ML20042F246

From kanterella
Jump to navigation Jump to search
Forwards D Kwiatkowski Transmitting FEMA Region IV Rept for 891206 Full Participation Exercise at Plant. Deficiencies Identified Corrected in 900117-18 Remedial Exercise
ML20042F246
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 04/27/1990
From: Collins S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Withers B
WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 9005080045
Download: ML20042F246 (3)


Text

w-[.

)

1 In Reply Refer To:

M 27 E Docket: STN 50-482 Wolf Creek Nuclear Operating Corporation ATTN:

Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlemen:.

I Enclosed is a letter from Dennis Kwiatkowski of the Federal Emergency _

Management Agency (FEMA) dated March 22, 1990, transmitting to NRC the FEMA Region VII report for the December 6, 1989, full participation exercise at Wolf Creek Generating Station.

The letter contains the FEMA evaluation report

~

of the. state and local radiological emergency response demonstrated during the exercise. The state of Kansas and Coffee County fully perticipated in the exercise.

Franklin and Allen Counties partially participated. There were eight deficiencies identified during the exercise.

The deficier.t.ies involved inadequate emergency broadcast system messages, inadequate dernonstration of the Joint Radiological Monitoring Teams, and failure of Franklin and Allen Counties to perform shift changes. All of the deficiencies were corrected in the January 17-18, 1990, remedial exercise.

No response to the NRC is required.

If you have any further questions,' please i

contact Dr. D. Blair Spitzberg at (817) 860-8191.

Sincerely, 1

l Original Signad D7.

Samuel J. Collins, Director Division of Reactor Projects

Enclosure:

As stated l

cc w/out enclosure:

Program Manager FEMA Region 7 911 Walnut Street, Room 200 Kansas City, Missouri 64106 RIV:SEPS k C:SEPS D:DRSS' D-pPowers{v}a BBeachq S

1 Spitzberg/ sir

/g/90 ts\\

k 6/90

[

g/p/90 4/g/90

,(

9005080045 900427

_ y1r ADOCK0500g2 DR qv F

Wolf Creek Nuclear Operating Corporation !

I cc w/ enclosure:

Wolf Creek Nuclear Operating Corp.

ATTN: Gary Boyer, Plant Manager P.O. Box 411 i

Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge ATTN: Jay $11 berg, Esq.

1800 M Street, NW Washington, D.C.

20036 i

Public Service Commission ATTN: Chris R. Rogers, P.E.

Manager, Electric Department P.O. Box 360 Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission ATTN: Regional Administrator, Region III I

799 Roosevelt Road Glen Ellyn, Illinois 60137

. Wolf Creek Nuclear Operating Corp.

ATTN: Otto Maynard, Manager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 1

Kansas Corporation Commission ATTN: Robert Elliot, Chief Engineer Utilities Division-4th Floor - State Office Building Topeka, Kansas 66612-1571 Office of the Governor State of Kansas l

Topeka, Kansas 66612 Attorney General 1st Floor - The Statehouse Topeka, Kansas 66612 Chairman, Coffey County Commission Coffey County Courthouse Burlington, Kansas 66839 t

f k

3 Wolf Creek Nuclear Operating Corporation,

Kansas Department of Health and Environment Bureau of Air Quality & Radiation Control ATTN: Gerald Allen, Public Health Physicist Division of-Environment Forbes Field Building 321 Topeka, Kansas 66620 U.S. Nuclear Regulatory Commissi,n

-ATTN:

Senior Resident Inspector i

P.O. Box 311 Burlington, Kansas 66839

.U.S. Nuclear Regulatory Commission 4

ATTN:

Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 bec to DMB (A045) i bec distrib, by RIV w/ report:

i Resident Inspector Inspector i

D. Pickett, NRR Project Manager Emergency Preparedness Section File RIV File bec w/o report:

R. Martin B. Beach D. Powers Project Engineer DRP/D DRP MIS System C. A. Hackney R. Erickson, NRR L

l l

l

w fy Federal Emergency Management Agency Washington, D.C. 20472

'I4il 2 ;

Mr. Frank J. Otegel Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Oczmaission Washington,: DC 20555

Dear Mr. CorxJel:

Enclosed is a copy of the exercise report for the December 6,1989, exercise of the offsite radiological amargency response plans, site-specific to the Wolf Creek Generating Station. 'Ihe State of Kansas and Coffey County participated fully in the exercise. Lyon, Franklin and Allen Counties participated partially in the exercise.

The report was. prepared by Region VII of the Federal Emergency Management Agency.

Eight deficiencies and 27 Areas Requiring Corrective Action (ARCA) were identified during this exercise for the State of Kansas and the participating counties. All eight deficiencies plus eight ARCAs were adequately detier-Lcated at the ran=hl exercise on January 17-18, 1990.

Based on the remedial actions taken by the State of Kansas, FDR considers that offsite radiological emerge.Ty preparedness is adequate to provide reasonable assurance that appropriate measures can be taken offsite to i

protect the health and safety of the public.living in the vicinity of the site, in the event of a radiological emergency. 'Iherefore, the approval of i

the offsite plans for the State of Kansas, site-specific to the Wolf Creek i

Generating Station granted under 44 CFR 350 on April 4, 1989 continues to be j

i in effect.

If you have any questions, please feel free to call me on 646-2871.

Sincerely, l

( c:y

.c k (A y

\\

-(DennisH.Kwiatkowski

[,

Assistant Associate Director office of Natural and Technological l

Hazards i

M osure A aA L1 A f th %U fy-L i

.__ _.. ~. _ - _ _ _____-_ _ _

0-s l

i 1

ETALUATION OF TME IMPLEMENTATION OF STATE AND LOCAL EADIOLOGICAL EMBESENCY RESPONSE PLANS j.

BEERCISE CONDUCTED DECEMBER 6, 1989 f

l-AND I

l REMEDIAL EEERCISE CONDUCTED JANUARY 17-18, 1990 for the i

r WOLF CREEE GENERATING STATIOW Burlington, Coffey County, Esasas PARTICIPANTS State of Kansas ceffey County Allen County Lyon County Franklin County February 16, 1990

.i prepared by s

Federal Emergency Management Agency Region VII til Walnut Street, Room 200 Kansas City, Missouri 64106 Jerome D. Overstreet, Regional Director Ah A

^5 3

($ Rg A

?

A L,

_\\

( v v T uo ns ]

1]

i-1

}

1 OONTENTS j

i i

ABEREVIATIONS AND ACIONYNS..................................

iii EEERCISE

SUMMARY

vii i

i INTRODUCTION.............................................

1 1.1 Exercise Background.................................

1 1.2 Exercise Evaluators.................................

2 1.3 Evaluation Criteria.............................

3 1.4 Exercise Objectives.............................

3 1.5 Exercise Scenario...................................

14 1.6 State and Local Resources...........................

16 2

EEERCISE EVALUATION......................................

18 i

2.1 Kansas State Operations.............................

18 2.1.1 State Emergency Operations Center............

18 2.1.2 Emergency Operations Facility................

23 2.1.3 Dose Assessment and Field Team Coordination..

25 j

2.1.4

?orward Staging Area.........................

28 2.1.5 Joint Radiological Monitoring Teams......:...

31 2.1.6 State Radiological Laboratory (RADLAB).......

36 2.1.7 Information Clearinghouse....................

39 2.1.8 Media Release Center.........................

42 2.2 County Operations.................................

45 2.2.1 Coffey County Escrgwncy Operations Center....

45 2.2.2 Coffey County Road & Bridge Department.......

49 2.2.3 Medical Coffey County Hospital,-Burlington.

52 Medical:

Lyon Count 2.2.4 Emporia.............y Ambulance Service, 53 2.2.5 Unified School District #243,. Waverly........

54 2.2.6 Allen County Reception & Care Center.........

56 2.2.7 Franklin County Reception & Care Cer.ter......

57 2.2.8 Lyon County Reception & Care Center..........

57 3

SUNNARY OF DEFICIENCIES AND AREAS REQUIRING CORRECTIVE ACTION..................................................

62 4

RENEDIAL REERCI83........................................

67 s

4.1 Kansas State Operations.............................

67 4.1.1 State Emergency Operations Center............

67 4.1.2 Joint Radiological Monitorin Coffey County Operations...........g Teams..........

68 4.2 74 4.2.1 Coffey County Emergency Operations Center....

74 4.2.2 Allen County Reception and Care Center.......

75 4.2.3 Franklin County Reception and Care Center....

75 i

t 11

ABBRBYIATIONS AND ACRONYNS ACOTs Analog Channel Operational' Tests ANL Argonne National Laboratory ARC American Red Cross ARS (Kansas) Administrator, Radiological Systems ASRAM Assistant State Radiological Assessment Manager ASTRA Automatic Statewide Telecommunications and Records Access CCEOC Coffey County Emergency Operations Center CCP Centrifugal Charging Pump CVCS Chemical and Volume Control System DOC U.S. Department of Commerce DOE U.S. Department of Energy DOI U.S.

Department of Interior DOT U.S. Department of Transportacion EBS Emergency Broadcast System EMT Emergency Medical Technician EOC Emergency Operations Center EOF Emergency Operations Facility EPA U.S. Environmental Protection Agency l

EPC (County) Emergency Preparedness Cooroinator EPZ Emergency Planning Zone FDA U.S.

Food and Drug Administration FEMA Federal Emergency Management Agency FHNWR Flint Hills Mational Wildlife Refuge FNARS FEMA National Radio System 111

.. ~ _

i FNATS FEMA National Teletype Systen FSA Forward Staging Area l

GE General Emergency I

GM Geiger - Mueller (Survey Instrument)

GM Guidance Memorandum gpa

. Gallons Per Minute NHS U.S. Department of Health and Human Services HP Health Physicist IC Information clearinghouse i

IEC Instrumentation & Controls INEL Idaho National Engineering Laboratory IPZ Ingestion Planning Zone JRMT

.Toint Radiological Monitoring Team JRR John Redmond Reservoir KCPL GO Kansas City Power and Light General Office KDHE Kansas Department of Health and Environment KDOT Kansas Department of Transportation KHP Kansas Highway Patrol KNG Kansas Army National Guard KNGA Kansas Army National Guard Aviation Section KI Potassium Iodide i

KWP Kansas Wildlife and Parks LOCA Loss of Coolant Accident MARS Military Affiliated Radio System pCi Microcuries I

mR Millirem l

iv i

. ~..

~

MRC Media Release Center MSIV Main Steam Isolation Valve NRC U.S. Nuclear Regulatory Commission j

NUE Notice of Unusual Event NUREG-Criteria for Preparation and Evaluation of Radiological 0654 Emergency Response Plans and Preparedness in Support of Nuclear Power

Plants, NUREG-0654, FEMA-REP-1,-Rev. 1 (1980)

PAB Protected Area Boundary PAG Protective Action Guide PAI Protective Action Instruction PAR Protective Action Recommendction PDP Positive Displacement Pump PHS U.S. Public Health Service PIO Public Information Officer psig Pressure Per Square Inch Gauge R&C Reception and Care RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Services RADCON State Radiation Control Team RADLAB State Radiological Laboratory I

RCS Reactor Coolant System RHR Residual Heat Removal i

RMS Reactor Coolant System SAE Site Area Emergency SDAS State Dose Assessment Supervisor SDEP Kansas State Division of Emergency Preparedness SEOC State Emergency operations Center 1

v 1

SIP Safety Injection Pump SOP Standard operating Procedure SRAM Statr Radiological. Assessment Manager I

SS Shift Supervisor TLD Thermoluminescent Dosimeter TSC Technical Support Center USD Unified School District USDA U.S.

Department of Agriculture WCGS Wolf Creek Generating Station WCNOC Wolf Cre'ek Nuclear Operating Corporation I

4 I

1 vi

BIERCISE

SUMMARY

1 The purpose of an exercise is to determine the ability of appropriate offsite agencies to respond to an emergency covered by state and local Radiological Emergency Response Plans.

The evaluation of such an effort will, of necessity, tend to focus on the negative aspects of the exercise, on inadequacies in plan-ning, preparedness and performance.

i This focus of attention on the negative should not be taken to mean that there were not a great many positive accomplish-

ments, as well.-

Indeed,1there were; however, in the interest of brevity, only inadequacies will herein be summarized.

)

FEMA classifies exercise inadequacies as deficiencies ~c ar-eas requiring corrective action.

Definitions of these categuales i

follow.

Deficiencies are demonstrated and observed inadequacies that I

would cause a finding that offsite emergency preparedness was not

.i adequate to provide reasonable assurance that appropriate protec-tive measures can be taken to protect the health and cafety of the public living in the vicinity of a nuclear power-facility in the event of a radiological emergency.

Areas reauirina corrective action are demonstrated and ob-t served inadequacies of State and local-government performance, and although their correction is required, they are not consid-

ered, by themselves, to adversely impact public health and safety.

In addition, FEMA identifies areas recommended for imorove-

ment, which are problem areas observed during an exercise that are not considered to adversely impact public health and safety.

While not

required, correction of these would enhance an organization's level of emergency preparedness.

l It should be noted that there is a' distinction between fail-ure to' fully demonstrate an objective and the declaration of an inadequacy.

Limitations imposed by an exercise scenario, or the choice of one response option over another, could preclude a full demonstration, yet, not necessarily constitute an-inadequacy.

KANSAS OPERATION 8 During this exercise, eight deficiencies,-twenty-seven areas requiring corrective action, and four areas recommended for im-i provement were identified for the State of Kansas.

Deficiencies, the most serious of the inadequacies, are sum-marized for Kansas, as follows:

vii m

~+

.-,m

l I

i Coffev County Emersanov onerations Center (CCBOC) 1.

The CCEOC drafted and released, to the ~SEOC, inadequate Emergency Broadcast system (EBS) messages for dissemination of public emergency information.

These messages were inad-equate in the following respects:

a) evacuation messages failed to identify evacuation routest b) the public was di-rected to Reception and Care Centers based upon the i

emergency planning rone subarea in which they reside, how-l

ever, these subareas were not described in terms of local landmark descriptions for each Reception and Care Center; c) the public was not informed of the Reception and Care Center l

to which school children had been evacuated;. and d) the EBS message erroneously informed the public of hospital and nursing home evacuations when no such facilities were im-pacted.

The State of Kansas was notified on December 14, 1989 that,

[

as a remedial action, adequate coordination, formulation and

~

dissemination of public information instructions, Objective-Number 13, was to be demonstrated at a remedial exercise prior to February 4, 1990.

At the January'17-18, 1990 reme-dial exercise, the CCEOC adequately demonstrated Objective Number 13, thereby correcting this deficiency.

state amaraoney onorations center isEOc) 2.

The SEOC failed to correct inadequate EBS messages generated by the CCEOC, which resulted in inadequate instructions be-ing issued to the public.

At the January 17-18, 1990 remedial exercise, the SEOC ad-equately redemonstrated Objective Number 13; coordination, formulation, and dissemination of public informatien in-s structions, thereby correcting this deficiency.

Joint Radiolocical Monitorina Teams (JRMTs )

I The JRMTs provided an inadequate demonstration of their role by using only one of the two evaluated teams to define and track the plume.

More specifically, this demonstration're-sulted in four deficiencies, numbers 3 through 6, for the JRMTs.

3.

One field team demonstrated the appropriate equipment and procedures for determining field radiation measurements with t

j the exception that during the field radiation process, mea-l surements of gamma were made at about one meter (waist level), but were not made at 2 cm (near ground level) to de-termine groundshine.

The second team did not demonstrate this capability.

viii e

e.

---m-

i l

At the January 17-18, 1990 remedial exercise, both field i

teams demonstrated appropriate equipment and procedures for i

determining field radiation measurements, thus correcting i

this deficiency.

4.

One field team demonstrated the appropriate equipment and i

L procedure for -the collection of an airborne radioiodine l

sample in the presence of noble gases.

However, te;tm mem-bars did not fully comply with the Plan in that they did not t

aspirate the cartridge prior to counting it with an HP-210 probe.

Analysis of the sample (i.e.,

conversion of field count rate on the cartridge to radiciodine concentration in air) was done by dose assessment personnel at the EOF in ac-cordance with procedures.

The second team did not demonstrate this capability.

At the January 17-18, 1990 remedial, both field teams demon-strated the appropriate equipment and procedures for the mea 9urement of airborne radioiodine concentrations as low as 10 microcurie per cc in the presence of noble gases.

This

,i redemonstration corrected this deficiency.

S.

Neither team demonstrated the ability to obtain samples of particulate activity in the airborne plume and promptly per-

+

form laboratory analysis, one team partially. demonstrated this objective by taking an air sample.

However, they did not package the particulate filter, nor dispatch it for transport to a laboratory for analysis.

The second-team did not demonstrate this capability.

l At the January 17-18, 1990 remedial exercise, both field teams adequately demonstrated the ability to obtain samples

{

of particulate activity in the airborne plume and promptly perform laboratory analysis.

This demonstration included transfer of samples to a courier and corrected the defi-ciency.

6.

Neither team fully demonstrated a shift. change required for demonstration in 1989.

This failure caused the JRMTs to ex-i caed the six year requirement imposed by NUREG-0654, as redefined in Guidance Memorandum (GM) PR-1.

One team partially demonstrated this objective by a

shift change of the County team member only.

The second team did not demonstrate this capability.

In order to obtain full j

credit for a shift change for objective Number 34, four teams were required to fully. demonstrate field team op-

erations, two teams in the first shift and two teams in the i

second shift.

All three members of each team were required to demonstrate the shift change.

L L

ix

. = -.

." =

e At the January 17-18, 1990 remedial exercise, each team in both shifts demonstrated objectives Number 4, 6,

7, 8,

9, 16, 27, and 34.

This demonstration corrected this defi-ciency.

111eg county Reception and care center 7.

Allen County failed to perform a shift change required for demonstration by 1989.

This failure caused this facility to exceed the six year limit imposed by NUREG-0654, as rede-fined in Guidance Memorandum (GM).PR-1.

Allen County successfully demonstrated the ability to per-form a

shift change at the January 17-18,

,1990 remedial exercise when second shift facility leaders were finally in-tarviewed by FEMA evaluators.

This interview corrected this deficiency.

Franklin county Recention and care 8.

Franklin Co?inty failed to perform P shift change required for demonstration by 1989.

This failure caused this facil-ity to exceed the six year limit imposed by NUREG-0654, as redefined in Guidance Memorandum (GM) PR-1.

Franklin County successfully demonstrated the ability to perform a shift change at the January 17-18, 1990 remedial exercise when second shift facility leaders were finally in-tarviewed by FEMA evaluators.

This interview corrected this deficiency.

As previously stated, twenty-seven areas requiring correc-tive action (ARCAs) were identified during the Wolf Creek exercise and are summarized as follows:

Two ARCAs were identified at the Stoc.

In the first in-

stance, the SEOC Communications Center failed to distribute an EBS release to the staff after public release of that message.

t The second concern arose when the backup communication system with the utility failed.

Dose Assessment and Field Team Coordination experienced two ARCAs.

In one, the Cose Assessment and Field Team Coordination personnel failed to record the implementation of a protective ac-tion on the status board and logs for 40 minutes.

In the other, the initial protective action recommendation was released to the County by the utility, without consultation / coordination with State representatives at the EOF.

At the State Forward Staging Area (FSA),

four ARCAs were identified.

The first ARCA resulted from intermittent telephone and radio communications, the second ARCA occurred when FSA per-(

x

sonnel were equipped with only a low range dosimeter.

TLDs and film badges were available but not distributed.

The third ARCA occurred when KI was not provided to the Kansas Highway Patrol (KHP).

The fourth ARCA was identified when the KHP monitoring instrument was out of calibration.

J Ten ARCAs were identified in evaluating the Joint Radio-logical Monitoring Teams.

Eight of the 10 were corrected at the s

remedial exercise of January 17-18, 1990.

j Teams failed to wear anti-contamination clothing.

This ARCA was corrected at the January 17-18, 1990 reme-I dial exercise, when tease demonstrated availability and correct procedures for donning and doffing.such cloth-ing.

}

Dosimeters prepared for JRMT use were charged and I

recorded as reading zero, vtan'some read as high as 180 mR.

The correct preparatisa and recording of dosimetry was demonstrated at the January remedial exercise, cor-recting the ARCA.

.1 Team 1 read and recorded dosimetry values only once during the entire exercise.

At the January remedial ex-ercise team members on all teams recorded their dosimetry readings at appropriate intervals, correcting l

the ARCA.

J Team 1 members were unaware of where vehicle decon-tamination was available.

This ARCA Was not corrected at the remedial exercise and remains to be corrected at the next exercise.

Team members did not know their radiological dose limits.

This ARCA was corrected at the January remedial i

exercise when all team members demonstrated-knowledge of J

l their limits.

i Team 2 failed to demonstrate the availability of

{

all necessary equipment for field sample taking.

As an

example, this team did not demonstrate that they had 1

)

preservative, coolers, scoops, shovels, clippers, fun-

nels, etc.

This ARCA was corrected at the January remedial exercise when teams were equipped with all ap-propriate equipment for the taking of' field samples.

Team 1 did not adequately label soil samples.

The team failed to identify the size of the area from which samples were taken (i.e.,

a square meter, or a square

foot, etc.).

Failure to provide sample configuration makes ground deposition determinations impossible.

Team 1

attempted to correct this ARCA at the. January reme-dial; however, labeling of samples was still inadequate l

xi 1

m 4

and remains an ARCA to be corrected at the next exer-cise.

l l

Team 2 did not adequately label vogutation samples.

The team failed to identify the size of the area from which samples were taken (i.e., a square meter, or a

square

foot, etc.).

Failure to provide sample con-i l

figuration makes-ground deposition determinations-t impossible.

Team 2 corrected this ARCA at the January remedial exercise by properly logging, and labeling per-l tinent data, including the correct size of the area from which samples were taken.

Both teams failed to monitor the ground surface at sample locations prior to-taking soil samples.

This omission was corrected at the remedial exercise in January, correcting the ARCA.

i Team 1 failed to follow written procedures for soil sampling by collecting a soig sample 1/2 inch deep from an-area approximately 100 cm.

Soil sampling procedures I

in the Plan and SOPS conflict, in that thgy previde for 2

samples to be from areas of 625 cm or 1 m.

This ARCA was corrected at the remedial exercise.

One ARCA was identified at the State Radiological Laboratory (RADLAB) when the laboratory measured / counted vegetation and soil j

sample aliquots without-reference or documentation of the size of the original sample area, or the portion of that sample which made up the aliquot thet was analyzed.

Two ARCAs were identified at the Information Clearinghouse (IC).

In the first ARCA, the first EBS message was not distrib-uted to-the IC staff for two hours.

The second ARCA resulted from the IC being commanded by the utility Public Information Of-ficer (PIO) rather than the State PIO, as specified in the Plan.

Two ARCAs were observed at 'the Media Release Center (MRC).

l In the first ARCA, MRC staff were unable to provide; the media with the protective action area boundaries, :using a

map, and

)

failed to follow-up on media requests for further information.

The second ARCA resulted when the utility assumed the lead at the media briefings in conflict with the State Plan.

Two 'ARCAs were identiflad at the CCEOC:

the first when dosimetry was not issued to CCEOC staff and the second when per-sonnel dispatched from this facility did not know their radiological exposure limits.

Two more ARCAs were discovered at the Unified School Dis-trict #243, Waverly.

The bus driver was unaware of how and where KI would be made available to him, and he carried only a 0-200 mR dosimeter and TLD, having no mid or high range dosimeter.

xii

~

1 l

1 IntnODDCt10E 1.1 EXERCESE BACKGROUND

'On December 7,

1979, the President directed the Federal Emergency Management Agency (FEMA) to assume lead responsibility I

for all offsite nuclear planning and response.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

Taking the lead in offsite emergency planning and in the i

review and evaluation of radiological emergency response i

plans developed by State and local governments.

  • Determining whether such plans can be implemented on-the l

basis of observation and evaluation of' exercises of the j

plans conducted by State and local governments.

  • Coordinating the activities of the following Federal agen-cies with responsibilities in the_ radiological emergency planning process:

- U.S. Department of Commerce (DOC)

- U.S. Nuclear Regulatory Commission (NRC)

- U.S. Environmental Protection Agency (EPA)

- U.S. Department of Energy (DOE)

+

- U.S. Department of Health and Human Services (HHS)

- U.S. Food'and Drug Administration (FDA)

- U.S. Public Health Service (PHS)

- U.S. Department of Transportation (DOT)

- U.S. Department of Agriculture (USDA)

-U.S. Department of the Interior (DOI)

Representatives of these agencies serve as members of the Regional Assistance Committee (RAC), which is chaired by FEMA.

Formal submission of the radiological emergency response P

plans for the Wolf Creek Generating Station (WCGS) to the RAC by the State of Kansas and affected local jurisdictions was followed t

by a critique and evaluation of these plans.

Formal approval of these plans was granted by FEMA cn April 4,

1989.

A full scale joint radiological emergency preparedness exer-cise was conducted for the WCGS on December 5 and 6,

1989, to assess the capability of State and County emergency. preparedness organizations to:

(1) implement their radiological emergency l

o

. ~. -

.. ~,. _ -

preparedness plans and procedures, and (2) protect-the public during a radiological emergency at the Wolf Creek Generating Sta-tion.

This was the fifth exercise held for the Wolf Creek i

Generating Station since 1984.

In addition,. Kansas and coffey County participated in an off-hours, unannounced drill on Decem-

+

ber 5, 1988.

Following the exercise, an Exit Interview with the State and local governments and the licensee was conducted by the Regional Assistance Committee (RAC) Chairman to discuss the results of the exercise.

A public critique of the exercise for the participants l

and the general public was held jointly by the RAC Chairman and a representative from the Nuclear Regulatory Commission on December 7,

1989.

+

1.2 Exercise Evaluatota Eighteen Federal agency personnel and five FEMA contract I

staff evaluated offsite emergency response functions:

OBSERVER AGENCY ASSIGNMENT Robert Bissell FEMA Coffey County EOC Marlee Carroll FEMA Kansas State EOC Lee Clark FEMA Kansas State EOC Bobby Dillard HHS/FDA Coffey County EOC Bob Dye EPA Dose Assessment & Field Team l

Coordination John Elbert HHS/PHS Coffey Co. Hosp./Lyon Co. Amb.

Jon Furst FEMA USD #243, Waverly / Overview l

Steve Harrell' FEMA Emergency Operations Facility Dewey Johnson FEMA Kansas State EOC Bill Knoerzer ANL JRMT Joe Keller INEL RADLAB Richard Leonard FEMA USD #243, Waverly/ Overview l

Gary McClure FEMA Information Clearinghouse /

Media Release Center i

Diane Money FEMA Coffey County EOC Elizabeth Post USDA Kansas State EOC 1

Ed Robinson ANL Information Clearinghcuse/

3 Media' Release Center Chris Saricks ANL Allen Co., Franklin Co. & Lyon l

Co. R&C's/Coffey County Hosp /

Lyon Co. Ambulance Ron Shaw FEMA Coffey< County Road & Bridge /

Emergency Worker Decon/Lyon Co. AGC Lyle Slagle INEL JRMT(s)

Richard Sumpter FEMA Emergency Operations Facility Neal Voltz FEMA Regional Office Coordination

, - +. - -,.,

c m

i I

\\

Jim Winger FEMA Forward Staging Area /Lyon Co.

i R&C Connie Wisniewski FEMA Coffey County EOC l

1.3 EVALUATION CRITERIA I'

The evaluation criteria for this exercise were:

1 1.

44 Code of Federal Regulations, Part 350.9.

2.

NUREG-0654/ FEMA-REP-1, Rev. 1-(all applicable require-monts).

3.

The Exercise Evaluation Methodology (EEM):

36= Objec-tives identified in FEMA Guidance Memorandum (GM)

EX-3 issued by FEMA as a composite of-exercise demonstrable.

elements contained in NUREG-0654.

A copy-of these ob-1 jectives.is contained in section 1 of this.: report.

These objectives will be referenced by number through-l out the report.

l l

4.

The State of

Kansas, Appendix 12, Nuclear Facilities Incidents Response' Plan to Annex N, Nuclear Emergencies of the State Emergency Operations Plan (Revised April 1989.)

5.

Coffey county Contingency Plan for Incidents Involving Commercial Nuclear Power (Revised December 1988).

6.

Allen County Radiological Energency Response Plan. (Re-vised November 1987).

7.

Franklin County Radiological Emergency

Response

Plan-(Revised August 1987).

8.

Lyon County Radiological Emergency Response Plan (Re-vised November 1987).

1.4 EXERCIBE OBJECTIVES Exercise objectives included full participation for the State of Kansas and Coffey County.

State activities' included the activation of the Radiological Field Monitoring-Teams, Forward Staging Area,.and participation at the Emergency Operations Fa-cility nearsite.-

The Kansas State Emergency Operations

Center, i

Information Clearinghouse, Media Release Center, and-State Radio-logical Laboratory in Topeka were activated to support. the licensee and Coffey County.

The Coffey County Emergency Op-erations, Center and the county Shop were also fully activated.

Lyon County activated its Reception and Care Center.

3

The exercise was intended to demonstrate many, but not nec-essarily all, of the WCGS capabilities to respond to a wide range e

l

,of emergency conditions.

The scenario was designed to activate l

the state and local radiological emergency response plan through their various levels.

The exercise demonstrated a number of pri-l mary ' emergency preparedness functions.

At no time was the t

exercise permitted to interfere with the safe operations of the WCGSr and, the plant management, at its' discretion, could have suspended the exercise for any period of time necessary to ensure this goal..

On September 1,

1989, the State of Kansas submitted formal objectives for State and local jurisdictions for this exercise.

Refined objectives were received on November 24, 1983.

The for-mat of this submission utilized the thirty-six standardized i

objectives previously referred to under Section 1.3 (3.) of this report.

They will be referred to,.by number, throughout

this, evaluation report and are as follows:

State Emergency oneration center (sEOC) 1 OBJECTIVE NUMBER 1

Demonstrate the ability to monitor, understand and use emergency classification levels (ECLs) through the appropriate implementation of emergency func-tions and activities corresponding to ECLs as required by the scenario.

2 Demonstrata the ability to fully alert, mobilize and activate personnel for-both facility and field-based emergency functions.

3 Demonstrate the ability to direct, coordinate and control emergency activities.

4 Demonstrate the ability to communicate with all appropriate locations, organizations and field.

personnel.

5 Demonstrate the adequacy of. facilities, equipment, displays and other materials to support emergency i

operations.

11 Demonstrate the. ability to make appropriate pro-tective action decisions, based on projected or actual dosage, EPA PAGs, availability of adequate

shelter, evacuation time estimates and other rel-evant factors.

4 1'

5 1

12 Demonstrate the ability to initially alert the public within the 10-mile EPZ and begin dissemina-r tion of an instructional message within 15 minutes f

of a decision by appropriate State and/or local official (s).

i 13 Demonstrate tho' ability to coordinate the formulation and dissemination of accurate.informa-tion. and instructions to the public in a

timely fashion after the initial alert and notification has occurred.

I 20 Demonstrate tho' organizationalfability and re-sources necessary to control evacuation traffic flow and to control access to evacuated and shel-tered areas, amaraency onerations Facility (EOF)

OBJECTIVE NUMBER 1

Demonstrate the ability to monitor, understand and use emergency classification-levels (ECLs) through the appropriate implementation of emergency func-tions and activities corresponding to ECLs as required by the scenario.

2 Demonstrate the ability to fully alert, mobilize and activate personnel for both facility and field-based emergency functions.

3 Demonstrate the ability to direct, coordinate and control emergency activities, 4

Demonstrate the ability to communicate with all appropriate locations, organizations and field personnel.

5 Demonstrate the adequacy of facilities, equipment, displays and other materials to support emergency 3

operations.

6 Demonstrate the ability to. continuously monitor and control emergency worker exposure.

11 Demonstrate the ability to make appropriate pro-tective action decisions, based on projected or j

actual dosage,. EPA PAGs, availability of adequate r,helter, evacuation time estimates and other rel-

'~

evant factorr.

i.

L 5

l l

I 16 Demonstrate the ability to make the decision to recommend the use of KI to emergency workers and institutionalized persons, based on predetermined

criteria, as well as to distribute and administer it once the decision is made, if necessitated by radioiodine releases.

Dame asses---at anA pield Tamm enardination OBJECTITT NUMBER __

2 Demonstrate the ability to fully alert, mobilize and activate personnel for both facility and field-based emergency. functions.

3 Demonstrate the ability to direct, coordinate and control emergency activities.-

4 Demonstrate the ability to communicate with all-appropriate locations, organizations and field personnel.

5 Demonstrate the adequacy of facilities, equipment, displays and other materials to support emergency operations.

6 Demonstrate the ability to continuously ranitor and control emergency worker exposure.

10 Demonstrate the ability, within the plume exposure pathway to project dosage to the public via plume exposure, based on' plant and field data, 11 Demonstrate the ability to make appropriate pro-tective. action decisions, based on projected or actual dosage, EPA PAGs, availability of adequate

shelter, evacuation time estimates and other rel-t evant factors.

16 Demonstrate the ability to make the decision to recommend the use of KI to emergency workers and institutiona'.ized persons, based on predetermined

criteria, aus well as to distribute and administer it once the decision is made, if necessitated by radioiodine releases.

6

l I

Forward staging area l

I OBJECTIVE NUNRRR 2

Demonstrate the ability to fully alert, mobilize 3

and activate personnel for both facility and i

field-based emergency _ functions.

l i

3 Demonstrate the ability to direct, coordinate snd' i

control emergency activities.

J 4

Demonstrate the, ability to communicate with all appropriate locations, organizations and field 4

personnel.

l 6

Demonstrate the ability to continuously monitor and control emergency worker exposure.

16 Demonstrate the ability to make the decision-to

.1 distribute and administer KI once the decision is made, if necessitated by radiciodine releases.

20-Demonstrate the organizational ability and re-sources necessary to control evacuation traffic flow and to control access to evacuated and shel-tered areas.

Joint Radioloalcal Monitorine Tem== fJRMTs)

OBJECTIVE NUMBER 2

Demonstrate the ability to fully alert, mobilize and activate personnel for both facility and i

field-based emergency functions.

-1 4

Demonstrate the ability to communicate with all appropriate locations, organizations and field personnel.

6 Demonstrate the ability to continuously monitor l

and control emergency worker exposure.

7 Demonstrate the appropriate equipment and proce-dures for determining field radiation j

measurements, l

8 Demonstrate the appropriate equipment and proce-i dures for the measurement of airborne radioiodine i

l 7

1

~7 concentrations as low as 10 microcurie per cc in

-tho' presence of noble gases.

L 9-Demonstrate the ability to obtain samples of. ' par-ticulate-activity in the. airborne uplume and properly perform laboratory analysis.

16 Demonstrate the ability to make the decision to

.)

distribute and administer KI once the decision ~ is made,.if necessitated by radiciodine releases.-

27 Demonstrate the appropriate use of equipment'.and procedures for collection?and' transport of samples i

l' of vegetation, food crops,. milk, meat,:

poultry, j

water and animal feeds.

34 Demonstrate-the ability to maintain 1staffin'g on' a continuous 24-hour basis by an. actual shift

' change.

4 Radiolocical Laboratory f aim.in)

OBJECTIVE l

NUMBER r

2 Demonstrate 'the ability to. fully alert, mobilize L

and activate personnel for both. facility and i

field-based emergency functions.

L 3

Demonstrate the ability to. direct, coordinate and control emergency. activities.

5 Demonstrate the adequacy of facilities, equipment, displays and other materials to support-emergency operations.

6 Demonstrate the ability to continuously monitor and control emergency worker exposure.

9 Demonstrate the ability to-obtain samples of particulate activity in the airborne plume and properly perform laboratory analysis'.

28 Demonstrate the appropriate lab operations and procedures for measuring and analyzing-samples of vegetation, food crops, milk, meat poultry, water and animal feeds.

34 Demonstrate the ability to maintain staffing on a

continuous-24-hour basis by an actual shift change.

8

zg 1

Information Clearinghouse (IC) i OBJECTIVE NUMBER 1

- Demonstrate the' ability.to monitor,. understand and use emergency. classification: levels (EClm) through the appropriate' implementation of emergency func-tions and activities corresponding to ECLs as required by the scenario.

2 Demonstrate the ability _tol fully alert,. mobilize

)

and activate _ personnel for both facility and field-based'energency: functions..

3 Demonstrate the' ability to direct, coordinate land.

control emergency. activities.

4 Demonstrate the ability to communicate with all f

appropriate. locations, organizations and-field personnel.

5 Demonstrate the' adequacy of facilities,_ equipment, displays and other materials to support emergency 3

operations.

14 Demonstrate' - the ability to_briefitho' media in.an accurate, coordinated and timely manner.

15 Demonstrate. the ability to establish and operate rumor control in a coordinated and timely fashion.

Media Release Center (MRC)

OBJECTIVE NUMBER 1

Demonstrate the ability to monitor, understand and use emergency classification' levels ~ (ECLs) through the appropriata= implementation

~ of

' emergency functions'and activities corresponding to ECLs as required by the scenario.

2 Demonstrate the ability to fully alert, mobilize and activate personnel

.for' both facility 'and field-based emergency functions.

3 Demonstrate the ability to direct,- coordinate and control emergency. activities.

i-

'l 9

4

-.--m-+

-r,,

air g

gy y9-ece

n 4

Demonstrate the ability to communicate with all appropriate locations, organizations: and field personnel.-

5 Demonstrate the adequacy of facilities, equipment,.

displays and other materials to' support emergency operations.

t 14 Demonstrate the ability to brief the media in an accurate, coordinated and timely manner.

i p

15 LDemonstrate' the ability to establish and. operate-rumor control in a coordinated and timely fashion.

coffev county Emeraency onerations center fccBoci OBJECTIVE' NUMBER

+

1 Demonstrate the'~ ability to monitor, understand and use emergency' classification levels. (ECLs); through the appropriate implementation of emergency func-tions and-- activities corresponding to ECLs as l_

required by the scenario.

[

1:

2 Demonstrate the ability to fully alert, mobilize

~

and activate personnel.for both facility-and field-based emergency functions.

3 Demonshrate the ability to direct, coordinate and control emergency activities.

4 Demonstrate-the ability to communicate with all' appropriate locations, organizations and field personnel.

i 5

Demonstrate the adequacy of facilities, equipment, l

displays and other materials'to support emergency operations.

6 Demonstrate the ability to continuously monitor and control emergency-worker exposure.-

J 11 Demonstrate the ability to make appropriate pro-i tective action-decisions, based on projected-or actual dosage,' _ EPA PAGs, availability ofiadequate.

4

shelter, evacuation time estimates and_other rel-evant factors.

I 12 Demonstrate the ability to initially alert the l

public within the 10-mile EPZ and begin dissemina-c 10

.m

+;

y

" a tion'of an instructional message within 15 minutes-0 of' a decision by appropriate ~ State and/or local official (s).

13

Demonstrate the' ability to coordinate the. formula-i tion and dissemination of accurate information and i

instructions to the public:in a timely fashion af-ter the initial- ' alert and notification-has occurred.

16 Demonstrate the ability to make the decision to, distribute and administer KI.once the decision is made, if necessitated by radiciodine releases...

18 Demonstrate the ability and resources necessary to' implement appropriate protective actions for the impacted-permanent; and transient. plume EPZ population. (including. transit-dependent : persons, I

special needs populations, handicapped persons and institutionalized persons).

19 Demonstrate the. ability-and resources necessary to implement appropriate protective actions for school children within'the

?.t, EPZ..

4 20 Demonstrate the organiza*'vu.

dbility. and' re-sources necessary to contro; w;cuation traffic flow and to control access te u<acuated and shel-tered areas.

Coffav County Road and Bridae Denartment OBJECTIVE NUMBER I

O Demonstrate the ability to fully ~ alert,- mobilize and activate personnel for 'both-facility and field-based emergency functions.

l 3

Demonstrate the ability,tx) direct, coordinate and L

control emergency: activities.

4 Demonstrate.the ability.ta) communicate with. all appropriate locations, organizations and field personnel.

5 Demonstrate.the adequacy of facilities, equipment,.

l L

displays and other materials to support emergency operations.

6 Demonstrate.the ability to continuously monitor and control emergency worker exposure, i

11

l l

1 12 Demonstrate tho' ability to initially alert-the i

public within the 10-mile EPZ and begin dissemina-tion of an instructional message within 15 minutes of a decision by appropriate state and/or local i

official (s).

16 Demonstrate the ability to make the. decision to distribute and administer KI once-the decision 'is J

made, if necessitated by radioiodine releases.

18 Demonstrate the ability and' resources necessary to implement appropriate protective actions-for the impacted permanent and transient plume EPZ_popul,a-L tion (including transit-dependent persons,.special

)

l needs populations, handicapped persons and insti-tutionalized' persons).

20 Demonstrate.the. organizational ability and re-

. sources.necessary to controlL evacuation -traffic flow and to control access to evacuated and. shel-I tered areas.

25 Demonstrate the adequacy of facilities, equipment,

supplies, procedures and personnel for decon-i I

.tamination of emergency workers,. equipment-and vehicles and for waste disposal.

Medical:

Coffev County Hosnital, Burlinaton OBJECTIVE NUMBER 6

Demonstrate.the ability to continuously monitor i

and control emergency worker exposure.

24 Demonstrate the. adequacy of medical facilities equipment, procedures and personnel for handling

~

contaminated, injured or exposed individuals.

i Medical:

Lyon County A=hulance Service, Emnoria L

OBJECTIVE NUMBER 4

Demonstrate the ability to communicate with all appropriate locations, organizations and field personnel.

6 Demonstrate the ability to continuously monitor and control emergency worker exposure.

12 i

n:

.b

[

y i

16 Demonstrate the ability to make the. decision to distribute and administer KI-once the decision-is made, if necessitated.by radioiodine releases.

23 Demonstrate the adequacy of vehicles, equipment, procedures, and-personnel for transporting con-taminated,' injured'or exposed individuals.

Unified school-District #243.=Waveriv 4

OBJECTIVE NUMBER 4

Demonstrate the ability to communicate with all appropriate locations,- organizations and ' field personnel.

1 6

Demonstrate -the~ ability to continuously-monitor and control emergency worker exposure.

j 16 Demonstrate the ability to make the decision.to distribute and: administer KI.once-the decision is made, if necessitated by radioiodine releases.

19 Demonstrate the ability and resources necessary to

'{

~

' implement appropriate protective actions for school children within the plume EPZ.

4 Allen County Recention and Care Center i

OBJECTIVE NUMBER 34 Demonstrate the ability'to maintain = staffing on a

continuous 24-hour basis, by an actual shift change.

Franklin County Reception and Care Center OBJECTIVE NUMBER i

21 Demonstrate the' adequacy of procedures,

. facilities, equipment and' personnel for the regis-y

tration, radiological.-

monitoring and L

decontamination of evacuees.

p l

34 Demonstrate the ability to maintain staffing on. a continuous: 24-hour basis by an actual shift change.

13

p Lyon county Recention and care center I

(

l-OBJECTIVE l

NUMBER s

2 Demonstrate the. ability to fully alert,

' mobilize and ; activate personnel for both facility and i

field-based emergency functions.

3 Demonstrate'the ability to direct,.

coordinate and-r control emergency activities..

[

4 Demonstrate the ability to communicate wit'h all' appropriate locations, personnel.

organizations and. field t

t i

6 Demonstrate the ability to continuously monitor i

and control emergency worker exposure, i

21

-Demonstrate tho' adequacy of procedures, fa-i

cilities, equipment and personnel for the registration, radiological monitoring and tamination of evacuees.-

decon-1 22 Demonstrate the adequacy of facilities,. equipment and personnel for congregate 1 care of evacuees.

34 Demonstrate the ability to maintain. staffing.on

.j a

continuous 24-hour basis-by an actual shift

=

change.

1.5 EXERCISE SCENARIO The scenario for'the exercise consisted of:a sequence.of i

events resulting in a. release of radioactivity of sufficient mag-nitude to warrant the declaration of a General Emergency.

This release of radioactivity, or plume,. traveled in a. south-south-easterly direction from the plant into Coffey County.

Protective action recommendations resulted in the evacuation and/or shelter-ing of residents within a portion of the plume exposure pathway

)

emergency planning zone of the plant.

The following narrative summary is an excerpt from the sce-nario submitted by the Wolf Creek Nuclear Operating Corporation (WCNOC).

Initial conditions establish the plan operating at 98%. full power du~e to Instrumentation and controls (I&C)

Analog. Channel Operational Tests (ACOTs) in progress.. Centrifugal Charging Pump A (CCP-A) and the Positive Displacement Pump (PDP) are - tagged out for repairs.

A Health Physics technician-and a Maintenance j

l 14

Fl l

J e-l technician have initiated their routine walkdown tour of the con-

~

tainment building. _ Equipment SHB01.in the-Waste Evaporator Room

- 7204 of the Radwaste-Buildingxis undergoing some welding with'a person standing as fire watch nearby.

At

0745, the welder knocks'over the pump oiler causing an oil spill which is ignited by the welding.

It takes the fire

-watch:about.30 seconds to'act and put out the_ fire on the welder.-

l

(

The welder suffers:2nd and 3rd degree ~ burns to both. hands and l

forearms with first degree burns to his chest.

While reacting to the. fire, the welder contaminated his hands and face.-

TheLCon-trol Room is called-toisend: the Fire Brigade,

_since thes fire.in the room is.still burning, and the Emergency Medical Technicians (EMTs),

for the burn victim.

Coffey County, Ambulance is called by the Control' Room to transport the victin'to Coffey County Hos-pital.

The Shift _ Supervisor.(SS) should= declare a Notification of Unusual Event (NUE).

Offsite notifications are performed i

through the Control Room Shift Clerk.

i At 0815, the Control room receives.a High Rad Alarm on' the Chemical & Volume Control-System (CVCS) letdown monitor.

The SS should request a Reactor Coolant System-(RCS)l sample be drawn.

Thirty _ minutes later_at'0845, he receives the' analysis report from Chemistry which confirms.a significant increase in RCS ac-tivity.. An Alert should be declared due to failed fuel.

Control Room commences to ramp down-power at fapproximately 1/2%

per

minute, but not greater-than:34 per hour.

Offsite notifications are performed by the Control Room.

Nonessential personnel inside the Protected Area. Boundary (PAB) are directed to exit _the Pro-tected Area and assemble in the parking lot.

Essential personnel are directed to their appropriate Emergency Response _ Facility.

The Health Physics / Maintenance Team inside containment is unable to exit through the personnel batch, and goes to the escape hatch to ' exit containment.

During their exit,. the inner hatch door jams open.

The Team is'becoming very concerned due to the-high radiation levels near the hatch because of the' failed fuel.

In their desperation to get.out, they do not carefully check'to'en-sure the outer hatch door latch has completely engaged. _ They report to the control Room that the outer door is. sealed, but the inner door is jammed open.

At 1000, a 5,000 gallons per minute (gpm). Loss of Coolant Acci-dent (LOCA) occurs'.

Reactor and turbine 1 trips occur.

NB-02 experiences electrical faults on four load centers.

' Safety Injection Pump-A (SIP-A). trips.

Residual Heat Removal (RHR)-

Pump-A remains operable _for core cooling.

A Site. Area Emergency should be declared due to the combination of failed fuel and a

RCS breach.

An Exclusion Area Evacuation should be implemented by security.

Offsite notification should occur from the Techni-cal Support-Center (TSC).

The-Emergency Operations Facility (EOF) should promptly assume command and control of the emer-15 J

~.

j gency.

County and atate-Emergency Operations. Centers (EOCs) should activate shortly.

As thel core becomes uncovered, more fuel damage occurs and a

large amount of hydrogen is produced and finally burns creating a very high pressure spike (50 pressure per square inch gauge' (psig))

inside the containment' building.

This pressure = spike damages the outer emergency. hatch door enough to_ create

'a.

sig '

nificant release.

Containment Spray Pump-A breaker trips.

A General Emergency should be-declared based on the' combination of failed

fuel, a RCS leak and a; breach to containment integrity.

All-emergency response facilities are operational._ Offsite-noti-fications are perfermed by-the' EOF.

There'is intense media-and' public interest in the accident.

Rumors include a terrorist

.or-ganization claiming responsibility for the ' accident-and that southwest Coffey. county is:being affected'instead of the -south-east part, j

During the release, a media plane inadvertently flies through the' plume to take several photographs of the plant.

'A.

short. time l

later, the photographer experiences symptoms of congestive heart failure.

The plane-lands at the Coffey County Airport and re-quests an ambulance.

Coffey-County ambulances are responding 1to

, I a

multi-casualty car accident southwest of

Gridley, so- 'Lyon y

County Ambulance responds.

The man'is contaminated-and his con-dition continues'to degrade.

.Lyon County Ambulance takes him to-

- i Coffey County. Hospital immediately.

As the primary system.and containment depressurize, the release is terminated after about 90 minutes..

Plant conditions continue L

to stabilize.-

At 1430, a news helicopter:from a Kansas

City, 1'

L television station crashes near the switchyard.

There are no l

survivors.

1 At approximately 1600, the drill will be terminated.-

Planned Actual Time Event Time 0635 Alert

-0640 0905 Site Area Emergency 0850 l

1135 Radioactive Release 1118 l-(calculated) 1135 General Emergency 1045 1300 Release Terminated

-1315 i.

1600 Exercise Terminated 1505 1.6 STATE AND LOCAL RESOURCES Indicated below 4,

a list of organizations which par-ticipated in the Decemhe-6, 1989 exercise.

l 16 L

4 o

w,-

4

+

.--4

". }

l l

]

State _of 1 Kansas l.

Adjutant General's Department 2.

Division of Emergency Preparedness 3.

Department of Health and Environment =

4~

Highway Patrol n

5.

Department of Transportation L

6.

Board of' Agriculture 7.

National Guard' 8.

-Department of Social and Rehabilitation' Services 9.-

Attorney. General 10.

Department uf Wildlife and; Parks.

coffav County 1.

Emergency Preparedness' Office 2.

Sheriff's Office 3.

Board of Commissioners 4.

County Road and' Bridge 5.-

Health Department 6.

Fire Department 7.

Radiological Department 8.

County Attorney-9.

County Hospital

10. Unified. School' District #243, Waverly Allen County 1.

Emergency' Preparedness Office 2.

Sheriff's Office.

Franklin County i

1.

Civil Defense Office 2.

Sheriff's office Lvon County 1

1.

County Ambulance Service' 2.

Board of Commissioners 3.

Emergency Preparedness Office

-4.

County Attorney 5.

Sheriff's Office i

6.

County Clerk 7.

Boy Scout Troop #157 City of Emooria 1.

Mayor 2.

City Engineer i

l l

l l

17 1

I;

[

2 EXERCISE BVALUATION 2.1 EANSAS STATE OPERATIONS 2.1.1 State Emercenev'Onorations center (SEOC) 3 Objectives to be demonstrated-were:-

1, 2,- 3, 4, 5,.11, 12 ',

~ 13, and 20.

In addition, an area requiring correct.ive action (ARCA) from the 1987 Wolf Creek. exercise,.regarding-Objective

. Number 13-and the' timeliness of follow up_EBS messages,' was'to be t

redemonstrated at this exercise.

y Objectivt Number 1,

,the. ability to monitor,= understand and; use emergency classificationL levels f (ECLs),

. as fully demon-w strated.

ECLs were used,by all staff and were prominently dis-l played in both the operations-and communications: rooms.

Estaff were aware of ECLs and had corresponding procedures for; use !at

-each level..

Objective Number 2, the ability to fully alert,- mobilize and activate personnel for both facility and. field-based emergency functions, was fully demonstrated.

Upon notification of an Un-usual Event, initial staff notificationsLwere made between 0817 and 0820.

.Following declaration of the Alert, three staff mem-3 bers divided the-contact list to assure the:most' rapid notifica-tion -of remaining staff members and accomplished - all calls between 0840 and 0851.

Call lists were current and accurate.

The communications room was staffed by 0841.' All SEOC: staff _were activated and/or dispatched by 1000.

p Objective Number 3, the ability to-direct, coordinate and control emergency activities, was not' adequately demonstrated.

The inadequacy occurred when the SEOC Emergency Broadcast System (EBS)

Coordinator received EBS message number 3'from the Coffey 1

County ECC (CCEOC),

read the message-to theEEBS station and pro-vided a copy for duplication and distribution., However, Communi-t cations. Center staff discarded copies.and did not distribute them to-either the operations room or the Information Clearinghouse (IC).

Operational staff, therefore, were unaware of the changing protective instructions to the public-until-after the release of EBS message number 4.

This is an area requiring corrective.

ac-T tion (ARCA).

In other respects, the Deputy Director of the Kan-sas State Department of Emergency Preparedness (SDEP)

_ was effectively in charge of the emergency response.

Periodic brief-ings were held to. update-staff and. staff-members were included'in i

decision making, as appropriate.

A current copy of_the plan was available.

Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and field personnel, was not 18

-adequately demonstrated.

The_ inadequacy was identified when the SEOC's backup communication' system _to the Emergency Operations Facility (EOF) failed during an' attempt to use a hand-held radio at 1125.

The system which failed was composed of a ' hand-held ra -

dio with a magnetic mount antenna in-the basement of the SEOC.

This fis an ARCA.

FEMA communications personnel suggested _ that adequate-communications would require at;1 east a;25 watt _ base station'with an:outside antenna.

This evaluation confirmed that 18 commercial telephone lines were available for.this facility, including conferencing capabil-t ity.

Available radio' systems: included:. FEMA 7 National ~ Radio Sys-I temc(FNARS),

Kansas Department'of-Transportation-'(KDOT),

. Kansas Army National Guard ~ (FMG), - Kansas Army National Guard Aviation Section (KNGA),_ Military Affiliated Radio-System (MARS) and Radio-Amateur Civil Emergency Services (RACES). -Computerflinkages were established _through FEMA National Teletype System (FNATS) and-Au-tomatic Statewide Telecommunications land Records Access (ASTRA);

i Weather teletype-and a facsimile machine were also available..

Communications traffic was handled without delay, with the exception of,the backup communication' failure mentioned: earlier.

Objective Number.5,.

the adequacy of facilities, equipment, displays and other materials to support emergency. operations, was fully demonstrated.

This facility provided sufficient space,-

furnishings,

lighting, and : ventilation to' - support' emergency operations.

Restrooms wereEadequate and backup power was avail-able.

Additionally, altypewriter, computer / word processor, and copier were provided to support operations.

Twenty-four hour op-erations-were made possible by the availability of lockers, cots

{

and kitchen supplies.

. Access lto the facility was fully. con-trolled.

Staff in this facility used plume exposure emergency plan-ning zone (EPZ) maps which showed appropriate planning areas la-i L

beled, radiological monitoring points and the ingestion planning zone (IPZ) for agricultural'information.

Maps'were also avail-able showing evacuation routes, plume EPZ population by planning e

areas, and relocation centers.

Status boards were updated-immediately and were -positioned for ease of reference.

They identified emergency classification levels -(ECLs), weather data, and both' recommended and actual pro-l tective actions.

. Objective Number 11, the ability to make appropriate protec-tive action decisions, based on projected orLactual dosage,

'U.S.

l l

Environmental Protection Agency'(EPA) Protective Action Guides (PAGs),

availability of adequate shelter, evacuation time esti-mates and other relevant factors, was ful'ly demonstrated.

Kansas Department of Health and Environment (KDHE) discussed protective 19

=

action recommendations (PARS) with KDHE staff,. at the. EOF, as well as with'the Deputy Director,

SDEP, and tho' Kansas State Board of' Agriculture,' at the SEOC.

Protective action decisions were coordinated between the coffey County Emergency Preparedness Coordinator-(EPC),

SDEP Deputy Director,.KDHE,'

and Kansas-State j

Board lof Agriculture.

At 1215, when two additional subzones were l

added-to the previously evacuated drea, the SEOC decided that the plant recommendation,-

placing dairy cattle on-stored. feed out to 10 miles in sectors H, J, and K, should be expanded to sector G.

l t

l They notified the County Agent of the change.

At 1255,

.the SEOC received--the recommendation 1that expanded cattle on stored feed out to 50 miles.

The Kansas State Board of Agriculture personnel l

contacted all affected County representatives to' notify impacted' dairy farmers.

KDHE beganLchegking water supplies at'1034.

At 1310, KDHE requested precautions onl downstream water supplies and: initiated

. calling downstream users..

By 1406, KDHE was reviewing precau-t tions for downstream water ~ supplies beyond 50 miles and had dis-i patched staff to take samples.

A request was made toLthe State Radiological Laboratory (RADLAB) for analysis of'these

samples, which the lab said could be accomplished within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of sample receipt.

At 1445, KDHE set up sampling points on the river at-L Chanute and Woodson and samples were to be taken every.30. min--

utes.

Objective ' Number 12, the ability to. initially alert. the public within.the plume exposure EPZ and begin dissemination of instructional message within 15 minutes of a decision by ap-an propriate State:and/or local official (s), was fully demonstrated.

The first offsite notification was to the'CCEOC at 0927.

The SEOC was notified of the SME at 0930.

At 0931,.

they notified the EBS station.

The.EBS message was to be aired at 0935..

CCEOC contacted at 0932 and instructed to sound-sirens (3 minutes was prior to EBS broadcast).

The tone alert radio at the SEOC. was actually activated at 0937 and carried an EBS test' notification.

The bottom of each message carried'an instruction for each EBS message to be repeated every 15 minutes.

The public notification process was coordinated effectively among involved organizations.

Objective Number 13, the ability to coordinate the formula-tion and dissemination of accurate information and instructions to the public in a timely fashion'after the initial alert and-no-tification had occurred, was not adequately demonstrated.

Following the declaration of a State of Disaster Emergency, the Deputy Director, SDEP, was responsible for the review and/or revision of EBS message content, and the coordination, supervi-

sion, and release of all State and local agency EBS announce-ments.

The Coffey County EPC prepared a draft announcement and transmitted it to the Deputy Director,

SDEP, for review and re-lease.

20

.. _... - -,. -. =.

F1

a. j h

At this exercise, anJinadequacy_was identified at the CCEOC for preparation of inadequate EBS messages.-

'These messages were not corrected by the Deputy Director, SDEP, at,the SEOC prior to release over the EBS station.- As a result, the SEOC released EBS messages which

. ore inadequate in-the following respects:.

a) j w

evacuation messages failed to identify evacuation. routes; b) the j

public-was directed to Reception.and Care Centers based upon the emergency planning zone subarea in.which;they

reside, however, these subareas were not described in terms of local landmark' de-

'scriptions for each Reception and Care Center;- c).the public was not informed of.the ReceptionLand Care-Center to which school L

children had been evacuated; and d) an EBS message erroneously

~

informed the public of hospital and nursing home evacuations when no such facilities were impacted.

c L

The failure by the SEOC to correct these EBS messages was a

deficiency and required a remedial demonstration prior to Febru-

,4 ary 4,

1990.

A remedial exercise was held on January 17-18, 1990, during which this' deficiency was closed.

See Section 4 for the remedial exercise report.

Protective action' instructions for the general public were issued over the ISS station.

Protective action instructions for

-dairy farmers were issued by direct telephone contact from-the Kansas State Board of Agriculture at the SEOC to County

Agents, then< by direct telephone contact from those' Agents to the farm--

l ers.

1 l

At

1050, the SEOC was notified that the General. Emergency (GE) - had been declared at the plant at 1045.

The protective ac-tion recommendation (PAR) from the plant was_to-evacuate in aL 0 to 2

uile radius (subzone CTR) and the John Redmond Reservoir (subzone JRR),

which is.in the 2 to 5 mile area.-

The PAR also directed the public to shelter in sub2ones S-1 and SE-1 in the 2

i to 5 mile area.

Milk animals were to be placed on stored feed out to 10 miles in sectors J, K, and M..

.)

The State questioned the inclusion of sector M.

It was de-cided that farmers should be notified out to 10 miles in sectors H, J, and K,,and the decision was discussed with Coffey County.

At 1103, the SEOC EBS Coordinator received a call from the Coffey County EPC which contained the protective action instruc-tion.

The call was concluded at 1106, at which time, the SEOC EBS Coordinator contacted the EBS station and delivered the EBS messageL identified here as EBS message number 2.

EBS message number- ?:was completed.at 1111 and was to be aired at 1115.

At

1111, the SEOC EBS Coordinator called the CCEOC, informing them that EBS message number 2 would air at 1115.

21

.. ~ - -.. - -,,

~ _ - _ _ - _ - _ -.-__ - - _ ____ --_- -_ _ _.

l At 1204, the SEOC received another plant PAR, _ which recom-mended evacuation of the.following areas:

In the 0-2 mile ra-L

dius, subzone CTR; in the 2-5 mile area, subsones JRR, S-1,.

and SE-1;' and in the 5-10 mile area, subsonas S-2, SE-3, SE-4, and SW-2.

In addition, milk animals were to be placed on stored feed out to 10 miles in sectors H, J, and K.

From 1206 to 1211, coffey, County dictated the text of the resulting EBS message (herein referred to as EBS message number i

l

3) to the SEOC EBS Coordinator.

From 1212 to 1219, the SEOC EBS l

Coordinator dictated EBS message number 3 to the EBS. station.

The message was to be aired at 1220.

The CCEOC was notified of the time of release.

At 1215, the SEOC received PARS from the plant.which recom-mended subzones E-1 and SE-2 be.added to theLpreviously impacted area.

The total area recommended for evacuation was as follows:

In the 0-2 mile radius, subzone CTR; in the. 2-5 mile area subzones E-1, S-1, and SE-1-(this PAR inadvertently omitted subzone JRR); and in the 5-10 mile area subzones S-1, SE-2, SE-3, t

SE-4, and SW-2 were-identified.

Milk animals out to 10- miles' l

were to be placed on stored feed in~ sectors H,.J, and K (this PAR inadvertently omitted sector G).

From 1225 to 1227, Coffey County. dictated the content of EBS message number 4 to the SEOC EBS Coordinator.

FromE1228 to 1234, the SEOC EBS. Coordinator dicP.ated EBS message number 4 to the EBS-Station.

The message was to be aired at'1240.- At 1235,'the SEOC contacted CCEOC to inform them of the 1240 broadcast time.

The EBS message released did correct for the first' PAR omission by reincluding subzone JRR in the evacuated area instructions..

The Kansas 3

State Board of Agriculture contacted their County repre-sentative to notify farmers in. sector G subzones.'directly by-phone regarding the protective action of placing dairy cattle on stored feed out to 10 miles.

t At

1255, the SEOC was notified of. the recommendation to place dairy cattle on stored feed out to 50 miles in sectors G

through K.

The Kansas State Board of Agriculture contacted all affected County representatives to notify impacted dairy farmers.

Objective Number 20, the organizacional~ ability and re-sources necessary to control evacuation traffic flow and to con-j trol access to evacuated areas, was. fully demonstrated.. Kansas l

Highway Patrol (KHP) simulated the dispatch of representatives i

for 10 roadblocks on State Highways, as well as the Command Post at the Forward Staging Area (FSA).

The Kansas Army National Guard (KNG) simulated the dispatch of two 2 battalions, which t

staffed 47 County roadblocks.

All roads'providing ingress into the protective action area were blocked.

KHP roadblocks were es-tablished by 1027; KNG roadblocks were established by 1245.

t 2

22

..t Summary:

The previous ARCA regarding timeliness of EBS mes-sages was not corrected as a result of the deficiency..

Objec'-

.i tives fully demonstrated:

1, 2, 5,

11, 12, and 20.

Objectives not adequately demonstrated:

3, 4,

and 13.

Deficiency 1.

The SEOC failed to correct inadequate.EBS messages! generated-by the CCEOC, which resulted in inadequate instructions be-ing issued to the-public.

t kreas Requiring Corrective Action 1.

The SEOC Communications, Center staff failed to distribute an EBS-release to the operations staff and.the Information clearinghouse staff after it was issued to the public.

2.

The SEOC backup radio communications system with'the plant-EOF failed.

q 2.1.2 Eneraency onerations Facility (EOF) objectives to be demonstrated were:

1, 2,

3, 4,

5, 6,

11, 5

and 16.

Objective Number 1, the ability to monitor, understand and use emergency classification levels (ECLs),- was-fully demon--

strated.

Staff-at this facility were notified'of ECLs. byf the utility via the public address system.

ECLs werel prominently displayed and staff were aware of their current status.

Objective Number 2, the ability to fully alert, mobilize and-activate personnel for'both facility and. field-based-emergency functions, was fully demonstrated.

State EOF ~ personnel were mo-bilized by calldowns initiated'by utility'and State alerters, and arrived at the EOF at 1030.

The facility was fully staffed at 4

1245.

Staffing consisted of the Kansas Administrator,- Radio-logical Systems (ARS), and his assistant, as well as a. Kansas De-

~

partment of Transportation (KDOT) Communicator..

Objective Number 3, the ability to direct, coordinate and-control emergency activities, was fully-demonstrated.

The1 Kansas ARS was effectively in charge of the emergency response provided by this staff.

Periodic briefings were held by the utility and attended by the ARS and his assistant.

Message logs were kept for all incoming and cutgoing mes-sages and transmissions and, if appropriate, messages were repro-duced and distributed.

The facility used an internal-message handling system and information was provided to staff in a prompt manner.

A current copy of the Plan was available for reference.

23

~.. -

~.

J Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and field personnel, was fully demonstrated.

This portion of the EOF was equipped with at least-four commercial telephone lines.

Radio backup was available via the 450 KHZ FM transmitter and the Kansas DOT and National-Guard i

Systems' were in place at the State Forward' Staging Area (FSA).

.This facility maintained communications traffic with the

SEOC, l

the FSA and the CCEOC.

Objective Number 5, the adequacy of facilities, equipment, l -

displayn and other materials to support operations, was fully demonstrated.

The Wolf Creek EOF provided sufficient space,: fur-

nishings, lighting, ventilation and restrooms to support

~

emer-gency operations.

In addition, typewriters, a

computer / word

[

processor, copier and-kitchen supplies were available and suf-ficient to support emergency operations.

Access to.the facility was well controlled by utility' secu-rity personnel.

l Personnel utilized EPZ maps which identified appropriate

~

l-plume. exposure EPZ planning zones, radiological monitoring points and the ingestion planning zone (IPZ)' for agricultural 'informa-tion.

Status boards More positioned for ease of reference. and' wers updated.within 10 minutes of notit_ication of status changes.

objective-Number 6,'

the ability to continuously monitor and control emergency worker exposure, was fully demonstrated.

Each staff member was equipped with a TLD and high and low range direct-reading dosimeters.

Each had-access. to

.-a. dosimeter charger.and had charged and recorded. initial dosimeter readings..

Each person had instructions for use of dosimetry and an exposure record chart for recording readings, and knew his/her-radio-t logical exposure limits.

All staff members had knowledge of pro-cedures for. reporting' overexposure or. seeking permission to exceed: exposure limits.

Objective Number 11, the ability to make appropriate protec-tive action decisions,. based on projected or actual dosage, EPA PAGs, availability of adequate shelter, evacuation time estimates' and other relevant factors, was fully demonstrated.

Protective.

action' decisions'were made without delay as plant status changed..

PARS were coordinated by the State and County with one exception which was cited as an ARCA under Dose Assessment and Field Team Coordination.

Objective Number 16, the ability to make the decision to recommend the use of KI to emergency workers and institutional-ized persons, based on predetermined criteria, as well as to dis-tribute and administer it once the decision was

made, if necessitated by radiciodine releases, was fully demonstrated.

At 24 L

~.

e e

i

1245, the-decision to recommend KI was.nade by the State Radio-logical Assessment Manager (SRAM), at which time, the ARS issued

.the recommendation to all State emergency workers (other than JRMT members who were notified by the Field Team Coordinator).

Summary:' objectives fully demonstrated:.

1, 2,

3, 4,

5, 6,

11, and 16.

2.1.3' Dose Assessment / Field Team Coordination Objectives to be demonstrated were:

2, 3,

4, 5,

6, 'lo,-

11, and 16.

In addition,'one ARCA remained to be corrected fromsthe

.1987' Wolf Creek exercise,_when the, PAR to evacuate from 0-2. miles' in downwind' sectors wasfenacted tur-the CCEOC.

This decision was not coordinated between~KDHE.and the CCEOC before implementation.

The Dose Assessment and Field Team ' Coordination functions' are located in the Wolf Creek EOF, Objective Number 2, the ability to' fully alert, mobilize and activate personnel for both facility and field-based. emergency functions, was fully demonstrated.

State personnel were-mobilized, by utility and ~

State calldowns, and arrived at the EOF at 1045.

All required person-

'3

nel, the SRAM, the State Dose Assessment Supervisor (SDAS) and the Assistant State. Radiological Assessment Manager (ASRAM), were present.

5 Objective Number 3, the ability to direct, coordinate-and control emergency activities, was fully demonstrated.-

The SRAM effectively in charge of the emergency response.-

Periodic was briefings were held to update staff,'

Staff were. involved in de-cision making, as appropriate.

A current copy of the Plan was available for reference.

Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and field personnel, was fully demonstrated.

Dose Assessment and Field-Team Coordination staff had commercial telephone and radio' systems to the.offsite.. teams.

(Quarters were provided to field. team. staff for phone contact in-the event of radio failure.)

A portable hand-held. radio was used to maintain communication with theLoffsite teams, the SEOC, CCEOC and KDHE.

Primary communications systems worked without failure; i

backup systems were tested'for evaluation.

l Objective Number 5, the adequacy of facilities, equipment, displays and other materials to support emergency operations, was not adequately demonstrated.

The inadequacy identified here re-sults from a failure by' Dose Assessment and Field Team Coordina-tion personnel to record essential information on status boards and logs.

In this case, they failed to record the-implenettation i

25

i 1

i e

of a protective action on the status board and logs for 40. min-utes.

The PAR that milk animals be placed on-stored feed out-to

]

50 miles.was decided upon between 1242'and 1246;

however, the status 1 board did not reflect this decision'until:1325.when the portion.of the board labeled " Protective Actions: Implemented" was updated.

The time. assigned to the status board'for the event was

'1242.

The log entry of the event naver did identify the actual measures -recommended-or implemented; reading only.." Talk-to-1 (name),

release information and evac.-protective action".-

This 1

failure -to update the status boards and logs in a timely manner is an ARCA.

Regarding other aspects of!the facilities equipment and dis-plays, :the facility 'provided sufficient

space, furnishings,

~

3

lighting, ventilation 'and restrooms'to-- support emergency op-erations.

A computer / word processor and copier were available.

and sufficient to support emergency operations.

Adequate kitchen supplies were also available.

~

l Access toLthis. facility was well controlled by the utility, j

Personnel utilized maps of the plume EPZ. showing appropriate

]

planning areas, radiological monitoring points, plume EPZ popula-I tion by planning areas, and the IPZ for agricultura1Linformation.-

1 i

l Except -for the aforementioned' failure to maintain status boards for-the dairy animal RAR, status boards were.quickly up-dated,and were~ positioned"for ease-of reference.

Status boards-carried ECLs, weather data'and protective action. decisions.

[

l

[

Objective Number 6, the ability to continuously monitor and>

i control emergency worker exposure, was fully demonstrated.

Per-sonnel were equipped with TLDs and high and low range' direct-i reading dosimeters, an exposure card and instructions. ' Staff had t

access to dosimetry chargers, had charged.their dosimetry and had recorded their initial readings.

i l.

Personnel were aware of their. radiological dose limits, pro-cedures to follow if they received an exposure higherethan autho-

[

rized, and how to seek permission to exceed authorized limits.

Objective Number 10, the ability, within the plume exposure

pathway, to project dosage-to the public1 via plume
exposure,

.I based on plant and field data, was fully' demonstrated.

The util-ity and SRAM-were involved-in making PARS';- the utility did' the projections and the State confirmed.

Primary and backup-systems were available for dose projec'-

tions through the use of an in-line computer and Hewlett-Packard programmable calculators.

Plant status information was provided promptly so that offsite dose projections could be made.

New 26 d

~. -

l l

1 dose projections were made~ upon the availability of field monitoring data and when plant status changed.

The projected plume location was plotted using such fe.ctors

(

l as plant status and weather.

Field team. data was compared -sev-l eral timesLwith projected dose rates.

Teams were directed so that the-plume could be properly defined.

Field teams were periodically updated on_ changing plant sta-l

tus, meteorological data and PARS.

Team movements were ad-equately tracked by the utility.

The Field Team Coordinator was aware of' field-team exposure: limits and limited their exposure by keeping track of the-amount of time teams were in.the_ plume, pe-.

riodically updating exposure readings and rotating: teams out of o

the plume.

Objective Number 11, the ability to make. appropriate protec-

~

tive action decisions, based on projected or actual dosage, EPA-PAGs, availability of adequate shelter, evacuation time estimates-and.other relevant factors, was not adequately demonstrated.

This exercise presented an unmonitored release..

PARS were made using correct PAGs and doses were properly projected, since field team samples were the source of release data for this unmonitored

release, n

Projected dose, plant status and evacuation times were con-sidered in the protective action decision making process.-

The utility initiated this process and the resulting projection was checked by the State.

New PARS were made without undue delay as plant status changed.

t An ARCA was identified when, during issuance of the~ first PAR by the utility, the State Dose AssessmentLstaff was' bypassed.

As a result, the first PAR called for evacuation of-subzone CTR and JRR and sheltering of subzones SE-1 and.S-1, fand was sent to the CCEOC.

The CCEOC acted on this PAR in the belief that State Dose Assessment personnel had concurred and approved these recom-mendations.

In fact, the SRAM became aware of the PAR when it was posted on the status board.

This same inadequacy was ob-served at the September 1987 Wolf Creek exercise and remains an ARCA to be demonstrated at the next exercise.

Objective = Number 16, the ability to make the: decision to recommend the use of KI to emergency workers and institutional-ized persons; based on predetermined criteria, as well as to dis-tribute and administer it once the decision was

made, as necessitated by radiciodine released, was fully demonstrated.

At 1245,- the SRAM made the decision that emergency workers should distribute and administer KI.

Emergency workers were immediately notified.

The decision was base'd on FDA PAGs for projected dose to the thyroid.

j 27-

l Summary:

The previous ARCA regarding. failure to adequately coordinate protective action recommendations between State and l

. County personnel was not corrected and remains an ARCA to be cor-l rected at the next exercise.

Objectives fully demonstrated:

J2, L

3, 4, - 6, 10,,and 16.

Objectives not adequately demonstrated:

5

{

and 11.

kreas Requirina Corrective nation 3.

Dose Assessment and Field Team Coordination personnel failed to record the implementation of-a protective action on the L

status board and 1ogs-for 40 minutes.-

L The initial protective' action recommendation was released by 4.

the utility to the County and then the county to the SEOC without consultation / coordination.with State representatives L

at the EOF.

This same inadequacy was observed at the Sep-tomber 1987 Wolf Creek exercise and remains an ARCA to be demonstrated at the next exercise.

4 2.1.4-Forward staaina Area (Fan)

Objectives to be demonstrated were:

2, 3,~4, 6,

16,-and 20.

In addition, an ARCA from the September 1987' Wolf Creek exercise when a

Kansas National Guard staff member failed to properly record zero. dosimeter readings, Objective: Number 6, exposure' con-trol,-was to be demonstrated.

Objective Number 2, the ability to fully alert, mobilize and activate personnel for both facility and field-based emergency functions, was fully demonstrated.

KHP and KNG' personnel were mobilized by State calldowns.

The KNG vehicle arrived at.1004, commenced erecting their antenna.and establishing. communications

linkages, and completed their-facility setup at 1055.

All KNG personnel assigned to this particular post were in <the: vehicle when it arrived..

The.ERP van arrived at.1022, and established telephone line hookup at 1025.

The area sergeant for the KHP ar-rived at 1005.

KHP units then rendezvoused at-this location to acquire dosimetry.

Dosimetry pickups were completed at 1037.

Objective Nwnber 3, the-ability to direct, coordinate and control emergency activities, was fully demonstrated to the' de-gree possible at this location.

The KNG and KHP each provided vans for this location arf their staffs worked in near isolation from one another; within separate chains of command.

This ar-rangement resulted in a distinct command structure for each agency, but no one agency was in charge of the FSA.

Both the KNG and the KHP had current copies of the Plan available for reference.

Each kept message logs for all incoming and outgoing message traffic.

4 28

Objective 'Humber 4, the ability to communicate with all ap-propriate locations, organizations.and field personnel, was not adequately demonstrated.

An ARCA resulted when telephone equip-ment failed to work properly for the KHP, and radio. traffic was-also' intermittent.

i L

The HKHP ' established communications-linkages with. law.en-forcement personnel.which included their own units, the: Coffey County Sheriff's-Department and also:the' KDOT.

The. linkages i

worked. well.

_However, telephone message traffic to-and-from Chanute was: intermittent due to incompatible telephone jacks':and plugs..

This was especially important since Chanute-was the source of the KHP's field instructions.

Radio backup was also i

intermittent, possibly due to interference-from the KNG repeater antenna which was erected on the hill directly behind.the KHP Although_ delays in communications traffic-were sometimes as.

van.

long as 10 minutes, these delays did not coincide with emergency protective-actions.

Although located next to one,another,. KHP and KNG personnel interacted very little.

.This wa3-avident Eas the KNG was in full communications with all sources 'of current

=information when the KHP was out of. touch, but information was

'never shared, i

The KNG established communication linkages with the-'SEOC, the

EOF, and the military task force.-

Primary ~ systems. worked without-breakdown and wereLaufficient to4 handle' all communica-tions. traffic without delay.

Backup systems were demonstrated, but not needed.

Objective Number 6, the abilit worker exposure,y to continuously monitor and' control emergency was not. adequately-demon-strated.

FSA personnel wore only 0-200 mR dosimeters.

One KNG person entered the plume EPZ without a

TLD, and transported unshielded TLDs through the plume EPZ.

TLDs were not distributed to KHP personnel although'they were available for distribution in the KNG van.

-According to the Plan, SDED was to assure that TLDs were transported to the FSA.

In this exercise, the KNG had made a

trip-to the EOF to deliver a radio.

At that time he was given the supply of TLDs and the supply of KI for personnel both-at the

FSA, and for further distribution to traffic and access j

control ~

personnel.

Upon returning to the FSA, these supplies were left in the back of the KNG van and were never distributed to.lGiP per-sonnel at the FSA or in the field.

This failura to-adequately equip personnel for the monitor-i ing and control of emergency worker exposure is an ARCA.

Other aspects of this objective included the satisfactory correction-of the previously cited ARCA from the September 1987 29 A

-i e

Wolf Creek exercise, during which a-KNG staff member failed to

-i properly record his dosimeter readings when he did not record zero-readings.

In this exercise, personnel were prompted-by 1

their supervisors to read and record all dosimeter readings.

l i

i-Personnel knew their radiological, exposure limits, had ac-Ij

-cess.to dosimeter chargers, and had been issued instructions and exposure record charts.

They also'were knowledgeableiof the pro-cedure: to follow if they received an exposure which exceeded the limits,cor needed permission to exceed those limits.

Objective Number 16, the ability-to distribute.and adminis-i ter; KI once the decision was made, was not.

adequately demon-strated.

This _ inadequacy occurred when the KHP received the recommendation to administer and distribute KI at 1257.-

HKI - had i.

been provided to the KNG representative'during the delivery of a

' radio to the EOF.

This supply was available for distribution ~to emergency workers if ordered; however, the KNG never made this supply-available to the KHP. personnel.

No KHP personnel were equipped with KI. 'This is an ARCA.

The KNG had KI available and received the-recommendation to take KI at 1305.

l All personnel at-the FSA were knowledgeable of procedures-for use of KI.

Objective RNumber 20, the organizational ability and re-2 sources necessary to control evacuation traffic flow and to-con-trol access to evacuated and sheltered-areas, was not adequately j

demonstrated.

.The first-KHP representative who arrivedJ at. the FSA examined his monitoring instrument and discovered a ~ calibra-tion date of September 14, 1982 on the instrument.

This is an l

ARCA.

i Traffic and acceus control: points were correctly located in conjunction with the areas under protective actions.

These points were identified as ingress and egress' points and traffic and access control points were established accordingly, outside the affected area.

i Personnel at this location had the ability to receive in-l structions from the KNG at the SEOC and from the KHP facility in Chanute, except when communication systems malfunctioned.

l KHP implemented actions to staff primary traffic and

~

access control positions and the KNG implemented actions to staff sec-i ondary traffic and access control points.

The positioning of control points was expanded as the protective action area grew.

l 30

~j a

summary:

'The' previous ARCA regarding proper recording of all dosimetry readings, including zero readings, was corrected at i

this axarcise.

objectives-fully demonstrated:

2 and 3.

Objec-tives~not adequately demonstrated:~

4, 6,'16, and 20..

Areas Requirina Corrective notion 5.

Telephone equipment failed'to work properly for the KHP, and radio communication traffic was also intermittent.

6.

KNG. and KHP personnel were inadequate'ly equipped with dosimetry in that.only a low range dosimeternwas. worn.

TLDs I

and film badges were available for distribution, but-not distributed to the KdP; and,- KNG personnel entered the plume-1 EPZ without dosimetry.

t

[

s 7.

KI was not distributed to.KHP personnel,: although KNG repre-sentativen h6d acquired KI for distribution to them.

i 8.

The KHP monitoring instrument was out of calibration.

2.1.s Joint Radioloaical Monitorina Teams ' (JRMTs)

Objectives to.be demonstrated:

2, 4 ',

6, 7,

8, 9,

16, 27, and 34.

Additionally, two ARCAs remained from the previous exer-cise:

one_concerning dead or weak batteries-in field team equip-ment; the:other regarding inadequate l decontamination' procedures

- 3 separating: contaminated from uncontaminated vehicles, equipment, etc.

Both were to be redemonstrated at this exercise.-

The joint radiological monitoring teams (JRMTs)

~

were com-posed of members from the licensee, :the Kansas Department-of Health and Environment,. and Coffey County..

They were to meet at-the plant EOF unless directed to do otherwise from.the FSA.

For the purpose of this report, the blue team was called Team 1, the l

red team, Team 2.

The ability to fully alert, mobilize and-activate personnel for both facility and field-based emergency' functions, was fully demonstrated.

)

Four field teams consisting of three members each were dis-patched;

however, only two teams were evaluated.from an offsite j

perspective.

As stated above, each team included'one representa-tive each from the licensee, State.and County. -Team members were alerted.at the Alert ECL at 0920.

Utility personnel were allowed to be prepositioned at the EOF at 0850; County members reported at 1034 and State team members arrived from ; Topeka at~ 1045.

l Teams. departed the EOF for their first assigned station at 1118 and arrived at 1132 and 1137, respectively.

31

0 g -

r l

Objective Number 4,

-the ability to communicate.with all ap -

l

- propriate locations, organizations and field personnel, was fully demonstrated., Each team was able to maintain contact with' Dose L

Assessment and Field Team Coordinators throughout the exercise.

l Objective Number 6, the koility.to continuously monitor and control emergency worker exposure, was not-adequately -demon-strated, resulting in numerous inadequacies.

Teams failed to - demonstrate the capability.

to.

wear-anti-contamination clothing.

This is an ARCA.

Team members were equipped with TLDs,

'a 0-200 mR low range-dosimeter and a 0-5 R dosimeter.

-Privr to deployment,-. team dosimetry was charged on available chtecers.-

.Following -this, j

some dosimeters read as high as:180 mR, but were logged as read-

~

ing zero.

This is an ARCA since an incorrect-record was created.

l During the' team briefings, Team 1 was not instructed on:how 1

often to read.their dosimetry.

This may have contributed-to. Team-l 1 only reading and. recording dosimetry values once during the en-'

tire exercise.

This insufficient-frequency of1 dosimetry refer-encing is an ARCA.

Team 1

was unaware of where vehicle decontamination was available.- This is an ARCA.

During the course of the exercise it'was also determined that neither. team was aware of their radiological exposure lim--

its.

This is an ARCA.

Objective-Number 7, appropriate equipment and procedures for determining field rediation measurements, was not adequately dem-onstrated.

The JRMTs provided an. inadequate demonstration of their role by using only one of the two evaluated teams.to define and track the plume.

Team 1 demonstrated the appropriate equip-ment and procedures-for determining _ field radiation' measurements, i

with the exception that during the_ field radiation-measurement process, measurer.ents of gamma only and beta plus gamma were made at about one meter (waist level), but were not made at 2 cm (near ground level) to determine groundshine.

This was important. to-I distinguish whether.the readings (if any) were from an elevated i

or nearby cloud, an enveloping cloud, or from shine from deposi-tion after the cloud had past. Team 2 did not demonstrate this capability-This is a deficiency.

Objective Number 8, appropriate equipment and procedures for the measurement of airborne radioiodine concentrations as low 7

as 10 microcurie per cc in the presence of noble gases, was not adequately demonstrated.

Team 1 demonstrated the appropriate equipment-and procedure for the collection of an airborne 32

1

/

radioiodine sample'in the presenceiof noble gases.

However, team

' members'did~not' fully > comply with the. Plan procedure in that'they Edid not aspirate the cartridge; prior to counting:~it 'with an HP-210 probe.

Analysis of the sample (i.e., conversion of field count rate on the cartridge to radiciodine. concentration in' air) was done by' Dose Assessment' personnel ~at the EOF, in-accordance

~

with procedures._

-Team 2>did not demonstrate this capability.

j This is a deficiency.

L Objective. Number 9, the ability-to obtain samples of par-I ticulate activity in the airborne plume and -promptly 1 perform laboratory-analysis, was not adequately demonstrated.-

Team _1 6

partially demonstrated this objective by'taking:an-air sample.

However, othis team ~did=not package'the particulate -filter,

.nor' dispatch ~it for transport-to-the laboratory for-analysis. ~ Team 2 did_not< demonstrate this_ capability.

This is'a_ deficiency.

Objective Number 16, the ability to distribute and.adminis-I ter KI once the_ decision'was made, was-fully demonstrated.

Team 1 was notified' of the decision to administer KI at 1245.

Team 2

_ as notified at 1250.

Both teams were equipped with an ample w

supply of KI.

The KI~was within>the current expiration. date.

Team members understood that' administration of KI was voluntary.

l Objective Number 27, appropriate use'of' equipment and-proce-dures for collection and' transport of samples'of vegetation,Lfood

-crops,- milk, meat, poultry, water and~ animal. feeds, was'not ad-equately. demonstrated, resulting in numerous inadequacies.

Team 2 failed to demonstrate the availability of all neces-sary equipment for field sample:taking.

As an example, this team did' not demonstrate that they had preservative for perishable liquid samples, coolers, scoops,. shovels, clippers, funnels, etc.

j As a result,

grass, for example, was pulled >up by the roots be-1 l

cause no clippersowere available.

This is.an ARCA.

]

Team 1 failed'tol adequately label soil' samples.

The team failed to identify the' size of the area _from which samples

. ere i

w taken (i.e.,

a square meter, or a square foot, etc.)- Failure to provide sample configuration would make ground deposition deter-minations impossible.

This'is'an ARCA.

l Team 2 failed to adequately label vegetation samples.

The l

team failed to identify the size of the area from which samples l

were taken (i.e., a square meter, or a square foot, etc.)

Fail-ure to provide sample configuration makes ground deposition de-l terminations impossible.

This is an ARCA.

Regarding other aspects of this objective, samples were sim-ply bagged in the field and delivered to the EOF at the close of field team exercise efforts.

33 a

u.

._ a. -. _ _.. _,. _. - _.... _. _.

i i

l L

Both teamsLfailed to monitor the ground surface.at sample locations, prior to;taking soil samples.

This was of importance because the Kansas-State Radiological Laboratory.

(RADLAB) was prepared only for low level samples.

A warning of high.. surface radiation measurements at'the site of' soil or vegetation sampling

would have prevented problems being caused at the RADLAB by.unex-L

-pectedly high level samples ^and would have provided the opportu-nity. for such samples to be sent to an alternative location for analysis.

Also, a reading near surface level.would.have been an 1

indication that surface deposition had occurred.

This-is an ARCA.

Team 1 took only a soil sample,.while Team 2 took vegetation and water samples.

SamplingLlocations were located promptly.

L The size of the soil sample'taken by. Team 1 failed.to comply.

with either of the written procedures for soil sampling in thgt

'it was 1/2 inch ofLsoil taken from an area approxigately 100-cm-.

This. sample area differed from'the 625.cm.2 or 1! m as specified by the conflicting Plan Standard Operating Procedures (SOPS).

This is an ARCA.

One area recommended for. improvement (ARFI) is that soil and vegetation sample sites should-be spray painted to define the geographical area and identify the sample -location in case t

further sample data.is required:at a latar time.

Objective Number 34,

.the' ability-to maintain' staffing on a

continuous 24-hour basis by aniactual shift change,

. as not ad-w equately demonstrated.

Neither team' fully demonstrated a shift l

change required for demonstration in 1989.-

This failure caused the JRMTs to exceed the six year: requirement imposed by NUREG-0654 as redefined by Guidance Memorandum-(GM) PR-1, and is a deficiency.

Team 2

partially demonstrated this objective by-a shift change of the County team member only.

Team 1 did not demon-strate this capacity.-

Summary:

The previous ARCA regarding weak or dead batteries was corrected at this exercise.

The previous ARCA regarding de-contamination procedures for JRMTs was corrected by Plan changes which assigned emergency worker decontamination to the Coffey County Road and Bridge Department-and Host County 1 Reception and

Care Centers.

Objectives fully demonstrated:

2, 4, and 16.

Ob-jectives not adequately demonstrated:

6, 7,

8, 9,

27, and 34.

I Deficiencies L

L The JRMTs provided an inadequate demonstration of their role I

by using only one of the two evaluated field teams to define and track the plume.

34 I

l'

]

{

L

i l

1 More specifically, this demonstration resulted.in four defi-ciencies,: numbers-2 through 5, for the JRMTs.

]

'2.

One ' field > team demonstrated the appropriate equipment and procedures..for-determining field ' radiation jaeasurements; The second team did.not demonstrate thisicapability.

3.

One field team demonstrated the appropriate. equipment and procedure for the-collection'of an airborne. radioiodinei sample in the presence of. noble-gases,: except for a failure:

to aspirate the cartridge.

This team;took the requisite air samples,.but the second team did nct. demonstrate this.capa-bility.

4.

Neither team demonstratadithe ability to obtain samples. of ~

l particulate activity in the airborne plume and promptly per-form laboratory analysis.

y

f one team partially demonstrated.this objective by taking. an air sample.
However, it did not package the particulate
filter, nor dispatch it'for. transport-to the. laboratory for analysis.

The second tema did not demonstrate this capabil ity.

5.

Neither team fully demonstrated-a shift _ change required for demonstration in 1989.- This failure caused the JRMTs to ex-

'~

coed the six year requirement imposed by NUREG-0654,.

as re-defined in Guidance! Memorandum:(GM) PR-1.

One team _ partially demonstrated this objective by. a: shift change ~of the County team member ~only, The second' team did

-not demonstrate this capability.

L Areas Reauirina Corrective Action 9.

Teams-failed to wear anti-contamination. clothing.

c!

10.

Dosimeters prepared for.JRMT use.were charged and recorded:

as reading zero, when some read as high as 180 mR.

11. ~ Team 1 read and recorded dosimetry values only once during the entire exercise.

12.

Team 1 members were unaware'of where vehicle decontamination was available.

13.

Neither team knew their radiological dose limits.

14.

Team 2 failed to demonstrate the availability of.all neces-sary equipment for field sample taking.- As an example,'this L

35

t s

I team did not demonstrate that they had preservative, cool-l ers, scoops, shovels, clippers, funnels, etc.

15.

Team 1

did not adequately label soil samples.

The team failed to identify the size of the area from which samples were taken (i.e.,

a square meter, or a square foot, etc.).

Failure to provide sample confipration would make ground l

l deposition determinations impossible.

16.

Team 2-failed to adequately label vegetation samples.

The team failed to identify the size of the area from which samples were taken (i.e., a square meter, or a square foot, etc.).

Failure to provide sample configuration would make ground deposition determinations impossible.

i 17.

Both teams failed to monitor the ground surface at sample locations prior to taking soil samples.

18.

Team 1 failed to follow written procedures for soil: sampling by collecting a sgil sample 1/2 inch deep from an area ap-proximately 100 cm.

Soil sampling procedures in the Plan and SOPS conflict, in that they provide for samples to be 2

2 from areas of 625 cm or 1 m Area Recommended For Tamrov-- at'

(

1.

JRMT members should spray paint soil and vegetation sample sites to define geographical area ~and identify the sample location in case further sample data is required at a later time.

2.1.5

@diolocrical T-Wratory (antan)

Objectives to be demonstrated were:

2, 3,

5, 6,

9, 28, and 34.

Three ARCAs were cited at the 1987 exercise.

Of these, one, cencerning a State SOP, was corrected by a SOP change.

Another, concerning contamination control, was corrected in this exercise.

The

last, concerning the laboratory staff's knowledge of their radiological exposure limits, was also corrected at this exer-cise.

The Radiological Laboratory is located in Topeka, Kansas.

j Objective Number 2, the ability to fully nlert, mobilize and activate personnel for facility-based emergency functions, was not applicable to this facility.

The RADLAB demonstration was out of sequence with the rest of the exercise play.

The staff-reported to their normal work assignments at their normal report-ing times and were in place to demonstrate their capabilities for this exercise.

This objective at the RADLAB was seen to be inap-36 A

--w-m-

-n-,-.e w

v e---e-s-

--wn.

<---w.ne-e va-*-

e.

-n n-++,.--o.s,,

-s---.

--v-m v

m-me-o-em--o-

--e,-,-w

-e-v---ne

=w s-w e--www

~s,w--

m propriate and should be deleted as an objective in future exer-I cises.

objective Number 3, the ability to direct, coordinate and control emergency activities: was not applicable to this facility since direct:,on and control of the RADLAB were evaluated in dem-onstrating the laboratory's other functional responsibilities.

If the RADLAB was unable to perform proper analysis of

samples, then inadequate direction and control would be revealed.

This objective-was seen as inappropriate at this facility and should be deleted as an objective in future exercises.

Objective Number 5, the adequacy of facilities, equipment, displays and other materials to support emergency operations, was fully demonstrated.

However, this objective was seen as unpro-ductive at this facility since RADLAB facilities were evaluated in demonstrating the laboratory's other functional responsi-bilities.

For example, if RADLAB facilities were inadequate to properly perform radiological analysis on various required sample

media, then inadequate facilities or equipment would have been revealed.

This objective should be deleted as an objective at this facility in future exercises, i

Objective Number 6, the ability to continuously monitor and

{

control emergency worker exposure,.

was fully demonstrated.

Laboratory personnel each had a permanent record dosimeter and an appropriate direct-reading dosimeter.

Personnel were aware of their radiological exposura limits, which corrected the ARCA from the 1987 Wolf Creek exercise.

Objective Number 9,

the ability to obtain samples of particulate activity in the airborne plume and promptly perform laboratory analysis, was fully demonstrated.

Simulated delivery of the particulate filter was performed at 0830.

The RADLAB used established laboratory procedures for analysis of the filter.

The analysis was completed in'approximately 60 minutes using a

properly calibrated computer based gamma ray spectrometer and a

calibrated geometry.

A suitable nuclide library was available i

for use in the analysis.

Laboratory personnel then simulated re-porting the results of the analysis to the SEOC.

One ARFI was observed.

The transmission of relatively large amounts of numeric data by telephone is possible; 'however, it presents the possibility of mistakes.

A hard copy transmission is a much better means of avoiding possible mistakes.

It is rec-ommended that a courier be considered to run a copy of the fig-ures the short distance to the SEOC, or possibly a fax machine.

1 Objective Number 28, appropriate laboratory operations and procedures for measuring and analyzing samples of vegetation, food crops, milk, meat, poultry, water and animal feeds, was not adequately demonstrated.

37 m

The inadequacy centered on an incorrect procedure used dur-ing laboratory analysis.

The laboratory measured / counted vegeta-tion and soil sample aliquots without reference or_ documentation of the size of,the original sample area, or the portion of that sample which made up the aliquot analyzed.

.This factor must be addressed by improved procedures to assure that ground deposition values can be derived from field scmple analyses.

This. is an ARCA.

The laboratory received and performed analysis on an air particle filter, vegetation samples,_ water and soil samples, as well as food crop and annual feed samples.

Witn the exception of the aforementioned inadequacy, these samples underwent analysis.

and measurement through the use of proper procedures in a timely Although analysis-of milk samples was-not demonstrated, manner.

laboratory personnel were ready to add formaldehyde to such samples to assure preservation.

Sample analysis results were to be provided to the SEOC.

The Kansas RADLAB utilizes an internal quality control pro-gram and program data was available.

Equipment required by the Plan was available and was being calibrated on a biweekly basis using instrument calibrations tracwable to the National Bureau of Standards.

This laboratory follows appropriate

entry, contamination cross-contamination and labeling procedures for samples delivere/

l d

from the field.

The demonstration of contamination control pro-cedures during sample receiving and preparation was excellent.

A previous ARCA concerning contamination control from the September 1987 exercise was corrected at this exercise when the drying

oven, formerly vented directly into the laboratory, had been moved into a vented hood.

The use of suitable contamination-control procedures now assures that samples would not be cross-contaminated and that the laboratory would not, itself, be-contaminated.

Objective Number 34, the ability to maintain staffing en a

continuous 24-hour basis by an actual shift change, was fully demonstrated.

The RADLAB performed a shift change at both the sample receiving and preparation positions and the sample count-ing position.

The second shift was fully staffed, well briefed by the outgoing staff and demonstrated appropriate knowledge and capabilities of its emergency functions.

This established that the facility could implement 24-hour staffing through the use of two 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts.

4 Summary:

The three previous ARCAs were all corrected at this exercise.

The first previous ARCA, concerning the venting of a drying oven directly into the work area, was corrected by a

1 38

i moving the oven into a vented hood.

The second previous

ARCA, e

concerning the failure of SOP DHE 36 to specify the type of dosimetry which Radiological Laboratory personnel must wear, was i

corrected by Plan amendments since the 1987 exercise.

The third

(

previous ARCA, concerning the failure of laboratory personnel to know their maximum radiological exposure limits, was corrected at this exercise.

Objectives fully demonstrated:

6, 9,

and 34.

Objective not adequately demonstrated:

28.

Objectives not ap-plicable 2,

3, and 5.

I krem naquiring correetive nation l

19.

The Irhoratory measured / counted vegetation and soil sample i

aliquota without reference or documentation of the size of

+

the original sample area, or the portion of that sample i

which made up the aliquot analyzed.

This factor must be ad-dressed by improved procedures to assure that ground deposi-tion values can be derived from field sample analyses.

krea Recommended For Improvement 2.

A courier.or fax machine should be considered as a means of 5

transmitting the relatively large amount of numeric data from the RADLAB to the SEOC, so as to avoid possible mis-takes.

2.1.7 Information clearinghouse (IC)

Objectives to be demonstrated warrt 1,

2, 3,

4, 5,

14, and 15.

1 The Information Clearinghouse (IC) 'is located at the State Defense Building in Topeka, Kansas.

Objective Number 1, the ability to monitor, understand and use emergency classification levels-(ECLs),

was fully demon-strated.

Staff were notified of ECLs by the Wolf Creek Public Information Officer (PIO) and hard copy notifications from the State Communications Center.

ECLs were prominently displayed.

Staff at the IC were aware of the current ECL.

Objective Number 2, tha' ability to fully alert, mobilize and

)

activate personnel for both facility and-field-based emergency

)

functions, was fully demonstrated.

Calls and contacts were made to notify offsite response organization members by telephone be-tween 0822 and 0837 by the State PIO using current written call lists.

Staffing of the IC/ Media Release Center (MRC) was com-plate at 0959 and included the State, County and utility PIOS and support staff.

Objective Number 3, the ability to direct, coordinate and-control-emergency activities, was not adequately demonstrated.

l 39

The IC operations were commanded by the Wolf Creek Nuclear Op-eration Corporation (WCNOC) PIO although. the State PIO was to be t

in charge according to the Plan.

Utility dominance at the IC, I

and thus the MRC as well, was seen in several respects.

The l

utility PIO conducted the briefings in the IC and declared the IC operational.

The IC contained an organization / staff board which showed the State and local Pios as operating beneath the.. utility i

PIO, and press releases identified WCNOC as the first ' releaser, before the State and County.

This is an ARCA.

Periodic briefings were held to update staff on the changing situation, and staff, as appropriate, were included in decision making.

Message logs were kept for all incoming and outgoing mes-sages and transmissions and, with the exception of the first EBS

message, messages were reproduced and distributed, if appropri-ate.

The first EBS message was not reproduced and distributed to the IC staff and, respectively, the MRC, for two hours.

This is an ARCA.

The IC also used an internal message handling system and provided the staff with information in a prompt manner, with the exception of the aforementioned EBS message.

A current copy of the Plan was available for IC and MRC staff reference at the IC.

i The evaluation of the combined IC/MRC functions revealed an i

l ARFI.

The State PIO team was hampered by a lack of sufficient staff.

This resulted in the State PIO's inability to

prepare, review and coordinate press releases at the IC during the numer-ous MRC press conferences which the State PIO had to attend as a

panel member.

Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and field personnel, was fully demonstrated.

The IC/MRC was equipped with 10 commercial tele-phone lines with conferencing capability.

Computer linkages and facsimile machine linkages were also available.

Communications traffic was established and maintained with the Wolf Creek EOF and Technical Support Center (TSC),

the CCEOC and the Rumor Control Centers in the Wichita Office of the WCNOC and in Kansas City (Kansas City Power and Light (KCPL)).

Com-munications traffic was maintained on the primary communications systems without breakdown, although backup systems were tested and functioned properly.

Objective Number 5, the adequacy of facilities, equipment, displays and other materials to support emergency operations, was fully demonstrated.

This facility provided sufficient

space, furnishing, lighting, ventilation and restrooms to support emer-gency operations.

Backup power was available.

1-40

i i

Additional equipment was also available, including a

i computer / word processor and copier, as well as cots and kitchen supplies.

Staff utilized maps of the plume 3PZ with appropriate plan-ning areas labeled.

The IC contained status boards which were.used to update IC-staff at briefings prior to their departure for the NRC.

Status boards were positiened in the IC for ease of reference and were i

updated in a timely manner with information on ECLs and protec-tive action decisions.

Access to the facility was. controlled.by two members of the Military Police.

l Objective Number 14, the ability to brief the media in an

accurate, coordinated and timely manner, was not demonstrated at the IC.

This objective was evaluated at.the MRC, where media l

briefings occurred.

Objective Number 15, the ability to establish and operate rumor control in a coordinated and timely fashion, was fully dem-onstrated to the extent possible at the IC.

[Per the

Plan, Rumor Control. Centers are established offsite.

Rumor control is performed at the Wichita Office of WCNOC and at the KCPL General Office (GO) in Kansas City.

All

+

public concerns are directed to Wolf Creek N9 clear Operating Cor-poration in Wichita.

Media monitoring is performed at both the WCNOC Wichita Office and KCPL GO, and media inquires will be di-rected to the Wichita Office of WCNOC.)

At the IC, the operations consisted of four incoming tele-

. phone-lines staffed by four individuals.

Numerous additional i

telephone lines were available for outgoing calls necessary-to obtain information or call back inquiring parties.

The rumor 1

control number was publicized at this. site by press briefings and news releases.

Rumor control operators had access to current and accurate information through news releases,. plant handbooks,

- etc., and their phone releases were authorized by-the utility and i

State Pios.

Also, upon receipt of a notice of a rumor from WCNOC and 1

KCPL General Office, the rumor was discussed among utility, State i

and County staff, when available.

Prer,s releases were coordi-nated and issued, as appropriate.

Summary:

No ARCAs from previous taxercises remained.

Objec-tives fully demonstrated:

1, 2,

4, 5,

and 15.

Objective not ad-equately demonstrated:

3.

Objective not applicable:

.14.

41

_____---____________.-.m,

. -A...

~.

...-mn,

Arena===uirina corrective nation 20.

The IC was commanded by the utility PIO although the State PIO was to be in charge according to the Plan.

21.

The first EBS message was not distributed to IC staff for two hours.

Area Recommended For Improvenant 3.

The State PIO team should be provided with an additional staff member to enable,the State PIO to prepare, review and i

cocrdinate press releases while media briefings are-taking place.

2.1.3 Media Release center twac1 objectives to be demonstrated were:

1, 2,

4, 5,

14, and 15.

The' Media Release Center is located at Nichell Memorial Ar-mory, Topeka, Kansas.

As staff prepared press releases at the IC prior to actual press briefings at tne MRC, there will be a great deal of overlapping documentation reflected in this section.

Objective Number 1, the ability to monitor,- understand and use emergency classification levels (ECLs),

was. fully demon-strated.

Staff at the'IC were notified of changing ECLs by the l

Wolf Creek PIO and by hard copy notifications from the State Com-munications Center.

Staff informed the media at the MRC of the change in ECLs during the media briefings.

'1 objective Number 2, the ability to fully alert, mobilize and activate personnel for both facility and field-based emergency functions, was fully demonstrated and documented at the IC, Sec-tion 2.1.7.

Objective Number 3, the ability to direct, coordinate and control emergency activities, was not adequately demonstrated.

As at the IC, operations were commanded by the Wolf Creek

PIO, although the state PIO was to be in charge according to the Plan.

Utility dominance was also seen at the MRC media briefings.

The utility PIO conducted the media briefings and press releases listed Wolf Creek as the first releaser, before the State and County.

This was identified previously as an ARCA at the IC, Periodic briefings were held at the IC prior to MRC media briefings to update staff on the changing situation.

Staff, as appropriate, were included in decision making.

Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and field personnel, was 42 I

= - - -, - -

,,,,,m w.,

.-+,,..-......,%

1 l

documented under the IC.

However, the Armory provided work sta-tions equipped with phones for the press in an area separated l

from the media briefing room, thus fully demonstrating this ob-jective to the extent possible for this facility.

Objective Number 5, the adequacy of facilities, equipment, displays and other materials to support emergency operations, was i

i fully demonstrated.

This-facility provided sufficient. space, i

furnishings, lighting, ventilation and restrooms to support emer-gency operations.

Backup power was available for the facility.

l Additional equipment was also available including a computer / word processor and copier, as well as-cots and kitchen supplies.

Staff utilized maps of the plume EPZ with appropriate plan-

]

ning areas labeled.

]

1 Access to the facility was controlled by two members of the Military Police.

objective Number 14, the ability to brief the media in an

accurate, coordinated and timely manner, was not adequately dem-onstrated.

The staff provided four briefings to the

" media"

+l

- which rangod from 17 to 28 minutes in length.

These briefings were conducted by the utility, State and County Pios, with the Wolf Creek technological representative and a moderator.

Staff 1

had access to current, accurate and timely information.

An inadequacy at this facility occurred-when the staff i

failed in two ways to provide the media with adequate pertinent information.

In the third and fourth press conferences, the staff were asked questions by members of the. media which they could not answer, and they never followed up to provide these an-Specifically, staff failed to answer questions regarding swers.

two workers injured at the plant, and inquiries about a bridge l

being out.

In addition to this, at the fourth press ' conference, the State PIO failed to adequately use a map to identify the bound-aries of the protective action area.

This effort to define the affected area failed until the audience assisted-the-State PIO in locating some of the landmarks.

These problems constitute -an ARCA.

With the exception of the aforementioned

problems, staff provided accurate and responsive information to the media in a

prompt _ mantier.

Protective action decisions were described in terms'of familiar landmarks and boundaries for affected-planning Late breaking news was hand delivered _during briefings.

areas.

At the briefings, staff avoided using technical jargon.

Informa-tion concerning protective actions provided to the media-matched j

the protective action instructions provided to the public over EBS.

This information was supplied to the press in a timely man-43 1

a' ygy y.

.--.,v.--

r-W 9m - -

ir

+

?

ner from when it was provided to the public over E88.

One excep-tion to this aspect of timeliness was the two hour delay in the distribution of.the text of the first EBS

message, which: was l

cited as an ARCA for the IC.

i Objective Number 15, the ability to establish and operate rumor control in a coordinated and timely fashion, was fully _ den-onstrated'to the extent possible at this location.

The location of-the Rumor Control Centers was documented in Section 2.1.7.

Rumors were discussed and corrected during media briefings and press releases.

Summary!

There were no previous ARCAs at this facility from the previous exercise.

Objectives fully demonstrated:

1, 2,

C, 5, and 15.

Objectives not adequately demonstrated:

3 and 14.

f kreas annuirina corrective Action 22.

The utility assumed the lead at media briefings in conflict with the State Plan.

T 23.

MRC staff were unable to provide the media with boundaries of the protective action areas using a map, and failed to follow up on media requests for further information.

e

-4 e

p

\\

44 4

4 3.3 QQM H_02ERM10ME 3.3.1 coffey county Emereeney operations center fccEOc1 Cbjectives to be demonstrated weret 1, 2, 3,

4, 5,

6, 11, 12, 13, 16, 18, 19, and 20.

It was also intended that one area l

requiring corrective. action be corrected,.which existed from the i

September 1987 exercise, and concerned the County's failure to i

l notify schools of. protective actions in a timely manner.

l l

The CCLOC is located at the Coffey County Courthouse in Burlington, Kansas.

Objective Number 1, the ability to monitor, understand and use amargency classification levels (ECLa),

was fully demon-strated.

This organization was notified of ECLs by the utility.

at each major change of status.

SCLm were prominently' displayed and staff were aware of current levels.

i objective Number 2, the ability to fully alert, mobilize and

{

activate personnel for both facility and field-based emergency

-~

functions, was fully demonstrated.

Ca11 downs were made batween 0900 and 0946 by the Sheriff's Dispatcher and responding staff using telaphone and radio.

A written call list of staff names and telephone numbers, which were current, was.used.

All staff responded by 0947 when the facility was fully staffed.

Objective Number 3, the ability to direct, coordinate and control emergency activities, was fully demonstrated.

.The Emer-gency Preparedness Coordinator (EPC) was effectively.in charge.

Periodic briefings were held to updato staff on the current situation and staff were involved in decision making, as tppro-t priate.

A current copy of the Plan was available for reference.

Message logs were kept for all incoming and outgoing messages and file copies were reproduced and distributed.

This facility used i

l an internal message handling system, and a record was kept of in-l ternal messages through logs or file copies.

Protective action decisions and implementation of those decisions were coordinated effectively with all appropriate organizations.

Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and field personnel, was fully demonstrated.

This facility employs commercial telephone with conferencing capability, radio systems, -computer and facsimile machine linkages which carried all communications traffic.

Backup systems were not needed to correct any breakdowns, but were demonstrated for evaluation.

objective Number 5, the adequacy of facilities, equipment, displays and other materials to support emergency operations,.was fully demonstrated.

This facility had sufficient

space, furnishings, lighting, ventilation and restrooms.

Backup power i

45

~_. -

l was available.

A typewriter, computer and copier were available, as well as kitchen supplies and cots which were also available and sufficient to support emergency operations.

Access to the i

facility was controlled.

Personnel utilized maps de the plume EPE, which labeled appropriate planning areas,picting i

- evacuation i

routes, traffic control points, population and planning area, re-location

centers, special needs populations and the ingestion i

pathway.

Status boards were updated in an excellent manner and were positioned for ease of reference for all staff.

Status boards included ECla, protective action decisions, weather data, plant cor.ditions and data and facilities activated.

objective Number 6, the ability to continuously monitor and control emergency. worker exposure, was not adequately demon-strated.

Workers in the CCEOC, which is located within the plume l

exposure EPZ, had not been issued, dosimetry.

In addition, one member of a field team was unaware of his radiological exposure limits.

These inadequacies are two ARCAs.

Forty dosimetry kits were available at this facility.

Per-sonnel dispatched from this facility were equipped with

TLDs,

~

high and low range dosimeters and exposure charts.

Dosimeters ware charged prior to use.

Objective Number 11, the ability to make appropriate protec-tive action decisions, based.on projected or actual dosage, EPA PAGs, availability of adequate shelter, evacuation time estimates and other relevant factors, was fully demonstrated to the extent possible.

The decision to evacuate John Redmond Reservoir (JRR) at the Site Area Emergency (SAE) was a preplanned protective ac-tion undertaken by the County.

All other decisions were based on recommendations from the State.

The ability to make appropriate protective action decisions based on other criteria was not dem-onstrated at this facility.

Objective Number 12, the ability to initially alert the pub-lic within the plume exposure EPZ.and begin dissemination of an instructional message within 15 minutes of a decision by appro-priate State and/or local official (s),.

was fully demonstrated.-

The alert and notification system was used at the C ce Area Emer-gency to initially alert the public.within.15 minutes.

The ini-l tial message included instructions for visitors on and around the JRR to evacuate to the Reception and Care Center in Emporia, Initial alert and notification was carried out by the County l

EPC and the County Sheriff's Office.

The process included -cti-vation of the fixed siren system and tone alert radios which were activated by the EBS system.

The process was coordinated effec-tively among involved organizaticns.

EBS messages followed the wirens by about a minute and were repeated every 15 minutes, per instruction at the bottom of the messages, i

46 4

1 Objective Number 13, the ability to coordinate the formula-tion. and dissemination of accurate information and instructions to the public in a timely fashion after the initial alert and no-tification has occurred, was not adequately demonstrated.

EBS messages were drafted by.the CCEOC and forwarded to the SEOC in Topeka for editing, release and broadcast.

Messages drafted by the CCEOC and authorized by the SEOC failed to adequately provide instructions to evacuees.

Messages contained no instructions re-l garding what evacuation routes evacuees should use and they as-l signed evacuees to Reception and Care Centers by

subzones, critting landmark descriptions.

Furthermore, two messages stated that patients and' residents of hospitals and nursing homes were being evacuated to area hospitals, when no such facilities were impactoi by protective actions.

This error occurred when a draft message was prepared using a prescripted EBS message.

The prescripted text included a reference to these special popula-i tions and this reference should have been crossed out, but re-mained in the body of the message.

In addition, following the i

evacuation of LeRoy School, EBS messages failed to inform the j

public of the location of evacuated school children.

These inad-equate EBS messages are a deficiency.

Other aspects of the. CCEOC operations showad that

.prescripted messages were used-and when released, were rebroad-cast every 15 minutes.

Staff had access to current, accurate and timely information which was received directly from the utility at the EOF.

Protective action areas were identified in terms of accurate familiar local landmarks and boundaries.

Messages ad-dressed how to maximize protection when: sheltering, use of ad hoc respiratory protection, etc.

A log was maintained of all releases disseminated to the public and copies were kept and accessible to all staff.

Infor-mation released to the media was provided to the County by the MRC, which telefaxed news releases to the CCEOC.

Objective Number 16, the ability te distribute and adminis-i ter KI once the decision was made, if necessitated by radioiodine releases, was fully demonstrated.

When the State of Kansas chose to order distribution of KI, the call was' received by CCEOC at 1302.

Staff at this facility were knowledgeable of procedures for KI use and means of notification.-

A list was prepared to identify all emergency response personnel in the County. who should be supplied with KI.

At 1319, personnel were given in-structions to deliver.KI to ambulance drivers and-patients, County Road and Bridge Department personnel,c and Sheriff's De-partment personnel.

At 1324, courier personnel were dispatched to deliver the KI to all but the jail population.

-At 1327, the courier was dispatched to the jail.

KI distribution included sufficient quantities and was performed in a timely manner.

In-structions for KI 'use were included.

47

3.;;p ',;.; __.; g.- z ; ___ [

- -~

~;3-y 3 3 7 : ~ ~ 3 y- ~

a

~.o KI was distributed to the jail in Sector SW-1, although this subsector was not in the protective action arent however, offic-ers in the -jail faced assignment to the field.

Objective Number 18, the ability and resources necessary to implement appropriate protective actions for the impacted perma-nent and transient plume EPE population (including transit depen-dont persons, special needs populations, handicapped persons and institutionalized persons),

was fully demonstrated.

Staff at this facility implemented protective actions for special needs populations with the assistance of the County Road and Bridge De-partment.

Transit dependent, special needs and institutionalized per-sons were all identified by computer lists.

Telephone calls were made to all such people except the hearing impaired, who were ac-tually contacted by County Road and Brid personnel at the direction of the County Engineer. ge Department Transportation was provided for transit dependent persons to pickup points in LeRoy.

An ambulance simulated transporting a

bedridden resident to the Reception and Care Center.

Health officials maintained good contact with hospitals and nursing homes.

The County exhibited a good system for effec-tively dealing with special needs populations.

Objective Number 19, the ability and resources necessary to implement appropriate protective actions for school children within the plume EPZ, was fully demonstrated.-

The county Commis-sioners agreed to enact the protective action concerning school evacuation at 1208.

A call was slaulated to the LeRoy School at 1221.

The County then undertook traffic control efforts to as-sist the school in evacuating.

This corrected an ARCA from the September 1987 exercise, in which the County failed to notify the schools of protective actions in a timely manner.

In fact, all schools were notified of each ECL by the Sheriff's Dispatcher.

Objective Number 20, the organizational ability and re-sources necessary to control evacuation traffic flow and to con-trol access to evacuated areas, was fully demonstrated.

The control demonstrated at this facility was the simulated access placement of KHP Officers at State Highways.

This was adequately demonstrated.

Traffic and access control points were identified and set up at locations which were chosen in conjunction with areas under protective actions and were outside the affected area.

It took County personnel approximately 15 minutes to establish access control points after the areas under protective actions were identified.

48

I i

Traffic controllers had the~ capability to receive instruc-l tions from CCEOC staff.

~

l Necessary dosimetry for traffic and access control personnel was available, although actual dispatch of Sheriff's Deputies was i

neither required nor performed.

]

Summary:

The previously identified ARCAs, regarding timely t

notification of schools, was corrected at this exercise.

Objec-I tives fully demonstrated:

1, 2, 3, 4,

5, 11, 12, 16, 18, 19, and 20.

Objectives not adequately demonstrated:

6 and 13.

i Deficiency 6.

CCEOC drafted and released, to the SEOC, inadequate EBS mes-sages for dissemination of public emergency information.

These messt.ges were inadequate in the following respects:

a) evacuation messages failed to identify evacuation routes; b) the public was directed to Reception and Care Centers based upon the emergency plahning zone' subarea in which they 1

reside; however, these subareas were not described in terms of local landmark descriptions for each Reception and Care Center; c) the public was not' informed of the Reception and 1

Care Center to which school children had been evacuated; and l

d) the EBS message erroneously informed the public of hospi-tal and nursing home evacuations when no such facilities were impacted.

Arman noeuirina corrective hetion 24.

CCEOC personnel were not issued dosimetry.

25.

One emergency worker dispatched to the field was'not aware of his exposure limits, i

2.2.2 Cpffav County Road and Bridae Department i

Objectives to be demonstrated were:

2, 3,

4, 5,

6, 12,.

16, 18, 20, and 25.

I' One ARCA remained.from the September 1987. Wolf Creek exer-L cise,- in which the County Shop had no current copy of the County l

Plan.

L The Coffey County Road and Bridge Department is located at the County Shop in Burlington, Kansas.

1 Objective Number 2, the ability to fully alert, mobilize and activate personnel for both facility and field-based omergency functions, was fully demonstrated.

Normal duty hours were in ef-fect during the exercise, so some personnel were present in the County Shop when the notifications began, calldowns were com-49

~-

1 l

l l

l plated at 0944 by the County Shop secretary using telephone and radio while referring to a written call list.

Call list informa-i tion was current.

Staff were mobilized to their preliminary as-signments as members of JRNTs, access control

teams, hearing impaired and secondary roadblock teams, transportation assistance t

j and evacuation confirmation teams, road service and ice control I

teams.

Those personnel who staff the shop facility and emergency i

road service crews also serve as decontamination team nombars.

Staffing was accomplished at 1010,.for all personnel.

. Objective Number 3, the ability to direct, coordinate and control emergency activities, was fully demonstrated.

The Road Supervisor was effectively in charge of the facility.

A current copy of the County Plan was available which corrected an out-standing area requiring corrective action from the September 1987 Wolf Creek exercise.

Periodic briefings were held to update staff on the situation and staff were involved in decision mak-

ing, as appropriate.

Message logs were kept of all incoming and outgoing

messages, and pertinent Information was promotly pro-vided to staff.

Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and field personnel, was fully demonstrated.

The County Shop was equipped with three commercial i

telephone lines, a radio system base station and attendant mobile l

and hand-held radios.

All County Road and Bridge Department ve-i hicles were-equipped with radios to maintain contact with the t

County Shop.

Communications traffic was maintained between this facility and the CCEOC and Sheriff's Department, as well as County Road and Bridge Department vehicles.

Backup communication l

systems. were demonstrated although primary systems were capable l

of handling all traffic without breakdown.

Objective Number 5, the adequacy of facilities, equipment, displays and other materials to support emergency operations, was fully demonstrated.

Sufficient space,

lighting, furnishings, ventilation and restrooms were available at this facility.

A typewriter and computer were also available to support emergency operations.

Maps of the plume EPZ were posted and utilized by staff.

A status board was used, updated regularly and cositioned for ease of reference by staff.

ECLs and protective a.tlon deci-sions were monitored and posted.

Objective Number 6, the ability to continuously monitor and control emergency worker exposure, was fully demonstrated. 'Emer-gency workers were issued TLDs and a

mid-range dosimeter.

Personnel' charged dosimetry on the available charger prior to

use, knew their exposure limits and procedures if overexposure occurred or became necessary.

Staff were equipped with exposure record charts and read and recorded values properly.

1 50

f Objective Number 12, the ability to initially alert the pub-i lic within the plume exposure EPE and begin dissemination of an instructional message within 15 minutes of a decision by appro-priate state and/or local official (s),

was fully demonstrated

.within the responsibilities of this facility.

Primary alerting was not a responsibility of this facility, except that alerting of hearing impaired individuals was accomplished by actual con-tact.

County Road and Bridge Department personnel assembled a

hearing impaired alerting team.

The County Engineer at the CCEOC i

called the county shop to dispatch the hearing impaired alerting team.

objective Number 16, the ability to distribute and adminis-l ter KI once the decision was made, if necessitated by radioiodine releases,.. as fully demonstrated, to the degree possible by per-w sonnel from this facility.

Following the decision by appropriate personnel that KI should be distributed, the CCEOC contacted the County Shop.

County Shop personnel were told that KI was being ordered and that a list of County Road and Bridge Department per-sonnel in the field who needed KI should be provided to the EOC.

Within 10 minutes, the list of County Road and Bridge Department personnel needing KI was provided to the CCEOC so that CCEOC per-sonnel could distribute KI to them.

Prior to dispatch, knowledge of KI purpose and procedures was exhibited by the County Road and l

Bridge Department personnel.

Objective Number 18, the ability and resources necessary to implement appropriate protective actions for the impacted' perma-nent and transient plume EPZ population (including transit depen-dont persons, special needs populations, handicapped persons and institutionalized persons), was fully demonstrated.

County Road and Bridge Department personnel assembled teams to provide trans-I portation, ice control, emergency road service, block secondary L

roads, and evacuation confirmation.

The County's transportation dependent persons and other special needs populations are listed by computer and the County Road and Bridge Department's teams are assembled and dispatched to assist them accordingly, i

Objective Number 20, the organizational ability and re-sources necessary to control evacuation traffic flew and control access to evacuated areas, was fully demonstrated.

At the County

Shop, the County Road and Bridge Department assembled personnel to establish access and traffic control points on County roads.

This effort was undertaken in concert with KHP and KNG personnel who were also establishing control of area roads.

The CCEOC notified the County Road and Bridge Department of two locations for initial traffic and access control at

~1110.

These control points were established at 1136 and 1143.

.As the protective action area enlarged, these control points were moved in accordance with CCEOC instructions.

Traffic ingress and

)

51

l egress points were outside the affected area and were established in a

timely manner by personnel who had accurate knowledge of their emergency response role in evacuation routes and access control.

objective Number 25, the adequacy of facilities, equipment,

supplies, procedures and personnel for decontamination of emer-gency workers, equipment and vehicles and for waste disposal, was fully demonstrated to the extent planned at this facility.

Per-sonnel are decontaminated at the Reception and Care Centers.

Emergency vehicles were monitored and decontaminated at the Coffey County shop.- Contaminated, uncontaminated and unmonitored vehicles could be kept separate.

Following monitoring.of the ve-

hicle, the driver was also monitored.

The

car,

. hich was w

simulated to be contaminated, was actually decontaminated at the facility.

A unique device for decontaminating the underbelly of vehicles had been developed by facility personnel and was ob-served to work very well.

The remainder of the vehicle was de-contaminated with hot, soapy water and rinsed, then resurveyed.

Procedures were good.

Water pressures were kept low to avoid spreading contamination.

The air filter was removed and monitored.

Procedures and equipment were ready for isolating con-teminated clothing, equipment and personal articles.

The area i

where decontamination was performed was shielded from surrounding areas by large curtain like devices.

Summary:

One ARCA from the September 1987 Wolf Creek exer-

cise, in which the County Shop had no current County
Plan, was resolved at this exercise.

Objectives fully demonstrated:

2, 3,

4, 5,

6, 12, 16, 18, 20, and 25.

2.2.3 Medical Coffev County Hospital Objectives to be demonstrated were:

6 and 24.

The Coffey County Hospital is located in Burlington, Kansas.

Coffey County Hospital is the primary hospital for the Wolf Creek Generating Station and is located within the plume exposure EPZ itself.

Objective Number 6, the ability to continuously monitor and control emergency worker exposure, was fully demonstrated.

Hos-pital personnel were each equipped with a TLD, both high and low ranga dosimeters, appropriate instructions for dosimeter use and an exposure record chart on which to record readings.

Each person had access to a charger for the direct-reading dosimetry, had charged his/her dosimeters and recorded initial values.

Personnel were aware of their radiological exposure

limits, and were knowledgeable of what to do if they received an exposure k

1 52

i higher than authorized, or needed authorisation to incur exposure l

higher than authorized.

J t

objective Number 24, the adequacy of medical facilities, l

l equipment, procedures and personnel for handling contaminated, injured or exposed individuals, was fully demonstrated.

Upon ar-i l

l

rival, the hospital demonstrated procedures for checking the pa-3 l

tient for radiological contamination and for decontamination of the patient.

The proper monitoring equipment was used and car-ried a recent calibration date.

Proper procedures were used.

l l

staff were aware of levels for initiating decontamination and continued proper decontaminacion precedures until normal readings were obtained.

Staff utilised proper contamination con-trol measures and wore full protective clothing.

i Contamination control was demonstrated for this area of the hospital; and visitors and other hospital personnel were pre-vented from entering the area.

Prior to departure, the ambulance i

and crew were properly monitored by hospital personnel to ensure that they were not contaminated.

Summary:

There were no previous inadequacies at this facil-ity which required redemonstration at this exercise.

objectives fully demonstrated:

6 and 24.

2.2.4 Medical Lvon county ambulance service Objectives to be demonstrated:

4, 6,

16, and 23.

i This was the first exercise for.this ambulance service.

No previous ARCAs sxisted for correction at this exercise.

The Lyon County Ambulance Service is located in

Emporia, l

Kansac.

Objective Number 4, the ability to comm'..icate with all ap-I propriate locations, organizations and fielf 3rsonnel, was fully-demonstrated.

Tht ambulance contained two..dio systems, a low band radio which provided communications with the Emporia Dis-

patcher, and a Kansas Medical System Radio which was capable of contact with. all medical channels in Kansas, including coffey County.

In addition, a hand-held unit carried by the crew was capable of contact with the Emporia Dispatcher and an additional radio in the cab could have reached Coffey County.

Communication Ainkages were demonstrated between the hospital and the ambulance l

enroute.

l The primary systems were capable of handling all communica-tions traffic from the ambulance without' noticeable delay.

Backup systems were demonstrated for evaluation, but not required I

by a breakdown in the primary system.

i i

53

~

~. - - - -

t l

l t

Objective Number 6, the ability to continuously monitor and control emergency worker exposure, was fully demonstrated.

Ambu-i lance crew members were equipped with TLDs and both high and low i

range dosimetry.

The ambulance crew had access to a dosimeter charger at their dispatch center and had charged their dosimeters i

and recorded their initial readings upon dispatch.

Each crew member had been issued an exposure record chart and instructions for the use of dosimetry.

All were aware of their radiological i

exposure limits and the procedures necessary to retelve authori-zation to exceed exposure limits or to report.an exposure higher

~,

than authorized.

Objective Number 16, the ability to distribute and adminis-l ter KI once the decision was made, was fully demonstrated.

Ambu-lance crew members were aware of procedures for the use of KI.

objective Number 23, the. adequacy of vehicles,- equipment, procedures and personnel for transporting contaminated, injured

(

i or exposed individuals, was fully demonstrated.

Upon arrival at the

scene, the patient was evaluated for injuries and surveyed for contamination, with a recently calibrated monitoring instru-ment.

Readings were recorded.

Crew members were aware of the action level which required decontamination.

When determined to be contaminated, the patient was wrapped to prevent the spread of contamination.

The crew wore appropriate protective clothing which included masks and paper anti-contamination suits.

l t

The patient was transported to Coffey County Hospital and delivered to the correct entrance.

The crew was knowledgeable of,

}

both the primary and backup hospital.

Proper procedures for con-tamination control were empicyed by crew members in the use and disposal of contaminated clothing and supplies.

i Summary:

This was the first demonstration for this ambu-lance service.

Objectives fully demonstrated:

4, : 6, 16, and 23.

2.2.5 Unified School District #243 - Waverly Objectives to be demonstrated were:

4 3 6,

16, and 19.

One ARCA remained from the September 1987 Wolf Creek exer-cise in which the driver failed to know his exposure limits or how to read his dosimeter.

Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and field personnel,-was-fully demonstrated.

The School Superintendent of the Unified School District (USD) #243,

Waverly, was informed of emergency. actions by telephone and could also have been notified'by tone' alert ra-dio.

Both communication links were observed to work well during this exercise.

The Superintendent communicated with the schools 54

i 1

i viu telephone, but was also equipped with an FM radio link which j

he demonstrated for this evaluation.

1 i

objective Number 6, worker exposure,y to continuously monitor and the abilit control emergency was not adequately demon-t-

strated.

i i

The school : bus driver, who reported to the

school, was l

equipped with a TLD,.one 0-200 mR dosimeter, and a record keeping.

i chart.

Dosimetry was, therefore, inadequate by not including a l

aid or high range dosimeter capable of reading higher than 200 mR.

This is an ARCA.

l The driver did know his dose limits and how to read his do-

simeter, which corrected the ARCA from the September 1987 Wolf r

Creek exercise.

The driver had instructions for.use of dosimetry and an exposure record chart on which to record dosimeter read-ings.

The driver knew who to contact if he needed permission to li exceed his dose limits, or if he received an exposure higher than authorized.

~

Objective Number 16, the ability to distribute and adminis-i ter KI once the decision was made, was not adequately demon-strated.

The bus driver was knowledgeable of KI and its possible use during his emergency response, and of possible side effects.

The driver knew how he would be told to take KI; however, he did not know how KI would be made available to him..This is an ARCA.

t objective Number 19, the ability and resources necessary to-implement appropriate protective actions for school children within the plume EPZ, was fully demonstrated.

The School Superintendent received a call advising him to evacuate his schools to Ottawa.

He then called the bus barn to alert the drivers, instructing them to evacuate the grade school

first, then the high school.

The Superintendent then called the grade school to tell them to evacuate to Ottawa, and that the buses _ had been called and would be arriving immediately.

The high school was then called to warn of the evacuation and that L

buses would arrive after the grade school students had been L

picked up.

At the grade school, the principal received the instruction to evacuate.

Through the use of an interview, it was determined that the teachers were-to have been notified of the evacuation, student roll was to have been taken, and the school was to have been searched and closed up.

Buses were then to have been loaded and student roll again checked.

Buses would then depart for Ot-tawa.

Written procedures were available for use by the Principal in the implementation of this process.

b 55

The Principal was also aware of-procedures for sheltering within the building and at which point doors, windows and venti-lation systems would have been secured.

The bus driver was contacted by telephone at the bus barn in Waverly which is close to the schools.

He could also have been reached by radio or pager.

It took five minutes for the bus to arrive at the grade school.

The driver was knowledgeable of evacuation routes and the location of the Reception and care Cen-l ter for this portion of the EPE.

Summary:

One previous ARCA, regarding~ the bus driver's knowledge of his exposure limits and procedures for reading and recording desinators, was resolved at this exercise.

Objectives fully demonstrated:

4 and 19.

Objectives not adequately demon-s strated:

6 and 16.

7*

Arena Reauirine corrective Action i

26.

The bus driver was not equipped with either a mid or high range dosimeter capable of reading higher than 200 mR.

27.

The bus driver was unaware of how and where he would receive KI.

2.2.s Allen county mecention and care center

~

i objective to be demonstrated was:

34.

l The Allen County Reception and Care Center is located at the National Guard

Armory, 1021 N.

State

Street, Iola, Kansas.

Evaluation of this facility was performed on December 5, 1989.

Objective Number 34, the ability to maintain staffing on a

continuous 24-hour basis by an actual shift change, was not_ ad-i equately demonstrated.

Allen County failed to perform a shift change required for demonstration by 1989.

This failure caused this facility to exceed the six year limit imposed by NUREG-0654, as rodefined in FEMA GM PR-1, and is a deficiency.

Summary:

Objective not adequately demonstrated:

34.

Defielenev 7.

Allen County failed to perform a shift change required for demonstration by 1989.

This failure caused this facility to exceed the six year limit imposed by NUREG-0654, as rede-fined in GM PR-1.

5 56

{

l l

i i

2.2.7 Franklin e objectives to be demonstrated were:

21 and 34.

The' Franklin County Registration Center is located at the Ottawa High School, lith and Ash, Ottawa, Kansas.

Evaluation of

]

this facility was performed on December 5, 1989.

)

1 objective Number 21, the adequacy of prococures, facilities, equipment and personnel for-the registration, radiological monitoring and decontamination of evacuees, was partially demon-strated to the degree required.

The previone demor.stration of this facility was incomplete i

in that the shower facilities used for evacues decontamination were unavailable for inspection.

This evaluation, therefore, fo-cused only on the adequacy of this portion of the physical facil-ity.

Adequatw separation of contaminated persons from uncontaminated persons vas demonstrated.

Evacuees were segre-gated at the monitoring line, at which time contaminated indi-viduals were routed to the shower facilities.

The showers were segregated for male and female.

A large area was available for disrobing and included an area designated.for bagging al.d tagging of belongings.

.The shower was adequately large.

There 'sas an into which.the evacuees could then go, where remonitoring area could be performed and the distribution of replacement clothing could be accomplished.

objective Number 34, the ability to maintain staffing on a

continuous 24-hour basis by an actual shift chang 2, was not ad-equately demonstrated.

Franklin County failed to perform a shift change required for demonstration by 1989.

This failure caused this facility to exceed the six year.llait im as redefined in GM PR-1, and is a deficiency.poced by NUREG-0654, i

Summary:

Objective partially: demonstrated:

21.

. Objective not adequately demonstrated:

34.

Deficianov i

8.

Franklin County failed toLperform a. shift change required for demonstration by 1989..

This failure caused this facil-1 ity to exceed the six year limit imposed by NUREG-0654, as

.]

redefined in GM PR-1, 2.2.8 Lyon County Reception and Care Center Objectives to be demonstrated were:

2, 3,

4, 6,

21, 22, and-I 34.

In addition, an.ARCA identified in the 1984 exercise and 57

,,3

..m.,

, ~., -,,. _.

_-,_m_

__,___m_____._.

. _ _ - ~

l which concerned the use of campus police as a

communications linkage, was corrected in this exercise.

The Lyon CoJnty Reception and Care center is located at the Emporia state University Campus in Emporia, Kansas.

Evaluation j

of this facility was performed on December 5, 1989.

Objective Number 2, the ability to fully alert, mobilize and l

activate personnel for both facility and field-based emergency functions, was fully demonstrated.- This facility was demon-

.itrated out of sychronization with the exercise.

Ca11 downs were begun by the county Clerk using a computer generated roster..

objectivo Number 3, the ability to direct, coordinate and' control emergency activities, was fully demonstrated.

The Lyon r

County EPC was effectively in charge of the emergency response.

Periodic briefings were held to updats staff on the situation-and i

new information was promptly-provided to staff.

An internal mes-sage handling system was used at this facility and the Sheriff's Dispatcher kept records of messages through logs or file copits.

A current copy of the Plan was available-for reference.

+

Objective Number 4, the ability to communicate with all ap-propriate locations, organizations and' field personnel, was fully demonstrated.

Commercial telephones and law enforcement radio i

systems were available for communications linkages at this facil-

ity, as well as RACES (Radio Amateur Civil Emergency
Services, i.e.,

a volunteer portable ham operator) support.

Backup com-munications were demonstrated by the RACES operator although no breakdowns required use of backup systems.

The appropriate use of planned communications systems cor-rected an ARCA from the 1984 Wolf Creek exercise, when campus po-lice communication linkages, which did not comply with existing plans, were used by this facility.

L Objective Number 6, the ability to continuously monitor and control emergency worker

exposure, was fully demonstrated.

Monitoring personnel were each equipped _with a TLD and both high and low range dosimeters.

Each monitor waJ also equipped 'with instructions for use of dosimetry and exposure record charts on which to record dosimeter readings.

This staff had access to do-simeter chargers and had charged their dosimetry and recorded initial readings.

Additionally, they were aware of their radio-logical dose limits, what to do if they exceeded their authorized r

limite or needed authorization to exceed those limits.

All monitors exhibited a very good understanding of protective proce-dures.

Objective Number 21, the adequacy of procedures, facilities, equipment and personnel of the registration, radiological monitoring and decontamination of evacuees, was fully demon-i e

58

~.

l

-t strated.

Reception Center monitoring was demonstrated by 2 seven person teams, one performed-evacues monitoring and the other re-corded results in counts per minute.

When a scan was completed, those evacuees who were not contaminated were given a hand stamp and were directed to registration.

Those evacuees who were dis-covered to be contaminated were directed to the showers.

Monitors were aware of the action level for decontamination of evacuees.

This procedure was adequate to segregate contaminated individuals from noncontaminated individuals.

Monitoring personnel were made up of personnel from the i

County Emergency Management office, County Sheriff's office and the County Division of Health.

Fourteen monitors were present for the evaluation of seven two person. teams.

This was adequate to satisfy FEMA's. require-ment that 1/3 of the total number of monitors required to monitor 20%

of the population to be received at a

host county be evaluated during demonstration of this objective.

If evacuees were found to be contaminated, they were decon-

- taminated at this facility via a system which provides total seg-regation of clean and contaminated persons.

If contaminated, evacuees followed a closed route to the area where disrobing and showering took place and where evacuees were remonitored-upon completion of showering.

If the person was still contaminated, the Reception Center Manager was notified.

After all evacuees bad been processed, bagged and tagged clothing was removed.

Pa-per gowns were available-for passage to reception and care.

A sufficient number of CDV-777 radiological' monitoring kits were available for this facility and -the survey meters were la-beled to indicate proper calibration.

Adequate arrangements had been made for segregating con-taminated and unmonitored vehicles from clean vehicles and suf-ficient parking was available for thennumber of expected cars.

Procedures for the monitoring of evacuee vehicles were demon-strated.

Monitoring personnel were aware of the action level for decontamination of vehicles and decontamination of these vehicles was to occur at this location.

Contaminated vehicles were moved to an isolat6d soccer / baseball' field which was equipped with a

hydrant for water hookup.

Here, the vehicles were washed

down, remonitored and returned to the main parking area, if clean.

All parked vehicles were impounded until monitored.

Registration procedures were demonstrated and no evacuee would have been processed without first receiving a hand stamp from the monitoring station signifying that he/she was uncontaminated.

The only alternative to the

" clean" stamp l

process would occur if an evacuation had been undertaken as a

precaution, in the absence of a release from the-plant.

59


.----.u.

,--,v a v

.--.-n

,,m,

j i

o The overall Reception and Care Center evaluation revealed I

that both the first shift Reception Center Manager and his re-placement were very knowledgeable of functions and activities of I

the Center, as defined by the Plan.

The monitoring teams dis-played good technique and the supervisor was knowledgeable of procedures for special cases, e.g.,

mothers with nursing chil-dren.

-1 One area is recommended for improvement.~

Decontaminated in-dividuals.should have access to clothing, beyond simple. paper

gowns, before departing the Reception Center and arriving at the Congregate Care Center.

objective Number 22, the adequacy of facilities, equipment and personnel for congregate care of evacuees, was fully demon-

]

strated.

Congregate care facilities were located on the campus of Emporia State University where dormitory and other University-buildings were made available through prior agreement.

Suffi-cient shelter space is available on campus for all expected evacuees.

Shelter staff were aware of alternative resources, if-shelter capacities were exceeded.

University facilities con-tained sufficient sleeping accommodations which would have been available within 24-hours, as well-as sufficient

toilets, drinking
water, secure storage and parking for the expected evacuees.

Food supplies were available immediately, from the University cafeteria, >with support from the American Red Cross and Salvation Army warehouses within 24-hours.

Shelter facilities were staffed and equipped to handle dis-abled evacuees, such as those in wheelchairs, and a nursing sta-tion was established in the facility.

Quick access was available to hospital care and crisis coun-seling was available in the community.

Periodic briefings were held by the Center Manager to inform the public of events in the affected area and staff had been

)

briefed by the Center Manager regarding pertinent aspects of the care facility, such as how many evacuees were expected.

p Objective Number-34,- the ability to maintain staffing-on a

continuous 24-hour basis by an actual shift change, was fully demonstrated.

The organization demonstrated a shift' change at 1510.

Both Lyon County Reception and Care Center Managers, one from each of the two planned 12-hour shifts, were knowledgeable of Lyon County Reception and Care procedures.

Each Center Man-ager was familiar with the facility, layout and procedures-for the activation and operation'of the facility.

Both Center Managers were aware of procedures to provide monitoring and de-i ccntamination, congregate care locations, and the capability to provide congregate care.

60

l l

o J

a Summary:

One ARCA from the 1984. Wolf Creek exercise was corrected at this exercise, when communication linkages were uti-lized in accordance with present Plans.

Objectives fully demon-stratedt.

2, 3,

4, 6,

21, 22, and 34.

Area Recommended For Improvement j

~

i 4.

Decontaminated individuals should have access to

clothing, beyond simple paper gowns, for the trip from the Reception Center to the Congregate Care Center.

s I

l I

l 61

--r-,,s-r

-+wv--

--we- ----

.w

=o--

- - ~.

<2 a,e=-

.m-g

1 l

i samunar or narIcInucIns aun l

amans REQUIntmo comascTIva acTIow I

DEFICIEwCIES EmMSAS STATE OPERATIONS state amercena, onerations center f amoc) 1.

The SEOC failed to correct inadequate EBS messages _ generated by the CCEOC,. which resulted in inadequate instructions be-

)

ing issued to the public.

(corrected at remedial.)

Joint Radioloaioal Monitorina T----

(Jawest i

The JRMTs-provided an inadequate. demonstration of their role by using only one of the two evaluated field teams to define and-track the plume.

More specifically, this demonstration resulted in four defi-ciencies, numbers 2 through 5, for the JRMTs.

2.

One field team demonstrated the appropriate equipment and procedures for determining field radiation measurements.

The second team did not demonstrate this capability.

(Cor-rected at remedial.)

3.

One field team demonstrated the appropriate equipment and procedure for the collection of an airborne radiciodine sample in the presence of noble gases, except for a failure to aspirate the cartridge.

This team took the requisite air

samples, but the second team did not demonstrate this capa-bility.

(Corrected at remedial.)

4.

Neither team demonstrated the ability to obtain samples of particulate activity in the airborne plume and promptly per-form laboratory analysis.

one team partially demonstrated this objective by-taking an air sample.

However, it did not package the particulate
filter, nor dispatch it for transport to the laboratory for i

analysis.

The second team did not demonstrate this capabil-ity.

(Corrected at remedial.)

5.

Neither team fully demonstrated a shift change required for demonstration in 1989.

This failure caused the JRMTs to ex-ceed the six year requirement imposed by NUREG-0654, as redefined in Guidance Memorandum (GM) PR-1.

62

i One team partially demonstrated this objective by a

shift change of the County team member only.

The second team did not demonstrate this capability.

(corrected at remedial.)

COUNTY OPERATIONS coffav csunty =--enenov Oneratione center tecnoc)

G.

CCEOC drafted and released, to the SEOC, inadequate EBS mes-sages for dissemination of public emergency information.

These messages were inadequate in the following respects:-

a) evacuation messages failed to identify evacuation routes; j

b) the public was directed to Reception and Care. Centers 1

based upon the emergency planning sono subarea in.which.they i

reside; however, these subareas were not described in terms 1

of local landmark descriptions for each Reception and Care Center; c) the public was not informed of the Reception and-J Care Center to.which school children had been evacuated; and d) the EBS message erroneously informed the public of hospi-L tal and nursing home evacuations when no such-facilities were impacted.

(Corrected at remedial.)

Allen county Recention and care center 7.

Allen County failed to perform a shift change required for demonstration by 1989.

This failure caused this facility to exceed the.six year limit imposed by NUREG-0654, as rede-fined in GM PR-1.

(Corrected at remedial.)

Franklin county Recention and care center 8.

Franklin County failed to perform a shift' change required for demonstration by 1989.

This failure caused this facil-ity to exceed-the six year limit imposed by NUREG-0654, as redefined in GM PR-1.

(Corrected at remedial.)

AREA 8 REQUIRING CORRECTIVE ACTION KANSAS STATE OPERATIONS state Emercenev onorations center.11EOC) 1.

The SEOC Communications Center staff failed to distribute an EBS release to the Operations staff and the Information Clearinghouse staff after it was issued to the.public.

2.

The SEOC backup radio communications system with the plant EOF failed, i

r 63 l-l'

l 1

v.

l l

Dose Essessment/ Field Team Coordination 3.

Dose Assessment and Field: Team Coordination personnel-fa'iled L

to. record the implementation of a protective action on.the-status board and. logs for_,40 minutes.-

4.

The irdtial protective. action recommendation was released by the ' utility to the County and then the County to the SEOC l

without consultation / coordination with. State representatives at the. EOF.

This same' inadequacy was observed at the Sep-Ltember 1987. Wolf. Creek exercise-and remains'an-ARCA to be

[--

demonstrated at the next exercise.

t i

Forward Staging Area (FSA) 5.

. Telephone equipment. failed to work properly for the Kansas-

{

Highway': Patrol (KHP),

and radio communication traffic-was' also intermittent..

L 6.

Kansas National Guard (KNG).and KHP personnel were inad-j equately. equipped with dosimetry in that only a low range dosimeter.was worn.

TLDs and.~ film badges ware-available for distribution, but not distributed to the KHP; and, KNG per-sonnel entered the plume EPZ without dosimetry.

7.

KI wassnot distributed to KHP: personnel, although'KNG repre-sentatives had acquired KI for~ distribution to.them.-

8.

The KHP monitoringLinstrument=w&s out of calibration.

l Joint Radioloaical Monitorina Tamma (JRMTs ) -

9.

Teams failed to wear anti-contamination clothing.

(Cor-rected at remedial.)

10.

Dosimeters prepared for JRMT use were charged and recorded as. reading zero, when some read as high as-180 mR.

(Cor-rected at remedial.)

11.

Team 1 read and recorded dosimetry values only once during l

the entire' exercise.

(Corrected at remedial.)

l.l 12.

Team 1' members were. unaware of where vehicle' decontamination L

was available.

L 13.

Neither team knew their radiological dose ' limits.

(Cor-rected at remedial.)

14.

Team 2 failed to demonstrate the availability of all neces-sary equipment for field sample taking.

As an example, this did not demonstrate that they had preservative, cool-team 64

ers, scoops, shovels, clippers, ranania, ebb (corrected at remedial.)-

15.

Team-1-

did not adequately label col, samples.

The team j

failed to identify the size of the srea~from which samples-i were taken: (i.e.,:

a. square meter, or a square foot,

-etc.).

~

Failure to provide sample configuration-would _make ground deposition determinations impossible.

.(Team-I attempted to-correct-this ARCA'at the'remedialt

however, labeling of

-,l samples-was still inadequate and remains an ARCA to be cor-rected at the:next exercise.)

i 16.

Team-2 failed to-adequately' label vegetation! samples.-

The

-team -failed -to identify the size of,the area from' which j

samples'were taken (i.e., a: square meter, orLa square: foot,

{

etc.).

Failure to provide sample configuration would make

-ground deposition determinations-impossible.

(Corrected at remedial.)

17.

Both teams failed to monitor theEground: surface at sample locations prior to taking_ soil samples.

dial.)

' (Corrected at reme-

,D 18.. Team 1 failed to follow written procedures for soil sampling by collecting'a sgil sample 1/2-inch deep from an_ area ap-proximately 100 cm.

LSoil sampling procedures in the Plan and SOPS conflict'-2in that they provide for samples to be 2

from' areas of 625 cm or 1 m. -

(Corrected.attremedial.)

Radiolocical fa h ratory (mm.n) 19.

The laboratory measured / counted vegetation and-soilL sample

. aliquots without reference or documentation 1of the size of the original sample area, or the~ portion.of that sample I

which made up the aliquot analyzed.- This factor must be ad-dressed by' improved' procedures to assure:that' ground deposi-tion values can be derived from field sample analyses.

Information clearinehouse (Ic)

20. -The IC was commanded by the utility PIO although the State-PIO was to be in charge according to the: Plan._

4 21.

The first EBS message was not distributed to_IC staff-for two hours.

Mauia Release Center (MRC) 22.

The utility assumed the lead at media briefings in conflict with the State Plan.

65

L ::

a l

L

'2 3.

MRC staff were unable to provide the media with boundaries of the protective action areas using a map,- and failed to follow up on media requests for further information.

COUNTY OPERATIONS Coffav County Emercenav Onerations Cent'ar fCCEOC) 2 '4.

CCEOC personnel'were not issued dosimetry.

25.

One emergency worker dispatched to the field was not aware.

i of his exposure limits.

Unified school District 4243 - Waveriv 26.

The bus driver was not equipped with-either:a_mid or high range dosimeter capable of reading higher than'200 mR.

1 l

27.

The bus driver was unaware of how~and where'he would receive l

KI.

L r

3 a

I i

66

F i 4

REMEDIAIe EIERCISE r

p January 17-18, 1990 The deficiencies summarized.in Section 3 necessitated a re-medial exercise for the State _of Kansas SEOC and the-CCEOC.' This was held on January 18,11990.

.Other deficiencies necessitated a.

remedial exercise of'the JRMTs and the Allen and Franklin-County Reception and Care Centers.

These functions were redemonstrated-

-on January 17,-1990.

4.1 I&MSAS STATE OPEE1fIONS

}

4.1.1 Stata==-coenev onerations center famoc)

The remedial demonstration at the SEOC required the adequate

}

demonstration of Objective Number.13, so as to correct the SEOC's failure to' correct inadequate EBS messages disseminated' during the December 6, 1989' exercise.

Objective Number 13, the ability to coordinate.the formula-tion and dissemination of accurnte information and instructions to the public in a timely -fashion elfter the initial alert and no-tification has occurred,. wastfully-demonstrated.

Appropriate staff disseminated-instructions-to'the<public after the first i

alert and-notification sequence during'the remedial ' exercise.

The SEOC was notified of:SAE at 1033:and the initial protective action recommendation (PAR) required the evacuation of JRR.

-At j

1037, the CCEOC finished providing the text.of'the draft EBS mes-j sage to the SEOC and staff immediately contacted'the EBS station.

-(CCEOC and SEOC times differed slightly due. to clock dif-ferences.)

By 1038, the text had been provided to the. station and the station was directed tolair.the message at 1040.

The l

second PAR, received by-the SEOC at 1100, at the time of the Gen-

)

eral Emergency notification, recommended downwind sectors K,

L,

!~

and M be evacuated from 0 to 10 miles.

This area was defined as-subsones CTR, JRR, S-1, SW-1, W-1, S-2, SW-2 and W-2.

Milk pro-ducing animals were placed.on storedJfeed in the-same area.

CCEOC drafted the EBS message and telephoned it to the SEOC, fin-U ishing at 1112.

At that time, the SEOC called the EBS station to-convey the message for broadcast.

The message was completed-at 1115,. and the EBS station was told to broadcast it beginning at 1120.

These messages were rebroadcast every 15 minutes as indi-cated on-the prescripted messages.

The staff had access to current, accurate and timely infor-mation. -They obtained PARS from Wolf Creek and protective action decisions from'the CCEOC.

The SEOC then notified the CCEOC of the timing of the EB3 message broadcast.

Newly written 67

1 1

prescripted messages were used which corrected problems from the December 1989 exercise.

Message content was scrutinized to ensure that~ specific in-l adequacies within the-EBS messages,. observed atzthe" initial exer-cise, were~ corrected.

In these messages, protective action ~ areas were accurately described-in' terms of familiar ' landmarks and boundaries - for the affected areas..

Messagescincluded instruc-tions for transients without' shelter.

Evacuation routes and-the locations of Reception and Care Centers were identified in mes-sages for subareas of the EPZ which were defined by landmark..de-scriptions.

The public was correctly informed of the Reception and care Centers to which school children had been evacuated-and-i that hospital and nursing.home residents also were being evacuated.

' Formulation and dissemination of these messages were coordi-nated effectively and provided accurate _and. timely information to the public.

A log was maintained of all releases' disseminated. to the public and copies of releases were kept and were accessible to staff.

Return flow of information from'the SEOC to the CCEOC was accomplished well.

When the CCEOC' initially contacted the :SEOC with an EBS message, a time was specified for the broadcast of that message over EBS.

After the SEOC-had-given the message to

=-

the ESS station,- the'EBSEstation'was instructed to air that message.at the specified time.-

The CCEOC was then called to reconfirm the timing of the EBS broadcast.

The communications coordinator handledLEBS messagesJrapidly.-

Also commendable was the demonstration of the EBS station link in the remedial.-

The EBS calls were transmitted from.the SEOC to a simulated EBS station.

The message was actually taken down by a.

simulated EBS representative, allowing confirmation ~of accurate message transmission.

The message was then reread, as if by a

broadcaster, to assess the time'needed to read the; messages.

This redemonstration of Objective Number 13 corrected: the deficiency identified during the December 6, 1989 Wolf Creek ex-ercise.

4.1.2 Joint Radiolocical Monitorina Tomme (JRMTs F l-The deficiencies _for the JRMTs required correction through a shift change at a remedial exercise.

This shift change required.

four teams to fully demonstrate field team operations, two teams in a first shift and two teams in a second shift.

All three mem-bers of each team were required to demonstrate a shift ~ change.

f l

68

f L

To fully demonstrate field team operations, each team was required to demonstrate objectives. Number 4, 6,

7, 8, 9,E16, 27, and 34.

i Objective Number 4,.the ability to communicate with all-ap-propriate locations, organizations and field personnel, was fully demonstrated.'

i communications-traffic for bothLshifts of both field teams i

was: adequately handled by portable radios and. radios affixed to

-the field team vehicles.

Contact was maintained with the Field-Team Coordinator at the EOF.without any observed delay.or break-

'i down'.

Objective Number 6, the abliity to continuously monitor and.

i

. control emergency. worker exposure, was fully demonstrated.

Each team member was equipped with a TLD.and three. direct-reading dosimeters'..

The ranges of the dosimeters were O to 200 mR, -

O to 5 R and 0 to 200 R.

.Coffey County personnel'had been equipped by the County with Civil Dafense dosimeters at the:CCEOC and were, therefore, doubly" equipped.

Dosimetry'was provided to teams at the EOF, where a large stock was. stored, and-.where chargers were available.... Dosimetry was charged and initial val-ues were correctly recorded at the EOF.

This. corrected'an ARCA; cited for incorrectly. recorded initial readings-during the Decem-l ber 6, 1989 exercise.

During the remedial exercise, ' dosimetry was read and values recorded.each.30 minutes, when prompts were given,to the teams by

radio, and values'were reported to theLEOF for record keeping-at.

that location.

This corrected an ARCA: cited-for -insufficient monitoring and recording of dosimetry values'during the December 1

6, 1989' exercise.

]

l Appropriate instrucElons'were issued regarding desimeter use l-and. team members all-knew their radiological exposure limits.

All team members were aware of procedures to seek permission to.

exceed authorized exposure levels and what to do if they receive an exposure higher than authorized..This corrected an ARCA cited because team members failed to know their radiological dose' lim-its during the December 6, 1989 exercise.

One area is recommended for' improvement.

Field team kits should each include a dosimeter charger.

This capability would enhance team performance.

Teams are not presently capable of re-1 charging-dosimeters-in the field; they must return to the EOF'if recharging of dosimetry becomes necessary.

The teams were equipped with full anti-contamination cloth-ing including coveralls, hoods, boots and boot covers.

Team res-69

y

)

e.

l p

pirators had1available lens inserts for people with glasses.

To' l:

avoid. the public=. concern generated by teams-working _ in full L

anti-contamination gear, evaluators assessed the adequacy of team equipment and procedural training by having. members of the first o

shift dress out prior _to_ leaving the EOF.

Procedures for removal

-of this equipment were then_ demonstrated across e

simulated hotline.

.The first shift teams were then dispatched' to the field.

Second' shift personnel were permitted'.to-relieve the first-shift and perform their-duties without donning _ their anti-contamination clothing; however, upon conclusion of the ex-

arcise, the second shift demonstrated the: correct-use of protec-tive' clothing.

In, this way, withithe exception of sargical gloves, anti-contamination clothing was not worn in public.

This demonstration of-protective equipment-corrected an ARCA from.the December 6, 1989. exercise.

Objective Number 7, the appropriate' equipment and procedures for determining. field radiation measurements,. was fully demon-i strated.

The teams warm properly equipped, had access to equip-ment

spares, utilized an equipment. checklist, 'and performed battery and source checks.

Equipment had been calibrated within the prescribed time limit.

l Teams had maps showing predetermined' monitoring points and l

were able to promptly find and arrive at, monitoring locations.

-This endeavor was aided by the' local team-members who were famil-iar with the> area.

Vehicles were large enough.for all equipment and personnel.

Team members used the appropriate instrument and scale for the. range supplied by the controller. -Readings were logged along with' location, time, date and name of the monitor.

Determination of groundshine was demonstrated

.by.

taking gamma only and beta plus-gamma readings at about one. meter (waist level) and at about 2 cm (near_ ground. level').

. Field readings were transmitted promptly to.the EOF.

This corrected the defi-ciency.

Objective Number 8, appropriate equipment andLprocedures for the measurement of airborne radioiodine concentrations as low 7

as 10

(.0000001) microcurie per.cc in the presence of noble gases,.

was fully demonstrated.

The teams were equipped with cppropriate equipment which included an air sampler (pump).

Team vehicles were equipped with an inverter which provided-the power tooper-ate the sampler. -Teams used an appropriate iodine absorber (sil-ver zeolite) and particulate filter paper.

' Air samples were taken using the proper flow rate'and sample duration.

Sample components were properly bagged and labeled with time, date, lo-cation and identification of the person who took the samples.

Teams left the plume and traveled to a low background area'before attempting to count the air sample media with an instrument which 70 u

... ~

).

T s

was within its calibration date.-

Air cartridges were aspirated by hand prior to counting.1 This demonstration by-both teams _cor-1 rected the deficiency' cited in the December 6, c1989 exercise re-garding demonstration of this objective.

j A fixed (reproducible) geometry used to count the air sample i

media was transmitted promptly.to the EOF.

1 Teams demonstrated the procedures for converting the' count-ing data-to'radiciodine concentrations while'in the-field.

-1 Objective Number 9, the ability'to obtain samples of _ par-

[

ticulate activity in-the airborne plume and promptly perform laboratory-analysis, was fully demonstrated.

Teams in the first i

shift 1 took.their air samples separately'between.1050 and' 1130.

Both left'the plume-to count the samples and reported data-to the EOF between 1130-and 1155.

The JRMTs were directed by radio to be prepared for courier rendezvous and particulate sample pickup and_ transport.

Teams were directed to a specific rendezvous point.

"i The

courier, a Kansas Radiological' Control (RADCON) team member, had been staged for courier duty at'the EOF, and'had been equipped with anti-contamination clothing, dosimetry, communica-tions equipment, maps,.

a compass and a radio. equipped' vehicle.

He had.been-trained in procedures.for. sample handling.

i Samples were provided to the courier at the team rendezvous point between 1305 and 1330, and were delivered to the FSA at 1346.

i This series of events was repeated by teams in the afternoon.

both second shift i

At both rendezvous' between the courier and the' field teams, the same series of procedures was observed.

The courier and-field teams were directed to depart for the rendezvous point by the Field Team Coordinator at the EOF.

I The courier checked his dosimetry and' recorded his values and simulated donning his anti-contamination clothing.

He per-formed a radio check from his vehicle prior to. departing the EOF parking. lot.

He then proceeded to-the randezvous point and in-formed the EOF of his location.

Upon arrival of the teams, field-samples were inspected by the courier for-physically touching the sample containers. proper labeling without

-Once he was assured that proper labels were in place for each sample, the courier prepared a clean, clear plastic bag-for receipt of the sample container.

Field team members placed the-sawple within' the courier's clean bag without touching the clean bag.

The courier then carefully removed his rubber srrgical gloves, one at a time, 71 l

i I

placing each within the clean bag with the sample and sealed the

[

zip lock.

.The courier then donned fresh gloves and the procedure j

L was repeated until all~ samples were transferred.

V L

The courier then placed the samples carefully within the

vehicle, as far_'from the driver as possible.-

The courier monitored the: sample containers,-with a monitoring instrument, to a

ensure-that the samples wore: contained.and secure.

Then the~cou-rier notified the EOF that he was departing'the rendezvous' point, with the samples, to proceed to the FSA,1where the samples would I

have been-transferred to the KNG helicopter for airlift to.the State-RADLAB.. Transport of the samples from the rendezvous point l

to the FSA took 16' minutes, arriving at 1346.

1 l

The courier knew his dose limits and was knowledgeab1'e of the procedures he was to follow:if-he had exceeded his limits ;or 3

needed permission to. exceed same.

The courier was also well aware of the purpose and appropriate procedures for: KI instruc-y tion and use.

/

l objective Number 16, the< ability to distribute _and adminis-

~

ter KI, once the decision was made, was fully demonstrated.

In p

this remedial exercise, the Field. Team Coordinator ' communicated c

the State's decision to issue KI to the JRMTs.

Instructions for-t taking KI.were_ issued to both;the first and second shifts.

KI was availablerin sufficient quantities for.theiteam members, and r

supplies -carried an expiration date of 1990.

The majority of JRMT members.in both shifts-refused to take the.KI.

The EOF was notified and made a record of those individuals refusing KI.

Objective Number.27, the appropriate use of equipment and procedures for collection and transport of' samples _of vegetation, food crops, meat, poultry, water and annual. feeds (indigenous to the area and stored),

was not adequately demonstrated because of incorrect sample labeling.

Teams were able to find sampling locations promptly and dem-onstrated proper technique in sample collection.

Surface samples were taken-from a consistent geometric configuration, in that soil and vegetation samples were taken from a 1

square meter

?

area.

Ground surface radiation measurements were taken andL re -

corded at sample locations using an appropriate survey. instru-ment.

This demonstration corrected'an ARCA from the December 6, 1989 exercise.

Procedures were demonstrated for collection of soil, vegeta-tion and water samples only, hy prearrangement with FEMA.-

Teams were equipped with scoops and/or shovels, plastic col-lection bags with ties or fasteners, plastic containers, identi-72 s

t 1

/.

t o

I:

/

i fication

labels, writing materials, an area measuring-device,

'~/

-grass clippers, and-funnels.

This corrected an ARCA from the De -

cember 6, 1989 exercise.

L Written SOPS' were- 'available and-were-~followed.-

Field samples: taken by Team 2 were properly logged and : labeled with Ltime, date, location and other, pertinent data,.which corrected an

'ARCA-for. inadequate labeling,of. samples during the December-6, y

L 1989 exercise.'

The second shift of Team 1,

however, failed to B

include-the area.of the first vegetation sample and. incorrectly l

labeled'their'1 square meter vegetation and soil samples as being-l 1 cubic' meter.

Inadequite labeling of samples was identified as an ARCA during the Decem'aer 6, '1989 exercise and _ remains an ARCA~

for Team 1.to be corrected at the next exercise.

n

. Teams took soil samp1gs comprised of 1/2 inch of soil-from an area approximately 1 m in compliance with-one of the Plan SOPS.

This. corrected an ARCA from the December 6, 1989 exercise ~.

l 1

During sample taking, precautions.were taken~to: ensure that I

equipment used in. collecting samples was decontaminated prior.to the collection of additional samples.

Samples were transferred to a

courier at a rendezvous point for transport'to' the State

'l RADLAB.

Proper packaging and handling was employod for sample transport.

Objective Number 34, the ability to' maintain staffing on a

continued 24-hour basis by an actual shift change,.was fully dem-onstrated.,

All members of'both firsteshift teams were relieved-by their.second shift counterparts at 1330.'

' Incoming staff were briefed. appropriatelyEat the EOF by the State'and

utility, and again by~the outgoing team.

The second~ shift-staff demonstrated approprfspa knowledge-and capabilities of_the$.r emergency re-1 sponse roles and functions.

Twenty-four hour staffing capability l

L was demonstrated through simulation of two 12-hour shifts.

In summary, this'redemonstration of, Objectives Number 4, 6,

7,

.8, 9,

16, 27, and 34 1,y both field" teams-corrected the defi-ciency identified during the December 6,:

1989 Wolf' Creek exer-cise.

In addition, eight (8) of ten (10) ARCAs identified during that exercise were also. corrected.

Corrected'ARCAs have~ been identified again in the Summary of Deficiencies and-ARCAs, Sec-tio'n 3 of this report.

One:ARCA regarding' inadequate labeling of field samples by Team 1 remains to be corrected at the next exer -

cise..

[ Teams did not attempt to correct ~the other ARCALwhich was 1

cited because team members. failed to know where ' decontamination I

would be provided.- This ARCA remains to be corrected at the next exercise.)

One new ARFI was identified during the remedial exer-cise.

73 1

31 k

L '.

Area Recommended for Improvement

-f 1.

It was recommended that field team kits be equipped with do-simeter. chargers.

Presently, teams must return to the EOF if recharging of dosimetry _becomes:necessary, i

4.2 COFFEY COUNTY OPERATIONS i

1 4.2;1 coffew county =--connev onerations center (cenobl The remedial demonstration'ofLthe CCEOC required-the ad-equate demonstration of Objective Number 13._

This was necessary to correct the CCEOC's failureLto draft, and release to the SEOC, g

adequate EBS messages for dissemination of_public emergency in-t formation.

l Objective Number 13, the ability-to coordinate the formula-E tion 'and dissemination of accurate 1information and; instructions to the public.in a timely manner afterlthe. initial alert and no-

)

tification has occurred,-was fully _ demonstrated.

~'

Appropriate staff / disseminated'instructionsto Ithe' public after the.first alert and notification sequence in tl.e-remedial exercise..

The initial protective action instruction occurred ~at the. notification of SAE and required evacuation of JRR-

'The CCEOC was notified.of the-SAE at.1029.- At 1030,xthe CCEOC called the SEOC.to transmit the draft.EBS message for review:and broad-cast over EBS.;

The message was-completed at 1035 and the pro-posed time for broadcast was specified-to be:at'1040.

At 1038',

the CCEOC ordered sirens to be sounded at 1039, so. that they would proceed the EBS' massage broadcast.

At 1039, -the SEOC called the CCEOC to' confirm.that the message release would occur at 1040,_and were informed that sirens had been sounded.

At 1101, the CCEOC was notified of thel General Emergency and

~

received the recommendation that an. expanded evacuation be_under-taken which includsd subtenes JRR, CTR, S-1,.S-2, SW-1, SW-2, W-1 and W-2.

At 1102, the simulated County Commissioner was informed of the situation. and maps were consulted.

The _ decision to evacuate this area was~ concurred upon at'1104 and'the CCEOC staff began constructing the EBS message.

At 1109, the CCEOC contacted;the.SEOC withz the EBS message which directed the evacuation of the affected'EPZ_subzones.

Milk producing animals were placed-on stored. feed in the same area.

Upon completion of this message, it was agreed that 1120 would be specified as the time of broadcast. _ Rebroadcast would occur ev-

~

ery 15 minutes according to the instructions on the message.

i Staff had access to current and-accurate

.information and utilized prescripted messages which had been rewritten to correct 74

t -

r i

probleas' identified in the deficiency from the December 1989 ex-arcise.-

Message: content was: scrutinized to: ensure correction of pre-r vious. inadequate message content.

Protective action' areas were described in-terms of familiar landmarks and boundaries for the affected areas.

Messages included instructions for transients without shelter.

Evacuation routes and-the-locations of reloca -

tion' centers were properly identified in.nessages for subzones of the EPZ which were defined by;1andmark-descriptions.

The :loca-l tions of Reception and Care Centers to which evacuated -school children had been sent were also included.

The public was prop--

l erlyLinformed that hospitals. and _ nursing: home residents were be-ing. evacuated.

l.

Formulation and dissemination of these messages Sere'coordi-nated effectively and provided accurate and timely information to the public.

A log was-maintained of all releases.

\\

This.redemonstration of Objective Number 13 corrected -the deficiency identified at the December 6, 1989 Wolf Creek exer-cise.-

4.2.2 Allen County Recention and care ~ Center L

Objective to be demonstrated for remedial-action was:

3 4 '.

L

.This deficiency resulted from a failure to perform a ' shift change required for demonstration by 1989.

This failure caused this facility to exceed the'six year limit imposed by NUREG-0654, as redefined in GM PR-1, and is a deficiency.

l The two Allen County Reception and Care Coordinators, one l

from each of-two planned 12-hour _ shifts,. were interviewed separately; - one during the December 6, 1990 Wolf Creek exercise and one during this remedial exercise.

Both were knowledgeable of Allen County Reception'and Care procedures.

Each coordinator i

was familiar with the facility, layout and procedures for the ac-tivation and operation of the facility.

Both_ Coordinators were aware of procedures to provide monitoring and decontamination, t

transportation to Congregate care Centers, Congregate Care Center locations and the capability to provide congregate care'.

These shift leaders adequately demonstrated their indepen-dent understanding of the operation of the center and :how they would brief their replacements-during-a shift change.

This defi-ciency is closed.

l 4.2.3 Franklin County Reception-and Care Center Objective to be demonstrated for remedial action was:

34.

75 i

L --.

h J : ti.

o' l --

.This. deficiency resulted from a failure to perform a : shift

change required for demonstration by 1989.=

This failure -caused this facility-to exceed the six year limit imposed by.NUREG-0654, as-redefined in GM PR-1, and is a deficiency.

The two Franklin County Reception and Care Coordinators, Lone-from each lof two planned 12-hour

shifts, were interviewed separately; one during the December 6,-

1990 Wolf Creek exercise-and:one during this remedial exercise.:

Both were-knowledgeable of Franklin County Reception and care procedures.- Each coordina-tor was familiar with the-facility,. layout and procedures for:the activation and operation of the facility.

Both coordinators were'

~

' aware of. procedures'to provide monitoring and decontamination,

. transportation to Congregate care Centers, Congregate Care Center locations and the capability to provide congregate care.

q These shift leaders adequately demonstrated their indepen-dent understanding of the operation of the center and how: - they 3

would brief their replacements during-a shift change. -This-defi-ciency is closed.

i

?

l I

I

1 k

I

(

s i

i 76 i

dr