also a volunteer fireman and medic and may be needed to perform other duties during an evacuation. FEMA RESPONSE FEMA's position concerning the availability of one road agent, with no back-up, is that this is not sufficient to ensure adequate coverage for this E0C position. The response to the first basis of this contention O
' explains fella's position in greater detail.
(51 )
t ll 32. p q I k,.-)U { R;E VISED KENSINGTON CONTENTION' 2 The NHRERP, Revision 2 for "TOK" does not provide for adequate "notifiestion, by the licensee of State and local response organizations, and for notification of emergency response personnel by organizations, as - required by 10 C.F.R 50.47(b)( 5 ) . Provision for notification of the town emergency response organization is in6dequate in that it depends upon notification through the Rockingham County Dispatch. 4 BASIL:
"TOK" will no longer te using Rockingham County Dispatch as of'the end of 1986.
FEMA RESPONSE.: This Contention deals with the means by which the Town of Kensington will receive notification of an emergency at Seabrook. In its review of - Rev. 2 of New Hampshire Plans for Seabrook dated December 15, 1986, FEMA and the RAC found that the Rockingham County Disptach Center had both^ adequate equipment and personnel coverage for providing notification to the towns. Thus, although the Town of Kensington may not use the Rocking-- O ham County Dispatch Center on a routine basis, there is no reason that it could not notify Kensington personnel in the event of an emergency at Seabrook. O n
t . H REVISED KENSINGTCN CCNTEt? TION 4 The NHRERP, Revidon 2 for "TOK" does not provide reasonable assurance that adecuate protective measures can and will be taken in the event.cf a radiological emergency at Seabrook Station, as required by 10 C.F.R. S 50.47 (a)(1), because the Kensington Elementary Scrool provides inadequate radio-logical protection. BASIS: The Kensington' Elementary School is currently proposed as a shelter for 'elegtentary school students in the event that sheltering is recommended. The elementary school in the Town of.Kensirgton is inadequate for sheltering children, the highest risk population, due to the fact that there are no interior roons, no basement, and all cla.ssrooans have a wall of windowsn. FD4A RESPONSE: This~ Contention deals with the suitability of the Kensington Elementary School as a shelter, with a Dose Reduction Factor at least .9. In that the New Hampshire Plan does not differentiate between studen's and the general O public regarding the suitability of sheltering as a protective action, and the Dose Reduction Factor inherent in virtually any winterized building is at least .9, FDiA has no reason to believe that the Kensington Elementary School. is unsuitable as a shelter. i l 0
~
34. \ G 1 REVISED KENSINGTON CONTENTION 6 The NHRERP, Revision 2, for "TOK" does not provide adequate arrangements for effectively using assistance and resources as required by 10 C.F.R. 5 50.47(b)(3) because there are not appropriate letters of
. agreement to identify support organizations and other facilities which are to provide assistance.
D ASIS : N UREG-0654 II C.4. requires that each organization shall identify nuclear and other facilities , organizations or individuals which can be relied on in an emergency to provide assistance. Such assistance shall be identified and supported by appropriate letters of agreement. "TOK" is not aware of a letter of agreement with Midway Excavators. "TOK" has been informed by Midway Excavators (not by NH State Civil Defense) that as of November 21, 1966 it will not be servicing any towns. Midway Excavators left "TOK" unplowed during the snow storm of November 19, 1986 and, in fact "never showed up" or called "TOK" to inform "TOK" that it would not be coming. Midway Excavators is servicing only State roads as of November 21, 1986. In AFFIDAVIT OF RICHARD H. STROME (CONTENTION KENSINGTON -6 AND CONTENTIONS SOUTH HAMPTON-1 ( AND 3) MAY 19.1986 in support of APPLICANTS' MOTION FOR
SUMMARY
Q] DISPOSITION OF KENSINGTON CONTENTION NO. 6 AND SOUTH HAMPTON CONTENTIONS NOS.1 AND 3 MAY 20,1986, Richard H. Strome states: at 3. "As to local tow or snow removal companies such as Midway Excavators, the state has adequate back-up rescurces should local contractors be unavailable to two or to plow the snow in the Town of South Hampton " In light of Midway Excavators action of November 21, 1986 in which it effectively transferred the resources of "TOK" to the State, "TOK" has serious questions as to the existence of the St ate's back-up resources and the adequacy of any resources the State purports to have. "TOK" no longer has a Snow Removal Agreement with Midway Excavators.
"TOK" does not accept as appropriate letters of agreement the letters of agreement with transportation companies. Many of these letters list raore buses and other vehicles than there are drivers. There are no letters of agreement for the already inadequate number of drivers.
FEMA RESPONSE: FEMA has addressed Town of Kensington P,ev.ised Contention 6 and its basis that there are not appropriate letters of agreement with Midway Excavators or with transportation companies by applying Planning Standards A, C, and J. (Evaluation Criteria A.3, C.4, J.10.g, and J.10.k) in FEMA-REP-1. The December 15, 1986 RAC Review of the State and municipal plans p reflect FD'A's views on this issue. Specifically, FEMA's review comments t
. 6 'i }
35. REVISED KENSINGTON CONTENTION 6 (Cont.) i (' on the New Hampshire State Plan on this issue are provided on pages 74, 74-b, and 85 of Section I, on page 1 of the Letters of Agreement subsection
- of Section IV, and on page 50 of the Compensatory P1an subsection of Section IV. FEMA's review comments on the municipal plans on this issue are pro-vided on .pages 5 and 6 of Section II.
FEMA relied upon the following documents in forming its conclusions on this issue: Revision 2 of the New Hampshire State Plan; Revision 2 to the municipal plans. For a response to this issue, see the FEMA response to South Hampton Contention 3. As noted in the response, there is no Letter of Agreement with Midway Excavating Company. However, it appears that there would be sufficient other resources available from the State to remove impediments to evacuation. It is noted, however, that Midway Excavating Company was not identified in the Kensington Plan as a provider of contracted services (see page C-3 of Appendix C of Kensington Plan). As also noted in the FEMA response to South Hampton Contention 3, which is applicable to the response to Kensington Revised Contention 6, the letters of agreement with transportation companies are considered by tne RAC to be adequate, q
- LJ
\
9 O m,
i i 36. ( REVISED KENSINGTON CONTENTION 10 The NHRERP. Revision 2 for "TOK" does not provide for communi-cationr, with contiguous State / local governments within the plume exposure
, pathway EPZ, as required by 10 C.F.R. 5 50.47 App. E.E. (9)(a),
because provisions for communications with the State government are inadequate. BASIS: NUREG 0054 F.1.b. requires provisions for communications with contiguous State / local governments within tne EPZ. The Kensington Emergency Operations Center (EOC) currently has only one telephone (red phone) for communications with State / local governments, located on the ground floor of the EOC, while the command post is located on the second floor of the EOC. Thir system is not adequete to allow necessary emergency communications. "TOK" asserts that there is no showing that the equipment exists. The NHRERP. Revision 2 for "TOK" at page 11-6 states: "This description is of the new communications system planned for the Town of Kensington. All of this equipment has been purchased, however the town has elected to accept only a portion of this equipment at this time." "TOK" hks not made such an " election". In AFFIDAVIT OF GARY J. CATAPANO RE KENSINGTON CONTENTIONS NOS. 2 AND 10 MAY 16,1986 in support of APPLICANTS'
SUMMARY
DISPCSTION OF g KENSINdTOIT CONTENTIONS NOS. 2 AND 10. MA Y 20,1986, Gary J. t
\
Catapano states at 5: " A dditionn] radio equipment was purchased for the Kensington Police Department as part of a complete reconfiguration of the existing communications net work and installation was begun. (Installation was halted, insofar as I am aware at the direction of some official of the Town." No official gave such direction. "TOK" has never refused equipment. . FEMA RESPONSE: This Contention deals with the adequacy of communications equipment to contact contiguous State and local governments. Equipment already in place would allow Kensington to communicate with State / local governments. The availability of additional radio equipment, already purchased and ready for installation, would certainly enhance the town's communications abilities. (See FEMA /RAC Review of New Hampshire Municipal Plans, December 15,1986, pp 9-10). O ( T '? )
37. NECNP Contention RERP-2
'( The New Hampshire REDP violates 10 C.F.R. I 50.47(b)(3) as implemented by NUREG-0654 H i II.C.I.b in that the state has not specifically identified all areas in which it requires federal assistance or the extent of its needs; nor has it made arrangements to obtain that assistance; nor has it stated the expected time of arrival of Federal assistance at the Seabrook site or EPZ.
BASIS: NRC regulations at 10 C.F.R. I 50.47(b)(3) require that
" arrangement for requesting and effectively using assistance resources have been made: before offsite plans may be approved. liUREG-0654 further provides that each state "must make provisions for incorporating the Federal response capability into its operation plan , " including
" specific Federal Resources expected", and their " expected time of arrival at specific nuclear facility sites." f il . C . I . b . The New Hampshire RERP does not comply with these requirements in several respects. First, the RERP does not specifically identify all of the state' needs for assistance from the federal government. Section 1.4.5 identifies a need for support from the Boast Guard and Federal Aviation Administration for restriction of the coastal waters and the airport. The plan also identifies a need for
" shellfish contamination screening" but does not describe the agency that it expects help from. Section 1.4.4 also vaguely describes the state's need for nontechnical and technical support , including " radiological monitorin g. " The exact nature and extent of these needs is not described. .
This generalized identification of need does not give the Federal government sufficient notice of the state's expectations for assistance, nor does it give sufficient assurance that the necessary steps will be taken to protect the public health and safety. The plan must instead identify the particular functions that the State cannot carry out, and the equipment and number and qualifications of Federal personnel needed to carry them out. Second, the plan speaks of requests for aid as a future task. RERP 56 1.4.4, 1.4.5. There is no indication of the time at which Federal aid is to be arranged for--whether it is sometime in the near future, or after un emergency has occurred. In order to assure that Federal aid will be made available promptly upon request, specific types of Federal assistance must be prearranged by written contract with the Federal government. The arrangements for Federal aid must include an indication of when the i e.id is expected to arrive in the EPZ, as required by NUREG-0654 ! ! 11. C .1. b . Without these measures, there can be no reasonable assurance that the stato plan can and will be implemented. Limited as to required federal assistance , Board Order, 4/1/86. FEMA RESPONSE: This Contention deals with the areas in which the State requires federal G assistance, especially from the U.S. Coast Guard and for shellfish exam-Q ination, in the FEMA /R AC Review of December 15, 1986, it was founa that the deficiencies noted ir Rev. 1 of the New Hampshire Plans with respect to this matter nac been corrected (see page 14 of the State Plan Review). (5 S I
- 38. i l
{
,m) NECNP CONTENTION-RERP-8 v
The New Hampshire RERP does not provide a " reasonable assurance I that adequate protective measures can and will be taken in the event 50.47(a)(1). in of a that radiological emergency " as required by 10 C.F.R. the plan does not provide reasonable assurance that the Nor does sheltering is an plan provide
" adequate protective measure" for Seabrook.
adequate criteria for the choice between protective measures, as required by 5 50.47(b)(10) and NUREG-0654. 9 II.J.10.m. FEMA RESPONSE to Revised Town of Hanoton Contention VIII to Revision 2 (of the New Hamosnire RERP for Seabrook) , SAPL Contention 16, and NECNP Contention RERP-8 These three contentions all deal with what is fundamentally the same issue: protection frcm a radiological release for beach-going population at Seabrook who do not have ready access to any effective form of sheltering. This group includes both " day-trippers to the beach and those persons who only have access to unwinterized or other types of construction which will offer a lesser degree of protection than that offered by standard residential or cm mercial buildings. This issue has been of great concecn to FEMA fran our O Backcround - earliest detailed involvement with the preparation of plans and the achieve-V ment of a level of emergency preparedness which would achieve our regulatory standard set for that 44 CFR 350.5 of adequately protecting the public health and safety by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency at the Seabrook Nuclear Power Plant. In Ibcember 1985 the State of New Hampshire submitted plans for protecting the public in the event of an accident at Seabrook to FEMA for review pur-suant to 44 CFR 350. Those plans were forwarded for review by the Regional Assistance Committee (RAC), an interagency group established pursuant to 44 CFR 350 to both assist state and local government in the developwsnt of radiological emergency response plans and to evaluate the adequacy of such plans. On December 31, 1985, FEMA, as chair of the RAC, requested that the members of the RAC (as well as the other FEMA staff who were reviewing ) the New Hampshire Plans) immediately focus on the issue of the protection of beach population and the occupants of unwinterized acccrmodations. This 3 menorandum is attached as Appendix C to tnis response' to interrogatories. l
)
FEMA Position - Since the time of our December: 31, 1985, nemorandum on the subject of the protection of the public on and near the beaches around Seabrook, the State of New Hampshire has refined and improved its j emergency plans and sutnitted a detailed Evacuation Time Estimate which i ' sheds a considerable amount of light on this issue. The facts relevant l to understanding this issue are that: I 1 6 '/) l l
s F I' J' 39.
"EC"P C01TmTION ?OD-8 (Cont.)
C (1) The primary guidance doctment used by FEMA and the RAC in reviewing off-s ite emergency plans 'is. WUREG-0654, FEMA REP-1, Fev.1, a doctrr.ent jointly developed by FEMA and the NRC. That guidance document indicates on p.13 that "(t)he range of times between L- the onset of accident conditions _and the start of a major release is of the order of one-half hour to several hours". This statement is further clarified on p.17, Table 2 to indicate that (a)' the major portion of a release may occur in a tim period ranging from as little as one-half hour to one day af ter the release begins and (b) that the travel time of the release to exposure point can range fran one-half hour to two hours at five miles, and one hour to four hours at ten miles. (2) On peak summer days there are thousands of beachgoers in the Seabrook EPZ in areas beginning approximately 1.7 miles from the plant. We current New Hampshire plans contemplate evacuating the many thousands of beachgoers who have access to no adequate shelter as a protective action in the event of an accident at Seabrook. We understand that the plans contain no consideration of sheltering the " day trippers" because on sumer days when there are a large number of these people, it is not possible to find reasonably accessible shelter for them. Were are an additional number of persons who would be in or have access only to shelter in unwinter-ized cottages and mtel rooms. De protection afforded by sheltering in these structures will definitely be less than that afforded by a normal wood frame house. / (3) The Evacuation Time Estimate for the Seabrook EPZ submitted by the State of New Hampshire indicates at pp.10-1 et. seq. that in good weather when the beaches are at 60 to 100 percent of capacity it will take three and one-half hours to clear the beaches, and a total of from four hours and fifty minutes to five hours and fifty minutes to evacuate all the population on the beaches from the EPZ. In same situations such as sudden bad weather following a peak summer day, the total evacuation time for portions of the EPZ range up to seven hours and fifty minutes. Werefore, using the standard guidance for the initiation and duration of radiological releases, and the current New Hampshire RERP lacluding ETE, it appears that thousands of people could be unsble to leavy tarirg an accident at Seabrook involving a major release of radioact6ity without adequate shelter for as much as the entire duration of that release. Therefore, until these issues are resolved even if all the other inadequacies and deficiencies cited in the RAC Reviews of the New Hampshire Plans, and the Review of the Exercise of these plans were to be corrected, FEMA would not be able to conclude that the New Hampshire State and local plans to protect the public in the event of an accident at the Seabrook Nuclear Ibwer Plant are adequate to meet our regulatory standard that such plans
" adequately protect the public health and safety by providing reasonable l assurance that appropriate protective measures can be taken offsite in the .
event of a radiological emergency." (See, 44 CFR 350.5(b)). O 1 y l
40. NECNP CONTENTION NHLP-2 The local emergency response plans for New Hampshire communities within the plume exposure emergency planning zone do not assure that "each principal response organization has staff to respond and to augment its initial 50.47(b)(1), in the response on a continuous basis," 10 C.F.R. 50.4 7. following respects: . a. The police forces for the towns surrounding Seabrook do not have sufficient personnel or resources to carry out their responsibilities under the plan.
~
- d. The plans contain no demonstration that private companies or individuals who will be depended on to assist i.n.an emergency will actually be able, committed an'd willing to perform those functions,
- g. Under the plans, the local fire departments are responsible for such tasks as assisting in monitoring the evacuation, for decontamination of of affected individuals, operating and maintaining the E0C or the public alert system (PAS), and assessing emergency transportation needs. The local fire departments do not have sufficient personnel or resources to fulfill these responsibilities.
- h. There is no assurance that local emergency response personnel will be reachable or that they will be able to respond soon enough to assure protection of the public health and safety.
O .
- 1. The local plans do not provide for adequate backups or alternates for important positions in the event that assigned personnel are not available.
J. Many of the posts crucial to an effective emergency response have not yet been filled. , FEMA RESPONSE: FEMA's position on this Contention, overall, is the same as that for the other personnel resources contentions (Kensington 1, Hampton Falls 2, South Hampton 2, Hampton 6, and SAPL 8) which is FEMA does not have assurance that there exists the capability to staff local emergency response positions for an initial response, and to augment that response on a continuing basis, since there are numerous positions in the local emergency response organiza-tions which do not have alternates (P)anning Standard A.4, page 6 of RAC Comments for Municipal Plans). Similarly, the State has not adequately demonstrated in its planning that it has the capability to fully compensate for non-participating localities and localities needing supplemental State assistance (cee RAC comments on page 3 of Compensatory Plan review, Planning Standard A.4). FEMA's responses to the six basis of this Contention are as follows: Basis A - This basis concerns the Ldequacy of the staffing of local police forces to carry out their responsibilities, as identified in the local plans. ( [
U' FEMA RESPONSE 3
.n. aL :
NECNP CONTENTION NHLP-2 (C' o nt.) ." p n . u it is not clear to FEMA what. procedure (s) the local police are to fol-low to assist with public alerting and notification. The system of public notification is primarily.a State responsibility, with activation of the - system to occur at the Rockingham County Complex. Each local community has-back-up activation capability, which physically involves no more than the pushing of several buttons. This is not resource-intensive at the. local level. However, if there are siren failures, then'is the police chief responsible for implementing route alerting (which could be resource , intensive)? See RAC comments for item J.10.c. on page.18 of the Municipal ' Plan Review. The following tatulation shows the total number of local police, as identified.in Appendix C of the respective local plans, versus the number of personnel necessary to staff local traffic control posts for each -espective., community, as found in Table 8-6 of Volume 6 of the New Hampshire State Plan. I EOC Police Secur-[l Total ,l
- TCP l Fuil l Part l Total - Staff ity
'I Greenland 3 3 - 3 , 1 4 l \
Kingston l 4 3 l 7 - 5 . , 1 6
- k. Kingston 4 4 - 3 l 1 4 l
g Xensington 6 l 6 - 3 1 4 , l
- 3. Hampton 5 l 5 - 2 1 3 Rye 7-10 17 27 5 3 1 4 l
Newfields 1 l 6 l 7 - 4 1 5 l New Castle 3 ! 7 lI 10
- 2 1 3 I l Hampton Falls l 1 l 3 l 4 - 1 1 2
\ l \
Stratnam l 5 3 I 8 - 4 1 5 1 - l Exeter l 19 13 1 32 - 10 1 11 Brentwood 10 l 10 - 3 1 4
' - 28 Hampton _
! 24 I 50 l I
74 - )8f 1 29'l Js As can.be'seen, local police resources (both full-time and part-time) range from" marginal to more than' adequate for traffic control. O I w f ;
42. FEMA RESPONSE NECNp CONTENTION NHLP-2 (Cont.) {%) When you f actor in the responsibility of providing security at the local E0C and normal police duties, all of which require 24-br staf fing,
.- it is apparent that the lown of Greenland will need cutside assistance and the Towns of Kingston, E. Kingston, Newfields, and Stratham may need limited assistance due to the fact there are not alternates for all necessary police personnel. The Towns of Kensington, So. Hampton, Rye, Hampton Falls, and Hampton have indicated their intentions not to participate in the emergency response organization, thus shifting the responsibility for emergency response onto the State. See comments at beginning of this Contention.
a Basis D g Letters of agreement for towing companies and bus transportation com-panies are now found in Volume 5 of the State Plan, and are referenced as such in each local plan. This is appropriate, since the State now controls the distribution of these resources. FEMA and the RAC found the State's resources for removing impediments to evacuation were adequate (see page 85 of the RAC Review of State Plan, item J.10.K). Additionally, the RAC found that the letters of agreement with transportation companies were generally adequate (see RAC Review of State Plan, pages 74 and 74-b, item J.10.g; pg.1 of RAC Review of Letters of Agreement, items A.3 and C.4). Basis G The designation of volunteer firefighters as local emergency workers is not uncommon or inappropriate. As long as designated emergency workers can be reached at home and work, and can travel to their assigned posts in time to fulfill their emergency responsibilities, there is no reason to conclude that the use of volunteers is inadequate. FEMA has not determined whether the number of fire department person-nel, both full-time and volunteer, is sufficient to cover assigned duties in all municipalities, since the State's Resource Allocation Survey is not t yet completed and submitted to FEMA (see RAC Review of Municipal Plans, page 6, Planning Standard A.4). Basis H As stated above for Basis G, there is nothing intrinsically wrong with designating part-time personnel as local emergency workers, so loag as they can be reached at work and home and arrive at their assigned posts in time to fulfill their responsibilities. Since emergency workers w mhLbe mobilized g' g at the ALERT stage, this p allow sufficient time to travel to emergency response posts. In a more rapidly developing emergency the plan provides for 3 alerting the public to take protective actions without fully staffing the State or local E0Cs.
\
gl A
/ /,
a- _ - _ - - _ _ _ _
43. FEPA' RESPONSE
/
- NECNP CONTENTION NHLP-2 (Cont.) -
O The ability to alert and mobilize emergency workers, whether full-time or part-time, is something that is frequently tested in exercises. FEllAg4 judgment about this matter will be made at the next Seabrook Exercise. Basis I See FEMA response at beginning of Contention.
. Basis J With the exception of Hampton Falls, all key emergency response positions have been filled. However, many do not have alternates. See response at beginning of Contention.
O l (64)
44. NECNP Contantinn NHLP-6 The local emergency plans do not provide for an adequate range of protective actions , 10 C.F.R. I 50.47(b)(10), because they contain [ inadequate means of relocation or other protection for those with special N needs, those without private transportation, school children, or persons confined to institutions or elsewhere for health or other reasons. Moreover, the resources available to the towns for these purposes are inadequate to provide a reasonable assurance that the public .will be
. protected in the event of an accident.
FEMA RESPONSE FEMA has addressed Amended NECNP Contention NHLP-6 and its basis of in-adequate means of relocation, and inadequate resources in host communities, by applying Pl anning Standards A,C,E,H,J, and L (Evaluation Crittria A.3,C.4, E .7,H.l l .J .10.h ,J .10.g ,J .12, L .1, L .3, a nd L .4 ) i n FEMA-RE P-1. The December 15, 1986 RAC review of the State and municipal plar.s re-flect FEMA's views on this issue. Specifically, FEMA's review comments on the New Hampshire State plan on *.his issue are provided on pages 12, 34, 74, 74-a, 74-b, 74-c,113, and 114 of Section I, and on page 1 of the letters of Agreement subsection of Section IV. FEMA's review comments on the Host communities municipal plans on this issue are provided on pages 10, 12, 15, and 16 of Section III. FEMA relied upon the following documents in forming its conclusions on this issue: Revision 2 to the New Hampshire State Plan; Revision 2 to the municipal plans. . FEMA does not yet have assurance of the adequacy of plan provisions for means of relocation and resources at host communities. Responses to specific portions of Amended NECNP Contention NHLP-6 are provided below. . III. Amendments to Contention NHLP-6 A. The following basis is substituted entirely for the basiy supplied in NECNP's contention NIILP-6, dated . February 24, 1986: .
- a. In many cases there is a telephone number to call for those without private transportation who need relocation assistance. Such a provision is inadequate not only because of the vulnerability of telephone systems in the vent of an emergency, but because even if the telephone works, there is no assurance that the assistance will be available to all who need it. Moreover, the telephone systcm in the EOC may be overloaded. Fop example, there are 1,798 people in Exeter who have no transportation FEMA RESPONSE (a) The revised municipal plans no longer require telephone calls to the E0C at the time of the emergency to request relocation assistance. Pre-designated bus routes or pickup points are now used to provide transportation O for residents and transients requiring transportation. These bus routes are shown on public information material distributed annually to residents. EBS messages will also direct residents to these routes or pickup points (e.g.,
Exeter plan pages 11-32 and 33). Identification of those people with special needs is done by return of a special postage-paid survey card which is included (d i)
45. NEC3P NHid-6 (Cont.). in the public information material (e.g., Exeter plan page 11-33). The listings of those people w.ith special transportation needs is held by local-O' officials in the communities for purposes of transportation resource planning. It -is, therefore, not necessary for people to call in to the local E0C to 'ob-tain transportation assistance, except for those people who-have not previously notified-officials of their special needs, and are unable to get to a pickup point on a bus route. As noted in the local plans-(e.g., Exeter plan page 11-33), these requests will be handled on an ad hoc basis as the people. call in to the E0C'or State number provided in the compensatory plan to request assistance. The contention refers to 1798 people in Exeter who have no transportation. The means of obtaining that information is 'not described and. differs signifi-cantly from the figure used by the State for planning purposes in Vol.Wof - 4f the State Plan. At this time, FEMA has no reason to believe the State't figures are-incorrect.
- b. Residents requiring transportation will have to report to the nearest bus route loc Ofon for pick-up . Durintr a radiological emergency, ma}dng an estin.u.e of the arrival. time of these buses at any given point will be . nearly impossible. Thus, people without transportation may find themselves standing outside during an emergency for an undetermined _ amount of time, waiting for a bus to come along the route. Evacuees may be ' exposed to unacceptable levels of radiation while waiting outside for c bus. Discouraged evacuees might also further risk exposure by returning to their homes and giving ,"up on , evacuating.
A " Latchkey" children who are at -home whfie their parents are at work may V also fall to call for help or to understand directions regarding bus pick-up. FEMA RESPONSE _ (b) The plan anticipates that evacuation buses for residents requir-ing transportation will make. multiple runs along the pre-designated bus routes (see ETE, State plan Volume 6, page 11-11; Hampton plan, Public Works Director procedures, pages IV-31 and IV-32). Therefore, it will not bc necessary for residents to arrive at pickup points at an exact time. The lengtn of time people will be waiting outside for buses will also be mini-mized by this method. The times required to mobilize buses and evacuate the people.have been estimated in the ETE. These estimated times will be used as one of the variables in protective action decision-making described in State plan Section 2.6,7. In other words, the possibility of evacuees i being exposed to radiation while waiting outside for buses will be taken into l account in the decision to evacuate or shelter. l O (66) L - __ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
46. YM NWJ-6 (Cont.) (3 c. The RERP does not provide a reasonable assurance of Q safety for school children who may he evacuated in a radiological emergency. For example, the Hampton plan notes that "{iln the event of an evacuation, the State Resource Coordinator will direct the dispatch of - buses from the State Staging Area to the Local Staging Area (EOC) where they will e provided maps and directions to the schools." Vol.18 at II-29. The ~ State RERP instructs the Director of Pupil Transportation Safety to "have the available drivers and buses (which normally service . the schools) report to their appropriate schools with adequate fuel in the buses." Vol. 4B, Pupil Transportation Safety Procedures at 2. Thus, it is r.ot clear where buses will go and from whom they will receive directfons. FEMA RESPONSE (c) Although not specifically commented on in the RAC review, there is some discrepancy in the plan and procedures as to where the buses that evacu-ate schools report to. For example, the Hampton local plan (Volume 18, page 11-29) states.that ."the State Resources Coordinator will direct the dispatch of buses from the State Staging Area to the Lucal Staging Area (EOC) where they will be provided maps and directions to the schools." A similar de-scription is provided in the Exeter plan (Volume 26,,'page 11-31). Conversely, A the State plan procedures for the Director of Pupil Transportation Safety h (Volume 4B, p. 2) state, "have the available drivers anc buses report to their appropriate scnoots " The LOC Resource Coordinator procedures in Volume 4 of the State plan also state, "have the Director or rupii fr ans-portation Safety instruct available drivers and buses to report to their appropriate schools" (page 7-3). The logistics for mobilizing evacuation buses to the schools need to be clarified and made consistent in the State and local plans. 1 O L & /) \ l 1
l U* NEC@ MEP-6 (Cont. )
- d. According to Revision 2, the State of New . Hampshire now
%/ intends to coordinate the dispatch of buses to schools in the EPZ.
However, the State has not demonstrated that this can be done in ' an efficient and timely manner. The cumbersor:e process ' of dispatching school . buses invites confusion and delay. The bus companies will need to i
- contact their buses and drivers, and be in continuous contact with the State staging area to update resource availability. If the regular drivers are not available , the Teamsters union or other drivers who may act ac substitutes will have to be contacted, get to where their designated bus
! is storied , and acquaint themselves with tasks such as learning a route and farr.iliariting themselves with an unfamiliar bus. The State staging
- area will need to determine how many buses have gone directly to schools, and therefore how many are needed to go to local staging areas.
l- The local staging areas will have to make their needs known to the State hgency, and will therefore need to be continuously updated on the number of buses headed directly to the schools . The schools and the local staging area will need to be in constant contact as well, so that the school can inform the local staging area of the arrival of normal buses and make its needs known to the local staging area nich will transfer that information to the State staging area, who will be in direct contact with the needed resources. The amount of time involved in gathering all of the necessary information and coordinating a response from the State Staging area will be enormous: the task is far too cumbersome to assure adequate protection to the evacuees who rely on buses. FEMA RESPONSE (d) Procedures in the State and local plans need to be clarified to ensure that the State can efficiently coordinate the dispatch of buses to the schools for evacuation. As noted in the preceding response for item
"(c)," there are inconsistencies which need to be resolved in where the buses report to. Also, as noted in the response to further basis item A.3 in the response to reviseo Hampton Contention IV, there are no details in the plans as to how the supplementary Teamsters' local No. 633 bus drivers will be notified and coordinated with available buses, or, for that matter ow many Teamsters will De released by their employers for emergency respolise O
w
12CND MEP-6 (Cont. ) ..
- c. The RERP indicates that the normal drivers and buses will f be counted on substantially, regardless of the time of day, schedule of
\ drivers , and availability of buses, to perform the functions that they perform at the beginning and end of a school day. Vol. 4 B . Pupil transportation Safety Procedures at 2. This assumes that~ the regular drivers are the same drivers that have been guaranteed in the letters of
- ogreernent. Nothing in the letters of agreement with the bus companies demonstrates that the same drivers , familiar with the route, will be 4 available. For example, a driver with Timberline in Portsmouth told us that many drives have second jobs, live far from the bus company, or are unteachable in between runs. She also told us that the regular school buses were not sitting in the lot all day in between the start and the end j of the school day, but are on the road for special runs and field trips as j much of the time as possible. In addition, many of these buses do not have radios, so even if they were close to the EPZ, they may not be
( reachable. Thus, there may be a large number of the normal school buses and drivers who will not be available during a radiological emergency. FEMA RESPONSE (e) Although the use of drivers and ouses whicinormally t~ryt school children will be used for tvmuation trensnortation to the greatest I /ta y extent possible, the plan provides for supplementary resources as needed. As noted in the response to item A.1 in the further basis to revised Hampton Contention IV, the RAC has concluded that, although there are numerous in-consistencies in ' bus needs estimates, overall the numbers of buses and drivers available according to the Letters of Agreement in Volume 5 of the State plan are sufficient. (See pages 74, 74-a , 74-b, 74-c of December 15, 1986 RAC review of State plan Section I, and page 1 of Letters of Agreement , subsection of Section V.) However, as mentioned previously, FEMA does ' have a concern about the provisions in place with the Teamsters' employers to release them when needed. d O e - _ _ _ = _ _ _
NECNP NHLP-6 (Cont. )' 49 , B. Cint::ntion HP-1: The host plans for Manchester, Dover, Salem, and Rochester, do not q meet the requirements of 10 C.F.R. Sections 50.4"fa), 50.47(8), (10), q) (11), and (13), or NUREG-0695, Sections J.12 and K.S.b. B ASIS : , n. NUREG-0695 requires that the personnel and equipment at relo-cation centers should be capable cf monitoring within about a 12 hour period all residents and transients in the plume exposure EPZ arriving at relocation centers. Section J.12. MANCHESTER:
- 1. The Manchester relocation center does not contain enough equipment to assure that all individuals can be administered the quick one minute check for contamination before entering the reception facility for registration (the check would take over 40 hours if all the available monitoring equipment were used only for this checkpoint), nor enough to do a more thorough check on those evacuees who are contaminated to find out where the contamination is. Only 3,060 of the 20,000 expected evacuees could be scanned in 12 hours in the decontamination facility if all of the available monitoring equipment were used only at this checkpoint. This is only for the first scan in each case. However the lans call for several scans in the decontamination facility per person.
Moreover, it is absurd to assume that evacuecs,'would stand in line (f.s') for this long before being able to register and begin rendezvous process.
\_/ It is very likely that the host facilities will be abandoned by most evacuees when the inefficiency becomes apparent, leaving people without access to the organized method of finding one ancther within the reception area. Those discouraged individuals may seek shelter in other parts of the State or outside the State, thus spreading radioactive contamination as they travel. .
i
- 2. After twelve hours, the Manchester facility is {
scheduled to become the only facility that will handle the decontamination j of emergency workers. Vol. 36 at B -2. Obviously, monitoring and decontamination of the general public will still be underway at that time. Thus, there is no reasonable assurance that the Manchester relocation center een meet the needs of emergency workers. ROCHESTER:
- 3. There will not be enough equipment in the Rochester relocation center to assure that everyone can be administered even the quick one minute check for contamination before entering the reception facility for registration. The plans do not clearly state how many CDV-700 surveying instruments will be available for use in Rochester.
However, there will be four radiological monitoring kits, and therefore no more than four CDV-700's can be counted on. Vol. 35 at !!-11. facilit for d contamination. ol 35 a I-8 f Q(7 CDV-700 s for the initial scanning, it will take the last evacuee 143 hou s adeEuste protection to the vacuee ity. This clearly will not provide ( ~70 1
- _ _ _ - _ _ _ _ _ _ ~ _ ._. __ __ -__ _ _- . __ - . _ _ _ - NECNP NHLP-6 (Cont.) 50. DOVER: 4. There will not be enough equipment at the Dover host g facility to assure that everyone can be administered even the quick one minute check for contamination before entering the reception facilities for registration. There will be 43 CDV-700's available for use in Dover during a radiological emergency. Vol. 33 at II-11. There could be 57,000 evacuees coming to Dover for decontamination. Vol. 33 at I-10. Just to get everyone into the reception facility after one scan will take 22 - hours. SALEM:
- 5. There will not be enough equipment in the Dover host facility to assure that everyone can be administered even the quick one minute check for contamination before entering the reception facility for registration . There will be 3 CDV-700's available for use in Salem during a radiological emergency. Vol. 38 at I1-11. There could be as many as 29,000 evacuees coming to Salem for decontamination. Vol. 38 at I-8.
Just to get everyone into the reception area after one scan cdil take 161 hours. FEMA RESPONSE (B) Host Plans (HP-1 ) (a) Manchester (items 1 and 2); Rochester (item 3); Dover (item 4); and Salem (item 5). The RAC, in its December 15, 1986 review, has concluded that the host (7 plans are inadequate to determine if there are adequate resources (equip-O ment and personnel) to support the monitoring and decontamination operations for the anticipated number of evacuee arrivals in a 12-hour period. As indicated by the RAC in its review of the host community plans (Section III, pages 10 and 15), the descriptions of the number of staff members required for monitoring and decontamination activities is provided in Appendix B3 of each host community plan. However, it is impossible to assess from the ' plans if the number of staff positions are adequate to support the operations for the anticipated number of evacuee arrivals in a 12-hour period, and if there are enough trained personnel available locally to fill the required number of staff positions. Call list rosters for local personnel (see Appendix B9) are not yet available. In addition, it is also not known if the , number of monitoring instruments available (see Section II.E.4) is sufficient to support the operations. Seccion II.E.4 of each of the host community plans refers to CDV-700 survey meters. Although the meters are also listed on the inentory sheets provided in Appendix B8, there is no indication on the inventory as to the quantity of survey meters (and dosimeters) on hand (see p. B8-1). It is recommended that the total number of each item on hand be indicated on the inventory sheets. The RAC recommended that in order to clarify the capabilities and ade-quacy of resources to perform the monitoring and decontamination operations, the plans should clearly specify the assumptions used in preparing the staffing lists indicated in Appendix B3 and the equipment resources indi-D cated in Section II.E.4 (i.e., what are the total number of evacuees ex-( pected to arrive at the moriitoring and decontamination facilities of the reception center, and what percent of the evacuated population does this number represent?) L9t !
I' ED@ NHLP-6 (Cont. ) 51.
- b. The human resources available according to the plans are
,m inadeouate to protect the public health and safety. All of the host plans (O) - regardless of the size of the populations they are expected to serve -
provide for 94 staff members to perform the many diverse tasks associated with the facility. Vols. 33, 35, 36 38 at B3-1, -2 Not only are these numbers inacequate on their face, but the State clearly has applied a generalized formula without making any attempt to determine what are the staffing needs of each separate facility. FEMA RESPONSE (b) (See response to previous item "(a)" on the need for additional supporting information on the staffing resources.) l l
- c. The plan does not assure that everyone evacuated from the EPZ will go to a reception area. Vols, 33. 35, 36, 38 at I-11. Without p)
(" an assurance that every evacuated person and every evacuation vehicle is scanned for radiological contamination and decontaminated if necessary, a pub!Ic hazard in the form of radiologically contaminated people and j vehicles will go unchecked throughout the state, into other states and to ' Canada. In addition , there is no assurance that people who miss decontamination services at the host community will be able to obtain them i anywhere else in a reasonable amount of time, since few hospitals have extensive decontamination capabilities. Vol. 1 at 2. 8-5. { j l F_EMA RESPONSE (c) The sample prescripted EBS messages contained in the State plan state that monitoring and decontamination services are available to evacuees at the reception enters (NHCDA Procedures, Volume 4, Appendix G, pages G-31 and G-37 ) . However, as noted by the RAC comments (Section I, page 24), the RAC recommended that in the case of a contaminating accident in which people may actually have become contaminated the messages should specifically direct evacuees to gc to reception centers for monitoring. l 71
NILHP NHLP (Cont. ) 52.
- d. . The plan does not adequately accommodate the
. decontamination needs of evacuated hospittil patients and nursing home residents. Since the decontamination of these individuals will occur at
- ( their. host health care facilitics, they will need to wait for the arrival of a CDV-700. which will already be in great demand at the reception center.
Likewise, the monitoring ' team trained to perform decontamination to be dispatched reception center. to these facilities will have more than enough to do at the In addition , there are no procedures for how to-decontaminate these -individuals in the plans. Further, the host medical facilities may risk exposing regular residents to radiologically , contaminated materials. Vols. 33, 35, 36, 38 at B-3. FEMA RESPONSE-(d) Based 'on the description on page B-3 of Appendix B of the host community plans, monitoring and possible decontamination of evacuated hospital patients or health care facility residents will not be performed by staff at the health care host facilities, but by. personnel from the same resource pool supplying staff for monitoring at the reception centers. Since the adequacy of staffing and equipment for monitoring and decontami-nation at the reception centers fs in question, the availability of staff and equipment to be dispatched to the health care host facilities is also in question. (See response to previous item "(a)" on the need for additional supporting information on the staffing resources.) U O ov i
NECNP NHLP-6 (Cont.) 53.
- e. It is not clear that injured contaminated evacuces or internally contaminated evacuees will be accommodated by the plans. Both O sets of people, are to be ' referred to the DPHS Supervisor.
36, 38 at B-4. However, there is no indication of what s/he wiu do udth them beyond the vague activity of referring them to medical authorities, Vol. 33, 35, how s/he will base decisions, and whe.t facilities will be available for these pecple. For example, the two Manchester hospitals that are listed in Volume 1 of the RERP are Catholic Medical Center, which has no decontamination capability, and Elliot Hospital, which can handle one contaminated patient per hour. There is no reasonable assurance from
. . this that medical care will be available for injured and contaminated or internally contaminated individuals.
FEMA RESPONSE l (e) The December 15, 1986 RAC review concluded that the plans have adequate provisions for medical services for contaminated injured individ-uals. As noted in the RAC review (pages 113 and 114 of Section I), hospita!- capabilities are listed on Table 2.8-1 of the State plan (pages 2.8-5, -5A, and -5b). Letters of agreement from these hospitals are included in Appendix H of Volume 2 of the State plan. The handling of injured contaminated ' individuals who arrive at the reception centers is described in procedures for the OPHS Supervisor, the EOC RHTA, and DPHS Director in Volume 4A of the State plan. Based on the individual case, the individual may then be transported to one of the p hospitals listed in Table 2.8-1 of the State plan. As noted inn the RAC review of the host community plans, this will be handled by coordinating with the State on a case-by-case basis (page 16 of Section III). O , ao
54 NECNP NHLP-6 (Cont.) 1 - (/ f. The host facilities coordinator is charged with the task of identifying personnel who may provide emergency medical treatment on-site . No explanation of how this will be done or where the host coordinator will find these people is demonstrated in the plans. Vols. 35,
. 36 at III-70 Vols. 33, 38 at III-6.
FEMA RESPONSE l (f) The method or means by which the Host Facilities Coordinator identifies " personnel who may provide emergency medical treatment on-site" is not clear in the plans. For example the Dover Host plan (Volume 33) indicates on page I-17 that the City of Dover Health Officer will, " Assist the DHS, DPHS, and ARC in identifying and treating health problems of evacuees." The Dover plan also states on page 11-10 that, " Medical support will be supplied by the Rescue Section Chief of the Fire Department. Went-worth Douglas Hospital will provide shelter for evacuated patients who need skilled nursing care." On Page 11-;14, the Dover plan also indicates that the DHS will provide " medical services references" at the reception center. The State plan procedures (Volume 4B, Division of Human Services, Appendix B, oage B-7) also indicate that several state agencies are available to support the Reception Center activities, and that the Division of Public A Health, Emergency Medical Services can provide embulance service support and medical facility references. Thus, whi h it appears that sufficient medical i.") resources would be available, it is not clear in the plan now the Host Facili-ties Coordinator coordinates these resources, and which source is most appro-priate. The plans should be revised to clarify this issue. O m
(< 1, . i 55. f'
}- NECNP !HP (Cont.)
- g. Although there 'is a letter of understanding with the Rod Cross that it will.take responsibility for feeding, clothing, and sheltering all evacuees who have those needs, there is no demonstration of a Red Cross capability to provide these services to the huge number of people Vol. 5 Statement of ' Understanding between the
- - who may ~ need them.
State of New IIampshire and the American Red Cross. FEMA RESPONSE (g) The RAC review of the host community plans (page 12 of Section III) indicated that the mass care facilities appear to have adquate capacity. Trie Statement of Understanding with the Red Cross in Vclume 5 of the State plan
-documents its-intent and capability-to provide feeding, clothing, and shalter-ing services to evacuees in a radiological emergency. The American Red Crosas-has proven ability to provide these disaster relief services to large numbers of people and there is no compelling reason to question its capabilities in-this specific instance. In its Statement of Understanding, the Red Cross states that "American Red Cross disaster responsibilities are nationwida.
Therefore, when the local chapters in the affected arsas are unable to meet the needs of disaster victims, the resources of the t'otal organ 12ation are made
% available."
A U (7k)
i NECNP NdLP-6 (Cont.) 56,
- h. Although the plans report that there is a day's food N regularly on hand at local schools, it is not clear whether that is a 1 day's food for the 1.000 regular students at the scidol, or a day's food )
to serve 20,000. In addition, the State claims that within that one day j period , Red C?oso will be able to gather its resources to provide for further food n eed s., However, no evidence is given to cupport that
. projecticn. Vols. 33, 3J, 36, 3R at II-10 The Red Cross will also be responsible for providing any clothing that is needed. Vols. 33, 35, 36,
$8 at II-10. Since fresh clothing is an integral part of the decontamin-ation facility, it is not adequate to rely on receiving clothes on an ad hoc basia.
FEMA RESPONSE ( h) The statement in the host community plans that "public schools generally have enough 'ood on hand to last for a day" should be clarified. It probably refers to either the normal student population or to the svacuee capacity of each facility. However, this requires confirmation and clarification in the host plans. In regard to the ability of the Red Cross to assemble its resources to supply food af ter one day, the Anerican Red Cross has proven ability to provide disastor relief services in atimely manner to large numbers of people, and there is ro compelling reason to question its capabilities in this specific instance. It is also noted in each of tile host plans that the host communities will proa vide interin suoplies, including food and clothing to the reception centers, p decontaminate 1cn centers, and mass care shelters as rjeeded to assist State b} r agencies or the Anerican Red Cross (page 11-11 of Volumes 33, 35, 35; pages 11-10 and 11-11 of Volume 38). The Red Cross is primarily responsible for providing clothing to evacuees. However, supplementary resources are also available. The plans indicate that the Salvation A-my may assist the Red Cross in providing supplies (food and cicthing) for evacuees at the mass care shelters (pages I-20,11-13, and 11-17 in Volume 33; pages 1-20, 11-13, 11-16 in volume 35; pages 1-19, and II-17 in Volume 36; pages 149 and 11-16 in Volume 38). In addition, the procedures for the Host Facilities Coordinator indicate that he/she will coordinate with the local E0C in obtaining additional replacement clothirtg if initial Oe-contamination Center supplies appear insufficient (pasge III-7 of Volumes 35 and 36; page III-8 of Volunies 33 &nd 38). Although the host community plans i indicated that a letter of agreement with the Salvation Army is preser.t in l Volume 5 of the State plan, the RAC review (page 12 of Ssction I) of the l State plan indicated that this letter vqas not present. If tr.e State and I host communities intend to rely on the Salvation Army to assist the Red Cross in provid1ng Supplies, the appropriate letter of agreement should be added to volume 5 of the State plans. l O n
- - 9
I f 57. f, j 2CNP MHLP-6 (Cont.)
- 1. The host plans contain no system to communicate lists of registered evecuees with other host facilities. Vols. 33. 35, 38. 38 at
!!-12. If the host facility does not keep track of the location of evacuees, order among evacuses will not be kept. For families who are split up because children go to . school in a different area than their areas. a more parents live or work, or spouses who work in different . comprehensive system of logging the whereabouts of evacuees will be L tiecessary to maintain order.
[ 1 FEMA RESPONSE (i) Although there appears to be adequate capabilities at the reception centers and mass care facilities to track and communicate the lists and loca-tions of evacuees who use the host community facilities, the host community plans do not specifically describe how this will be done. Mdition of this activity description to the host community plans and procedures would clarify who is responsible for performing this activity. The capability is presently described in detail only in the State plan procedures for the Division of Human Services, which is responsible for operation of'the reception centers. Appendix B of the Division of Human Services indicates that all persons O entering the reception center are registered on ,a special form (Appendix B, page B-1). A copy of this form is sent to the Message Exchange and Locating Service. As indicated in the procedurcs, a phone line for incoming telephone calls will be installed at the Message Center for receiving inquiries from outside friends and relatives (page B-2). Persens inquiring about the location of relatives / friends will be directed to this station to find out if the individual they seek has registered, and/or to determine if any massages have been left for the inquirer (page B-2). O i
l 58. l l A
. \j -
l SAPL Contention 7 1 l The New Hampshire State and local plans fail to meet the require-ments of.10 C.F.R. I 50.47(b)(11) and NUREG-0654 K.S.b. ' because there has been no showing that the means of radiological decontamination of emergency per'sonnel, wounds, supplies and equipment have .been established. Further, there has not been a clear showing that adequate means for waste disposal exist. By way of amendment of the basis and additional basis, SAPL states as follows: The NIIRERP Rev. 2 now assumes that all monitoring and decontamination of evacuees will be handled by host community personnel under the supervision of D PliS. There are no letters of agreement committing the host community personnel to perform these functions (save that for the American Red Cross) and there are no letters of agreement securing the reception center facilities contemplated for use under the plans. Therefore , the adequacy of personnel and equipment is not assured. Further, there are now two less host community primary reception centers due to the deletion of Nashua and Durham, which will increase the burden on the municipal resources (personnel and equipment) for those communities still participating. According ,to Rev. 2, the peak Q summer midweek population is 142,929. A high percentage of the C/ evacuating population could require monitoring and decontamination under plausible accident scenarios. Even Icsser percentages would overwhelm the facilities and personnel available to perform monitoring and decontamination services. The decontamination centers' procedures and facilities are now more adequately described than heretofore, though how contaminated areas of the decontamination centers are to be vacuumed or otherwise decontaminated to prevent individuals from becoming contaminated at the facility is not well described. There is still no storage capability for waste water that will result from the washing of evacuees and their vehicles. The State of New Ilampshire still contemplates dilution as the solution to this hazardous pollution problem. That is not a satisfactory answer and could lead to a public risk for the residents of the host communities. The Decontamiantion Supervisor Pool at Vol. 4 A , p. A-2 lists an "R. Letellier" as a possible supervisor for three centers, "E. Thompson" for two centers and "C. Albano" for two centers. If these are cetually the same people listed more than once, as it appears, this creates the false impression that there is a larger pool of potential supervisors than actually are available. l O , (77) _ - _ - - -_----_----_-_U
59, FEMA RESPCNSE TO SADL 7 In the December 1986 review of the New Hamcshire State and Host Cmmunity Planning, FDiA and the PAC examined the provisions for the registration and nenitoring of evacuees at reception centers. Planning Standard J.12 of FEMA REP-1 defines the requirements which must be met. The RAC concluded that the State Plan contained adequate provisions for the registration and monitoring of evacuees, (page 98 of State Plan RAC Review) but the host plans do not adequately describe the resources (equipment and personnel to . support the nonitoring and decontamination operations for the anticipated number of evacuee errivals in about a 12-hour period (page 15 of Hmt Plans RAC Review).- As indicated by the RAC in its review of the hmt emmunity plans (Section III, pages 10 and 15), the descriptions of the number of staf f nembers required for conitoring and decontamination activities is provided in Appendix B3 of each host cmmunity plan. However, it is impossible to assess from the plans if the number of staff positions are adequate to support the operations for the anticipated number of evacuee arrivals in a 12-hour period, and if there are enough trained personnel available locally to fill the required number of staff positions. Call list rosters for local personnel (see Appendix 89) are not yet available. In addition, it is also not known if the number of monitoring instruments available (see Section II. E.4) is sufficient to support the operations. Section II.E.4 of each of the host cmmunity plans refers to CDV-700 survey meters. Although the meters are also listed on the inventory shaets g provided in Aasa&rrB8, there is no indication on the inventory as to the quantity of survey meters (and dosimeters) on hand (seeE). It is gl recommended that the total number of each item on hand be indicated on the Ams inenter; sheets. The RAC recommended that in order to clarify the capabilities and adequacy of resources to perform the nonitoring and decontamination opera-ticns, the plans should clarly specify the assumptions used in preparing the staffintJ lists indicated in Appendix B3 and the equipnent resources indicated in Section II.E.4., (i.e. , what are the total nunber of evacuees expected to arrive at the nonitoring and decontamination facilities of the reception center, and what percent of the evacuated population does this nunter represent?) It is FEMA's position, as articulated in the menorandum from Richard Krimm to all FDiA regions, dated December 24, 1985, that provisions for monitoring evacuees must address at least 20% of the total EPZ population (see Appendix B for a copy of this menorandum). The RAC found that Appendix F of the DPHS procedures specifies appropriate criteria for decontamination and that the facilities for conducting decon-tamination are acceptable (pg. 109 and pgs. 110-112 of RAC Review of State Plan, elements K.3a and K.5b). I.atters of agreenent with host ecmmunity personnel and f acilities are not necessary, since they constitute local governnent organizations. O l'i C )
60. SAPL Contrntion 8 The New Hampshire State and local plans fall to meet the _ requirements that there be adequate manpower and 24-hour per day per ( emergency response, including 24-hour day manning of V) communications links , as required by 10 C.F.R. 5 50.47(b)(1), f 50.47(b)(2), and NUREG-0654 I!.A.l.e, II. A . 4. and 5 50.47(a)(1), II . F .1. a . Contention 8 A:
- The New IIampshire Compensatory Plan fails to meet the requirements that there be adequate msnpower and 24 hour per day emergency
- response. including 24 hour per day manning5of50.47(b)(1), communications links, as NUREG-0654 required by 10 C. F . R. ! 50.47(a)(1),
II . A .1. e. , II . A . 4. , and II . F.1. a. FEMA RESPONSE: In its Cec.1986 review of Pev. 2 of the New Hampshire Radiological Dnergency Response Plans for Seabrook, FEMA and the Pegional Assistance Committee (RAC) reviewed all municipal (EPZ) plans for their capacity to provide for 24-hour continuous operation for a protracted period. Specif-ically Planning Standard A.4 frm FEMA-REP-1 defines this requirement.
- Ch page 6 of the Dec.1986 RAC Review of Rev. 2 Municipal Plans, FEMA found that many key emergency response positions do noc have a back-up listed for second shift responsibilities. Based on these review findings, FEMA does not have assurance that the EPZ municipalities can fully
(-3) ' implement their plans. In Volume 2, Appendix G of the State Plan (Compensatory Plan), the State has clearly carmitted its personnel and equipment resources to providing support to municipalities where the required emergency response exceeds the capabilities of the municipalities. Since many of the municipal plans, in their respective Appendix A, indicate an insufficient second shift capability, it is quite conceivable that the Ftste may have to comtit sme of its limited personnel resources to assisting one or nore local camtunity in implementing its emergency response due to the unavailability of the primary local responder. In addition, there are currently six comunities who have indicated they will not participate in the planning process. The State will have to fully canpensate for those camtunities. In its June 1986 RAC Review of Rev.1 of the NH Compensatory Plan for Seabrook Station, FEMA found that the plans did not adequately identify the personnel to carry out the State's 02npensatory Plan. 'Ihe State responded to this by indicating that a resource allocation study was.being conducted to identify the personnel and equipnent necessary to implement local and state plans, coverino all functions. Rev. 2 of the NH olans still does not contain the results of this personnel allocation study. FEMA's findings are found on page 3 of the Ihcember 1986 RAC Review of the New Hampshire Compensatory Plan for Seabrook. Until New Hampshire develops this information as part of its planning (',') base, FEMA has no basis to change its determination that the State has V not demonstrated that it has adequate personnel resources to canpensate for the non-participation or supplemental needs of the EPZ cernmunities. (See RAC Review of the Compensatory Plan, pages; 3(A.4i 6(H.4 ), 7 (H.10)) . D I)
SAPL Cont:ntien No.15 61. SAPL rsessarts Redrafted SAPL Contantion No.15 and the basis for that contention in SAPL's filing of April 8,1986. Redrafted SAPL Contention No.15 t The letters of agreement that have been submitted by the M.H. Civil Defense / gency in Volume 5 of the State plan fail to meet the require-ments of 10 CFR ISO.47(a)(1), 550.47(b)(1), 550.47(b)(3), 550.47(b)(12), Appendix E.II.D. and NUREG-0654 II. A.3. , II.C.4. , and II.P.4. because they .do not demonstrate that adequate arrangements for requesting and effectively using assistance resources have been made, that the emergency responsibilities of the various supporting organizations have been specifically established, that each principal response organization has staff to respond or to augment its initial response on a continuous basis, or that agreements are being reviewed and certified to be current on an annual basis as is required. FEMA RESPONSES ( AMENDMENTS AND FURTHER BASIS) FEMA has addressed the redraf ted and amended Seacoast Anti-ibilution League (SAPL) Contention No.15 and its basis of inadequate letters of agree-ment by applying Planning Standards A, C, and J (Evaluation Criteria A.3, C.4,M(fJ.10g)inFEMArREP-1.
}.~ d PA-^
-.77 t December 15, 1986 RAC review of the State and municipal plans reflect I'# ' FEMA's views on t.his issue. Specifically, FDIA's review ccraments on the New Hanpshire State plan on this issue are prcvided on pages 10, 12, 19 snd 74-b of Section I, and on pages 1 and 2 of the Letters of Agreement subsection of Section IV. FEMA's resview conments on the municipal plans on this issue are provided on page 3 of Sectios III.
FEMA relied upon the following documentsin forming its conclusions on this issue: Revision 2 to the New Ha/mpshire State plan; Revision 2 to the municipal plans. FEMA does not yet have assurance of the adequacy of the written agree-ments. As noted in the Decernber 15, 1986 RAC review, evaluation criteria element A.3 is censidered inadequate due to the fact that the State plan does not contain all let ters of agreertent whi.ch have been referenced in the host conmunity plans (see pages 10 and 12 of Section I RAC review). Other aspects of r6 source assistance and letters of. agreement are generally considered adequate by the RAC. Respenses to specific contention issues are provided below. t ts n . 1 i J
SADL 15- (Cont.) 62. By way of amendment' and statement of further basis. SAPL holds as follows:
- 1) Though the Coast Guard and Hew Hampshire Towing Association agreements are now signed, the USAF agreement has wholly disappeared.
There ' is thus no assurance that Pease AFB will make its hospital anti l
- runway facilities available, which . are key in . the emergency response effort for Seabrook Station. Civil Air Patrol flights must be able to' fly into Pease for transport of officials and radiological samples . The agreement with the Portsmouth Naval Shipyard has also disappeared.
l. FEMA RESPONSE 1)- The written agreements with the U.S. Air Force (Pease AFB) and Portsmouth Naval Shipyard have been deleted from the plan. Inclusion of these letters is not required since assistance by these federal. facilities could be provided under the Federal Radiological Emergency Response Plan
-(FRERD). A copy of the FRERP is now provided in Volume 5 of the State plan. In a separate letter included in Appendix H of State plan Volume 2, the U.S. Air Force Hospital at Pease Air Force Base has indicated its willingness to make its hospital facilities available during a radiological
. emergency to the extent that such care to civilian casualties does not interfere with its prinary responsibility to active duty military personnel.
- 2) There are no letters of agreement with the reception centers and mass care facilities in the local communities and letter agreements are missing for certain of the host care facilities for special facilities in the EPZ (egs. Goodwin's of Exeter. Fventide Home. Seacoast Ilealth Center).
The RAC specifically asked these agreements (Reply to RAC, P. 10 of 134).
. FEMA PESPONSE
- 2) The American Red Cross (ARC) is responsible for providing mass care to individuals svacuated frem the plume exposure EFZ (see State Plan, page 1.3-17). A written agreement between t.he ARC and the State of New Hangshire is included in Volume 5 cf the State plan. As noted on page 10 of the December 1986 RAC review of the State plan (Section I), the RAC found that the Red Crcss letter of agreenent adecjuately demonstrates an ability to open and staff planned mass care facilities. However, as noted on page 12 of the RAC review (Section I), other letters of agreement are referenced in the host ecmnunity plans as being available in Volume 5 of the State plan (see page I-19 of Manchester and Salem plans, and page I-20 of Dover and Rochester plans). The RAC found this item to be inadequate I because no letters of agreement related to mass care are present in Volums 5 of the State Plan for the follcwing private organizations:
m i i
.. , 1
SAPL 15 (Cont.) 63.
- Salvation Army
- New Haneshire College
_
- Notre Dame College and Parochial School
- District Nursirg Association
'{v}
- Salem Boys Club
- Pochester Catholic School
- Rochester Day Care Center Although not specifically noted in the RAC review, it is correct that-there are also no letters of agreenent in the plans from the host facilities, for residents of the folicwing special facilities: Goodwin's of Exeter (Volume -
26A), Eventide Hcme (Volume 26A), and the Seccoast Health' Center (Volune 18A). Page A-2 of Attachment A of each of the preceediro special facilities have been received, written confirmations are " currently under review." These written agreements should be provided in the plans.
- 3) Though the N.II. Towing Association letter is now signed, there is still no letter of agreement with Rockingham County to assure that the Dispatch Center can be used. This facility is key in the emergency notification scheme.
F_EMA RESPCNSE
- 3) A letter of agreement with the Rockingham County Sheriff's Department !
O i is present in Volume 5 of the State plan. Notification procedures for the Rockingham County Dispatch Center are also fully described in the Procedures section of the State plan (Volume 4B). i
- 4) Though a letter of 8greement has been secured with the Federal Aviation A administration, there is still no letter of agreement with New England Telephone. The November 1985 draft of the NHRERP stated that it was "on file." It has not yet surfaced in the plens.
FENA RESPONSE
- 4) Volume 5 of the State plan does not contain a letter of agreement with New England Telephone. However, the need for such a letter is not apparent. .
1 1 1 O _______________-__a
SAPL 15 (Cont.) 64.
- 5) The letter of agreement with Teamsters Local No. 633 does not provide the requisite reasonable assurance that sufficient drivers will be p availabic to make up the shortfall c,f drivers indicated by the letters cf i
'j agreement wit!. the specific bus companies.* .Jany of the drivers wculd have prior commitments to be coing other lcbs. +he individual members ci the union have in no way demonstrated their willingness to perform these
' functions and are or where they there is no indication relative of how to the location the buses. of the drivers would be notified FDiA RESPCNSE
- 5) The RAC has concluded (see page 74-b of Section I of PAC review of State plan, and page 1 of Section IV RAC review of letters of agreemnt) that the State plan properly allcus for the fact that not all bus conpanies have as many drivers willing to serve as theyhouses that would be made 3
{dW available. The letter of agreement with Teamsters Local No. 633 of New Hampshire (Volume 5 of State Plan) provides for the Iocal to provide as many as 1,500 personnel, a number well in excess of any foreseeable needs, to drive trans-partation vehicles as needed durirg major emergencies. However, FEMA dces not yet have assurances that there are procedures in place for r:cbilizing the Teamstets from their places of employnent. p
- V 6) The letter signed by OMNE Partners II on July 31. 1986 inay or may not remain current for a reasonable period of time since OMNE is in a bankruptcy proceeding. Therefore , there is no assursnee that this transportation staging area will indeed be available.
FEMA RESPCNSE
- 6) The letter of agreement with CNNE Partners II provides for the availability of the CNNE Mall parking areas as a transportation staging area. "Italetter of agreement also clearly states that, "this agreement is subject to renegotiation at such tine as ownership of the property is conveyed frun CNNE Partners II to another party."
O ($ '> I
SE 15 ' (Cont.) 65.
' B ASIS:
l
- l. NUREG-)654 II . A .3. requires that each plan include written letters l of. agreement referring to the concept of - operations bet ween Federal, State and local agencies and other support organizations having an emer-gency response role within the EPZ. The agreements are supposed to identify the emergency measures to be provided and the mutually accept-able criteris for their implementation and specify the arrangements for the exchange of information. NUREG-0654 II . C . 4 states th6t each organi-
, zation shall identify nuclear and other facilitics , organizations or individuals which can be relied upon in an emergency to provide assistance and that such assistance "shall be identified and supported by appropriate letters of agreement." NUREG-0654 II.P.4 states that each organization shall update its plan and agreements as needed, review and certify it to be current on an annual basis. The letters of agreement in Volume 5 of the S'. ate plan do not suffice to satisfy these requirements for the following reasons:
a) Some of the letters of agreeraent bear no signature. The New England Interstate Radiological Assistance Compact has no signature page to validate it. The letter of agreement between New IIampshire Ycnkee and the State of New Hampshire and Massachusetts is neither completed, nor signed. -The Memorandum of Understanding with the Coast Guard has a typed in name, but no signature. The agreement with the New liampshire Towing Association is not signed. (A prospective date of 11/27/86 appears on the agreement.) The Memorandum of Understanding Between the USAF and the State of New Hampshire is nct signed nor dated. FEMA RESPONSE (BASIS)- (a) Many of the letters of agreement have been updated for Revision 2 to the plan. With only a few exceptions, the letters and agreenents have been signed. Mttersofagreement/whichareunsignedinclude:
- Agreement between New Hampshire Yankee Division of Public Service Cmpany of New Hampshire and the states of New Hampshire and Massachusetts (unsigned by Massachusetts representative, as noted on page 2, Section IV RAC review of Letters of Agreement).
- New England Interstate P2.diation Assistance Plan (no signature page included).
- Agreements between radio stations WCYT/14NH, NUNH and the New Hanpshire Civil Defense Agency (unsigned by either party).
- Memorandum of Understanding with U.S. Coast Guard (includes typed-in name no signature of Coast Gua-d representative).
All other agreement.s have been signed, including the one with the New Hampshire Towing Association. 'Ihe menorandum of understanding with the U.S. Air Force has been deleted frcm the plan (as noted above in its G of amended basis). (%)
SAPL 15 '(Cont.) 66. [ b) There are no letters of agreement with. many of'the key response organizations and governments. . For example , there are no letters of agreement with the 17 N . II . local communities nor are there letters of agreement with the host communities . Thus, the requirements V. of NUREG-0654 II. A.3 are not met. l -- FEMA RESPONSE
)
(b) There are no letters of agreement with the 17 New Hampshire EPZ comunities or with the four hest communities. 'Ihe concept of operations for emergency response by the local- ccumunities is provided in the radiological { emergency response plans for these communities. If specific cmmunities are unable to implement their plans, the State of New Hampshire would assum responsibility for implementation of the plans under provisions of the State compensatory plan. c)- Some of the agreements date back a number of years. For example, the New England State Police Compact is dated 6/69. Clearly , the specifics of any emergency response for the aren surrounding Seabrook Station were not contemplated when this compact was signed. This is contrary to the requirements of NUREG-0654 II.P.4. O _ PENA RESPCNSE (c) Although the fact that an agreement is old does not necessarily negate its applicability, it would- appear prudent for the state during its annual , review and update of the plan to confirm that old agreements, such as the New England State Poli Cc6 pact, are applicable to a radiological energency response at Seabrook. A d) There are not Ictters of agreement with School Administrative Units , schools , teachers. owners of towing companies (other than the unsigned postdated agreement with the New England Towing Association mentioned above), day care centers, nursing homes, Rockingham County Dispatch, but drivers or other organizations or individuals to be relied upon to provide assistance in an emergency as recuired by NUREG-0654
!! . C . 4 .
FENA RESPCNSE (d) Letters of agreement with individual teachers and bus drivers are not included in the plan. However, letters of agreement with those orcaniza-tions supplyirg bus drivers (e.g., bus ccmpanies and Teamsters Local No. 633) are present in Volume 5 of the State Plan. Letters of agreenent with towing ccmpanies are also now present in Revision 2 of the plan (Volume 5). Also see FEMA response to items #2 and #3 of the amended basis given above-for letters of agreement which are present or absent fram Rev. 2 to the plan. d/)
SAPL 15 ' (Cont.) 67. e) There is no showing that the FAA . Concord - F11ght' . Service Agreement or the agreement with New England , Telephone are sufficient to establish ' the responsibilities of those organizations as required by-
'l
- 10 C . F. R . 550.47(b)(1) because- those letters . arc not provided in Volume-5 but are said to be "on file."
- m. .
FD4A RESPONSE
.- (e) Revision 2 of the Stateplan (Volume 5) now contains a letter of agreement with the FAA. As noted in the above FDiA response to item #4 of the amended basis, there is still no letter of agreement with New England Telephone. However, the need for such a letter is not apparent.
f) The letters of agreement with hospitals include a number of letters = from hospitals which. are not listed in the New Hampshire State Plan (see p.2.8-5 for the list. ) It is very clear to SAPL . why these letters even appear in Volume 5. For example, the October !), 1985 letter . from Alice Fark Day Memorial Hospital in Lebanon, New Hampshire states
...because APD is a small hospital with extremely limited resources, it is unable to handle radiation victims." The October 7, 1985 letter from Valley Regional' Hospital similarly stateb, " ..the pflysical design of. our O . ' facility , and in particular our emergency receiving area, would make appropriate isolation of- the ' contaminated patient impossible." . SAPL believes that all extraneous letters from entities not to be counted upon in an emergency response should be removed from Volume 5. It seems SAPL that it would only add to the difficulty emergency responders face in making appropriate referrals to have non-applicable information to sift l
l through. The letters from hospitals that are listed in the State plan do not demonstrate that the requirements of 10 C.F.R. 950.47(b)(12) have been met. There is no letter for Newport Hospital, which is listed in the state p lan . . Pease Air Force Base Hospital states, "We are- willing to coopvrate fully with civilian hospitals and cisaster authorities is assisting with care of civilian causalities to the extent that such care does not interfere with
- our primary responsib'IIities to active duty military personnel." (emph& sis added)- There is, therefore7 no assurance that this hospitsl's resources will be available to civilians. Further, as was stated previously in SAPL Contention #4, Please is just a short distance beyond the EPZ boundary and could under certain circumstances need tc be evacuated. The letter provided for iluggins Hospital is illegible. The letter for Lakes Regional General Hospital in ' Laconia - dated 10/15/85 states ". . .we recognize our responsibilities to treat such cases that occur in our service e.rea and to help neighboring hospitals that may be faced with more casualties thiT they can treat as a result of a disaster situation." (emphasis added)
Seabrook Station and its EPZ are not in the Lakes Region General Hospital O service area nor are the hospitals in the Scabrook EPZ neighboring hospitals. The letter from Catholic Medical Center dated 10/17/55 states (G$} 4 f L . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
f' SAPL 15 (Cont.) , 68. that a letter written by' Dr. Windler on 1/6/84 still holds. No copy of the 1/6/84 letter is provided. For these and other reasons. the letters of agreement from hospitals included in Volume 5 of the State plan do not l V(~N provide support for a finding that adequate arrangements for ruedical services for contaminated injured individuals have been made. FEMA FISPCNSE (f) The letters of agreement with hospitals having radiological emer-
- gency capability are presented in Appendix H of the State plan (Volume 2, Pev. 2). Be letters are now consistenc with the listing presented on
. Table 2.8-1 of the State plan (pages 2.8-5, -5a, and -Sb). A letter from Newport Hospital is also included in the revised plan.
The letter frcn Pease Air Force Base Hospital indicates that this military hospital is willing to cooperate and assist in the care of civilian casualties to the extent that such care does not interfere with the hmeital's
" primary responsibility to active duty military personnel." Althouch there is no assurance that this hospital's resources will be available to civilians, its inclusion with the other hespitals is appropriate in the plan since it represents a resource which potentially might be available in a radiological emergency.
We 3etter frm Lakes Regional General Hospital reflects the hospital's responsibility to " treat such cases that occur in our service area and to help neighboring hospitals that may be faced with more casualties than they can [.) treat as a result of a disaster situation." The fact that Seabrook Station and its EPZ may not literally be "in the Lakes Pegion General Mcspital V service area,' and the hospitals in the Seabrook EPZ may not literally be
" neighboring hospitals" probably does not negate the hospitals' willirx; ness to provide the specialized medical services in a radiological energency.
Both the 10-17-85 and the ehrlier 1-6-84 letters frcm the Catholic Medical Center are now included in Appendix H of the revised State plan (Volume 2). g) Many of the letters are too non-specific and do not demonstrate that adequate arrangements for requesting and effectively using assistance resources have been made. The concept of operations is not clectly defined. For example, the R.S. Landauer, Jr. & Co. letter of 12/30/83 does not tell how fast the company can provide film badges. (The letter also needs to be updated as required by NUREG-0654 !!.P.4.) The Memorandum of Understanding between the USAF and the State of New Hampshire taakes no reference to an accident at Seabrook, and, as was mentioned above, it is unsigned and undated. FEMA RESPONSE (g) An updated letter frm R. S. Landauer, Jr. , & C680= \ is now included in Revision 2 of the State plan (Volune 5)( dated 3-3-86 The letter provides information on the required logistics and time frame for providits readouts of badges which are being supplied ;
~'
The Menorandum of Understanding with the U.S. Air Force has been deleted from the State plan. (Also see FEMA response to above item #1 in i the amendeC basis.) 3 { 81 I i
SAPL 15 (Cont.) 69. f f h) The letteza of agreement with bus companies provide no ! assurance that bus drivers will be available to drive buses into the EPZ. In some cases their [ sic] are too few drivers for the number of buses to be provided by a company under the plans. JanCar Leasing Corporation, b}
/
for example, is to provide 197 buses, but only lists 150 drivers. SAPL ale, is concerned that some of the buses that are alleged to be available during emergencies might be chartered out or otherwise not available. . l FEMA RESPCNSE
- (h) In regard to the availability of bus drivers to drive evacuation buses, see the FEMA response to'above item #5 in the amanded basis. l l
- 1) The letters of agreement with ambulance companies do not support a finding of reasonable assurance that adequcte protective measures can and will be taken. Most, if not all, of the companies listed are a minimum of 1 hour's drive from the EPZ. None of the companies except Berlin Emergency Medical Services, Inc. state how many ambulances and what personnel are available. That company's letter notes that "If the patient . is 'n a hazardous area, we usually have to wait on the outskirts until the. patient is brought to us. This might be signifi-cant in the event of a disaster involving the nuclear plans."
,_s For all of the above cites reasons, the letters of agreement fail to support the requisite 10 C.F.R f50.47(a)(1) finding of reasoncble (V) assurance that adeouste protective measures can and will be taken in the event of a radiological emergency at Seabrook Station.
FEMA RESPCNSE (i) Ambulance providers are located both within and outside of the i EP2. As noted in State Plan Section 2.8.3 (l. age 2.8-2), ambulance providers fram outside the EP2 will provide nonemergency medical transportation (i.e. , evacuation) of nobility-impaired persons. Energency medical services from within the EP2 will maintain emergency medical transportation. Iattersof agreement with ambulance providers are included in Volume 5 of the State plan. All letters in the revised plan (Rev. 2) now state the number and type of medical transport vehicles available as well as the number of EMrs. The August 1986 letter of agreement with Berlin Energency Medical Serices no longer states that "if the patient is in a hazardous area, we usually have to wait on the outskirts until the patient is brought to us." The RAC review indicated (pace 10 of Section I) that according to estimates of ambulance needs, an adequate number of letters of agreement with ambulance ccupanies have been signed. In addition, names ard addresses of numerous ambulance ccmpanies for which there are no letters of agreement are provided as an additional resource. C\ s)
70. SAPL Contention'16
'.,q The New lir ipshire State and local plans do not make adequate provisions for - the' sheltering ' of various segments of . the populace in > the
~ ~Q EPZ and therefore the plans fail .to meet the requirements of 10 C.F.R.
550,47(a)(1), $50.47(b)(10) and NUREC-0654 II.J.10.a. and m. l l FEMA RESPONSE: 1 -, See FEMA Response to NECNP-RERP-8 i I i
/
n I Olt) m _ _ _ _ _ _ _ _ _ . _ _ __
71. SAPL COtTITNTION 18 1 1 - The NHRERP Rev. 2 significantly miscalculates the numbers of A non-buto owning population for the 17 New Hampshire local communities. No buses are proviced in the plans for ~ the individuals who are not accounted for due to these miscalculations. Therefore , these plans fails to meet the- requirements of 10 CFR 550.47(a)(1), 550.47(b)(8), NUREG-0654 II.J.10.g. and SUREC-0654 Appendix 4. p. 4-3. FEMA RESPONSE: The validity of the Evacuation Time Estimates (ETEs) prepared by KLD Associates and incorporated into the talRERP was challenged by the following Contentions: Hampton Revised Contention III, SAPL Contention 18 ' SAPL Pavised Contention 31 SAPL Cbntention 34 . SAPL Contention 37 m At FEMA's request, the RAC reviewed the ETEs, stiecifically evaluating
. them against the guidance set forth in NUREG-0654, FEMA REP-1, Rev.l. The RAC found the ETEs sufficiently complied with the guidance contained in g Appendixgof NUREG-0654, FEMA REP-1, Rev.1 so as to serve as an adequate basis for protective action decision-making. FEMA concurs in that view.
The views of the RAC were expressed in further detail in the December 15, 1986, RAC Review of Revision 2 of the NHRERP. The witness who will address these issues at the licensing hearing is Cr. Thomas Urbanik, a recognized expert in the field. He has reviewed the ETEU and has also concluded that they are adequate under the standards set forh in NUPEG-0654, FDiA REP-1 Rev.1. The NRC staff has consulted with Dr. Urbanik on other evacuation time estimate studies and will sponsor his testimony. 1 1 Hampton Revised Contention IV to Revision 2, Basis (E)
~
and Further Basis (A)2 (ETE issues) Hampton Revised Contention VI Basis A (Rev. 1)
~
O m
72.
'v AMENDED SAPL C017In7 TION 10. 25 The New Hampshire State and local radiological emergency response plans do not reasonably assure that the public health and safety will .. adequately be protected because the provisions for protecting those persons whose mobility may be impaired due to such factors as institu-tional or other confinement are patently lacking. Therefore, the plans do i- not meet the requirements of 10 CFR 550.47(a)(1), $50.47(b)(8) and
'~* NUREG-0654 II.J.10.d. By way of amencment and additional basis. SAPL states as follows: The Exeter Hospital Radiological Emergency Response Plan contained in Volume 264 of the NHRERP Rev. 2 does not support a finding that there will be adequate care provided for those patients classified as Cate-gory I (Advanced Care Required) or Category IV (School Dus) because the letters of agreement with the host hospitals for Exeter Hospital do not indicate that any of these facilities have the willingness or facilities to take these patients. Catholic Medical Center and Concord Hospital only assert a willingness to accept Class II una Class III patients. Ilampstead Hospital's letter is non-specific in regard to how many or what category of patients it will accept and does not support a finding that these patients will be cared for. There is, therefore, no reasonable assurance that these individuals will be adequately provided for., O Further, at page 15 of the Exeter Hospital Ra'diological Emergency Fesponse Plan, it states: Patients aged 55 years old or considered too critical for transport should be considered candidates for sheltering rather than evacuation. Coordinate with DPHS. FEMA RESK)NSE: FEMA has addressed the amended Seacoast Anti-Pollution league (SAPL) Contention tb. 25 and its basis of inadequate provisions for protecting institutionalized nobility-impaired persons by applying Planning Standards A, C, and J (Evaluation Criteria A.3, C.4, J.10.d and J.10m) in FEMA REP-1. The December 15, 1986 RAC Review of the State and municipal plans reflect FEMA's views on this issue. Specifically, FEMA's review ccmnents on the New Hampshire State Plan on this issue are provided on pages 10, 12, gand 88 of Section I. FEMA's review cmments on the municipal N plans on this issue are provided on page 19 of Section II. , I l O e
l T4A RESPONSE 73. 1' AMENDED SAPL CONTENTION NO. 25 (Cont.)
-fS\
V j FEMA relied upon the following documents in forming its conclusions on this issue: Revision 2 to the New Hampshire State Plan; Pavision 2 to the municipal plans. FEMA does not yet have assurance, based on the available letters of agreement, that there are adequate provisions for protectf ng instituiton-alized persons. The December 15, 1986 RAC Revick of the State and local plans for evaluation criteria element J.10.d indicated that plan revisions adequately treated protection of the mobility impaired (see page 67 of Section I, State Plan review; and page 19 of Section II, local plan review). However, the RAC Paview did not coment on the f act that letters of agreement with the host hospitals for evacuated patients from Exeter tbspital do not include provisions for acceptance and care of Category I and Category IV patients. The letters frm concord Ibspital and Catholic Medical Center only indicate their agreement to accept Class II and Class III patients (see Attachment A to Exeter Ebspital Radiological Dnergency Response Plan in Vblume 26A of plans). The letter from Hampstead Hospital is non-specific. Additional information needs to be provided in the agreements and plans to clarify how Category I and Category IV patients frm Exeter Hospital will be protected in the event of a radiological emergency. In regard to the sheltering of Exeter Hospital patients " aged 55 years old or considered too critical for transport,".rather than evacuate them, State Plan Section 2.6.5 indicates that New Hampshire relies on two rw}
' protective actions for limiting the direct exposure of the general publaic within the Plume Exposure EP2. These two protective actions are sheltering and evacuation (State Plan, page 2.6-4). The decision whether to shelter or evacuate is based on several variables, including dose reduction factors due to sheltering (State Plan, page 2.6-29) . State Plan Section 2.6.5 (page 2.6-6) indicates that New Hampshire employs the " Shelter-in-Place" concept if sheltering is the chosen protective action.
In regard to sheltering residents of special facilities such as Exeter Ebspital the State indicates that sheltering is the preferred protective action (State Plan, page 2.6-7). FEMA concludes that the plans have been adequately revised to take into account the sheltering protec-tion f actors for special f acilities (RAC Review, Section I, page 67). A special tabulation of specific protection factors for each of the facilities (including Exeter Ibspital) is present in Table 2.6-3 of the State Plan (RAC Review, Section I, page 67) . The RAC Peview (Section I, page 88) indicates that the flow diagram in the State Plan (Fig. 2.6-7) now properly reflects the decision-making process for the election between sheltering and evacuation, and that the treatment of institutionalized is now adequately detailed. Relative to the lack of written agreements with the host facilities for residents of certain special facilities (Seacoast Health Center in U [f4 i
-: 74.
FDR RESPOIISES - AMENDED SAPL COfffENTION NO. 25 (Cont.)' , G .
. Hampton,; Coodwin's of Exeter, and Eventide Ibme of Exeter), and-the lack n of written agreements for reception and mass care facilities, see the FEMA response to Item #2 in the amended and redraf ted SAPL Contention tb.15.
The basis for the contention statement that "O'Brien Ambulance of Beverly, Massachusetts, has stated that/ the ccznpany will not be able to onse-in the Seabrook area" is unknown. The-participate in any type Mtter of' Agreement of O'Bri with resp % Anbulance, Inc.. (January 1986) provided in Wlume 5 of the State Plan makes no such statement. O 9 m
75. Revised SAPL Contention No. 31: The evacuation time estimate . report , as described in Volume 6 of NHRERP Rev. 2 does not meet the requirements of 10 CFR 550.47(a)(1), O $50.47(b)(10) and NUREG-0654 II.J.2, II . J .10, i. 10 h and 10 1, r.nd Appendix 4 because. it falls to account properly for the number of 1 vehicles that would be evacuating the EPZ: relies in p art upon 'l I unsuppcrie d assumptions: relies in part upon potentially . biased input S data: does not rely upon an extensive enough empirical base; relies upon traffic control personnel not shown to be available; doe snot appropriately account for travel impediments such as flooding, snow, fog and icing of roadways; does not account for the effect of driver disobedience on evacuation time estimates (ETE's); doe snot appropriately deal with topographicsf features ; does not deal rea.listically with the transport of transit dependent persons: in some instances overestimates roadway capacity and, for all of these reasons, underestimates the amount of time it would take to evecuate the EPZ and it subparts (" Regions") under the various scensrios analyzed. i 1 FEMA RESPONSE:
}
The validity of the Evacuation Time Estimates (ETEs) prepared by KLD Associates and incorporated into the NHRERP was challenged by the following Contentions: , Hampton Revised Contention III SAPL Contention 18 ' SAPL Revised Contention 31 SAPL Cantention 34 - SAPL Contention 37 At FEMA's request, the BAC reviewed the ETEs, specifically evaluating them against the guidance set forth in NUREG-0654, FEMA REP-1, Rev.l. The RAC found the ETEs sufficiently canplied with the guidance contained in g~ Appendix g of NUREG-0654, FEMA REP-1, Rev.1 so as to serve as an adequate basis for protective action decision-making. FEMA concurs in that view. The views of the RAC were expressed in further detail in the Cecember 15, 1986, RAC Review of Revision 2 of the NHRERP. The witness who will address these issues at the licensing hearing is Dr. Ihanas Urbanik, a recognized expert in the field. He has reviewed the ETEs and has also concluded that they are adequate under the standards set forh in NUREG-0654, FEMA REP-1 Rev. 1. The NRC staff has consulted with Dr. Urbanik on other evacuation time estimate studies and will sponsor his testimony. Hampton Revised Contention IV to Revision 2, Basis (E) - O and Further Basis (A)2 (ETE issues) Hampton Revised Contention VI Basis A (Rev. 1) Ull)
76. SAPL Contention No. 33 Contrary to the requirements of 10 CFR 550.47(a)(1), 550.47(b)(8), f50.47(b)(D), 550.47(b)(10) and NUREG-0654 II.J.12, there is no showing that NHRERP Rev. 2 provides adequately for the registration and moni-toring of evacuees at reception centers within about a 12-hour period. B ASIS: The NhRERP Rev. 2 has reduced the number of host communities from six communities down to four communities in eliminating Nashua and Durham. This has had the resultant effect of lessening the base of municipal resources that can be drawn upon to assist the evacuating population and has reduced the likelihood, which was not great before , that h11 ovacuees seeking assistance would indeed be assisted within the time frame set forth in NUREG-0654 as reasonable, i.e. , about a 12-hour period. The rate at which evacuees can be processed through the' remaining reception and decontamination facilities has not in any fashion been established in the plans. Therefore , reasonable assurance has not been demonstrated that any significant fraction of the summer midweek population of 142,929 estimated in these plans for the New Hampshire portion of the EPZ could be assured the requisite assistance in the speci-fled time frame. FEMA RESPONSE: . Refer to FEMA Response for SAPL Contention 7. O t '7 7)
77. SAPL Contention No. 34 ' p. The New Hampshire State and local plans do not meet the recuire-ment that there be maps' showing the population distribution around the
-Q facility as required at NUREG-0654 J.10.b. and Appendix 4. Therefore ,
there is no reasonable assurance that adequate protective measures can and wiu be taken pursuant 10 CFR 650.47(a)(1) and $50.47(b)(10). 3 FEMA RESPONSE: The validity of the Evacuation Time Estimates (ETEs) prepared' by KLD Associates and incorporated into the NHRERP was challenged by the following Contentions: Hampton Revised Contention " III SAPL Contention 18 SAPL Revised Contention 31 SAPL Contention 34 - SAPL Contention 37 At FEMA's request, the RAC reviewed the ETEs, specifically evaluating them against the guidance set forth in NUREG-0654, FEMA REP-1, Rev.l. The RAC found the ETEs sufficiently complied with the guidance contained in Appendix _gof NUREG-0654, FEMA REP-1, Rev.1 so as.to serve as an adequate
.g basis for protective action decision-making. FEMA concurs in that view.
1 The views of the RAC were expressed in further detail in the December 15, 1986, RAC Review of Revision 2 of the NHRERP. The witness who will address these issues at the licensing hearing is Dr. Thomas Urbanik, a recognized expert in the field. He has reviewed ~ the ETEs and has also concluded that they are adequate under the standards set forh in NUREG-0654, FD4A REP-l Rev.1. The NRC staff has consulted with Dr. Urbanik on other evacuation time estimate studies and will sponsor his testimony. Hampton Revised Contention IV to Revision 2, Basis (E) and Further Basis (A)2 (ETE issues) ! Hampton Revised Contention VI Basis A (Rev. 1) i 1 l 1 (9s)
78. S APL Contention No. 37 r The NHRERP Rev. 2 fails . to provide reasonable assurance of
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adequate public. protection because an adequate number of emergency vehicles are not provided for . in the plans and further there. is no assurance that effective use of these vehicles will be possible in view of a
-potential outgoing flow of evacuating traffic and a significant lack of -
drivers . Therefore, these plans do not meet the requirements of 10 CFR S -550.47(a)(1), 150.47(b)(3), ISO.47(b)(10) and NUREG-0654 II.J.10.g. and II . J .10. k . 1.
. FEMA RESPONSE:
l The validity of the Evacuation Time Estimates (ETEs) prepared by KLD Associates and incorporated into the NHPERP was challenged by the following Contentions: Hampton Revised Contention III-
~
SAPL Contention 18 SAPL Revised Contention 31 SAPL Contention 34 - SAPL Contention 37 At FEMA's request, the RAC reviewed th9 ETEs, specifically evaluating
.[ them against the guidance set forth in NUREG-0654, FEMA REP-1, Rev.l. The RAC found the ETEs sufficiently emplied with the guidance contained in
.g .
Appendix M of NUREG-0654, FEMA REP-1, Rev.1 so as to serve as an adequate basis for protective action decision-making. FEMA concurs in that view. The views of the RAC were expressed in further detail in the December 15, 1986, RAC Review of Revision 2 of the NHRERP. The witness who will address these issues at the licensing hearing is Dr. Thomas Urbanik, a recognized expert in the field. He has reviewed the ETEs and has also concluded that they are adequate under the standards set forh in NUREG-0654, FENA REP-1 Rev.1. The NRC staff has consulted with Dr. Urbanik on other evacuation time estimate studies and will sponsor his testiraony. Hampton Revised Contention IV to Revision 2, Basis (E) and Further Basis (A)2 (ETE issues) Hampton Revised Contention VI Basis A (Rev. 1) O m)
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CURRENT FEMA POSITICN CN N HAMPIm CWTENTICN AND NIENP CCNTENTICN NIEP-4 (Supplement to "Statenent of Position") O EXHIBIT B O
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NECNP Contention NHLP-a 4 1
\ Procedures- to provide early notification and clear instruction to the j L- populace within the plume exposure pathway EPZ,10 CFR $ 50.47(b)(5), j are inadequate. ;
1 S Limited to. notification of persons with special notification needs, j
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1 FEMA _ Response:
' FEMA has addressed NECNP Contention NHLP-4 and its basis that the 1 local plans do not make adequate provision for notification of people with 1
special notification needs by applying Planning Standa*d E (Evaluation Criteria E.5) in FEMA-REP-1. The December 15, 1986 RAC revitw of the State ar,d municipal plans reflects FEMA's views on this issue. Specifically, FEMA's review connents on the New Hampshire State Plan on this issue are provided on pages 24 and 25 of Section I. and on page 8 of Section II (local plans). FEMA found that the local and State plans do not indicate procedures for identifying and distributing tone-elert radios to new businesses and residents. Also, Section II.B of the local plans do not specify by what means instructions are provided to the hearing impaired to' enable them to understand what they are to do after receiving a visaal signal on the' visual-alerting radio receivers. O (lC?)
SOUTH HAMPTON C'ONTENTION 8 The RERP for South Hampton f ails to provide reasonable. assurance because, contrary to NUREG-0654 J.10.d. it f ails to provide for adequate transpor-tation arrangements for the evacuation of mobility. impaired individuals
* (subject to institutional or other confinement) and that adequate arrange-ments have not been made to identify and transport persons who do not own an automooile.
t.imited to' mobility-impaired individuals and transport dependent persons. FEMA Response: FEMA has addressed Town of South Hampton Contention-8 and its basis that the South Hampton local plan does not provide for adequate transpor-tation arrangements for mobility-impaired and transport dependent persons by applying Planning Standard J (Evaluation Criteria J.10.d) in FEMA-REP-1. The December 15, 1986 RAC review of State, municipal, and Compensatory Plans reflects FEMA's reviews on this issue. Specifically FEMA's review comments on this issue are provided on pages 66.and 67 of Section I, (State Plan), page 19 cf Section II (Municipal Plans), and page 10 of Section IV (Compensatory Plan subsection). FEMA found that the procedures in the State and local plans were generally adequate to deal with transportation for mobility-impaired or otherwise dependent persons. However, FEMA at this time is still reserving its judgment regarding the ability of the State to implement
- compensatory measures for local communities in this area. See RAC connents on pg.10 -
of Compensatory Plan review, and FEMA's April 15, 1987 position on the Motion for Summary Disposition of this contention. O
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O I W ER MTED AUGUST 7, 1987 FROM H. JOSEPH FLYNN
'IO 'IHOMAS G. DIGNAN, JR.
O EXHIBIT C O ( / c 3,)
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!j,Jy. ( Federal Emergency Management Agency k0 0 j Washington, D.C. 20472 i August 7, 1987
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-Thomas G. Dignan, Jr., Esquire Repes & Gray 225 Franklin Street Boston, Massachusetts 02110 Re: FEMA Statement of Position on Off-site Contentions (Seabrook Station)
Dear Mr.. Dignan:
On June 19, 1987, your office filed with the Nuclear Eegulatory Commission the Applicants' Answer to Joint Motion for Leave to File a Supplement to Motions for Stay of the Partial Initial Decision Filed by Seacoast Anti-Pollution League, Attorney General James M. Shannon and Town of g Hampton. The litigation invol.ved pertains to the application of Public t f-~j Service Company of New Hampshire and the other owners of Seabrook Station for . a low-power license, and the Federal Energency Management Agency (FEMA) is not directly involved in those proceedings. Nevertheless, we feel that we need to clarify our Statement of Position filed in connection with the off-site litigation on June 4, 1987, since your pleading refers to our Statement of Position and interprets it in a way that does not represent our views. Please understand-that I am not challenging the legal argumentation which you assert in the low-power license matter; that would be inappropriate, since FEMA is ' not a party. However, it is in the interest of all the parties to the off-site litigation to understand more fully what FEMA intended by its Statement of Position on the beach population issue. On page 3 of your pleading, you state: In essence, it is the positicn of FEMA Region I that it must be demonstrated for every nuclear power plant site I that in the event of an extremely unlikely major fast-breaking accident which results in a major release in one-half hour, it must be demonstrated that the emergency plan will essentially guarantee zero risk to the general public. 3 There are two aspects of this statement on which FEMA wishes to comment. First, in the quote ,above and at reveral other places in your pleading, you refer to the FEMA posite.on filed with the off-site ASLB on June 4, 1987, as v ( !C c '] I
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k The Answers to Interrogatories and representing the views'of FEMA Region I. Statement of Position represent the views of the agency, not those of a single cffice within the agency. l
.y Our second point, as our Statement-of Position points out at pages 38 and
'39, is that FEMA's evaluation of radiological emergency response plans assumes that the range of accidents to which the plans are intended to respond
)* includes those with .a major release in one half hour. This view is supported by the guidance provided by the NRC in NUREG-0396 and by the NRC and FEM l 1, jointly in NUREG 0654/ FEMA rep-1, Rev. 1. It is the NRC's role, not FEMA's, l to determine the nature or likelihood of the accidents to be addressed in off-site emargency planning. Our concern with evacuation time estimates has i- traditionally been with their accuracy because of their importance in toe f making of an informed choice between sheltering or evacuation of th:e l population potentially affected by a release from a nuclear power plant. However, the summer beach population at Seabrook is a special case cince the planning effort itself reflects a lack of reliance on sheltering as a protective action. Since the only available protective action in this case is evacuation, FEMA has also taken into account the time necessary for evacuation in making a judgment about the safety of the beach population. FEMA does not hold the position that emergency plans must guarantee zero risk. Indeed, we acknowledge that applicable guidance does not specify rigid or mechanical limits to the injuries which a plan may unavoidably open the q door for under certain accident scenarios. However, plans must address the full accident spectrum which includes the possibility of significant releases in as early as one-half hour, as the NRC has detehnined. FEMA has made a qualitative decision about the safety of the population of the Emergency Planning Zone in the first several hours where, under the existing pixm , no sheltering option is contemplated for large numbers of people at the' beach. FEMA does not hold that any level of risk is acceptable just because the dose savings are the best that can be conveniently achieved. In FEMA's view, its ultimate responsibility is to determine whether the protection afforded by a i radiological emergency response plan is reasonable. Sincerely, r. H. Jose Flynn, Assistant Ganeral Counsel O < 4 c ,. a) )
.e . . /). $ FederalLEmergency Management Agency 4
6 , A .2 Wr.shington, D.C. 20472
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' CPEFATIVE GUI7MCE MEMCFANCA FEDERAL EMEIGDJCY MANAGDEC ACCICY APRIL 21, 1987 j .
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O . 4/21/87 1
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- CPERATIVE GUIDANCE MEMCRANCA
*- Ntr.cer Date Title 4 4/1/80 Radio Transmission Frequencies and Coverage 5 4/1/80 Agreements Among Governmental Agencies and (revised- Private Parties 10/19/83) l 8 4/2/80 Pagional Advisory Ccmittee Cecrdinatien (revised- With Utilities 10/19/83) 16 8/7/80 .Standa$d Fagional Paviewing and Peporting Procedures for State and Lccal Padielegical Emergency Respense Plans 17 1/8/81 Joint Exercise Precedures 20 10/19/83 Foreign Language Translation cf Public Education Brochures and Safety Messages 21* 2/27/84 Acceptance Criteria for Evacuatien Plans .
22 10/19/83 Recert. keeping Regairements fer Puelic Meetings 24, 4/5/84 Radiological Emergency Preparedness for ilandicapped Persens - EX-1 7/15/85 Famedial Exercises EX-2 7/15/85 Staff Supper in Ivaluating FI? Exercises PR-1 10/1/85 Policy en NURE.U-0654/FS.A-FIP-1 and 44 CTR 350 Periedic Requirements A f
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1 IT-1 10/1/S5 A Guide to Cec =ents Related tc the FI? Pr gram
?!-l 10/2/85 "
EE% Accien to Pilct Test Guidance on P.tlic
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Infer =ation Materials and Prcvide Tecnnital Assiscance Cn Its Use FR-1 12/3/85 Federal Res p nse Center MS-1 11/13/86 Medical Services > , r/- 2 11/13/86 Prctective Acciens ter Schcol Children ! AN-1** 4/21/B7 EE% Action tc Oualify Alert and Notification Systems Against NUFIG-0654/TE'A-?IP-1 and FE%- REP-10
- G4-21 will be retititd G4 01-1 when it is revised to ecnform tc new nomenclature. *
** With the issuance of G4 AN-1, G&l3 is te=tirated.
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i g.- FEDERAL EMERGENCY MANAGEMENT AGENCY'
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l sq Wasnington. D.C. 20472
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s MEMOPANDUM FOR: REGIONAL DIRECTORS - FROM: John W. McConnei, Assistant Associate Director for Population eparecness
SUBJECT:
Guidance Memorandum Series Starting with the attached group of topical matters, we will be sending ycu a series of numbered memoranda ecvering a variety of issues of mutual interest. Some will simply describe factual situations, scme may request advice and cooperation, and some may suggest a means of resolving matters of interpretation. We view all of these as imocetant to our continuing coordination with NRC on the evolving Report to the President and niatters of continuing improvement in preparedness around nuclear facilities.. We hece'you will view them as helpful instruments through wnich we can work togetner. (mj v I will look forward to hearing from you regarding tne content of these . memorandums, especially with respect to those recut: sting interpretive l feedback from your offices. Please feel free to suggest items and information wnich you believe should go cut in sub1equent memortncums. Attachments G.M.Nos.2,2,@ ce; Mr. Macy General Camm Mr. Jett P&P Staff Directors REP Staff RC (0Xwiatkowski) l l 1 l l l
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,b. Wasningt:n. O.C. 2M70 Apr 1 1, 1980 O o Guidanca M2=orandum da Radiological EmergenEy~ Fre:aredness Division RADIO TRANSMISSION RECUENCIES AND COVEUGE A number of utilities have conrnented to NRC conce-ning tae avai'acility of frequencies for both eme-gency response actions or for pre ara cry data ecliec*ien wnica may be handled by microwave transmission af dig-iti:ed data. We ask the Regions and the RACs :: look into this : attar and deveic; a Ecsition regarding the radio frequency assignment problem. in tne If :ne Regient identify a generic problem, ream we vill sur' ace
< nile, for the recer: Oc 1
Federal Ct.municaticas' Comission (FCO). the President, we sugges na you be in a pcsition t.c advise en your rtgicnal situation ahead of its teccaring a crisis issue. Similarly, if, after consultation, utilities or State and local geve-n-ments , can identi fy dead s; cts or lack of coverage in tne 10- asc 50-mile eme gency ;;anning :enes wnich are act ecve-ed by tne Emergency Broadcast System, taey should se advise FE?.A Head:uarters wnica will take stecs with the FCC to secure inis coverage in tne earliest feasible time. This may include ; revisions der back-u;:s te dawn-:c-dusx ccm-mercial becadcast statiens . We do not knew i f thi s i s a real probl es, but i f it i s , earl y heti on by FE% in assuring covertse is vital . O
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SIT 1 JECT: Radi o l ogi cal Eme r ge ncy F r e p.a r e dn es s ( try ) Cud da nes Mersorandum Seri es Docaments The a t t a c t ed Cui da nc e Mc=c r a ndue ( Cd ) Se ri e s d ocusme nt s a re t h e f i rs t to result f rees car ef f orts to revit:11s4 this important forum for IIP inf orw ei on. The su g ge s ti ons you made in re s pondi ng t o ry Ma rcle ' 5, 1983, wemo r andum on re.i na ti t uti ng the Se ri es ha ve r aa ult ed i c r e vi si o ns to seme existing Ws and the development of new GM's. I as plassed te ! t rs =a ci t the f ollov1=g f or your prese t ass. CH 5, Revision 1 A,gr eement s A.mong Geve rw:tal Agenci es ant. Private Parties GFG Revision 1 Ka gi ona l Ad vi s o ry Cowai t t e e Cd e r cl:.a t i ca i with Qtilities
/N Cu la , Revision 1 TL"w.A Act i n n t o %11 f y Ale rt and Motif f ca tion
$ysttaa Agad:.st NL'R.F.O-06 54 / 7 D:A-CP 1, Lavision ! l CM 20 Fo r ei rn !.4 gua g e Tr ans la t i on o f Pu bli e Educatier. 3 roc. hurts and Sa f e t y Mas sa g es i i
GM 22 Escordkacping f or Fuhlic Meet 1=gs At tne sty,ge stion of a tumbe r of Rap, lor.s , revised and new CM s# will f ollow a standa rdi z ed f or1ms t as evide:t i n th e e t t e ch ed docume nt s . This creates an identity f or the seri es and is ir.t ended to aska the itf ormention contained to asen more accassible. By tai s memo ra ndwa, ex:i stinc W e 1, 2, 3, 6, 7, 9, 10, 11, 12, 13, 14, ad 15 are cancelled. GM's 5 and 6 are superced d h the attached. Work on rsristons to ::'s 4,16, and 17 a nd new CW s conti: ants. Your af f o rt s i n t M.4 andaavor are appreciated. Atta enssent s As Stated CC O L - - - - - -------- _
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@b T /2 Federal Emergency Management Agency Washinpon, D.C. 20472 Ny Cc ceer 19, 1953 Gddasca Memo rmedum 5, Revisic: 1 Tech ological Eazards AGRIDENTS AMONC COVE 2NMINTAL ACINCIIS A.C PS.1VA!! pal!!IS
,, x Purvose Thi s guidance memora dum sugges t s ca :al oging wri:: c2 a gr e eme:: s r ef e r:1:g to the co: cept of operacious developed betweet Tederal, Sea:e, and local age:cies a:d other support orga=.iza:1ons havtag an e=arge:cy respcese role vi:hi the Z erge:cy Fla= 1:g Icce.
h ekground NURIG-06 3 4 /II.w.A-RI?-1, lav . 1, evaluation cri:eria A3, calls for the prese::4:1c: of agree =e::4 1: each plan. Such agreeme::s or ec==1:me::s could be volu=1:cus a:d overburde: the pla vi:h paper. Guidatee ne deca 11ed agree =e::s required by A3 =ay be 1:corporated 1::o the pla: by - e a:d cataloged by ti:le, type of agre==:, a:4 gover_ meet level, i:cludi:g s :: and ef f ective dat es . All parties vould merely sign-of f on a cover sheet cert..yi-the validi:7 of the me:erials ref ere:ced. Se a ctual a 1: gr e eme:: ms : :he: be s ho rt , the de: ailed filed 1: the Regie: a:d be available for inspectic:. agreese::s could be lis:ed and trameed i: the same ma::er as procedures. 01s is a ae:hed si=ilar to tha: used previously by the Regional As sista:ce Co==1::ees 1: ces.u.:g with supporting ast erials . A1:ernatively, Sea:e and local pla:s may 1:clude all agreezer:s 1: a sui:able appe:diz. , legardiass of how the agreeme::s are cataloge'd a=4 ref ere=ced, their curre:: s:stua sust be periodically verified by the Federal Emerge:cy Ma:4geme:: Age :7 De Regio:s should have a tickler file on all agreeme::a a 4 ask for :ev c:es , or updaced signatories if they expire or the authorities of signatories are foreclosed by reorganizations or sta:ucory limita: Loss. nese stacucory lini:stic should be available as refere:ces 1: the legal basis alame:: Alb. O
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- SU'AJEC"f: Radiological Emergency Preparedness (E7) M dance l Meesorandum Ser1 es Doc. aments The a t t a c t ed Cui da n c e Mc:mo r a nd ue ( CH ) Se ri e s d ocume nt a a r e t h e f i rs t i
to result f rocs cor ef f orts to revitaliza this important forus for RE7 interw eien. Th e su g ge s.ti ona you ma d e i n r e s pondi ng t o my Mo r el. 9 , 1983, memorandum on reinstituting the Series have ramulted in revisions t o s ome e s.i s t i ng Gi's a nd t h e de ve l o ptme nt o f new Gl's . I as plear.ed tc tra cacit the f ollowing f or you.r present sae. QI5,Revisic$1 Agreements Anong Gover wee:tal Agencies sec.; Private Parties
, Gi S ,. Revi sion.1 Engt ona l Advi s o ry CM t t se Co orti:,s ti en v' with Utilities cza 16. Ravision 1 F2.4 Act i on t o qua li t y Al e rs a nd 8ct i f i ca t i o n 5yat ans Aga1 s& WILO-0634/7D:A-11P-1, 14viaion 1 'V Cr. 20 Foreirn Language Transla tio . of Pub 11; Educatici. 3 roc.hures and Saf ety Maasares GM 22 Recordkeeping for Public Meeti gs At tne suggestion of a number of Regens, revised and new CM s# vill f ollow a standardized f ormat as evide:t in the a tt ached document s. Ois creates an iden:Aty f or the series and is intended to make the inf orustion conta.Lned to amen more accessible.
By t ai s ammo r s ndum , existing o!'s 1, 2, 3, 6, 7, 9, 10, 11, 12, 13, 14, a4 15 are cancelled. GM's 5 and 6 are superceded try the atta ched. Werk on ri vi si ons to G:'s 4, 16, a nd 17 a nd new GN 's eenci nue s . Your af f o rt a in th.a andaavor are apprecdat ed. Atta ennent s As Stated CC O -
Federal Emergency Management Agency
/ Washinpon. D.C. 20472 Cctete. 19, 1983 Cuidacce Masorandum 8, Revisto: 1 Technological Hazards REGIONAL ADVISOP.Y COMMITTEI COORDIMATICN WITH UTILTIIIS Purwse This Guida:ce Memorandum outli:es now pla :1:g a:4 preparedness activities should be coordinated betwee: Re gi ona l Ad vi s o ry Commi t t e e s ( RAC ) a :4 utili ti es .
Backgrou:d Although the guida:ce cottal:ed i: NL*RIC-0 6 54 / 72.w.A-RI?- 1, R e v . 1. appli es to o=e or more specific organization::s, the iste::tio: throughout is to e sure that all parties recognize and u:de rsta:4 e.sch othe 's capa bilities , responsi bili ties , a:4 chliptio:s. Thus, it is vit al t ha t all efforts be pursued is recog:1 tio: of the authorities and precedures established by 44 CTI 350 and the Tederal Emerge:cy Manageme:t Agency (T!?.A)/Nuclea r Regulatory Comei ssio (NRC) Metso ra:dum of Unde rs tanding. Cuida:ce Est reme ca r e mus t be takes whe: dealing directiv vith a utility to resolve a problem of a=y. 4ture. The authority a:d responsibility for directi g the safety aspects of the 11cer. sees are under the purview of the NRC. It is both advisable and appropriate to work through NRC 10 order to resolve a y problema that might a ri s e wi th li c e ns e es . Radiologi cal emerge:cy prepa rednest post- exercis e draf t evaluatio /criti:tue report s should not be f urnished to the utility 1:volved. This restrictie applies to any communication , whether f ormal or it.f ormal, which 1:volves j i: formatio: under co=sideratio: f or submittal to the As sociat e Director l f or review and det er31:acio: of exercise adequacy. It is esse:tial to adopt this practice is order to avoid eve: the appearance of a co=flict of 1:terest. 1 It also should preclude misuedt rata ndi:gs which may arise amo:4 exercise pa r-i d p.a:ta or with the public and media. L y, 1 I ____-______ L
Y s.
-n FEDERAL EMERGENCY MANAGEMENT AGENCY Wasnington. D.C. 20472 (m' . V. \. .
AUG 7g ME."CRANDLH FCR: Regional Directors FTCM: Jonn W. McConnell *'31F#( Assistant Associate 0irec:cr fer Pcpulation Preparedness SL% W : Guidance Mercrandum # 16 - Standard Regicnal Reviewing and F4perting Procedures Encicced is a procedure for regional review and evaluation of State and local radiological emergency preparedness plans and reperting the results to TEMA Headquarters and for keepirq the related recc ds.
':he Federal Emergency Management Agency will te expec*.ed to make a detailed statement for the record in NRC proceedings. Because scme of tnese pro-ceedings may be contested, our review system imst be able to supeer. any ,n - FDA statements made to the NRC. .
These pt cedures were reviewed with the Regional Assistance C:mittee .
' Chairmen on July 25, 1980.
Attachments:
- 1. Guidance Memorandum 416
- 2. Sarple Federal Register Notice I
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l \ i m/ Aug:.s: 7, 1980 1 Guidance wemorancum 16 Radiolog2:al EmergenFy Precarecness olv:sien 1* STANDARO REGICNAL REVIEWING ANO REFORTING PC.CCEDURE5 l r er 5 tate anc :cas Mac5::::::aa 3mergencv rescense rians .
- 1. Backer:und nevisec Nuclear Regulatory C:mmission rules for racicl:g::al energecev planning (10 CTR 50.D,10 CTR 50.47, and 10 CTR 50.5A) recu:re tnat :n er:e to centinue ccerations cr to receive an eperating license, licensees anc acclicants must suemit their emergency plans.to tre NRC. Ince:encently, if tne State and local governments have prev:cusly previcec tre:r lans t: :ne NRC for inclus:en in the f acility cocket the licensee and accl : ants neec Only provide the accr:criate reference. The NRC .111 make a fincing as t: .netner the ensite and cffsite emergency preparedness pr:vides reasonatle assurance that adecuate prctective me asur es . e'an and will te taken in tre even: Of a o raciclogical emergency.
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- v NRC will base its determinate n of cverall emergency pr e arecness caca: *. ,1-ties in part en TEMA findings anc FEMA evaluati:n Of Offs?.te recarecress cacaellities. These findings and evaluati:ns will te tasec ucen a ::mcart-son of the pl'ans to tne ocjectives and criteria =cn t ainec in tre ;nterim guicance cecument, "C 1teria for Preparation and Evaluation :( Rac :1:g::a1 rmergency nescense' Plans anc Preparedness in Succort of .%cle ar P:-e r :l an:.s" ,
NUREC-0654/ FEMA-REF-1. NRC will issue a Safety Evalust:Cn Re: Ort (SER) -nl:n will contain statements f cm TEMA's find:ngs anc evaluati n. The FEMA ev alua tion of offsite plann',ng is descr:, bed in the FEua tr:: see rule AA CTR 350. This procesee rule assigns rescens:t:1:ty t: :Pe TEM: Regacns for making fincings and determinations en the acecuacy of State arc local raciclogical emergency plans and their precarecness :aca 111 :es. Regions w:11 suemit their findings to FEMA headquarters wh en -ill make the final ce te rmination of ade;uacy knd accreve the plan =nen all c :teria are met. FEMA headquarters will then tr ansmit this approval to tre State governor and to the !.RC. 8
- 2. ,ur:cse This memcrancum e s t a:11. sn e s a pr ec ecur e for FEMA reg; ns t: review S t at e, local plens, to maintain a file en the status of the lans, anc t: r e:c r tre regional findings of them to FEMA Headquarters, o
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). Dreeccures After a State has formally su:ma ttec its clans . and recuestec a TEWA r ev i ew .
the Regt.:nal Direct:r -111, within 30 ays of rece::t of tne State reccef publisn a net e in the Feceral Register ackne-lecging its rece::t pr::esec sa CT9 350.S), A samele f eceral Register Net::e :s attac ec. Te Reglenal Direct:r - t '.1 also ass:gn a FEMA ::cket f:l e numcer :: eac" s;te r e pe;;; geg;,3.,; f:l e . This same ::cket file nu= e; 111 te inchcec in ne notice concerning tre site. There ar e five elements in the file num:er ; 1. . FEMA; 2) Rac:01 gical Emergency Preparedness ( E?); 3) Reg:en acceer laraca: ' : a) State (t o-letter acc r ev iation) 5) 5: te numcer, ass:gnec .-nr:ncl:q:: ally for mul ti-s te States as plans are receivec. Therefore, f:: tre exan les . snown in tne Cecrgia case the Occket numcers are FEMA-RE?-4-CA-1 f:r tre 'ars' site and FEMA REP-4-CA-2 fer tne sec:nd site. Eacn Reg:enal Director =111 ;:recare and ma$ntain a ::melete s:te s:e::':: fil e of the Regi nal fincings tasec ucen tPe review anc ev a ha t::n. **e file will ;: resent current status of the plans and will be uccatec as re= information is receivec fr:m sucn scurces as: :tse rv a ti:n and esaltat:en cf drills and esercises; remecial acticos; training activities; revis::ns and corrected ce fielencies =f the plans; comments fr:m tre c=1::; anc :trer
;ertinent sour ces. The file will also include :hanges : :Orrecti:ns an :n are made after the in:tial TEMA evaluat::n and ace r:v a l . In lacet
- 11 te such th ngs as ;ucl: alerting 'and net:facati:n sy s tems ;-n::n are met recurred until July 1981) and ;u=11: inf:rmatien and ecucat:en :::grans. The file will be a matter of puol : recere and =111 te the :rinca:a! scurce document for the Reglenal 0 recter's evaluat:,en anc f : any FEMA : .-ti::.:st::n n relatec NRC pr:ctecings.
The Regicnal file will include a synces:s :( the findings :P tre Reg: ...e Assistance Committee and the FEMA Rega:nal staf f en One acecuacy :f State and lecal gevernment's plans, erececures and level =f :re:arecress. This , syncesis =111 track NUREC-065c/FE.M1 RE?-l t ::ver offs.te ::;e:::ves
-:.1 "A" and "C" threugn "F" anc eacn element within eacn ce;ect.ve. It l e !
- Deluce a Ocs tive statenent for each cr:teria element inat :s f: enc ::
- satisfact:ry, stat:ng by secta:n and : age numeer -nere tne :lan :ents: s ::
covers the criteria element. In additien, it -ill r e f'. ec t unsat:sfac*::s ' elements =1th a:propr: ate ex lanati ns and references t: ::rrect iv e acta:ns or reasons ny corrective actions are nct being taken. These state-ents :n f tre unsatisf act:ry elements will also incicate by secta:n and : age nun er el ement is ::verec in tre plan. Entr:es in tse synces:s -111 te ::m:st;:le with those entered in the FEMA MIS system, anc ine synces:s .t11 te :a:nt s: rec se that it can te repr:duced anc sent f:rwarc :n "a neurs nctice. After the Reglenal Assistance C:mmittee and the FEMA Regi:nal staff *av e c=mpletec tnel; review, including the evaluatien of the sue crting exer::se and pun,lic meeting re uired in pr :csed AA CTR Part 350, the FEMA Eeg:.:n al Director =111 issue a report t: FEMA nesccuarters On a site 5:ecif:: tasis #:r tr e State and 1: cal g:ver-' ment clans, crececures and ;retarecness 0a:20,1:- ties. This repcrt =:11 censist o f a narrative evaluati:n Of the O'. ans aga:n s t d
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n-_____- . eacn of'tn2 13 msjer of' site 3 bjsetives ( A snd C tnreugn P) =f Nt?C -Cs34/ FDit AT*-1. It =111 als: ::nta:n 'an ovalustion :f tas ;te:arteness, anc staffing sncul d incluce ::=ments en tre ;r:cedur es," tr aining , : escur:s s , g , levels, qualifiesta ns ar c ecu :: ment av ail acility te s ue=c rt ine' gerers! evaluatt.:n of eacn :cject:ve. (w The reecrt will also centain a sunmary of the everall fincings ar9c cetar-minatt.:ns by the Reg .:nal Cirecter. This sunmary st cul: stcw tna: . State an: local plans, precedures, and ;:ecareeness t ave been : meleted acc are acercate protect puolt.: health and safety in the event of a racial qical emerger cy. The sun =ary sneuld desenstrate c=nclusive working 's.nc= ledge s e the Reg :nal t level ef . the preparedness status of State and l= cal governments for ina : sceci fie site. It should reference a specific cate Theof the sue:crting ::uner-fe rma t of the se. nary taticn for the findings and determinations made. will be the sa e as that use: ty tne NRC in its Safety Evaluati:n Re: ru e 5r ns) , a same., =e o f =nien is a ttaenee. s 1 O O 9 g - n
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l 1 FCCRAL CMCRCNCY MANACMENT :CNCY Cc ket: IB A-RE? A-CA-1; F9A RC? 4-I Ce:rgia Radi:!:g:.:a1 Emergency Plan ACCT : receral Emergency Hanagement Agency ) t i ACTION: Notice of Receipt =f Plan , I SL'MMARY : T=r ::ntinued Ocerati:n of nuclear =cwer plants, tne Nuclear Requia i tery C mmissi:n recuires accrev ed lirensee anc State anc 1 cal geverments' ! radielegical eme rgency rescense plans. Since FOA has a res;:nsibility Ce rg:a ma s i
': : l reviewing ine State and 1 cal ;s ernment ;,l ans , the State =f su mitted its raciclegi:a1 emergency plans to tne FINA Regi nal ef fice. These
,. plans sue; cit nuclear pc-er plants =ni:n i=cact n Cecrg: 2, and incluce trese I. Mat " Nucitar {;
=f 10:21 gov e fnments near the Cecrgia P:wer C:mcany's Edwin M.
Plant 1 cated in Accling . Ceun ty ,, and the Alatama P:wer C:m;any's Geseen Tarley Nuclear Plant located in Heusten C unty, Ala:ams. CATE Plans Receivec: Cune 9, 1950 - TCR TURTHER INFORMAT ICN CONIACT: Mr. frank Newt:n, Regi:nal C:,recter , ~OA Regien IV, 1373 Peachtree Street Nh , Atl an t a , Ce:rgia JC3C9, ( CA) S 51 -I 40. In succort :( the f eceral requirement f r emergency rescense :' r NOTICE: TOA has pr==csed a Rule descricing its prececures f : rev iew and a Stata and l= cal geverment's radi:l=gi=al emergency res;ense plans. Su. n: to this pre;csed TOA ' Rule (aa CTR Part 350.8), " Review and Ac:reval :( 5 tate Radi:1=gical C.mergency Plans and Preparedness," a5 FR *341, tne St ate Rac::- Icgical C.mergency Plan fe r . tne State of Ce:rgia -ss received ::y One "eceral E:nergency Kanagement Agency Regi:n IV Cf fice. Included are plans fer lees!' governments weien ars =nclly : part ially -: :. .L.- - the plume ex;csure pathway eme rgency planning :enes :( the nucle ar plan:s. Ter the Haten Plant, plans en included fer Saxley, Ap= ling, Tec .e s , Oeff Cavis, and Ta ttnall Coun ties. F=r the Tarley P l ant , plans are incluce: f: Blakely and Carly Counties. Cecies of the Plan are av ail able for review at the FD A Region IV Cf fice, :: t?wy will be made availatie uoen request in ace rdance wi th tne f ee senecul e; for TG A Treedcm cf Inf rmatien Act recuests, as set cut in subcart C cf aa CTR Pirt 5. There are 6C6 pages in the dccument; re;r:cucti:n fees are 5. C a:
- page paysble with the request fer ce;y.
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J f; , Ccmments on the Plan.may t.e sucmattec in writing to Mr. Trank Newton, Regi nal .
'v Director, at'the acove accress witnin thirty days of this rederal Regisis note.c s .
TEMA . procesec Rule' A4 CTR 350.10 also . calls for a ;uelic meeting :::.or ic
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' a;;roval o f ' the #1ans. Details of this meet;.ng =111 Oe announcec in . t. e (name of newscacer with tne largest circulation in the area of~tne nuc'! ear facility) at least two weeks crier to the seneduled meeting. Local racio anc , television stations will be recuested to announce the meet 1,ng.
SAMPLE L i C l 4 s s 5
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V J/,H a 195j F g yg: .:t TOR: Cer.nis Wiatkowski Director
. Regional coordination yp.: ,t : John I Dickey, Direct ==
R:dL e1cgi:n1 E. c:gency , Preparedness Divisien p ;
.- LA THRU: John W.HcT nnell M[
Assistaat Associate Director for Population Preparedness SUEICT: Joint Ixercise Procedures - R.IP Guld.ance Mersoranduin f 17 Please arrange to have the attached guidance mee.orandum published is the Director's Memorandum as soon as practicable . The f ollowing text sheuld ) acccepany the guidance memorandu= . p In coordination with NRC, the attached joint ener=ise procedure s have be: n . ( developed. The objective is to establish more unifor=.ity in the Radiologi; Dnergency 7:eparedness exar:1ses under the preposed TIM A Rule 44 073 350. Since the TI:t A " Rule" speaks to off-site activity, the exercise procedaroc esiphasize that aspect. However, in recognition of the pa rallel involvese.m of the NRC, their activity is shown in d.irect rela ti on t.c tdt A ' s . We h v4 also ciscu s sed with tne !!R. our desi n for coepletien et all plans-and e x e rcis e s by April 1, 19 81. This is apparaatly causing a p:= hist: with some licensees 'who will not be ::ady to exer =ise ef f ectively until af ter this date. Therefore, while TrtA must concinue to press for 1.zpiew-tatic? of state a.nd local plans by April 1, Regions must be flexible in schedulink of joint exercises 1.n suppor. of the " Rule". Tacilities shou.1d nc. de fort into pre-April exercises if t.5ey are not ready, since prer.ature inucive e." of the facility works against the develep=ent of int egratsd pr epa redness . hope that this approach will help in schertuling your exercises more ef f ect; I l If you have any questions about this memorandum please contact Marold W . c. at $23-1781.
Attachment:
R,t? Caldance M emorandum i 17
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Jrr.ua:f 3, 138i Gcadasca Mescrandus _17 Rad:.cis p :11 2:ergencf Preparedness ::irissen
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. JCCN'" CCEC~SC 7*.Cu t"KIS is the issarest of assv.ri=g 24: the health and sadatf cf the ;c.bil is pertac.ed in de event cd as ac=1 dent at a suciaar ;cwer pla:-, i-is secassary f == ce Licer.see ( applicast) , := c=d :: as e==.yency preparedness exercise joi= ly vid appr priata Stata and iccal agencies .
Se reia cf de Fedeni geve:-.=ent at su== exercises is .c evaluata .n e capattlitf cf he : ' rf and de Stata and ice-* ' g vertsents t: ;;::ect de pub 2.f.c heale a d satsef is he eves cf as accident at the facilitf. S e m A cfdicial respensibia for "'s ac:17 :7 is ha ap;;:priate Rey:. -= '
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Cver de,last few sent.hs there have been seveni jci exe:: ses whers mA and NRC have =ade reviews both crally is as cpe see*' g, and is w :.t e f = == . We find hcwever, significant variata== a=cng res=s is te ;; ced : esed fc ;;; riding the ers12.a:1=. S e seed f== a s andardi.=ad appre.ae 1.s evidant and .he f=11: wing is a guide f == bcth D.A and NRC persensel T i=velved in exe=1.se evalsa ics. . A.ssir--m-ts !== cffsica ebservers will be =ada by he RAC Chas:=as . - * :. : e observers v:.11 be assigned 1cca:1==.s by de NRC *ea :,a ade r . A :se:1:g Of all pa.=les shcuid be cenducted ;;ier := ce exe =ise .= assure hat all chserve icca ic=.s a.re s.a.ffed by an evalt.at==, as well u .= =ak e v . A : eve: last ::.== a changes ars .acassa:7 bas ed == fiaid c=di 1:ss , :" ' 4 ef evale.at=n ava11abia, et=. ne exs=ise shecid be foll:wed as seen as pessible by a =1 ige.a . Se
= !. i ge.s i.s a werxing sessi=n f : pra' -.ma:f review cf ce exar:sse be: vee de panicipants (Stata and local of fiestis and :f represe: asi es and
.hs Tederal obsa rer taa=s headed by mA a:d the NRC) . ~. t ss=uld be Op e:
tm ::a public and the =edia. Oey shcuid,. hewever, at 4:d as chs e.-- e:s , 4:
=ct pa:_ =1;ata La the discussions . 13 accal :: :-- ancas die:ata -12: a p=17 ate sessi n be held with the Stata author ias, i =u.s be seceduled 1.:.
advu=== and the 12.fc =ation pr=vided by the RAC Chai: a- at t.h e private j =esting shocid be speated is the cpes sessi= . I 1 l l r . t
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, i.s des:.:stia :: == du e :e :: :ique V:.c all de pr sespri par .:.es present, ( e. g. ::a RAC, tse L reived 5:ste and 1 cal au ::::. .se:s , :e Licer_s ae and NP.C) . *hers =.ay he situa .cns w era su == a ; c ast' ::1- *
- .s sc: Ie asibi.e and separate sessiens (ena related := Licensne ;a.. 1:1,40-and e sisted := 5:sta and iscal par:::ipatien) a s necesaa:f due :=
1og1.stacal c fundi. q ::=st af.sts. 'tasa situa 1 =m art to be elearsd = advasca .br: he Trt AMGC S t ee:1:q O ~-- ::s s. *= su==. esses -J.a E Chaa. as shcuid be avaliable f: be h cc:.:isces. The ;cist. erttique shcuid M chaired by : e-'RAC chai:=e: a:d shcuid be ., wa-- - = sea -2s 10 -' ' a a::. As pa.- "a overali f::=at :le RAC Chai =as v1.11 d1scuss chser rar.icns of the effsite :sspense and tra N?:::: v1.'1 discess chsa: ra ices cf =e ens;.:a :ss;ensa. Oe St.a a, 1 cal at t.his ae ' g :: =aa e ;rt-gcve_- .=ests and 2 ' ' ' ty shecid be pr es en s===aticus. Te: -le ;eist critigae to be effec ive, it sn cid taXn pl.aca vi-"
- he 24-heur period ' ediately fell: wing the exer-me.
Thers shculd al.sc be cpper:- ' :y f = clarifica:1 :, 7:es 1:ns : ce-ts by 11:sesse, Sta a and local efficiais. ts RAC Cha.i_-= w ' s eve: r_ ew s 2:=-= .: should h based en ::m: s f
=s
- servas:.:= It RAC ex.krs and ether TF.A chservers as well as ""
- cvn sheuld i=ciada -l e s :=g pc12:s as veil as a gensrs.'. s ate &='
=e:: == .1e
's dadi:1accias seead. = der =c c:' :::=s _:ces will :.hs RAC a m s indicata -la: =a Sta:e er 1.0" '- p*=-* ;assed er failed Ee/s.e sace.id isdica .a taa: .se ==. m ets ar s ;; = ' ' ' ary .c be f=1.*.:wed tf a w p ehansive evale.asic: vi-" 14' days. -'t a fisa.1 n:tA fisdi..gs s"
dat.e " -=.1 c, as well a.s app = val cf a Stats and/or iccai pl.a. , _e - t ace = ding to 44 07R 350 of vc1=h can exercise 1.s a ;. art, is reserved A.ssociar,a Oirec :: f== ?ians and Prepared:ess i= Was*'*g.::. The prt:cipa.1 - *estenes f T&.A and N7.0 exercise obse:-b .ics and crit:.g a:s g ves is "ciest.re 1. ':"hese =11est::es a:s f : planni.:S pur;cses and actc.a1 setedules say =eed t: he diff ersa: because =f *.ccai cir ::=s ts. .==s. O
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- 75 days' Stata and Licensee cistly sd "--: axercise eb e. .i e :
TDtA and HM Reg; nal Offices.
- 60 days mA and NM ?.egsenal Cffices discens and =se v:. .h licensee / state as =ecessa:/ and prepare .espense.
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. 45 days Staza and licensee scenarie developers sulcit ex e r: s
- l sea =ars= := mA and NRC Rev css f:: rev *w- -
l l - 35 days TDtA and NM Regi-~< scrif f Sta a and Lieer.see of s c enar . accept.th:11:y.
- 30 days m A and NRC Regicns deve10p' specific post e.xe rcise ::1 :.gae schedule with the State a:d ad-r se mA a=d NRC headgaa. _ars. -
- 15 days :he RAC Chad-=- and NM team leader vi'1 ee. : devel p cbsa:-rer aet.icn plan (whare s s.10:ed, hcw =anyf: mea:
c ga=ication, vna := i=ck for).
- L day Meet.ing, L: the exe::ise a:sa, of a.L1 Tedeni itse:~re:s bc n casi a a 6 =ttsi:a := fL:= a as sL;:. ents , a=d 5:ve :.:st:: ;
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I day Exerr.ise I. day TZMA and RAC chse: rers caucus .= 11.ats obser a icns. NRC chsa: run aise eauces . :.: e=114:s chae: ra :. r.s. E day RAC & = d - = = and NM : sam leader =ses, as, sec . af ter .hef : sspec ive caucuses as practical, := eccedinate Tedeni pa.=1:i;at. =n is cc: 17:e. E := - i day "ci== RAC/NEC ::i:17:e General Aee=da A. State, iccais and lice =see ; es en . :Asi vi ew s.
- 3. Crt_igas cf ef f sita acti:ns, by RAC haa. ac C. Criticas cf ensits ac 1:ns, by NRC.
C. C= ique ed Tedeni responsa (if applicab'e), by RAC Chai ac. E. Cype. =itf f: cla:15i stien Tasst.1cas == :::=:nents by licensee, S t.at a a:d isca,s (; sss and pu.w. :.: gr.as. :=s v d set he en .ertained t.::isg tha ==d ique).
'3 days Writta= :::: Taes by m A Re?:.: := 5 tate, v th : paes : Tr-headgaar.e:s a. d NRC and by NM Regi - -- anseewarn:p.)
, := NRC hend t:ar:e:s and TDtA.
t (Rac andad Sus, pense :ates) en umm __m__-_..
l- 8 H_. k,-4 Federal Emergency - Management Agencv < w__f
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Wunington, D.C. 20472 ! OCT l.9 SB3 l l MD cRANtLt PQt: Al'I '7.e gi onal Di r e ct o r FIcr!: p,$ I.Ll vb blin g Deput y A.s soc:i a t e :ti rect o r State and local Programs and Support. W ATECT: Eadiolot tcal Emergency Frep.e rednaes (II?) M dashes Memo randum Se ri e s D>c.sment s Tbs a t t a ct ed Cui da nc e Memo r a ndue ( Gi) Se ri a s d ocume nt a a r e t h e fi rs t to result f rom car ef f orts to revitaliza th.is taportant forus for R.D inf orma tion. Th e su g g e s ti ona you an d e i n r e s pondi .g t o ry Ma r e!. 9 , 1983, memorandum on re.inacituting the series h.sve raault ed in revisions to some existing Gi'a aM the development of sev Ol's . I as pleased te tracanit the f ollowieg f or you.r prese:: n.a c . QI 5, Kevision 1 , Agreements Aneng Gover see:tal Agenci es anc Privat e Parties Gi G. Revision 1 Ma gi o na l Ad vi s o ry Cowni t t e e Co e r til e ti en with Utilities Cd 18,.D.eyiSion 1 FIF.A Action to M1.1!y A.le rt a nd Hot'i fi c.a ti on Sy s t e.ma Agai r.a t NUR?.C-46 34 /7DM-RIP-1, Ka ri si o . 1 O CM 20- Foreirn Latguage Translation of Public v Educatier, 3rochures and Safety Masaares GM 22 Ea cordka cpi .g f o r Publi c. Meetir.gs At tne sugestion of a tumber of Res, ions , revised and new Gi's v111 f ollow a standardized forms as evide:t i n t h e a t t a ch ed d ocume .t s . Ois creates an identity f or the series and is int ended to "ma' e athe i r.f orma tion cont a.ined in seen more accessible. By t al e me<=o r a ndum , exi s ting ol's 1, 2, 3, 6, 7, 9, 10, 11, 12, 13, 14, a r.d 13 are cancelled. CM's 5 and 6 are superceded by the atta c.hed. Work on ri vi si o a to C:'s 4, 16 , a nd 17 a nd new GN 's eenr i mue s . Your e.f f o rt a i n t h.u endaavor are appreclat ed. At ta enment s Aa Stated CC O , m
1 n, .4 Federal Emergency Management Agency
.s 2?}/ Washington, D.C. 20472 Ccenne. 19, 19e3 Guidance Memorandum 20 Join TU.A/NRC !ssuance Teennological Es:ards FOREIGN LA.4CUAGI ~3.ANSLATION OT PU3LIC EDUCATION 3ROC l
Purco s e This- guidance memorandum suggests when ::anslation of public educa ica =ac erials in:o a foreign =inori:7 language is warranted and when c:her efforts should be made to af f ord f oreign language minori:1es the same educa:1onal inf or .a:1on as the general population. Ba ck ground A: a see:ing of :he U.S. Nuclear Regulatory Commission (NRC) on Septe=ber !!,1951; ne and at a number of Atomic Saf ety and Licensing Board hearings thereaf:er, issue of radiological saf ety educa: ion and inf omation for foreign la .gua ge sinori:1es living in the Plume Exposure Pathway Ione (E? ) has bee . raisec. Nei: hor NRC nor the Tederal Emergency Manage =en: Agency (TE".A) ha s e s ta b li s n ed guidancs for when transla:1on of public education materials in:o a =1:c 1:7 -
,q language sheuld be required. The following is in: ended :o es:ablish such guidan'ce. {'"his guidance vill be submitt ed to the NRC/TIMA S:eering Commi: ee f or Emergency Prepa redness f or consideration as an addi:lon :o elemen: C, Public Education .and Informa: ion, of NUKIG-0634/TU.A-RI?-1, Rev.1, In the mess:1me, the follevi..g vnen a revised edi: ion is prepared. -
guidance vill 'sovern.] This guidance :akes the Voting Righ:s Aci of 1965 vi:h Amend =ents of 1975 and 1982 (Public Law 94-73)'as a point of departure. Under this law the Oiree:or of the Bureau of the Census is required to identify those Sta:es and politi:a1 subdivisions where more than $% of _:he citizens of voting age are me:bers of a - as single language minority. Poli:ical subdivisions are defined by the Ac: counties and independent cities , except for the folleving: In New England: ci:ies and : owns; In Michigan: ci:1es and townships; In Wisconsin: ci:1es , villages and towns; In Alask.a: election dis:rie:s.; and In Louisiana: pa ris hes . The coun:y or equivalen: da:a developed under the Act appear to be a prac:: cal p basis f or deter =ining when transla:1on of public education inf orma:1on in :ne ( Fiume Exposure Pathway EP: is warranted.
l Cui danc e 1.i c a na e e s , Stat es, and local governments should provide public edtca: ion and inf orma:1o n (brochures s..4 saf ety mes sages) translat ed into a f o r ei gn al..o ri ty la ngua g e , if the number of the foreign ainori:7 populatio.. . of voting age exceeda 5% of a surrounding county's or equivalen: populatio... Such a county or equivalen: is covered unde r the Act and is already under an obligation to provide bilingual ballots and vot er services. , A list of counties covered under :he Act ba s ed on the 1970 C4 .s us i s at: ached. Periodic updates are available on the Summary Tape File STT & at each State's Cacaua ::sta Can:er. A li s ti ng i s a t :a ch ed . 1teco==e .da:1ona If mi .ori:y language 1.dividuals in the Plume Exposure Pachway I?: do noc exceed 3: of the population and there are no foreig. langua ge za:erials provided, other ef f o rt s should be =.ade to 4!!ord them prot ection s1=.11a r to that provided to the general population. Such efforts =1ght 1.clude: o 5'p ecial cours<ts of ina: rue: ion f o r :he f or eign langua ge com= unity leaders; - o Public =eetings f escuring a trained f oreign la .gu. age speaker;
.o Trai ing leaders of neighborhood organizations; o Advertiseme .:s in f oreign language newspapers; 4..d o Providing oral assista .ce to individuals through a .* buddy
- sys:e=.
These effor:: s hould be a da p t ed t o lo ca l ci r cu=.s :a nc e s :o a chi ev e :h e purpose of the Public Infor:.a:1on Program, i.e., to bring the ; cpu!.a:io.
- o a knowledge of how : hey vill be ale rt ed a..d vna: : hey are supposed :o do, if a reac:or ace:1de.: has occurred.
At :a ch t e.". s Aa 5:stad Ncte: hhile ct identified in de C4, an "Adiress .ist" cf Sta:e Oa_a Cantar Program. State Cec:-dinati q Crganicaticns, dated April 1953, as prev .ded as an attac. tant. ' itis list was c:r: piled by de U.S. epa: : nent cf Cer:Tnerce's Bureau cf the Census and identifies crianicatiens vicin eacn State that provide infer =atien to the Census en " language nincrities" that c:rprise nere dan 5% of the w: irg pcpulatien. ~his attach en: is net previded in cis set of Cs's because it is dated arxi is of li .ited value to organi:ations i.-ple enti .g radic1cgical e argenej prepared .ess p: :gra: s . O
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t.is: ef L5 cu=f.:das required :s provide hi-1.1:p21 bal*.: s a=d assista=ce u=dar ::a 7eci:g 11gh:3 Ac: of 1963
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""11s limc1:g is bas ad the 1970 ee= sus. S a 3 ure as e.f :h e 04:su.s v '.1 accu issue a rwismi lis:1:g haamd e :te 1980 cecaus. To jud Te fr:= a f u, 1. . ..mo1 e_s er = , , .h4= x..sd. 31- u = o a1 se m a= ==1.=x cri Ese maaber d cou= 1as :ve:ed neda: tha Toei=g lign es Ac: vi.'.i
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/ Wathington, D.C. 20472
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' MDORANDt?H FOR: All Regional T.irect ors !
l TROM: g\GNO Sa wel 'J. Speck Ass,ociate Director St ate and Local Programs and Support 511BJEC : 34d.iological Emergency Preparedness (RE7) Gutdance Memorandum #21, Rev. ! , I am pleased to t:ansmit the final version of Guidance Memorandum 21, !
"ACCI?TANCE CRITEPI A FO R EV AC*JATION Pl.ANS " f o r you r p r e s e n t use. All suggestions you madis in response to my Memorandum of October 24, 1982, j have been evaluate d and almost all of them have been accepted and i incorporated. j Attachment As Stated O
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Guidance Memorandum 21 Technological Hacards ISUr23r7 29' 1984 p ACCI?TANCE CRITIRIA TOR EVACUA!!ON Fl.ANS Pureese This Guidance Me=orandum provides standards and criteria for revieving and evaluating evacuation proceduras and time estimates for various sectors 'and distances within the plume exposure pathway I?Z, contained
- in plans developed by State and local governments.
34ektround the Tederal E=ergency hanagement Age ncy ( TEMA) has received a nu=ber of inquiries concer-ing more detailed coerr*1onal guidance for evacuation planning. Plan and procedure reviews and post exercise assessments by Radiological Assistance Committees and TEMA Regional Directors note many problems associated with evacuation preparedness including 1nadequate maps, lack of preparation for the evacuation of the handicapp+3, transien and f oreign language speaking, non-cooperating bus drivers and bus companies , etc. In the Atomic Safety and Licensing Board (ASL3) hearings, the di!!iculties of evacuation are frequently dramatized by interveners and p' roof that local governments are prepared for effective evaeustion is not readily available. . Even though evacuatien is only one of several options available for pretsetive l
. p ~~ sction, it is a fequiiement for sach community in t.he plume exposure I ergency Planning Zone (E72) of a nuclear power plant to have an evacuation plan.
Unless a plan has been developed and at' least partially tested, evacuation cannot be activated as promptly and ef fectively as may be necessary. Evacuation planning sust be done on the basis of a range of possible accidents that say require only a ring, a sector, or the entire I?! ce be evacuat ed. A range of possible environmental conditions and daily and seasonable transport patt erns vill have to be assu=ed. It is also important to know the ti=e period necessary to ef f ectuate a ; partial or complete evacuation. Taced with the decision whether ce shelter or evacuate, authorities cust c:mpare the time period predicted f or release of gaseous and particulate sate:141 with the time needed for evacuat".on. Unless evacuation can precede the release, the public say be expesed to higher doses of radiation in their cars than they would have been it. base =ents or other shelters, yIMA issued RIP-3, " Dynamic Evacuation Analysis: Independent Asners=ents of Evacustion Times from the Plune Exposure Pathway Emergency Planning Zones of Twelve Nuclear Power Stations
- in order to assist with evacuation time estimates. The report deals with reactor sites surrounded by high population density and concludes that evacuation times tre highly sensitive to environmental conditions and to local government po li ci e s.
D (
TIMA is in the process of acquiring :he :echnology for pe rf orming comou:eri:- evacuacion s1=ulations through :he Exe rcise Evaluacion and Simula:1cn Tacill:7 (EIST). This technology will be made available :o Sta:e and local govern =enis and will go a long way :owards i= proving and evalua:ing evacuation plans. Guidance The standards and acceptance cri:eria ouclined below are based on NURIG-0654/
- TIMARIP-1, Rev. 1, wi:h additional evacuation-specific cr1:eria from other documents. I: is addressed :o one or ore local governments w1:h
- he Scace playing a guiding and assis:1ng role.
The information provided is divided into eigh: uni:s, each broken d:wn into a generic planning scandard and a lis:ing of the applicable evalua:icn criteria from NURIG-0634/TIMA-RI? 1, Rev. 1. Emergency planners may meet :he evacua ion planning standards and accep:ance criteria :hrough a variety of approaches:
- 1. The evacuacion plan say be incorporated in:o existing radiologi:21 emergency preparedness plans.
- 2. The 'evacua:icn plaa may be added as a separate annex :o an exis:ing generic emergency plan.
- 3. A separace evacuation plan may be developed, providing as a mini =u=:
- a. Statemen: of purpose;
- b. Concepc of operacions;
- c. Listing of local gove rnmen: and private sector orga.nizations tha: are part of the response fune:1on;
- d. Identification of a specific irdividual by title who shall be in charge of each response fune:1on; and .
- e. Func: ions and responsibill:1es of each primary and supporting response organi:acion.
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EV ACU ATION PLANS STANDARDS AND ACCEPTANCI CRITIRIA I. IVACUA~!CN PLAN DEVILCFFINT r%
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) Plannier Standard 4 l
l Responsib111:7 for evacua:1on plan development, reviev, and distribu:1:n l of implementing procedures is established. ' ?rimary rospensibili:7 for i j emergency response by local governments has been assiJned, :he emergency responsib111:1es of various supporting organizations have been specifically- l
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established and each principal response organization has developed plans and implementing procedures and has identified staf f and resource needs to respond in an emergency si:uacion requiring evacu.tcion. An individual has been identified by :1:le who has authority to order evacuatien and
. so authorize re-entry. An evacuacion time asse ssment study has been 4 prepared.
Acenetance Criteria I-1. NURIC-0654/TDiA-RIP-1, Rev. 1 Ivaluacion Criteria: A-1 ; A-2 : A-3 ; k-4; . J-10 a , b, 1, and m; C-1; P-2; P-3; F-4; P-5; ?-7; P-4; and Appendix 4 ! II. ALIRT AND NOTIFICATION, CCE*NICATIONS AND DfERCINCY TACIL 7':IS Plannine' Standard s ( Adequate emergency f acilities and procedures to , support the response effort are provided and maintained. Provisions have been sade and a I capability exists for the emergency organization :o communica:e ;r:ce:1y l among its own components end with State and other emergency response activi:1es prior to, during, and af:er the evacuation period. Ale rt and Notift:sti:n procedures ar~e developed and a capabilitt to disse =ina:e notifica:1:n j and prompc inscrue:1on to the public is maintained. Acceetance Criteria II-1. NURIC-0654 /TDiA-RI?-1, Rev. 1 Ivaluation Crt:eria:
- I-2; I-5; I-6; !+7; T- 1 ; R-3 ; R-4 ;
J-10c; Appendix 3; TIF.A-RI?-43, S:andard Guide f or the Ivalua:1:n of Alert and Notification Sys tems III. RILOCATION CIF:.R Planning Standard Provisions have been sade to receive, register and moni:or evacuees for radioactive:y a: reloca:1on centers; allocate congregsge care 10cgi g and feeding facill:1es; establish a recep: ion and care manage =en:. structure; and serve the human needs of special groups such as the aged, infir e c , n g handicapped, transients or prisoners. j f V l j
s Accaotance Crite'rta III-1. NURIG-0634 /TDiA-RIP-1, Rev. 1 Evaluation Crt: era: J- 12 ; .J- 10 h; J-10d, K-53 III-2. Prov1de a list of relocation cente rs v1:h es:f =ated capacity of each. Alloca:e ha:ard area population to evacua: ton routes. Provide adcress, telephonc cu= bet, and rou:e descrip:1cn to be taken :o each relocation . center. III-3. Describe the concept of managing reloca: ion centers. Indiente s:affing
- requirements and describe arrangements to provide emergency s:affing.
III-4 Identify special populations (e.g. , prisoners , hospi:a1 pa:ien:s , persons in health care facilities, etc.) and provide for : heir relocati: and care. III-5. Provide'the means :o supper: and decon:a=ina:e ecergency verkers, including supplies, ins:ru=ents, equip =en:, =edical care and was:e disposal. TV. EVACUAT10N TRAVI*. 1
?1.<nning Scandard Develop a =ove=ent control ' plan vi:h provt: ices for de:er ining ::ans;or a:i to be used, control of ::af fic flev, provtsien of fuel for eeergency se.-rica and provision of publi: transpor:a: ion for : hose segmen"s of the populaP.i ':
their own ::ansportation. 1 Acceccance Criteria i NURIC-06 5 4 / TIM 1-RIP-1, Rev. 1. l IV-1. , j Evaluation Crt:eria : J-9 , J-10g , J-101, J-10j , J-10 k
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IV-2. Descr,1be the method for the ::ansporta:icn of mobilt:iy i= paired persons and special populations. This should include people in group quarters, such an :he elderly and infir=ed, priseners , boarfing school residaner, etc. Designate centrally loca:ed pickup ;oin:s for pe' vi:hou: seans of transportation. IV-3. Iden:1!y for each jurisdic:1on the single individual by :1:le or agency responsible for the coordina:1on of all public transper:a:icn resources planned for use in the evacussion. IV-4 Describe evacus: ion rou:es in na rra:ive f ore along vi:h su:corting =aps include :raffi: con:rel check points, access :en:rol points and contingency sessurrs. O
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q 7. PUBLIC SAIT U
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~' 71,annine standard Arrangements have been sade to provide lau enf orcement and fire protection
~ I during the evacuacion period. Provisions have br:en made :o support the orderly novement of evacuees to recepcion areas; provide craffic control of the commuting emergency workers; movement of supplies and ' equipmenc; and securi:7 of the populacion and property in the recepcion and evacuated areas. Provisions have also been made to accee$lish fire prevention and suppressica, rescue and mobile-medical aid in avacuated and relocacion areas.
Acceccance Criteria 7-1. Provide for :he identification of emergency workers and vehicles.
?-2. Include provisions for security in evricuated areas, relocation and care centers, congregace lodging and feeding f acill:1es, and parking areas.
7-3. Assign res,ponsibili:les f or the traising and use of volun:'eer personnel to assist public safety forces. VI. EVACUA!!ON OF MIDICAL AND PU3LIC HE.AIJR PACILITIES jr's Planning Star.dard Provisions have been sade :o accomplish the relocation or consolida:icn 6f pacients, equ'ipme nt and personnel of hospi:als, aursing homes, and other health care fac111:1es in the plume planning zone. Acceotance cri:eria 7I-1 NURIG-0454/7EXA-RE?-1, Rev. 1 Evaluation Crice-ia: J-10d; J-10e; J-10g; K-3, K-4 71-2. Describe the concept of reducing patient population in hospi:als, nursing homes and other heal:h care f ac11:1es. Describe ac:lons required to protec: those pacies:s that canno t be relocated out of the hazard area. VI-3. Provide f or augmentation of~ health-sedical personnel, e.g. , nurses ' aides, paramedics , Red Cross pe rsonnel and othe r trained volunt ee rs. l v mm_-____2_ _ _ . _ _ _ _ _ _ _ _
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l 4_ VII. RADIOLOGICAL EXPOSURI CONTROL Plannine Standard Provisions have been made for :he capab111:7 to deter =ine the doses of - emergency workers and others presen: in af f ected areas of :he e=ergency planning zones. Plans include procedures for the dis:ribu: ion of bulk-s:ored dosi=ecers. The means for controlling radiological exposure shall include .I exposure guidelines consistenc vi:h the Environ =en:a1 Protec:1cn Agene.y's (IPA) Emergency Worker and Lifesaving Accivi:7 Protective Ac:icn Guides. Acceotance Criteria VII-1. NURIC-0634 /PDtA-REP-1, Rev. 1 Evaluacion Cri:eria: E-10; H-11; J-9; J-10e; J-10 f; K-3 a & b; K-4; K-Sa & b; O-4; O-3; VI!!. - FU3LIC INPCFy.ACCN AND EDUCA !CN PRCCRAM
. Planning Standard Provisions have been =ade for :he coordination and dissemination of public inf ormation and educational =actrials Oc :he general public by :he = l media. Official information vill be released through a designa:ed spokesee via che Emergency 3 broadcasting Service radio network. Educational ma:erials explaining procee:1ve measures have been dis:ribuced.
Acceccance Cri:eria VIII-1-. NURIC-06 3 4 / PEMA-RI?-1, Rev. l' Evaluation Cri:eria: G- 1 a-d ; C-2; G-3 a & b; G-4 a-c; G-5; E-3; V7.II-2. Develop and distribute at least annually public inf o r=ation materials, to include, but not necessarily li=1:ed to:
- a. Why evacuate; !
- b. Where to go;
- c. How to get there;
- d. Whac to take;
- e. Public cranspor:acion;
- f. Instructions for :he disabled;
- g. Securi:y in the evacuated areas;
- h. Provisions f o r pe c s;
- 1. Provisions for lives:ock ard produce;
- j. How to keep inf ormed; and i
- k. Who to contan: f or addi:ional inf ormation.
l Q l
ATTAGMENT I O. . . ACCI?TANC CM'"IMA FOR IVACUATION PLANS V RITIENCE MATEM ALS o -Ivacuacion Risks - An Ivaluacion IP A-520/6-74/00: o C:IAR (,C,alculates logiesi Ivacuacion And Reepense): A Generic Transpor:acion Netverk Model for the ?NL-3770 Calculation of Ivacuacion Time Es cinates NURIC/CR-1504. , o Methodology for Ivaluacion of Emergency Response Tac 111:1es , NUREG-0814 o An Analysis.of Evacuacion Times !scimaces Around 52 Nuclear Power ?lant Sites, NURIC/CR-1856, DNL-3660, voi.1. Tindings and Implics:1ons froc :he Reseas o Evacuacion Behavior and Problems: Literature, Contract DCPA 01-79-C-0258, Part II, EPA 5:0/1-78-0013. o Protective Action Evaluacion: .
.o Evacuacion Planning in the TMI' Accident TIMA RS 208-31., January 1980 . .
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g/yg% Federal Emergency Management Agency A Washington, D.C. 20472 jf/ 007 i g se MD30RACLt FUE: Al'1'lep onal Dir e ct o r s F1Crt: [] I.LI ^$evb h113 Deput y As so ci a t e Di re ct o r gg Star e sad 1.ocal ProgTaas and Support RT1 JECT: Eadiologi cal Emergency Frepa redness (II?) Cuidames Memorandum Seri es *ocuments l The a t t a c h ed Cui d.a n c e Mc=c r a n d ue ( Crf ) Se ri e s d ocume nt s a r e t h e f i rs t i to result f rom cur ef f orts to revitalize this important for.un for RZF inf orma tion. Th e s u g g e s ti ons you ma d e in r e s pond.14 t o ry Ma r ch 9 , 1983 , memo r a nd um on r e.i ns ti t uti ng t h e Se ri e s h.s ve r am u lt ed i n r e vi s i o n s to some exi s t ir.g Gi* s a nd t he development of sev Gl's. I as pleased tc transmit the f ollovi:; f or your prsae t nae. QI 3, Revision 1 Agr e ene r.t s Ano ng Cav e r sw :t a l Ag e n ci as a r.:. Privat e Parties i Gi G, Revision 1 Kagi ona l Advi sc ry Coussi t t ee Co or di . a ti en with Dtil.ities C11 IS, Revision 1 TD'.A Act i on t o N11 f y Ale rt and 4tifica tion 57s t esa Ag 4 :.s t 2n.,R?tC-04 3 4 /7D*A-IIP
. ~i , 24 vi ai c . 1 Cr. 2C Foreirn L4Wge Translation of Public Educ.atier. 3rochures and safety Massaras CM 22 Encordtecpint for Fuhl.ic Meetings
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At tne s%;e s tion of a .nsabe r of Re p.i opu , r evi s ed a nd oev Ms will f ollow a standa rdized f ormat a s evi d e nt i n th e a t t a ch ed docume nt s . Th.i s creates an identity f or the series and is ir. tended to make the ir.f ormation cents.ined in asen more accessible. By t hi s me<=o r a natus , est.sti.c DI's 1, 2, 3, 6, 7, 9, 10, 11, 12, 13, 14 , a nd 15 are cancelled. CW s 5 and 6 are super:eded h the atta ched. Wort on rivi st a::.s to :'s 4, 16, and 17 a nd new GI's conti: sues. Tour af f o rt a in the..s endeavor are appreciat ec.
'At t a cnment s As Stated CC O
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+9" Federal Emergency Management Agency Washingten, D.C. 20472 p
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, Cc Ober 19, *?S2 Guidance Memorandum 22
- yach=clogical Hazarda AICOR.0XI!?!NC II Ul?.DtINTS TC1 FU3LIO MECINCS Purvese .,
( nis Guida:ce Memerandum provides guida:ce to legie:a1 Assista:ce cosezi::ee 0T1 230. j (1AC) Chairse: c: keeping records of public meeti:gs required under 44 i i Rockr cued 4A C71 Far: 350.10 requires : hat a public see:1:g be held :s inf orm a:4 discuss vi:h the public and media :he 5:st e a:d local gover me::'s radiologiesi etargency pla:s 4:d coedue: of :he joi:: e:rercise prict 'to submissio: to :he Asseet.4:e Oirect:0 5:ste a:d 1.cial.F;cgrams a:d Support, for ici:ial Tederal Imerge::7 Ma age:at:
. Age:cy (m.A) app roval. I= addities, 44 071350.9(e)' requires a see:1:g of p r:icipa '
of exercises f or coc:1:ved T.A approval a:d this meeti:g shall 1::1ude ::e publie-and cedia as chae: vers al: hough : hey (:he publir, a:4 media) =ay, a: :he 01 sere:10: of the Regic a1 Direc:ct, submi: wri::e: comme::s er sugges:1cca during or af ter the meeti:g.. Se Nuclear Regula:ory Cassissic: (MRC) supports these require:es:s
'i: the TDiA rule, baelievi g : hat public cessa:: is desirable.
q Cuida nc e I. Public Mee:i:g 1: Adva:ce of TIXA Approval Bef ore the Regic:a1 Director ca: subst: his or her evaluatie: of :he 5:a:e and local gover.me::'s pl.a: a:4 exe r:i s e :n t he As s o cia t e 01 e : c e , a publi c se e :1:g . sust be held pursua:: to 44 CTI Far: 350.10. Although this se::1:: de s cri':es s, :ne aware:es
- he purposes of :.he see:1:3 a d requires to:1ces to e sure publi:
seed for accurate.recordkeepi:g is not specifically addres sed.
'of :he ne public meeti:g shall be prof assic: ally recorded a:d the :ra: ,.a scrip:
rti e s v::hi secti:g be made available upo: request f o r r evi ew by 1:: e r es t e d three verki:3 da y s . De tra acrip shall 1:clude a li sti_g of all 1:di-e.duls i=velved i: the secti=g, their organica:1c: a:d/or occupatia=, a:4 place :! restdre: Dia 1:cludes all Federal, 5:ste, local, a:d 1.1: :see ef ficials a d represe::a:ives ,; as well as all members of the ge:eral public a:4 sedia veo comme::, ask ques:1::s , asks suggestic s , or otherwise pa rticipate. A copy of the official tra: scrip: vill be sai::al:ed ih the Regiocal Of fice. Additio al copies may be distribut ed to the eceau ity(ies) withi: the eme rg e::y
- ne pla==1:g sete of the nuclear Nw ple :. :he s:a:e, a:d licassee(s), 4:
discretion of the Regie a1 $15se:te. Be resui:s of the public use:1:g. 1:cludi:g a:7 deficie:ci es 1: pl.4:s o r ex e r ci s es . J oted a:d correc:ed, should be made par. of ::e se 071 330 e v a l.t s ti : pa ck.a ge submitt ed by the Regiotal 01 ecto r to T.A Headqua r.ers . e+ O'
.
- l
)
1
- . hee:ings Subsequeni :o Mai..:enance Ixercises relieving an e.ter:ise f o r con:inued TDtA a pproval, i.4 C71 3f0.9(e) r eq ui re s :ha:
j
- he Regier.a1 01ree:cr shall :ndue: a see:1:g :ha: vill include :he exe rci s eand par.icipants, the NRC, c:her appropriate Tederal age:cies , plus :as puoli:
media as observers. Se purpcse of :ne =eeting is :o iiscuse :he evalua:icn of the ~ exe rci s e . A: the discrecien of the Regi 041 Di r e c: r , ::==ent s a nd sugges :1:ns fic= the public and media =ay be sub=1::ed at or after the meeting. hese ::==en:s - and suggestier.s v.11 be tair.en in:c consicera:icn duri:g the Regional Direc:or's evaluation. la addi:icn, the Regier.a1 Direc:ct er his/her desig.ee =4y res:ced McVever,
- tese vri: en f.c==en:s er sugges:1ons duri..g the =urse of : e =ee:1 4 a ::cpy of esca vri::en docu=:en: vill be sain:21.ed by :he. Regi :a1 Of fice v::n ~5e A::A cn ec na=e, orgar.1:a:icn, occupa:icn, and residence of :he inquirer / c:==en:o r.
- o :he c:==en:s or sugges:icas vill re :he Regional Oiree:or's respc .se, i.! any.
If the respc .se is made orally in :he course of :he meetin;;, a synopsis of :ne responso shall be a:: ached to :he vrt::en =aterial. Se resul:s =f :he =eeting , includi..g t .y defici enci es ci:ed by :he public exe r :1. s e or media and the dispest:icn of :hese defielenices, vill be included in the rspo r: submi::ed by :he Regic .41 Oirec:ct :: TD:A Headqua rt ers . O i J O
i n [ h Federal EmergencyJManagement Agency 5 bl Washington, D C. 20472 1 ME 5 GM MEMORA.M H TOR: All Regional Directors TROM: Saruel W. Speck . (e gk9'.b. Associate Director
> State and Local Progra=s :
1 and Support StTBJECT: Radiological E=ergency Preparedness (RE?) Guidance Memorandum #24 I am pleased to trans-Je the final version of Guidance Me=orandum 24 " Radiological Emergency Preparedness for Handicapped Persons" for your present use. All suggestions you made in response to sy memorandum of Nove=ber 30,.1983, have been evaluated and almost all of the= have been accepted and incorporated. Attachment As Stated
?
e l_ .. . . L -- - - . . - - _ - - - - - - - - - _ _ _ _ _ _ _ _ _
;g:.1 5 , '.38 4 Guidance Memorandum 24 Technological Hazards bV RA010 LOGICAL EMERGENCY PREPAREDNESS FCR HANDICAppC) PERSONS purcose
- This Guidesce Memorandum supplements and expands upon existing guidance in NUREG-0554/FIM-REP-1, Rev. 1, relating to the protection and safety of handicapped persons in radiological emergencies.
Background
Recent progress in making public f acilities accessible to handicapped . per2cns, and in deinstitutionali:ing the more severely handicapped, has I increased the need for greater ef forts during emergencies to ensure the safety of the people with disabilities. Handicapped person can now be found throughout the general population in schools, private homes, offices, industries, jails, day care and senior centers,'etc. Even though they are apt to be costly and, therefore, controversial, the following fundamental premises regarding handicapped, people and emergency preparedness have been adopted: Handicapped individuals have a right to protection in emergencies; Scme handicapped individuals have speciali:ed needs in emergencies; and
., Emergency preparedness activities should recogni:e those needs and plan actions that promote participation.
While it may seem natural to view *the handicapped
- as a totality, they are not a homogeneous group. In f act,_ the dif ferences between handicapped individuals are probably greater than their similarities. The capabilities and limitations of handicapped persons vary, including functional characteristics needed to cope with an emergency.
To address this issue, it is necessary to view handicaps as part of three major types, each of which has its own speciali:ed emergency preparedness requirements: o Sensory Impairments:
. deaf and hearing impaired .
- blind and visually impaired.
o Movement Impairments:
. loss of normel mobility ranging from one who uses crutches to the quadriplegic who requires a wheelchair and special vehicle for movement in an emergency -
- frnil elderly persons
. life-support-system hindered.
o Ment al / E.-ot i onal Impa i rment s
. retarded
. emotionally disturbed
. senile q . extreme alcoholic / drug-abuse cases.
----m_____________- _ _ _ . - - - _ _ - - - - - _-
i.
.t-We must also keep in mind that some pertens may' have more than one cisability, b For instance, any handicapoec person may also have special dietary or mecication requirements. The needs of eacn handicap type will vary depencing uoan 4
l i the particular planning and preparedness standard being addressed. I NUREG-065a/ FEM-RE?-1, REY.1, provides general guidance for handicapped persons at:
- Standard G. Public Education and Information, G-id, which states that the 'soecial needs of the handicapped" should be recogni:ed in the coordinated periodic dissemination of information to the "
public on how they will be notified and what their actions should be in an emergency; and
- Standard J. Protective Response, J-10c and d, which requires that the State and local governments include in their plans "means for notifying and protecting those persons whose mobility may be impaired due to f actors such as institutional or otner confinement."
The section which follows expands upon this general guidance. It cutlines four planning and preparedness factors which should be part of any State and local plans, procedures and preparedness programs to ensure that handicapped ;ersons are notified and can adequately respond to a radiological emergency: . I. Identification of Handicapped Populations; II. Public Education and Information; III. Notification Methods and Procedures; and . IV. Protective Response. These guidelines are provided for use during your review of plans submitted for 44 CFR 350 approval. The guidelines for each factor are followec oy a discussion of salient considerations. _Gui d an c e I. Identification of Handicapped Populations Guidelines A means to systematically identify individuals within the plume exposure patnway emergency planning zone (EPZ) is established and maintained. The security of acquired information is assured. Functional characteristics necessary to coce with a radiological emergency are determinec for those i dent i fi ed. Individuals and organizations capable of assisting and the ty;e of assistance required are determined. The accuracy of the data is periodically validated. This data base is integrated with the planning 9 process and reflected in the plans and procedures. Discussion Systematic identification of handicapped individuals located within the EPZ around nuclear power plants is the first. major step in radiological _ _ - _ _ _ )
s
./m emergency preparedness (REP) planning for the handicapped. This will V) provide planners and decisionmakers with information necessary t'o determine adequate manp Ner, the level of services required, how to manage eu rgency aperations, and the types of response necessary. All compiled data should be kept confidential in order not to compromise tne privacy and a
security of handicapped persons who generally desire anenymity. Data identifying locations of stationary handicapped individuals will be
. necessary as a basis for developing protective response plans. Indi vi dual s '
' functional" characteristics needed to cope with radiological emergencies, including those requiring special notification but able to take independent action, ~will be taken into account in developing an appropriate array of protective actions.
The data gathering effort should also focus upon identifying individuals willing and capable of assisting handicapped persons and the type of assistance required, should such a situation arise. This ef fort will also serve to identify people resources within the handicapped community who may be utilized in the development, review, and exercise of REP
)
plan 2 for,the handicapped. ;
- l Sources of help in compiling the data include: l
. Responses from mailings to EPZ residents. Handicapped persons have generally responded to offers for. help included in Emergency Public Information brochures containing'a separate section with
-s f the heading "If You Have Special Needs.* A detachable self-addressed postcard by which residents can register needs for special assistance
~
has proved successful;
. Welf are or social agencies, which have a list of recipients of their services. (Normally this information is covered under the Freedom of Information Act);
- Religious,' fraternal, sorecal, and service organi:ations;
. Voluntary and non profit organi:ations, such as the Atnerican National Red Cross, the Salvation Army, and others. This information may already exist in their files resulting from previous assistance in emergencies; 1
. National organizations for dif ferent groups of handicapped i individuals, such as National Feceration of the Blind, j National Association of the Deaf'," Council of Organizations !
Serving the Deaf, Eastern Paraly:td Veterans Association, Nntal l Health Association, and National Paraplegic Foundation; ) l l
i i
.4.
- Fire serv [ce organizations, wnich have in many instances already provided action on behalf of handicapped persons for fire safety; and l
- Families and friends of handi. capped persons.
The joint exercise af fords an excellent opportunity to test the accuracy of many of tne data develeped, througn a telephone check, for example. . II. Public Education and Information Guidelines Preparedness and self-protection information is related to and in a form useful to major handicap types. Efforts are made to include handicapped persons in develeping information. Instructional materials are developed for three groups: Handicapped persons, the general public, and emergency workers. Products are disseminated using methods and channels most likely to reach each group in the resident and transient population. Di scussi on The most significant problem plaguing the preparedness for handicacced persons for emergency situations is a general lack of awareness. Thr ee main groups should be targeted 1.n developing instructional and educational materi al s: Handicapped people themselves, the general public, and emergency services personnel. Disabled persons, or persons responsible for them, need to be cognizant of the fact that they are vulnerable to a radiological emergency and learn how to prepare for and deal with the proolem. The general public need to be acquainted with ways of assisting handicapped persons with appropriate protective responses. Em rgency workers need to have the proper training in orcer to ef fectively and efficiently handle emergency situations involving disabled people. A general awareness camoaign should precede any intensive educational efforts. This will serve to alert handicapped persons that such an effort is planned and tell them where they may go for further assistance. This may result in their active participation in developing mora ef fective REF educational materi al s. It will also lay the foundation fo* the identification eff ort outlined in the preceding section. Conveying the information developed for each handicap type recuires a methodology related to specific handicap ~ types. For example, hearing-impaired persons may be ef fectively reached through pantomime and demonstrations, literature, translation to sigring, and captioned films. Visually-impaired people may be reached by large print, braille materials, audio cassette tapes, and Other audio medi a. The information and materi als developed may be disseminated to tnt public through a variety of channels including public and private schools, special education organi:stions, i j fire service organizations, State, local and school groues for hancicaoped people, coccunity and church Netings, major e tployers, firmt. selling or renting medical supplies, and libraries, especially those serving handicapped individuals. ' O\ 1 l l 1 _ - _ _ _ \
l l III. Notification Methods and Procedures
,3 Guidelines i lV i.
Appropriate alert and notification ( A&N) systems, including hardware and interpersonal communication, are in place to provide information in a
- form useful to major handicap types identified. . Methods .for veri fying warnings esi st. The AaN system provides handicapped persons with directions for required actions. Arrangements for special notification and assistance l- for those requiring it are in place.
Discussion Certain types of handicaps hinder an individual's ability to perceive, te alerted to, and evaluate an emergency situation. Current A&N systems f all short of meeting the needs of all handicapped types. Thus, multi-mocal (auditory, visual, tactile, etc.) warning systems geared to particular handicap types may be warranted and should be tested for effectiveness during exerci s es . Hearing-impaired persons, for example, will require redundant or supplementary warning, whic*i might be accomplished through:
- Public service announcement'ts conveyed on the TV screen by means' of printed captions or trailer messages imprinted on the bottom of the screen--as in weather in. formation bulletins. Such
- announcements can also be conveyed througn an interpreter using g si gning; k '
- Use of a telecommunications device for the deaf (TDO) whereby vocal messages are communicated ,in imprinted form; and/or
- One-way or two-way personal communications devices such as tactile alarm watches, digital transmitters, transmitters triggerec by hand devices, ard tactile paging system;
- A human network.
In. general, individuals with all types of handicaps should be part of a
" buddy" system in which f amily, neighbors, building management, or caretakers personally convey the message. This is most important in States =nere emergency agency personnel is not autnerized to enter homes.
It is especially important to have confirmation capabilities. built into an A&N system for handicapped persons. This ensures that the message has been received early enough to permit an appropriate protective response. Action by disabled individuals, especially those who are elderly, can be slow.
!Y. Protective Response Gui deM nes Protective action plans have been developed for all categories of
/'N handicapped individuals present in the EPZ and integrated into the d general radiological emergency plan, nespensible and knowleegesele
1 of. 1 i I contacts to provide communication and physical assistance are identified 1: for each handicapped individual. Agreements have been made with ambulance, transportation companies, and van drivers to effectuate the transfer of tnose who need special transportation, and route instructions are provi,ded. Special areas in reception centers have been set aside for the sensory and movement impaired, the elcerly and retarded, and registration,Agreements j decontamination, and nonitoring has been arranged for them. ' have teen made with nospitals, mental hospitals, nursing homes, and comunity mental health centers outside the EPZ to receive the severely novement impaired and emotionally handicapped. Di scussi on .! actions For handicapped persons, as well as for the general pooulation, protective 1
~
are either evacuation or sheltering. Evacuation consists of four phases:
- 1. Preparation;
- 2. Travel;
- 3. Stay at Reception Center; and 1
- 4. Recovery / Reentry.
Sheltering is assumed to take pla'c e in the building in,which handicapped persons find themselves at the time the incident occurs, be it at home, office, institution, store, or work place. I The data gathered during the identification stage will help determine appropriate, approaches to e.chieving the recuired protective actions. Number and location of particular types of handicapped individuals will suggest the most cost effective methods to use. The Sensory Imoafred , This group includes people with a variety of degrees of blindness and deafness. Once alerted and notified, such persons are capable of some self-protection. They can use normal means ofThey transportation and may follow do need, however, a
- the guidance given to the general population.
responsible and knowledgeable contact person, a relative, neighcor, buddy, comunity volunteer, or responder agency employee to assist them physically and to keep them informed. Such a contact may assist several handicapped persons as a group. Sensory impaired persons need a means of calling for assistance if required. An alternate buddy or contact person should be available if the first contact is prevented from attending to them. Evacuation For evacuation. some blind persons may need assistance with packing necessities f anc provisions for their guide dog, if one is owned, with egress from buildings, with entering unf amiliar vehicle! and unf amili ar reception centers. Deaf persons will need someone to communicate with them by writing and/or :y signing throughout all four phases of the evacuation. l 1 [ _ ._______________-_____L
7 - --- - - --- - J" ' 7 lx 1 Shel t er For sheltering, some blind persons may need a responsible contact to [D make sure wincows and ventilators are closed and a wet cloth is being l h used f or respiratory protection, l Deaf persons will need a. contact person to keep them inforned of emergency broadcast system (E35) messages. If TY stations are repeating E35
. nessages py signing or captions, this assistance may be unnecessary.
Mobility Imoafred Persons This group includes the frail elderly, people on crutches and walkers, in wheel chairs, on stretchers, and on life support systems. This group is alert, but slow or unable to respond by themselves. They must overcome barriers in buildings, such as steps and narrow doors. Assistance on a one-to-one ratio is necessary to permit some mobility impaired persons to join with the general population in following EBS instructions. Evacuation Mobility impaired persons should be alerted and prepared for evacuation as early as possible, because moving them is slow and sometimes complicated. For egress from high rise buildings , an elevator should be reserved f or them. The more seriously impaired people must travel in ambulances or vans with s;ecial lifts. If possible, they should be taken to a reception center providing an access ramp and wide shower and toilet stalls. The less seriously disabled can share reception centec space with the general population O oi* can have a special area set aside for them, people on stretchers and life support systems must be taken to hospitals outside the EPZ with C/ which prior arrangements have been made. If possible, their responsible contact should remain with them and look after their welfare throughout their stay and the return trip. Shelter If given a choice, mobility impaired persons may prefer to be sheltered in their own homes or at work rather than undergo the strain of evacuation. In this case, the responsible contact will only check on closure of windows and ventilators and on respiratory protection, everything else being routine for mobility impaired pecple. If authori:ed by the State Health Department, potassium idodide tablets (KI) will be made available. Mentally and Emotionally Imcaired persd s_ This group includes the retarded, senile persens, deinstitutionali:ed street people, emotionally disturded persons, alcoholics, and drug abuse cases. They may live in their own homes, in halfway houses, in corvnunity mental health centers, on the street, or may be temporarily hospitali:ed. ( Many of these individuals are on tranquili:ing medications. They may be more or less functional at different times. Ev acu ati on p Functional individuals may need very little assistance by their responsible contact persons, and may join the general population in all four phases, i l 1
l
- l j
The non-functional and emotionally disturbed will need the assistance of trained staff on a one-to-one or otner appropriate ratio. Necessities, medications, and records snould be taten along. The mentally, and emotionally distur:ed can travel in occinary cars and buses. Severe cases may need to se restrained. At the reception te'nter, a special area snould be set aside for registration. monitoring, and decontamination of the mentally and emotionally distur0ed and for their maintenance, wnere staf f can exercise appropriate supervision and control, and can administer medication. Agreements to receive a , specific numoer of individuals should be made with mental f acilities outside the EPI, to accommodate non-functional severe cases. Responsible staff snould remain with their cnarges througneut the reception and recovery / reentry phases. Shelter If given a choice, sheltering mentally and emotionally impaired persons in their customary surroundings may be preferable. The responsible contact will perform or supervise the required protective actions, such as clcsing of windows and ventilation grilles and providing respiratory protecticr, If :utneri:ed by tne State Healtn Department, potas sium iodide tablets (XI) will be made available. O O
_l "4 4 ' y-
#hk' ~
Federal Emergency Management Agency Washington, D.C. 20472
; Mr . w v -
JUL 1215E5 , I MEMORADNUM FOR: Regional Directors FROM: .,pp C Samuel W. Speck , Associate Director State and Local programs and Support
SUBJECT:
Guidance Memoranda, EX-1 Remedial Exercises anc EX-2 i Staff Support in' Evaluating RE? Exerc;ses ' Guidance Memoranda (GM), EX-1 Remedial Exercises and EX-2 Staf f Support in Evaluating REP Eaercises, are herewith transmitted for your implementation. The policy and procedures set forth in these GM's were developed :nrougn
' the cooperative efforts of Federal Emergency Management Agency (FEMA) and Nuclear Regulatory Commission (NRC) Headquarters staff and FEMA's Regional Offices. The GM's are operative for exercises held on or after July 15, 1985.
GM EX-1 has been approved for use by the NRC Commissioners and, except for i
. one enange, is similar to the final draft copy which was provided to you for i
. review and comment on May 17, 1985. The change was made to the second level l of exercises inadequacies, i .e. , " areas requiring corrective actions" replaces
" areas requiring improvement." The terminology to be incorporated in your
( exercise evaluations now reads: 1) deficiencies, 2) areas requiring correc-tive actions and 3) areas recommended for improvement. See my memorandum of
. May 17, 1985, for reference or further details.
It is my belief that the consultation process will accelerate the evaluation process especially in the matter of determining which are " deficiencies" anc which are " areas requiring correct.ive actions." The summary table of exercise inadequacies will be discussed during the consultation process witn the identification of the type of corrective actions necessitated by :ne classi-fication of exercise inadequacies. Specifically, " deficiencies" warrant immediate remedial action and " areas requiring corrective actions" will have to be addressed during the next biennial exercise. Ycur assistance and cooperation in developing these important GM's is appreci ated. Any questions concerning One implementation of these GM's should be directed to Bill McNutt at 646-2357. Attachments As Stated We e i
- a -
l (f i' g } Federal Emergency Management Agency
) 1 # Washington, D.C. 20472 j %
- August 11, 1987 MEMORANDUM FOR: All Regional Directors,
.ct ng Regional Director . PROM: ave McLoughlin Deputy Associate Director State and Local Programs and Support
SUBJECT:
Guidance Memorandum (GM) EX-2, Staf f Support in Evaluating REP Exercises I am attaching the subject GM for your implementation when planning for the evaluation of REP exercises and drills. I want to call to your attention the new requirement that the annual medical emergency drills be evaluated. This would not create any additional evaluation requirements when included . in the biennial exercise but would when held separately or in an off-year exercise. The evaluation of the annual medical emergency drills will be required until their performance is enhanced and evaluated under the criteria of GM MS-1, g] " Medical Services." If you have any questions on this matter, please contact Bill McNutt at 646-2875. Attachment As Stated i a \ l l l
I o . ,
./ "
s u! kS.ai i Federal Emergency Management Agency i V I 'k.J # J
/ Washington, D.C. 20472 l AUG I i 19PA I i
i GUIDANCE MEMORANDUM EX-2 STAFF SUPPORT IN EVALUATING REP EXERCISES PurDose The purpose of this Guidance Memorandum (GM) is to set l guidelines on the use of Federal Emergency Management Agency l (FEMA) and other Federal staff resources and travel funds for assisting State and local governments in preparation for and evaluation of radiological emergency preparedness (REP) l exercises. Status ( Supersedes earlier edition of GM EX-2 issued on 7/15/85, and . ! is effective upon issuance. Backcround 4 gg The allocation and use of Regional Office resources, i.e., ( ,f - staff time and travel funds, in support of REP exercises for commercial nuclear power facilities is primarily dependent upon regulatory requirements. FEMA rule, 44 CFR 350, requires full participation by State and local governments in REP exercises on a biennial frequency. A major reason for adopting the biennial frequency was to lessen the demand for Federal, State and local resources required to assist and support the conduct and evaluation of REP exercises. However, some State and local governments will continue on an annual exercise schedule because of a State law or a policy decision to do so or to support a request by the licensee. The Nuclear Regulatory Commission (NRC) rule, 10 CPR 50, also requires participation of State and' local governments with utilities in REP exercises including those conducted on a biennial frequency. Difficulties may arise when available FEMA funds are not sufficient to provide full evaluation for each offsite emergency response organization during a REP exercise. The lack of funds will generally be more acute where the emergency exercise includes many local organizations, such as boroughs, villages, townships and school districts. 1
r - - _ _ _ . . _ _ _ _ l Guidance , l,m) N - A. Rankino n1 Exercise Evaluation Priorities l l The following list by priority ranking should govern the use of FEMA Regional Office and other Federal regional resources supporting REP exercises. 1
- l. Exercises required pursuant to 44 CFR 350, including those conducted for initial and continued 350 approval and site-specific State and local full participation exercises required pursuant to 10 CFR 50 for the NRC licensing process. Exercise requirements under 10 CFR 50 include the need for an exercise to be conducted and evaluated within a two-year period prior to the issuance of a license for full-power operation of a plant. Regional staff should be prepared to assist and support the conduct and evaluation of such exercises to expedite licensing considerations.
- 2. Remedial exercises in connection with item 1 above per 44 CFR 350 and 10 CFR 50. -
- 3. Because of the heightened interest in demonstrating capability to perform appropriate medical services during a radiological emergency the annual medical rx emergency drill should be evaluated by PEMA, using
() the criteria in GM MS-1, " Medical Services."
- 4. Annual exercises in which the State and/or local government desire to exercise more frequently than biennially or which consent to participate with utilities in their annual exercises.
- 5. Drills required by NUREG-0654/ FEMA-REP-1 for State and/or local governments. These include communications, alert and notifications systems testing (including operability maintenance),
radiological monitoring and health physics drills. Therefore, evaluation of these drills is at the discretion of each Regional Office contingent upon available resources. B. Resources far Etauired Exercises
- 1. When there are no constraints or limitations to resources, complete evaluation of all organizations participating in an exercise should be carried out.
- 2. When there are budgetary constraints, the following guidelines should be applied in securing and allocating exercise evaluators:
V 2
- a. It is the policy of FEMA to have at least one l rx evaluator for the following organizations: State !
( ) and county emergency operating centers (EOC), State health agency, joint information center or equivalent, other locations where State and/or county officials have significant emergency functions such as field monitoring, and at a ; minimum one-third of all subcounty jurisdictions (e.g., boroughs, villages and townships). However, it may not be possible to evaluate all j local jurisf.ictions and organizations because of ) the extensive costs involved in evaluating large numbers of them.
- b. If resources are insufficient to support the i' number of evaluators needed to cover all of the subcounty jurisdictions (e.g., boroughs, villages and townships) and organizations, evaluators should be assigned to cover, Al A EJJ11Eum, one-third of all such jurisdictions. If there are evaluators in excess of the minimum one-third, i the RAC Chair may assign each additional i evaluator to cover up to three locations, thereby . I significantly expanding the extent of the {
evaluation. For jurisdictions which have areas l requiring corrective action (ARCA's), if more j evaluators are needed for a biennial exercise )
/ than are available, then Headquarters should be 1
( ,)/ consulted early in the exercise planning process.
- c. Us'ing guideline b. would assure the formal !
evaluation of all local jurisdictions (e.g., j boroughs, villages and townships) at least once ; over a six-year period. The six-year goal for evaluating all such local jurisdictions would be ] i reached through the rotation of coverage for one-third of the jurisdictions for each biennial i exercise. Regardless of whether these l jurisdictions will be evaluated, those that have ! significant responsibilities, as reflected in emergency plans, should prepare for and participate in,each of the exercises.
- d. When remedial actions (exercise or drills) are necessary, at least one evaluator should be ,
1 assigned to each participating organization.
- e. Because of potential FEMA budgetary limitations for supporting REP exercise evaluations, State governments should be encouraged to assist FEMA in evaluating local emergency preparedness functions and activities. The inclusion of State
^ evaluators would supplement Federal REP exercise evaluators of local jurisdictions and
(\ -} organizations and provide for a vore comprehensive 3 ; I l
l
- e. (cont.) evaluation report. State evaluators f
would perform their assignments under the i direction of the FEMA Regional Assistance Committee (RAC) Chair. C, Exercises Egi RequiIgd by FEMA and EEC Hulga The following guidance is provided to address the use of FEMA resources for exercises not required by the FEMA and NRC rules.
- 1. When the availability of Federal resources is not a problem, and upon specific request, these resources should be offered to State and local governments that participate in exercises beyor.d the minimom biennial frequency required by FEMA regulation. The degree of FEMA Regional Office and other Federal regional staff assistance and support for any additional exercise should be related to the level of participation of the participants, i.e., full or partial. This assistance and support should be essentially ths ,same as that provided for a scheduled biennial exercise.
- 2. When FEMA Regional Office and other Federal regional resources are limited but sufficient to provide some assistance and succort in exercises, such assistance and support should be offered to State and local governments. It could. consist of performing minimum f'/)
\_ observation and evaluation roles at only primary locations (e.g., the State EOC, local EOC, the joint information center or the State Health' Agency). No post-exercise briefings or meetings would be required, although the RAC Chair could assist if the State decides to hold them. Any exercise evaluation report would be confined to a summary table of inadequacies and suggestions for correcting them. In any event, Federal assistance / evaluation would be provided only if requested by the State and if resources permit.
- 3. When FEMA Regional Office and other Federal regional resources are not available to assist and support additional exercises, the Regional Director shall so inform the appropriate State and local authorities and FEMA Headquarters.-
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D. Allocation pf Staff Resources Regional Directors should allocate staff resources in support of REP exercises and drills according to the priority ranking in section A above. FEMA Regional Office evaluator requirements are to be reflected-in Regional Work Plans. The
. use of evaluators from other Federal agencies represented on the RAC's should be determined and planned, to the extent possible, so that resources for exercises and drills can be allocated throughout the fiscal year.
HE.C coordination This GM has been reviewed and concurred in by the NRC staff. O l I i P
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! ' 9T%5 Federal Emergency Management Agency
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L f]. jc Washington, D.C. 20472 JUL i 2 SG5 MEMORADNUM FOR: Regional Directors
.. .FROM: . , , . -e f Samue1 W. Speck Associate Director State and Local Programs'and Supeor:
SUBJECT:
Guicance Memoranda, EX-1 Remedial Exercises and EX-? Staff Suceert in Evaluatine RED Ereecises Go,idance Memoranda (GM), EX-1 Remedial Exercises and EX-2 Staff Sepcor: in Evaluating REP Exercises, are herewith transmitted for your implementation. The policy and procedures set forth in these GM's were develooed througn the cooperative ef forts of Federal Emergency Management Agency (FEMA) and Nuclear Regulatory Commission (NRC) Heaccuarters staf f anc FEMA's Regional Offices. The GM's are operative for exercises held on or after July 15, 1985. GM EX-1 has been approved for use by the NRC Commissioners and, exceot for one change, is similar to the final draft copy =nich was proviced to you for
,s review and comment on May 17, 1985. The enance was made to-tne second level
.t '_ of exercises inadequacies, i.e., " areas requiring corrective actions" replaces
" areas requiring improvement." The terminology to be incorporated in your exercise evaluations now reads: 1) deficiencies, 2) areas requiring correc-tive actions and 3) areas recommended for improvement. See my memorancum of May 17, 1985, for reference or further details.
'It is my belief that tne consultation process will accelerate th'e evaluation process especially in the matter of determining which are " deficiencies" anc !
which are " areas requiring. corrective actions." The suqmary taole'of exercise ) inadequacies will be discussed during the consultation process with the t identification of the type of corrective actions necessitated by tne classi-fication of exercise inadequacies. Specifically, " deficiencies" warrant- 1 immeciate remedial action and " areas requiring corrective actions" will ! have to be addressed during the next biennial exercise. l 1 Your assistance and cooperation in developing these important GM's is appreciated. Any questions concerning the implementation of these GM's should be directed to Bill McNut: at 646-2857. Attachments As Stated t ( l 1
i N Federal Emergency Management Agency j Washinpon, D.C. 20+77 d July 15, 1985 GUID'ANCE MEMCRANDUM EI-2 STAFF SUPPCRT IN EV4LUATING REP E%ERCISIS Purcose
- The purpose of this guidance Memorandum is to set guicelines on the use of
' Federal Emer;ency Aanagement Agency (FEMA) and other Federal staf f resources and travel funcs for assisting State and local governments in recaration for and evaluation of radiological ernergency preparedness (REP) exercises.
Backcround , The allocation and use of Regional Of fice resources, i.e., staf f time and travel funds, in support of REP exercises for comercial nuclear :ower facilities is primarily dependent upon regulatory requirements. FIFA rule, 44 CFR 350, recuires full participation by State and local governments in REP exercises. A major reason for adcoting the biennial frequency was to. lessen the demanc for Federal, State and local resources required to assist and support the conduct and evaluation of REP exer:ises. However, some Sta'te and local governments will continue on an annual exercise schedule because of State law or a policy decision to co so or to satisfy a request by the licensee. The Nuclear Regulatory Comission (MRC) rule, 10 CFR 50 .also requires participation of State and local governments
,V with utilities in REP exercises inclucing those conducted on a niennial frequency.
Guidance A. Rankinc of Exercise Evaluation Priorities . The following list by priority ranking should govern the us'e of FEMA Regional Of fice and other Federal regional resources observing and evaluating State and local participation in exercises.
- 1. Deecises required pursuant to 44 CFR 350, including those conducted for initial and continued 350 approval and site-s;ecific State and local full participation exercises required pursuant to 10 CFR 50 for the NRC licensing orocess. Exercise requirements. under 10 CFR 50 include the need for an exercise to be conducted and eval'uated one year prior to the issuance of a license for full-power operation of a plant. Regional staff should :e .
prepared to assist and support the conduct and evaluation of such exercises to expedite licensing considerations.
- 2. Remedial exeretses in connection with item 1 above per 44 CFR 35C,
- 3. Orills reoui ed oy VJREG-0554/ FEMA-REP-1 for State and/or local governments. These incluce communications, medical emergency ra::iclogical ponitoring and health physics drills.
O V i i 4
2 i 4 Annual exercises in which the State and/or local government desire to exercise more frequently than biennially or wnich consent to participate with utilities in taeir annual exercises. !
- 3. Exercises Not Recuired by FEMA and NRC Rules The following guidance is provided to address :ne use of FEMA resources for ,
exercises not required by tne FEMA and NRC rules. Vnen the availability of Federal resources is not a procles, these
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1. rescurces should De offered to State and local governmen:s that part'cipate - in exercises beyn1d the minimum biennial frequency required by FEMA regul ati on . The degree of FEMA Regional Of fice and otner Federal regional staff assistance and support for any additional exercise should be related to the level of participation of the participants , i .e., full or partial. This assi. 20Ce and support should be e'ssentially the same as that provided for a seneculed biennial frequency exercise.
- 2. When Regional Of fice and other Federal regional resources are limited but suf ficient to provide some assistance and su: cert in exercises, suen assistance and support shoulc ce of ferec :o State anc local ;;overnments.
It could consist of performing minimum observation and evaluttien roles at only primary locations (e.g., the State Emergency Coerations Center (EOC), local ECC, tne joint information center or the State Health Agency). No post-exercise briefings or meetings would be required altneugh :ne Regional assistance Committee (RAC) Chairman could assist if the State decides to hold them. Any exercise evaluation report would be confined to a summary tacle of inadequacies and suggestions for improving them. In any event, Federal assistance / observation / evaluation would be provided only if requested by :he State.
'3. When FEMA Regional Of fice and other Federal regional resources are not availamle to assist and s.upcort additional exercises, :ne Reg!onal Director shall so inform :ne appropriate State and local authorities anc FEMA Heaccuarteas.
C. Allocation of Staf f Resources Regional Directors should allocate staf f resources in support of rep exercises accordfng to the priority ranting in section A above. FEMA Regional Of fice observer / evaluator requirements are to be reflected in Regional work plans. The use of observers / evaluators from otherf Federal agencies represented on the RAC should be determined and planned, to the extent possible, so that resources for exercises can be allocated throughout the fiscal year. O
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- ,te' ' .4,9 Federal Emergency Management Agency
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[ ,) gM A Washington, D.C. 20472 l Q a f O b
. E PK Ndi FCR: kgicnal Directors Actirq Regierdi i !
Directer
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FPCM: Saruel R. Ass:cdte/..e pr State egrams ard Supper SLEEC:': Guidan randum IR-1, Policy en St~AECr-0654NO.A-?S-1 and 44 CFR 350 Periodic Fequirewnts Guidance Mecerardum (GM) PR-1, Policy on SUPE-0654SS.A-FD-1 ard 44 CTR 350 Periedic Fequirenents, is herewith transmitted for your i:clecentation.
'Ihis 2 bec=es aperative en Cet:ber 1,1985. ~he ;elicy, preceizes and require:nents centained in this G4 -ere developed te sync .reni:e me- vien the biennial exercise frequency, highlight periedic requirements aM f:c ally set f=rth the re;crtirq requirements in the " Annual tatter of Certification,"
which is due b/ Jaruary 31 for tne precedi::; year's activities. I locx to the Regions to make this GM availatie to State and local gover.nent organizations that w:uld be invol'.ed in its irplementatien.
-O U States should prepare and for ard an " Annual tatter of Certification" by Janu-arf 31, 1986, te re;crt on tneir meeting these pericdic requirements applica le fer calendar year 19C5. Maile tnese periedic requirements are net nes and have been cperative since the pW1icatien cf Nt. RID-0654NS.A-P_N.1 in 1980, this is the first ti. e w have asked States to f=r-nally repert en tnen.
Ycur revies ard.coment en the final draf t c=py sent April 26, 1985~was I helpful in develeping the-final versien. We appreciate this assistance ; ard cooperation. Any questions concerning the. i.:plementatico cf this 1 GM should be directed to Bill McNutt at (F :5) 646-2857. Attachment As Stated O
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! @w ~ ,tt)- Federal
.s Emergency Management Agency
(( fl Washington, D.C. 204T2
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SE d GUIDANCE MEMORANDUM PR-1 OCT I POLICY ON NUREG-0654/ FEMA-REP-1
'# AND 44 CFR 350 PERIODIC REQUIREMENTS
.' Purcose This Guidance Memorandum (GM) provides intarpeetation and clarification of requirements contained in . ne Federal Emergency Nat agement agency (FEMA) rule, 44 CFR 350, and NUREG-0654/ FEMA-REP-1, rel ated to periodic planning and exercise activities and other requirements affected by :ne ciennial exercise frequency and otner RED program emphases, i
Background ! With the publication of the final FEMA rule, a4 CFR 330, on Septemoer E3,1382, and the the Nuclear Regulatory Commission (NRC) final regulation,10 CFR 50, on July 6, 1984, it has become necessary to clarify some of the requirements contained in these rules and our common guidance criteria cocu :ent. NUR E 3-06!
/ FEMA-REP-1. Also, as we are approaching :ne fif tn year of :ne im lemer:a* ion of our joint (NRC/ FEMA) radiological emergency Dre ared7ess (REP) ;eogre, it is appropriate to highlight and clarify requirements relatec :o ;eru:cic assessments, especially those made in the fif tn and sixth year of a 5:a:e' l c REP program.
U' \ Guidance , The changes and program emphases related to the referencee planning stancarcs and evaluation criteria of NUREG-0654/ FEMA-RE?-1 and 44 CFA 350 are accressac to State and local governments and to Federal reviewers of plans anc :recarec-ness. This guidance is divided into three sections. Section A contains planning standards, evaluation criteria and other REP program require en s that have been revised and/or clarified to f acilitate comoliance. Sec f on 5 includes those which remain unchanged but are highlighted here to ensure completion and compliance. Section C describes the Annual Letter of .] Certification which is submitted by the State to the FEMA Regional Oi ector l documenting actions taken on :ne requirements presented in sections A anc 5. SECTION A: THE FOLLOWING EVAltlATION CRITERIA INCLUDE CHANGES FROM Et:5~ING REQUIREMENTS PLANNING STANDARDS AND EVALUATION CRITERION N. Exercises and Drills ] planning Standard Periodic exercises are (will ce) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will ce) conductec to p develop and maintain key skills, and deficiencies identified as a result of exercises and drills are (will ce) corrected. ( NUREG-0654/ FEMA-R E?-1, p.71) . i i
-g-N.1.b. Evaluation Cri* erion, An exercise shall include moeili:ation of St-ate and local personnel and resources adecuate to verify the capacility to respond to an accident scenario recuiring response. The orgi nization snali provide for a critique of ne cienul C .d' exe acise by Fecera' and State observers / evaluators.
._g.. sucn The sce7CiFio snould be varied from exercise to exercise . .
- nat :ne major elements of tne clans ano pre;arecness organi:ations are tested within a si x-year P - : ;na ;eriod. Each organi za:icn should -' axe m .l provisions to star; an exercise cetsen 5:00 a.m. and a:00 a.m. ~ :
r e ': ';- , :- ':- :n _ x - : : ' ;- - ,- ;f once every six years. Exercises snould be conductec durino dif ferent seas 3ns of :ne year at within a six-year oeriod f or exercisino unoer var 1cus e.estner conottions, ~! least are exercise over a perloc of s1x years c : : : : : : :- = should be un anno uilc ec. Areas of Review Evaluation criterion, N.1.b.., addresses several periodic exercise requirements, All of these requirement s are modi fied. The most important change is to perm 1: the testing of major planning and preparedness elements wi:nin a six ra:.'er : than five-year period. All of the remaining exercise retuiren nts are :i aced within this .six-year period. Attencant Criteria In addition to meeting specifi . exercise requirements, State ano local governments should meet tne fo? lowing requirements: for
- 1. For those requirements related to the six-year comoliance :ected selected exercise aethities delineated in N.1.o. acove, :ne six-year period commences with the date of the first jef nt (utility and Sta:e and . local governments) exerci se conduc*ed af*er Novemoer 3,1980, - e effective date of tne Nuclear Regulatory Commission Final Reguia: ions on Emergency Planning,10 CFR Part 50 ( Accendix E) (a5 FR 55410, August 19, 1980). For example , i f the date of :ne fd es: joint exerc'se was Marcn 23, 1981, the end of the six-year period is Varch 23, '.987 3 All of the major elements are to be tested wf:Nin the sir-year ;eri:
on a si te-s.peci fic basi s except for ingestion-related el emen:s as :ne ! testing of such elements is not tied to a particular site for State governments, (See Attendant criteria 3 below.)
- 2. Scenarios for periodic exercises should be suf ficiently varied so that all of the major elements of the plans and preparedness of of f s':e organizations are tested within a six-year period. The major elemen:s of plans and preparedness are incorporated in the 35 exercise cojec .ives contained in the August 5,1983 memorandtm: 'Paccecural Policy on Radiological Emergency Preparedness Plan Reviews, Exer:i se Observa: ions and Evaluations, and Interim Findings."
- 3. Imolicit in evaluation criterion, N.1.b., is the requirement for eacn State =nica has a nuclear oower clant within its boccers to fully
- To nignitgnt cnanges to criteria in NUREG-065a/ FEMA-REP-1, ne new language 's underlined and the old language is lined through.
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l. L_ o< .c- exercise its plans and preparecress relatec to ingestion ex esure j l(' - patnway measures at least once every six jears in conjunc:f on ai ': a plume exposure pathway exerci se .for some site "- * '- . ... .his E requirement is reflec ed in :ne h exerc1:e cojectives and is I presented in 44 CFR 350.9(c)(4). Eacn State .itn inges:icn ex:osure I
;, catnway responsibilities for : o or more sites located wi:nin 1:s borders will fully participate at see site on a rotationai :ast s anc partiaily :articipate-a: the otner sites Once every .six. years. 4 State nich nas ingestion related responsibilities for a site (s) located witnin !:s sorders and wnich is also wi;nin the 50-mile l iiigestion exposure cathway of a site (s) located in a borcerinc q 5ta:et s), shall car:ially participate .1n all of :ne inges:ica l relateo exercises for inose bordering State site (s). For : nose j States that do not nave a power plan: located in its bar:ers, Ou: !
are lucated within the 50-mile E:nergency planning Zone of a nor:ering i State's power plant, they snould fully participate in at least one , exercise over a six-year :eriod and sar:ially participa:e in all l others. These inges:f on-related requirements reoresent revisi'on of provisions enntainec in sot 9 NUREG-0654/ FEMA-RE?-1 and 44 CFR 350.9(:)(4). A. The definition of full ; participation in inges: ion as:ects of e'xer:t ses i s guided by 44 C.~R 350.2(j ) . Since local governments are no: usual y required to develop and :e .: ingestion plans and ;ee:artness, Sta:e of ficials would be the emergency personnel primarily involved in : e ingestion ;ortion of exercises. However, in some States, l ocal governments have caspersicili:ies tnat require Oneir car icita:icn i-(# such exercises. The numoer and' function of personnel needed snoul :e suf ficient for carrying out all those ingest'en measures- na: are necessitated .hy a particular ac:icent scenario. Also, organi: : ens i fully participating in the ingestion portion of an exer:ise snoul: deploy field :eams to secure anc analyze media sam:les as recut rec :y the accicant scenario.
- 5. The definition of par:ial par:f cipation in inges: ion as;ects of exer:ises is guided my 44 CFR 350.2(k). As sta:ec in item a acove, Sta:e o f't:: ai s :
would be the emergency personnel primaril_y involved in :ne inges: ion portion of exercises. The number and func: ion of Sta:e :ersonnel eecec shculd be determined on One bas.f s of veri fying croabili:1es for carryi g out the following responsibilities: Direc:icn an.: con:rol anc rela:ec communications for protective action cecisionmaking anc :issemina'.f n of emergency infor nation to appropriate individuals, groups anc :ne general public. Organi:ations partially participating in :ne ingestion portion of an exercise will not have to ceploy field teams to secure and analy:e media samples as such sections can be simulated.
- 6. Offsite organi:ations should make provision to start an exer:ise bet een 5:00 p.m. and 4:00 a.m. ence every six years.
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l .a . l l 7. Of f site organizations should scnodule 0xer:i ses at di f ferent seasons l over a 1ix-year period to increase tne likelinood for exercising uncer various weatner conditions. This provision can ce ful fillec througn :ne regular scheduling of exercises and in conjunction uitn items 2 and 3 aoove.
- 3. Cff site organi:ations should make provision to par.icioate in l
unannounced exer:ises at least once every six years. An unannounced exercise is a regularly scaeculed exercise in nicn :ne knowlecge f . the exact date of the exercise is restricted to only tnose eersons witn a need to cnow. Altnaugn :ne knowledge of :ne exact : ate is restricted, a time frame of 7 days within nien :ne unannounced ~ exercise is to ce conducted will ce established and known to all parties involved.
- 9. Items 2,3,6,7 and 3 may be combined in the same exercise or accressac in separate exercises =1:nin a six-year period.
SECTION B: OTHER FERIODIC REQUIREMENTS HIGHLIGHTED TO CALL ATTENTION TO TWE NEED FOR C0rPL!ANCE
- PLANNING STANDARDS AND EVALUATION CRITERIA F. " Emergency C:mmunications Planning Standard Provisions exist for' prompt communication: among principal resconse ce;ani:ations to emergency per'sonnel and to :ne puolic. (NUREG-0654/FEwA-REP-1, p. C Evaluation Criteria F.3. Eacn organi:ation snall conduct periodic testing of :ne entire emergeacy communica:icns system (See evaluation criteria N.2.a., N.2.d. and Ac:eacix 3.:
G. Public Education and Information Planning Standard Information is made available to the puolic on a periooic basis on how tney will ce notified and what their initial actions should te in an emergency (e.g., listening to a local broadcast station and remaining indoors), :ne principal points of contact with the news media for dissemination of infor a: On during an emergency (including the physical location or locations) are estacl'snec in advance and procedures for coordinated dissemination of information :o :ne public are established. (NUREG-0654/ FEMA-REP-1,p.49) Evaluation Criteria G.I. Each organi:stion shall provide a coordinated periodic (at leas annual'y' Es'semina: ion of information to the public regarding how they will te 90:i'* ec and wna their actions snould ce in an emergency. This information snall include, but not necessarily be limited to:
- a. educational information on radiation;
- b. contact for additional information;
- Language for some of :ne evalua:1on criteria has been enanged to clarify i. .,
but :ne requirements are not changed. i
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- c. protective measu es, e.g., evacuation routes and 'elocation canters, a
sheltering, respiratory protection, radioprotective drugs; anc
- d. special needs of the handicapped.
Means for accyplishing this dissemination My include, but not necessarily limited to: information in the telephone book. periccic information in utility bills and publications distributed on an annual basis. G.2. The public information program shall provide the ;ermanent and transient
.acult population within the plume ez;osure !7Z an adequate opportunity to becye aware of the information annually. The programs snould include provisica for written material that is likely to be availacle in a residence during an emergency. Updated infc7 nation shall be disseminated at least annually.
Signs or other measures (e.g., decals, posted notices or etner means, pt aced in hotels, motels, gasoline stations and pnene booths) shall also be used to disseminate to any trantient population within the plume es;osure pa2=ay EPZ appropriate infonnation that would be helpful tf an emergency or accicent, occurs. Such notices should refer the transient to the tele;rone dirsciory or other sources of local emergency information and guide tne visitor to a:Jropriate radio and televison frequencies. G.5. Each organization shall conduct coordinated programs at least annually to ac;uaint news media with emergency plans, information concerning raciation and points of contact for release of public information.
/N H. Erer;ency Facilities and Ecuicment planning Standard Adequate emergency f acilities and ecui; ment to suppor* the emergency res; case are provided and maintained. (NUREG-0654/ FEMA-REP-1,p.52)
Evaluation Criterien H .10 . Each organization shall make provisions to inspect, inventory and operationally check emergency equipment / instruments at least once each cat eacar quarter and after each use. There shall be sufficient resenves of instruments / equi; ment to replace those which are removed from emergeecy kits ' for calibration or repair. Calibration of equipment shall be at intervals recommenced by the supplier of the equipment. N. Exercise and Orills planning Standard periodic esercises are (will be) conducted to evaluate major portions of emergency. response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of f '
; . 71 )
exercise and drills are (will ce) corrected. ( NUR E ri-0 65 4 / F E.w A-R E F -1. l l m i i l ____..___.______U
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-s- i Orill Requirements (Evaluation Criteria)
N.2. Cefinition: A drill is a supervised instruction period aimed at testing, ceveiocing and maintaining skills in a carticular coeration. A drill is often a component of an exercise. A drill shall ce sucervised and evaluated my a cualified drill instructor. Eacn organization small conduct dr1115, in addition to :ne biennial annual exercise at ne l frequ'encies indicated below: )
-l N.2.a. Communication Drill s: Three types of communication drills are l accressec: (a) Jammun1 cations witn State and local governments witnin :ne f . plume exposure pathway emergency planning :cne snall be tested mon:nly; !
(b) communications witn Federal emergency response organi:ations and State (s) within the inge.stion pathway shall be tested at least once quarterly in conjunction with the testing of plume exposure pathway measures of :ne State plan and (c) communications between tne nuclear f acility, State and local government emergency operations centers and field assessment teams snall be tested at least once every year. Communication drill s snall also include one aspect of understanding the content of messages. 4.2.c. w ecical Emergency Orills: A medical emergency drill involving a simuiatec contaminated ino1v1cual :nat contains provisions fo,e par *1cicaticn by local support service agencies (i.e., amoulance and offsite medical treatment facility) snall be conducted annually. N.2.d. Radiological Monitoring Orills: Requ1rements are set for:n for two types of rad 1ological monitoring cr1lls: (a) Radiological monitoring cellis related to the plume exposure pathway emergency planning zone snall be conducted at least annually and shall include provisions for connunications and recordkeeping. (b) Radiological monitoring dril1s eelatec to :ne ingestion exposure pathway emergency planning zone shall be tonducted at least annually and snall include provisions for communications and rec:r: keeping. N.2.e. Health physics Orills: Health physics drills shall be conducted semi-annually oy State governments with licensees to test response Oc anc analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment. The State drill s can be conducted at any site. . O. Radiological Emergency Resconse Training Planning Standard Radiological emergency response training is 'provided to those who may oe called on to assist in an emergency. (NUAEC-0654/ FEMA-REP-1, p.75) Evaluation Criterda 0.1. Eacn organi:ation snall assure training of appropriate individuals. O 9
f 7.. 0.1.b. Each offsite, response organi:stion shall participate in and . receive training. .iihere mutual aid agreements exist between local agencies sucn' as fire, m D([~ police and amoulance/ rescue, tne teaining snall also be of fered to -:ne otner- , departments wno. are memeers of the mutual aid district.
.- 0.4.. Each' organization shall establish a training program for instructing and
- qualifying personnel no will implement radiological emergency response plans.
The speciali:ed initial training and periodic retraining programs- snall te defined with respect to their scope and frequency and snould De proviced in
- the following categories:
- a. Directors or coordinators of respor.se organizations; b., Personnel responsible for accident assessment; '.
- c. Radiological monitoring teams and radiological analysis personnel;
- d. . Police, security and fire fighting personnel;
- f. . First aid and rescue personnel; g.- Local support services personnel including Civil' Defense / Emergency i
Service personnel; h.: Medical ~ support personnel; and
- j. Personnel . responsible for transmission of emergency information and
-instructions.
0.5.. Each organi:ation snall provide for tne initial and annual retraining of personnel with emergency response responsibilities. P,. Responsibility for the Plannin'g Effort: Develcoment. Periodic Review ano 01strioution of Emergency Plans A '
- Plannino Standard Responsibilities for plan ' development and review and for distribution of emergency plans are' established,' and planners are properly trained. - (NUREG-0654/ FEMA-REF-1, p.78)
Ev'aluation Criteria P .a . Each organization shall update its plan and agreementi as needed, review and certify it to be current on a annual basis. The update shall take into account changes identified by drills and exercises. P.S. The emergency response plans and approved changes to the plans snall oe forwarded to all organizations and appropriate individuals witn responsibility , for implementation of tne plans. Revised pages shall be dated and marted to show where changes have been made. P.10. Each organization shall provide for updating telephone numbers, call-down lists and maps in emergency procedures at least quarterly. Acpendix 3: Means For Providing Promet Alert and Notification of Resoonse Organi:ations Ano Tne Pooulation i Periodic requirements related to alert and notification will be discussed and delineated in a forthcoming GM. 1 m____?_._.__._. _ _ _ m. -
.a.
SECT *0N C: ANNUAL LETTER CF CERTIFICATION In arcer to f acilitate :ne monitoring of REP planning and pr epa rednes s requirements as prescribed in NUREG-0654/ FEMA-REP-1 and 44 CFR 350' as d el i nea t ed in this memorandun, an Annual Letter of Certification snall be suemitted from each State to the accropriate FEMA Regional Director. ~h e
- State sucet ssion of the Annual Letter of Certification :o :ne FEMA Regional Director snould be made ey January 31 of each year and snould address comoliance with periodic requirements for the preceding year. This letter shall include assurances that tse requisite activities have been under:aren -
or completed, as appropriate, by the State and local organizations for ne following functions:
- 1. public Education and information (G): McLns of dissemination of information, dates, participants, sponsoring organi:stions and description of any programs conducted to increase public and
- media radiological emergency planning and response awareness.
- 2. Emergency Facilities and Eouiement (H): Type of equipment / instrument ,
quantity and cates of :necx/ test.
- 3. Exerci ses (N1: Testing of all major elements, conducting exer:ises uncer various time ano- seasonal concitions, unannounced exercises and testing of State (and local, as appropriate) plans for implementing ingestion pathway measures. .
4 ' Orills (N): Types, dates held and participating organf zations.
- 5. Radiological Emergency Resconse Training (0): Scope and purpose of train ,
dates nelc, numoer of participants, agencies represented and sponsors of trainings.
'6 . Uedate of plans and Letters of Agreement (p): Verification that plans and letters of agreement nave oeen reviewec anc appropriate enanges made. Ued a te s of plans should include telegnene numoers, call-down lists and maps.
- 7. Alert and Hetification (Accendix 3): Type of tests conducted in accorcance with estaolisnea scnecule, cates nela, and operacili:y percentage acnieved based on periodic testing.
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"o lO f ygy*g Federal Emergency Management Agency T- !/ Washington, D.C. 20472 l OCT 2 S85
,ie CRANC04 FCR: Regional Directors /Aceitt; Tegional Director FPCM: .anoel W. Speck Associate Directer State and Iccal Pregrans and Suppert SLNECT: Guidance Memorandum (G4) IT-1, A Guide to Decments Related to the REP Pr:: gram te G4 identified above is provided to ytu for your infcenatien.- ~his Guide presents the ;elicy and procedures cf de Federal T.::er;ency. Manage:ent Agency (TP.A) for ce development, distrihation and use of a variety cf documents related to the radic1cgical emergency preparedness (FIP) pr:grr.. 1 Please ncte dat the 34 addresses hcw RD documents will be coordinated wi2 your ot;anization.
Any concerns er questiens abcut this CM should be directed .to Vern Wirr;ert A./ (202) 646-2872. Aetace. ment As Stated I I i i V U) '
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! ,) .Q EMtg Federal Emergency Management Agency 1 Washington, D.C. 20472 Octooer 1,1925 Q
.. GU!OANCE mew 0RANDUM 17 1 A GUIDE TO DOCUMENTS .RELATED TO THE REP PROGRAM This Guide 'has been prepared to provide an overview of the various ty;es of docments associated with the Federal Emergency Management Agency's (FE.wA) radiological emergency preparedness (REP) paogram. It deals witn the purpose, intended audience, format, classification, coordination, distribution, and periodic review of these documents and their relationship to other types of FEMA publications (e.g., Civil Preparedness Guides). Levels of REP Occuments. The various types of REP documents are groused accorcing to tne1.e placement in four levels of publications. These levels are described below. Level I. Level ! publications are regulatory in form, content and intent. At tne present time, this level incl 0 des 44 CFR 350,-44 CFR 351 and the
" Memorandum of Understanding between NRC and FEMA Relating to Radiological Emergency Planning and Preparedness."
OV Level I I' . Level II publications constitute major policy and guidance documents that haye been incorporated into the FEMA-REP series suen as NUREG-0654/ FEMA-RKP-1. Level III." Level III documents pertain to clarification of policy and procecures or transfer of tecnnology between orgar,izations and are designatec as guidance memoranda (GM). GM's are developed on an as-needed basis. Level IV. Level IV documents include a variety of publications including researcn reports (e.g., Taf t, Louisiana chemical plant explosion), studies / reports (e.g, New Mexico prototypical plan for radioactive material transportation accidents and Sandia's report on the volume of radioactive materials transported in the United States). It is our intent to designate level IV docunents as REP-numbered documents. While REP documents are grouped into four levels, the documents in these various groups are of ten related to each other in content or by reference. They also may be related vertically in that documents of a lower level may be incorporated into documents of higher level. For example, it is anticipated that several GM's will be developed on the same general topic of exerci ses. Once these GM's are published, it is the our intent to consolidate them and publish them as a CPG and eventually to incorporate portions in the regulations as changes or additions. Develcoment, Use and Review of REP Occuments. The following guidelines are set fctr n for ceveloping, using anc rev1 ewing REP documents accoroing to the four levels of publications. These guidelines are to be followee O (/ unless exceptions to the general guidelines are warranted by special ci rcunstanc es . n
- \ 1 I4 vel I_. I4 vel I documents are used := prwide the basis and frrew.* fer unple.centin; the ?d? prcgram. Be tw current regulations, 44 CFR 351 and 44 CTR 351, centain the ;clicies, procedures and ecnanisms fer the prevtsien ; cf eccrdinated assistance :y Tederal agencies to State and local gever . ents in reviewirg ard e/aluacirq cf fsite radiological erergency planning and pre- ,, paredness. Also, the T&A-NRC ew -cranduri of Understanding (G) provides tne fra,ewrx for ef f ec.ive cceedination cf the respective roles and responsibil-ities of these tw agencies within the context of the NRC's licen. sing functien. - me t.c regulations are puolished in the Federal Fegister and their centents are codified in the Code of Federal Peculations. B e CU is puolished in the Federal ?egister but is ret par: ci tne Coce. Prwisien well te ade fer puolic ecmrents, as appropriate, to published regulatcry revisiens with tire frares set acccedire to the extent cf the modifications and the urgency of puttirq them into effect. l l 2e &velcpment er modification cf I4 vel I documents vill be cceedinated with the folicwin; ceganizations' FSA Fegions, the NRC, the Federal Radiological i Preparedness Cocedinatirg Ccmittee (FRPCC) and other ceganicatiens (e.g. , Conference of Radiation Control Prcgram Directors, National E ergenef Manage-ent l Association, National Cecrdinatirq Ccuncil en Eregency Mana;e-ent, Edison l Elec.ric Institute, Atcmic Industrial Terari, the Audu en Society and t 4 { Union cf Concerned Scientists). The specific ceganizations with wnich T&A will ccordinate the development ard review of level I docurents will varf 2 I acccedirg to the content and ;ctential impac.. As a general rule, net rcre than 30 days will be alicwed for the conearrent review and cerrnents by the organizations that are assistirq in the deve1@ ment cf these decurents. l REP-related sgulations, the T&A-NRC G and cther level I documents will be reviewed on a four-year cycle to detecnine the need to retain, revise er nedify them. Charges necessitated by pecgram nedifications in intervening years will be made en an interim as-needed tasis. Level II. Level II documents are used for a nuncer of purpcses: (1) To prcmulgate guidance for State and local governments to use in develepirs radiological eargency plannirq and preparedness, (2) to establish criteria for Federal of ficials to use in reviesirg and evaluatirq State and local govemrent plannirg and preparedness, (3) to provide information and. data to support specific aspects cf State and local qcverment radiological emergenef pregram and (4) to f acilitate the transfer cf tecnnelogy between and areng the private secter, State ard local gewrments and the rederal gewmnent. 2e current listirg of REP-series docuants contain publicatierts that teth de ard do rce c:entain rajor policy and gaidance. For those decurents that de contain najor policy ard gJidance such as NURm-0654/T&A-RD-1; t. hey vill be, to the extent ;cssible, republished in the future as Civil Preparedness < Guides (CPG). These docurents that do not centain nujer ;clicy and guidance such as TD1A-REP-6, Exercise Evaluation and Simulation Facility Evacuation l Events Models: Part I-PREDYN Users Guide, will be retained as RE:P-series l dcctrrents and will be placed in the level IV grcup. j l O .
T n/ f 2e inc=rporation of scne cf the FIF-series dccrents into CPG's reflects cur ccmr.i trent , to the extent possible, to use Agency pu=lication for nats for REP decrents as . ell as to integrate tne centents of FIP dec nents into Ws CF;'s that address Integrated D er;;ency Managerent System pr:grn e:rpe.as4s.
- are used :y the Agency for transmit irc :rajor ;clicy and guidance to State and local geverreents. A listirq cf TIP-series cccurrents is provided as Atta:r. ent 1 to tnis G .
Tederal Fegister netices are ;r:vided for all level !! dccuments in Order t= inform the puolic of tneir ~ availability, to invite pwlic cenrents and to acxnewled;;e fer al ad ction :y T9A. Se ;attern and ti. e allo.aed f r revies and :2rrents en level !! deezents is tne sacre as tf.at set fortn for level I decrents. Se periodic revies cycle for level !! decrents will be :,.c years. We will use the current CPG nutoering senem for REP-related CPG dce.: ents.
!.evel III. I.evel III m's are used for these pu:;cses: (1) c set forta TPA policies and procedures related to FIP regulatier.s or general Agency ;clicies su:h as the Integrated Erergency w a nagerent Infer atien Systen, (2) to provide clarification and interpretation cf criteria contained in guidance decurents such as .%.'RC-0650??A-FIP-1 and (3 ) to provide infer-ation of a -cre tecnnical nature t= sup;crt .e i. ple entation :f the FIP pr: gram througn the transf er :f
'technolcqy. We will use t .e new nur.cerirq scnce for level ::! m's mien inclufes t.c alpha characters that suggest tne sucject addressed and a se:;uential nurter for :t.at sunjeet area suen as EX-1 (Exer:ises) .
f.evel III doceents are to be developed in cecedination with other Organizati:ns in the sane manner set forth for level I docurents. Ter these decrnents, 30 davs (K_)) will be alleM for Regional revie-s and 30 days for the cene.:.rrent review by the NRC, TEFCC and other Organi:ations. Sese docu.ents are to be reviewed eacn year er :n an as-neefed 0. asis to deter-ine if they snould be ter-inated, replaced ce redified. As c.:rrent listin; cf cperative 2's is provided as Attacnment 2. I.evel IV. I.evel IV docurents are used for' the g;cse of providirq supgert to specific aspects of T9A's REP pr: gram and may inclufe prototypical studies , special resear:n reports and pmlications on Other pr:gre issues and concer .s. As stated, it is our intent to use the current REP-series designation fer these dec. ents. - 2e Tederal Fegister : ray be used to rctify the pcli: cf the availabilief of these dec.: rents. No precise procedures are established for t*,ese dce rents as cecedination in their develc;nent and publication will te done en an as-appropriate basis accordirq to their intended use and ;ctential i.p.act. Level IV decrents are to te reviesed every tw years to deternine if tne doc;.: rent should be terminated as an availacle publication, replaced er modif ied.
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i Oistri:utien. r&A :tadquarters will assure distriNeien of RE-related coc : rents to organir.atiens involved in the coordination peccess and tr.at
- ay be f.meced by tne ;:clicies, prxedures, guidance er general centant cf the dcca ents. T&A Regicnal Mfices vill be res;:ensicle fer distributing these decu ents to State and iccal goverrrrent and private secter c ;ani:atiens ,
within their regions that may be i. p.tcted t/ t.% centents Of these doc. ants. Attact; tents (2) 8 O e O
l - l [ km Federal Emergency Mana$ement Agency ( .'~be%w e
$/ Washington, D.C. 20M2
, .s Attac." rent 1 August 6, 1986 (Updated)
I REP-SERIES COCLNE!CS l l
- REP-1 " Criteria for Preparation and Evaluation of Radiological Prergency l; Response Plans and Preparedness in Suppere of Nuclear Pcwer Plants 1
- PIP-2 Guidance on Offsite Emergency Radiation Measunment Systems l'
- REP-3 Dynamic Evacuation Analysis: Independent Evacuation Analyses: Inde-pendent Assessments cf Evacuation Ti:nes Fran the Plume Exposure Patn-l' l way Emergency Planning Zones of Welve Nuclear Pcwer Stations
- PIP-4 Joint Feview of Cor:rnents en Criteria fer Preparation ard Evaluatien of Radiological Emergency Paspense Plans and Preparedness in Sc; pert of Nuclear Pcwer Plants
- REP-5 Gaidance for Developing State and I.ccal Radiological Emer;ency Pe-
.[ sponse Plans and Preparedness fer Transportation Accidents
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' REP-6 Exercise Evaluation and Simulation Facility D/acuation Events Medels:
- Part I - PPIDYN Users Guide
- REP-7 Exercise Evaluation and Simulation Pacility D/ents "odels: Part ::
- Users Manual for tne Interactive Dynamic Net'crk Evacuatien Model
- REP-8 Exercise Evaluation and Shnulation Pacility Events Models: Part III-
- Application of the I-OYNEV System
- REP-9 (Peserved for next Exercise D/aluation and Simulatien Pacility docu-ment]
- REP-10 Gaide for the Eval ~uation of Aler$ and Notification Systems fer Nu-clear P::wer Plants
- REP-ll A Guide to Preparing Emergency Public Information . Materials C
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- Ys' g Federal Emergency Managem Washington, D.C. 20+^2 A::ach=en: :
4/21/37 (Updated) . CPEFAT."lE 3.IIr.:ANCE M.EMCPANCA Ntecer Cate Title 4 '4/1/80 Padic Transmission Frequencies and Ccverage 5 4/1/30 Agreements Arceg Gcve: mental Agencies and (revised- Private Parties 10/19/93) a 4/2/E0 Pegional Adviscry Oce: ittee Cecrdinat.icn (revised- With Utilities 10/19/33) 16 - 8/7/80 Standard ?egicnal Paviewirq and Paperting Precedures for Stats and *ccal Radielegical Emergency Resperse ?lars 17 1/8/81 Joint Exercise ?recedures 20 10/19/93 Ecreign Language Translation of Public Educatien Brochures and Safety Messages 21* 2/27/34 Acceptance Criteria fer Evacuation Plars 22 10/19/83 Facordk.?eping Requirements f:r PuOlic M.eetir.gs 24 4/5/94 Fadic1cgical Emergency Preparedness for Handicapped Persers EX-1 7/15/85 Femedial Exercises EX-2 7/15/85 Stafd Suppert in Evaluatirq RE? Exercises PR-1 10/1/B5 Felicy en NUR1rr-0654/TEMA-REF-1 and 44 CTR 350 Periedic Requirements O
y s
- . P:- ;.n Lt; 1
1 ' / d % g i a > ,1. . . 1 . A Guide : Occ.:nents F.elaced :: the FIP ' Fr:grrc i-IT-1 ~10/1/85 m., PI-1 10/2/85' FC% Action' to Fil t Tes: Ouidance en Pu=lic Infer.ation ?.aterials and Pr0 vide ~ecnnical. Assistance'On Its Use FF.-1 ~ 12/3/85 Tederal Fasponse Canter MS-1 11/13/86 - Medical 5e::/ ices
' r/-2 11/13/86 .P :tective Actions'for Scheel Children AN-1** 4/21/87 FD% Action to Oualify Alert ard Mctificatien-
- Systers Against NUFIG-0654/FD%-?IP-1 and FD%-
FIP-10 ,
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- Gi-21 will % recicled G4 r/-1 when it is revised to confor.: to new ncr-enclature.
** With the - issuance Of 24 AN-1, G4-lS is tertainated.
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() p ( Federal Emergency Management Agency g%'s)E 1 Washington, D.C. 20472 ~ c 2 ses P.DCFANDF. FOR: Fegional Direc-Ors I?CM: Sanuel .S X Assoc' ate . or State Pr rams I, Sup;crt SL% TOT: Pilet-T s irq Guidance en P21ic Infeeatien Materials and Pro . ding Technical Assistance on its Use Attached are dEce unts wich will support cur effons for the next par in developing a standard against Wich emrgency public inferMtion materials for residents ar :und ruelear ;o er plant.s can be revie ed consistently: n o TDd.A RD-11, A Guide to Preparirq Dergency Public Infer ation Materials, aM o CM PI-1, TD'A Ac. ion to Pilet-Test Guidance on P21ic Infor atien Materials and Provide Technical Assistance en Its Use. As you knew, the guidance, TDdA RIP-11, has been prepared te assist these who prepare public ir.for ation decu=nts to i, preve the centent and dissemination cf errer Ancy infor-ation. We haw reviewd and applied ycur coments on the April draf t,cf this docurent ard are now ready to issue it fer voluntary use, durirg e one-year ccrrent peried. We are efferirg a technical assistance pregram to t,%se who are interested in pilet-testirq the guidance against their public information :reterials. I am f :vardirq to the Federal Begister an anncuncerent aboat the availability of the guidance and the tec".nical assistance pecgrm. 1 I I would like your support in distribution cf these dee:. ents and in solicitirq participation in the voluntary tec*.nical assistance pregram. Any q.estiens f on t.his pecqrm should 1:e direc.ed to the Heady:ar.ers Tee.nclegical Ha:ards j Divt.sion, as noted in the attached GM ;?I-1. [ Attae.nents
' As Stated l
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i Federal Emergency Management Agency Washinpon. D.C. 20472 Cc cbe.: 2, 1985 ; GUITANCE VIMCRAtCLM PI-1 ] I j FDA AC'"ICN ':0 PI!,OI' TEST GUICANCE CN PUBLIC INFCWATICN MA~TPlA! S r, PaCVICE TECHNICAL ASSISTANCE ON ITS USE Purpese "his Guidance Memorandum (Gi) describes procedures and policy the Tederal Dner;ency Management Agency (T&A)~ Tegicnal Offices and Headquarters should I folicw in implementing a voluntary technical assistance program. designed to sclicit participation of State and local gover rnents and ifcensees in pilot-testing Guidance on Preparing Dnergenef Public Inforation waterials , TE"A PIP-11. FIP-11 provides an amplification cf NUPIC,-0654/TEwA PIP-1, Fev.1, Planning Standard G.1. and 2. The review of puolic infer-.atien materials 'against these standards is an aspect of TA's everall res;cnsi-bility for of fsite radiological energency planning and :espense and is one ' j of the ways DA assists. State and local gover nents in i:rplementing their responsibilities for the safety of persons and pregerty in the vicinity cf c=mnercial nuclear pcwr plants. T&A REP-11 is intended to assist these who prepare pc.blic information-docUnents, i.e. , State and local goverrrnents and the licensees of nuclear C pcwer plants, in i.~ proving the content and dissemination cf emergen: y instruction. It is our goal to increase the cenprehensibility of these doe.snents so that if notification of an emergency becerres necessary, f
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residents in Dner;ency Planning Zones around nuclear pcwer plants will knew i wnat actions to take. With the final publication of this guidance in late 1986, T&A will have a standard against which public infer.aticri material,s nationwide can ::e reviewd consistently. A voluntary, contracter-supported technical assistance pregram is being initiated by TEwA Headquarters for several reasons: 1) The technical assistance program will provide the target audience exposure to the principles and techniques of improving emergency public information , dissemination as reflected in t.he guidance. 2) The pilot testing will give . FEMA the benefit of practical experience in applying the guidance to several site-specific situations prier to finalizing the guidance as a standard for required periedic review. 3) State and local governments will have the 1 opportunity to provide input into the final guidance through particie.ation in the technical assistance visits. 4) FDA will collect infernation accut the range of public information and education techniques beig utilized and ) disseminate the most successful techniques. Although only written prcducts will be evaluated at this tiine, all techniques being used will be reec;ni:ed and doe.srented. Until the pilet-testing phase of this technical assistance pecgram is ecmpleted and the r&A PIP-11 guidance is finalized, the applicatiers of t .is guidance is voluntary. All written reviews of materials durim this ene year period are par. of the process of pilet-testing and finalizig T&.A RET-11. Itemized advice and cerments shculd be censidered as suggestions. After the ( one-year period, the finalized T&A PIP-11 will be used as a standard for required periodic reviews.
1 scree of Technical Assistance Censultatien O' q ctganizatiens requestirq technical assistance reviews will receive" an f evaluation of all written pr: ducts designed to c:municate anergency ;ctlic
- infor-nation, with particular eghasis en readability. A centracter team pr=vided y T A will provide advice on aspects of centent, cerTrenensi-bility, design, and distribution. A readability analysis also can be regaested as a single-item consultation. All persennel wno participate in ,
the pr: duct develecment, including ecunty, state, licensee and "tegional effice persennel will be invited to take part in the discussion to get maximum benefit cf any advice ef fered and to achieve maxin.rn interaction. Technical assistance can be provided 1) througn a field visit by the centracter to the &A regional office er to the licensee siter 2) througn written correspondence with telephene consultation; er 3) threugh readability analysis provided with written advice. If technical assistance is revsested through correspondence, all parties' vill receive c pies of the written , reper. through the DA regieral ef fice. 1 Criteria fer Selection As Technical Assistance Site Organi:ations interested in technical assistance must inake tneir request j through the State to the FDA Fegional Cf fice. State suppcrt of the technical assistance is essential te having the centracter perform the review. Dae to limited resources available, sites currently egerating vill receive priority for technical assistance. Cecqraphic distribution also may te a consideration in selecting and scheduling sites fer tecnnical assistance. Precedures fer Fec;ectine Technical Assistance Cr;anizatiens (licensees, State and 1ccal governments) interested in technical assistance should fellew these steps: 1
- 1) Make a written request to the TA Regienal Office through the State of fice, specifyinc site, materials to be reviesed, w. ether er net a site j visit is requested, and the ti.e period in which the technical assistance ;
could be conveniently scheduled. A twk vindew should be allcwed for j scheduling, if possible, or alternate dates suggested.
- 2) he State, in passine the reraest to &A, should indicate which persennel, if. any, can participate durirg a site visit, er who should be responsible for reviewing and res;cnding to results.
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- 3) When a site has been selected for technical assistance anf so infer-ed by the Begional of fice, the requesting organi:ation should send t.hree copies cf all pablic infermatien materials to be reviewed, any dec.rnent-ation of the distribution system for the materials and other public education ef forts, to the &A Fagional Of fice. "he materials shculd be sent to the &A Fegion at least three weeks in advance cf the re7;ested technical assistance review date.
l Ol , L_- - _ _ __________ _ _ _ _ _ _ . _
3_ l kseensibilities
.m i A) 9.4 Headcuar ers:
o Be Technciccical Mazards Divisien (WD), Prcgram Develcgmqnt (PD) Branch is responsible for develegment and revision of PDdA PIP-11
.- ard this procedural CM; selecting sites in eccrdination with the field Cperations (FC) Eranch; seneduling technical assist.ance wit.n the centracter; fervarding the materials to be revie ed to the contracter; doc rnenting practical application of the guidance:
c::rmunicatin; ;olicy ard objectives pertaining to the guidarce: ard collecting data en'infomation practices to add to WD data t.ase ard to share with the industry, State and local govemment.s. ~he PD Branch will hold pre-technical assistance conference calls with the kgien ard contracter to discuss the materials to be reviewed and to deal with major issues. m e PD Branch will pass en the results of the technical assistance review to the FC Branch fer distribution to the kgion. ~he PD Branch will finali:e the guidance based on ecrrents received fran the public and these wne par.icipted in the technical assistance pecgram. o The FV Branch will support the schedulirq of the technical assistance:. netify the Pegicnal Of fice men a site has been approved f r tec..nical assistance and confirm dates: advise the regions vnen Headgaar .ers
. learns of any crcanization with interest in technical assistance; advise the PD Branch on requirements for scheduling and cceedinatien with cther field activities and participation of regional, State and licensee staf f. We FC Branch will pass on the results of the tec .nical
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assistance revi'ess to regienal effices for their censideratien. B) FDdA bcienal Offices: o Make distribution of TDdA PIP-11 to State and local gever cent and licensee emer;;ency management ard radiatien/ health personnel, ard provide information en the technical assistance pecgram. Contact States to fo11cw throagh on leads fran Headgaarters to expedite scheduling of technical assistance, ard solicit ma.xin.in participation. Infer .ation en crqanizations interested in volunteering shenald be provided to TDdA Headgaarters by Novecer 15. Tervard rec; vests and two copies of materials to be reviewed to TEWA Headgaarters and participate in prv-technical assistance conference calls with Headgaarters ard the centractor. Detain ene ccpy of the materials in the hqion Office for reference. Prior to the teennical assist.ance sessien, will review the public information materials against the amergency plan for consistency. Continue to perderm standard ;uelic infomation revice, accordirg to Planning Standard C, for these sites who have not volunteered to participate in the technical assistance pregram. Distribute, as appropriate, results of the technical
- assistance report to licensees, State and local gover rnent, and utilize results of review, as appropriate.. (As noted in t.he discussion of Purpose, application of the result.s of a tec^.nical assistance review during t.he one year pericd is voluntary. ) Briefings on ;uclic information pregram may be held as part of regicnal ccnf erences, with . cdest suppert, if available, fran Headq;4rters and contractor. WD persennel should ccordinate these ef forts with the Regicnal Public Af f airs of ficer ard appr griate NRC regional personnel.
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l l O) C) echnical Assis,tance Contractor (Educatien & Yaininc Assceistes, Inc./ Ar-enne National Lac t: Will schedule technical assistance based on written :'eqaest frm Headgaarters. Confer with Fegicnal Of fice and Headgaarters en pre-technical assistance. Perform revies/ technical assistance as specified in regaest. . Provide written report within One week to ~l Headquarters on any technical assistance ef fort administered. Sunnarize results in monthly reports, and dec rnent tec"niques presented fer project data file for future reference. Maintain a cenplete file of all materials reviewed, by site, for future reference. D) State / County Offices: Will coordinate and forward regaest for technical assistance fr rn licensee to mA Fegien. Participate in technical assistance as feasible and provide input to guidance during visits and/or in writing af ter tec*.nical assistance has been delivered. Participate in regional briefings to discuss public inter-ation pr: gram ard provide input on guidance. Feview results of technical assistance reper s. Ti. etable_ September 24, 1985 Notice in Fe:!eral k.cister (estimated) Cetecer 1,1985 - Technical Assistance Feviews May 31, 1986 Deceter 30, 1986 PJblic Information Guidance Finalized January 1, 1987 Petaired Periodic Feviews Based on Guidance Begin FCR Ft7tDfG INFCPpATICN CCPCAC : Stacey Gerard, Technological Hazards Division, Of fice of Natural ard Technological Kazards Prtgrams, State and Local Programs and Seppert, rederal Dnergency Management Agency, 500 C Street S.W. , Wasnington, D.C. 20472 202-446-2861. Copies of &A FIP-11 can be obtained frem the NA Regional Of fices cr by writing the &A Publications Division, P.O. Box 8181, Washirgton, D.C. 20024. O
Federal Register / Vol. 50 No.199 / Tuescay. Oct:cer 15. 1985 / Nocces M ~37 T forwarced to de CfEce of Manasement EPA =0995. :ntenm Status Stancards Due:Ic Information Collecten
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(",) and Budget (CMB1 for eview. The ICR desenbes the nature ai tne souc:tauon for Cwners and Cperators of Hazarocus Requirement Suomatted to me Ctace Waste Treatment. Storage, and Dsposal of Martagement and Succet for Review and the expected impact. and wners Fac:11 ties (ISS Surface Impoundment Cesign and Cperstmg Ceru!!csnan Ccteoer f. tsas. appropnate irciudes de acmal data collection distrument. The followmg Requirernents). was approved 9/1?/85 The Federal Communicanons (CMB =O50-27: ex;tres 9/00/88). Commission has sucmitted me fcilowing [CRs are availaole for review and information collecnon requirement to emnment. Com.ments on all par:J of dis notics may De sent to: CMB for review anc clearance under PCM FU8tTNaN IWFCAuATICN CCetTACT: ' anette (Jepman. 20:482- 742 or FT3 Nanene IJepman. U.S. Environmental k'[* **M' "dhg*'
* * * ' ' " Pactecton Agency. Office of Coptes. f this suomtssion are susms.tworTAar twomu Artote . Standards and Reguiscons (PM-Z=). availacle :cm the Cornmission by !
Regulation and Informanon calling Cons R. Sens I*,0 1 M:-r513. CfHea of Air and Radiation
'"*8'*"' "' "" #I " E "' "* ""* 8 * ""'"' # " *
Title:
New Soruce Performance S.W Washmgton. D.C. 20460: utformanca cod.ection snould contact , Standarna (NSPSI for Automootle and and Dartd Reed. CfEce of Management snc p ions b ) . ss remstaternent of an expired Information Wayne Lais (ICR *1064) or Richard Ctis Budget. Room 32:5 NECB. Wascu gten, (ICR 81083). CfHee of Management DC 20503. (202) 395-731. 3 and Budget. OfSce of Information and Couecton Request there are no changes.) Regulatcry Affairs. New Executive
) 3ca e Sh!p Rad!c Abstrace Facdities which cost de Of5ce Budding (Room 3=s). ?:s F o.F. r surfaces of motor vehicie,s are required Jackson Place. N.W Washmgton. Actoru Exten on.
to suomst reports anc to xeep recorcs D.C. M m g mg M=*3g which document compuance with VCC Responses: 319 Hours. enussions standards. Initial perfet=ance Cate: October f.19ss. tests. monthly calculanons of VCC Dami L Uonn* Feceral Caaunumcanoes Cam 2 mon. emissiorts. and processtag tnformanon Ac:wg Danct.sr Replarion and ! dot ~nacon Wuuam b incanca,
~
aresuppUed. Division. $,;,w,y, Respondents: Cwners and operators (yR Coc so-casti Fund 10-11-ass 8:45 am) E Doc. 45-4571 MW "o-114 $a5 W of facdittas which coat motor venicie es.une coce une e .a we, ,,, surfaces, n Research and Developesut Propama FEDERAL CWMCEMS FEDERAL EMERGENCY
Title:
Research Quesdonnaire on [V) Health Haoits and Dnnking Water (ICR CNN MWMEXT WhCY A Nde h Narms Ewgem
!nf t1 wtil c1 .ed e e only.) Petttfone for Reconsideration of Abstract The Envirortmental Actierts in Rufemadng ProceechNs AcaNCY: Federal Emergency Protecton Agency's Cf"ce of Rawatch Management Agency 07.MA).
and Development wdl study- Ocwone a. tses. ACT1cac Nocca of availacdity of A
. cardiovascular nsa factors by surveymg The followmg listings of petitions for Gmde to Preparing Emergency Noiic Wisconsm residents from cact= unites reconsideration Eled in Commission Informanon Matenais and tee..:ucal with varyuts depres of water hardness. rulemaking proceedings !s puolished assistanca on its use.
Respondents: )Visconsm residents pursuant to l L4:9(e). Oppositens to suuuAny:This s.erves as sonce of de from communides with varying degrees such periticus !cr reconsideration must be filed within 13 days after publication avadabdity of a C.udanca en P e; ann; of water hardness. Emergmcy Nbue Infor=auers of this Public Notice ut the Federal Agency PRA Cearance Requesta Registar. Replies to an opposttien must Matenals. FE.%4 REF-11. and a Completed by CMB W N wtthin 10 days after de ti=e for voluntary technical assistance pregam EPA 80012. Request for Vehicle fUing opposteens has expired. designed to pdot. test ce g.ucance. Exclusion from Cean Air Act. was Subject Licensmg Speca Stanons in FEMA REP-11 is intended to assist , approved 9/13/85 (CMB *:066 01:t: de Domesuc Fixed Satellite Service (CC dose who prepare puenc infor=anen ' expires 9/30/88).
- Docket No. 85-135). documents. i.e State anc !ocal EPA so:St. NotiRestion of Hazardous FUed by: Carl J. Cangelost & Wimam governments and ::e licensees cf Waste Actvtty-Amandmant Based on F. Taylor for RCA American nuclear power planta. Ln improving de Hazardous and Solid Weste Communications. Inc.. On N content and disseminauen of ene gy Amendments (HSWA) cf 1984--Smau Henry Goldberg. Phdll; I. Spector, instruccon. It ts our goal to inc esse .ne :
Quantity Generators, was approved 9/ Stephanie Sommer & Regma Harrison. de compncestbdity of due
*S/85 (CMB 83050-00:3: expires 9/30/ Attorneys for Naconal Exchange. Inc., documents so dat tf notEcacen of an 881, on 9-30-35. emergucy becomes necessarf.
EPA e901.Uruform Hazardous Weste residents us Emer;ency P'an:ung *:nes Feo.ersi Commurucanoes Coa:mumon. around nuclear power piacta wid k: aw Manifest for Generators and Transporters--Amend =ent Based on Wuuam b incanca' what senons to taka. W!ta tne .inai HSWA of 1984-Srnail Quanney Sanmer- publicauon of tis guidance a late :ssa. Generators, wes approved 9/25/&S (TR Doc. SM451 FUed 10-11-45; e 4s aml FEMA wdl have a standard asamst which public :nformation m.tter:ais Q (CMB =2050-0039: exptres 9/30/88k s e a coot m s.ews
\v) l i
I
f 4r38 F*ederal Rstist:r / Vol. 30. No.199 / Tuesday. Cet:ber IS.1985 / Notfcts nanonw de can be renewed analysts provided with wetten sdwes. If som rumrwu macewanoM cowrac-tecemcai assistance is requested Stacey Cerarc. TecamcolcMpeal Hazarcs consistently. A voluntasy contrac:or supported trougn correspondence, all partes wiu Civision. Cffice ci Naturai anc techmcal assistance program is bemg receive copies of tse wntten report Technolopeal Marsrcs P ograms. arougn tne FEMA reponai office. and i.ocal Programs anc Support.
- mr:sted by FEMA Hesacuarters for Federal Eugency Management several reasons:(1) The tec=ucal Catena for Seiection As Technical Agency. co C Street SW., Wasnm;t:n.
assistance program wid prowds te Asstatance Site target audience exposure to me CC 0047: 202-646. :361. prmc:ples and (ecamques of improvmg Crgaru:acons mtensted in technical Captes of FEMAU. .P-11 :an :e " emergenc/ pucd_ e tnformanon assistance must maxe tnett request cotamed from tne FT.MA Regional dissammacon as teilectec as me trougn me State to tne FEMA Regional OfEces or by wnting tne FE'4A guidance. (2) The pdat testmg wdl pve CfSce. State support of tae tecamcal puo ications Division. ? C. Ecx 5181. FEMA de benefit of precucal assistance ts essenual to havmg me Wasnmgton. OC 200:4. expertence in applying te guidance to :ontractor perform de review. Due to , 04 tea: Cc:ocer :. tsas. limited resources avadable. sites several sites-spec 1Ec situauons pner to Samuel W. Specx. 1 Snalizmg the guidance as a stancard for currently opersting wdl receive pnoney- Associare arrece. State H.occ/ /- frems #
.vquired penocic review. (3) State and for techmcai sssistance. Geograonic
- ocal governments wd1 have te cistnbucon also may be e consideracon Suc9ere opportumty to provide input into de in seiecung and seneduling sttes for 75t Coc. 35-244a7 Med :0-1:-45:5:43 aml techmcal assistance. an.u.e caos ersw Snal guidance trouga paruciaption in the techmcal assistance visits. (4) FEMA Procedures for Requesting Technical wd! collect informacon about se range 3,,i,g,,c, of pubuc information and education FEDERAL RESERVE SYSTEM techniques bems unitzed and Crgamzations (licensees. State and dissecunate de most successfuj local govemments) interested in ArnertTrust Corcoratton, et sa:
tecamques. Althougn ordy wntten tecemcal assistance should follow dese Formadons ort Acquisitions oy; and products wdl be evaluated at tis time. ste;s: Mergers of Bann Holcing Companies all techniques being used will be (1) Make a wntten request to de FEMA Repocal offee trougn de State he compan.tes listed :n mis non:e recoptzed and documentec. ciEce. specifymg site. =atertais to be have appued fer me Boarc's aperovai Untd be pdat.testmg pcase of this techmcal assistance pregram is renewed. wnetter or not a site visit is under seenen 3 of $e San.x Heicina requested. and Se ti=e pened in which Company Act (12 U.S.C.134 : and '
, completed and de FEMA REP-1: section:25.14 of ce Scarc's Regulaten guacance is.Mnm6d. de appiir. acon of to techmcal assistance could be mis guidance is voluntary. All wntten convemenuy scheduled. A two.weeit Y (12 CTR 203.14) to become a banx revtews of matettals durmg dfs one- mndow snould be allowed for holding c:mpany or to ac:;utre a bank c-scheduling. if possible, er alterzate bank holding company. The facter a year penod are part of Se process of are consicered in actng on de pdot-testmg and SnaHrny FEMA REP. dates suggested.
- 11. !temized adytes and comments (2) The State. in pasems the request to aopiicacons are set forta m sect should be considered as suggestions. FEMA. should !rdicate which personnel, of de Act (u U.S.C.184:tel).
. After the one-year;ened $s Ensuzed if any can pa: tic:pate dunng a site visit. Eaca appi! cation is avadania for or woo snould be responsible for immediate inspection at de Federal FEMA REP-n wdl be used as a standard for required penodic reviews. reviewuss and responding to results. Reserve Bank malcated. Cnce de (3) Men a sua nas bem seiected jor appucanon has been acceptec f r Scope of Technical Asetetance te: nical assistance and so infor=ec by precessmg. it wdl also be avadable for Consultation the Repocal OfSce. de requeseng especton at $e offices of de Board of Organizations requesting technical organization should send tree copies of Govemors. Interested persons may assistance reviews wul receive an all pubuc informacon matenals to be opnsa Se'.r news in wndng 'o me evaluation of all wntten products reviewed. any docu=entanon of the Reserve Bank or to de ofSces of $e designed to cornmunicate emergency distnbution system for de matenals and Board of Govemors. Any comment en pubuc informanon. mth particular other public education efforts. to de an appucacon mat requests a heanns emphasis on readabdity. A contractor FEMA Reponal Cface. ne matenals * 'ciud I ' '
team provided by FEMA wd! prowde should be sent to de FEMA Revoani at w tten present u n d no uffice in adytce on aspects of content. least &ree weeks in advance ol de un of a hearAg. idenufymg spechauv - cornprehensibdity, design. and requested technical asststance ruwew any' ques ne g gact 3at are m cispute disenbunon. A readabdity analysis also da<e. and summarizing de evidence dat can be requested as a smgfe-item T;.merable would be presented at a neanng. ennsultanon. A!! persormel who Urdess otherwise noted. c mments participate in the product development. Technical Assistance Reviews- Cet.1. regarding each of $ese applicauons including county, state. IIcensee and 1985-May 31.1986 must be received not later San Reponal ofEcs personnel wdl be invited Pubuc Information Guidance Finalized-. November 1.1985. to take part in the discussion to get Dec. 30.198a Recuired Pened Revtew Based on A. Federal Reserve Bank of C:eveisad maximum ben St of any advies offered Candance Begm--Jan.1.1987 (Las S. Adams. Vice P*estcent)1453 East and to achieve =anmum interaccon. Sixd Street. C!eveland. Chio 4410t Technical assistance can be provided (1) Comments on dis document w11] be recetved arough September 30.1986 and 1. AcenT/ ast C.;rrce:rien. C;evelanc. trouan a Seid visit by te contractor to should be addressed to: Rules Dociet Chio: to acquire 100 percent of me We FE.MA restonal offlee or to the voting snares of Ament.;st Ucansee sste: (2) througn wntten C:erk. Federsi Emergency Management Agency. Room 835. 500 C Street SW Development Sank. C:eveiand. Chio.. correspondence mth telephone Comments on mis appucanon .ust :( constdtanon: or (3) througa readabdity Wasamston. DC 034?:. O
N. PUBLIC INFCFFATICN uATERIAL5
'EU!NTARY Fe/IEWS - S~AT'. S LIST 5/28/86 44 CFR 350 TAV Reper:
Site Accreval Date
- 1. Salem /Hepe Creek 8/10/85 8/10/85
- 2. *rejan CR/M 7/82 10/03/85 in 10/14/85 in
- 3. WNP-II in
- 4. Mine Yankee 10/31/85 5 Ver ent Yankee -in
- 6. Yankee Fewe 11/01/85
- 7. Arkansas Nuclear One AR 1/82 11/18/85 in 12/02/85 in
- 8. San Cnefze in
- 9. Termi II 12/20/85
- 9. Comanche Peak 1/10/86 in ALL STATES CCNF. FE'dA FIGICN V 1/16/86 in
- 10. Cyster Creek 1/13/86 in in
- 11. Big Rcck MI 5/83 1/24/86
- 12. Palisades MI 7/82 1/24/86 in
- 13. Menticello MN 5/85 2/10/86 in ,
- 14. Prairie Islard WI 5/85 MN 9/85 2/10/86 in I 15. H.S. Rccinsen SC 12/81 2/11/86 in b 16. Shearon Harris
- 17. Brunswick NC 3/82 2/11/86 2/11/86 in in 2/24/86 in j
- 18. Ncrth Anna VA 2/83
- 19. Surry VA 2/83 2/24/86 in i
- 20. Three Mile Island 3/24/86 in l
- 21. Beaver Valley in
- 22. Lirerick in
- 23. Peach Betten
" in
- 24. Susquehanna in )
in
- 25. D.C. Cock MI 9/83 2/25/86 )
3/13/86 in
- 26. Calvert Clif fs MD 8/85
- 27. Fer: Calhoun NB 12/84 3/25/86 in
- 28. Cooper MO/NB 6/84 3/25/86 in
- 29. Ciablo Canyen 3/26-8/86 in 3/E
- 30. Ranche Sece in
- 31. Pale Verde 3/10-11/86 in
- 32. Artificial Island 4/14/86 in
- 33. V.C. Su:mer SC 11/81 4/2,8-30/86 , in ;
- 34. Clinton 5/5 in l 1
I s%
[4..~.M 9 Federal Emergency Management Agency O) 8
\"
l-Washington. D.C. 20472 m-L w MEMCFRCW FCR: Fegicnal Direct rs Acting Regicnal Oirec:cr, Fagien 5 IKri: SamuelW. Speck!Qs:sd* - Associate Direcher State and !.ccal Pr: grams and Support T L M "': Guidance Mercrandum FR-1: Federal Respense Center Site Selection Criteria fer Peaceci.me ?adiciccical Eme.rgencies 2,e Federal Fadielegical Emergency Fesperse Plan (FRERP) was published in cporational form, including acproval at senicr levels of management Of tne twelve Federal agencies resocesible for paacetime radielegical emergency planning and respense, en Novemcer 3,1985. A ccpy of the Federal Fagister publication of the FRERP is attacned. Also attac'hed is a ecpy of Gaidance Memorandum FR-1: Federal Fesocese Center Site Selection Criteria for Peaceti:ne Padiolcgical F.nergencies. Se substance of G FR-1 reflects guidance previcusly puolisned in .ne Cuidance for Dner:ency Fes;cese Team Planning (FF.MA Manual 3720.1Nuly 1985),
/
sectien 3-2, pages A18-19. Se pu:pese of issuinc G FR-1 at enis ti.-e is (,/) to bring inte sharper fccus the preselection ef f:rts fer Federal Resperse in the vicinity cf etmnercial nuclear pcwr facilities. Centers (FRC's) When considering sites for Federal Resperse Center pre--fesignatien, keep in mind that ecliccation wit.h tne (f: rwa:t) State Dnergency Operatiers Center is of primary im;cr:ance, if at all feasible. If the preselected candidate FRC site is greater than 50 miles. frcm the nuclear f acility, special attencien to cer:runicatiers systems arerg the resperse f acilities will be necessary. In this regard, the General Services 1&dnistration Fegional Cffice :-ay be of valuable assistance in identifying pctential Federal and State facilities for FRC's. I appreciate the f act that this preselection ef fort will regaire ccesideracle eccrdination atteng Federal and State ef ficials this fiscal year. ~har.k ycc fer ycur ef forts in satisf actorily cencleting this taak in a ti.-ely manner. Attac.%ents A)
\m l
l I 1 i l
- - _ _ _ _ _____-_)
.2 %.
!99:"'). Federal Emergency Management Agency C)' '
s
-. Q
..#f.A
,/. Washington, D.C. 20472 v-1140/'35 GUI:A CE ERMCm FR-1 FEERAL RESFCNSE CESTE"4 SITE SELEC TCN CRI T.RIA FCR PDCEi!E FADICLT.ICAL DERGENC:IS The fellcwirg guidance .emerarrfa (m) has been prepared to assist Fe;ienal Cffices ard the State and local goverrtents in plannirg fcr Federal res;cese to a ;eacetime radiological emegency. This guidance deals prir-arily witn fixed nuclear facilities ard atteq:ts to identify the minimun meds to su;;cr {
a Federal respense at a Federal Fespense Center (FFC) . BACXCPCUND Executive Order 12148 calls for F&.A to ccordinate the Federal res;cese plare.iq and mitigatien ef forts for eTegencies that af fect the safety and p well 'ceirg of the public. W1ile One cencept cf a FFC is . cst familiar in a radic1cgical emegency settirg, in any rce-declared emergency requirin; a unified Federal presence and tae depicpent cf a F&.A Emegenef Fes;cese Tem (ERI), an FRC could be utili:ed to ceganiae that res;cr,se. Fcr nu: lear ;cwr reac:ces ard etter peacetime radicicgical enegencies, the Federal Radicicgical Emegency Fes;cnse Plan (FFERP) prcvides fcr estaclishTent Of an FRC in ceder to eccedinate of f-site Federal respnse efforts, etner than radic1cgical nenitorirg ef fcres. In addition to Executive Order 12148 and the FRESP, evaluatien criterico C.l.c. of NLREG-0654/F&.A-REP-1 directs States ard licensees at c= enercial telear
;cwer plants te make provisions for incer;cratirg Federal res;cn'se capabilities within their plans. This m prevides practical guidance to States and licensees te fulfill this function ard provides specific acceptance criteria fcr eval.ati.g cenpliance with C.l.c.
FEDEFAL RESPCNSE CUT"!R (F?C ) The FRC is a center established by T&.A at a lccation identifief in conjunction with the State that se:/es as a focal ;cint for Federal res;cnse tem interactices i with the State. he FRC is similar in concept c an emergency cperatiens center. For nuclear ;:>er reac ces, t.M FFC is cperated in conjunction 4:n t ,e E. eqency Cperations facility were the State, NRC, ard utility can cocedinate ;rctective ' action rec = emendations. or\ l
2 S~NJCAR:S, E'/AL'.A**CN CRI~TRLA ' ABEAS CF RE'/:Di N4C ACCEFDJCI CRI~TRIA C. DECDCY PISF"NSE SUFFCR AND FISCL?CES Plahnine Standard Arrart;enents for requestirq and effec.ively ustry assistance , resources nave seen made, arrangements t= accenredate State ard local staff at the licensee's nea. site
~
Emergency Cperatices .; Facility have teen made, ard etner ce;aniratiens capacle of atx;nentirq the planned res;ense have been identified. (NLREG-0654/TDd.A-REP 1, p. 40 ) C.l.c. E'/ALUAT!CN CRI TRICN The Federal goverrrent maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Penitorirq and Assess ent Plan (focnerly Fadiolcgical Assistance Plan (BAP) ard Intera;ency Radielegical Assistance Plan (IPAP). Each State ard licensee snall : rake previsiens for ineceperatirg the Federal res;=nse e vaaility into its operation plan, includity the fellowirgs specific licensee, State ard 1ccal rescurces availacle to su= pert ene Federal res;=rse, e.g.,. air fields, cerard ;csts, teleprene lines, radic frequencies ard telecomunicatiens centers. AREAS CF RD/IDT The 611cwirg are basic site-selection criteria Se establishing the 1ccation of a FRC. This f acility would be established, if warranted, durir; a radiolcq emergency occurrirg at any fixed ruclear facility or site of incident. The FRC site srculd be preselected ::y FDd.A in cenjunctico with ard ccesultation Of ne NRC, utility ard State r;cvernnent durirg FYS6. FDd.A srculd seek State cccperation in identifyiry the location of the FFC. he Cepartment of Energy (trE )-des ignated Federal Padiolcgical ?tnitorir; ard Assessment Center (FRd.AC) site should be c:csidered een lccatirn ;cssible FRC sites, in censultatien with the senice : l CCE Radiological Assistance Program ten wtber and IE contractors. O.ere are j no costs assceiated with preselection of an FRC site. Cests to establish the FRC at the ;reselected site in the event of a Federal res;cese will be hardle' en a case by case basis bec een the FDA Fegicnal Office ard the State goverrrent(s). l l l 4 O
3 ACCEF*ANCE CRITERTA - A
- 1. '.CCAT:CN
!v).
Se FPC snculd ::e located at least 10' miles fren :ne fixed ruclear facility er site of incident.
" 2, location sneuld be net cre tr.an 10-15 minutes ty venicle fr=n :ne State connard ard centrol center. ne ??IRP states, *!deally, tne (Senier FPA Cf ficia11SFO and staff, etc.er Federal agency res;cese teans, and State a;ene/
, representatives wuld te cellecated at the scene, cut many State plans do not reflect this cencept. Acceedirgly, !?A ard tre Cognicant Federal A;ene/
site-specific plans and precedures should te flexible enough to accamedate State cperatices. Suen eccedinatien is cest Octained -r.en =ese ef ficials and key sup; cec staff are located near each cener, pref'eracly in the sare f aciliev, ard have direct lines cf ecmonications."
- 2. FACIL: Y The FPC srculd ::e appecximately 2,500 sc;uare feet in size, ard capacle cf accc:m:: dating 100 pecple representirz; F9A ard other Federal ager.cies with a rcle under cte FPIRP ard appropriate State liaisens, includirr; space fer files, messa;e center, effice machir.es ard conntnicatico equi;rnent. 2e f acility ray be eit er fixed er xcile.
. There seculd be sufficient parxir:; space for a minimun cf 40 wnicles.
- 3. ECUIPMDir i The FPC should be acle to achte c enty-five six cr eight feet feldirg taclet
'V and 100 foldin; chairs.
- 4. CMMUNICAT:CNS Previsiers seculd be made for sixty telegtene lines - 20 tr.:nk lines.
I.ccatien should be suitable for radio transmissions ard installation of anterr.ae. 1
- 5. (Ir:1.ITIES Space in the FRC sneuld be lighted, neated and air-ccrditiened.
Appecxi.mately 20 electrical cutlets for rermal of fice machines shculd te availac15 ' 2ere is no requirement for 220 velts. Sanitarf facilities should be in place to acccmedate 100 people. 2ere may be a need for janitorial services.
- 6. SECL*R: Y There will be a need for 24-tcur security.
- 7. AcT: VAT:CN The FPC steuld be capacle.cf beirq fully operaticral vimin 12 to 24 hours p
' af ter ratification of incident. Provisice.s should de mafe fer continucus 24-hour cpe 3eion. 4 f-
r~~ - - - O ,e
~
y @;f Federal Emergency Management Agency 1 $,iN.[#f - Washington, D.C. 20472 ~
'D 6 NOV l 3 Gi3
.. ME". ORA!!DUit Ton: All Regienal Di eetors,
*" Acting Regional Directors TRott : Dave ticLoughlin
"- ty Associate Director e and Local Programs and Support SUUJECT: Guidance Memorandum (G!t) 'EV-2, Pr otective Actions for School Children.
I am attaching Gt! EV-2,.f or your use in reviewing radiological emergency prepa redness (REP) plans and exercises. This guidance provides clarification and interpretation of applicable !!UnEG-0654/TE::A-REP-1 criteria a nti, as such, has been cencurred in. by !!uclear Regulatory Commission staff. I appreciate the assistance of your Regional Office REP staff who provided comments on the draf t edition of this documen:. ( If you have any questions on use or implementation of the C::, pleace get in touch with Bill ric::utt, 202-64G-2557, of my staff. f.t ta chme n t As Stated
an o (A N~$$,1 Federal Ernergency Managernent Ag 2
% */ Washington, D.C. 20472 GUIDANCE MEMORANDUM EV-2 . PROTECTIVE ACTIONS FOR SCHOOL CHILDREN j Purtese i
This Guidance Memorandum (GM ) is intended for rederal officials to aid them in evaluating emergency plans and preparedness for school children during a radiological emergency. This guidance is also intended for State and local government officials and administrators of public and pr mvate schools, including licensed and government supported pr+-schools and day-care centers, for developing emergency response plans and preparedness for protecting the health and saf ety of students.
?Jlu;k ereurd The joint Federal Emergency Management Agency (FEMA) and Nuclear Regulatory Commi;5sion (NRC) guidance document, NUREG-rN 0654/ FEMA-REP-1, provides criteria f or protective actions for
( ') persons, including school children, within the plu=e exposure pathway emergency planning :ene (EPZ ) in the event such protective actions are needed in response to a radiological emergency at a commercial nuclear power plant. The need to address the issue of protective actions for. school children stems from both the lack of detailed guidance on this issue and the expressed interest for such guidance from public interest groups, State and local government officials and Federal Fegional officials. Scoce Guidance is provided in this GM on school evacuation in two contexts: for developing emergency response. plans and for conducting and evaluating exercises. The primary methed for protecting school children examined is evacuation to relocation centers. This GM is a companion of the guidance on evacuatica contained in GM 21, Acceptance Criteria for Evacuation M ans. This specific guidance related to school children is appropriate because of the interest and concern expressed about protecting the health and safety of school children during a radiological emergency at a commercial nuclear power plant. I (~' q i l 1 _ _ _ _ _ . _ _ . _ _ _ - _ _n
l School Evacuatien Considerations l i Evacuatien ;g ?elocation Centers. The evacuation of schoci children under the continuous supervision of teachers and administrators f rom a ' school to a relocation center is a viable and reasonable apprcach when conf ronted with a l radiological emergency. The decision to implement a erotective action recommendation to evacuate to a relocation
' center snould be tied to the nuclear power plant's e=ergency *l action level classification.
Some emergency, response plans include the protective action . strategies of early evacuation and early dismissal. If State and local governments select one of these strategies, then they ought to address it in their emergency response plan. If a State or local government elects to employ early evacuation or early dismissal, this guidance is sufficiently I flexible to cover both strategies. All of the general guidance for evacuation would apply with the addition of the special considerations for early protective actions at the ' end of this GM. The recommendation to school officials to evacuate the schoci children to relocation centers should specify the area (s) to be included in the evacuation. For example, the evacuation could include schools within ihe two-mile radius of the plant and within three downwind sectors beyond the two-mile radius. Prompt evacuation is not' advisable during exceptional situations such as having to drive through a radioactive plume or into a severe blizzard. Under these circumstances, the special population including school children, handicapped and/or immobile persons should be temporarily sheltered and subsequently evacuated, if need be, as soon as conditions permit. School children and other special population evacuees (see also GM 26, REP for Handicapped Persons) should be relocated outside the ten-mile EPZ in predesignated facilities to ensure that the accountability, safety and security of the evacuees can be maintained and to minimize vehicular traf fic and telephone use within the EP3. Genersi considerations. For whatever protective action options are contained in emergency plans, the plans should include provision for notifying parents and guardians (e.g., through the Emergency Broadcast System (EBS )) of the status and location of their children during a radiological emergency. Also, the plans should document the decision making process and criteria used f or develocine emercencv
~
procedures for implementing protective acticn 5easures f'or school children. Acceptance criteria for developing and evaluating emergency planning and preparedness f or school children are provided below. G _ . . _ _ _ _ .__._________________..-.__.---___._.___.--___J
l 1 I
/~N
(
- (_f
) Plannine Standard And Evaluation Criteria J. Pretective Restense . ?lanninc Standard A range of protective actions have been develoced for the plume exposure pathway EP: f or emergency workers and the l
public. Guidelines'fer the choice of protective actions curing an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EP appropriate 50 the locale have been developed. (NUREG-0 6 3 4 /T E MA-RE P -1,
- p. 59)
Evaluation Criteria 1212 Each State and local organization shall establish a capacility for implementing protective actions based upon protective action guides and other criteria. This shall be consistent with the recommendations of C?A regarding exposure resulting from passage Of radioactive airborne plumes (E PA-5 2 0 /1 -7 5 -0 01) , and with those of CHEW (DHHS)/FDA regarding radioactive contamination of human food a'nd animal f eeds as s published in the Federal Resister of Sece.. bee isr iG7er [J i J,10. f43 PR sB996v October 22<1982 (47 IE 47073).* The organization's plans to imple=ent protective measures for the plume exposure pathway shall include: J.10.a. Maps showing evacuation routes, evacuation areas, preselected radiological sampling and monitoring points, relocation centers in host areas and shel:e: areas (identification of radiological sampling and ! monitoring points shall include the designators in j Table J-l or an equivalent uniform system described in the plan); ) 1 i J.10.b. Maps showing population distribution around tne nuclear facility. This shall be by evacuation areas l (licensees shall also present the informa:icn in a I sector format); ; J.10.e. Means for notifying all segments of the transient : and resident population; ! 3.10.d. Means for protecting those persons whose mobility I may be impaired due to such factors as institutional or other confinement; l l
- For your information and reference, the 12/15/75, CHHS guidance has been superseded by the 10/22/82, guidance.
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J.10.c. Means of relocation; l J.10.5. Relocation centess in host areas which are at least five miles, and pref erably ten miles, bevond the Gt boundaries ef the plume exposure EP: (See K.8); J.10.1. Time estimates f or evacuation .of va rious sectors and .l distances based on a dynamic analysis (time-motien study under various conditions) for :he plume exposure pathway E?t (See Appendix 4); , f Accendix J.,. Evacuation 212% E s t im a t e s W i t h i n dit ?lm Excesure Pathwav Imercencv Plannine Cone i Accendix 4.II.C. Scecial Facilitv Peculation l 1 An estimate for this special population group shall usually be done on an institution-by-institution basis. The means of transportation are also highly individuals:ed and shall be 4- l described. Schools shall be includ'ed in this segment (p. 3). Areas 21 Feview These evaluation criteria address the key planning requirements concerning the evacuation of students from schools. The review unde': these criteria is intended to ensure that adequate planning and preparedness capabilities exist to. enable school officials to evacuate students in the event such a protective action is necessary du:ing a radiological emergency. This guidance covers those actions from the initial notification to school officials of the need to evacuate the students to their a :ival at relocation centers or other protective actions. In addition to these actionJ, the guidance also addresses time f rames f or accomplishing the protective actions, For purposes of definition and reference to NUREG-0654/ FEMA-REP-1, we are including " schools" among the types of institutions, the mobility of whose population may be impaired during a radiological emergency, because most students are dependent on school officials for ::ansportation to and from thei: residences. (See evaluation crite rion J .10. d. ) Also, " schools" are explicitly referenced in Appendix 4 on pages 4-2 and 4-3 as a type of "Special Facility Population" for which evacuation time f rames are needed on an institution-by-institution basis. The term,
" schools," as used in this GM refers to public and private schools, and licensed or government supported pre-schools and day-care centers.
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c- -_ _ l l l l 1 \ L /^\ Accertance criteria V An emergency plan will typically be acceptable under these r evaluation criteria if it fully addresses the following ! emergency functions for the eva:uation of, or other s appropriate protective measures for, school chi *dren. Local governments should take tne initiative Oc identify and contact all rublic and erivate rchool systems within the
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designated plume exposure pathway EP2 to assure that both L public and private school offic.:als address appropriate planning for protecting the hea;th and safety of their students f rom a commercial nuclear power plant accident. The planning of both the public and private school officials should be closely coordinated wsth that of the local government. Local governments should ensure that appropriate o organizational of ficials assume responsibility for the emergency planning and preparedness for a*1 of the identified schools. Local governments should also ensure that the emergency planning undertaken by these organizations is integrated within the larger offsite emergency management framework for the particular nuclear pcwer plant site. In accordance with the guidance contained in GM 21, the
,s evacuation planning undertaken may be developed in three t
contexts: {
%) Part of the existing . radiological emergency (1) preparedness plans, (2) A separate annex of an existing integrated emergency plan for many types of disasters and emergencies or (3) A separate evacuation plan f or all of the schools in each' school system.
School officials should document in the plan the basis for
. determining the proper protective action (e.g., evacuation, early preparatory measures, early evacuation, sheltering, early dismissal or combination) including:
- Identification of the organi:ation and officials responsible for both planning and effecting the .
protective action.
- Institution . specific information:
- Name and location of school;
- Type of school and age grouping (e.g., public elementary school, grades kindergarten through sixth);
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- Total population ( .s t udent s , faculty and other employees);
- Means for effecting protective actions;
- Specific resources allocated for transportation and ,
supporting letters of agreement if resources are provided from external sources and
- Name and location of relocation center (s), and -
transport route (s ) , if applicable.
- If parts of the institution-specific information apply to many or all schools, then the information may be presented generically.
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- Time frames for effecting the protective actions. l 1
- Means for alerting and notifying appropriate persons and groups associated with the schools and the students i' including:
- Identification of the organization responsible for providing emergency information to the schools;
- The method (e.g., siren and telephone calls) for contacting and providing emergency inf ormation on recommended protective a'ctions to schco" officials; g-
- The method (e.g., siren, tone alort radios and telephone calls) for contacting and activating designated dispatchers and school bus drivers; and {
- The method (e. g. , E3S messages) for notifying parents and guardians of the status and Location of their l children.
Plannine standard and Evaluation Criteria N. Exercist and Drills Plannine Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities. Periodic drills are (will be) conducted to develop and maintain key skills.' Inadequacies identified as a result of exercises or drills are (will be) corrected. (!NREG-06 5 4 /FE MA-REP-1, p. 71)
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l - l l l l9 , o i ' i Evaluation criteria l d N.1.a. An exercise is an event that tests the. integrated l capability and a major portion of the basic elements j existing within emergency preparedness plans and / organi:stions. The emergency preparedness exercise i shall simulate an emergency that results in offsite radiological releases vnich would require prompt )4 response by offsite authorities. Exercises shall be conducted as set forth in NRC and FEMA rules. N.1.b. An exercise shall include mobilization of State and local personnel resources adequate to verify the capability to respond to an accident scenario requiring response. The organization shall provide for a critique of the biennial exercise by Federal and State observers / evaluators. The scenario should be varied from exercise to exercise such that all major elements of the plans and preparedness l organizations are tested within a six-year period, i Each organization should make provisions to start an exercise between 6:00 p.m. and 4:00 a.m. once every six years. Exercises should be conducted during different seasons of the year within a six-year period in order to provide fpr exercising under j various weather conditions.. Some exercises should be
/% unannounced.'
( ) H232, Official observers from Federal, State or local governments will observe, critique and evaluate the required ex.ercises. A cr,itique shall be scheduled at the conclusion of the exercise to evaluate the ability of. organizations to respond as called for in the plan. The critique shall be conducted as soon as practicable after the exercise, and a formal evaluat. ion should result from the critique. Areas 21 FeView i i l These evaluation criteria address exercise-related j requirements and their evaluation by Regional Assistance l Committee (RAC) staff. In addition to identifying j capabilities for evacuating students or effecting early l dismissal as a " major element" of an organi:ation's emergency j response plan, suggestions are provided for conducting l interviews with officials f rom schocis during an exercise. l l 1 l l l
- These provisions conform to the revision of evaluation !
criterion N.1.b. of NUREG-0654/ FEMA-REP-1 promulgated in I GM'PR-1, Policy on NUREG-0654/TEMA-REP-1 and 44 CTR 350 Periodic Requirements.
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Accertance criteria Requirements are set forth in FEMA (44 CFR 350.9) and 11RC (10 CFR 50, Appendix E.IV.F.1-5.) rules for conducting periodic lh exercises and drills. Under these r equ'i r e m en t s , organi:stions with assigned responsibilities f or protecting students are required to demonstrate through exercises their ' ability to implement emergency procedures contained in their emergency response plans. However, :he public (e.g., school ! i children) are not required to participate in exercises. Further, the actual use of school vehicles is optional. The s / demonstration of each organization's capability to implement these measures in exercises will be evaluated by FEMA and other Federal officials. . The following functions should be demonstrated and evaluated ! in exercises in which the evacuation of students is ; necessitated by events in the exercise scenario:
- 1. Alerting and notification of appropriate school of ficials by local emergency officials with respect to status of radiological emergency and need to implement protective actions, including evacuation;
- 2. The contacting and notification of dispatchers and school bus drivers, as appropriate, to inform them of any potential or actual .need f or them to transport students and
- 3. The provision of information to the parents and guardians, as appropriate, concerning the status and intended location or destination of the students.
With respect to simulating the evacuation of school. children in an exercise, the following guidelines are provided.
- 1. At the discretion of school officials, the bus driver T.ay proceed to drive a school bus to a relocation center, as necessitated by the simulated exercise events.
- 2. An exercise evaluator will interview the relevant personnel at the ECC's, the School Superintendent's .
office, the School Principal's of fice, and the Dispatcher's office, as well as the bus driver to determine their awareness of and preparedness f or the evacuation of the school children. Pertinent questions for the exercise evaluator pertaining to the dispatcher and bus driver include: Emereenev Crerations center (s) - (ICC1 One or more IOC's may be involved in decisionmaking to effect the evacuation of schools. For example, in some States, local school evacuation must be coordinated with 8
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State officials. In such cases, observers may need to ('}/
\_, concurrently evaluate evacuation or other protective
, action decisionmaking in both State and local ECC's.
- 1. Who'made the decision for evacuation or other
- protective action of schools and when?
- 2. What specific actions (evacuation, early dismissal or shelter) are incorporated in the decision and what specific sectors / schools are impacted by this decision?
- 3. When and f rom whom did the ECC receive information about this decision?
- 4. When and whom did the ECC staff contact to implement this decision?
- 5. Did ECC staff undertake actions to assist school evacuation or other protective action such as securing guides, buses and assistance in traffic control?
School superintendent's O_ffice
- 1. When and f rom whom did the superintendent receive protective action instructions or recommendations?
What specific instructions or recommendations did the [s\-} superintendent receive?
- 2. What actions did the superintendent take to implement these instructions or recommendations? Whom did the superintendent contact and when?
School Princioal's Office
- 1. When and f rom whom did the principal receive protective action instructions? Uhat specific instructions did the ;rincipal receive? !
- 2. What means of communications (e.g., telephone, tone alert) were used to provide these instructions? Did this means of communication function adecuately to provide accurate and timely information?
- 3. What actions did the principal take to implement these instructions? Whom did the principal contact and when?
Disratcher
- 1. When and f rom whom did the dispatcher receive the instructions? What specific instructions were received?
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- 2. I.7. a : means of coccunications were used? Mere the communications between the dispatcher and his/her lh supervisor and the dispatcher and the bus driver adequate to convey appropriate and timely information? .
- 4. When did the dispa:cner initiate no ifica:icn :o bus drive:s and guides to implement the evacuation c:
other protective action plan? What specific -4 instructions were provided by the dispa cher? How long did it take to contact the bus driver to give the order to evacuate? 121 Orivers/ Guides
- 1. When and f:cm whom did the bus drivers and guides receive instructions? Mhat instructions were received?
- 2. Mhen did the driver arrive at the school?
- 3. Did the driver have an adequate map or knowledge of the route?
- 4. Mas the driver aware of any agreement between the drivers and local authorities for them'to provide their' services in the event of a radiologi, cal emergency? i
- 5. Mhat means of communications were used? "ere communications with the dispatcher adecuate to convey appropriate.and timely information?
- 6. Did the exercise play necessitate a change in instructions to bus drivers and guides? If so, what were these new instructions? What means of communications were used to contact the bus drivers and guides? Was this means cf communication adecuate?
Padiation "onitorine and Protection M ggs Orivers M Guides iga desienated emereenev workers)
- 1. Here bus drivers and guides provided with specific means for radiation monitoring (e.g., dosimeters and film badges) and exposure control (e.g., potassium iodide, respiratory protection)?
- 2. Mere bus drivers and guides trained in the prope: use of these instruments and materials?
- 3. Mere instructions provided to the bus drivers and guides for the authori:ation and use of potassium iodide?
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l f ) k/ 4. During :he exercise, were instructions given to alter evacuation /early dismissal routes in order to aver: radiation exposure by bus drivers and guides? l 1
- Relocation ra--a-=/'Teichborhoods 11;; as-1v dd=~dsrali l 1
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- 1. When did the buses at:ive at the relocatien l center (s)/ neighborhood (s)?
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- 2. According to the exercise scenario events, dic :ne l bus drivers go to the appropriate relocation j centers / neighborhoods? Did they arrive in a timely I manner to avert radiation exposure?
Provision 21 Emereenev Instructions 12 Parents and Guardians i I 1, was information provided to parents and guardians on j the location of students, e . g . ,. relocation centers, ; early dismissal to residences or sheltering? When ! was this inf o rmation provided?
- 2. What means (e.g., ESS messages and telephones) were used to provide this inf ormation?
rx 3. Was this information provided in a timely and accurate manner according to the exercise scenario () events? In some cases, answers to the above questions will be secu:ed f:cm direct observation of the simulated evacuation, thus obviating the interviews. Seecial Considerations ing Imelementine Protective Actions In addition to the guidance above on school evacuation, the following special considerations are provided f or use when implementing other protective actions. Ear)v Precaratorv 3easures. In order to facilitate the implementation of protective actions, the f ollowing measures should be considered:
- a. Inventory resources f or mobili:ation; e.g., school buses and drivers.
- b. Curtail extramural or extra curricular activities so that school children are available for prompt evacuation, if it becomes necessary.
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- c. Select the method Nr.g., ISS) and the draft message to notify parents and guardians of the status or destination of their children if i: becomes necessary to take protective actions.
- d. Assure that the relocation center is available in the .
event evacuation is necessary. Ig;13 Evacuation. Early evacuation is accelerating the implementation of protective actions for school children - prior to the activation of protective actions for the general public. For example, if a plan calls for an evacuation of the public at the " General Emergency" level, then protective actions for school children would be initiated at the " site , Area Emergency" level. In the event of a rapidly i deteriorating situation, school children would be evacuated 1 simultaneously with the general public. Earlv Dismissal. While early dismissal of school children is not addressed as an evacuation option per se in NUREG-0 6 5 4 /TE!!A-RE P-1, it is incorporated in this GM as a method for accomplishing the intent of evaluation criteria under planning standard J because of its use for other types of emergencies such as imminent natural hazards he.g., snowstorms). Hazards such as a school fire or boiler failure have a limited hazardous area, unlike an extended radiological plume; therefore, the early dismissal of students to their parents and guardians may be prudent. The greater area aff ected by severe weather, such as a bli::ard, usually does not jeopardize the health and safety of the school children if they are dismissed early bef ore the storm or remain sheltered in the school. In contrast, the radiological plume may make both the school and home undesirable shelters if both are in the plume exposure 4 pathway, or if a f ast moving event could escalate to while , the children were in transit. Further, in the presence of I unstable meteorological conditions it is difficult to project the movement of radiological releases. Therefore, the unique characteristics of a radiological emergency place limits on the use of early dismissal as a viable protective action, particularly in heavily populated areas. Evacuatien combined El;t IA;12 Dismissal. Early dismissal used in conjunction with evacuation as described above provides another option. The school children who reside in a sector of the ten-mile EPZ not effected by the potential danger or outside the ten-mile EP2 could be dismissed early to their parents, guardians or other supervision while those students whose homes are potentially in the path of a radioactive plume would be evacuated to designated relocation centers. O 12 ___m.-.__W
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i l r'~x shel eri.221 'Jnder certain circumstances sheltering may be f ( the preferred p:ctective action ( e . g. , when :here are
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hazardous read conditions or the possibili:y exists tha: evacuation may result in ::ansporting students through the plume). Sheltering may be used as a primary c: temporary protective action depending upon :he characteristics of the . radiological. release and the status of weather and road conditions, i- GM EV-2 is issued subsequent to review and concurrence by URC staff who have determined that it provides clarification and interpretation of existing NUREG-0654/ FEMA-REP-1 criteria applicable to protective actions for "special populations." G b
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TPCM: cLough1:n ueputy Assoc:, ate Direct:r State and J.ccal Programs and Sepger: SLE T02: Guidance Memcrandum (G4) MS-1, Medical Seriaces . . 1 The < tac *.ed G4 MS-1, Medical Ser/ ices, is feraarded f:r your use in prevming guidance to State and 1ccal officials in devoleping eneir radiological emergency resp:nse plans and in evaluating the medical ser/ ices capabilities of State and local goverments.
':he erigins of this G4 and its development and approval have been semewr.at different i:: m other Gi's. *his G4 was develeped as a result of a series of 1r.441 decisiens involving NRC which deter.dned that the existing integretation of the required pre-accident medical arrangements Sr centauinated injured individuals as net sufficient. These decisiens led b
. NRC to issue a golicy statment ( Attac . ment B) en Septecer 17, 1986, indicating that the NRC staff (in consultation witn FCd.A) would develop detailed guidange en the necessary pre-accident arrangements ir medical ser/ioes by Ncvember 17, 1986.
We he wrked closely with NRC in recent weks in the preparation Of this guidance. Unfortunately, the shcr deadline did not ge:m.it our usual procedure of cotaining aegicnal and other co rents before issui.m this final guidance. If you have any questions about MS-1, you may contact James "hemas at 646-2808. A list of all current operative G4's ( Attachment C) is also provided Sr your information. A"'IAC."CCS : A. G4 MS-1, Medical Seri ces B. Onergency Planning - Medical Ser/ ices, September 17,19 86, 51 FR 329 04 C. List of Operative G4's (not provided) W
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'D [Ng'*E'*- Federal Emergency Management Agency Washington, D.C. 20472 i NOV 13 955 GUIDANCE MEMORANDUM MS-1
- MEDICAL .5ERVICES f
Purcose This Guidance Memorandum (GM) provides interpretation and clarification of requirements . contained in the Nuclear Regulatory Connission rule,10 CFR 50.a7 (b)(10) and the associated guidance in NUREG-0654/FEPA-REP-1, Revision 1, re-lated to th'e provision of medical services for members of the general public. Backcround The background is contained in a policy statement from the Nuclear Regulatory Cor:nission (NRC) titled " Emergency Planning - Medical Services" (51 ~R 22;C4). In this policy. statement, NRC states its belief that 10 CTR 50.47(b)IT2) r (" arrangements are made for medical services for contaminated injured individuals") requires pre-accident arrangements for medical services-(beyond the maintenance of a list of treatment facilities) for individuals who might be ( severely exposed to dangerous levels of offsite radiation following an accident at a nuclear power plant. As used in 10 CFR 50.47(b)(12) and planning Standard
'"L" of NUREG-0654/ FEMA-REP-1, Revisien 1, the tem " contaminated injured" means
- 1) contaminated and otherwise physically injured; 2) contaminated and exposed ::
dangerous levels of radiation; or 3) exposed to dangerous levels of radiation. Guidance 10 CTR 50.47 (b)(12) requires that " Arrangements are made for contaminated injured individuals." In its policy statement the NRC determined that this standard requires pre-accident arrangements for medical services for offsite individuals who might be exposed to dangeroJs levels of radiation following an accident at a nuclear power plant. The following guidance applies to the eval-untion of the medical services aspects of State and local emergency plans under the criteria in NUREG-0554/ FEMA-RE?-1. Standards, Evaluations Criteria , Areas of Reviews and Acceotance Criteria A. Assionment of Responsibility (Oroani:ation control) Plannino Standard
. Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organi:stions within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various suo-porting organizations have been specifically established, and each princi;al response organi:ation has staff to respond and to augment its initial respense on a continuous basis.
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O . 2 A.J. Evalua tion Cri terion . Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other supoort organi:ations having an emergency response role within the Emergency Planning Zones. The agreements shall identify the emergency measures to be provided and the mutually acteptable criteria for their implementation, and specify the arrangements for exchange of information. These agreements may be provided in an appendix to the plan or the plan itself may contain descriptions I of these matters and a signature page in the plan may serve to verify the agreements. The signature page format is appropriate for organi:ations ane-e response functions are covered by laws, regulations or executive o ders where secarate written agreements are not necessary. Areas for peview and Acceotance Critpria State or local governments should obtain written agreements with the listed medical facilities (Planning Standard L. Evaluation Crite'ria 1 and 3) and trans-portation providers (planning Standard L. Evaluation Criterion 4). ~he written agreements should contain simple assurances that the providers have adecuate technical information (e.g. treatment protocols) and treatment capabilities fo handling " contaminated injured" individuals. An indication of Joint Commission on Accreditation of Hospitals (JCAH) accreditation will suffice for such assurance. (Note: Veterans Administration (VA), military anc other government hosoitals are not usually ac:redited by JCAH but usually have the desired capabilities. ) If state or local governments do not obtain written agreements, the licenses should obtain written agreements with the listed medical facilities and trans-portation providers. If good faith efforts are not successful in a particular case, the licensee shall provide or arrange for adequate compensatory measures, e.g., cbtain written agreements with other providers or provide temporary field medical care. . L. Medical and Public Health Suecort plannino Standard Arrangements are .made for medical services for contaminated injured individuals. L.1. Evaluation Criterion Each organi:ation shall arrange for local and backup hospital and medical services having the cacability for evaluation of radiation exoosure and uotake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals. O
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v l 4 Areas for Review and Acceotance Criteria There- should be one primary local hospital and one backup hosci:31 f:r each site for the evaluation and emergency treatment of ":0ntamination injured" members of the general public. Hospitals are generally distributed precortionai to the population. Thus, at sites with low population and few hoscitals, the primary local and backup hospitals for members of the general public c:uld be the same as those for the utility employees and emergency workers. L.3. Evaluation Criterion Each State shall develop lists indicating the location of :ublic, rivate and military hospitals and other emergency medical services facild ties within the State or contiguous States considered capable of providing medical su::or; for any contaminated injured indivicual. The listing shall include the name, location, type of facility and capacity and any special radiological ca:tbfii-ties. These emergency medical services should be able to radiologically monitor contaminated personnel, and have facilities and trained personnel 1ble. [~_s) to care for contaminated injured persons. A/ s Areas for Review and Accectance Criteria The lists should be annotated to indicate the ambulatory /ncn-ambula*. ry ca:aci-ties for providing medical su: port for " contaminated injured" members :f tre general public and any special radiological capabilities. This will enable siste and local officials to direct members of the general public to those instituti:ns capable of handling " contaminated injured" patients. In the event that local and regional medical resources need to be supplemented, additiona1 medical re-sources wculd be available through the Federal Radiological Emergency Res:ense Plan. These rescurces would include the Radiation Emergency Assistance Cen:er! Training Site at Oak Ridge, Tennessee and the National Disaster Mecical Sys:em with headquarters in Rockville, Maryland. L.4. Evaluation Criterion Each organization shall arrange for transporting victims cf radiological ac:i-dents to medical support facilities. Areas fo; Rev ew and Acceotance Criteria i Because the early symotems of persons exposed to dangerous levels of radiation are usually limited to nausea and vomiting, ambulances may not be recuired :: transport such persons to medical facilities. Rather, non-s:eciali:ed :eblic
,,,s and private vehicles can be used, supported, if necessary, with agreements in
( ) accordance with A.3, above. For oth types of contaminated injured individ-A/ uals, specialized transportation resources (e.g. , ambulances) would be necessary and should be assured by agreements, if necessary, in accordance with A.3. above. i Provisions should be made for the use of contamination centrol in transporting contaminated persons to medical facilities. _____..-_-___._._____m
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Planninc Standard , O. Radialecical Emercency Resconse Trainine Radiological emergency response training is provided to those who may be called on to assist in an emergency. 0.4. Evaluatien Criterion Each organization shall establish a training program for instructing and ouali-fying personnel who will implement radiological emergency resconse plans. 'he speciali:ed initial trainine and periodic retraining programs (including the scope, nature and frecuency} shall be provided in the following categories:
- h. Medical support personnel Areas for Review and Acceotance Criteria Each hospital listed under Evaluation Criteria L.1 and L.3. shall have at leas
- ane physician and one nurse on call within about 2 hours who can supervise th:
evaluation and treatment of radiologically " contaminated injured" members of the general public. There are several sources for this trainf ag including "RC licensee sponsored t-aining. Transportation providers should have basic training in' c ntamination control. Examples incl.ude but are not limited to:
- 1. FEMA handbook, videotape, slides and instruction manual titled "Mosoital
- Emergency Department Management of Radiation Accidents," SM 80/1984
- 2. Courses from The Radiation Emergency Assistance Center / Training Site (REAC/TS) at Oak Ridge Associated Universities.
- 3. Audiocassette and text course, " Radiation Accident Preparedness: Medical and Managerial Ascects" by Science-Thru-Media Inc., 203 Fifth Avenue, Su tei 803, New York, NY 10016.
N. Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major cortions of emer-gency response capabilities, periodic drills are (will be) conducted to deve'co and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
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v >- 5 N.2. Evaluation Criterion A drill is a supervised instruction period aimed at testing, develocing and maintaining skills in a carticular operation. A drill is often a c:moonent of an exercise. A drill shall be supervised and ev&luated oy a qualified drill instructor. Each organization shall conduct drills, in addition to the biennial
&RRWaI* exercise at the frequencies indicated below:
- c. Medical emergency drills A medical emergency drill involving a simulated contaminated individual which contains provisiens for participation by the local support services agencies (i.e., ambulance and offsite medical treatment faci'ity) shall be c:ncuctec annually. The offsite portions of the medical drill may' be performed as :ar:
of the ' required biennial aRawa?* exercise. Areas for Review and Acceotance Criteria . s ( ,)\ State or local governments should provide for the conduct of appropriate drills and exercises which include " contaminated injured" individuals. These medical emergency drills involving the primary local (L.1.) hospital for state and local governments should be conducted annually. These drills should also test the capability of relocation centers to direct " contaminated injured" members Of the general public to the appropriate hospital. If State or local governments canno: provide for the conduct of the drills, the licensee shall provide for the ::n-duct of such drills. If good faith efforts are not successful in a particular case, the licensee shall provide or arrange for adequate c:moensatory measures. Implementation State and local emergency response plans should reflect the provisiens of tnis . I GM at the next annual update following 9 months from the effective date of this . GM. Plans for plants that do not have a full power operating license should reflect the provisions of this GM within 9 months of the effective date of this GM. Tne first medical drill reflecting the provisions of this GM should be conducted by the end of the next biennial exercise following 1 year from the effective date of this GM.
- Changes reflect language incorporated into GM PR-1.
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O 6-NRC Coordination This Guidance Memorandum has been ;repared in : ordination with the NRC s taff. - As noted in the referenced NRC Policy Statement, the C0mmission has determined that these modifications fall under the backfit rule's exception as neces:ary to bring facilities into compliance with a. rule of the Commission. O e O
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.3 E904 Federal Rezister / Vol. 51. No. :so / Wednesday September 17 1sse / Rules and Ferulations l \
U such additional anangements. Se dac:sien1. se Commission itsei! faced f:r the Erst :=e se question weemer Commission leaves to me mfer=ed judgment of de NRC staff. subsect to plannmg standard (b)(1:1 appiled to general gwdance frem te Commissicn. me=cers of taa pubuc wne were me exact ;arameters of the mmimaily exposed to offsite radiatten f:i!cwing an necessary arrangements fcr medical accdent at a nuciear power facdity ::ut services. To fuifill 6:s menoate 2e staff were not otherwise mtured and .! so to (and Fr MA) will issue a pproprtate wnst extent. In censidermg dis gmdance to licensees. e pplicants. sad question. We Commission seuent me . state and !ccal governments. views of the part:es m te SCNCS
""he United States Court of Appeals proceeding, reviewed the pnne:;al for the Dismet of Columbia FCourt"} purposes of me plarmmg standard vacated and remanded a previous analyzed de likehhood of senous Cotamassion interpretation of plarming exposures to the public recumng standard (bi(10) which required only tne emergency medical treatnent. and development and mamtenance of a IIst evaluatec We type of emergency of treatment facdities on wisich post
- treatment liie!y to be required. Based on event, edhec estrangements for medical tgjs review, de Commission conciudad tnetment could be based. CUAM Y. as a genene matter dat:(1) P!armmg NRC. 733 F.:t 7144 (D.C. Cir.1985). standard (b1(12) applied to individuals Pending final Commission acdon in bo6 onsite and offsite: (:)
response to the CUAAD remand. We " contaminated injured individuals" was
. Cornmission issued a statement of intended to include seriously :rradatad intenm guidance which permitted * = embers of ie public as weil as pursuant to to CTR 50.47(cM1) de = embers of the public who are not issuance of full power licenses wnen senously irradated but also are de applicant satisfied the requirements somatically iniured from oder causes of plarmmg standard (b)(12) as and radiologically contaminstei and (3)
. interpreted by the Commission ;rter to Adequate, post.accdent arrangement CUAM. and where the applicant for necessary medical treatment of committed to full compliance with the exposed =e=bers of the public could be Commission's Enal response to the made on an od3 e basis tf eo:ergency
/,3 CUAM remand. The Commission's plans contained a list of locai rea:nent pnet intenm gmdance wd1 continue to facdides.
("/ govem the issuance of full power b, censes :mulissuance end On appeal. 6e United States Court of Appeals for de D.C. C;temt cocciuded implementation of $a NRC stafTe dat the Commission had not rasenaciy specific guidance on this matter, at interpreted planning standard (b)(10) which pomt 2e new policy wdl apply. when it genencally founc Sat a pre-EmenVI cati:: September 17.1988. accdent list of 7 eat =ent faculties FCR FustrHER INFCMusMCM CCarraCW constituted " arrangements
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C. Sebastan A!oot. Off.ce el the accident medical reat=ent. CUAM v. Ceneral Counsel. U.S. Nuclear NRC. 733 T.:d 1144 (D.C. C;r 1984 Ter NUC.IAR REGULATCRY Regulatory Commission. Washington, thjs reason. de Court vacated and CCMMISSICN DC 20553. Telephone (2:2) $34-3 :4. remanded that part of de Comm:ssten's sumzurNTany turCauano'< SCNCS dec:sion dat had interpreted 10 CFR Part 50 planning standard (b)(10) to require enly the preparanon of a list oflocal Emergency PfannireMedical In the wake of de Three Mile Island erstment facdities. However. 2 doing S e cas accdent in 1979, the Nuclear Regu! story so, de Court made c!aar dat de
- ActNcy: Nuc!aar Regulasory Commission FNRC" or "Coc:massion") Com=:ssen had on remand, m as scund Cornnussion. romu! sted requiscona requmng its discrecon. Cexshdity m fashionmg a p!censees
! and applicants for !!canses to reasonable interpreta:en of ;ian:ung actCoc Statement of Policy on F.mergency Planning Standard to C7"it opuste commercial nuclear power standard (b)(1 ).
gg7pgg reactors to develop piana for eme gency responses to accidents at their facilines. D. Arran3ementa bey'nd A Ust Of Among dose requirements was to CFR Treatment facilitisa Required suuussen The Nuc! ear Regulatory Commission ("NRC" or " Con =ussion") 50.4?(b412)(" planning standard When originally faced wi6 de believes that 10 CTR 5&4T(b)(1:1 (b)(1:F1. krifch ptovidea: question wheder de pnrase r;lannmg standard (b)(1:1"1 requires 'bmn onaae and effaue emergency " entammated intured edividuals was pre.acc: dent anangements for medical ruponse plan for nuc!ast power reactors !ntended to encompass. mrer oiic. services (beyond the maintenance of a must mnt 'te followtne standarcas members of the pdc who, se a result list of treatment facdities) for (1:1 Armtemems are made for medical of an accdent, were exposed to ladviduals who might be severe!y seen for unisminated tamred andividais. dangerous levels ot' reciatten, de expesed to dangerous teve!s of of!stta In SoutAern Californio Edison Commission found no expiic:t and adiation following an accident at a Company. er o/. (Sao Onofre Nuc! ear conclusive defitutten of the phrcse in de nuc! ear power plant. While concluding Centraung Staten. L' nits : and 31. CU- regulation itself or its underlying (qV) that plannmg :tandard (bl(1:1 requites 83-10.17 NRC 3:8 (IGC) ISCNCS) documents. Nonetheles6 Se
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Federal Rep.stc? / Vol. 31. No.180 / Wednesday. September 17 1988 / Rules and Repu!ati:ns r l Commission concluded $at the prudent The minimaily necessary The Comrntssion has determined mat risk laduction purpnse of the arrangements for the pe-son dat may be the nr age =ects c:ntemplated under C:mmission a regulations reoutred exposed need not be sisborste. As this Statement :f Peiicy are me interpretmg plannmg standard (b)(u) to previously stated by the Commission. . .inimum requred by a .essenable sopiy to suca offsite exposed "li]t was never the mient of de reading of plann:ng standard N{i::. mamduals. given the underivity regulanons to re:utre dire:t!y er Acc:rdmgiy. sitnough :m:lementat:en :( assumption of tne NRC's emegency incirectly that state and local this readmg :(Se standarc m!1 entad plannmg reguisuons that a senous govemments adopt extnordinary some sedmons to. and some accdent could occur and the mearures such as construction of modi!%anons of. the emegency - Commission presumption that such an additional hospitals er recruit =r:t of procedures and eqanizattora fer wh;ch ac: dent could result m offsite substannel additional medical licensees are ultirnately nsponsibia, ma individuals bemg exposed to dangerous penannel. !ust to deal with nec!est require =ents of de back.a.t rule.10 CTR j levels of radiation (a presumpuen plant accidents.";7 NRC at 533. Rather. 50.:09 (1988). for a cost benefit analysis concurnd in by the Federul Enc.qency the Com'm ission believes dat and a finding that the cesu of de h!anagement Agency). After sausfactory arrangements sheeld modificanons an pisuf.ed by a reconsidenten of 21s matter following include (1) a list of local or ngtonel substantia.1!ncrease in safety are :ot the CUARD decision. the Cors=lssion medical tnatment facilities and applicable. since these modificauens !a2 has decided to re.afntm ttis pner transportation providers appropnately under de backfit ruie's excepten for interpretat:en of planning standard annotated to show Weir capac:uaa, modificat: ens necessary to anna (b)(12). special capabilities or other unique factlities into compliance with a rule of However, the Commission has come charactenstics. (:) a good faith the Comm:ssion. See to CTR 50.;C9 to a different result with respect to the reasonable effort by licensees or local or (a)(:) and (a)(4)(1986). The analys s mmtmum arrangements necessary for state goverr.ments to facilitate or obtain whicn the backfat rule requires be done individ::als who mieht be senously wnttan agee:nents with Se listed to justify de appucation af any ofits exposed, but not otherwise injured. In a mecical fac:lities and transportanon excepuen provtsions constitutes t:e radiolegte emergency. In enginally providen. (!) provision for maimg core of tham St. ate =ent of Toucy.5ee!d resolving the scope of arnngements available necessary traimns for lisue, the Commission focused on the IIL Interim Guidamca emergency nsponse personnel to particular needs of offsite exposed idenufy, transport. and provida In its prior statement of policy. Se individuals for emergerrey nedical emergency Arst aid to severely exposed Co==:ssion ide:uSed ine factors treatment of their radiation injury. In individuals. and (4) a good faith which justified an interi= policy cf this fashion. the Commissica made a reasonable effort by licessees or state or grantir:g apptacts for Adl-power
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distinenon between the need for ' local governments to see that license an equitable excepuen to th immediate or near-term medical care, appropriate dnlis and exerc.ses are requirements of pianning staccard which was in its view the goal of conducted which include simulated (b)(u) under 10 CTR 50.4?(c!(1) wners plannmg standard (b)(ul. and the need severely-exposed individuals. lf good the applicant sausfied the reouin=e ts for long. term medical care. As to faith efforts are not successfulis a of;larmmg standard (b)(10) as exposed individuals, the Commission particular case. the licensee shall interpreted by de Com=:ssion ;nor to found that: provide or arrange for adeqsata de CUAR.D decsion ar.d cet .=:tted the special hazard la posed by de radiation compensam messuns, censistant d Hsd W M c=phance e any exposure to the patient The nature of the Com=ission's icte=t to limit the additional requirements imposed by be rac2 anon meury is that, while mecical need for enraordinary =e.asures cated Commission m response to the CUA.R.D treatment may be eventuany reqmred in above. The compensatory measuns remand. Statement of Policy on cases of extreme esposure. the ponents er, must be approved by NRC.This leve.1 of Emergency Plann:rg Standard : C"'R unisely to newd emergency toedical car, planning would help (1) provide 50.47(b)(C). 50 FR :::ES:(May r :r4.3;. (foomote ornitted).The non tmmedaac7 of the additional assurance of the cooperation The three facters wera:(1) tne trustment required for radaauoo erpmed of medical faculties. (2) ensure proper possibdity that the scope of piarming individuals provides onens and offs.ta tra:ning. (3) ensure $e ayallabdity of standard (b)(U)'would be limates!; (2) authonuae witn an addnanal panod of tune transportatten. and (4) demonstrate a de posatbdity dat deisy m es=pliacca h'[f s e ed med.ui aamn capability to provide necessary services through dedla and exereses. with de post CUAR.O requirer:ents could be fou:d to be instgmEcant due to From this. the Commluion reasoned The Commission has directed the stag de low probabdity of accdents dunn that the long. term treatment needs of to develop consistent with this the intenm period: and (3) the possibdary exposed indmduals could be interpretation of the plarming standard. of "other compeili tg reasons
- justtfymg adequately met on cdhoc basis. detailed and spectfic guidance on the a bnef excepuen wcere applicants had
" After reconsideration in light of the nature of the medical services to be relied in good faid upon pner CUAR.D decsion. the Commission has avadable to exposed individuals and on Commission interpretauca cf plan =ng concluded dat some additional planned be application of pianmng standard standard (b)[u).
arrangements beyond the developrnent (b)(u) to NRC licensees and applicants In sia Statement cf Policy interpreung of a list of treatment factlitaes are for licenses to operate commercal planning standard (b)lC: 're necessary to provida addiuonal nuclear power reactors. The Co==ission directs ',ne NRC stan to aseurance of r.ifective management of Commission has also directed be staff cevelop (in consultation with TDLA) emergency medical services in the hours to consider whether and under what and issue by 11/:7/S6 appropriate or days followmg a severe acedent. entens it is necessary er appropriate for detaded guidance on $e exact cent However, the Commisalon canonues to the staff to venfy the appmpnateness of of the necessary arrange =ents believe that the long.ierm treatment training. and dnlls or exere:ses consistent with the Cocurussion's needs of ex. posed mdividus's can be assocated with the handling of sevenly determination $st planning standard adequetely met on cdhoc basts. exposed persena. (b)(u) require arrangements for =ecical
1 _ 1 i 30906 Feder'al Register / Vol. 51. No.130 / %7dnesday. Se:ternber I?.1986 [ Rules and Regulations servtces (beyond the maintenance of a ' list of pre-existing treatment Lc:uties) for offstte exposec individuals. The-Commissten believes that me last two facters, ciscussec .n detailin its May M. 1983 Statement of Policy, contmue to justify reliance on de interim guidance for the perted ~.scessary for t.ne NRC stall to issa and licensees, applicants. , . a and state and local governments to I ) implement de detailed guidance. l i Therefore, until appropriate detailed ( guidance consistent with bis policy statement is issued and unplemented, the Ucensing Boards may contmus to reasonably find dat any heanng l regarding compliance with 10 CFR 30.4Tib41:1 shall be limited to issues which could have been neerd before t.he Court's decision in CUAAD v.NRC ; Oated at Washiraton. OC. 2 s 12:n day of r Septerr.cer.1966. For the Nucient Regiatory Commission. Samuel J. Chilk. See:rtary of Lee Cammission. (R Cnc. 86 .'t038 Filea bl6 46: 8:45 ami
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(*M h Washington, D.C. 20472 AFR 21 587
~ MI.MCFR1rCM FOR: ?egicnal Directors Ac ing Re;ienal Director '
FPCM: kMcLeugnlin
%;uty Associate Director State and Local Prcgrams and support SUE 7EC':
. Guidance Mercrandu:n (GM) AN-1, FriA Acticn to Oualifj Alert and Notification Systems Against NCFIC-0654/TC4A-FIP-1 and FEMA-?IP-10.
Guidance Me.crandum
~ AN-1.is pr0vided as an Operative G4 for ycur use in implementing alert and notification system ccmponents of Fr%'s radiological emergency preparedness program and for assisting utilities and State and local geve. - rents in developing and evaluating alert and nctificaticn system capabilities for c mercial nuclear pcwer pint accidents. With de issuance of GM Mi-1, GM-lS, Revisien 1 (Fr4A Action to Qualify Alert and Notification systems Against NU?IG-0654/Fr%-?Ip-1, Revision 1, dated October 19, 1963) is te:=tinated. A current listing
/O cf all operative GM's is also attached fer vcur use.
U We are appreciative of the cemnents provided by de Regions and, drough. your cecperatien, many states. Please provide ecpies of 21s GM and Your de current listing of operative Ct's te the states in ycur Regicns. review and ccmrents en the draf t copy of GM N1-1 were helpful in develeping the final version. Any questiens ccnceming tne implementati:n cf this GM shculd be directed to either Megs Hepler (F 3 646-2S67) cr i Vern Wingert (? 5 646-2972) . Attachments As Stated 1 j I i l \ 1--- _-
i Federal Emergency Management Agency (j, f-j, W1siungen. D.C. 20472 1 i 4 v.,. CPEFK"'< E GU 144CE M_OCPA'CA St.=:cer ' ate _ Ti le 4 4/1MO Padic Tnns=issien Frequencies ar.d '. verage 5 4/1/30 ;qree:-ents Accrq Ocver rencal .24encies ar.d (revised- ?-ivate Parties 10/19/8 ) 8 4 4 /30 Fegier.a1 Adviscr/ C.=:rr.i tee Occ:dinati:n (revised- With Ctilities 10/19/8 ) 16 SA/80 stard.ard Fegiccal Paviewi.z and Fepc:-i.g Phures f:r St. ate and "ccal Fadi:1cgica; O
'd E.ergency Fespense Plar.s 17 1/3/91 'cint Exercise Precedures
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20 10/19/O icreign *arquage Traesiation of ?mli: Educati:n 3 rec.ures and Safety Messages 21 2/27/34 Acceptance Criteria for Evacuatien Fir.s 22 10/19/O Fecordkeepir.g Pegairements f:: Prii: M.ee:1. .g s 24 4/5/84 Padiclegical F.e: gene / ? preparedness f:r Handicapped Persens E-1 7/15/35 Femedial Exercises C-2 7/15/B5 Staff Supper: in Evaluatirq FI? Exercises PR-1 10/1/B5 Felicy en NUPEG-C654/ FEMA-FEP-1 and 44 0T?. 3 50 Periedi: Feqairements 6 A s s / Ns' 1 l l j
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!!-l 104/S5 A Nide :: ccments Palated :: :.e F" ? =grz:
FI-l 10/2/35 IEG .a c :icn :: ?'i10: Cest L idance en ?~rli: Inf:t ation Materials and ?= vide Tec nical , Assistance On ::s 'Jse m-1 12/3 /S5_ Federal Fas;cese Cen:er . Ms-1 1143/86 Medical 5er/ ices N-2 1143/86- ?= cec:ive Actices 1:r Sc .cci Children
#1-1** 441/87 Fr % Acticn :: Cualify Aler ard Netificatien Systems Against NU?SG-0654/mA-?_"-l and FEdA-FIF-10
- G4-21 will be retitled G4 W-1 wnen it is revised :: cend::= :: P.ew nctnenclarre.
" Witn the issuance cf G4 Ri-1, G4-13 is te.. inated.
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QgC"' GUICANCE SE:CPA7 D1 X;-l 4 f" l FEMA 2C" CM ~O OCALIFY AIIE ViD ';CTIF~'AT!^N SYSD4S MAINST NUPE-0654/FC%-?IP-1 AND FCG-?IP-10 l l l
?URPCSE his Guidance Memorandum (G4) describes eli:y and pr:cedures = e followed Oy the Federal F.ergency v anagement Agency (FD.A) Headquarters and ?egi:nal
-# v Cf fices in' assessing and rakin; findims and determinatiers on the adequacy and ,
notification systews installed around ccmmercial nuclear ;cwer plants. Plana.ing l Stanfards E, F , and N and Appendix 3 of NUREG-0654/FC4A-?IP-1, and FE'%-?I?-10, the " Guide for the Evaluatien of Aler. and Ratification Systems for Nuclear Power Plants" contain the specific technical criteria against which aler: and .ctificati:ni system desig-s will e reviewed. This G4 supersedes the currently cperative 24-13, Fevision 1, entitled "FEG Action to Qualify Alert and Notification Syste~s Agnnst NUPEG-0654/Fe%-PIP-1, Revision 1" dated Cctober 19, 1983. 4ACFG.OCND The President Of the United States, in a statetent en Cecem.cer 7, 1979, assigned fm FCm as the lead Federal Agency for cecrdinating State and local radici qical emer-gency planning and preparedness activities at:und camercial :.uclear ;cwer :lants. (v') This responsibility included evaluating and approving State and local radici:qical emergency planning and preparedness for dealing with the consequences of an acciden: at a cermercial nuclear peser plant. Fol10wim this Presidential directive, FEG and the Nuclear Fegulatory C: mission (NRC) jointly pr:duced, in Sevem er 1980, NUREG-0654/TC%-FIP-1, " Criteria f r Preparation and Ivaluation of ?adicl:gica*. D ergency Res;cnse Plans and Preparedness in Supper: of Nuclear F-:wer ?lt.n s" . This guidance decurent provides the basis for the develo;nent of radiol:gi:31 emer-gency response plans and preparedness by State and local goverments and the NEC licensees for dealing with accidents at cerarcial nuclear ;cwer plancs. NCFIC-0654/FDG-REP-1 also provides .he basis for the review of radiclegical emergency response plars and preparedness by Federal agencies. Apcendix 3 of NUPE-0654/FCG-?EP-1 states that NPC licensees are required : install aler; and notification sptems around commercial nuclear ;cwer plants and *
- nat activation of enese syscams is tne rescensibility Of me State anc 1:c2.
gover m nts. ~he licensees -ere mandated ty NRC = have aler and .ct:.fi:stion systems installed arcund cperating c:nmercial ru: lear ;cwer plants Oy Ferr:ary '., 1982 (originally by July 1,1981). Any nuclear pcwer plant seneduled for Operanien ' after Fecruar/ 1,1982, is required to have an alert and notification syste , installed price to c:mer:ial cperation of the f acility.
~hr ugn agreement with fra NRC, FE"A accepted the lead responsibili:y for review-ing and approvun alert and notification systems. ~his included confirming ra:
- ne systes are in full Oc pliance with NCPE-0654/TCG-?IP-1, FD% Pule 44 :? .
350, and NRC Rule 10 CFR 50, Ac;endix E. As part of :nis lead res;cnst:ili .y, Fr'.A A developed tne "Str.ndard Guide for the Evaluatich of Alert and Notification Svste-s for & clear ?cwer Plants" (FD%-43) whien was issued as interim-use guidance" f:r (v) k I
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evaluattrq aler and net:.ficatien syst es. FSA-43 presented an elaccratien en and an acclicaticn of :ne cr:.teria contained in :rFIG-06f 4/FrlG-?IP-1 fer purocses Of rev:.eMng and appreving aler- and notification syste-s. FCG-43 was sucsewen t_ . revised ec reflect cements received during tne interim-ase ;eried. :n tve-cer 085, final guidance -as issued in FDA-?IP-10, wnten su;erseded FC%-43.
*he guidance contained in enis 2 addresses de crecedural stecs wn cn wil'. Ce follr.ed rf .ne FC% Regions and Headcuar ers in ne evaluation cf alert anc net '.-
fication sv. stems teacirq ue c ac.c. reval cf tne systes. All tecnnical ascects involved in the revtew and approval peccess are centained in FC%-?IP-10. - FISICNSIS!!ITIES The res;cnsibilities for de procedural aspects of evaluatirq alert and noti-fication syste-s are described belcw: FEPA Headquarters is rescensible fer the follcwinc:
- Establishing and reviewing ;clicy fer ~aking findings and deter.inatiens en tne adequacy Of =.ler and notification syste-s;
* :n coordination with the Regicns, develeping standard fer ats, centent, and acceptance criteria for reviewirq :ne tecnnical aspects of alert and nctifi-cation system design sucmittals frem State governments and/or NRC licersees:
Issuing recemmerdations and pelicy cencerning tne Energency 3rcadcast System (EES), National Cceanic and Acm. espheric Mministratien radio syste~s , etc. ,
'as eney relate te aler and notification systeas;
- Cocedinatirq arrangements with cther Federal .2cencies, if necessarf, to c:mplete the aler: and notification system desic;n reviews;
- Previding assistance in making ;olicy determinations en soecific issues and problems when requested by the FEM.A Fegiens;
- Administering centracts for de previsien of technical sssistance in revies-irq and evaluating alert and netificatien systeas;
- CccedinatiN t".e schedulirq cf alert and notification system teleprcne sur/evs with the FCG Fegiers and tecnnical assistance centrac:ce;
- Coordinating contractual arrart;ements for cenducting ce telephone sur/evs and resurveys, if necessary, for each alert and notification system;
- Cccedinating arrangements wid the Cf fice Of Management and Budget (CMS) fer clearance .c cencuct ene telegnene surveys;
- Issuing for-al findings to the NRC cn :ne adeg :acy cr inadequacy cf aler-and notification systers tased on Fr% Pegional reccmendations and findi.qs :
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*ssuing guidance, as neceS33ry, f:r ne FD% 3egions "O fil:W in rev*.ew'.ng
=e : utine aler; and actif t:st.cn 53 stem tes-irq pr:grm anc Opera::..;;y follcwirq =e in:..ial aler; and notifi st:.:n system appr: val.
. . . . _ . . 'FCG Ee .21.:.n.a.l_O f.f i.c.es_a.r.e r.esCCC.S_ic_l_e _f or_-ne f.O_ll_cWi.n..c *.
FBViewin.) aler and notification system fesi.fn suOmit:31s as a par ~ Of FCM' 3 evaluation and appr val process of State and local radielegical emergency plans and pre:aredness in accordance vien FC% Rule 44 CFR 350: Makitr; preliminary and final recer rendations to FD% Headquarters On appr:ving cr disapprovirq aler. and notification systems pursuan : NUFIC-0654/TCG-FIP-1 evaluation cri teria E.5. , E.6.(witn tecnnical assistance) , F.1., N..., N. 2. , N . 3. , and N. 5. ; Confi=ing that State and local gevem.ents have demonstrated de capa:iliry ' to aler and nctifv. =e pcpulation within .he 5 - er 10-mi .e pla o emer.ene./ plannirq :One (E?2) in ac Ordange wi h the ti:.e requirements in 10 CTR 50, Appendix E, Section D.3, Ntl REG-0654/Fre-REP-1, Appendix 3, and FCm-?I?-10 : Confining that acceptacle pr cedures are established, have :een demonstrated: If required, and are in full :=pliance witn all FD% guidance f:r aler:= and notifying the per.anent peculation in rural and remote areas and =e transient pcpulation in recreational areas, State Parks, wi'.dlife ref;ges, TN hunting areas, river areas, ccean areas, beacnes, and Otner areas frequen:ed ( by the transient populacien; Reviewirq de :utine aler and notification system testing pr: gram e p'.:yed my tne licenaee and/cr One State and iccal governments :: rain: 2:n and tes: the systems, s.o as to assist FC% Headquar.ers in detenining de adequacy Of; ce ge: gram; Reviewing Statenicensee operability rep:r:s to confin that =e siren Oper-acility standard of 90% required in FC%-PI?-10 has men achieved based :n the most recent 12 menes of test results bef:re de system is a::::ved (re .. operao lity of de system will be deter :'.ined y averaging =e resul:s Of all regularly scheduled tests uployed as par: Of the testirq pr: gram, e.g. sCer growl, full-cycle); Reviewirg aler and notification sv.ste tes:irq results annu_ ally after ce : -- initial system approval := confin =at testi.g has :een : mpleted in ac: rd-; ance with approved pr cedures and that the siren Operaci".ity rema;ns a: Or abcve 90%; and notifying FEMA Headquaners if it f alls elow 90S, t= s ray be included as par cf the periedic requirements stipulated in 34 FR-1) Assisting in the aler; and notification system teleph:ne sur/eys :y ::cr-
. dinatirg all necessary arrangements with State and local officia".s and :y providirg a representative at ce aler; and notifica:icn system ac:iva:::r j point (E ergency Operattens Centern, e :.) =e day of :ne sur >ey, if possi:9 and if .rnvel funcs peal:, . act as a liaisen to =e tecnni:ai ass u:arce centrac r:
l m t Q Reviewing and evaluating charges to alert and notification systems as necessary followin; One initial approval of the system; and j
* !cvising FC% Meacquarters of aler; and nctifi stion system pr le-s af ter
=e .n;;ial syste approval and recem: endirg resur/eys if .arran:ec, O\ l The 'e.c.n.n.i.c.a.'.
. - - - - ..--- - - Ass -- is tance Ce.n.:.r.a.c.:.:.r. s. .r.e.s.c.e.n.s.i.b.l.e. .f.o.r..=.e..i.:11:.w.i.n.c
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Reviewi g alert and netificatzen system design su mi-tals pursuan: :: eva - . uation enter:.cn I.6. :n :iL~aIG-0654/Fr%-?I?-l and Fr%-?I?-10: Cocu;entim me results of =e :ecnnical rev'.ew in prelimina:7 and final reports for 2se Oy me FC% Re. pens and Headquarters; , Previdirg .ecnnical assistance and advice on procles dat may anse in =e aler; and notification system reviews;
- Conductirg a public telepnene survey i mediately follcwirq activation of tne alert and notification system and statistically analyziry the results for inclusion in a final report en the adeg;acy of ne system; and Conducting telegnene resur/ays if directed.
.S tate .a.nd
- - - - - - - -iccal - - - -:c. - ~ vee..
- - - - men..t.s
- - - - - ar.e
--- rescens.i.ble .f.o.r.
de f ellowin.c:. C ctdinat:.rg wi .n licensees : ensure proper considertt:en of Offs :e radio-icgical emergency res;xanse plans and preparedness in the design of aler and notification systems; 4 Reviewirg, to the extent ;cssible, the alert and nctificatien syste designs sucmitted by One NRC licensees and .providirg appropriate seg ents of their radiological emergency respense plans (er at a minimum, an accurate :: ss reference) for :.nclus;0n in the alert and notification sys em design: Feraarding me licensee's alert and notification system design surmi .:a*. :o the FC % Fe;1 n for review; Assurirg activation cf de alert and notification systems for telephone sur/ey purposes and for routine tests and exercises; Revising offsite radiclo;ical emergency plans and preparedness to reflect any enarges to an aler; and notification system after :: is approved and pr vidi.g the Fr% Pegional Of fice wid ccpies of the revisions; Cecrdinating en and summitting a repor: en alert and notificati:n system siren operability and testirg results to the FC% Fegions for review annual'.y if =e data ,is not already provided by tne licensee (:ne data can be su:mittec in conjunction with the Gt PR-1 submission); Assurirg that address reg:.sters containirq infor .3 tion en de distribution of t:ne alert radies vitnin the mergency planning :ene are updated annually and are avaC.acle f:t ins';ectien; Confirmirg that appropriate testing and maintenance of tone aler: radi:s nas been ccepleted pursuant to t".e guidance in FD%-?IP-10 for =cse syste s cen-tainirq tone aler: radics; and O
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- Conductin; resur/eys Of aler; anc notificatica systems af er de initial sys-
- em approval, if =e resur/ey cannot ce condue:ed y FC % su: is deter = = ed cin:1y y TEG Headgaar:ers anc =e FE%, ?egicn to re necessary to certify me
- centinuec adequacy of =e systen. his is more lixely := apply :: systems w; =
a significan: ::ne aler: rad:: ::=penent; hewver, =e reasons f:r ze resur/sy will ze Outlinec for 5 tate and local officials, ce licensee, ard me NRC dnd suffic:.ent time will ce alicwed in wnien to cenduct it if cener satisfac: ri arrangements to correc tne pr:clem cannet ce made. NFC licensees are rescensible for the fellcwinc: Prepar:.ng alert and notification system design re;cres in acc rdance vi n ce , guidance in FC%-REP-10 and in NUFIG-0654/FCG-FIF-1, Appendix 3, and Occri.- nating the design with State efficials (and local goverr. ment officials if necessary); and sucmicirq de designs to the appropriate State gcVer . ment for review; Eepending en established precedures, sucmittirq alert and notification system Operability and testirq records ei=er cirectly :o de State gcverr. ment or :: the FEG Fegicns ,for review annually; and Assisting in aler; and notification system telephcne sur/eys and resur/eys, as necessary, and pr:mptly correcting system problems, t
.f%
\" ) NFC is rescensible for de fellcwinc:
Reviewing and approvirg alert and actification system designs prier :: installation of the sys: ems y the licensees; and
- Reviewirq Fr u findirgs en the adegaacy or inadegaacy of aler; and actifi-cation systems and folicwing up with appropriate actions to ensure ma:
prc:pt corrective actions are taken when needed. FFCCE3JEAL MPEC"S OF ALERI' NC NCTIFICATICN SYS EM FSVIEWS h*RC licensees are respersible for preparirq and submitting dree c0 pies Of deir aler; and notification system cesigns :: State efficials (ard : local gcverrrun: Officials if necessary) for coordinanen and review. State and local ;cver ren: Officials will ce expected to incer; crate appropriate sect ens of =e Offsze rad _~ icnical emergency response plans into the alert and notification system design su -
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mit.tal. Followiry tne review by State and local efficials, the designs will re i sucmitted to de Fr% Pegion, and tne Pagion will in turn suomi: a :cpy of ee I design to FD% Headquarters for review by the tecnnical assistance centractor. It is acceppaole for the alert and notification system design submission :: incorporate an accurate cross reference :o evaluatien cri:eria E.3. , E.6. , F.1. , N.1. , N. 2. , N.3. , and N.5. as addressed in the State and local radiological l l emergency respense plans instead Of navi g these pertions of .he plans rewn=en Just for ce aler and notification system des gn repert. O ~he FC% Regional review of =e aler and notification system design arxd of =e ( tecnnical assistance contracter's preliminary draf t report en ene alert and notification system design snould censist cf tne following: __-___-__-__n
_ _ _ _ _ _ _ . _ . __.y_..__ _ l
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- A verification er reverification of the adequacy of evaluation critens E.5. , ;
E.6.(administrative aspects and if possible, Onysical aspects), F.1., N.1., i N.2. , N.3. , and % 5. as dcct:-enged in the xst recent interim finding , exer- { cise repen, or 44 0FR 3f 0 approval
- A review of and cc-rents en :ne :acnnical assistance contracter's preliminar/
draft reper escecially as it relates to evaluation criterion E.6.f:nys; cal aspects) and a review cf the routine systen testing precedures and pers:O:y; -l1 1
- A confirmation of compliance cf the State and 1ccal ;cverrrents with : e tire requirements in 10 CFR Par: 50, Acpendix E, See:icn D. 3, NCREG-0654/FC4A :IP '. ,
Appendix 3, and FC4A-FIP-10 (See Attachrent I to this 04 for mre details );
- A review of both institutional alerting procedures and special alening cro-cedures utilized for the transient pcpulation to dete=nire :ne adequacy Of these procedures.
Folicwing their preliminar/ review, the Fagicnal Cf fice snould provide a prelir.inarf finding cf adequacy er inadequacy to FC% Headquarters. T.f the system is found :: ; have adequate alertin; coverage, a date for e .e telephene suriey sill :e estaclisr.ec l i by FC4A Headquarters dat is agreeacle to the Fagional Orfice, State and 1: cal gove rnuen:3, tecnnical assistance contrac:Or, and the NRC licensee. :f tne system is found to have inadequate alerting coverage er other proclems, tne State and/or utili:y vill be notified througn the FC% Fagional Cffice that further decrrentacien to sup;cr the aler and notificatico system design is required. A ere detailed review of the alert and notification systen design Oy ce Fagional Of fice -ay be required if significant time has elacsed since the last Regional interim finding, 44 CFR 350 review, or exercise was ccmoleted in wnich the aler and notification systen related plan elements wre reviewed. As car: Of the review crecess, ne tecnnical assistance centrae:Or will endue: a telegtene sur/ey of pec anent residents in the 10-mile E?2 af ter activation Of the alert ard nctificatien systan. Households will be pelled to ascer.ain she:ner er not they wre alerted during the ac.ivation of the sysr.en. Suen a teleonene sur-vey will te perfor ed only once to approve the aler: and notification system unless the results are unacceptable during the initial sur/oy. O,e telephone sur/ey can be conducted follcwing activation of the alert and notification systen either during routine testing, as cart of a scheduled exercise, er as a separate ac.ivatien.
'he tecnnical assistance contracter will prepare a final draf t reper: On :ne aler; and notification system following the telegnene sur/ey, mir final draf: recce:
will document the results of the survey along with the results of ene earlier teen-nical review of the system design. te FC% Regions will review dis fir.al draf t re;crt, address the acceptability of the r utine stren testing procedures and Ocer-acility witn respect to estaclisned standards, address any re-ainin; issues nce covered in their preliminary findi c, as discussed accve, and rake a final recem-rendatier, en approving rr disapproving : e system. ~he Regtenal finding nay i .cMa reccmrendatiens f:r system cdificatiens er enncncenents. FC% Meadquar ers wC1 incorporate all appropriate Regicnal rec =nnendatices into a final report and issue a findia; to :ne NRC en :ne e.dequacy or inadequacy of ene aler; and notification system. It is imper: ant to note that findings en aler; and notification syste-s enploying sirens cannot De issued without documentation that the routine siren
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testing procedures are adequate and that the operability standard of 90% in FC%- REP-10 has been achieved based en 12 xnths of current testirq reeneds. l 1 1
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state and local government emergency planning and preparedness can :e aper ved y Fr% pursuan: .: 44 CFR 350 without appr: val of =e aler and nctificati:n system. In =csc cases, FD% will issue a 00ncinonal 44 CFR 2f0 approval : ave-ated en =e ultimate ac.c.r. eval Of me alert and net ficati:n system. Che : aves: in =e 44 CFR 350 approval will :o removed once me aler: and notification sys:em is approved. Hewever, in scme cases, alert and notifi:stien system related proc-lems ray delay a 44 CFR 250 approval and in cener cases the alen and nonfica:icn systan approval may e granted simultaneously vim tne 44 CFR 350 approval. . An ale n anc ncetfication system is sucjec to an engineenng analysis agams: E C- ( 0654/FD%-FIF-l, and FD%-FIP-10 by :hia procedure only once, unless a signifi:an: charge, as spec.ified in 44 CFR 350.14, ir made to de system. 2e Fr% Reg:0nal Of fices will te responsi le for advising ED4A Readgaarters Of significant changes to alen and notification systems or of significant enanges in me IFZ .nat mtpn impact the ale:: and notification system after the initial approval. Che Regions will also te resportsi=le f:r assisting in re-reviews dat may :ec:me necessarj. If necessary, tecnnical assistance ray be pr:vided and a telegnene resurvey conducted if sucn re-reviews are uMertaken. Felicwim te initial, q;alifying telephone survey and approval of an aler and notification system, FD% will not condue: not require =a: addi-ional celepnene surveys be conducted to assess de continued capabilities of the system anless one or mere of the followin; conditions is encountered ca m uld warrant suen surveys: n
- A.significant change occurs in the demographics er in the configurati0n of the EP2 around de nuclear power plant; A significant modification is made to de pnysical c:mponents Of ce alert and notification system that actually er potentially decreases the effectiveness of the system; A significant problem is identified in s:me aspect of the alen and notification system er there is documentation provided by de Regi:n supporting concerns over the centinued adequacy cf me system; 1 l
Should any of these conditions be encountered, it will be incumcent upon =e Tsegional Office 0 notify Fr% Headquarters and rec:mmend revisions and/or ccerective actions wni= could include a telephone resur/ey :enducted ei=er cy Fr % or :ne State. If TC% conducts te resur/ey, FD% Eeadquaners wC cocedinate all appropriate arrangements f:r ne addi:icna'. surveys wim =e NRC, CMB, ard cener offices 'as necessary. State and local governments, in 4 conjunction with the licensees, are encouraged to conduct meir Own annual j surveys as a methcd of monitoring the continued ef festiveness of their systens , especially tacse wie significant t:ne alert radio :mponents. Eclicwing tne ini .ial approval of an alert and notification system, ce Fr% 4
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Fegions will se responsible for routinely receivin; de results of aler; and nenfication sys cm usts and will te ex;ected to review .ne results and reper-cem :: FD% Meadc; caners annually. ~he results snould te su mi::ed as ar: Of 1 te periedic regatrements re;ce:irg. his is necessary to 4/enfy =a: siren s/3 e.' cperacility is maintained at 90% or higner, the standard in FDG-FIP-10, and t; []) ( confim that routine testing, including testing of special aler ing ccepenents, is being conducted at the proper frequency and in accordance witn these procedures i f l l
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reviewed and appreved by FDG. 2.e cperacility results ay be sucmitted :: i FEMA ?egien by sieer the state and local gevemments er the licensee. l 1 1 For alert and notification systems corsisting cf tene aler radics, =e FD% ' *' Fagiers should receive confim acion frem State and local Officials and/cr =e licensee annually that the tene alert registers have been reviewed and updated l and that annual aintenance and testing of these systers has been per#ce ed ; by the appropriate authorities. ~his infer ation can te provided in conjunction -l j with the GM PR-1 subnission.. i 1 Attachment I :: this guidance memorandum centains an explanation of the ti.e requi'rements for alert and notification systems cut 11ned in WFIG-0654/FD%-?I?-1, j Appendix 3, FEMA-FIP-10, and 10 CFR 50, Appendix E. Attachment II contains an j 1 approximate ti.e line for reviewing alert and notification syste:n designs as cutlined in the precedures abcve. Nuclear ?sculaterv Cemissien Cecrdination GM AN-1 is issued subsequent te review and concurrence by NRC staff who have deter .ined that it provides clarification and interpretation of existing NU?IC-0654/ FC%-REF-1, % . vision 1, criteria applicable : :ne review of alert and nctificatice syste s, Attachments .4 . Stated e 4
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- l. ~he puqcse Of this attacnment is twofold:
- TO elaccrate apon :ne accepted FC% inter retation and aoplicatien Of
' aler: and notification system design ecjectives outlined in 10 CFR 50, Acpendix E, NUREG-0634/Fr%-REP-1, Appendix 3, and FE%-?I?-10 tnat relate to aler and notification system activation and timinc: and
- To provide guidance and suggestions for evaluating ard confi.~. .ing =cm-pliance aid these design 00jectives during of fsite radic1ccical s' er-gency preparedness exercises; The provision of timely and appropriate alerting and notification ecul.d be One of de aest critical aspects of protecting the puclic in the event Of an acci-dent at a nuclear power plant. Ensurirg that aler and notification systems installed arcund nuclear power plants are in fact capaole Of rapidly warni.c the puclic is an important aspect of FD4A's review of cifsite radiological emergency planning and preparedness.
BACKGP,CCND Each aler and notification system must have the capacility : rapidly aler-n t 1 the puclic and advise them cf protec ive action recomendatiens. Se actual V design cbjectives against wnich these systems must be designed are Outlined in the Nuclear Pegulatory Ccanission (NRC) Rule 10 CFR 50, Apcendix E, NCREG-0654/FD4A-FIP-1, Appendix 3, and FEMA-REP-10. As stated in NUREG-0654/FDG-REP-1, Acpendix 3, and in FD%-REP-10 the minimun acceptacle design Oojectives for ceverage y an aler: and neciftestien system are:
" a) Capability for providing teth an alert signal and an infonational er instructional -essage to the population en an area wide casis throughout the '10 mile EP2, within 15 minutes.
b) The initial notification system sill assure direct coverage Of essentially 100% of the peculation witnin 5 miles of the site. c) Special arrange'ents will e ade to assure 100% =cverage within 45 minutes Of de population wne ay net have received de ini :.a1 notification within the entire plume exposure EP2. The basis for any special requirements exceptiens (e.g., for extended water areas with transient coats or re-cte hiking trails) must :e documented.
- he NRC rule 10 CFR 50 Appendix E, See icn 'V. D.3. requires tnat licensees "snali denenstrate that :ne State / local Officials nave the capacility :: se a puclic necification decision'pr:r.ptly en :eing info: ed :y :ne licensee :f an es.ergency condition." 2e rule further states that "the design eo;ect:.ve of the pr:mpt puclic notification systen shall be to have the capacility to s
'-) essentially c mplete the initial notificatico cf the puclic within the plc,e ex;csure pat.%ay EP2 witnin aceut 15 minutes. The use of this notification
cav acility will rance frx. i.:nediate notification of 2e c.uclic (wi$in 15 -inu cf de tire eat 5 tate and local of ficials are notified eat a situation exists requiring ur;ent actien) te 2e xte likely event wnere eers is substantial ti. e availacle fer une State and local gevemmental efficials te make a judg:ent whetner er net 50 activate .ne puolic nctificatien system." . A verf im;cetant aspect cf the fer al FEMA process fer reviewing and appreving alen and notification systems is confi=ing that de design cojectives and requirements ^ cutlined accve ha' ve been met. In confi=ing alen and notification system capa-tility, FEMA ust consider a cerser/ative scenario, i.e. , the ecnditien requiring system activation and issuance of an instructional message ey effsite auderities within 15 minutes of notification by de licensee cat i rediate protective actices are required. NRC Rule 10 CFR 50, Appendix E requires that licensees have the capa-bility to notify responsible effsite officials within 15 minutes after declaring a . emergency. Sirliarly effsite, in extre e situatiens with no decision- aking ti e availacle, the capacilit*/ must exist to activate the system and broadcast an instr.:c-tional ressage wicin 15 minutes of notification by de licersee; er if decisien-making time is available, the capability must exist to activate de system and broadcast an instructional message within 15 minutes of a decision by the respersible official te warn the pcpulation. While FEMA and NRC require dat 21s 15 minute capability exist, it is reccgnized that net all emergency ccnditions wi'.1 necessita:e Offsite notification within as shcre a time as 15 minutes. The "15- .inute capability" is confirmed through the observation of actual demn-strations or simulations of this capability during effsite radic1cgical emergency -- paredness ex' e rcises. Actual demonstratiers are enceuraged. Curing dese exer exercise evaluators actually time the alert and notification process to cen" the administrative procedures and mechanical ecmponents cf the system are in place and satisfy FE:% and NRC requirements. INTERPRI. AT'CNS FD%'s interpretation of the design objectives outlined in NUR!r,-0654/FIMA-FI?-1, Ap;endix 3 and of the requirements in 10 CFR 50, Appendix E are based on gecgrapnic iccation within the emergency planning tene. Se alert is censidered to W :ne warning signal and the notification is censidered to be the issuance of puclic in-structions via the Emergency Broadcast System (EBS) or other systems. Se desig cb-jectives will be applied by FEMA in alert and notifiestion system reviews as fel'.cws
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- Wiein 0 to 5 Miles of the Site Alen and netificatien systems must be capable of providing an alen signal and an instructional ressage within 15 minutes to pcpulated (per anent and transient areas located within 5 miles of tne f acility. This includes aler-ing and neti-fying the transient pcpulation in remote r.:ral areas, cpen water areas, rivers, hunting areas, recreational areas, private c:r.pcends, beaches, natienal f erests, and ether icw pcpulation areas wnich may require special alerting pr cedures.
' Wie in 5 te 10 Miles cf de Site Alert and notification systems must also be capable of previding an alert {
signal and an instructional message widin 15 minutes between 5 and 10 mi'- of the facility. !!cwever, in extremely rural, icw population areas beye i I 1 - i i _______-J
C :_3-( miles, up to 45 r.inutes .sy be allcwed for providing an aler signal Exa and anet, ples 4' inst =c.icnal message to 2e per anent and transient ;cpulatien. such areas l include : ural f ar-s, hunting areas, recreational areas, c;en water areas, natienal forests, beaches, and rivers. ~he alert and notification 4f system design submittal should :entain the ratienale for reqJiring up :: minutes to. alert such areas as well as the ccher documentation reqJired in f?.MA-?IP-10. Areas pec;csed in the alert and notification system design sub-missien for aler-ing witnin 45 minutes will be reviewed en a case-by-case basis.
- All Areas Widin the E.er;ency Planninc 2cne In all situations the time frames for activating de alert and notification system are measured fran 2e point at which the designated efficial', . cr Of ficia'.
if tse or mere jurisdictiers are involved, reaches a decisien wnich necessitates the activation cf de alert &nd netificatien system. As indicated in de d art below, there is decision-making tine available to offsite efficials.. eat shculd net be calculated in the 15 or 45 minutes.
~he felicwing chart illustrates de key steps in 2e aler; and notification process:
TIMING CF_UC' 6
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Alen Signal Authori:ed Public Activated and Official Peaches Instructional -{
'icensee Cecisien Which Re- Message Issued Nctifies quires Activating via E:nergency Emergency 3rcadcast er Declaration Public the Alert and Ncti ' i fication System Cther Syste.es l by a Utility officials t i
15 Minutes Varies 15(cr 45) Minutes l Decision-maxing ; I Time for Public officials Varies Fr:m , virtually No Ti.e Available In A Fast-Breaking Accident To . Substantial Time In -\ Slowly Evciving Accident CONFI? MAT!CN OF CAPABII.IT!ES U? LNG EXERCISES f In preparing to evaluate 2e 15 minute alert and notification cacability durinc ~ C an exercise, there are steps that can be taken to make this task' easier fer .ne k evaluator. Belcw are suggestions and considerations regarding evaluating'this capability before, during, and fc11cwing exercises: i
~ .r _4 Fre-Exercise Activities Sefere exercise activity tegins, ce Regicns shculd confim er be awars of 3 ce .foilcwing aspects:
- That for the effsite jurisdictions with alert and notification respcnsi-bilities, all administrative peccedures for ccepleting the entire peccess are clearly cecedinated and dccumented in the plans. .
That ce plans clearly state cat de alert and netificacien peccess can :e carried cut within :ne recuired :ime frames. with
- hat the plans clearly identify the official er appointed official (s) decision-making authority who can issue pectective action recorrendatices and autheri:e activation of the system (this official mignt be =e Gover cr, a Ccunty Administrator, a Ocunty Judge, er other similar officials) . ?.e 15 cr 45 minutes begins with =is efficial's autheri:. tien :c activate de system.
- That de plans clearly indicate de planned alert and notification activi-ties related c each emergency classifica:icn '.evel cutlined in de plan.
- Which emergency classification level will be used to verify :ne aler-and notification system capabilities. It is acceptacle to verify tne capabilities Of de system at any ene of the activations, if dere is mere than One, as long as the entire sequence can be ecserved during de activation chosen for verification.
* 'which routes will be cbserved if rcute alerting is par: cf de aler: and notification system and is te'ing confi=ed during the exercise.
- hat any backup alerting procedures dat have been develeped are clearly cutlined in de plan including hew dese procedures will be i plemented and the time frames prepcsed by the res;cnding crqanizaticn for ccepleting them, if any are prepcsed.
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Exercise Activities During exercises, the Regions shculd be ccgnizant of the following:
- Star-ine the Cicek In confiming that the aler; and notification system time requirements are satisfied, the evaluater should begin the timing frem the point at which the decisien to activate the alert and notification system is made. Within 15 er 45(:.f applicacle) minutes of dis decisien cy offsite l
1 officials, the aler signal must be activated and an ins:=ctienal essage i must be on de air. 1
- Menitorinc 7.acn Stec Every step of the alerting process should be monitored starting with de decision to ac.ivate ce system through the actual or simulated bread-j l
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U cast of the protective. acti:n recerrendation to confi= that pr:Fer pr:- cedures are being fc110wed. i During exercises, fecisien- .akirs time should be available to effsite Offic-ials. Ecwever, it will be incumeent upon de exercise evaluaters to deter-mine if tne time required by offsite officials t0 rake pr0tective acti:n
' rec: emendations is excessive and would result in ce public being placed at risk. Cbviously in a real emergency, the nature of the emer;ency wil'.
dictate the amount of the available to effsite officials in arriving at protective acticn recemmendatiers. Similarly, during an exercise, de scenaric and exercise play will give an indication of what reasonacle fe-cision--aking the is and wnen a lack of action shculd result in a required corrective ac 1cn citation er deficiency. Cecisien-making time ceuld range fr m absciutely zero in a serious, fastbreaking accident, to the m:re likely situation whereby consultation time would be available to effsite efficials. Cnce the Offsite efficials rake a decisien to _i plement a prc:ective action, the 15-minute cicek begins. Since every exercise is different, de decisi:n-makin; time cbserved will vary.
- Pri-arv Reute Alertine If route alerting is a primary means cf providing the aler signal, de Region can assign evaluaters to ac xpany the individuals perf =ing this function to confirm that preger procedures are fc11cwed and that de ap-p)
( U plicable 15- er 45-minute requirements are achieved including all steps cut-lined in TEMA-?IP-10 (e.g., mobilization of persennel, trarsit ti..e t0 the beginning of the route). If multiple rcutes are involved and sufficient r. evaluators are net available for evaluating sver/ route, a sampling of the routes may be chosen for evaluation, pessibly focusing en de mest difficult routes cr. de xre pcpulated r utes.
- Backun Reute Alertirc If backue route alert and notification system procedures ,are de-enstrated dunng exercises, evaluaters should be aware of the time required f:r off-site authorities to complete the entire backue route aler: irs process.
hese systems are designed to be put into etfeet only when pri-arf syste-s, j especially sirers, f ail. There is ne hard and f ast time requirement for i c mpleting the backup route alerting process; however, 45 minutes is a suggested ebjective for ::mpletin; the process. f l
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- 51rulation $
It is acceptable to simulate the activation of alert and notification syste-s J' durirq exercises. Ecwever, even though the system activatien is being si=- lated, the 15-minute capability can still be confi med. It is irportant dat all jurisdi :icns par-1:ipating in ce notification process are cperning :ff the same sim lated aler activatten tire. ? cute alerting ti-es should e cen-firmed througn actual ccservati:n. Even thcugh de notification pr: cess is being simulated, tne cese:ier shculd see de pregrati:n cf ee ins::ve:icna'. , r~N message, coordination with participating jurisdictions, ::ctnunleacion wi:n I the broadcast station and empletion of the authentication process. (v) 1 1
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O pest-Exercise Activities In prepari.g the ; cst-exercise reper , the felicwing items shculd :e addressed: I
- A clear statement of snether er not the exercise cejectives asscciated with the alert and netificatien system were acnieved.
s
- A chart er seme other method cf indicating the exact times of the varicus
! steps in :ne alert and netificatien ; recess that will -ake it clear if the tire requirements have ceen achieved.
- Failure by offsite authorities to ccmplete the cri .a:! alert and notifi-cation process within the the frames stipulated in NUPE -0654/ FEMA-?IF-1, Appendix 3 and FEMA-FIP-10 shculd auternatically result in a " deficiency" sirens, tene alert citation, regardless of the type of system (e.g.
radies, rcute aler.irg) employed.
- Failure to ecmplete backue rcute alerting in acccedance with the ti e frames established by tne respendirq cr;anicatiens should be cited as an
" area recenmended for improvement" .
O O
I V) , A :ac = er.: O l selcw is an appr:ximate time line representing eacn of =e : ajer steps~his '.eacing time up to and following an aler; and notification systen femenstration. le := cnanges in pri:ritieo
' line is appr ximate and for planning purpcses only.
it may ::e modified :y FD% Headquarters as needed on a site-specific basis. PRE-5URVEY
-16 'eeks FC% Headquarters receives a 00py of the 'i:ersee's .
design su mission through the FC% Regional Office vita a copy remaining in the Region for revies.
-15 Weeks FEMA Headquarters provides the licersee's design su nit:al to the tec .nical assistance contrac:Or f:r review.
-12 Weeks FD% Headquarters and Region jointly agree on a preliminar/
date for tne alert and notification dencrstratien and surzey.
-9 Weeks FD% Readgaar:ers receives the preliminary repr: en =e design frcm the technical assistance contracter.
FC% Headquarters submits the prelimina:/ re;cr: 50 =e O'u
-8 Weeks Begional of fice for review. .
-4 Weeks Regional Office ::meletes a review Of the preliminar/ repr:
frcm the tec .nical assistance contracter and, includir; their own review, makes a preliminary findin; Of adegascy or inadequacy to FC % Headquarters. If :ne design sucmissier. is found to be adequate, the Region c mpletes final seneduling. for the alert and notification demonstration. At this point the technical assistance centractor initiates efforts wi = the subcontrac:Or to prepare for the telephone survey. POST-SURVEY
-8 Weeks Technical assistance :ent-actor pr:vides final reper: :n t.he alert and notification fem:rstrati:n to FE% Headq;ar ers .
+10 Weeks FEMA Headquarters trarsmits report to the Regional Direct:r for final revies and evaluaton.
+14 Wee <s Regional Directer submits final reccmendatiens en the aler; and actification de enstration to FD% Headgaar:ers.
-16 Weess FD4A Heatdgaarte:s issues final findings and certifi:sti:- ::
NRC. If a si.e has a :endi icnal 350 approval, :3ves: :s if and tne Governce is notified Of approval. i, %
;/ '"
[p.. 49 lh.i Federal Emergency Management Agency
/._% w \.w : m Washington, D.C. 20472
)
ua 2 t 4,* MDiORANDC.14 FOR: bTri Division Chiefs FD4A Regional Offices k FIOi: Richard W. Krimm Assistant Associate Director State ard local Prograns ard Support StBJECT: GJidance on tRJRDG-0654/FD4A-REP-1 Evaluation Criterion J.12 . his memorandtrn provides interpretative guidance on NUREn-0654/ FEMA-REP-1 protective response evaluation criterion J.12: Each organization shall describe the means for registering ard monitoring of evacuees at relocation centers in host areas. We personnel and equipment available should be capable of monitorirn within about a 12-hour pericd all residents ard transients in the p1trne exposu-e EPZ p arrivirg at relocation centers. ( We question arises as to the percent @e of the evacuees' that could Previous reason-experience ably be expected to arrive at a relocation center (s). gathered on evacuation responses to a variety Ibsearch into of natural this matter, ard technological however, has emergencies is ret conclusive. revealed that anywhere fran 3 to 20 percent of the evacuees arrived at For radiological emergencies, it is rea-relocatiori conters or shelters. sonable to asstine that additional evacuees, to allay their concerns and fear over ra$iation, will go to relocation centers whether or rot they have been exposed to ra$iation. Bus, the percentage of ptential evacu-ees for radiological emrgencies may be closer to the upper erd of the 3 to 20% rarge. Ee congregate care issue is re/fewed as a part of all Atomic Safety and Licensing Ibard hearirgs, altretgh it has never been formally litigated at sich a hearirg. De congregate care facility capscity in the vicinity of nuclear power plants is usually cited as beirn between 5 and 15 percent of With these percentages in mird, it is the estimated ntrnber of evacuees. J apparent that there is significant diversity in the frame of reference sur- ' roundirg this issue. im I
r
..,~
2 h
/^ rhe guidance provided below is based on the following f actors: (1) Past
'\\-1'2)perience with evacuations regardless of the nature of the energency,
) inclusion of fear and-uncertainty f actors associated with radiolo;ical ernergencies ard (3) percentage of patential evacuees for corgreaate care fccilities cited in ASLB hearirgs.
Guidance "h
- The State ard local ra$iological energency preparedness plans n
should incitde provisions at relocation center (s) in the form of trained personnel ard equipnent to monitor a minimtrn of 20 percent of the estimated population to be evacuated.
- For highly improbable ra$iolcgical releases involvirg high levels of radiation enconpassirg a relatively large area, it may be necessary to monitor a greater runber of evacuees beyond 20 percent of the ppulati~on. In stch a situation, State and local gcuernnents w3uld be expected to develop ard implement ad hoc response measures, supplemented, if needed, by Fbderal ard private sector resources.
Any questions or concerns about this guidance should be directed to Mr. Bill Merbtt at 646-2857. l [ 4
l l' ewto ccumuojLa ucyry U$41C
'87 OCT -2 A9:25 UNITED STATES OF AMERICA HCKDikG&'dy{
4FF!CE 0' it ;i; fAk[y NUCLEAR REGULATORY COMMISSION BRANCIi BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
Public Service Co. of New Hampshire, ) Docket No. 50-443-OL et al. ) 50-444-OL
) Offsite Emergency (Seabrook Station, Units 1 & 2) ) Plannir.g Issues
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the following documents:
- 1. Index to FEMA Pre-Filed Testimony
- 2. List of Corrections to Testimony of FEMA Witnesses
- 3. FEMA Pre-Filed Testimony (With Corrections)
- 4. FEMA's Response to NECNP'S, SAPL'S, Town of Hampton's, and Commonwealth of Massachusetts' Motion for Suspension of Hearings with Respect to Contentions Involving Transportation Availability, Reception Centers, and Response Personnel Adequacy, dated September 26, 1987
- 5. Current FEMA Guidance Memoranda
- 6. Correspondence dated July 21, 1987 from Edward A. Thomas to Judge Helen Hoyt
, 7. Memorandum by Richard Krimm on the Subject of montoring of evacuees have been served on the following by Express Mail through the United States Postal Service on this 30th day of September, 1987:
a f I l . l h l l Ivan W. Smith, Esq., Chairman : Atomic Safety and Licensing Board Nuclear Regulatory Commission 1 East West Towers Building I 4350 East West Highway Bethesda, Maryland 20814 l Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board Nuclear Regulatory Commiss ion Bethesda, Maryland 20555 Gustave A. Linenberger, Jr. Administrative Judge Atomic Safety and Licensing Board Nuclear Regulatory Commission Bethesda, Maryland 20555 Docket and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Beard U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Sherwin E. Turk, Esq. Office of the Executive L67al Director U.S. Nuclear Regulatory Commission Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814 Thomas G. Dignan, Jr., Esq. Ropes & Gray 225 Franklin Street Boston, MA 02110 Stephen E. Merrill Attorney General George Dana Bisbee Office of the Attorney General 25 Capitol Street Concord NH 03301-6397
- l. s I
1 Carol S. Snieder f Assistant Attorney General j Office of the Attorney General l One Ashburton Place, 19th Floor l' Boston, MA 02108 Diane Curran, Esq. Harmon & Weiss 2001 S Street, N.W. Suite 430 i l Washington, D.C. 20009 Robert A. Backus, Esq. Backus, Meys.r & Solomon 116 Lowell Street Manchester, NH 03106 Paul McEachern, Esq. Mathew T. Brock, Esq. l Shaines & McEachern Post Office Box 360 Portsmouth, NH 03801 Edward A. Thomas i Federal Emergency Management Agency l 442 J.W. McCormack (POCH) Boston, MA 02109 Jane Doughty
. Seacoast Anti-Pollution League 5 Market Street-Portsmouth, NH 03801 Sandra Gavutis, Chairman Board of Selectmen RFD 1 Box 1154 Route 107 Kensington, NH 03827 J.P. Nadeau, Esq.
Selectmen's Representative Board of Selectmen 10 Central Road , Rye, NH03870 Dated: September 30, 1987
=_
li. gSEP LYNN '/ AssIsta GeneralMounsel Federal Emergency Management Agency
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