ML20039G085
| ML20039G085 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/07/1982 |
| From: | Reynolds J JOINT INTERVENORS - DIABLO CANYON |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8201150267 | |
| Download: ML20039G085 (10) | |
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l UNITED STATES OF AMERICA '~
NUCLEAR REGULATOP.Y COMMISSION -
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of ) '
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PACIFIC GAS AND ELECTRIC COMPANY ') Docket . .
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(Diablo Canyon Nuclear Power
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Plant, Units 1 and 2) )
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JOINT INTERVENORE' MOTI -
POR
SUMMARY
DISPOSITIC ,
'- I' OF CONTENTION ONE -
In its Memorandum and Order (" Order") served Decem'ber 28, ;'
1981, and received by Joint Intervenors on January 4, 1982, -
this Atomic Safety and Licensing Board (" licensing board")
ruled that the FEMA Finding. required under the NRC'c -
,3 regulations-is the FEMA' Memorandum of November 17,~1981,-. and
,7 the November 2, 19El attachment thereto. December 28 Order, J
at 2-2. (h copy of that " Finding" is' attached hereto.I JoiM Intervenors hereby move for summary. disposition of contention , _ .
one on the ground that that Finding- is ~ inadequate as 'o matter ,'
of law under the NRC's regulations, because it fails to ,
address whether the titate of Callfornia Nuclear Power Plant >
Emergency Response Plan (" State Plan") is adequate nd capable
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8201150267 820107 -
{DRADOCK 05000275 PDR
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. .f', ,- 'y of/being impromented. Although the deadline for filing of r . 1 .; - ,
, .y oumary ' disposition motions in this proceeding was December
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v a21', 1981, Joint'Intervenors could not have filed this motion
,c MahT.datebecausethisboardhadnotyetruledthatthe.
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. Nov' ember 17 FEMA hemorandum' constituted the essential FEMA
. / _
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"78Nding. Nhan ,tih5' board so ruled on December 28, this motion
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y was prepared pursu6nt to the board's earlier order allowing
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y :, - all parties a reasonable time to file pleadings'with respect L to FEMA's finding. 'o T expedite the board's consideration of
~ ' this motion ~, Joint Intervenors have served all parties by s
u 4 ., y' ' Express, Mail. '-
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Underf i0 C.F.R.;S 50.47 and the FEMA /NRC Memorandum of i - ;e -
y %nderstanding,F3Mfhasspecificresponsbilities: '
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A Yo'make. findings-and determinations as k ,-, to whether State and local emergency plans are
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w -o adequate.
! 2. To verify that State and local emergency plans are capable of being implemented 5
(e . g . , adequacy and maintenance of procedures, training, resources, staffing levels and qualification, and equipment).
'/
C ,
'3' . To assume responsibility for emergency preparedness training of State and local
~
officials. .
o ,
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% 5 ' Fed '; ^ Reg .
55[,406 (1980) (emphasis added) . The NRC, in
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turn; must relp upon the required FEMA findings:
M The NRC will base its finding on a review of the Fo'deral Emergency Management Agency . (FEMA) is %. ~*
findings'and determinations as to whether State
'is, , ~
- , and local emergency plans are adequate and
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, ,,y .
- ' capable of' being implemented, and on the NRC C1 -
assessment as to whether the applicant's onsite me >
' emergency plans are adequate and capable of c /' be,ingsimplemented. 10 C.F.R. S 50.47 (a) (2) .
, (Emphasis added) .
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Thus, u'nder the NRC's established regulatory scheme, FEMA findings on the State' Plan' as well as on local emergency response plans, are essential. Indeed, the required FEMA finding is to constitute a " rebuttable presumption on the question of a'dequacy" in any licensing proceeding. 10 C.F.R.
$ 5 0. 4 7 ('a ) ( 2)' . Because the parties are entitled to prepare to suppor t or rebut bhat presumption, it follows logically that such a " finding" regarding,the State Plan must be provided
, prior to the hearing.
7 The NRC Staff has itself recognized the necessity for FEMA findings on the State Plan. Thus, in SER Supp. 14, the Staff stated:
Upon satisfactory completion of the items
, > identified below, the staff will issue a i
favorable finding with respect to emergency preparedness matters for full power operation.
- 4. NRC review of the Federal Emergency Management Agency findings and determinations as to whether State and local emergency plans are adequate and s,_ capable of being implemented (10 C.F.R.
- 50.47 (a) .
! SER Supp. 14, pp. 2-26' (emphasis added) . In that same document, the Staff stated further that the issuance by FEMA of its findings on adequacy of the State and local plans is a prerequisite to the Staff's own final conclusions on the
'I adequacy of Diablo Canyon's offsite preparedness:
After receiving the findings and determinations made by FEMA on State and local emergency 4 -- respons'e plans, and after reviewing the revised site plan from PG&E, a supplement to this report will provide the staff's overall conclusions on
the status of emergency preparedness for the Diablo Canyon Power Plant and related Emergency Planning Zones.
Id. at B-11 (emphasis added). No staff supplement has yet been issued, nor could it have been: issued in light.of the continuing lack of any FEMA " finding" regarding the State Plan.1!
The November 17 FEMA Finding does not make any finding regarding the adequacy of the State _ Plan or whether-it is capable of being implemented, on the contrary, while passing reference is made to the State Plan, the November 17 Finding involves only an evaluation of the County Plan. Thus, FEMA's
" Interim Evaluation" is as follows:
The FEMA Rule _ requires a detailed planning process for the-development and maintenance of off-site emergency response plans. This process includes plan development, training, drills, exercise,'and plan revision culminating in a formal review by FEMA with a regular repetition of this cycle to ensure maintenance of response capability. The San Luis Obispo County Plan is well ur.derway on this process, although has-not yet arrived at the point of a formal review by FEMA. Progress to date has been satisfactory, and unless something goes dramatically awry during the remaining portion of the process required by the FEMA Rule, this evaluation will remain valid. To assist in this evaluation the NRC-FEMA planning. objectives from the FEMA Rule and the FEMA REP-1/NUREG 0654 document are provided here. The information available to FEMA Region IX at this point in time indicates that the planning objectives have, for the~most part, been met. The planning objectives are shown here to highlight the significant remaining corrective actions that need to be accomplished. Most of these actions involve providing hardware or equipment that is needed 1 NUREG-0654 also demonstrates the importance of findings on the State Plan. Indeed, pages 31-79 of that document list no less than 107 evaluation criteria which apply to the State Plan.
I 9
to establish the necessary response capability.
When these corrective actions are accomplished to the satisfaction of FEMA Region IX, and the ,
County plan is completed and submitted to the i State for formal review, we believe with reasonable. assurance that an adequate level of emergency preparedness will exist in San Luis Obispo County. (Emphasis supplied).
I The evaluation then goes on to address briefly the Section 50.47 (b) planning standard with reference to the county plan.
f Thus, FEMA has made no finding regarding the State Plan.
Indeed, the " Finding" attached hereto notes that the " State Plan is tentatively scheduled for formal submission under the FEMA Rule process in July 1982." Further, Mr. Jack Kearns confirmed at his December 7, 1981 deposition that FEMA had not formally reviewed the State Plan. Kearns Tr.-122.
Absent the required FEMA finding regarding the' State Plan, this Board must rule that a finding of adequate preparedness at Diablo Canyon cannot be made at this time.2/
2
- Indeed, until FEMA has issued its required finding regarding the State Plan -- on an interim-or final basis -- a hearing on emergency preparedness at Diablo Canyon is clearly premature. .
Accordingly,-Joint Intervenors respectfully request this l Board to rule as follows: -
l l
/ Joint Intervenors submit that no finding that the State Plan is adequate could be made at this time. In' deed, Mr. Kearns acknowledged that the injestion pathway plan -(a
, State responsibility) has not yet been completed, that plans i for recovery and reentry are inadequate, and that offsite j medical facilities have not been provided. Kearns Tr. 132, 133, 134, 138, 174-75. See also the numerous State plan deficiencies cited by PGandE in its September 2, 1981 Response to Joint Intervenors' First Set of Interrogatories.
1 i
(1) The NRC regulations require a finding by FEMA regarding whether the State Plan is adequate and capable of being implemented; (2) FEMA has issued no finding regarding whether the State Plan is adequate'and capable of being implemented; (3) The absence of a FEMA finding regarding the State Plan precludes as a matter of law any overall finding that emergency preparedness at Diablo Canyon is adequate and in compliance with 10 C.F.R. S50.47; and
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(4) Joint Intervenors' Motion for Summary Oisposition is granted and that a hearing on emergency preparedness at Diablo Canyon is postponed until the requisite FEMA finding is issued and all parties are able to review the same.
DATED: January 7, 1982 Respectfully submitted, JOEL R. REYNOLDS, ESQ.
JOHN R. PHILLIPS, ESQ.
Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ.
P. O. Box 1178 Oklahoma City, OK 73101 By 701 O/L R. R2Yy.DLDS Attorneys for Joint Inter-venors SAN LUIS OBTSPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVFR ELIZABETH APFELBERG JOHN J. FORSTER STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE DISPUTE
- 1. The NRC regulations require a FEMA finding on the adequacy ot the State Plan and whether it is capable of being implemented as a precondition to any overall finding on the adequacy of emergency preparedness at Diablo Canyon.
- 2. FEMA has made no finding on the adequacy of the State Plan and whether it is capable of being implemented.
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
)
CERTIFICATE OF SERVICE I hereby certify that on this 7th day of January, 1982, I have served copies of the foregoing JOINT INTERVENORS' MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION ONE, mailing them through the U. S. mails, first class, postage prepaid.
- Admin. Judge John F. Wolf,
- Docket & Service Branch Chairman Office of the Secretary Atomic Safety & Licensing U.S. Nuclear Regulatory Board Commission U. S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555
- William Olmstead, Esq.
Marc R. Staenberg, Esq. .
- Glenn O. Bright Edward G. Ketchen, Esq.
Atomic Safety & Licensing Office of the Executive Legal Board Director - BETH 042 U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
- Express Mail
- Dr. Jerry R. Kline Nancy Culver Atomic Safety & Licensing 192 Luneta Board San Luis Obispo, CA 93401 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Fredrick Eissler *Malcolm H. Furbrush, Esq.
Scenic Shoreline Preservation Vice President and General Conference, Inc. Counsel 4623 More Mesa Drive Philip A. Crane, Esq.
Santa Barbara, CA 93105 Pacific Gas & Electric Company P. O. Box 7442 Sandra A. Silver San Francisco, CA 94106 Gordan Silver 1760 Alisal Street Arthur C. Gehr, Esq.
San Luis Obispo, CA 93401 Snell & Wilmer 3100 Valley Center David S. Fleischaker, Esq. Phoenix, AZ 85073 P. O. Box 1178 Oklahoma City, OK 73101 Carl Neiburger Telegram Tribune
- Bruce Norton, Esq. P. O. Box 112 3216 N. Third Street San Luis Obispo, CA 93402 Suite 202 Phoenix, AZ 85012 Byron Georgiou, Esq.
Legal Affairs Secretary to Janice E. Kerr, Esq. the Governor Lawrence Q. Garcia, Esq. State Capitol Building J. Calvin Simpson, Esq. Sacramento, CA 95814 California Public Utilities Commission
- Lawrence Coe Lanpher, Esq.
5246 State Building Hill, Christopher & Phillips 350 McAllister Street 1900 M. Street, N.W.
San Francisco, CA 94102 Washington, D.C. 20036 MHB Technical Associates 1723 Hamilton Avenue Suite K San Jose, CA 95725 Mk
- f. S. VARONA
- Express Mail
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NOV 17 L980 MEMORANDUM ?CR: 3rian Grines . . . . . . . . . . . . . . . .
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SUEJEC"': Interin Evaluatien.and Status Report-Diablo Canycn I a= fervarding the attached apv.. .f m?cde- a1. Emergency Management. ..,
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Age ==y (FEMA) Regie: II which.prevides . infer..aticu- en the status .of , ..,,,
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hfi Federal Emergen6' y Management Agency khh[ Region IX 211 Main Street, Room 220 San Francis p ,M" 6f,IRL*,NMCL gP & [NVIRONME N,' ' ' SMETY TAM November 2, 1981 . JLP Es' NOV 121981 $'r N3.aie comm.ni CTP SAW ng anew RAU TWO m DLD EWI SRF JSM .
9.0RANDUM FOR THE ASSOCIATE DIRECTOR, STATE AND LOCAL PROGRAMS AND SUPPORT DIRECTORATE Attention: Robert T. Jaske, Acting Chief Tecypflogical Hazards Division .
/gV FROM: Fr . Manda, Acting Regional Director .
SU3 JECT: FEMA Region IX Evaluation and Status Report on State and Local E=ergency Preparedness Around the Diablo Canyon Nuclear Power Plant The FD!A Region II Evaluation and Status Report on the State and Local E=ergency Preparedness Around the Diablo Canyon Nuclear Power Plant is attached for your infor=ation and necessary action.
When the necessary corrective actions are acco=plished to 'the satis-faction of FEMA Region IX, and the County plan is co=plete M 1 M tifcA 3 ~ ~ ~
to the State for for=al review, we believe with reasonable assurance (3 '
that an adecuate level of emergency preparedness will e<ist in San Luis Obispo County.
The docu=ents referred to in the attached report were, in cost cases, forwarded to your office previously. Those that were not provided are attached to the report.
Attachment l
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s FEMA REGION IX EVALUATION AND STATUS REPORT'ON STATE AND LOCAL EMER0ENCY ?REPAREDNESS AROUND THE DIASLO CANYON NUCLEAR PorcR PLANT
'T 1
1-I. INTRODUCTION: .
As cited in 44 CFR 350.3d (the proposed FEMA rule), 'JFEMA has entered into I a Memorandum of Understanding (MOU) with the NRC to which it will furnish findings and determina: ions as to whether State and local emergency plans and
- preparedness are adequate and continue to be capable of i=ple=entation." In
! accordance with the schedule shown on the NRC/ FEMA Joint Monthly Report to Congress on Emergency Preparedness, Region IX is submitting this report to the FEMA National Office. The rep' ort is based on an assessment period from April 1980 to the present and focuses on the portions of the planning process out-
! lined in *k a TEMA Rule that have been completed to date. The report concludes with ajN#I((?[ valuation of the current status of each of the planning objec-tives usec oy ::Ma.
i
- II. 3 ASIS FOR EVALUATION
A. Draft Plan Review. In June 1981 the FEMA Region IX staff and its
{ Regional Assistance Co==1ttee (RAC) members reviewed the draft San Luis Obispo i County Nuclear Power Plant Emergency Response Plan (Parts I and II), dated May 1981. This review constituted a part of the developmental assistance by FEMA Region IX and the RAC in accorance with the FEMA Rule. Thi's review followed 1 the planning standards and evaluation criteria in the FEMA REP-1/NURIG 0654 s document. The plan was measured against each criteria ele =ent and judged on
, (_ its acceptability. A nu=cer of ecm=cnts were made to assist the planners in the further development of this plan. It was noted that a large number of the evaluatica criteria ele =ents were to be addressed in the Standing-Operating Procedures (50P's) and other parts of the plan which were not developed at that time. -
- 3. Training and Drills. The State of California Of fice of' Emergency Services, in conjunction with FEMA, developed and conducted a s'eries of training and drills during June, July, and August of 1981'. These activities were based in part on the concepts of exercises and drills set forth in the f
FEMA REP-1/NURIG 0656 docusent. This previded training for.the people I
involved in emergency response and allowed for further development of plans and SOP's in preparation for the full exercise. (See attach =ent, Califolrnia OES Letter, June 5, 1981.)
C. Exercise. The County revised their plan and developed SOP's based on
- the FEMA draft plan review co==ents and their training and drill experience so
- that hey could be further tested in the exercise. On August 19, 1981, FEMA
- . Region IX conducted an evaluation of the of f-site capabilities of the County 1 and State te respond to a nuclear emergency at Diablo Canyon. The evaluation, preparation, conduct, and subsequent critique process followed the guidance j previded by the FEMA National program office.
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,s .The evaluation conclusion was that due to the planning effort and participation by all those involved, the exercise succeeded in its three basic goals. First, it denonstrated a capability to respond to a developing e=er-gency situation; second, it served as an excellent training device;'and third, it highlighted potential proble= areas to be corrected. An initial corrective action schedule that responds to the FEMA " Exercise Evafuation Findings" was developed through joint consultation a=ong the County Of fice of E=ergency Services, State Of fice of E=ergency Services, FEMA, NRC, and Pacific Gas and Electric Co=pany representatives. This correc:ive action schedule addresses each finding and describes how and when it will be corrected. FEMA Region IX expects to receive the co=pleted version of this schedule by'=id-November 1981.
D. Status of the County Plan. The " San Luis Obispo County Nuclear Power Plan: E=crgency Response Plan" has undergone considerable develop =en:
since the FEMA review of the draft plan in June 1981. The plan was =odified based on those draft review coc=ents, and 50?'s were developed and tried during the training and drills in preparation for the exercise. As a result of the August 19 exercise, the plan was =odified based on the FEMA evaluation findings and the experience of the County staff during that exercise. The plan will shortly be ready for review and co==ent at the public =eeting scheduled for Nove=ber 24, 1981. This will also satisfy the public =eeting recuired by the FEMA Rule. 1: is expected tha: the County plan will be sub-
=itted to the State Of fice of E=ergency Services by January 1981 for for=al review by the State and Federal govern =ent.
h' The State'of California Nuclear Power
~
5 E. Status cf the State Plan.
Plan: E=ergency Response Plan, in effect since 1975, has gone through a' number of revisions, the lates: being a revision of :he ad=inistrative portion of the plan in early 1981. The 1973 revision received NRC concurrence in. August 1978 based on the MRC criteria existing at that ti=e. FEMA Region IX provided develop = ental assistance in March 1931 by review of this revised draf t of the ad=inistrative plan against the new criteria. Since that time the ad=; ;e--a-tive plan has been revised and the State agency SOP's are w l'o3=e~nb It is expected that the State will fully exercise its plans D .' 1 isc..
The State plan is tentatively scheduled for for=al sub=ission under the FEMA Rule process in July 1982.
III. INTERIM EVALUATION:
The FEMA Rule requires a detailed planning process for the development and =aintenance of of f-site e=ergency response plans. This process includes plan develop =en:, training, drills, exercise, and plan revision culminating in a fornal review by FEMA with a regular ranetition of this evele en ansure pygg
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p.nydyMAs pr ogr es s to date has been satisfac:ory, and unless crc =a;;catly awry during the re=aining portion of the process required by the FEMA Rule, this evaluation will re=ain valid. To assist in
. -3
's this evaluation the NRC-FEMA planning objectives fro = the FEMA Rule and the FEMA REP-1/NURIG 0654 docu=ent are provided here. The infor=ation available to FEMA Region IX at this point in time indicates that the pl anning 'ob j ec tiv e s have, for the cost part, been =et. The planning objectives are shown here to highlight the significant re=aining corrective actions that need to be accc=-
plished. Most of these actions involve providing hardware or equip =ent that is needed to establish the necessary response capability. 'a' hen these correc-tive actions are accomplished to the satisfacticn of FEMA Region IX, and the County plan is ce=pleted and submitted to the State for for=al review, we believe with teasonable assurance that an adequate level of e=ergency prepared-ness will exist in San Luis Obispo County.
IV. 2LANNING OBJECTIVES: .
A. Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the E=ergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organi:ations have been specifically established, and each principal response organization has staff to respond and to aug=ent its initial response on a continuous basis.
Corrective Action. None
- 3. Not applicable.
(~, C. Arrange =ents for requesting and effectively using assistance resources have been made, arrange cnts to acco==odate State and local staff at .the licensee's near-site Er.ergency Operations Facility have been =ade, and other crganizations capable of aug=enting the planned response have been identified.
Cerrective Action. None D. A standard e=ergency classification and ' action level sche =e whose bases include f atility syste= and ef fluent parameters is in use by the nuclear facility licensee, and State and local response plans call for reliance on infor=ation provided by facility licensees for deter =inations of =ini=um initial offsite response =easures.
Corrective Action. None E. Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of e=ergency personnel by all response organizations; and content of initial and followup
=essages to response organizations and the public have been established; and
=eans to provide early notification and clear instruction to the pcpulace within the plume exposure pathway E=ergency Planning Zcne have been established.
e!
4 Corrective Action:
~
s, 1. The technical specifications for the design and =aintenance of i~ the proposed warning syste= should be suh=itted for preliminary review and approval by FEMA.
- 2. Pagers should be previded for alerting key County response personnel.
- 3. A reliable co==unications link consisting of both a two-way radio '
capability and a dedicated telephone line cust be established between the EOC and the two E=ergency 3roadcast System stations. Co==unications lines to both radio station KVIC and radio , station KSLY are required in order to provide full 24-hour coverage. Also, an agreement between the two radio stations and San Luis Obispo County regarding disse =ination of e=ergency instructions to the public needs to be for=ulated.
- 4. The public warning syste= cust be co=pleted and operational in accordance with the NRC established deadline.
F. Provisions exist for pro =pt ce==unications a=ong principal response organizations, to emergency personnel and to the public.
Corrective Action:
The County radiological monitoring tea = =e=bers should be supplied
., with radios to establish a direct co==unications_ link to the County Unified
(' Dose Assess =ent Center Supervisor. - - -
t G. Infor ation is made available to the public on a period basis on how they would be notified and what their initial actions should be in an e=ergency (e.g. listening to a local broadcast station and re=aining indoors') che principal points of contact with the news =edia for disse =ination of infor=a-tion during an e=ergency (including physical location or locations) are estab-lished in advance; and procedures for coordinated dissemination of infor=ation l to the public are established.
l Corrective Action:
1 l
< The public infor:stion progra= req;1 red under this planning objective l cust be carried out to ensure that e=ergency response instructions are =cde available to both resident and transient populations.
- h. Adequate erergency facilities and equip =ent to support the e=ergency response are provided.
[ Corrective Action:
I
- 1. The additional telephone capability needed for operations in the EOC should be established and those lines should be installed.
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._ 2. The ECC should have a backup power source to ensure continuing
- 3 operations under conditions of a co==ercial power failure.
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- 3. Develop and install a systen that will allow the cities involved in the plu=c exposure zone to be kept infor=ed of the deve, loping situation frc=
the EOC.
I. Adequate methods, systems, and equip =ent for assessing and =onitoring actual or potential offsite consequences of a radiological e=ergency condition are in use.
Corrective Action. None J. A range of protective actions has been develcped for the plu=e exposure EPZ pathway for emergency workers and the public, guidelices for the choice cf protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway E?Z appropriate to the locale have been developed.
Corrective Action. None K. Means of controlling radiological exposures, in an emergency, are established for workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA E=ergency Worker and Lifesaving Activity Protective Action Guides.
~
4 .
s Corrective Action:
Provisions =ust be made for the distribution of dosimeters, both self-reading and permanent record devices, to e=ergency workers. .This equip-ment should be per=anently located in the County.
L. Arrange =ents are made for medical services for contaminated injured individuals.
Corrective Action. .None M. m.r,enstyTEAIX.antorgcrirics)%m.digieArrpuiMit!%NpMdh me= - x , e . = , - x. c .. - ~.mur.m - - -
TW!?RImuse-Actf&gJbiiqd uw:nz 2 mw a. "
N. Periedic exercises are (will be) conducted to evaluate =ajor portions of e=ergency response capabilities, periodic drills are (vill be) conducted to develop and =aintain key skills; deficiencies identified as a result of exercises or drills are corrected.
Corrective Action:
The annual drill and training schedule for the County should be estab-lished and activities under that schedule begun.
6 -
O. Rediological emergency response training is provided to those who may be called upon to assist in an emergency .
Corrective Action. (SeeparagrapbN.above.)
P. Responsibilities for plan develop =ent and reviev'and distribution of e=ergency plans are established and planners are properly trained.
Cctrective Action. None Attach =ents 2 FEP.A Rgn IX & RAC Plan -
Review--San Luis Obispo Co.
California OES Training and D:ill Ltr & S-hedule 1
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