ML20154H309
| ML20154H309 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/16/1988 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| 2.206, NUDOCS 8805250295 | |
| Download: ML20154H309 (6) | |
Text
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s a MAY 161988 Docket No. 50-440 The Cleveland Electric Illuminating Company ATTN: Mr. Alvin Kaplan Vice President Nuclear Group 10 Center Road Perry, OH 44081 Gentlemen:
Enclosed for your information and action are: (1) FEMA's February 26, 1988 review of the petition filed under 10 CFR 2.206 by the Concerned Citizens of Ashtabula County, Concerned Citizens of Geauga County and Concerned Citizens of Lake County, Ohio, concerning the Perry Nuclear Power Plant; and (2) the April 19, 1988 clarification of two issues in FEMA's review.
The transmittal of the February 26, 1988 review was delayed pending issuance of the clarification from FEMA.
In the interim, the petition was amended on April 8, 1988, to limit concerns only to alleged deficiencies in the revised public information contained in the 1988 calendar. The petitioners have identified five issues.
We encourage you to continue to work closely with State and local agencies as you have done in the past to resolve these issues as appropriate.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the attachment will be placed in the NRC's Public Document Room.
Sincerely, coriginal cigned by W.D. Shafor" W. D. Shafer, Chief Emeroency Preparedness and Radiological Protection Branch
Enclosures:
As stated See Attached Distribution N
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% A The Cleveland Electric Illuminating 2 MAY 161988 Company Distribution cc w/ enclosures:
F. R. Stead, Director, Perry Plant Technical Department M. D. Lyster, General Manager, Perry Plant Operations Department Ms. E. M. Buzzelli, Manager,. .
Licensing and Compliance Section DCD/DCB(RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Harold W. Kohn, Ohio EPA Terry J. Lodge, Esq.
James W. Harris, State of Ohio Robert M. Quillin, Ohio Department of Health State of Ohio, Public Utilities Commission Murray R. Edelman i
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Enclosure 1
. j C[h[\ Federal Emergency Management Agency k Washington, D.C. 20472 rn '~
FEB 2 6 1999 MEMORANDUM FOR: Fra.k J. Congel Director Division of Radiatien Protection and Emergency Preparedness Office of Nuclear Reactor Regulation V. S. Nuclear Regulatory Commission FROM: a Assistant Associate Director Office of Natural and Technological Hazards Programs
SUBJECT:
10 CFR 2.206 Petition, Public Infomation Brechure, Perry fluclear Power Plant This is in response to your November 3,1987, ecmorandum requesting assis-tance in reviewing a petition f!!cd under 10 CFR 2.206 by the Concerned Citizens of Lake County, Concerned Citizens of Geauga County, and Concerned Citizens of Ashtabula County, Ohio. The petition primarily contained a request that the Director of Nuclear Reactor Regulation order the Cleveland Electric illuminating Company (CEI) to correct certain deficiencies and i
misinformation contained in the undated Emergency Preparedness Information Handbock (ElH), and to redistribute the corrected handbook to the population within the Plume Exposure Pathway Emergency Planning Zone for the Perry Nuclear Power Plant.
f The Federal Emergency Management Agency (FEMA) Headquarters and Region V l reviewed the petition and associated materials. Our review is attached to this memorandum. The new Perry ElH entitled,1988 Calendar, Emergency Preparedness Information, dated December 1987, has also been reviewed.
! The 1988 ElH calendar was forwarded to FEMA on December 14, 1987, and has l replaced the ElH addressed in the petition. The attached review reaches l conclusions, summarized below, on the issues raised by the petition:
The 1988 EIH calendar does respond to key issues raised in the petition; therefore, FEMA does not recommend that the current ElH be immediately revised and redistributed. However, FEMA does recommend that certain i changes be considered in the next annual revision of the ElH; The review does contain a recommendation that the Nuclear Regulatory Com-mission order the CEl to work with the State and local authorities to address within 120 days the planning issues involving the role of "receiving schools" in evaluation procedures and the lack of pemanent installation of emergency information signs in Lake and Ashtabula Counties; and,
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The CEl, State, and local authorities should be commended for encouraging the reading of the EIH to blind persons; however, in the next annual ElH update these authorities may want to consider other means of providing information to the visually handicapped such as large print, braille materials, audio cassette tapes, and other audio media.
The FEMA review addresses only offsite issues in the 2.206 petition and does not address any issues FEMA believes should be reviewed by the Nuclear Regulatory Commission, in addition, the section on radiation and its health effects in the petition has been reviewed and commented on by the Environmental Protection Agency, Region V.
If you have any questions concerning this review please do not hesitate to contact me at 646-2871.
Attachment FEMA Review
FEDERAL EMERGENCY MANAGEMENT AGENCY Response to a Request for Assistance by the U. S. Nuclear Regulatory Commission to a Petition filed ender 10 CFR 2.206 from the Concerned Citizens of Ashtabula, Geauga, and Lake Counties, Ohio concerning the Emergency Preparedness Information Handbook for the Perry Nuclear Power Plant Februa ry 16, 1988
Introduction:
This review addresses issues raised in the 10 CFR 2.206 petition from the Concerned Citizens of Ashtabula, Geauga, and Lake Counties in Ohio, concerr,-
ing the Perry Nuclear Power Plant's Emergency P,aparedness Information Hand-book. The petition requests that the Nuclear Regulatory Commission (NRC),
Director of Nuclear Reactor Regulation, order the C,leveland Electric Illumi-nating Company (CEI) to correct certain deficiencies and misinformation contained in it's undated Emergency Preparedness Information Handbook (here-after referred to as ElH) and to redistribute a corrected handbook to the population living within the Plume Exposure Pathway Emergency Planning Zone (EPZ). Comments reflected below are addressed in the order that the issues are raised in the 2.206 petition. Please note that this review is based on information contained in the 1988 EIH calendar (distributed in December 1987) while the petition addresses the earlier green, undated EIH.
ElH Cover:
A two page map of the Perry ten mile EPZ is included in the 1988 ElH calendar.
This map is similar to the foldout map in the earlier "white" and "green" versions of the Perry ElH. The ten mile EPZ map in the 1988 EIH 1:. also entitled "Pick-Up Points, Referral Points and Care Centers". It shows evacuation routes, county boundaries, some geographic features, locations of some towns, etc., but it is not so detailed that it would confuse the reader. Printing the ten mile EPZ map on the cover would be impractical and redundant.
The 1988 Perry EIH Calendar does have a date printed on page one. This corrects the concern rnised in the 2.206 petition.
, i j s 2
Page 2 "
Dear Resident":
The 2.206 petition finds the entire page 2 of the green E!H "Dear Resident" objectionable. FEMA believes the rewrite of this section in the 1988 edition addresses most of the 2.206 concerns, e.g., putting a date on the ElH, read-ing the EIH to a blind friend, emphasizing that there might be danger from the radiation from the Perry Plant in the event of an emergency, as well as being able to use the ElH for other emergencies such as tornadoes or chemical spills, etc. The ElH is not printed in braille since it is recommended that the ElH be read to a blind person; however, in the next annual ElH update the utility may want to consider other means of providing information to the visually handi-capped such as large print, braille materials, audio cassette tapes and other audio media. It is not printed in Spanish due to the low number of Spanish speaking people in the vicinity of the Perry nuclear Power Plant.
FEMA appreciates why the planners of the EIH feel that the "Citizens of Ash-tabula, Geauga, and Lake Counties are protected by one of the most effective emergency preparedness plans in the natioh." The State and local emergency preparedness plans for the Perry Nuclear -Power Plant have been exercised twice. The first exercise was a full-participation exercise conducted November 28, 1984. The second exercise was a partial-participation exercise conducted on April 15, 1986. FEMA, in both exercises, found that State and local governments could implement their plans and provide information on a timely basis to protect the health and safety of the public.
The FEMA Region V report of the 1986 exercise was very positive. No deficien-cies were found at either the State or local level. One Area Requiring Correc-tive Action was identified for the State and none were identified at the local level. Several Areas Recommended for Improvement were offered to the State as well as to Ashtabula, Geauga, and Lake Counties. Federal review of the State and local site-specific plans for the Perry Nuclear Power Plant are also positive.
The 2.206 petition would like the statement that refers to the planning being "one of the most effective in the nation" deleted. This statement has been removed from the 1988 ElH calendar which should eliminate the concern expressed in the petition.
It is important to note that FEMA does not require citizen participation during nuclear power plant radiological emergency preparedness exercises, as suggested in the 2.206 petition. With the exception of public participation, full-partici-pation and partial-participation exercises have been conducted and evaluated according to Federal requirements and a second full-participation exercise is currently in the planning stages.
The word "unlikely" in the second sentence of paragraph two of the previous edition of the ElH has been removed from the 1988 ElH calendar. The rewrite of this section of the ElH should address the concern of the 2.206 petition.
3 FEMA agrees that the reference to the facility would be more specific if the facility was referred to as the "Perry Nuclear Power Plant" rather than the Perry Power Plant; however, this by itself is not seen as justifi-cation for revising and redistributing a new EIH. Previous editions and the 1988 edition of the Perry EIH refer to radiation and nuclear energy and reference.is made to the Perry Plant as a nuclear power plant in numerous sections of the 1988 EIH calendar.
The word "temporary" in the first sentence of paragraph three on page two of the previous undated EIH does not appear in the 1988 ElH calendar edition. This should eliminate the concern expressed in the petition.
The names of individuals to contact for information is not a requirement or seen as important since the people in those positions will change over time. Therefore, titles of positions rather than names should be used if individuals holding certain positions are included in the future editions of the EIH. The 1988 ElH calendar in the "Resident" section does have a December 1987, date and lists the utility and the appropriate local or State emergency management agency' to contact for further infor-mation. Telephone numbers are found on pages 4, 8, and 19 of the 1988 EIH calendar. The addresses of the appropriate local emergency management agency are found on the "Special Needs Information Card"; however, it is recommended that names of agencies / counties to contact for infomation, addresses, and telephone numbers be included together in future editions of the EIH in the "Dear Resident" section.
Page Three:
(1) Sirens:
The Perry prompt alert and notification system was evaluated by FEMA, tested on March 13, 1986, and determined to be adequate on September 8, 1986. The system is tested monthly and the results are monitored by FEMA Region V. The operability of the system is also certified annually by the State of Ohio in its "Annual Letter of Certification" provided to FEMA Region V. The design and operability of the Perry prompt alert and notification system currently meets Federal standards.
FEMA is aware of the "Report of the Emergency Evacuation Review Team on Emergency Response Plans for the Perry and Davis Besse Nuclear Power Plants" dated January 7,1987. The scientific quality of this report has been criticized in the media, by local government (Ottawa County), utility consultants and a scholar in the field of nuclear energy. Although the scientific quality of this report has been challenged, the issues raised are being addressed jointly by staff from the two nuclear facilities, the State of Ohio, and the concerned counties.
4 (2). Television and Radio Stations that operate 24-hours a day:
The 1988 EIH calendar as well as previous EIHs, does distinguish between the television and radio stations that operate on a 24-hour per day basis.
Whether or not the asterisks and the footnotes should be larger or the words "not on for 24-hours each day" should be in all caps or underlined for emphasis is an issue the authors of the EIH can consider in future revisions of the ElH. The 1988 EIH calendar is informative as written.
Residents living in the area are likely to be familiar, through daily monitoring of local television and radio stations, with those stations that operate on a 24-hour per day basis. The idea of battery powered radios, though not required in Federal guidance, is also one that can be considered by the authors of the EIH when they undertake future revisions.
(4). Relocation Sites:
The references on pages three and ten of the previous undated EIH to "go to a place at least 10 miles away from the plant" have been eliminated in the 1988 EIH calendar. This should eli.minate this concern raised in the petition. .
Page 4 "Why Do We Need Emergency Plans":
The second and third sentences in both the undated EIH and the 1988 EIH calendar are referring to U. S. Nuclear Power Plants since Federal, State, and local laws, regulations, ordinances etc., effect only nuclear power plants in the United States. The 1988 EIH calendar was modified slightly to indicate that nuclear power plants in the United States have been making electricity for almost 30 years rather than the wording in the undated EIH which stated nuclear power plants have been making electricity for over 25 years. A further revision in the 1988 EIH calendar was to state that no member of the public has been hurt as a result of an accident at a U.S. Nuclear Power Plant. The undated EIH did not include the reference to U.S. Nuclear Power Plants.
The word "but" should not necessarily be deleted from the fourth sentence of the 1988 E1H calendar simply because the 2.206 petition infers that the word changes the overall message to an implication that emergency preparedness is a "damn nuisance". Dropping the word "but" would not necessarily change the message to emergency preparedness being a good l idea. The word "but" in this context is saying it is a good idea to be prepared.
The suggestion that this portion of the EIH could be more descriptive concerning the level of radioactive material developed in the production of electricity and its possible health effects on people near the Perry Nuclear Power Plant in the event of an accident is one that can be considered by the authors of the EIH during the next annual revision.
5 Page 5 "Remember":
The "Remember" section of page 5 of the undated E!H does not appear in the 1988 ElH calendar. Therefore, the concern expressed in the petition has been addressed.
Page 6 "How Wide An Area":
The word "several" in this section of the undated EIH and in the 1988 EIH calendar refers primarily to the 10 mile EPZ. This section in the 1988 EIH calendar is revised slightly. The first sentence of paragraph two describes "the area within about 10 miles from the Perry Plant" rather than the previous undated EIH description of "the area up to 10 miles from the Perry Plant is called the Emergency Planning Zone." The other change in the 1988 ElH calendar is in the last sentence of paragraph two of this section. The 1988 version states "Xey parts of the plans are described within the following information" rather than the undated version stating "Key parts of the plans are described in this booklet."
FEMA does not believe the word "several" is incorrect or misleading.
Federal guidance has established a radius of approximately 10 miles around most commercial nuclear power plants as the primary EPZ or inhalation zone. State and local governments develop detailed plans, standard operating procedures, etc., in order to implement protective actions (e.g. shelter and/or evacuation of the public) in the event of an accident at a commercial nuclear power plant. The EPZs of some commercial nuclear power plants have been reduced, with Nuclear Regulatory Corm 1 mission approval, to 5 miles due to the smaller size of the reactor.
The Perry Nuclear Power Plant plume exposure pathway EPZ is about 10 miles. Federal planning guidance (NUREG 0654/ FEMA-REP-1, Rev.1) recog-nizes the potential for the expansion of the 10 mile EPZ, if necessary.
The revision of this section in the 1988 ElH calendar is more consistent with this concept and with Federal guidance in that the EPZ is described as an area "within about 10 miles" of the plant versus an area "up to 10 miles" from the plant, the earlier description.
The ingestion EPZ has a radius of about 50 miles. The 2.206 petition implies the word "several" on page 6 of the Perry ElH refers to the secondary EPZ (ingestion) when it in fact refers to the primary EPZ.
FEMA believes that detailed references to ingestion pathway planning, Lake Erie, and Cuyahoga County, are not necessary for the Perry EIH.
The 2.206 petition further states on page 9 "The State of Ohio also has not acted as if they felt the plans within the 10 mile EPZ are adequate let alone outside the 10 mile EPZ." FEMA Region V does not have this impression from the State of Ohio. On August 16, 1986, the Governor of Ohio wrote the Chairman of the Nuclear Regulatory Commission expressing concerns about the explosion and fire at the Chernobyl Nuclear Power Plant in Russia, the June 9,1985 accident at the Davis Besse Nuclear Power Station and the earthquake on January 31, 1986, near the Perry Nuclear Power Plant. The Governor did not state that he felt the plans were inadequate.
Instead he indicated to the Nuclear Regulatory Commission that he wanted to review the Ohio plans as a result of these events.
6 The Governor of Ohio appointed a team, chaired by the Director of Highway Safety, to conduct this review. OthEr members of this team included the Chaiman of the Public Utilities Commission of Ohio and the Adjutant General of Ohio. This team, called the "Emergency Evacuation Review Team", completed its work in January 1987, and produced a series of twelve recommendations. A working group of utility companies, counties, and State representatives was formed to address the recommendations in the Emergency Evacuation Review Team report and to develop an implementation strategy.
On November 12, 1987, the Chairman of the Public Utilities Commission of Ohio wrote Ms. Connie Kline, Lake County Concerned Citizens, regarding the 2.206 petition. This letter is enclosed as Attachment 1. In his letter to Ms. Kline, the Chairman said he urged the Nuclear Regulatory Commission to give positive review to the suggestions offered in the petition to improve the Perry ElH. He indicated the State of Ohio would stop short of endorsing in totality the remedy which the 2.206 petition seeks. How-ever, he added that he believed that the greatest success for implementing t' a recommendations of the 2.206 petition would result from the Ashtabula, Geauga, and Lake Counties Concerned Citize'ns working with representatives of the counties, the State, and the utility companies.
Additionally, the State of Ohio has not acted as if the plans within the 10 mile Perry and Davis Besse EPZs are inadequate. In several meetings with FEMA Region V, State of Ohio officials have never indicated that they believed that the planning was inadequate. The State has worked in a positive manner in revising their State plan, including, as indicated above, the recommendations of the Governor's Emergency Evacuation Review Team report. The State has worked with appropriate local governments to revise plans and procedures for the Beaver Valley, Davis Besse and Perry Nuclear Power Plants. In addition, the State of Ohio and appropriate counties have exercised their plans on a regularly scheduled basis consis-tent with Federal requirements.
The State of Ohio plan and the Columbiana County plan site specific to the Beaver Valley Nuclear Power Plant were approved by FEMA on June 5, 1987. Ashtabula, Geauga, and Lake Counties have revised their plans on a basis consistent with Federal policy and have exercised their plMs on two occasions. As indicated above the results of both exercises were that State and local government are capable of implementing their plans to protect the health and safety of the public. Planning for the third l
exercise scheduled for May 4,1988, is currently in progress.
l Page 8 "Sheltering" l
l This section of the 1988 ElH calendar has been revised to address issues raised in the 2.206 petition.
l l
l
r 7
The first point raised in this section of the 2.206 petition has been addressed in the 1988 ElH calendar. A reference to closing the fireplace damper has been added.
The second point raised in this portion of the 2.206 petition has also been addressed in the 1988 ElH calendar. The last sentence under point
- 1, page 8 of the previously undated ElH, has been removed from the 1988 EIH calendar.
The 2.206 petition expresses concern over references to people venturing outdoors once they have been told to take shelter. The petition recommends that people not venture out at all. The 1988 ElH calendar states on page 5 that people should "Go indoors and stay inside." However, it recognizes that it may be necessary to go outside to warn a friend or family member and indicates time spent outdoors should be limited. For this reason, FEMA does not agree with the 2.206 petition that a portable radio should be taken with you, if possible, so you can stay informed. The 1988 ElH calendar also states "While outdoors, cover your mouth with a cloth or towel. When returning indoors, leave your outer clothing outside. Wash your face and hands with soap and water." The language used is consistent with that recommended by NUREG-0654/ FEMA-REP 1, Rev.1 and is similar to that found in other ElH's throughout the country. The 1988 ElH calendar also addresses the concern expressed in the 2.206 petition of what to do with possibly radioactive contaminated garments before re-entering the house.
The 1988 ElH calendar, as did the previous EIH, indicates the green "WE HAVE BEEN NOTIFIED" card should be placed in a wirdow facing the street.
It further states that if you do not have the green card or have misplaced it, tie a towel to your door or mail box or other object visible from the road. The time needed to put the green card in a window is minimal and may or may not involve going outside. The time to tie a towel to the front door or even a mail box is also minimal. The green card and/or towel is a signal to emergency workers in the area which verifies whether or not the residents of the home know about the emergency, thus eliminating the time needed by these emergency workers to make this verification.
The 1988 ElH calander states that "if you D0 need assistance, DON'T use the green card."
The issue of ionizing versus non-ionizing radiation is discussed later.
Page 9: "What should 1 Do If I'm Told To Evacuate The Area?",
This section of the 1988 ElH calendar has also been revised. The reference to leaving your home as if you were going on a vacation has been eliminated.
This elimination was recommended in the 2.206 petition.
The previous undated green ElH recommendation to go some place at least 10 miles away from the plant has been modified in the 1988 ElH calendar.
8 Page 6 of the 1988 ElH calendar states that residents should leave when advised and proceed to a care center. Page 7 of the 1988 ElH calendar states residents can go to a place of their choice, e.g. a friend, relative, care center, etc. It is recommended that page 6 of the 1988 ElH calendar be revised during the next annual update to be more consistent with the statement found on page 7. This revised section in the 1988 ElH calendar states "Gather the people in your home. Do not try to pick up children or relatives in schools, hospitals, or nursing homes. Such facilities have their own evacuation procedures."
FEMA recommends a statement be added during the next annual update of the ElH to indicate that information can be obtained from hospitals and nursing homes as to where children and relatives can be picked up in the event they are evacuated from these f acilities located within the 10 mile EPZ.
Page 10 " How Much Time Would I Have?" and "Where Should 1 Go?"
The "How Much Time Would 1 Have?" sectionchas been removed from the 1988 E!H calendar. This should eliminate the 2.206 concern that the previous undated EIH gave a false sense of security. The 1988 ElH calendar also includes a revised "Where Should 1 Go?" section. The statement is elimi-nated that previously stated "You should go at least 10 miles away from the Perry Plant." The picture on page 10 of the previously undated EIH has been eliminated in the 1988 ElH calendar. This should eliminate the 2.206 concern that the previous ElH included a picture of a smiling f amily that looked like they were going on a pleasure trip to Disneyland instead of evacuating their home.
The 2.206 recommended the addition of the statement "Your safety will be enhan:ed if you study this booklet carefully, and do some advance planning of your an." The intent of this statement is included in the 1988 ElH calendar on page 1 where it states: "This information is important-please read it carefully. Discuss it with your f amily, friends and neighbors.
They may need your help, or you may need theirs. If you know someone who is blind, read this booklet to that person."
FEMA does not believe it is necessary for individuals to purchase radiation alarms or detection instruments since the utility and the State of Ohio have the ability and responsibility to measure radiation levels, and to provide public emergency infonnation and protective actions based on these measurements. The policy of the State of Ohio is to provide only emergency workers and the institutionalized population remaining in shelter with potassium iodide, a thyroid protectant medication (KI). It is not the policy of the State of Ohio to provide KI to the general public.
Therefore, the suggested language in the petition relative to obtaining K1 is inappropriate.
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b 9
Page 11 "What Should 1 Take?_" And Page 13, "* .. About Children in Schcol?"
FEMA does not believe the recomw nded text found in the 2.206 petition con-cerning what to take is necessary. The list of things to take in the previous and the current 1988 EIH calendar is a good one and the recom-mndation to add items of individual / family choices to fit their particular needs is implied on page 7 of the 1988 EIH calendar.
The previous ElH and the 1988 ElH calendar include school provisions, in-cluding guidelines and/or instructions for parents that meet the planning criteria of NUREG-0654/ FEMA-REP-1, Rev.1. General information is found on page 8 of the 1988 E!H calendar and information on specific schools is found on pages 4 and 15.
Page 14 "Livestock" Additiord text has been added to this section of the 1988 E!H calendar concerning Federal and state agencies conducting follow-up surveys of farm products to check for contamination. Ano.ther statement added is that the County Cooperative Extension Agent Service should be contacted for more information. The picture of the dog shown outdoors lapping water found in the previous undated E!H has been removed from the 1988 ElH calendar. This section does, emphasize listening to the radio or tele-vision for instructions and it further states that the farmer could be told to put livestock indoors and may be told to give them stored feed.
The changes made to this section should eliminate most of the issues raised in this portion of the 2.206 petition. The exact wording of this section or any remaining 2.206 issues can be addressed by the utility and appropriate State and local governments during the next annual revision.
Page 15 "Radiation and Nuclear Enerqy" FEMA Region V requested the Environmental Protection Agency (EPA) Region V to review this portion of the 2.206 petition since this is more in their area of expertise. The 2.206 petition asserts that page 15 of the previously undated E!H contained several trisleading stwnts re'"1.ed to the health effects of ionizing radiation. The 2.20- 'etition states the entire page needs to be rewritten. The EPA Region y reviewed the previously unaated EIH and largely concurred with the assertion of the 2.206 petition. However, EPA Region V also concluded that the previously undated ElH did not imr!inently compromise the implementation of the emergency plan. As such, EPA Region V believed the necessary modifi-
! cations of the EIH could take place within some reasonable time frame without consequence.
10 This section of the 1988 ElH calendar was slightly revised from that found in the previously undated EIH, The revisions do not change the conclusions of EPA, Region V. Their written review commerls are included as Attachment 2.
Page 16 "Nuclear Energy" Ard Page 17 "Safety" FEMA defers any coment concerning this section of the Perry ElH to the NRC. Page 17 of the 1988 ElH calendar concern 3 the design and cperation of a commercial nuclear power plant which is more appropriate for the NRC to review. Written review comments from EPA Region V concerning a portion of the text on page 17 of the 1988 E!H calendar is included in Attachment 2.
Page 18 "About American Nuclear Power Plants and Chernobyl" This section of the previously undated ElH has been eliminated in the 1988 ElH calendar. This should eliminate the 2.206 concerns regarding the design and operatien of United States commercial nuclear power plants as ccmpared to the design and operation of Rr:sian commercial nuclear pcwer plants, e.g. Chernobyl.
Pages 21-28 "Map of Pick-Up Points, And Care Centers" The 2.206 petition is concerned that the undated E!H does not include a map that shows the location of the receiving schools. In responding to this issue it should be pointed out that there is no requirement for a map of receiving schools to be included in an ElH. The 2.206 asserts that the absence of this map causes confusion if people cannot find the receiving schools on a map. The evacuating and receiving schools and their addresses were listed on a fcid out map that was separate from the previously undated ElH. This separate map also included infomatian on pick-up roints for people who need rides, Referral Points, Care Centers, Public Information, Hotline Telaphone Numbers, a checklist of things to take in the event of an evacuation, and a list of radio and television
! stations to monitor in the event of activation of the ;,rompt alert and notification system.
All of the above infomation and the map has been included in the 1988 ElH calendar. Combining this map and accompanying information into a single document and attaching the EIH to a calendar should encourage l people to retain this information. This should also eliminate the cri-l ticism of the 2.206 petition that a separate fold out map was cumbersome.
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11 The 2.206 petition further asserts that the list of receiving ::chools is tentat:'e and depends to a great extent on wnich way the wind is blowing.
The petition also asserts that the receiving schools could be changed and be different from what is listed. FEMA Region V discussions with staff at the Perry Nuclear Power Plant revealed that the list of receiving schools is not tentative. Of course, the activation of certain receiving schools is dependent upon the parameters of any accident or event, whether at the Perry Nuclear Power Plant or as a result of a natural event such as a snowstorm, tornado, flood, etc.
Information on what receiving schools are activated would be provided over the Emergency Broadcast Systc:1 (radio and television) and to the media and public through media briefings and news releases at the Joint Public Information Center once it is activated or by appropriate officials priur to activction cf the Joint Public Infonnation Center. The fact that scme of these receiving schools are only a fraction more than 10 miles from the Perry Nuclear Power Plant is a concern, however.
FEMA Region V discussions with a staf f member from the Perry Nuclear Power Plant indicated that the locations of the receiving schools were selected to allow for emergency actions outside the 10 mile plume EPZ, to minimize the time necessary to evacuate school children, and to allor for a logical flow of traffic cut of the 10 mile plume EPZ to the receiving schools so that students can be reunited with their families who would then travel to destinaticns of their own choice or to a relocation (congregate care) center, it was also pointed out that, if necessary, a light snack could be provided to the students at the receiving schools, but the planning assumed the students would be reunited with their family.
In the event the students were not reunited with their family the re-cniving school would remain opel until a specified time and then closed.
Any remaining students would then be moved to a relocation center located 5 to 10 miles beyond the boundaries of the 10 mile plume EPZ. A sign would be posted on the door telling people where the students could be located.
Based on the above information, *he use of receiving (staging) echoolt for evacuating students within the 10 mile plume EPZ is proble;natic for the following reasons: (1) The students may be subjected to radiological releases because of their proximity to the Perry Nuclear Power Plant; (2) If students are kept at receiving schools for a number of hours, then the receiving schocls are used as "de facto" evacuation centers, without benefit of radiological monitoring, congregate care, and possibly adequate sheltering; and (3) The evacuation of the students would be based on ad hoc decisions in the event an accident at the Perry Nuclear Power Plant was so severe that receiving schools near the 10 mile plume EPZ could not be used.
I .
12 The assumption underlying the evaluation criteria in Standard J (J.10.a.
- b. , c. , d. , g. , h. , J. , k. ,1. , m. , and J.12. ) i s that evacuation of persons and groups within the 10 mile piume EPZ would be essentially continuous from departure to their arrival at their destinations and/or relocation (congregate care) centers. The use of receiving schools (staging) within this context would entail evacuees being picked up quickly by their parents or in the abser.;e of being picked up by their parents, moved quickly to relocation centers. Permittino students to be retained at receiving schools located only a fraction more than 10 miles from the Perry Nuclear Power Plant for possibly hours conflicts with the intant of guidance in planning standard J.
Evalaction criteria J.10.h. reinforces the underlying intent of the guidance in NUREG-0654/ FEMA-REP-1,Rev.1. In requiring relocation centers to be located "at least 5 miles and preferably 10 miles beyond the boundaries of the plume exposure emergency planning zone", it is expected that evacuees would be transported as quickly as possible to relocation centers sufficiently far from the nuclear power plant to preclude or, at least minimize, the possibility of further exposures to radiological release and, therefore, the necessity to reevacuate people again.
Finally, the guidance is postulated on the basis that evacuation strategies would be preplanned from departure to arrival at relocation centers (or other destinations of choice) without reliance upon ad hoc decisionmaking as may be neccessitated in the Perry evacuation strategy for stelents.
At least three options are available to planners from the Perry Nuclear Power Plant, the State of Ohio, and appropriate local governments to address the FEMA concern of using receiving schools just a fraction more than 10 miles fom the Perry Nuclear Power Plant. First, the time interval at the receiving schools from arrival to departure for relocation centers be shortened to a period not to exceed 30 minutes. Second, the strategy could be changed to transporting students directly from schools within the plume EPZ to receiving schocls/ relocation centers located at least 15 miles from the Perry Nuclear Power Plant. Third, planning could call for the early dismissal of students at either the Alert or Site Area Emergency accident classification level rather than just prior to or at the General Emergency accident classification level. This, coordinated with EBS announcements, could possibly result in students being quickly picked up by their parents so that in an accident these students would not heve to be evacuated a second time. Ooviously, in a fast breaking accident this would not be a viable option.
The State of Ohio, appropriate local governments, and the Cleveland Electric il'uminating Company should be given 120 days to develop a schedulo of corrective actions to revise their evacuation plans. This schedule should include a list of milestones for irplementing the revised
b
.'- a 13 evacuation plans (strategies). These planning changes would be included in the next annual revision of the State and local plans and the Pem ElH.
Whether or not the separate fold out map of Pick-Up Points, Referral Points, and Care Centers is cumbersome is an individual opinion. One could argue that it is not cumbersome and is actually beneficial to have a map of these facilities separate from a general EIH. This map is bound in the 1988 Perry ElH calendar; however, the issue can be examined by the authors of the Perry ElH when they do their annual revisions.
"Special Needs Information Card" The 2.206 petition asserts that the "Special Needs Information Card" has a box marked "Special Transportation." The petition alleges that "Special Transportation" tends to connote specialized vehicles to accommodate the handicapped such as vans with chair lifts, etc. In the opinion of FEMA this may not be so. One could also conclude that an individual who does not drive or own a car would also fill out this card. It is obvious that the card, taken in total, is a request to have anyone who may require special help during an evacuation fill out this card and mail it to their County Emergency Management Agency, it chould be pointed out that during the November 15, 1986, Perry radiological emergency preparedness exercise, it was determined by the Federal evaluation team that offsite governments were maintaining a current. list of mobility impaired individuals and that Ashtabula, Geauga, and Lake Counties have procedures in place to evacuate these mobility impaired individuals.
"Public Educatien and Information" Appendix C of the 2.206 petition contains the results of a survey conducted by the Concerned Citizer.s of Ashtabula, Geauga, and Lake Counties during the Spring and Summer of 1987. The purpose of the survey was to determine whetner required decals are posted at hotels, motels, gasoline stations, and phone booths in order to disseminate to any transient population within the plume exposure pathway EPZ appropriate information that would be help-ful if an ecergency or accident should occur at the Perry Nuclear Power Plant.
The 2.206 petition also points out that the new telephone directory for Lake County, "Ameritech Pages Plus, 1987-88", issued August 1987, for Chesterland, Eastlake, Mentor, Painesville, Willoughby and nearby communi-ties and the White / Yellow pages, issued by Ohio Bell, contain no infor-mation on emergency planning in the event of an accident at the Perry Nuclear Power Plant. Appendix D to the petition is a copy of last year's telephone directory dich had two pages of emergency information and evacuation instructions. The petition states the it'sence of these pages in the above telephone directories violates NUFEG-0654/ FEMA-REP-1, Rev.1.
planning requirements.
14 FEMA Region V conducted telephone discussions concerning these issues with a staff member of the Perry Nuclear Power Plant on November 24, 1987. This staff member indicated that Appendix C, in his opinion, is evidence that emergency infor nation was distributed to hotels, motels, gasoline stations, etc., even though the number of locations in the survey that had this information available is small. In the opinion of this individua' the Ferry Nuclear Power Plant could not force the pr.-
prietors of these establishments to post or make available this material once it was given to the proprietors. It is the opinion of this Perry staff member that a good faith effort was made to provide this material.
FEMA Region V understands this position but still encourages officials from this Perry Nuclear Power Plant and Ashtabula, Geauga, and Lake Counties to continue efforts with these proprietors so that more of them will make this material /infomation available.
This individual further pointed out that stickers were distributed and plastic posters for transient areas such as parks, beaches, etc., were provided to Ashtabula, Geauga, and Lake Counties. It was reported that Geauga County actually installed posters 'in transient areas such as parks, beaches, etc. Ashtabula and Lake Counties have their plastic posters for transient areas but they base not been installed. Ashtabula and Lake Counties intend to install plastic posters in the transient areas at the time of an accident at the Perry Nuclear Power Plant rather than have them installed now and subjected to possible vandalism. FEMA cannot accept the Ashtabula and Lake County approach for installing public information signs at the time of an accident to avoid the potential of vandalism. Ashtabula and Lake Counties should proceed to install their posters in transient areas or develop a schedule for installation within the next 120 days. FEMA believes the information contained in these signs is too critical and should be readily available in the event there is an emergency at the Perry Nuclear Power Plant.
It was also pointed out by this staff member that officials from the Perry Nuclear Power Plant were aware of the deletions of emergency infor-mation in the above telephone directorics shortly after they were printed and distributed. Action was taken by officf als of the Perry Nuclear Power
- Plant prior to receiving this 2.206 petition. it was pointed out that this emergency infonnation material was supposed to have been printed in the telephone directories. Discussions were held between officials of the Perry Nuclear Power Plant and the appropriate telephone companies and/or printers as to why this material was not printed. Apparently no
! explanation was given except that it was an oversight.
It was reported to FEMA Region V that there is an oral agreement between the Perry Nuclear Power Plant and the printer (s) of the above telephone directories that the two pages of emergency infonnation that was intended
- to be printed in the above telephone directories will be printed and dis-
! tributed to the holders of the directories via a special mailing which will be completed in the near future.
.G ,
15 FEMA believes that once this special mailing of two (2) pages of emergency infonnation is completed this oversight will be corrected. FEMA recommends efforts be made to ensure this problem does not happen in the future.
"Summa ry" FEMA concludes that most of the issues raised in this 2.206 petition have been addressed in the recently distributed 1988 ElH calendar. In some in-stances, FEMA did not agree with certain assertions in the petition. In other instances FEMA has agreed with certain 2.206 issues but does not believe that it is necessary to immediately revise and distribute another ElH.
FEMA strongly agrees with Mr. Thomas V. Chema's assertion in his November 12, 1987, letter to Ms. Connie Kline, Lake County Concerned Citizens that "greatest success for implementing your recommendations will come by working with the utility companies, counties, and State representatives." Mr. Chema also pointed out in his letter that the State of Ohio would not join in the petitioners request for action. The above was also stated by Mr. Chema in his November 12, 1987, letter to the Director, Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission. Both letters are included as Attachment 1.
FEMA recommends that the Nuclear Regulatory Commission order the Cleveland Electric Illuminating Company to address within 120 days with the State of Ohio and local jurisdictions the issue involving the receiving schools and the issue iavolving the installation of information signs in Lake and Ashtabula Counties.
Many of the changes suggested in the 2.206 petition have been made to the 1988 ElH calendar distributed in December 1987. In addition, the 1988 ElH calendar as written does not adversely affect public health and safety and as EPA Region V concludes, does not imminently compromise the
! implementation of State and local plans site specific to the Perry Nuclear l Power Plant. Other revisions to the Perry ElH could take place within some reasonable time frame without consequence, e.g., during annual revisions.
l This review addresses only those issues in the 2.206 petition on which FEMA offered review comments and is not based on those issues FEMA believes i should be reviewed by the Nuclear Regulatory Commission. The Nuclear l Regulatory Commission in their review of these 2.206 issues should make their own conclusions on whether or not to order an immediate revision and redistribution of the Perry EIH.
t Attachment 1 l Letter from State of Ohio, Public Utilities Commission to Ms. Connie Kline Letter from State of Ohio, Public Utilities Commission to NRC Attachment 2 Letter from EPA to FEMA
C o I
ATTACHMENT 1
srcs.c3 Ts 15:59 res Recw4 V CHICMO 1 P.02 4
STATE OF OHIO PUBLIC UTILITIES COMMISSION OECgf., ,9 ?
180 EAST BROAD STREET f.*/ggy18 COLUMBUS, OHIO 43266-0573 P// g l alca g c g sT November 12, 1987 Ms. Connie Kline Lake County Concerned Citizens 38531 Dodd's Landing Drive Willoughby Hills, OH 44094
Dear Ms. Kline:
As The Governor has referred your 2.206 filing and cover letter to me.
you may be aware, the Governor has asked that I assume responsibility for nuclear power issues for him. My first direct involvement in nuclear safety issues came about when he asked me to be a member of the Cabinet Level Emergency Evacuation Review Team to review our nuclear disaster preparedness planning. The EERT work produced a series of twelve recommendations on ways to improve the nuclear disaster preparedness planning process for the Perry These recommendations covered a wide and Davis-Besse Nuclear Power Plants. An EERT range of planning issues including public education and information.
working group of utility companies, county, and state representatives was formed to develop agreements on the resolution to the EERT recommendations and how to implement them. '
Most recently, at Governor Richard F. Celeste's request, I have established a Citizens Advisory Council to provide recommendations to state, local, and utility officials on ways to further enhance the safety of the public from the potentially adverse ef fects of nuclear power plants.
Althou3 nuclear power plant safety, is by law under the jurisdiction of the Nuclear Regulatory Agency, the Public Utilities Commission can play a We can work to ensure significant role both nationally, as well as locally.that the NRC has effe nuclear power plant operations safe for the citizens of Ohio.
Locally, we can, in combination with greater oversight of NRC inspection programs, and through focused review of utility company management policies, practices, and organization, develop additional ways to leverage utility company management accountability, as well as NRC inspection and the review programs to assure the most robust nuclear safety program possible.
It is with this background that I wish to respond to your letter of
.' September 21, 1987 to the Governor and the attached 2.206 filing.
I reviewed your 2.206 filing and find that there are indeed a goed number a quality, of constructive improvements suggested that will benefit the tone and substance of the Emergency Preparedness Information Handbook published by the Cleveland Electric Illuminating Company.
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Hs. Kline November 12. 1987 Page As I have expressed to those in the business of safety planning, prepared-ness, or maintenance--there is no perfect emergency plan, as there is no risk-f ree enterprise or human activity. Planning for a disaster is only a useful and prudent activity if the plans are tested, ano the plans are reviewed and improved. If we accept a plan without periodically testing the assumptions upon which it was built, and exercise and evaluate its constituent parts, then in reality we don't have a plan, just the pote.'itial for one.
Without passing judgmen on the merits of each of the indivioual recommendations that Concerned Citizens make in their 2.206 filing, I think that it would be in the best interest of the citizens of Ohio for the State to send a letter of support for your pet; tion to the Director of the Of fice of Nuclear Reactor Regulation of the United States Nuclear Regulatory Cor. mission.
The support fer your petition will be prnmised on the one hand by the generally meritorious qualities of the recommendations made, and on the other by supporting a program of review, redesign and distribution based on the existing consensus building opportunities we have with groups such as the Emergency Evacuation Review Team working group, and the Citizens Advisory Council for nuclear safety.
I will urge the NRC to give positive review to the suggestions for improvement of the brochure which you make, but we will stop short of endorsing the totailty or snu remeof which you seek, rwether, I hsend se request that the EERT working group and the Citizen's Advisory Council on Nuclear Safe'.y both review your recommended changes and determine if they 'can have positive impact in improving public information and safety. I think that greatest success for implementing your recommendations will come by working with the utility ompanies, counties, and state representatives who have the clear mandate to create a continually improving, living breathing, emergency evacuation plan.
Thank you for your great interest in contributing to the enhancement of public safety in Ohio. The hard work and thought you have put into the 2.206 doc.Jment is evident in the quality and care taken in the substance of your reccmcendations. I am pleased to join with you in your efforts to improve the quality of a nucitar power plant emergency preparedness, cerely g M%
dhomas V. Chenta Chairman AG:bl cc: Governor Richard F. Celeste Xen Cole, Adjutant General's Of fice, Disaster Services Division Andy Grandjean, Chief. Nuclear & Gas Pipeline Safety Division, Consumer Services Department
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180 EAST BROAD STREET -/1 s" , Q .
COLUMBUS. CHIO 43266-0573 o g h0 h.ye.
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e t Dr. Thous Nriey Director grfice of Nuclear Reactor Regulation l United States Nuclear RegulalOry Comission 1717 N Street. N.W.
Washington, oc 20655 ,
i Ric Ocetat Nos.60-440 and 50-441 :
Dear Dr. Nrleyt i am writin to you In the Metter of the Cleveland Electric Illuutnating -
Cosonny, et 41.g(Perry Nuclear Power plant) Docket hos. 60440 aM 80441; Request for Action Under C.F.R. 2.206 filed by Petitioners Concerned Citizens of Lake. 444uga. and Ashtabula Counties of.0hio.
On behalf of the State of Ohio, the undersigned has reviewed the Petitioners' filing and has found that many of the recommendations contained in the filing are meritorious and provide an opportunity to enhance the quality of the Cleveland tiedtric Illuminating Coopany's Emergency Presared8ess Ififormation handbook.
While at this time we do not forsally join in the Petitioners' request for action, we did want to make it known to you that we believe that e. enhancement of the EmerstNy P_reparedness Indermathn handbook would be in ths bett interett of the 5tste of Onto ans our ctrtens wiD live near the Perry h4164r Power i Plant, We strongly encourage your thorough review of the recommendations made by the Concerned Citizens and we tre anxious to participate with you in improving the information provided to cittreet of northeastern Ohio. , ,
! In this regard, within the last year the severnor of Ohie establfshed an l Eurgency tvecVation Revtew Teen composed of three can1Mt members who see
.:hsrged with a review of the emerlenty evetuation plans for the nuc', car pp,ge plants in Ohio. In J6nvary 1987, the EERT produced a report that a6de a brosoly Naching series of tweivi recomiendatient en ways to improve our omrgency preparedness in the evnt of a nuclear power plant disaster, One of those recommendations went to thu issue of public education, the subject of the instant petition, The roccasumdetions by EEP.T have been generally accepted by all of the participants in esortancy planning sad a series of agreements have been reached for the implementation of the itRT Coneittee's recommendations, <
In additica, to provida for treater pub)ic porticipation, the Chairman of the Public Utilities Casseisstes of Ohio, at the request of the Governer, estatiished a Citizen's Adytter Council to advise the state goverreent on etters relating to the public h'ealth and safety of Ohipsnt that Ny be affected ky the potential hazardi af netlear power p) ants.
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gr. 'kr1ey Nov1mber 12,1987 Page t*
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it is *W intention to bring the subject of the Concerned Citizens petition before both the working group charged with implementing the EERT recomumendation
, and the Citizen's 4visory Council with the request that both of these groups seek to find methods to implement the rt:omendettone which the Concerned Citizens have suggested. In our opinion, improving putlig education concerning appropriate mthods of avoiding injury from nuclear power )lant hazards is so ongoing responsibility, we losk forward to working with tw Nuclear Regulatory Comission to try to esvelop reasontble courses of action to enhance public education and minimize risks.
Thank you for your consideration.
y trul yours, qQ.Chema.W omat V /
Chairman l
TVCibi ec: Governor Richard F. Calente Ken Cole. Mjutant kneral's Office Disetter services Division Connie Klino, Lake Cour.ty Concerned Citizens Murray Edlesan Vice President, Nuclear of Centerier G
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j UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 g
4 134 SOUTH DEARBORN ST, CHICAGO, ILLINOIS 60604
- m ro m mumow er 9 3 XC N5 Nr. Den Bement Federal Emergency Management Agency Natural and Technological Hazards Division 175 West Jackson, 4th Floor Chicago, Illinois 60604
Dear Mr. Bement:
In response to your request of November 23, 1987, the Radiation Program staff of the United States Environmertal Protection Agency (USEPA) Region V Office offer the following comments relating to three statements of radiological significance from the Rtquest for Action Under 10 CFR 2.206 for the Perry Nuclear Power Plant:
On pages 1415 of the Request the assertion is made that page 15 of Perry's booklet entitled "Emergency Preparedness Information" contains several misleading statements related to the health effects of ionizing radiation, and should be rewritcen. We largely concur with these assertions. On page 15 of the booklet examples of nonionizing radiation are casually associated with tonizing radiation in a way in which a lay reader could I be led to believe that they have identical health significance. Also, the notion is put forward that low exposures to ionizing radiation (background levels) are "normal", while high exposures "may be harmful to human
, hemith". This could easily be misinterpreted as stating that low exposures are safe. This misinterpretation may be carried further by the statement:
! "But to be safe, the law requires that people are not exposed to too much radiation", when the only numerical example of too much radiation put
- forth is 25,000 millirem (mrem). We feel that this section of the booklet l
does picture need to be rewritten of current radiation so as to convey protection to the lay philosophy (public i.e. a more linear, non- accurate threshold health effects model, principle of keeping exposure es low as reasonably achievable, known health effects of ionizing radiatten, etc.)
However, we feel that the lack of rigor in the current version of the i booklet will not inninently compromise the implementation of the emergency pl a n . As such, we believe that the necessary modifications of this booklet
- could take place within some reasonable time frame without consequence.
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On page 14 of the request, exception is taken to the statement on page 15 of the Emergency Preparedness booklet: "By law, a nuclear power plant may not ex;Jse the public to more than five millirems per year. The Perry plant will give you a dcse of one or two millf rems per year." We believe that the license should furnish the reference for this statement, as our own research into the legal limit for operation has not yielded a consistent answer. The USEPA environmental standard for nuclear fuel cycle facilities is 25 mrem /yr to the general public (40 CFR 190.10), but this is a limit from all nuclear fuel cycle operations (i.e., from both reactors in the case of the Perry station). The Nuclear Regulatory Commission (NRC) imposes an objective on the design of a nuclear power plant that it be built to limit population exposures to between five and ten millirems per ycar due to gaseous releases, however, this design objective is assioned specifically to each plant during its sitting and 1icensing. (10 CFR 50, Appendix I, Paragraphs B1 and B2)
Finally, on page 15 of the request the assertion is made that "CEI plans to recommend evacuation only to prevent projected public exposures which will exceed ... within six hours, the. annual limit of 5000 millirems for nuclear plant workers." (USEPA Region V staff would like to obtain the reference for this statement.) " And any exposure already received during the emergency, without limit, is ignored. This is al', owed by EPA 520/1-75-001, which has never been Justified. It was supposed to be justified by Appendix C, to be published later."
It is unfortunately true that Appendix C of EPA 520/1-75-001, "Hanual of Protective Action Guides and Protective Actions for Nuclear Incidents",
is still unpublished in final form, although a draf t form of Appendix C does exist. The criticism of this fact is justified, and will be communicated to the appropriate USEPA staff. However, the bulk of the criticism in this paragraph appears to be directed at an improper and i
inflexible interpretation of the Protective Action Guide (PAG), presented l in EPA 520/1-75-001 which applies to the general public for the purpose of r
' avoiding unnecessary exposure from a passing plume. Moreover, the criticism is directed solely at the utility, when in fact, State and local responce agencies carry the primary responsibility for using the PAG to recommend and implement protective measures such as sheltering and evacuation. A detailed understanding of the PAG may help to clear up this issue.
The PAG for the general population / plume exposure from which the Stata and local agencies draw guidance applies to actual or projected exposures to the g1neral population commencing at the beginning of the accident. It does not cover population exposures occuring before the beginning of the accident which are limited to between 5-25 millirem per year by environ-cental standards and design objectives. The PAG is expressed as a range 1
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of real or projected exposures over which the need for protective actions shculd be considered. The PAG is expressed as a range, rather than a single valut, in order to give the states flexibility in their accident response. The purpose of the PAG is to guide decisions about protective actions so that they may be implemented before the exposures 3ctually occur, i.e., while the exposures are still only projected to occur. This is consistent with the philosophy of keeping exposures as low as reasonably achievable, and at the same time, allows local constrairts such as ease and economic impact of evacuation to be taken into accour.t by response anencies.
The range of projected population exposures over which this PAG applies is 1000 to 5000 millirem. The PAG recornmends that evacuation be considered when projections reach 1000 mrem (although evacuation could be recommended at lower projections depe.iding on local and plant conditions) and that evacuation be recomended when projections reach 5000 mrem or higher.
It is thus, untrue that EPA 520/1-75-001 allows unlimited population exposure and, if it is borne in mind that the State response agency has the primary 7
responsibility for deciding to recommend protective actions, then it follows that the criticism of the utility in this matter is largely misdirected.
Please contact us if we can be of further assistance in this matter.
l Sincerely yours.
l keve Rothblatt, Chief l Air and Radiation Branch (SAR-26)
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Enclosure 2 40 Fede'ral Emergency Management Agency
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Washington, D.C. 20472 APR I 91988 fiDDRATITU1 FDR: J. Philip Stohr Acting Director Division of Radiation Protection and Ehergency Preparedness Office of Nuclear Reactor Regulation II.S.11uclear Regulatory Ccrnission W
FR')ll: . c and . Krim Assistant Associate Director Office of flatural and Technological Haztrds Programs SUIVECT: Clarification of Two Issues in the Federal Fnergency thnagenent Agency's (PDM) Response to the Perry 41 clear Power Plant 2.205 Petition
'Ihe purpose c# this nenorandtn is to clarify FE'iA's position regarding two issues addressed in our response to the Perry ?!uclear Power Plant 2.?06 petition on the Ehergency Infomation Handbook. 'Ihe first issue involves the receiving schools and evacuation procedures involving school children.
'Ihe second issue involves tt e placment of instructional signs in Lake and Ashtabula Counties.
It is PStA's position that the existing school evacuation planning procedures involving the receiving schools should be reviewed to consider alternative plenning approaches, as outlined in our Febntary 26, 1988, response to the
!!uclear Regulatory Ccrnission (1TRC). In our view these approaches should be considered for incorporation in the next revision of the offsite plans for Perry. In our Fbbruary 26, 1988, review we were trying to emphasize that we believe this issue is important enough to warrant having all affected parties, the State af Chio, the local jurisdictions, and the Cleveland Electric Illini-nating Gmpany, revisit this issue within the next four months with a goal of eithe; arriving at a schedule for implementing plan changes or adopting a po':ition on the issue.
Regarding the p)acement of energency infomation signs, FDtA does not concur with the current approach of storing the signs in Lake and Ashtabula Counties because of the potential for vandn11m. 'Ihe difficulty of installing then at the time of an accident overrides the storage approach. Our position remains that the signs should be installed within the next four months or a schedule should be provided for their installation, w
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Enclosure 3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .
Before the Director, Office of Nuclear Reactor Regulation In the Matter of )
)
THE CLEVELAND ELECTRIC ILLUMINATING )
COMPANY, ET AL. ) Docket Nos. 50-440/441
) 2.206 Petition (Perry Nuclear Power plant, Units 1 )
and 2) )
)
. CONCERNED CITIZENS' REPLY TO RESPONSE OF THE CLEVELAND ELECTRIC ILLUMINATING COMPANY TO THE PETITION ON THE EMERGENCY INFORMATION HANDBOOK This reply addresses the March 9, 1988 response of the Cleveland Electric Illuminating Company to the 2.206 petition filed by the Concerned Citizens of Lake County, Concerned Citizens of Ashtabula County, and Concerned Citizens of Geauga County on September 22, 1987 regarding the emergency information handbook for the Perry Nuclear Power Plant.
i While not explicitly conceding the validity of Concerned Citizens' petition, CEI nevertheless took corrective action in
.- revising the handbook that, by CEI's own admission, has "mooted" many of the petition's complaints. Concerned Citizens finds that, in' substantial part, the relief requested in the petition has been granted by CEI's revision contained in the 1988 calendar. Indeed, the the word "mooted" throughout CEI's response could easily be read as "validated" or "affirmed".
Accordingly, Concerned Citizens herein focuses attention on the portions of the 1988 calendar which remain objectionable, and requests that the Director issue a decision on only these matters. A ruling on all other matters is unnecessary,.as the
o O O 1988 calendar has rectified the major deficiencies in the October 1986 handbook.
- 1. It is not clear that the 1988 calendar has been distributed to businesses within the plume EPZ. This is important, as persons who live outside the EPZ but work within the EPZ are without information on emergency planning in the event of an accident at Perry. Similarly, the page on emergency planning which was distributed by Ohio Bell to remedy the omission of that page from the phone book (see CEI Response at 63) may not have been delivered to businesses. Also, the page did not have any instructions or explanation that it should be placed in the phone book; thus, it is likely that recipients did not put the page in the intended location, if they kept it at all.
- 2. CEI's Response (p. 45) erroneously asserts that the receiving schools are firmly established. The fact is that, in an emergency, the receiving schools may have to be changed if they are in the path of the plume. This is conceded by the ,
affidavit of Daniel Hulbert, p' 9, where he states that, if an expansion of the evacuated area were necessary while the schools were in use, the children would be relocated. The handbook should emphasize that parents should listen to the EBS broadcasts to confirm the location of the receiving schools before going to pick up children, because the schools are subject to change depending on wind direction. Without this caution, parents are likely to proceed to the schools listed in the handbook, unnecessarily risking exposure to the plume and 4
creating heavy traffic on roads needed for evacuation of residents.
- 3. Page'16 of the 1988 calendar remains objectionable. It fails to distinguish between ionizing and nonionizing radiation in claiming that "people cannot see, taste, feel, hear, or smell radiation" but then including "heat, light, and radio waves" as examples of radiation. According to this passage, we should not be able to see light or feel heat. This explanation is erroneous and tends to undermine the credibility of the handbook. (Compare the quote from Consumers Power Co. (Big Rock Point Plant), LBP-82-60, 16 NRC 540, 554 (1982) included at p.
11 of CEI's Response.) The problem can be easily corrected by using the word "radiation" to mean ionizing radiation throughout the discussion on p. 16 of the calendar under "Sources of Radiation", and changing that section as fo11cws:
(a) First paragraph: Delete third sentence. In the second sentence, change the word "energy" to "radiation". (b) Fourth paragraph delete the last sentence.
The section then remains readable and no longer contains false information.
The discussion under the section "Dangerous Levels" falsely asserts that doses of radiation less than 25 rems are harmless.
Thi's is contradicted by government documents; for example, Report of the Interagency Task Force on the Health Effects of Ionizing Radiation, Departme'nt of Health, Education, and We,1 fare, June 1979: "Doses in the 0.2 to 20 rem range appear to
e ^ o e
increase the risk of childhood cancer." (p. 32). See also Environmental Protection Agency, A Citizen's Guide to Radon, OPA-86-004, August 1986: "Scientists estimate that from about 5000 te about 20,000 lung cancer deaths a year in the United States may be attributed to radon."
The section on "Dangerous Levels" shetid be rewritten as follows:
"You should avoid unnecessary exposure to radiation. Large amounts of radiation, 100,000 millirems or more, received in a short period of time, can cause radiation sickness and death.
Smaller doses increase the risk of cancer and birth defects.
Many scientists feel any amount of radiation has a risk."
- 4. The special needs information card should be postage paid l and pre-addressed. If persons must expend too much effort or a incur any expense the card is not likely to be returned. An i
easy solution for addressing the cards would be to include peel-off stickers, one for each county EMA so the person can choose the appropriate county EMA address.
- 5. The information about the Three Mile Island accident on page 17 of the calendar tends to create complacency about nuclear accidents, thereby undermining the message and purpose l
of the handbook, as explained in our Petitio.n. In addition, L
there is controversy about the health effects of the TMI accident. To state that the THI radiation releases are not a l
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hazard to the public is inconsistent with the views of many scientists that there is no safe dose of radiation. The material under the heading "Safety" in the calendar should be removed.
Respectfully submitted, Connie Kline 38531 Dodds Landing Drive
, Willoughby Hills, OH 44094 (216) 946-9012 DATED: I, /k k
,Ib CERTIFICATE OF SERVICE This is to certify that the above has been sent to the following by U.S. Mail, first class, postage prepaid:
Dr. Thomas Murlcy, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Jay Silberg, Esq.
Shaw, Pittman, Potts, and Trowbridge 2300 N Street, NW Washington, DC 20037 Mr. Robert A. Meck Emergency Prephredness Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. William G. Snell U.S. Nuclear Regulatory Commission Region III 799-Roosevelt Rd.
Glen Ellyn, IL 60137 Ms. Margaret Lawless FEMA 500 C St. SW Washington, DC 20472
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Mr. Dan Bement FEMA
. Region V 175 West Jackson, 4th Floor Chicago, IL 60604 l l
Docketing and Service Section l Office of the Secretary U.S. Nuclear Regulatory Commission Washington,.DC 20555 Mr. Andrew Grandjean Division of Nuclear and Gas Pipeline Safety '
Public Utilities Commission of Ohio 180 East Broad Street Columbus, OH 43266-0573 n
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