ML19352A874

Emergency Preparedness Evaluation for TMI-1

ML19352A874
Person / Time
Site:	Crane
Issue date:	05/29/1981
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML19352A873	List: ML19352A874
References
NUREG-0746, NUREG-0746-S01, NUREG-0746-S01-DRFT, NUREG-746, NUREG-746-S1, NUREG-746-S1-DRFT, NUDOCS 8106020261
Download: ML19352A874 (54)

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c EMERGENCY-PREPAREDNESS EVALUATION FOR TMI-l; SUPPLEMENT 1 BY.THE i

i DIVISION OF-EMERGENCY PREPAREDNESS.

0FFICE OF INSPECTION AND ENFORCEMENT i-r

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DOCKET NO. 50-289 L

h MAY 29,.1981.

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l TABLE OF CONTENTS Page I.

I n t ro d u c t i o n.....................................................

I-1 II. Status of Onsi te Emergency Planning Defici encies.................

11-1 II.A Noti fi cation Methods and Procedu re s.......................

II-1 II.B Pu bl ic Educa tion and Info ma ti on..........................

II-4 II.C Containment Leak Rate Assumptions Used in Emergency Dose Projections.............................................

II-6 II.D Evacua ti on Time Es tima te s.................................

II-7 II.E Thyroid Blocki ng for Onsi te Emergency Workers.............

II-9 II.F Exercises and 0 rills.....................

II-10 II.G Eme rg e ncy Ac t i o n Lev el s...................................

II-11 II.H Radiological Emergency Response Training..................

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Page II.I.

Staffing. of Licensee's Emergency Operations Facility.......

II-13 II.J Cns i te Eme rgency Orga ni za tion.............................

II-15 II.K Conclusion on Adequacy of Onsite Emergency Planning.......

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4 I II. Of fsi te Eme rge ncy Pl anning Eval uation............................

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IV.

Conclusions......................................................

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~ INTRODUCTION The Nuclear Regulatory Commission's Emergency Preparedness Evaluation for TMI-1 (NUREG-0746), issued in December 1980, provided an evaluation of the

'ompliance of the TMI-1 licensee, Metropolitan Edison Company, et al., with c

the NRC's standards for emergency preparedness plans as set forth in 10 CFR 50.47(b) and NUREG-0654/ FEMA-REP-1 (Revision 1).

NUREG-0746 indicated that Revision 2 to the TMI-1 Emergency Plan generally satisfied the requirements and criteria of 10 CFR 50.47(b) and NUREG-0654 with the exception of some specifically identified items.

Since the issuance of NUREG-0746, the Licensee submitted Revision 3 to its Emergency Plan dated January 1981.

That revised plan addressed some of the items identified by the NRC staff as being unresolved.

Additionally, Met-Ed provided additional information on several of the unresolved items in a letter to Mr. John Stolz of the Nuclear Regulatory Commission, dated April 30, 1981.

The Licensee's response to these previously unresolved items has been evaluated j

and is discussed in Part II of this report.

This supplement also contains the preliminary findings of the Federal Emergency Management Agency (FEMA), dated May 15, 1981, on the current status of offsite l

l emergency preparedness plans for the TMI environs.

These preliminary findings of FEMA on the plans were prepared and provided by FEMA in response to the NRC l

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staff's request that FEMA provide its findings and determinations on offsite emergency preparedness in accordance with Section II.4 of the NRC/ FEMA Memorandum of Understanding of November 1980.

The FEMA findings on the offsite plans and preliminary judgment appear as Part III of this report.

Part III of this report also contains a letter dated May 27, 1981, from John Dickey, Director of FEMA's Radiological Emergency Preparedness Division, summarizing in preliminary and

. general terms, FEMA's views on the adequacy of offsite emergency plans and pre-paredness for TMI-1 based on FEMA's evaluation of the current status of offsite emergency preparedness plans.

In addition to the information provided in this supplement, the NRC and FEMA will report on the results of the joint exercise scheduled for June 1981, which is designed to test both the onsite and offsite emergency plans.

FEMA has indicated that its report on the exercise will contain FEMA's conclusions on the adequacy and implementab lity of offsite emergency plans for TMI.

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II.

STATUS OF PREVIOUSLY IDENTIFIED ONSITE EMERGENCY PLANNING DEFICIENCIES II.A Notification Methods and Procedures P'rompt Alerting.

NUREG-0746 reported that in order for the TMI-1 licensee to satisfy the planning standard dealing with Notification Methods and Procedures, the means to provide prompt warning and instructions to the public within the plume exposure Emergency Planning Zone must be established'and be in conformance with Appendix 3 of NUREG-0654.

The staff further identified the licensee action necessary to cor-rect this deficiency in the February 9, 1981."NRC Staff Testimony of Stephen H.

Chesnut on Contentions Related to Onsite Emergency Planning and the Licensee's Emergency Plan" (February 9, 1981 Testimony). With regard to the early warning and notification capabilities, the following licensee action was indicated as being needed:

Provide descriptions of the early warning and notificstion system including descriptions of the methods for activating such a system, the implementation schedule, and how such a system will satisfy the acceptance criteria of Appendix 3 to NUREG-0654.

If restart is after July 1, 1981, demonstrate that the physical and administrative means exist for prompt notification.

(February 9, 1981 Testimony, p. 83).

Discussion The proposed emergency preparedness alert-notification syrtem for Three Mile Island Nuclear Generating Station is a siren system using approximately 83 sirens ic:ated throughout the plume exposure Emergency Plan'ning Zone.

In a letter to II-I p

the NRC dated March 12, 1981, the licensee indicated that the system will be j

operational by July 1981. These sirens will be radio-activated from the respec-tive County emergency operations centers which are manned on a 24-hour basis.

The licensee is supplying to those County E0Cs that need them the radio trans-mission equipment needed to activate the new sirens. The control systems will be compatible with each county's existing civil defense siren system'. The s

network of sirens is designed to provide essentially 100 percent coverage of the plume exposure pathway EPZ with an alerting signal of at least 60 dbc for areas with population densities less than 2000/sq mile, (assuming a 50 db(a) ambient noise level) and 70 dbc for areas with population densities greater than 2000/sq mile (assuming a 60 db(a) ambient noise level). The licensee also indicates that the sound levels received by any member of the public will be less than 123 dbc, the level which may cause discomfort to individuals. The assumptions for ambient noise levels and effective siren range utilized by the licensee, and as described above, are consistent with the guidance in Appendix 3 to NUREG-0654 and Figure 1 of CPG 1-17, " Outdoor. Warning Systems Guide".

In a draft of its final siren report, the li;ensee provided an acou.tical per-formance evaluation of its siren alert system using a model which considered local terrain, a range of local meteorology, and area population distributions.

Based on this evaluation, the licensee determined a sound level distribution j

which indicated that the planned locations for thi 83 sirens wuld provide an l

area-alert capable of warning essentially 100 percent of the plume exposure l

pathway EPZ population. The licensee has indicated that a final report, including the final results of laboratory siren tests and graphical and tabular sound level predictions for the siren system, will be submitted by June 1,1981.

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Based on the description and the schedule for implementation of the siren alert

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system, the staff concludes that the licensee has provided an acceptable response to this item, and that Met-Ed has made reasonable progress towards attaining an acceptable alert notification system by July 1981.

Upon the review of the final report, the FEMA and NRC staffs will determine the ultimate acceptability of the systems for alerting the population.

Contingency Procedures for Notifying Counties In NUREG-0746, we indicated that there existed an additional item with regard to Notification Methods and Procedures that remained unresolved.

Specifically, the staff sought a description in the licensee's Emergency Plan of contingenc procedures to notify the counties within the plume EPZ if PEMA fails to contact them within 15 minutes of declaration of an Alert, Site Emergency, or General Emergency.

At the time of preparation of NUREG-0746, a draft response on this matter had been provided to the staff but this was not final and was not incor-porated into the TMI-l Emergency Plan.

Subsequently, Revision 3 to the TMI-l Emergency Plan was issued.

That revision to the Emergency Plan includes a con-tingency procedure througn which Dauphin County will notify the cther risk counties for TMI in the event that PEMA fails to contact those counties.

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Since the contingency procedure for Dauphin County's notification of the other risk counties has been formaisj incorporated into the licensee's Emergency Plan, this matter has been resolved.

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s II.B Public Education and Infomation NUREG-0746 reported that the licensee's public education and infomation program was under development and, as such, in order for the TMI-1 ifcensee to satisfy

- the planning standard for Public Education and Infomation, details of the planned public infomation program should be provided. NUREG-0746 further stated that the infomation namphlets and the means of dissemination of information regarding how the public will be notified and what public actions should be in an emergency should be provided.

Discussion Since the issuance of. NUREG-0746, the licensee has provided the staff with proposed public infomation/ education pamphlets dealing with radiation and emerg-ency actions to be taken by the public in the event of an emergency. These pamphlets were prepared by PEMA and the five counties with populations in the i

plume exposure EPZ. ~ Additionally, in a letter from Met-Ed ( Mr. H. O. Hukill) to the NRC staff dated April 30, 1981, the licensee provided inforration regard-ing its commitments and future contributions to the distribution of State and county public infomation packages. The licensee agreed to provide assistance to the State and counties by paying some of the direct postage costs associated I

with the distribution of tha pamphlets and will arrange for distributior, of public education /infomation material through direct mailing to Metropolitan l

Edison and Pennsylvania Power and Light customers living within the 10 mile radius of TMI-1.

In enclosure 2A to the April 30, 1981 letter to the NRC from i

Met-Ed, the licensee indicated that it will assist PEMA and the five counties II-4 l

within the plume exposure EPZ in completing the public education program by September 1981. We believe that the licensee's efforts constitute an acceptable program but that the State and local emergency information pamphlets should be distributed to the public within the plume EPZ prior to a restart of TMI-1.

Specifically,-the information provided in the PEMA pamphlet as well as in the appropriate county' pamphlet for a specific county should be provided to resi-dents of each risk county for the TM plume EPZ.

The licensee also provided the staff as an enclosure to its April 30, 1980 letter to the NRC, a summary of public information/ education activities which are being pursued by the licensee.

These include but are not limited to:

meetings and information to aquaint officials and citizens with the siren alert system, speakers for local meetings, general radiation education seminars, and briefings on emergency responsibilities, and emergency pamphlets and tours for media per-sonnel.

These public education / relation activities go beyond the criteria of NUREG-0654 and serve to enhance the licensee's public education /information program.

As the Public Education and Information Program is a joint responsibility of the licensee and State and local governments, FEMA is reviewing the content and coordination of these programs. An evaluation of the Public Education and Information Program may be found in Section IU.G of this report.

Conclusion j

Based upon the information provided by the licensee which is summarized above, I

the staff concludes that the licensee has provided adequate information regarding i

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its commitments for assuring that its public education program, when fully implemented, will provide the public with information as'specified in Section II.G of NUREG-0654.

Accordingly, the staff concludes that the coordination ar.d commitments for providing the public with information on a periodic basis as to how they will be notified and what their initial actions should be in an emergency constitute an acceptable response to this item.

The staff also feels, however, that the State and county brochures discussed above and in Section III.G of this report should be distributed to the population fa the plume exposure EPZ prior to restart.

II.C Containment Leak Rate Assumptions Used In Emergency Dose Projections NUREG-0746 indicated that the use o. the design leak rate for all dose projec-tions involving a radioactive release from containment was unacceptable and that more realistic assumptions should be developed.

Discussion The licensee, in its submittal of April 30, 1981, provided the staff with a graph which presents estimated containment leak rates as a function of design containment leak rate, design containment pressure, and actual measured con-tainment pressure.

The estimated leak rate from the graph can then be applied to the source term to arrive at an estimated release rate for use in making offsite dose projections.

Also in the April '30, 1981 submittal, the licensee committed to factoring this relationship into Emergency Plan Implementing Pro-cedure (EPIP) 1004.7. "Offsite Dose Projections." Since the leak rates measured II-6 i

during periodic testing are typically less than design leak rates, this method may tend to over-estimate the actual leak rate: however, the licensce's procedure would provide an approximation of the upper bound of containment leak rate at a particular pressure yet a lower and more realistic leak rate than that which would result by assuming the maximum leakage resulting from design pressure.

Conclusion 4

Based on our review of the licensee's submittal as outlined and discussed above, we find that the licensee has provided a satisfactory r sponse to this item.

e II.D Evacuation Time Estimates NUREG-0746 reported the NRC staff position that the THI-1 licensee should be required to include in its emergency planning documents, time estimates for evacuations within the plume exposure EPZ which are consistent with the guid-ance of NUREG-0654, Appendix 4.

Discussion Subsequent to the issuance of NUREG-0746, the licensee submitted to the staff a study entitled " Evacuation Time Estimates for the Plume Exposure Pathway EPZ at Three Mile Island Nuclear Generating Facilities." This study provided estimates of the time to conduct an evacuation of all or portions of the plume exposure emergency planning zone during three different scenarios:

normal day-time, nighttime, and adverse weather conditions. These evacuation time estimates 1

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will be considered by the licensee in making protective acticn recommendations

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to offsite authorities.

The licensee's evacuation time estimate study utilized a computer model cons.ist-ent with NUREG-0654 guidance.

The study also provided detailed population esti-mates for permanent residents, transients, and special facility residents.

Several critical locations and potentials for traffic bottlenecks during an-evacuation were identified by the study.

This information would be useful to allow emergency planners and response personnel to determine traffic control needs or to account for the lack of traffic control et critical locations.

To aid decisit a-makers in estimating the evacuation times during an actual emergency, the study provides upper and lower bound estimates for each evacuation scenario which would allow response personnel to account for the level of mobilization or readinen for an evacuation as well as other condi-tions, such as weather or road conditions, which would affect the time required to complete an evacuation. This evacuation time estimate study was evaluated by a consultant to the NRC staff who concluded that the study conformed to the criteria of NUREG-0654.

Conclusion Based on our review and as outlined and discussed above, we find that the licensee's evacuation time estimate submittal meets the criteria and intent of NUREG-0654 and is acceptable.

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i II.E - Thyroid-Blockina 'for Onsite Emergency Workers NUREG-0746 expressed the NRC staff position that the licensee should establish provisions for stockpiling thyroid-blocking drugs for distribution to onsite emergency workers.

Discussion In a letter dated March 16, 1981 from h,'. H. D. Hukill of Met-ED. to Mr. Brian 4

Grimes of tre NRC, Meted indicated that it maintains a stockpile of potassium iodide (KI) on site and that a procedure was beir.g developed to provide guid-ance for distribution of the thyroid-blocking agent.

The procedure has been completed and has been approved by the PORC.

Conclusion The licensee's response to this item, as summarized above', is acceptable, and satisfactorily resolves this matter.

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1 II.F Exercises and Drills

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- NUREG-0746 reoorted the NRC staff position that the provisions of.the.TMI-1

' Emergency Plan dealing with tests of oommunications links with States and

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Federal response organizations within the ingestion EPZ should be changed so that such tests are conducted at least quarterly.

. Discussion Revisien 3 of the TMI-1 Emergency Plan dated January 1981 included a modifica-tion to Section 4.8.1.2.4 dealing with Communications Link Tests.

Under chis revised plan, the licensee will test the communications links with States and Federal emergency response organizations at least quarterly.

Conclusion The licensee's action in response to this item is acceptable, and satisfactorily resolves this matter.

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II.G Emergency Action levels NUREG-0746 reported that the staff had not received a formal submittal which included expanded Emergency Action Levels, used to declare each of the four emergency classifications, consistent with the example initiating conditions of Appendix 1 to NUREG-0654.

Discussion Revision 3 to the TMI-1 Emergency Plan included revised Emergency Action Levels

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which were, for the most part, consistent with Appendix 1 to NUREG-0654.

This was reported in "NRC S' aff Testimony of Stephen H. Chesnut on Contentions Relatad to Onsite Emergency Planning and the Licensee's Emergency Plan," dated February 9, 1981.

However, the staff testimony of February 9, 1981 also addressed the staff position that some of the Emergency Action Levels (EALs) for the Alert and General Emergency category were based on lower radiation or coolant activity levels than those recommended by Appendix 1.

(February 9,1981 Testimony, pp. 9, 26; Tr. 15442-47) In response to the staff-identified deficiency, Metropolitan Edison inform 26 the staff by letter, dated April 30, 1981, that the projected whole b)dy dose which would be used to triggtr the declaration of a General i

Emergency would be 1 R/hr at the TMI site boundary using actual meteorology.

This value is consistent with guidance contained in Appendix 1 of NUREG-0654.

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'With regard to coolant activity levels used to trigger cn Alert Category, the staff indicated that an EAL based on 300 microcuries per milliliter equivalent Iodine-131 should be incloded in the licensee's emergency action 1svel scheme.

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, pc/ml would trigger a Site Emergency declaration instead of an Alert. The staff position is that this EAL should be modified to be consistant with NRC guidance in Appendix 1 of NUREG-0654.

Conclusion Based on the licensee's use of revised EALs as summarized above, we conclude that the licensee has in place an Emergency Classification / Action Level scheme consistent with NRC guidance with the exception of the primary coolant iodine activity level used to declare an Alert which should be modified to be consis-tent with Appendix 1 to NUREG-0654 which provides that a coolant activity level of 300 pCi per millileter equivalent Iodine-131 should be a basis for declaring an Alert.

II.H Radiological Emergency Response Training NUREG-0746 provided the staff position that the licensee's emergency plan should describe periodic emergency training for chemistry personnel.

Discussion Revision 3 of the TMI-1 Onergency Plan provided a description of the initial and periodic emergency training which the licensee has committed to provide those chemistry personnel who fill functions in the emergency organization.

The plan calls for annual training for chemistry personnel on the TMI-1 Energency Plan and Implementing Procedures, classification of emergencies, II-12 l

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7 post-accident sampling and analyses, radiological controls, and communications in addition to the standard initial and cyclic training programs for chemistry personnel.

Conclusion 4

Based on,the licensee's response as summarized above, the Staff concludes that the licensee's plan provides adequate commitments to provide emergency training for chemistry personnel.

II.I Staffing of the Licensec's Emergency Operations Facility NUREG-0746 expressed the staff position that portions of the licensee's emergency plan dealing with the functions and staffing of the Emergency Operations Facility (E0F) would be reviewed against the criteria of P UREG-0696, Revision 1, parti-cularly with regard to the. time required to staff the EOF.

Subsequently, "NRC Staff Testimony of Stephen H. Chesnut on Contentions Related to Onsite Emergency Planning and the Licensee's Emerge,1cy Plan" of February 9,1981 indicated that the license should commit to making the EOF functional within about one hour of declaration of a Site Emergency or General Emergency by September 1,1981.

Discussion Revision 3 to the TMI-1 Emergency Plan dated January 1981, indicated that the licensee's interim Emergency Operations Facility would be fully staffed and II-13

functional within six hours rather than one hour of an emergency declaration which requires activation of the EOF and the offsite emergency organization.

Additionally, the licensee's revised plan did not commit to stationing the Emergency Support Director, the senior manager at the EOF, until six hours from an emergency declaration.

This is contrary to the criteria of both NUREG-0654, Table B-1 which calls for stationing a senior manager at the EOF within one hour of an emergency, and NUREG-0696 " Functional Crite'ria for Emergency Response Facilities," which describes the staff position that the EOF should have the capability to be fully functional within one hour.

Additionally, NUREG-0654, 8II.B.5 i:,dicates that staffing falling below the minimum staffing guidelines of Table B-1 to NUREG-0654 should, by September 1, 1981, be capable of being augmented within 30 minutes and that deficiencies should be fully removed by July 1, 1982.

Conclusion The staff position with regard to the time required to staff and make the Emergency Operations Facility functional remains as expressed in the February 9, 1981 Staff testimony; that is, the licensee should commit to staffing the Emergency Operations Facility within one hour of the declaration of any emergency classified as a Site or General Emergency.

This commitment should be implemented prior to restart.

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II.J Onsite Emergency Organization

-NUREG-0746 reported that the staff had not received a formal submittal which included identification of tnose personnel by position or title who would man the licensee's onsite and offsite' emergency organization.

Discussion Revision 3 to the licensee's emergency plan included an acceptable description of how personnel assignments will be made to fill positions in the lic2nsee's emergency organization.

Additionally the staff reviewed the procedures used by the licensee in assigning individuals to emergency functions during an onsite inspection conducted in May 1981.

The staff evaluation of the licensee's provisions for assigning individuals to positions in the emergency organization is contained in Inspection Report 81-12 dated May 26, 1981, items 50-289/80-22-56 through 50-289/80-22-59.

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. II.K Conclusion on Adequacy'of Onsite Emergency Planning Based on our review of-the TMI-1 Emergency Plan against the requirements of 10 CFR S 50 47(b), 10 CFR Part 50, Appendix E, and the criteria of'NUREG-0654, we conclude that the Three Mile Island Unit 1 Emergency Plan provides an adequate planning basis for an acceptable state of licensee's emergency preparedness.

The licensee's Emergency Plan meets the planning standards of 10 CFR S 50.47(b) and the criteria of NUREG-0654 with the exception of:

the need to modify the reactor coolant activity level used to declare an Alert to be consistent with NUREG-0654.

provisions to staff the EOF within about one hour of declaration of an emergency.

It is the Staff's view that the licensee should modify its planning to rectify these matters prior to a restart of TMI-1.

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III. OFFSITE EMERGENCY PLANNING

. At the NRC's request for findings and determinations', preliminary findings on.the State and coisnty emergency-plans were provided by the Federal Emergency

- Management Agency (FEMA). FEMA's report and preliminary judgements in this regard follow.

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lesy 27,1981 b

Mr. Brian Grimes Director. Division of hergency Preparedness

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'8iU Weekington, DC~20553 Dear Briant l

Yos wequested am suplification to my May 15, 1981 letter regarding the St*

W local plane relating to Three Mila Island. As I am sure yo4 are aware, I cannot address the level of preparedness until the plans have been reviewed in concezt with the upcoming exercise.

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As to the plans themselves, we note that extensive imptovemmets have been made whom compared to those_ plans nich existed prior to the l

@ree Mile Island accident. We find that the State plan is generally ataquate in response to the criteria established in NUREG-0654/FEHA-R$F-1, Revision 1.

'fhe county and municipal plans generally have more deficiencies which need correction as outlined in the enclosure to my

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May'IS 1stigr. At this time. I cannot judge the significance of these i

deficiencied with resord to the overall level of preparedness. Improve-ments are also needed in Scare / local coordination for public information.

We believe that the facilities identified is the plans are generally adequate, however, thera are some equipment shortfalls.

The level of accident assessment called for in the plans is acceptable. Protective j

response activities, however, need additional definition.

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In summary, we are encouraged by the level of planning rc.flected at j

the State and local Icvels and anticipare that the itene identified j

by FEMA to the State authorities requiring correction will be l

iglemented.

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Sincerely yours,

~ ~dohn E. Dickey Director, Radiological Emergency

_ Freparedness Division I

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FEDERAL EMERGENCY MANAGEMENT AGENCY Washington D.C. 20472 May 15, 1981

'Mr. Brian K. Grimes Director, Division of Emergency Preparedness U. S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Grimes:

This responds to your request of March 23, 1981, that the Federal Emergency Management Agency (FEMA) provide comments on the State and local plans and preparedness relative to Three Mile Island (THI-1) in Pennsylvania.

What follows is a preliminary judgment pending formal State submission of plans, conduct of a joint exercise and of a public meeting in accordance with 44 CFR 350.

The cuirent editions of State and county plans, as reviewed by the FEM /. Region III Regional Assistance Committee (RAC), represent a significant improvement over previous versions as covered in its December 24, 1980, Interim Report.

Intensive effort on the part of the Pennsylvania Emergency Management Agency has gone into the upgrading of State and county plans.

Specific deficiencies as keyed to the standards of NUREG-0654/ FEMA-REP-1, Revision 1 are noted in the enclosed RAC review.

We will be in a better position to comment on the adequacy of the site specific TMI-1 preparedness following the joint exercise.

Sincerely yours, r?S en aohn E. Dickey lirector, Radiolo #ca Emergency Preparedness Divisi, Population Preparedness Office Enclosure I

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.- ~ a REVIEW OF PENNSYLVANIA REP PLANNING-

' SITE-SPECIFIC TO THREE MILE ISLAND FIXED NUCLEAR FACILITY This report is based on a Regional Assistance Committee review of the latest Pennsylvania state and county plans site-specific to Three Mile Island Fixed Nuclear Facility and provides an analysis of the current status of state and local planning prior to F'EMA's formal findings in accordance with '44 CFR 350.

.The February 23, 1981 edition of Annex E " Fixed Nuclear Facility incidents" to the Commonwealth of Pennsylvania Disaster Operations Plan was reviewed.

This state plan is current, and supercedes all previous versions of Annex E.

The five risk county plans which were reviewed are those.of York, Dauphin,.

Cumberland, Lancaster, and Lebanon Counties. These plans were completed in draf t form in April,1981, and state and county plans are still in draf t status at this time.

Discussion

-The format of this report follows the planning standards of NUREG-0654/ FEMA REP 1,.Rev. 1, upon which this analysis is based. The highlights of this analysis are as follows:

A.

Assignment of Responsibility:

State plan covers state organizations well, including interf ace with counties.

Federal and private agencies-(e.g.,

Red Cross) are not mentioned in this planning standard, which is a deficiency.

County plans have planning gaps to be cet in this area; 1.e., there are still-cany procedures and details not presently incorporated bato the plans.

C.

Emergency Response Support and Resources: State and county organita-tions covered well. State plan still needs to provide more details for feder-al support requirements at state level.

D.

Emergency Classification Syste=: Both state and county plans use a standard classification and action level syste=, which is adequate.

E.

Notification Methods and Procedures: County plans do not provide for" adequate notification and warning of the public prior to the installation and functioning of the licensee's proposed siron system.

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Emergency Communications: The back-up communications role of Dauphin County for the state needs further development particularly in establishing procedures.

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Public Education and Information: Closer coordination between state and counties is needed for developing handout materials, and counties ne'ed to j

better insure availability of Laformation to transients.

H.

Emergency Facilities and Equipment:

Emergency facilities are adequate, l

emergency equipment kits are deficient in scope and quantity.

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Accident Assessment: This standard has been adequately met.

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. Protective Response: The state still needs to fully analyze and in-corporate, where appropriate,' the licensee's evacuation route and time study into its planning. Counties still need to complete unfinished municipal coordination planning.

K.

Radiological Exposure Control':

State planning needs to.be modified to allow for much greater predistribution of cosimetry equipment. County _

planning needs to be modified to allow for smergency worker decontamination monitoring closer to their work stations.

L.

Medical and Public Health Support: State and county planning is ade-t quate.

M.

Recovery and Reentry Planning and Postaccident Operations:

State and county planning is adequate.

N.

Excrcises ar.d Drills: County-plans need to develop radiological mon-itoring drills and improved communications drills.-

O.

Radiological Emergency Response Training: County plans need to include radiological monitoring training and improved emergency worker training in-general concerning dosimetry considerations. There is also a need for both state and county planning to provide for an annual retraining progra=.

P.

Development, Periodic Revic,-and DLstribution of Emergency Plans:

The state needs to update its duty officer and E]C procedures.. County plans need to identify and list supporting procedurer in much greater detail than is pre-sently evident.

The current editions of state and county plans represent a significant improve-ment over previous versions reviewed for the December 24, 1980 Interim Report.

Intensive eficat on the part af the Pennsylvania E=ergency M.:;.nagement Agency has gone into the upgrading of state and county plans.

County plans, including necessary municipal plans, however, do not reflect the degree of development and completeness found in' Annex E.

Additional effort in,

the areas of procedures and coerdination with responsible municipalities is necessary.

While important issues relative to NUREG-0654 have been identified, the plans provide an adequate planning bape for the exercising of response capabilities, i

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- I A.

1 ASSIGNMENT OF RESPONSIBILITY-i i

Planning' Standard.

i Primary responsibilities for emergency response by the nuclear facility lican-see, and by state and local organizations within-the Emergency Planning Zones have been assigned, the emergency responsibilities.of the various supporting organizations have been specifically established, and each principal response l

organization has staff to respond and to augment its initial response on a con-tinuous basis.-

State Plans-

.The February 23, 1981 State Plan-(Annex E of the DOP)~ meet's the assignment of responsibility requirements of NUREG-0634 -for state' and county organizations, from a state level perspective.

Specifically, the Governor retains overall directional authority over state emergency response ogranizations, while the Pennsylvania Emergency Management Agency (PEMA) is charged with overall res-ponsibility for the planning and coordination of state and county level res-

~

ponse' for fixed nuclear facility incidents. HPEMA's authority is derived from the Pennsylvania Emergency Management Service Act 323 of 1978.

h Regulations promulgated pursua"/ to Act 323 (Emergency Responsibilities of De -

partment and Agencies, 4. PA. Cade, Section 3.2 st. seq.'as approved April 1980) identify 20 state agencies ato departments with response and/or support roles for a' radiological emergency relative to fixed nuclear facilities; 19 of which also have state Emergency Operations Center (EOC) responsibilities. This is reflected ciearly in the state plan, and represents a-significant i=provement over pre-vious versions of Annex E.

In previous versions, Annex E referenced the much 4

broader DOP, which did not adequately define state agency concepts of operations 1

and responsibilities pertinent to fixed nuclear facility incidents.

Facility res'ponsibilities and concepts of operations are dealt with adequately in r

the state plan.

f Consricuously absent in the concept of operations and responsibilities sections of the state plan are federal agencie: (Federal Radiological, Monitoring Assistance -

Plan (FRMAP)) and private agencies, e.g., Red Cross.

[

Both groups are actually intrinsic to the state's response scheme, and as such should definitely be included in these parts of the state plan. It should be

[

noted, however, that federal and Red Cross roles are covered in other parts of i

the state plan which deal with the specific roles these groups are expected to

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t perform.

i The state plan assigns authority for directing emergency respense to the state agency heads for their respective organizations, and at the county and municipal l

levels to the respective elected officials. The Governor's and PEMA's authority l

were mentioned previously. County level government is also given sufficient

[

authority to act in behalf of PEMA, should communications be interrupted.

This last point is a significant taprovement over previous versions of Annex E.

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v The state: plan provided for 24-hour emergency response capability of all key response organizations, on both an-initial and continuing basis.. Written agreements between the state, other support organizations, and other s*.ates

' (Maryland) are included.in draft form. They are consistent with the plan's concept of oeprations, and will be acceptable once signed. The agreement be-tween the state and Red Cross is signed and acceptable. This represents a positive change from the previous version of Annex E.

County 7' $gs All five county plans adequately identified individuals in authority, by title, to take charge of emergency response. The Governor is the official responsible for the decision to evacuate; the "oun,ty Commissioners are responsible for their respective counties' decision making;.and the county emergency management coor-dinator for all response organization coordination within their respective

- counties.

However, the five risk county plans are written in such a way that they do not always provide a clear understanding of assigned responsibilicies and organiza-tion interrelationships (concept of operations) between all response organizations

' falling under. county planning jurisdiction.

All five county plans recognize assignments of responsibility at the federal, j

state, county and municipal levels, but they are presentec in a sketchy and in-consistent fashion. The only reference to the federal role in the scheme of No mention things was found in a block diagran type interrelationships chart.

at all was found of the licensee's role in ei:her the responsibilities or con-cept of operations sections. This is f elt to be a particular problem in the case of Dauphin County, due to its ur.ique role as being the parent county.

During normal operations, Dauphin County and PEMA both receive direct notifica-tion by the licensee at all four action levels. The other four counties ar'e notified directly only during a general emergency. Should comnunication channels breakdown between the licensee and PEMA, Dxuphin County will assune PEMA's notification role in relation to the other four risk counties.

Also not adequately covered in the responsibilities and concept of operations sections of all five county plans was the Red Cross. The Red Cross is responsible for operating and providing services at the mass care centers. This raises ques-tions as to the level of coordination which exists between the county governments and the responsible Red Cross chapters.

All five county plans assign significant responsibilities to the municipalities in such areas as evacuation, security, training of volunteers, reentry and in general providing for a coordinated and consistent municipal plan. However, there is no mention of municipalities in the concept of operations sections of the county plans. Furthermore, mary municipal plans are still under development and are not available to FEMA for review. Many of the municipal plans which were submitted as part of the county plans were found to be lacking in important pro-cedural details and content. There seems to have been very little progress at the county / municipal interf ace level of planning.

All five counties demonstrated 24-hour emergency re..onse capability through their communications centers and EOCs. They all have adequate legal authority to fulfill their assigned responsibilities.

III 7

= - -

1 Letters'of a g eement between the risk counties and' support organizations are

provided; bat many which are necessary are still in the process of being negotiated.

In summary, au five county plans have not shown an adequate level of planning concerning overall. assignments of responsibility and the interrelationships of h

all' emergency response organizations. It is quite possible that the levels of preparedness and response capabilities of the counties e: meeds that which is in-in the county plans.- The June 2 TMI exercise should shed more light on d'

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6 III-8 l

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C.

EMERGENCY RESPONSE SUPPORT AND RESOURCES Planning Standard Arrangements for requesting and effectively using assist-ance resources have been made, arrangements to accommodate state-and local staff at the licensee's 1-near-site Emergency Operations Facility have been made, and other organizations capable of' augmenting the planned response have been identified.

State and' County P1 ans, In general, the state has indicated in its plan the ability to man the licensee's EOF with qualified PRP liaison personnel who 'will assist BRE Headquarters to assess any radiological accident. BRP Headquarters will make the state assessment, not the licensee, unless there is insufficient time to do so; then the licensee will-provide the assessment. The state plan also provides for the NRC on-site assess-ment to be given equal weight with that of the state.

The state will'also make use of federalFR>MP capabilities in its assessnent functions, when appropriate.

The state plan has made some progress in incorpotating the federal response capa-bility into its operations planning. The BRP logistician is the state official with the responsibility of calling for federal assistance through!2 MAP at Brook-

.,_~

lawn National Laboratory. The logistician will first check with the licensee before calling on F7MJ3, so that the request will be coordinated. This is a positive change from the previous version of Annex E, where both parties seemed to function independently in calling IFJJ.

The BRP plan identifies the federal FIFRp resources expected. describes their res-pective responsibilities, and includes their expected time frames for arrival at TMI in an emergency response situation. This, too, is a positive change.

The state plan identifies the State Department of General Services with having the responsibility for providing facilities and communications support for federal response organizations. This is a positive change from the previous version of Annex E, where no specific responsibility was assigned in this area.

However, the state plan still does not give any indication of what specific facilities and communications are being planned for. This last area constitutes a deficiency,however, the federal response organizations themselves are partly to blame for this 'for not actively identifying their own needs.

The state plan clearly states that BRP will rely on its in-house laboratory capabilities as will the State Department of Agriculture for the ingestien path-way, for analysis of samples. There are no unset needs in this area; and. con-sequently no need for identifying other support organizations and their capabilities in this area.

The five county plans have relatively little applicability towards this planning standard, in that the state is responsible for assessment, radiological monitor-ing, and interfacing with federal response organizations. County plans indicate that county personnel will be made available, upon request, to assist state per-sonnel when needed. There is also a provision for the County Extension Agent to operate from the county's EOC. This is adequate, since the state has not identi-fied any unmet needs in this area.

III-9

~

, _ l

1 Unlike the state Plan, the five county plans.do rely heavily on private organi-zations, e.g., Red Cross, RACES, etc., municipal ' service personnel (some of whom are volunteers), other counties (support), and school. districts.

Some required agreements are still under development, making it difficult to determine the actual levelof resource support available in the counties.

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III-10 l

D.

EMEhCENCY CLASSIFICATION SYSTEM

~ Planning Standard A standard emergency classification and action level scheme, the bases of

. which include facility system and effluent parameters, is in use by the nuclear facility licensee, and state and local response plans call for relicace on information provided by facility li:ensees for determinations of minimum initfal offsite resp (nse measures.

State and County Plans The state and county plans have adopted a standard emergency classification and action level system consistent with one another, the licensee's plan, and Appendix 1 of NUREG-0654. This scheme is incorporated throughout the planned emergency response activities.

This represents a positive change over previous planning, where particularly the county plans were inconsistent with one another and this standard is now adequately met.

1 i

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III-11

E. ' NOTIFICATION METHODS AND PROCEDURES Planning Standard Procedures have been established for notification, by the licensee of state and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume ex-Posure pathway Emergency Planning Zone have been established.

State and County Plans Adequate initial notification procedures have been established between the licensee and the state and five risk counties. Both PEMA and the parent, i.e. Dauphin, county will be notified at all four incident classification levels. All five risk counties will be notified by PEMA at the various classi-fication levels with direct notification by the licensee at the General Emer-gency level. The state and county plans also provide for Dauphin County to assume the prinsry role of coordination with the remaining risk counties should PEMA's communications fail.

Notification of emergency response personnel vill take place, for the most through the use of telephone fan-out systens.

This is not considered a

part, deficiency as such personnel should be notified prior to any general public announcenent and thus there should not be any unusual decand on the telephone However, most key personnel at the county level can be reached by system.

alternative methods such as pagers, mobile radios and emergency services com=uti-cations. In some cases, the procedures for notifying emergency response per-sonnel at the state and municipal levels need to be expanded upon, including alternates for key personnel at the municipal level.

The present method of notifying the public calls for the use of existing siren systems, and of police and fire vehicles equipped with public address systems.

This mode is considered inadequate in that many of the municipal plans do not contain predesignated routes and delineate the resources needed to insure this can be accomplished. Along with these deficiencies, it is generally assumed that the present notification system would require greater than 15 ' minutes to notify the populace within 5 miles of the plant and 45 minutes for the entire Plume Exposure EPZ. The licensee has proposed to complete, by July 1, 1981, an enhanced outdoor warning system adequate to meet Appendix 4, N-0654 guid* -

lines utilizing the attention a72rt signal of 3 to 5 minutes steady duratiot These sirens will be supplemented 'through the use of emergency vehicles equ'ipped with public address systems, where necessary, it is reasonable to assume that adequate warning will be provided when the pro-posed system is complete. However, a complete testing of the system from a mechanical and administrative standpoint will be essential.

III-12

s s

-E.-NOTIFICATION W ODS AND PROCEDURES

- State and County Plans (cont'd)

The current emergency public information r Jsages prepared for announcement over the EBS system by the respective risk counwies are deficient only in terms of a i

lack of provision for information as to the specific nature of the problem (s) at the facility and the consequences to the public if recommended protective actions are not followed. This is expected to be accomplished on an ad hoc basis as the information is known and the need perceived during an incident.

Additional " fine-tuning" of the messages should al :o be accomplished in order to provide clearer more precise instructions to the public.

1 4

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III-13 l

L F.

EMERGENCY COMTUNICATIONS 1

Planninr~ Standard Provisions. exist for prompt communications==cng principal response organizations -

to emergency personnel and to the public.

State and County Plans The principle means of initial contact between primary response organizations and emergency personnel is by telephone. The State EOC, BRP headquarters, and the five risk county EOCs maintain a 24-hour co==unication capability. BRP and the'five countiss provide for 24-hour notification at their EOCs, while the State EOC can be operated 24-hours-a-day but is dependent upon a duty officer I

for notification. An alternative method of notifying the state is through the Dauphin County EOC (operational on a 24-hour basis). This alternative meaua has not been sufficiently developed in that procedures would have to be estab-lished to notify all state and county agencies.

Dauphin radio communications with the other risk counties needs to be for=alized.

State and county communications planned for use include emergency services networks (i.e. police, fire and ambulance networks) and other emergency sys-tems (such as teletypes and radios). These systems, utilized on a day-to-day 3

basis will be supplemented by the respective county's Radio Amateur Civil Emergency Services (RACES), which will use their own equipment. These volunteer services will serve as a backup to commercial telephone by providing alternative co==unications to schools, other counties, municipalities and mass care cer.ters.

Letters of agreement and i=plementable plans are still being sought by FEMA for inclusion in the various county plans in order to ensure agreement and coordi-nation among the parties involved.

The full-scale exercise, scheduled for June 2, should demonstrate whether or

~

not the existing syste=s meet the requirenents of Pennsylvania's Fixed' Nuclear Facility Planning.

The primary communications link between PEMA, adjacent states and federal agencies will be via commercial telephone lines and Civil Defense National Teletype System (CDNATS) and Civil Defense National Voice System (CDNAVS) which interfaces with FEMA, Region III. Backup communications will be via Civil Defense National Radio System (CDNARS), which also interfaces with FEMA, Region III.

Communication between state off-site monitoring teams and the near-site EOF are to be via radio. However, it is unclear whether this radio system is capable now of direct communication with the EOF or does it have to be relayed through BRP Headquarters over dedicated telephone to the EOF. This is an important' item to be exercised on June 2 since the BRP team captain is to be located at the EOC and capability of the communication system is critical to accident assessment.

As stated under planning Standard E, expanded procedures for notification of emergency response personnel at the state, county and municipal level need to be reviewed by FEMA. Also, the PEMA Duty Officer SOP for FN7 must be updated to include all response organizations.

Since alerting procedures were not demonstrated during the last exercise, it is crucial it be shown on June 2.

III-14

- F.

EMERGENCY COMMUNICATIONS State and County Plans (cont'd) r Both the state and the five county plans call for periodic testing of the entire emergency conusunicaticrts system and the county plans es11 for testing of the public warning system imee it is in place.

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III-15

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' G.

PUBLIC SDUCATION AND INFORMATION Planning Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the publie are established.

State and County Plans

~

Neither the current state nor the five courty pre-emergency publ.

information brochures independently provide all elemen,s of the information sought in NUREG-0654/ FEMA REP-1, element G.l.a.-d.

Thus, only if the state and county material (in the case of York County, municipal instructions as well)were distributed in a coordinated manner or the pamphlets were combined would the present brochures be adequate.

Provisions need to be made to assure that emergency information is provided to transients. Motel, hotel and park managers, as well as employers, must be made aware of their responsibility to provide the necessary information to their guests and employees.

The proposed public information programs and public education programs set out in the state and county plans are still under development. If implemented they would exceed the requirements of this planning standard.

The PEMA public information officer will be the state spokesman, under the authority of the Governor's Press Secretary. This clears up some of the confusion on this point; from the previous version of Annex E.

Both the state and counties have planned to establish points of contact with the news media for dissemination of information during an ecergency. However, the actual physical locations have not been established at this time.

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O III-16 l-

'E.

EMERGENCY FACILITIES AND EQUIPMENT

/

Planning Standard' Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

State and County Plans The lead offsite organizations, state and county levels, all have established emer-gency operations centers-(EOC). Staffing of these EOCs is projected to provide for 24-hour operations and timely notification. The emergency response staffs include representatives of the major response organizations and are to coordinate the activities of their respective organizations which may either be directed from the E0C's or from some other locations.

The lead EOC's planned for use are:

State Level: State EOC, Commonwealth and Forster Streets, Harrisburg, PA State Control Area EOC, Rt. 522 School Ent., Selinsgrove, PA Dauphin County: County EOC, Front and Market Streets, Harrisburg, PA Cumberlan'd County: County EOC, S. Hanover Street, Carlisle, PA Lancaster County: County Ecc, 50 North Duke Street, Lancaster, PA Lebanon County: County EOC, 400 South Eighth Street, Lebanon, PA York County: County EOC, East Market Street, York, PA These EOCs were developed for use by the respective level of government during emergencies t'o include nuclear attack. Each have trained staff, communications, emergency generator, fuel supply, etc. to meet FEMA's EOC criteria. The EOC's are all occupfed on a day-to-day basis by the Energency Management Staff of the State or the county they serve and at county level they are all utilized as the counties central dispatching for fire, police, and ambulance emergency services.

The EOCs and the respective emergency response staffs have been consistently activated to the level required to deal with the consequences of disaster emer-gencies and have operated for 24-hour periods over extended periods of times to include the two week period during the TNI-2 incident in 1979.

In addition to the State EOCs at Rarrisburg, which coordinates the Commonwealth's emergency response, and at Selinsgrove, which coordinates the hosting preparations, several state agencies have headquarters operation centers which either supp' ort the emergenet response team at the main ESC or direct the activities of their i

agencies coct.dinating such action through their representative at there EOCs.

Among these aeadquarters operations centers are:

Bureau of Radiation Protection / Department of Environmental Resources 14th Floor of Fulton Building, Harrisburg.

State Department of Agriculture, the Agriculture Building in Harrisburg.

III-17

H. EMERGENCY FACILITIES AND EQUIPMENT State and County Plans (cont'd)

State Police Headquarters, 1800 Elmerton Avenue, First Floor, Harrisburg.

i National-Guard Headquarters, Fort Indian Town Cap.

St' ate Dep; rtment of Health, Health, Welfare Building, darrisburg.

The Bureau of Radiation Protection has the primary role for offsite radiological monitoring for the commonwealth and shall serve both state and county level decision makers through the PEMA coordinating channels. Th'e BRP will dispatch two monitoring teams for a TMI incident and =aintains field monitoring equipment at three locations; Harrisburg, Fittsburgh, _ and Wernersville, Pennsylvania.. Three i

sets of equipment are maintained at each of these locations. BRP maintains an inventory of this equipment, inspects it and keeps it calibrated in accordance with existing requirements.

The licensee't. emergency operating facility (EOF) will receive all field moni-i toring readings and environmental sampling results generated by the state, licensee and federal agencies. BRP headquarters will be the central receiving point for state level monitoring and will interface by radio and/or dedicated telephone with the licensee EOF and the DOE FRMAP headquarters at Capital City Airport when it is established.

Activation of emergency response staffs at state and county EOCs and head-quarters operations centers are generally dependent upon telephone.. Cascading fan-out systems have been designed to enhance the timeliness of this process.

Some procedures still need to be developed and reviewed at state agency level and at municipal, government level. Notification drills of all response members should result in correcting any difficiencias to include familiarization of the procedures, maintaining currency of telephone nu=bers and increasing the pro-ficiency through training.

(See Planning Standard E).

Current inventories of radiological monitoring equipment to support emergency personnel monitoring and monitoring of public by the county level government shows there is insufficient quantities of needed equipment on hand to allow for predistribution where it is recommended and planned for. To meet the requirement for geiger counters (CDV-700) and self-reading dosimeters (CDV-730) an. adequate j

number are stored at PEMA Supply Depot in Fort Indian Town Gap. There are in-i sufficient thermoluminescence dostmeters (TLD) for permanent record dosimetry of emergency workers. PEMA is in the process of securing them.

(Sce Planning

• Standard K).

Preparedness to mobilize for a fixed nuclear facility incident at THE has not progressed to a point that emergency personnel kits for emergency workers have been established. Items that would make up such a kit are still being collected which precludes such packaging. The only respiratory protection equipment or protective clothing under present consideration,is that of the National Guard.

Current planning adequately describes quantities needed and predistribution points for KI and dosimetry. Equipment presently available is to be expediently distributed upon activation of emergency workers. Predistribution of KI, personnel dosimetry equipment, instruction on equipment, respiratory protection and pro-tective clothing should be in place at least to the operational level of the emergency workers response organizations before this standard can be considered adequately met. (See Planning Standard K).

III-18 o

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.I.

ACCIDENT ASSESSMENT Planning Standard Adequate methods, systems-and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are-

-in use.

i State Plans

=The Bureau of Radiation Protection which is within the State Department of Environmental Resourcef is specifically assigned the role,of Accident Assess-ment for the Commonwcalth of Pennsylvania. This is to include: the-interface with the-licensee and the federal agenc2es at the-Licensee's Emergency Operations Facility; providing a 24-hour headquartors ' operating center at the Fulton Build-ing in Earrisburg; liaison personnel at the state. level EOC in Harrisburg; and off-site field monitoring within the plume exposure Emergency Planning Zone.

BRP _ has two mobile two-man radiological monitoring teams with sufficient equip-vehicles and two way radio maintained in a ready to act and use status.

ment, The equipment'available and planned for use is designen to adequately measure airborne radiciodine under field conditions. Locations where readings are to be made around and in the plume exposure zone of TMI have been predesignated.

The f amiliarity of the mobile teams with the predesignated location, their ability to operate the equipment, and the radio cocmunications to 3RP headquarters operation center were adequately denonstrated during the Julyf16, 1980 exercise.

The personnel for these monitoring teams li.e in the Harrisburg area and based on the July 16, 1980 exercise, their response time appeared adequate.

The BRP monitoring team captain will operate out of the near-site EOF and share the monitoring teams reading with the licensee as well as BRP headquarters in Harris, burg. When DOE is operational in tha field, its representative at this EOF will share its findings with the licensee and BRP. A joint assess =ent will The adequacy of the communications espability be sought through these processes.

and the interf ace planned for the near-site EOF has not been demonstrated and' was not included in the July 16 exercise.

i A full scale exercise is scheduled for June 2, 1981, which will test the inter-face between the licensee and BRP exercising the capabilities and procedures in the assessment and monitoring of actual or potential offsite consequences of a radiological condition.

BRP and the licensee will coordinate on the call for assistance from DOE f[or offsite radiological monitoring assistance. Based upon communications between BRP and DOE the estimate response time, size of response team.nd general re-quirement to support the federal response team.

(See Standard C.)

(

DOE capability is planned for to provide tracking the airborne radioactive plume from the air and to operate a computer record of all known and estimated dose commitment for periodic estimation of total population exposure.

(See Standard M.)

This standard has been adequately met.

III-19 i

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PROTECTIVE RESPONSE

Plannint Standard -

A range of _ protective. actions have been developed for the plume exposure path-Guidelines for the choice.of vay'EPZ for emergency workers and the.public.

protective actions during an emergency,Leonsistent with federal guidance, are-

- developed and in place; and protective actions for the ingestion. exposure path-

.wayl EPZ appropriate to the locale have been developed.

^

State and Local Plans Sheltering, evacuation, 'and aqcess control are the protective actions planned ^

~

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- for in the IMI site-specific planning..

State Plans' In general, the state planning is adequate to show' the decision process and means to direct or recommend protective actions.. Protective actions are to be based upon' EPA Protective Action Guides (PAGs).for plume exposures and HHS/FDA Guides for food and animal feeds. Conunonwealth planning takes into account considera-tion of protective action well in advance of the PAGs.

Implementation of pro-tective action is generally a county level function with PEMA and other state agencies La coordination with PEMA providing suppert requirement.

Although the Concept of Operations and the genera" neans of providing such sup-e port are covered for the various agencies in present state planning and_the more detailed procedures,are provided 'for PEMA, the State Department of Health, j

and Agriculture and the Bureau of Radiation Protection, the expressed imple=en-ting procedures of the Department of Military Affairs, State Police and State Department of Transportation need to be reviewed to completely assess the state Other state agencies do-not support and coordination with the primary roles.

l significantly impact upon the ability of the' counties to carry out protective i

actions.

The State Department of Agriculture Plan (Appendix 7) and the BRP (Appendix 8) 1 The maps deal adequately with protective measures for the ingestion pathway.

for food, crops and dairy facilities, etc., which are necessary to support these plans will' be reviewed on-site during the June exercise.

PEHA is presently studying the Parsons Brinkerhoff Quade & Douglas, Inc. Study to incorporate in the decision process for determining the best choice of pro-tactive action. A portion of the Standard is met by the present use of th,e study by PEMA in assessing its planning and decision process.

i The location of traffic control points is being reconsidered as a result of the i'

Parsons Brinkerhoff.. Study. The present traffic control locations reflect con-siderable coordination and based on current assessment are the best locations for such traffic control points. County and municipal plans currently available provide for manning of these predetermined locations.

i Security and controlling access to evacuated areas and coordination of these functions is the responsibility of the Police Service to include State Police More detailed and Municipal Police augmented as required by the National Guard.

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III-20 l

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consideration of this matter and access control during evacuation tc fesure traffic'does not entor the EPZ during the evacuation is necessary. These Eteas

,of concern will be specifically addressed in review of the State Police and Na-tional Guard procedures.

Provision for the use of radioprotective drugs, establishing a decision process and predistribution plan has been adequately met.

A supply has not been secured.

The decision to use liquid KI is under consideration. Liquid KI would drastically affect the present planning as self administration vould not be as feasable and

)

therefore additional procedures would have to be developed and a delay in admin-

)

istering drug would have to be recognized.

Regardless of the type of KI secured, the Commonwealth has decided not to provide KI to the general public, but plans to implement protective actions such as sheltering or evacuation to protect the general public from radioactive iodine.

County Plans Each risk county plan recognizes that Accident Assessment and technical advise shall be the purview of the Bureau of Radiation Protection and that recommenda-tion and direction of protective action shall-come through PEHA channels. Risk county roles are t' implement the protective action.

Some operational maps are still under development. PEMA is producing some of these =aps for the five risk counties. The state produced area wide map is enclosed in each county plan and depicts the plume exposure EFZ and =ajor evacuation routes with their esti=ated capacity and ti=e esti=ates for those links. The counties have produced individual county =aps as part of a public infor=ation brochure to direct and control the public to reception centers or to mass care centers.

Transient population notification is expected to be accomplished by the same means as the general population. At present no system or nethod has been pre-scribed to ensure that e=ployers, park managers, hotel / motel =anagers, etc., re-cognize the responsibility to Laform their guests and employees of what they are to do when action is called for during an incident. When this deficiency is corrected and an adequate cutdoor warning system is installed and operational, notifiestion of transients will be considered adequate.

The means for protecting those persons confined in an institution has been con-sidered in each county plan and appears adequate. Regarding non-institutionally confined persons, some municipal plans have not been developed and some of those developed have not prepared a list of home bound persons who may need transporta-tion assistance within their jurisdictions. There is reasonable assurance based upon county planning and municipal plans accomplished, that this special p'opula-tion group is under careful consideration and it is only a matter of time before such lists are compiled and ready for use.

The means of relocation of the general population is addressed in the county plans.

Personal owned vehicles are assu=ed to carry the bulk of the evacuated popula-tion; school buses are to carry school children if circumstances dictate; persons without transportation are to be transported by mass transit bus service and re-turning school buses.

Institutionalized per sons in nursing hemes, hospitals, III-21

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e prisons' are to be transported by vehicles specit.cally identified for th.s e.ed, j

and: mobility impaired persons not under institutional care are to be transported by vehicles assigned by municipal fire' companies in coordination with municipal Coordination of these functions is covered at the county level.

EMA coordinator.

However implementation plans such as district and individual school plans and municipal plans are still under development, and chus require ad-hoc manage-ment at this time.

Relocation centers and mass care centers have been designated and their loca-tions are 10 miles or more beyond the plume exposure EPZ. Registration of the population using these centers will be on standard forms with the information provided to the respective county EOCs every two hours.

The means for dealing with potential impediments (e.g., seasonal impassability _

'of routes)-of evacuation routes are covered at county level by dispatchers in county EOCs who have the day-to-day responsibility to call lf or such service The counties maintain a resource manual of additional assistance for police.

resources which may be called into service when and if service assistance is not Assistance then can be sought from the Department of Transportation available.

and the Nctional Guard through coordination with PEMA. There is no specific The snow removal plan set out in the radiological emergency response planning.

Parson Brinkerhoff Study assessed additional ti=e necessary to effect evacuation for snow conditions. County assessment, in their situation reports to PEMA during an incident, would provide progress on mobilization and clearance of impedimests to evacuation routes. This infor=atien would then be taken into account la the protective action decisions.

Radiological monitoring is to be acco=plished at mass care centers following procedures provided in the county level plans *1y linemen trained as radio-logical monitors. Any discovered contamination shall be reported immediately to BRP through EMA channels. This appears adequa e when training is assured for the radiological monitors.

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~lK. : RADIOLOGICAL-EXPOSURE CONTROL;

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P1manine Standard-1Means for controlling radiological exposures, in an emergency, are established.

1 for-emergency workers. The means for controlling radiological exposure shall 2

include exposure guidelines consistent'with EPA Emergency Worker and Lifesaving Activity Protective Action Guides..

State and County Plans

'The state plan-sets the basic framework for providing a means of controlling radiological exposures. Each emergency worker is supposed to be issued two selfreading and 1 TLD. dosimeter (total of three), which from a' safety s:mnd-point sounds good. j However,. since the state plan now requires PEMA to d17-tribute thousands of dosimeters per site to affected state workers and counties, and county plans require the counties to then distribute these dosimeters (once received) to county and municipal emergency response workers, the planning is

. burdensome. The. state plan does not yet contain detailed procedures for this site-specific distribution plan; thus it -is very difficult to assess if distri-bution of all dosimeters to state and risk county personnel could be accomplished

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It could literally take l'

hours under this scheme for emergency workers to receive their dosinetry equip-nent.

County plans have desi=etry dist ibution plans for their emergency workers. Eased on inventories of on hand equip; at at county level a severe shcrtfall of such equipnent is shown cc include: CDV 742 (0-200R dosimeter), CDV 730s (0-20R

!~

dosimeter) or CDV 138. (0-200MR dosimeters) and TLDs (permanent record thermo-luminescent. Dosimeters. The state maintains.its supply of dosimeters and Geiger counter equipment in bulk storage at Fort Indiantown Gap, Pennsylvania, for emergency distribution to TMI risk county emergency workers and state emergency workers. This bulk storage is under control of PEMA which appears to have an adequate supply for the TMI planning area of CDV 742s and CDV 730s but does not l.

now have sufficient TLDs. Predistribution of these state stocked items is not

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considered because statew.'de, with other plants operating in the state, a much larger quantity of this equipment would be required. 'Regardless, FEMA feels most strongly that dosimetry equipment should be predistributed (most i

importantly TLDs and CDV 730s) to at least the emergency wurker organization level, state and local, site-specific tc each operating plant.

The counties are also reliant on PEMA for the distribution of additional CDV-700 I'

geiger counters needed for decontamination monitoring at the county level.'

This distribution problem is not considered as severe as in personnel dosimetry.

It j

is reasonable that CDV-700s can be distributed within 12-hour period, which should be sufficient.

The state /BRP expects to know if there is a possibility of contamination based on-the core inventory released long before it could be reported that members of the public have bean affected by mass care monitoring. All population leaving the area would then be directed to be screened and if such contamination were wide spread federal assistance will be sought through DOE and FEMA.

III-23

7' e.dimeframes for the reading of selfreading dosimeters by emergency w:riers, at 'least every 30 minutes, is adequate in both state and county plans.

State and county plans require that emergency workers seek replacement after.

receiving a dose of 15-20R.

It is up to elected officials in their respective jurisdictions to authorize emergency workers, if needed, to exceed the 25R PAGs for emergency workers. BRP will not recc==end this, just explain the conse-A state level decision has already apparently been made to automatic-quences.

ally permit emergency workers to exceed the general public FAGS of SR.

It is now necessary that. BRP explain to all emergency workers in advance the potential for a higher cancer risk from this decision. County plans do outline good de-cision criteria for elected officials to use in authorizing emergency workers to exceed the 25R PAG; i.e.,

for lifesaving activities, etc.

However, how or when a

the potential consequences of this will be explained to emergency workers is not provided nor are there considerutions to first solicit volunteers, or workers over 45 years of age.

State and county plans have see a level s

.05mR/hr above background as the trigger point for requiring decontamination. This is adequate.

Counties are responsible for providing decontamination monitoring services and facilities for the public and emergency workers under their jurisdiction. All five county plans provide for decontamination of the public, and emergency This is to be done at each mass care center which is to have 1 or 2 workers.

trained personnel (primarily fireman) in decontamination monitoring.. Risk counties should further modify their plans to establish separate deconta=ination points for emergency workers primarily to be located closer to the risk work areas, such as the county EOC or permit orstnizational decontamination.

Pre-assignment of trained perscanel for this fu ction should be provided in the county plans.

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MEDICAL AND PUBLIC HEALTH SUPPORT Planning Stendard

- Arrangements are made for medical services for. contaminated injured individuals.

State and County Plans The state and five county plans all contain a list or the pri: nary and support hospitals that will be relied upon to handle contaminated injured individuals The Pennsylvania DOH prepared this in the event of a radiological emergency.

list for county use.

The Pennsylvania Department of Health," Division of Energency Health Services offers a course to provide emergency medical technicians with basic instructions triage and concerning radiation and its characteristics, initial treatment, transfer of patients.

Arrangements for transportation of radiation victims has been identified.

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RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPT. RATIONS M.

Planning Standard General plans for recovery and reentry are developed.

State and County Plans The Pennsylvania Department of Environmental Resources BRP, is assigned the primary responsibility for the recommendation to relar protective measures and Included La the decision pro-the Governor retains authority to allow reentry.

cess is the assessment of radiological exposure through evaluating dose records and estimating total population exposure.

PEMA has the responsibility of notifying state agencies and counties to prepare for reentry; the governor will notify the public; and PEMA will coordinate the

.It is assumed that nor=al notification systems will be used re atry operation.

to notify emergency workers. For recovery, PEMA will coordinate supporting operations upon recommendation from DER to relax protection actions.

DER and BRP will rely on the U.S.- DOE to esti= ate total population exposure, based on information supplied to DOE by DER and other support state and federal The methodology for this assess =ent to total population exposure is agencies.

not included in the state plan; however, it 'is assu=ed that DOE does have ade-quate-methodology for providing this support.

It is The supporting require =ent for reentry are outlined in each county plan.

reasonable to assume that PEMA and the county ES.is can coordinate a reentry pro-gram through the agency and response organizational network developed -through preparation-and af fecting evacuation. Therefore, the general planning presently accomplished adequately meets this standard.

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EXERCISES AND DRILLS Planning Standari Periodic exercises are (will be) conducted :6 evaluate major portions of emer-are (will be) conducted to develop gency response capabilities, periodic drill and maintain key skills, and deficiencies identified as a result of exercises or drills are (vill be) corrected.

- State and County Plans The state plan adequately addresses the requirements for exercises and drills, This represents a positive change from the previous as specified in'NUREG-0654.

version, in that it. is made clear that PEMA i;ill ensure that all necessary planning modifications are made resulting from deficiencies uncovered by exercises and drills.

The five county plans are generally well tied in with the state plan in meeting The county plans the requirements of this planning standard, with one exception.

attempt to address the requirement for radiological monitoring drills by stating However, decontamina-that radiological monitoring is a state responsibility.

tion monitoring teams certainly fall under the purvue of radiological monitor-Therefore, these personnel ing, and these personnel come from the counties.

should be included in radiological conitoring drills when conducted by the state, their own drills when the state conducts its exercises and drills a:

or hav This deficiency =ust be rectifisd before county plans can be con-other sites.

See related ce=nant under planning standard 0, sidered adequate in this area.

regarding the training needs required in this area.

An area that requires sone clarification is the scope of the counties communica-A communications drill should de=onstrate the sufficiency of the tions drills.

At the county level, notification process down to emergency response personnel.

this involves a combination of radio contact and fairly extensive cocsarcial All these links should be routinely tested as part of telephone cascade listings.

The county plans as written imply that a properly conducted communications drill. Whatever the case may be, FEMA in-the telephone contacts will not be tested.

tends to work, through PEMA, to assure that the county plans clearly reflect It should also be pointed out that this is the only way to in-this approach.

sure that all telephone numbers and contacts re=ain current, and that the noti-fication and follow-up message contents are understood by all response parties.

m III-27

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RADIOLOGICAL EMERGENCY RESPONSE TRAINING Planning Standard' Radiological emergency response training is provided to those wha may be talled on to assist in an emergency.

State and County Plans PEMA is assigned the responsibility of coordinating Radiological Emergency Some courses will be Response training at both the state and county levels.

There is a major given by PEMA and the Pennsylvania Depart =ent of Health.

reliance on TEMA sponsored courses, with participation at all levels (state, county, w2nicipal). Many of the courses.have not yet been initiated;-however, the scope of the courses should be adequate when tsplemented.

Although plans call for retraining emergency response personnel, there is a need to ensure that this retraining be accamplished on an annual basis.

Currently, county level plans do not specificaliv include decontamination monitors in required drills (see previous co=menc under N), nor do they re-

'ference the need for training in this area. Another area that should be considered is a short course on low level radiation, dosimetry, and decontami-nation for emergency workers at local level. Some courses exist that include this;' however, because cf the size of the potential audience, this could be T

addressed separately.

fer a county oriented course to fa=111arize emergency A need is now apparent workers and decontamination :::itors with their ::les and dosimetry considerations relative to their functions.

Pennsylvania has not coordir.ated the prioritizing and registering of state and As a result, Pennsylvania county agency participants in FT}R sponsored courses.

has been slow to fill thet:t allocations and has lost some assigned spaces this fiscal year.

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'P, RESPONSIBILITY POR THE PLANNING E7 FORT: DEVEI.OPMENT, PERIODIC RT-Ek' AND DISTRIBUTION OF EMERGENCY PLANS 1

Planning Standard Responsibilities for plan development and reriev and for distribution of emergency plans are established, and planners are properly trained.

State Plans The state has adequately designated by organiz,1cion, title and responsibility The state has addressed its Radiological Emergency Response planning structure.

the training needs of its planning personnel and the method for incorporating exercise critique results into plans should be stated.

The Director of PEMA is responsible for reprcducing revisions to the State Disaster Operation Plans and distributing according to the published distribution list.

Currently, a detailed listing of supporting plans and their sources are contained in the State's plan and Appendix 18 has a listing by title of implenenting pro-This list does not appear ce=plete, and FEMA will seek SOPS

edures and SOPS.

from the eleven other State Agencies and the Red Cross in its review. However, it should be noted that the predominate respense roles are covered in the agencies procedures now shown in Annex E and/or listed in Appendix 18.

A schedule for update is not provided in the Plan and the staff duty officer procedures and the EOC operation center precaiure are not current to Annex E as revised. Planning has been very flaid up to this p: int and with the extra efforts 1

being nade to modify planning at both state and county it is recognized that such other docunents have fallen behind. Af ter the June 2nd exercise FEMA vill work with PEMA on a schedule where such supp rting plans and Annex E may be updated or co.rrected based on the lessons learned from the exercise and the recently modified plans.

County Plans County plans appear to adequately meet ' county responsibilities, but the supporting procedures for such organizations as Red Cross, State Police, USDA Extension covered for the emergency Service, school plans and nunicipal plans, are not response personnel coordinating with the county staff at county level.

Although the response individual should have such procedures, the County Plan should list them. Compatability of these procedures should be determined by the county and reviewed by FEMA.

The county EMA coordinators are responsible f-r naintaining the currency of their response plans and distributing the changes accordingly.

P00R ORIGINAL III-29

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IV. CONCLUSION Based on our review of the THI-1 Emergency Plan against the requirements of 10 CFR 50.47(b),10 CFR Part 50, Appendix E,'and the criteria of NUPEG-0654, J

" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", we conclude that the Three Mile Island Unit 1 Emergency Plan provides an ada,: sate planning basis for an acceptable state of licensee's emergency preparedness and meets the planning standards and criteria of the above-mentioned documents with the exception of the need to modify the reactor coolant activity level used to declare an Alert and crovisions to staff the licensee's Emergency Operations Facility within about ove hour.

It is the staff's position that the licensee should correct these deficiency prior to a restart of TMI-1.

With regard to the emergency preparedness plans of State and local groups, the staff notes that FEMA's preliminary findings and judgment which are based on a review by the Regional Assistance Committee (RAC), are that the offsite prepared-ness has been significantly improved since FEMA's previous report of January 1981. The FEMA document, though identifying several deficiencies in offsite emergency plans, also reports that the offsite plans provide an adeouate planning base for the exercising of response capabilities.

In a letter dated May 15, 1931, from FEMA's Mr. John E. Dickey to Mr. Brian K. Grimes of the NRC, FEMA indicated that it would be in a better position to comment on the offsite pre-caredness following the joint exercise, which is currently scheduled for June 2, 1981. Further amplification is provided by FEMA's letter of May 27, 1981 wherein FEMA indicates that, while the State plan is generally adequate, FEMA could IV-1

,e not draw definitive conclusions on the significance of deficiencies in, or the adequacy of, county plans until after the conduct of the exercise. As FEMA is the agency charged with the responsibility for evaluating the adequacy of emergency planning offsite, and since the May 15, 1981 FEffA report and May 27, 1981 FEMA general conclusions did not contain a definitive conclusion on the adequacy of the offsite planning or a discussion of the significance of those identified deficiencies, the NRC staff is unable to provide its position on the overall preparedness (including offsite preparedness) for TMI-1. As noted above, a more conclusive statement on the offsite preparedness is expected from FEMA following the upcoming joint exercise. Both the NRC and FEFA evaluations of the emergency exercise will be available within two weeks of the completion of the exercise.

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UNITED STATES OF A!! ERICA NUCLEAR REGULATORY C0l'JIISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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HETROPOLITAN EDISON COMPANY, ET AL.

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Docket No. 50-289

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(Restart)

(Three Mile Island Nuclear Station,

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Unit 1)

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CERTIFICATE OF SERVICE I hereby certify that NRC STAFF'S LETTER TO THE LICENSING BOARD TRANS-MITTING SUPPLEMENT 1 TO NUREG-0746 in the above-captioned proceeding has been served on the following by deposit in the United States nail, first in the Nuclear Requiatory class or, as indicated by an asterisk, by deposit Commission's internal nail system, this 29th day of May, 1981:

Ivan W. Smith, Esq., Chairman *(2)

Walter W. Cohen, Consumer Advocate Administrative Judge Department of Justice Atonic Safety and Licensing Board Strawberry Square, 14th Floor U.S. Nuclear Regulatory Concission Harrisburg, PA -17127 Washington, DC 20555 fir. Steven C. Sholly Dr. Walter H. Jordan Union of Concerned Scientists Adainistrative Judge 1725 I Street, N.W., Suite 601 881 W. Outer Drive Washington, DC 20006 Gak Ridge, TN 37830 lir. Thomas Gerusky Dr. Linda M. Little Bureau of Radiation Protection Administrative Judge Department of Environmental 5000 Hermitage Drive Resources Raleigh, NC 27612 P.O. Box 2063 Harrisburg, PA 17120 George F. Trowbridge, Esq.

Shaw, Pittman, Potts & Trowbridge Mr. l'arvin I. Lewis 1800 f t Street, N.W.

6504 3radford Terrace Washington, DC 20006 Philadephia, PA 19149 Karin W. Carter, Esq.

Metropolitan Edison Company 505_ Executive House ATTN:

J.G. Herbein, Vice P 0. Box 2357 President Harrisburg, PA 17120 P.O. Box 542 Reading, PA 19603 Honorable !; ark Cohen 512 E-3 i Capital Building Harrisbur, PA 17120 P00R 031GINE

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.. a John Levin, Esq.

Ms. Jane Lee PA Public Utilities Commission R.D. #3, Box 3521 Etters, PA 17319 Box 3265 Harrisburg, PA 17120 Ms. Gail P. Gradford Jordan D. Cunningham, Esq.

ANGRY 245 West Philadelphia Street Fox, Farr ar.d Cunningham 2320 North 2nd Street York, PA 17404 Harrisburg, PA 17110 Jchn E. Minnich, Chairman Dauphin Co. Board of Commissioners Ms. Louise Bradford

~ TMI ALERT Dauphin County Courthouse 1011 Green Street Front and Market Streets Harrisburg, PA 17101' Farrisburg, PA 17102 Ms. Ellyn R. Weiss Robert Q. Pollard Sheldon, Harcon & Weiss 509 Montpelier Street 1725 I Street, N.W.

Saltimore, MD 21218 Suite 506 Washington, DC 20006 Chauncey Kepford Judith H. Johnsrud Thomas J. Germine, Deputy Environmenta? Coalition on Attorney General Nuclear Power Division of Law - Room 316 433 Orlando Avenue State College, PA 16801 1100 *:aymond Boulevard Newark, N.J.

07102

!!s. Frieda Serryhill, Chairman Atomid Safety and Licensing Board Coalition for Nuclear Power Plant Pa r'el

• Postponecent U.S. Nuclear Regulatory Commission 2610 Grandon Drive Wiluington, DE 19808 Washington, DC 20555 Atomic L fety and Licensing Appeal Its. ::arjorie H. Aamodt Panel (5)*

R.D. /5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, DC 20555 Senator A?lan R. Carter, Chairman Docketing and Service Section (7)

Joint Legislative Committee on Office of the Secretary Energy U.S. Nuclear Regulatory Commission Post Of fice Box 142 Suite 513 Senate Gressette Bldg.

Washington, DC 2055S Columbia, SC 29202 i

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