ML20003G383

Evaluation of Nc Site-Specific Radiological Emergency Response Plan for Plant Mcguire. Related Documentation Encl

ML20003G383
Person / Time
Site:	Mcguire, McGuire
Issue date:	03/18/1981
From:	Pope H Federal Emergency Management Agency
To:
Shared Package
ML20003G379	List: ML20003G383
References
NUDOCS 8104290268
Download: ML20003G383 (41)

Text

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a'I EVALUATION OF TEE.

4 NORIE CAROLINA SI*E-SPECIFIC RADIOLOGICAL 4

EMERGENCY RESPONSE PLAN 1

FOR PLANT MCGUIRE

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HARRIS M. POPE i

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IN R0tCCTION Gcverner Ja=es Eus has sub=1::ed the Ncrth Carclina Site-Specific Radio-logical E=ergency Respcase Plan in supper: ef Plant McGuire fer FD'a review and approval. ~he plan was ce=pleted in :he Autu== cf 1980, and is dated Neve=ber 1, 1980. The plan ::::ains six =ajor parts: (1) The 5:a:e Plan, and (2) Five ceunty plans which include the ecusties of Ca:avba, Gasten, Iredell, Lincc1= and Mecklenburg. In addi: ice, as SCP fer the State E=er-gency Respcase Tea = is p cvided al ng with a 'supperting docu=entatica package shich includes the felieving ite=s:

e Execu:ive Su==ary e Quick reference hand boek for local gover==en: cfficials.

e E=ergency 3rcadcas: Sys e: (IIS) Plan f=r the Charle::e, N. C. E35 Operatic al Area.

e lessen plan used :c teach 3asic Radia:ie: E=ergency Preparedness in supper: of Nuc12ar ?cuered Electric Generating Plants.

e E=ergency ~ fer=atic: 3rechure dis::ibuted :c :he Public within a

=ile radius cf :he McGuire Nuclea: 5:a ics.

e Recrea:ic" ' _ap of the Lake Ner=a: area which shews locaricus a:

which per:anent curside signs centaining warni=g ins::uctiens fer vacatieners c and about Lake Nc:_a have been its:alled.

e Ccpies cf le :ers of agree =en: frc= Radic1cgical Labera: cries that vill provide supper: during Radiclogical E=ergencies.

e N. C. State IOC 50?

3c:h the S: ate pla: and each cous:7 plan have tables of ces:ents and cress ref e:ences :0 NUEEG 0634/FD'A-RE?-1.

FEEA 7.agic IV staff me=bers have reviewed the North Care m a si:e-specific plan for Plan: McGuire and assisted the Radiclegical Assis:ance Cc:cittee (EAC) in a detailed reviev to deter =ine whether the plan meets the requirements set ferth in NUEIG 0654/FD'A-EI?-l Rev.1. 1: the ecliective judge =e : cf the RAC,

he North Carolina size-specific plan far Plan: McGuire =ee:s the requirements se fer:h in 5:220 0651. vi:h the excep:1:n =f warning and :::ifica:100 which does ne: have to be in place until July, 1981.

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North Carolina of ficials and FD!A Region IV staff held a public =eeting on Dece=ber 4, 1980 for the purpose of providing =e=bers of the public an opportunity to:

e Ask questions about the FEMA review process e Provide input and suggesticas for i= prove =ents or changes to the plan, and e Gain knowledge concerning how the plan is expected to functica in the even: of a real e=ergency.

A de: ailed description of the public =eeting which includes the public notice and a recording of the proceedings of the =eeting is provided as Attach =ent 1, and is =ade a par: of this evaluation.

A ce=prehensive exercise el the McGuire site specific plan was conducted en Dece=ber 5-6, 1980, which included par:1cipants fro: all pri=ary State response organications/ agencies, local govern =ents, the 1.icensee (Duke power), and appro-priate federal agencies. '"he exercise was observed by =e bers of the RAC, FEMA Regien IV and Regiwn VI staff as well as by official 5: ate observers frc= North Carclina and South Carolina. A detailed critique of the exercise was held en Dece=ber 6, 1980.

Exercise =a:erials including the scenario are provided in A::ach=en: 2. hese caterials are ade a part of this evaluation package.

I: is noted that officials frc= the 5:a:e of Scuch Carolina were present in the Forward EOC during the exercise (i.e. , the end and control pcim ' for coordi-nation purposes in the even of required protective ac:icus in the 40 mile inges:icn expcsure pathway. Thus, proper coordina:icn was achieved with South Carolina for those coun:1es in South Carolina which are in the 50 =ile I?Z.

Observations and deficiencies noted by the RAC during the exercise are provided in A::ach=en: 3 aleng with North Carolina's response :o the noted deficiencies.

I: nay be observed that responses to the exercise observations and reco==enda-tiens previde dates and ti=es when those acted deficiencies will be corrected if corrections are no: cesady =ade. A::ach=en 3 is =ade a part of this evaluation package.

This evalua:icn repor lists each planning standard in the crder tha: they appear in W REG 0654/ FEMA-REP-1 Rev. 1 followed by a su==ary of appropriate porticus of the plan as they apply to both State and local off-site radiological planning and preparedness. The final section of this evaluation report provides a sunznary of =y overall evaluatien of the North Carolina Site-Specific plan for Plan:

McGuire with so=e closing ec=ments. A de: ailed file is available in the FD!A Region IV Regional Office for review regarding the evaluation of the North Carolian Site-Specific Radiological E=ergency Respense Plan fer Plant McGuire.

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4 j NORTE CAROLINA SC-S?ICITIC RADIOLOGICAL f

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EMERGENCY RESPONSI PIAN ,

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FOR PLANT E dI ,.

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HARRIS M. POPE ,

ACTING REGIONAL DIRECTOR FDfA REGION IV 4

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INTRODUCTION Governor James Hunt has submitted the North Carolina Sita-Specific Radio-logical Emergency Response Plan in support of Plant McGuire for FEMA review and approval. The plan was completed in the Autu::n of 1980, and is dated

' November 1, 1980. The plan contains six major par:s: (1) The State Plan, and (2) Five county plans which include the counties of Catawba, Gaston, Iredell, Lincoln and Mecklenburg. In addition, an SOP for the State Emer-gency Response Team is provided along with a supporting docu:nentation package which includes the following items:

e Executive Summary e Quick reference hand book for local government officials.

e Emergency Broadcast Systa= (E35) Plan for :he Charlotte, N. C. E3S Operational Area.

e Lesson plan used to teach Basic Radiation Emergency ?reparedness in support of Nuclear Powered Electric Generating Plants.

e Emergency Infer:ation 3rochure dis:ributed to the Public within a mile radius of the McGuire Nuclear Station.

e Recreational map of the Lake Norman area which shows locations at which permanent outside signs containing warning instructions for vacationers on and about Lake Norman have been installed.

e Copies of letters of agreement from Radiological Laboratories that will provide support during Radiological E=ergencies.

e N. C. State EOC SOP Bo:h the State plan and each county plan have tables of centents and cross references to NL~dEG 0654/ FEMA-REP"-1.

FEMA Region IV staff members have reviewed the North Carolina site-specific plan for Plant McGuire and assisted the Radiolegical Assistance Cors=ictee (RAC) in a detailed review to deter =ine t.h ther the plan meets the requirements set forth in NURIG 0654/ FEMA-RE?-l Rev. 1. In the collective judgement of the RAC, the North Carolina site-specific plan for Plant McGuire meets the requirements set forth in NUREG 0654 with the exception af warning and notification which does not have to be in place until July, 1981.

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North Carolina officials and FDM Regica IV st:ff held a public meeu.::g on Wee.mber 4,1980 fer the purpose of pre-riding members of the public an cpportunity to:

e Ask ques:1cus abou: the FDM review process e Provide input and suggestions for i=provements or changes to the plan, and e Gain kncvledge concerning how the plan is expected to function in the event of a real emergency.

A detailed description of the public meeting, which includes the public artice and a recording of the proceedings of the meeting is provided as Attachment 1, and is =ade a part of this evaluati:n.

A cc=prehensive exercise of the McGuire s:.3e specific plan was cceducted on Dece=ber 5-6, 1980, which included par:1cipants frc= all pri=ary Sta:e response c ganizaticas/ agencies, local governments, the Licensee (Duke ?cwer), and appro-priate federal agencies. The exercise was observed by me=bers of the ?.AC, FE%

Regien IV and Reg.on VI staff as well as by efficial State observery from North Carolina and South Carolina. A detailed critique of the exercise was held en Dece=ber 6, 1980.

Exercise =aterials including the scenario are provided in Attachmen: 1. These na:erials are made a part of this evaluation package.

I: is noted that officials from the State of South Carolina were present in the Fc vard EOC during the exercise (i.e., the ec:r.and and control point) for coordi-nation purposes in the event of required protective actions in Qe SC =11e ingestion exposure pathway. Thus, proper coordinatien was achieved with South ,

Carolina for : hose coun:les in South Carolina which are in the 50 =ile EPZ. V Observa: ices and deficiencies noted by the RAC during the exercise are provided in A :ach=en 3 along with North Carolina's respense to the noted deficiencies.

1: nay be observed : hat respenses to the exercise cbservations and recc=menda-tiens provide dates and rims when those noted deficiencies will be corrected if corrections are not alraady =ade. A :ach=en: 3 is =ade a part of this evalua:ica package.

This evaluation report lists each planning s:andard in the order that they appear in NT.T.EG 0654/FD%-rep-l Rev.1 follcwed by a su==ary of appropriate portiens of the plan as they apply to bo:h State and local off-site radiological planning and preparedness. The final section of this evaluation report provides a su ary of =v overall evaluation of the Scrth Carolina Site-Specific plan for Plan:

McGuire with so=e elesing ec=m nts. A detailed file is available in the FDM Regien IV Regional Office for review regarding the evaluation of the North Carolian Site-Specific Radiclogical I=ergency Response Plan for Plant McGuire.

EVALUATION A. Assignment of Responsibility (Organization Control)

Planning Standard Primary responsibilities for emergency response by the nuclear facility licensee and by state and local organizations within the Emergency Plan-ning Zones have been assigned. The emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staffed to respond to augment its initial response on a continuous basis.

Emergency Plan 4

The North Carolina Emergency Response Plan in support of McGuire Nuclear Powered Electric Generating Plant was developed to meet their require-ments as well as the planning standards found in NUREG 0654/ FEMA REP.1.

The operations area, as provided for in the plan covers five (5) Counties in the ten-mile Plume Exposure Pathway and an additional fif teen (15)

Counties in the fifty-mile ingestion Exposure Pathway. There are an additional four (4) Counties in South Carolina that are in the fif ty-mile EPZ. The North Carolina Plan addresses only the McGuire facility.

A separate plan has been prepared for the Brunswick f acility and is not addressed in this plan. The State has developed the overall plan for McGuire and incorporated the actions of the five county Governments into the overall State plan making one plan for the McGuire facility.

The concept of operations, as stated in the plan, is "the responsibility for directing ar d conducting Emergency Operations in the area of the Plume Exposure Pathway of the EPZ rests jointly with local and State Government.

Emergency actions required during approximately the first six hours (after notification of an accident) to protect the people in the affected area are the rescensibilitv of the Local Governments concerned."

The Depart =ent of Crime Control and Public Safety is the element of State Government charged with the recponsibility for emergency operations con-ducted by the State. The Assistant Secretary for Public Safety is the individual charged wich planning, organizing, directing, and supervising emergency operations conducted by the State. The Assistant Secretary for Public Safety has designated, a staff of specialists to assist him in I carrying out these duties. This staff is organized into a " State Emergency Response Team" (SERT). The SERT leader is the Assistant Secretary for Public Safety.

The time required, following notification, to assemble the SERT, move to the affected area, and establish an operating field Command Post is esti-mated to be six hours. Hence the assignment of responsibility to local Govern =ent for the first six hours.

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The Plan further provides that when the SERT is established, to the satisfaction of the Assistant Secretary for Public Safety, at the l

Command Post, the State will assume responsibility for directing State agency participation in emergency operations and coordinating actions involving both State and Local Agencies. When a state of disaster /

emergency is declared by the Governor, the State assumes responsibility i

for directing and conducting emergenev operations.

During the exercise conducted on December 5-6, 1980, it was observed that there seems to be much confusion when the State assumed control from the counties due to lack of proper communication between State and County. The written report on the exercise recommended that procedures i

should be developed which eliminate this confusien.

i The State is principally responsible for directing and conducting emer-

, gency operations in the area of the ingestion Exposure ?auway.

Emergency responsibilities and functions required for proper response are assigned to the appropriate State or Local Government Agency.

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3. On-Site Emergency Organiration planning Standard On-shif t facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the inter-faces among various on-site response activities and off-site support and 4 response activities are specified.

Emergency Plan The State of North Carolina has worked closely with the facility operator (Duke Power Company) during the development of on-site and off-site plans which ensure that State and Local organizations will be kept appraised of concitiens at the plant. The procedures, notification, and communications

.to effectively implement the plan were tested during the exercise.

j C. Emergency Response Support and Resources planning Standard Arrangements for requesting and effectively using assistance resources have been =ade, that arrangements to accommodate State and local staff at i the licensees near-site Emergency Operations Facility have been made, and

) other organizations capable of augmenting the planned response have been

identified.

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Emergency Plan Section III of the State Plan addresses emergency support and resourcas.

Types of Federal assistance that can be made available are listed. The Assistant Secretary for Public Safety, Dept. of Crime Control and Public Safety is designated as the person authorized to request services'and-assistance. Listed among other sources of assistance is the Southern Mutual Radiation Assistance Plan (SMRAF) and technical staff personnel from Universities and private industry in accordance w1th letters of agreement.

A State representative is designated in this .1ection to assume that resources are comitted in a manner that will promote maximum efficiency and effectiveness. This representative will serve at the Duke Power Company " Crisis Management Center".

Radiological laboratories available to support State assessment are listed along with their estimated response times and description of their capa-bility.

D. Emergency 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 reliance on information provided by facility licensees for determinations of =inimum initial off-site response measures.

Emergency Plan Emepgency classifications adopted by the State of North Carolina are in accordance with the requirements set forth in NUREG 0610. The emergency classification system provided in the Plan (Page 45) are consistent with that established by the Duke Power Co=pany. The four classes of emergencies are:

Notification of an Unusual Event

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Site Emergency

) General Emergency The Plan contains the rationale and actions to be taken for each emergency classification as well as exa=ples of emergency action levels for each classification.

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6 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 follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruc-tion to the populace within the Plume Exposure Pathway Emergency Planning Zone have been established.

Emergency Plan The State plan provides that the initial notification of anyone of the four classes of an Emergency action level (unusual event, alert, site e=ergency, general emergency) is trans=1::ed from the McGuire Nuclear Station Control room to the State warning point and to the warning points in the counties of Catawba, Gaston, Iredell, Lincoln and Mecklenburg.

Telephone is uded as the primary means of transmitting the notification with voice radio used as back-up means. The plan provides two methods of authentication. The Plan outlines procedures for notification, alerting and =obilizing emergency response personnel in the five (5) counties in the 10-mile EPZ. A separa:e procedure is provided for notification, alerting and mobilizing State E=ergency Response Personnel. Actions to be taken by the radiation protection section person receiving the call as well as the Department of Crime and Public Safety are also included.

A syste= is established and. procedures developed to disse =inate informa-tion concerning emergency conditions, instructions to be followed and protective actions to be taken by people throughout the area within about a 10-nile radius of the McGuire Nuclear Station. The system and procedures and time required to complete this task are described in detail in Annex A.

Messages containing instrue: ions concerning specific protective actions such as the appropriate aspects of sheltering, thyroid blocking and evacua-iton intended to be trans=itted to the public are contained in Annex 3.

Annex A listes planned notification co=pletion times as shown below:

0-5 =iles - 100ll of population - notified within 45 minutes 5-10 =iles - 100:: of population - notified within 75 minutes During the Exercise in Dece=ber there were several observations, with subsequen: recommendations made, if adop:ed, will strengthen the notifi-cation capability.

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7 F. Emergency Com::ranication Planning Standard Provisions exist for prompt ec==unications among principal response organizations to emergency personnel and to the public.

E=ergency Plan Section VI provides for comz:n:nication networks to support all emergency response organizations throughout the course of an emergency. The net-works are formed using cornercial telephone service. Luke Power Company Radio Systems, Local Government Emergency Service two way radio systems and State and Federal Government Communications. To assure that an imme-diste level of alert and notification readiness is available, the Plan

ates that systems are ter=inated in certain emergency response facilities that are manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Several means of cc

x::unications are listed to provide emergency com=unientions to contiguous Sta:es. Provisions for co==unications with field assessment tea =s are provided for. Periodic test of communications is also provided for in this section.Section VI also provides syste=s & procedures for co==unications to the public to include the Emergency Broadcas System.

The emergency communications were exercised adequately during the Exercise on December 5-6, 1980. The Exercise surfaced several com=unication deft-ciencies which can be corrected generally with the installation of addi-tional te*.< phones in Emergency Operations centers.

G. Public Education and Information Planning Standard Infor=ation 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 =edia for disse +ation of infor-

=ation during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated disse =ination of infor=ation to the public are established.

Emergenev Plan Section VII of(the State Plan provides two types of pu'blic infor=ation, concerning the use of Nuclear Energy to operate electric power generating plants. The first type is " Educational" in nature in that it acquaints the public within the emergency planning zones regarding the effects of the accidental release of radioactivity to the environment. The second type of information includes instructions and directions concerning safety

=easures to be taken by the public should an emergency conditica develop.

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The Plan provides for :he Assis: ant Secretary, Department of Cri=e Centrol and Public Safety to represent :he State 1: =a::ers dealing with the release of e:nergency public infomatica.

The Plan provides coordina:ing ins: uctices for release of public infer-

=ation and designates :he public infor=arien officer assigned to the State E=ergency Response Team as responsible for everall coc dina:1cn of public infor=atics activities between Sta:e and local Gover==ents and Duke ?cver Co:npany.

~he Plan provides for :vo principal points-of-ec :act available :o =edia personnel for obtaining current infor=atics on an e=ergency condition or situation. These are the Dub Power Cc=pany Media Center and :he staff E=erge:cy Respcase Tea = Field Cc==and Post.

E. E=ergency Facilities and Ecuir=en:

Pla==ing Standard Adequa:e e=ergency f acili:les and equip =es: to supper: the emergency respense are previded and =ain:ained.

E=ergency Plan

~~he E=ergency opera:1ces facilities listed in the Plan are: (1) The Sta:e IOC located in Raleigh, (2) The NC ANG EQS at Dcuglas international Airport, Charlo::e, and (3) Two additic a1 alterna:e cc a~' pests in Charlo::e and Sta:esville. The NC ANG EQS in Charlotte was used during the Exercise conducted en Dece=ber 5-6, 1980 and was adequate for this use. ~he alter-na:e c m d posts in Charlotte and Sta:esville are no: well equipped, but could be u:ilized if the direc.ica of the vind prevents use of the pri=ary facilities.

~he State ICC is a superier facili:7 vi:h adequate space. I: is well arra=ged and equipped with excellen: =aps, si:uation boards, and wall charts.

.~he Exercise revealed : hat Ccunty ECC's need additional space, additic al

=aps, be::er status boards, and be::er a t ica: ices.

The Plan ecut *

• adequa:e infer =ation ccacerning reliable eff-size =etecr-ological da:a for the Charlo::e area.

A=:ex D of the Plan centains an inventory cf E=ergency Ki:s by general categcry (Protective Equip ent, C-.:=icaricas Equip =ent, Radiclegical Monitoring Equip =ent and E=ergency Supplies) .

9 I. Accident Assessment Planning Standard .

Adequate methods, systems and equipment for assessing and monitoring actual or potential off-site consequences of a radiological emergency condition are in use.

Emergency Plan Section IX of the Plan outlines and details the requirements and actions to be taken by the Radiation Protection Section of the North Carolina Department of hcsan Resources to assess the extent of off-site Radiologi-cal problems as a result of an accident at the McGuire Plant. The Plan describes a mobile laboratory equipped with instrumentation for Gamma Ray Spectroscopy to le used for field analysis of collected samples.

Section IX specifically addresses Radio'.ediae in air, general field monitoring capability, asseusment capability and relationship of environ-mental radiation measurements to protective action guides. .

The RAC has indicated that the requirements set forth in NUREG 0654/ FEMA REP-1 have been met with regard to accident assessment. There were four observations requiring remedial actions noted during the Exercise on December 5-6, 1980. Some were very minor; however, if the recommendations are adopted, the Plan should provide an adequate accident assessment capability.

J. Protective Response A range of Irotective Actions has been developed for the Plume Exposure Pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions are developed in place and protective actions for the Ingestion Exposure Pathway EPZ appropriate to the locale have been developed.

Emergency Plan Protective response,Section X of the Plan, provides the requirements and actions to be taken by the radiation protection section of the Department of Human Resources. These actions will assure that necessary measures will be taken to protect the public frem an accident at the McGuire Plant. The Plan provides for the RPS of the Department of Human Resources to base its recocmendations for protective response upon protective action guidelines developed by the U. S. Environmental Protectica Agency and the U. S. Food and Drug Administration.

Frovisions fo* use of radio protective drugs (KI) are addressed in Section I.

Protective measures to be used for the ingestion""pathway are adequately pro-vi.ed for.

Evacuation routes, shelters and medical facilities are also addressed in Section X. Time esti=ates for evaluation for all sectors of the Plume Exposure Pathway are addressed in Section X.

10 K. Radiological Exposure Centrol Planning Standard i Means for controlling radiological exposure in an emergeacy are established I for emergency workers. The :neans for ec : rolling radiological exposure shall include exposure guidelines consisten with EPA Z:nergency ~4orker and Life-Saving Activity ?rcrective Action Guides.

I:nergenev Plan Radiological exposure centrol fer the public and emergency verkers is addressed in See::.cn II cf the Plan. The radia:icn p;ctectice see:1oc cf the Depart:nent of hwan Resources uses the raccuw.ded ? cte :ive Action

< Guides of the U. S. Environmen:al Protectic: Agency as the -ar dm.= accep:-

able levels of radiation to which the public and emergency verkers say be exposed during an emergency at a Nuclear Power Electric Genera:ing Plant.

Sectics E also describes the per=ane : and self reading dose record devices and the =athods for main:aining dose reccrds. The decisien chain for ac:hcr-icing emergency verke s :o receive deses in excess of EPA ?AG's is described in See:ics I!.

L. Medical and Public Health Scoper Planning S:andard Arrangements are =ade for :edical services for cen:n 3nated individuals.

Emergenev Plan Medical and Public Health sappor: is addressed in Sectie III of the Sta:e Plan. The Plan prevides thac :he radiatica protection section sys:ematically visi:s and evalua:es the capabilities procedures and v1111=gness of hespitals ro accept and treat radiatics accide : victi=s. Presently four (4) hospitals in the vicini:y of McGuire Nuclear Sta:ic have been evaluated and le::ers of agree =e :s have been execu:ed. Seven o:hers have been evaluated. Ecv-ever, le :ers of agreemen: have 00: been executed vi:h these seven.

Additionally, :he radiatics protection see:ic: has executed for=al agree-

=enrs with three in-sta:e corpora:f ens (General Electric, Carolf nm ?cuer &

Ligh: and Duke Power Co) which have whole body counting equip:nent and can be used in supper: cf the emergency respense Plan.

The assurance that adequa:e arrange =ents are =ade for medical services for centa=inated individuals was evaluated as adaquate by the RAC, and the ability of local hospitals to handle conta *na:ed victi=s was adequa:ely

exercised.

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11 M. Recovery and Reentry Planning and Post Accident Operations Planning Standard General plans for recovery and reentry are developed.

Emergency Plan Recovery, reentry and post accident operations are described in Section VIII of the State Plan. The Plan provides that the head of the Radiation Protection Section reviews reports and findings of the radiological moni-toring teams and health physics teams. When he determines that radiation levels are reduced to a point that the health asi safety of the public are no longer chreats, he recommends to the Assistan Secretary for Public Safety that re-entry and recovery operations Segin.

The Plan directa that Regulatory Guide 1.109 be. used in making evaluations to assure that PAG's are not exceeded.

The Assistant Secretary for Public Safety reco= mends to the Governor the date and time re-entry and recovery operations should begin.

N. Exercise and Drills Planning Standard Periodic exercises will be conducted to evaluate major portions of emer-gency response capabilities. Pariodic drills will be conducted to develop and maintain key skills, and deficiencies identified as a result of exer-cises or drills will be corrected.

Emergency Plan Exercises and drills are addressed in Section XIV of the State Plan. The N. C. Dept. of Crime Control and Tublic Safety is responsible for the development of all fixed nuclear facility exercises conducted by the State.

This section also provides for the annual exercising of one fixed nuclear facility and the integrated response capability of participating organiza-tions.

A schedule of specialized drills is included in Section XIV. The schedule conforms to the requirements found in NUREG 0654/FIMA REP-1. Evaluation ,

and Control of Exercises are also provided in this Section.

The RAC has indicated that the requirements set forth in NUREG 0654/ FEMA REP-1 have been met with regard to drills and exercises. The RAC observed and evaluated the McGuire Exercise in December 1980. Deficiencies were noted by Federal observers as well as State and Local participants.

% 12 O. Radiological Emergency Response _ Training )

Planning Standard l I

Radiological emergency response training is provided to those who may be called upon to assist in an emergency.

Emergency Plan Section XV of the State Plan addresses radiological emergency response training. The Plan lists the following types of personnel to receive training: Iaam leaders and coordinators; accident assessment personnel; radiological monitoring teams; law enforcement and fire fighting personnel; r emergency medical service and rescue personnel; medical support personnel; and local emergency servicg personnel. The Plan further indicates the State Departments or Ageneits will be responsible for training or will be responsible to arrange training and retraining of appropriate personnel.

P. Responsibility for the Planning Effort: Development, Periodie Review and Distribution of Emercency Plans Plans Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Emergency Plan The 3 tate Plan states that the Assistaat Secretary for Public Safety of the Department of Crime Control and Public Safety is designated as the Emergency Planning Coordinator. The Emergency Planning Coordinator is responsible for the development and updating of Emergency Plans and the coordination of plans with other response agencies at Federal, State and Local level. The Plan further states that the Emergency Planning Coordi-nator is responsible for training of individuals responsible for the planning effort. He has overall authority and responsibility for radio-logical emergency response planning; and he ensures that the Plan and supporting plans are reviewed, updated and certified to be current on

' an annual basis. The Plan also states that updates shall take into account changes identified by drills and exercises.

Assurances that responsibilities are established for plan development, review, update and distribution and that planners are properly trained were considered adequate by the RAC.

13 EVALUATIVE SLTfARY As Acting Regional Director of FEMA Region IV, I concur with the conclusions of State Officials that the level of radiological emergency preparedness in North Carolina is adequate to protect the health and safety of North Carolina citizens. This indication was provided in the letter of application dated November 6, 1980 (given in Attachment 4).

I: is my opinion that North Carolina has done an excellent job in the develop-ment of the Radiological Emergency Response Plan for Plan: McGuire. FEMA Rey.un IV staff members and the Regional Assistance Comittee (RAC) have worxed long hours to assist the State and local officials in this effort.

The requirements set forth in the proposed FEMA rule, 44 CFR 350, titled,

" Review and Approval of State and Local Radiological Emergency Plans and Preparedness," have been met and deficiencies noted by the comprehensive exercises have been or are currently being corrected by the State planning and emergency response staff which includes persons with expertise from both the State Radiological Health program as well as persons from State Civil Defense. Time frames for correcting iden:ified deff e.iencies are provided in A::achment 3.

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ATTACEMErr 3 EXERCISE CRITIQUE A:m STATE RESPONSE TO CRITIQUE ITDS l

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...' : .,v Mr. David E. Kelly Assistant Secretary for Crime Control & Public Safety Division of Emergency Management 116 West Jones Street Raleigh, North Carolina 27611

Dear Mr. Keny:

Observations and recommendations made by federal observers of the McGuire Site Specific Radiological Emergency Preparedness exercise which was conducted on December 5-6, 1980 are enclosed for your review.

It is our understanding dat State and local participants and observers did an outstanding job of self-criticue on December 6,1980. Further, the exercise has been classified as very successful by members of the R.AC and the State's exercise control team is to be complimented for the excenent job done during Se exercise. Notification of residents in the 10 mile EPZ was extremely effective according to reports from observers.

We are aware dat you are currently updating your site specific plan for the McGuire Nuclear Station based upon lessons learned during the exercise.

We wish to make final preparation to submit the North Carolina site specific plan for McGuire to FEMA National for review and acceptance. Lus, at

, your earliest convenience, please provide Mr. Frank Newton, Regional Director, FEMA Region IV, with your position on how, and wiiin what time frame, se deficiencies noted in the criticue will be corrected. Upon receipt of this report, we will proceed with the process of plan acceptance.

North Carolina is to be applauded on the excellent work done in P2P in the short time frame since the promulgaticn of NUREG-0654 by FEMA and NRC.

nus, we wish to compliment you for the excellent effort and assure you that the RAC IV members and FEMA IV staff look forward to supporting future REP activities in your state.

Sincerely yours,

',f*s 1 7 Harris M. Pope Chairman, RAC IV Enclosure

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l PLANT McGUIRE SITE SPECIFIC RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE Observations and Recommendations by Federal Observer Team A. ORGANIZATION AND STAFFING Observations were made from the SERT, Controller's Headquarters, State EOC, Catawba, Lincoln, Iredell, Mecklenburg, Gaston and Cabarrus counties, hospital, Mobile Radiological Lab and Radiological Monitoring Teams.

Observation 1 There seemed to be much confusion when the State assumed control from the county due to lack of proper communication between the state and county.

Recommendation Procedures should be developed which eliminate this confusion. Perhaps additional training on contents of the plan is appropriate.

Observation 2 The entire EOC concept for Mecklenburg County needs reevaluation. The NAWAS room is inadequate. The "EOC" on the first floor of the law enforcement buildinh has adequate space but little else.

Recommendation The EOC in the law enforcement building can be developed into a functional command post if the appropriate communications, displays and operational procedures are developed, tested, and implemented.

Obsenation 3 i

The shelter at UNCC had no official local government representatives.

Re commendation i

Management of the shelter should be the responsibility of the county social services department with Red Cross and other volunteer agencies serving in a support j capa city.

Observation 4 Local ZOf's need additional maps, status boards, SOP's and better communica-t

ions in sqme instances.

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• t Recommendation That local governments continue to work with State officials and licensee in improving EOC operations.

Observation 5 There seemed to be a low to moderate level of coordination between the SERT PIO and local government PIO's.

Reccmmendation Coordination of public information with local government should be increased.

Observation 6 Lack of control over ccunty radiological monitoring operations. No procedures were evident to control exposure for emergency workers.

Recommendation Procedures should be developed to control personnel exposure and supervision provided for monitoring teams.

Observation 7-Ability to operate for extended periods for county officials is questionable. The county civil defense director in one county (Iredell) was over tasked.

.e Recommendation "

Consideration should be given to the development of procedures and training of additional personnel should operations be required for extended periods of time ( i. e. , several days and perhaps weeks).

B. ~ ACCIDENT ASSESSMEN'f -

4 Observations,were made from SELT, the Mobile Lab, the. Mobile Radiation Monitoring Teams and local county EOC's. -

Observation 1 -

The Mobile Laboratory arrived 30 minutes later than expected due to taidng an alternate route. This caused the SERT :o lose communications with the Lab enroute.-

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3 Recommendation That both SERT and mobile lab personnel develop procedures for alternate routes and communications while enroute.

Observation 2 Security for the mobile lab was not provided on the first day.

Re commendation That highway patrol develop SOP's and/or procedures to provide for the security of equipment.

Observation 3 Field monitoring team did not demonstrate ability to evaluate air concentrations of radioactivity.

Recommendation That teams receive additional training on air monitoring and reporting require-ment for decision makers as part of a ccmfirmatory measurements program.

Observation 4 All assessment data gathered during the course of an accident (written and electronically comm2nicated) should be logged / recorded and retained for reference.

Recommendation Consideration should be given to utilizing standardized report forms / log books for recording assessment data, and adopting a system whereby all incoming and outgoing messages are recorded and preserved.

i C. MEDlCAL SUPPORT t

Observations were made at the Charlotte Memorial Hospital.

Observatim 1 Radioactive contamination control activities at the hospital need attention in order to prevent the spreading of contamination around the hospital.

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Recommendation That hospital staff receive additional training in contamination control practicer.

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4 f v D. ALE RTING / NOTIFIC ATION/ C OMMUNIC A TIONS Obs ervati as were made from the SERT, State EOC, Controlle r Headquarte rs sod Catawba, Lincoln, Iredell, Mecklenburg, Gaston and Cabarrus Counties.

Obs ervatie 1 Wording on the declaration of the disaster message was incorrect.

Recommendation Sample messages should be developed and used which correctly describe emergency conditions.

Observation 2 Terms which were not familiar to county officials were transmitted from the licensee ( i. e. , apparent gross failed fuel).

Recommendation That the licensee assure that messages sent to local officials are consistent with the requirements on accident classification as provided in NUREG 0654/

FEMA-REP-1, Rev. 1.

Cbservation 3 -

County officials assigned to the EOC's need additional phones during periods when a large number of calls are made and received.

Recommendation Install additional phone jacks in the EOC's to accommodate the county officiale.

. Observation 4 There were occasions when counties lost contact with the SERT because of busy circuits and poor radio transmission. This situation forced county into taking steps on their own which could have had adverse impact on overall response ( i. e. , unnateral redirection of evacuation traffic ).

Recommendation Improvements should be made in alternate means of comzmmications to assure contact with SERT at all times.

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5 Observation 6 Communications from county EOC's to evacuation shelters were not adequate at times.

Recommendation Improve this communication link with additional phones and/or radios.

E. PROTECTIVE ACTIONS Observations were made from SERT, County EOC's, Mobile Lab, and monitoring teams.

Observation 1 Counties were not prompt in opening evacuation shelters; activation procedures not clear.

Recommenda tion County officials shot.1d review county plans and develop SOP's for shelter activation in the event evacuation is judged to be the appropriate protective a ction.

Observation 2 The road block at I-77/SR 150 was manned by N. C. troopers, Iredell County Sheriff's Deputies, State Forestry Service, West Iredell Volunteer Fire De pa rtment, Lake Norman Volunteer Fire Department and the West Iredell Fire Rescue Unit. During casual conversation with members of these organi-zations it was noted that most had received little or no training to cope with a nuclear accident.

Recommendation Additional training should be provided to all emergency response members with specific training in each person's areas of responsibility.

Observation 3 After a vehicle had been washed down because of contamination no further contamination checks were made.

Recommendation Immediately after a vehicle has been washed down another check should be made to insure contamination has been removed.

6 After a vehicle is declared " clean" a clearance sticker should be affixed to the vehicle so that other check points will know that the vehicle is clean.

Observation 4 Evacuation route and shelter designation signs were not in place North of Shepherd School on US. 21.

Recommendation The present evacuation routes should be reviewed and routes finalized.

Permanent signs indicating routes and shelters should be installed.

Observation 5 The two evacuation shelters (Troutman & Shepherd's Schools) were both utilized and appeared to be adequate with one exception--no showers for wash down. Outside . wash down is provided by fire truck. This system would be very uncomfortable during the winter months.

Re commendation Additional monitoring equipment be made available in order to speed up proce s sing. Indoor showers be available or that cther shelters be found that already have shower facilities.

Obse meation 6 There was a lack of procedures for establishing and operating decontamination points and a lack of persons trained in decontamination procedures and techniques.

Recommendation Procedures should be developed at the local level for decontamination and adequan

number of persons should be trained and assigned to decontamination stations.

Observation 7 The County Social Services Department had no involvement in operation of shelte rs.

Recommendation That consideration be given to utilizing Social Services Department for shelter ope rations.

7 F. PUBLIC INFORMATION _

Observations were made from the State ECC, County EOC's and SERT.

Observation 1 Public information during the exercise was handled effectively, however, additional coordination between the SERT PIO and the County PIO's could help avoid providing erroneous information to the public.

Recommendation Additional coordination between the SERT PIO and the County PIO's should be achieved in future exercises.

G. REENTRY Observations were made at SERT and State EOC and county EOC's.

Observation 1 While there was proper discussion on recovery and reentry actions which were to be taken, time restraints did not allow implementation of the decision for reentry.

Recommendation The State should carefully review State and local plans to insure that they include adequate coordination procedures to assure this important phase of emergency operations can be carried out.

- H. INGESTION PATHWAY Observation was made from the State EOC since no off-site release was made during the exercise.

Observation 1 4

A complete table top exercise concerning the ingestion e>posure pathway was made on December 6,1980 beyond the close-out of the exercise.

Recommendation That consideration be given to exercising protective actions in the ingestion pathway on "real time" in future exercises.

Nor:h Carolina Depcr: ment of Crime ControiW,

&PubileSafe 116 Wes: Jones Street Raleigh 27611 James B. Hunt.Jr., Governor Division of EmergencyManagemen:

Bur:ey B.Mitchell,Jr..Secre:ari February 16, 1981 (9191733 3867 Mr. Harris M. Pope, Acting Regional Director Federal Emergency Management Agency Region IV 1375 Peachtree Street, N. E., Suite 664 Atlanta, Georgia 30309

Dear Mr. Pope:

The purpose of this letter is to address Federal Emergency Management Agency Region IV coments on North Carolina plans, and the exercise of those plans, to supoort the McGuire Nuclear Plant. More soecifically, reference is made to two Region IV documents: a letter dated November 17, 1980, which contains review comments on State and local plans, and a letter dated December 19, 1980, which lists Region IV observations and recommendations resulting from the exercise designed to test the plans. Each of these documents is addressed in secarate attachments to this letter.

Plan or procedure modifications or other actions required by the attachments to this letter will be completed by March 13, 1981. Modifications or actions ce1ng accomplished in a different time-frame are sDecifically pointed out where aporooriate. If you have comments germane to the actions proposed by the attachments tc this letter, clease forward them in time for consideration prior to the distribution of the planned changes.

Sincerely,

[ C% -

( David E. Kelly Assistant Secretary for Public Safety DEK:kl Attachments (2)

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C.'s' 31 M" ~i t m" e"e D LOCAL PL A :S TO SUPP00.7 THE 'CGl.E.E : UCLEAR PLANT 4

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1. State Plan; Page 114; D.3.  !

Unanimity of decisions-standards in State and local plans concerninq decisions to exceed the stated PAGs will be acconplished by revising paragraph D.3. on Page 114 in the State plan to achieve greater clarity.

The revised paragraph sill read as folices:

"The policy under this plan is not to allow emergency workers to receive a radiation dose in excess of the stated PA3s. The senior RPS recreser.tative on tne SERT may recommend to the SERT leader that emergency workers be allowed to exceed the PAGs provided that the RFS representative finds that:

there is no feasible say to rotate workers, and

- the activities involved are critical to public protection.

Final approval authority is vested in :he SERT leader.

' Permissions to exceed 75 Rens wit 1 nct be granted."

The county plans will then be changed to align with this paragraph. It should be remembered, however, tnat until the State Emergency Response Tear.

(SERT) is established, county autnorities will make the decisions affecting their jurisdiction. i.svertneless, they will e.rploy the same decision-standards.

2.

• eckler. burg County,

a. Fa:e 97; D.3.

See paracraph I above.

b. Page 31; D.4 The following will as added to this caragraph: '

" Pursuant to IRAP, addi:icnai las:: atory services will be available fro Federal agancies anc their ccntractors.

These services will be fec: lab;ra scies fecm Federal agencies signatcry to IRAP, includirg but r.ct lir.ited to:

. , P00R OREN!L

Savannah River Operations Office U. S. Decartment Aiken, South Carolinaof W 64EF.Mj Eastern Environmental Radiations Laboratory U. S. Environmental Protection Agency Montgemery, Alabama ORP Las Vegas Facility '

U. S. Environmental Protection Agency las Vegas, *levada Oak Ridge National Laboratory U. S. Depar::r.ent of Energy Oak Ridge, Tennessee NRC Regions II Mobile Lab Atlanta, Georgia Further laboratory analysis assistance is available frem 5" RAP Signatory State."

2. Iredell County

a. Page 105, 0.3. See paragraph I above.

b. Page 125. Signatures of local authorities will be obtained and submitted as a change to finalize the olan.

4 Lincoln County; Page 105, 0.3. See paragraph I above.

5. Gasten County

a. Page 128; D.3. See paragraph 1 above.

b. Page 155. See paragraph 3.5. above.

6. Cata.:ba County; Page 102; D.I. See paragraph I above.

P00R ORGINAL 3

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1 ATTACH'*EtiT 2 RESF0l:SE TO FE:% REGIO;4 l'.' 035ER'.'ATIO !S AT D REC 0tNEriDAT10:15 l

RESULTIl;3 FROM THE RADIOLOGICAL Ei*ERGEliCY PREPAREDNESS EXERCISE TO TEST THE STATE At:0 LOCAL PLANS TO SUPPORT THE MCGUIRE f;UCLEAR PLAi4T O

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• A. ORGANIZATION AND STAFFING.

Observation 1: Two steps will be taken to insure a smooth transition from local to State direction and control authority. The plans will be changed to reflect an easily identifiable point of change. Specifically, the following sentence will be added to paragraph II, C, 7 on Page 10 cf the State plan and to the appropriate paragraphs in the county plans:

"The exact time at which direction and control responsi-bility shifts to the State is when the SERT dispatches a message which states that a State of Disaster / Emergency has been declared, that the SERT is established and that the SERT assumes direction and control authority."

Secondly, this char.ge will be emphasizec and brought to the attention cf coun,ty and State emergency management personnel.

Observation 2: _

The NAWAS rocm in the Charlotte-Mecklenburg Law Enforcement Building is intended to serve only as a preliminary E0C until it beccmes necessary to more fully man the emergency operations center. It would have been adequate for this puroose except for the number of evaluators and other observers who were present for the exercise. The current E00 is actually located in a much larger room. Te imprcve cer.nunications in the larger E0C facility, six additional telephone lines have been installed. Various informaticnal displays and internal operational procedures have also been l

developed to improve EOC operations. Lor.ger range plans call for the establish-ment of an adequately designed and equip;2d EOC in "ecklenburg County Services Center Ccmplex.

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9 Observation 3: Internal procedures have been changed in Meckler.ourg County to give the County Department of Social Services the responsibility for overview tr.anagement and coordination of shelter operations.

Observation 4: The State will continue to work with local government to improve the functioning of local emergency operation centers. The counties concerned will be given a high priority when EOC operations training and on-site assistance in the preparation of standard operating procedures is scheduled. Communication at local EOCs will be improved by adding on additional back-up system. Specifically, the following words will be added to Section IV, EMERGE::CY CC"Mut:ICATIO :S, of the State and local plans.

" Additional Back-Up Cominunications

1. The : orth Carolina State Highway Patrol will position radio equipped patrol cars at each county EOC and at the McGuire Ituclear Plant to provide back-up cow.unications between those sites and the SEP.T.

2. In an extreme emergency when cther forms of communication-are not possible, these patrol cars and the State Highway Patrol members manning them can be used to transport hard-copy messages "

Observation 5: The need for thorough and careful coordination between the SERT and local government public information officers is recognized as being essential to the comprehensive management of emargencies resulting from possible accidents at nuclear plants. The need for such coordination will be ecphasized in planning and coordination meetings and during future exercises and e.ergencies. Contact witn ccunty liaison represent.atives in the SERT will also be emphasized as an additional treans by which pIO coordination can be effectively initiated.

P00HunlGINAL 2

Observation 6: The McGuire exercise scenario did not include a simulated release of a radioactive substance, and therefore, there was no need to initiate, coordinate anc control radiological nonitoring operations Or emergency worker er.pcsure to radiation. Mcwever, alth% gh the basic plan is censicered adequate, the tiorth Carolina Radiation Protection Section and Division of Emergency "enagen2ent will work with the aopropriate county persennel to develop standard operating precedures to assure effective radiological monitoring and proper exposure conitoring of emergency workers by local governcent. This work will be cor.pleted by May 1, 1981.

Observation 7: The ability of local EOCs to function over an extended period of time is in ortant. '.'here necessary, tne tiorth Carclina Division of Energen:y :*.anagement will prcvide training in EOC operations to increase the number of people available to man the local EOCs over extended periods.

Procedures to maximize the efficient icng-term utilization of available man;;wer wi'il be emphasized. (During exercises, however, EOCs will continue to be over-staffed in order te gain axiru- tenefit from the realistic training providec by su:n activity.) Trainir g will ce ;roviced frecuently enough to meet -he neecs create: by natural attrition of personnel.

S. ACCICE C ASSESSMEtiT.

Observation 1: The Radiation ?rotection Section will revise its procedures con:erning alternate r:utes by April 15, 1931. Additionally, State Highway Patrcl tasks described in Section II, paragraph D.2.b. of the State Plan will, be revised by adding s'.,b-;arag aph (17) On : age IE. It will read as feil:ws:

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" Provide a Highway Patrol car to escort the' Radiation Protection Section mobile laboratory v. hen it is en-route to the area of an accident and sufficient manpower to provide security for the mobile laboratory for the duration of the emergency."

This will reduce the travel time of the tobile laboratory and pn: vide an alternate means of concunication.

Observation 2: See Observation I above. The Hignway Patrol escort car will previce initial security for the Radiation Protection Section mobile laboratory; additfor.ai forces can be assigned as required.

Cbservation 2: Se:ause cf the McGuire exercise scenario, the Radia. ion Frotecticn Section did not physically place and run air samplers. H <.e.er, tnis ability was dar.cnstrated in :ne 1979 Brunswick Plant exercise. The Raciatien Prote::icn Se:: ion is already precared to estimate air concentra-tion of racicact'ivity by empicying conservative nomographic approaches using direct radiatien levels above background.

Observation 4: f*:re ex:ensive Radiaticn Protection Secticc (RPS) staffin; of the SERT head: ar:ses will enable mere exhaustive logginc of messages to form a basis for reference. The develop ent of specific RPS SERT staff positicr.s and respor.sicilities will also c:ntribute to more effective staff activity. A core comple:a staffing of the RPS SERT element will be accomplished by the use of technically cualified volunteers. The written aspect of this c:rre::ive action till be cc: pletec by :Pe r adiation Prctection Section by "ay 1, 1531. Eegir.ning July 1,1931, volur.:eers will be given training on cpe-ati:nal ;-ocedures.

P00R ORE M

C. MEDICAL SUPPORT.

Observation 1: Radioactive centamination control orocedures at the Charlotte Memorial Hospital have been reviewed and revised to prevent the spreading of contamination around the hospital. The hospital staff has also been given additional instruction in contar.ination centrol practices.

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Observati:n 1: The State will cispatch a riessage to each county concerned when it assumes cire:-ion anc cor. trol authority ever the off-site emergency reso nse to an incident at :ne McGuire ;;sclear Plant. This messace will s ate na an Offi:ial disaster / emergency has been ceclared by the Governor a .: tna: the S.P.T has been es:ablished an: aIsumes direction anc c ntrol res:ensibilt ies. (See paragra;h A, C:ser.a-icr 1.)

0:servatien 2: Tne :enten: cf messa;es dis;at:ned from the licensee, Duke P:wer Cem;any, is r.o: .-:ithin jurisdictier. cf State and local government.

H wever, Duke ?Ower Company officials will be in#ormed that terms not familiar to cour. y officials snould nc: te transmitted to those au-horities.

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In some cases, in order to conserve limited resources, arrangements have been made to allow a substantial increase in telephone comunications within a few hours of the decision to activate an EOC by installing telephone lines on which additional telephones can be added.

Observation .;: As stated in paragraph A. Observation 4 above, radio equipped 5:ste Highway Patrol cars will be positicned at each ccunty EOC and at the l':Guire tieclear Plant t: improve backup cc:.:anications by adding an additional radio link and the capability to hand-carry hard-copy messages in an ey.treme emergency.

Ctserva-icn 5: This cbservation r,u;rer w:s riitted # rem the FEFf, letter ca ed Cece.ber 19, 1913.

Cbserva:icn 5: Tc imoreve co aunications fec: the county EOCs to emergency shel ers, One ccunties will be prepared to supplement telephone communicationi

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, "If necessary, the EOC emergency shelter communication link will be supplemented by amateur radio support and/or by positioning : radio-ecuipped law enforce:aent vehicle at each shelter."

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