ML101400482
| ML101400482 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/19/2010 |
| From: | Sabo G R Ashtabula County, OH, Emergency Management Agency |
| To: | Lesar M T Rulemaking, Directives, and Editing Branch |
| References | |
| 75FR10524 00014, FEMA-REP-1, Rev 1, NRC-2010-0080, NUREG-0654 | |
| Download: ML101400482 (4) | |
Text
May, 19. 2010 7:44AM No. 3566 P 1 25 West Jefferson St Jefferson.
OH 44047 440.576.9148 Fax 440.576.9059 Fax Astbl Count Emergency~e&
Management Agn/4/TJ I FT To: Michael T. Lesar From: Ashtabula Co EMA ..iD =Fax: 301-492-3446 Pages: 4 including cover co Phone- Date. 5/19/10 Re: Docket ID NRC 2010-0080 cc;O1 Urgent x For Review 0 Please Comment 51 Please Reply 03 Please Recycle* Comments:
Michael Lesar Chief, Rulemaking and Directives Branch Division of Administrative services, Office of Administration Mail Stop. T'WB BOIM Dear Mr. Lesar Please find attached the comments from Ashtabula County EMA for the proposed revisions to NUREG 0654-FEMA-REP-1, Rev1, Supplement 3.I can be reached at via the contact information included on this cover page if there are any questions or concerns.Respectfuly George R Sabo Ashtabula Co. EMA (grsabo@co.ashtabula.oh.us)
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Ashtabula County Ohio (Perry Nuclear Power Plant county)DRAFT NUREG-0654 FEMA-REP-1, Rev.1 Supplement 3 Docket ID NRC-2010-0080 NUREG 0654 COMMENT LANG UAGE/REFERENCE General Comment In theory, a staged evacuation looks good and modeling shows that it would be more effective.
However, where is the "behavioral analysis/studies' to show people would really comply with the request? Actual emergencies show that people will spontaneously evacuate when informed of an emergency that may/will require it Example: Hurricane headed for the Outer Banks, N. C.; the Florida Keys.Section 1, Page 1 The use of calculations and computer modeling may show a The study results, documented in NUREG/CR-6953, "Review of lower dose received for the most at risk members of the NUREG-0654, Supplement 3, 'Criteria for Protective Action public, however, human nature may prove otherwise.
Need Recommendations for Severe Accidents," Volumes 1 and 2, (NRC, to show that a member of the public will actually follow the 2007a and NRC, 2008), (hereafter referred to as the PAR Study), show protective action decisions made and will "shelter in place" that shelter-in-place and staged evacuation can be more protective to or be on "heightened preparedness" instead of evacuating public health and safety than radial evacuation, providing a technical themselves.
basis for improving NRC PAR guidance.5/17/2010 Page 1 of 3 Ashtabula County Ohio (Perry Nuclear Power Plant county)DRAFT NUREG-0654 FEMA-REP-1, Rev.1 Supplement 3 Docket ID NRC-2010-0080 Section 3, Page A-6 Explanation regarding what to do with pets. Informational materials typically state that pets should be left at home or that pets are not allowed at congregate care centers. Research shows that residents are more likely to comply with an evacuation order if they can bring their pet (NRC, 2005; NRC, 2008a), thus, public information materials should not suggest that pets be left at home. Statements such as upets are not allowed at congregate care centers" do not tell residents what to do with their pets. A statement such as "Pets may be brought to congregate care centers, provided they remain in a pet carrier, in the vehicle, or outside at al times," informs the recipient that pets may evacuate with the family but restrictions may apply. The policy on pets must be discussed with the operator of the congregate care centers, as some operators do place restrictions on pets.Ensure any pet guidance aligns with existing/proposed FEMA guidance on pets. Do not duplicate.
Section 2.3, Page 7 "Heightened Preparedness" should not be called a protective Should licensees be unable to provide this assessment, the prudent action since the word action suggests 'TAKING ACTION' -action would be to implement precautionary protective actions. THE ACT OF DOING SOMETHING.
Heightened Heightened preparedness is one appropriate precaLtionary protective preparedness is planning ahead/now for AN EMERGENCY, action. not only for a radiological emergency.
Section 3.2, Page A-7 Public information does not need to go into this much detail.Public information materials should state that the evacuation will be Why would the public need to know who will staff traffic directed by local authorities who will staff traffic control points control points throughout the evacuation area?throughout the evacuation area.5/17/2010 Page 2 of 3 Ashtabula County Ohio (Perry Nuclear Power Plant county)DRAFT NUREG-0654 FEMA-REP-1, Rev.1 Supplement 3 Docket ID NRC-2010-0080 Section 3.5, Page A-9 Too much detail expected in communication to the public.-Describe how authorities expect transit-dependent residents to get to a The public has to take some responsibility for their own bus route safety/planning.
That's why public information suggests or-Discuss when the bus runs will start, taking into account that it may should that transportation dependent persons preplan for an take an hour emergency of any nature by already having identified and or longer to mobilize drivers and buses contacted a family member or neighbor that they can call-Discuss how long residents may expect to wait for pickup. for assistance Section 2.1, Page A-2 Define a "public warning message".More specifically, the following items are necessary for assembling Es it an EAS message?effective public warning messages (Mileti, 2000): EAS Messages are limited to 2 minutes due to the Encoder memory capacity.Appendix Any information more than the 2 minute EAS message wil be put out to the public through the Joint Information Center via the Public Information Officer.The excessively prescriptive guidance for messaging for the various groups (schools, special needs, transients) suggests that the general public does not have common sense. If all the suggested information for all the various groups is put out to the public in Special Information Bulletinslinformational bulletins during an emergency, a I message would never be complete.5/17/2010 Page 3 of 3