ML20042G640
| ML20042G640 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/09/1990 |
| From: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Cottle W SYSTEM ENERGY RESOURCES, INC. |
| References | |
| NUDOCS 9005150192 | |
| Download: ML20042G640 (3) | |
Text
f -@F 1
- )
g(p,ggzl af w
+
-MAY 0 91990 l
Docket No. 50-416 ( 50-911
,3._
License No. NPF i,
< System Energy Resources, Inc.
5: ATTN:' Mr. W.1 T. Cottle, Vice President 3
Nuclear Operations P. O. Box 469
-Port Gibson, MS 39150 T
Gentlemen:
3
SUBJECT:
FEMA FINAL REPORT - GRAND GULF NUCLEAR STATION EMERGENCY EXERCISE OF. SEPTEMBER 27,'1989 Enclosed is a copy of the Federal Emergency Management Agency's Final Report for.
.)
the Grand Gulf Nuclear Station Emergency Exercise of September 27, 1989.
As described in the. enclosure, FEMA did not identify any deficiencies; however, 1
8 areas recommended for-_ improvement were identified.
d We encourage you to assist the. appropriate organizations in ' resolving the weaknesses identified by FEMA.
Resolution of-these items should be completed prior ~to the_ next full scale emergency preparedness exercise.
~
We also encourage-you to work closely with the State and' local jurisdications in the development of' a scenario for-the next' full scale exercise that will-effectively test-those areas recommended for improvement.
Your cooperation in this matter isl appreciated.
Sincerely, l
crMw,L magro 3y a
IX ' "':
1 5 l'i C C l u m Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch-Division of Radiation Safety and Safeguards 1
Enclosure:
FEMA Final Report i
cc w/ encl:
(See page 2)
J 9005150192 900509
\\
PDR ADOCK 05000416 p
gg PDC
[
! ":-)
y, System Energy Resources, Inc.
2 L.
F
.cc w/ enc 1:
T. H. Cloninger, Vice President-Nuclear Engineering and Support-L
' System Energy Resources, Inc.
,.P.-0. Box 31995 Jackson, MS 39286-C.'R. Hutchinson, General Manager Grand Gulf Nuclear Station F
System Energy Resources Inc.
P. O. Box 756 Port Gibson, MS 39150 J. G.-Cesare, Director-Nuclear Licensing.
' System Energy Resources, Inc.
P.: 0.' Box' 469
-Port Gibson,.MS' 39150 Mr. Ralph T. Lally:
.q Manager of Quality Assurance 1
Entergy.Strvices, Inc.
1
.)
P..O. P4x 31995
-Jackson, MS 39286 1
I
~R. B. McGehee, Esq.
. Wise, Carter, Child, and Carawey-P. 0. Box 651
_Y
. Jackson, MS -39205 i
N.-S. Reynolds, Esq..
i Bishop, Cook, Purcell'& Reynolds 1400 L Street,.NW -.12th Floor j
Washington, D.-C.
20005-3502' i
l C. B..Hogg, Project Manager i
Bechtel Power Corporation
)
U
,P. O. Box'2166 L
Houston, TX 77252-2166 Te Alton B. Cobb, M.D.
State Health Office State Board of Health P. O. Box 1700 Jackson, MS 39205 (cc w/ enc 1:
Cont'd on page 3)
(
{f a:
s.; +;
3 t
System Energy Resources, Inc.
3-Q l
-t
.(cc w/ enc 1:- cont'd)--
The' Honorable William J. Guste, Jr.
1
- Attorney. General
-Department of. Justice State of Louisiana Baton Rouge, LA 70804 Office of the Governor LState of Mississippi Jackson,'MS-39201 '
P-W Attorney, General-Gartin Building'-
3 Jackson, MS 39205 l
a Jack McMillan, Director a
Division of Solid. Waste Management
--Mississippi Department of-Natural Resources 1
P 10. Box 10385 Jackson, MS.39209
~j
- President-Clairborne County. Board-
.of Su]ervisors.
. Port-;Giason, MS' 39150 bec w/ encl:
L. Kintner, NRR.
4
^
Document Control' Desk
'NRC Resident Inspector U.S. Nuclear Regulatory Commission H
Route 2, Box 399 Port Gibson,'MS, 39150 i
- 3. '
t
~
RJIj6RSS DRSS [ll RII:DRSS j >a(conAW WHRankin 39 a DMCollins BB
/I 5 /c/90
/g/90
/ /90
,fh y
?
1 fi r
b6' 8'
i e
c.i 9:y., % Federal Emergency Management Agency fj$g!
/
Washington, D.C. 20472
.-a
]
APR 201990 1
Mr. Frank J.~Congel Director, Division of Radiation Protection and Emergency Preparedness Office of-Nuclear Reactor Regulation j
U.S. Nuclear. Regulatory Commission Washington, D.C.
20555
Dear.Mr. Congel:
Enclosed is a copy of'the exercise report of the September 27, 1989,. joint, partial-participation exercise of the offsite radiological emergency-preparedness plans for the State of
. Louisiana and local jurisdictions site-specific to the Grand Gulf Nuclear Station.
Participants in this exercise for the Louisiana portion of the emergency. planning zone (EPZ) included the State-of Louisiana and Tensas Parish. This report was prepared by the-Federal Emergency Management Agency's (FEMA) Region VI staff.
There were no deficiencies or areas. requiring. corrective action identified during this' exercise; however, several areas-recommended for improvement were identified.
Based on the results of this exercise, the offsite radiological emergency
(
plans and preparedness are adequate to provide reasonable assurance that appropriate measures'can be taken offsite to t
protect the health and safety of the public in the event of a
, radiological emergency at the Grand Gulf Nuclear Station.
- Thus, the'44 CFR 350 approval for-Louisiana granted on June 23, 1983,
' remains in effect.
Should you have any questions, please contact Craig S. Wingo, Chief, Technological Hazards Division, at 646-3026.
Sincerely, b /5 3
I
- y J'
)
Dennis H. Kwiatkowski Assistant Associate Director Office of Natural and Technological Hazards Programs l
Enclosure t
p,
L
o
., g, 9
FINAL RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE REPORT Nuclear Power Plant: Grand Gulf Nuclear Station
~
Location of Plant:
Port Gibson, Mississippi Date of Report: April 1,1990 Date of Exercise: September 27,1989
'i1
Participants:
State of Loulslana Tensas Parish, Loulslana L
Winnsboro Reception / Care Center, Winnsboro, Loulslana Mahoney Ambulance Service, St. Joseph, Louisiana Federal Emergency Management Agency Region VI-Federal Regional Center 800 N. Loop 288, Denton, TX 76201 T - - y M,v l-y "TT
+
,[,.
- ..s FINAL RADIOLOGICAL EMERGENCY;.
PREPAREDNESS EXERCISE REPORT Nuclear Power Plant:
Grand Gulf Nuclear Station
.i Location Of Plant:
Port Gibson, Mississippi Date of-Report:
April 1, 1990.
Date of Exercise:
September 27, 1989 i
L i
Participants:
State-of Iouisiana Tensas Parish, Louisiana.
Winnsboro Reception / Care Center, Winnsboro, Louisiana-Mahoney Ambulance Service, St. Joseph, Louisiana i
I
'1 FEDERAL EMERGENCY E\\NAGEMENT AGENCY Region 7I I
Federal. Regional Center 800 N. Ioop 188 Denton, TX 76201 l.
i I:
L-l l'
1' m
pn t
CONTENTS r
ABBREVIATIONS / ACRONYMS.
iv.
. INTRODUCTION AND AUTHORITY v-l' EXERCISE BACKGROUND' 1
1 1 '1 Exercise Summary 2
1.2 Federal Evaluators 3
1.3 Off site Agency Exercise Objectives 3
1.4 Exercise Scenario Summary 7
1.4.1 Master Sequence of Events 7
1.5 Evaluation Criteria 12 2 EXERCISE EVALUATION 13 2.1 Louisiana State Operations 13 2.1.1 LNED Operations at GGNS EOF 13 2.1.2 Louisiana' State EOC 14 2.1.3 Emergency News Media Center 15 2.2 Local Jurisdictions and Support Organizations 17 2.2.1 Tensas Parish EOC 17
'2.2.2 Emergency Worker / Vehicle Monitoring /
Decontamination (Tensas Parish EOC) 19 2.2.3 Winnsboro Reception / Care Center 20' 2.2.4.Mahoney Ambulance EMS 21 2.3 School Evacuation Demonstration 22 2.4 Utility Issues 23 3 TRACKING SCHEDULE FOR STATE / LOCAL ACTIONS TO CORRECT.
DEFICIENCIES AND AREAS REQUIRING CORRECTIVE ACTION 24 4 EVALUATION OF OBJECTIVES 26 3
4.1 Summary of FEMA Objectives Remaining to.Be Met 26 4.2 FEMA Objectives Tracking -
Grand Gulf Nuclear Station 26 TABLES 1 Remedial Actions for the September 27, 1989 Grand Gulf Nuclear Station Exercise 25 2 Summary of FEMA Objectives Remaining to Be Met as of September 27, 1989, Grand Gulf Nuclear Station 27 l
3 FEMA Exercise Objectives Tracking Chart -- Grand Gulf Nuclear Station as of September 27, 1989 28 iii i
ABBREVIATIONS / ACRONYMS A/N' Alert and Notification ANL Argonne National, Laboratory ARCA' Areas Requiring Corrective Action l
-ARTIL Areas Recommended for Improvement.
'CD Civil Defense DOE - Department of Energy DOT - Department of Transportation EBS Emergency Broadcast System ECL. - Ersrgency Classification Level o
EEM Exercise _ Evaluation Methodology ENMC Emergency News Media Center EOC' Emergency ~ Operations Center EOF = - Emergency Operations Facility EPA Environmental Protection Agency EPZ Emergency Planning Zone FEMA
-Federal Emergency Management Agency FRC
' Field Response Center GGNS Grand Gulf Nuclear Station GM Guidance Memorandum HHS.- Health and Human Services
- HP Health Physicist
INEL -' Idaho National Engineering Laboratory KI
-Potassium Iodide LNED Louisiana Nuclear Energy Division LOEP Louisiana Office of Emergency Preparedness LP&L Louisiana Power and Light Company 1
LPRM-Local Power Range Monitors
-1 MEMA Mississippi Emergency Management Agency MP&L Mississippi Power and Light Company NOUE
-Notification of Unusual Event NRC Nuclear Regulatory Commission PAG. - Protective Action Guide PAR - Protective Action Recommendation PIO - Public Information Officer RAC - Regional Assistance Committee RDO - Radiological Defense Officer SAE Site Area Emergency TLD
- Thermoluminescent Dosimeter USDA - United States Department of Agriculture t
iv
{
i
b INTRODUCTION AND AUTHORITY On December 7., 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume the lead role responsibility for all off.
site nuclear power facility planning and response.
~
FEMA's immediate basic responsibilities in Fixed Nuclear Facility
. Radiological Emergency Response Planning include:
Taking the lead in off-site emergency response planning and in the-review'and evaluation of State and local government emergency.
plans, ensuring that the plans meet the Federal criteria set. forth in NUREG 0654/ FEMA REP 1. Rev. 1 (November 1980),
Determining whether the State and local emergency response plans e
a can be implemented on the basis of observation and evaluation of exercises conducted by the appropriate emergency response jurisdictions, Coordinating the activities of volunteer organizations and other e
involved Federal agencies.
Representatives of these agencies, listed below, serve as members of the Regional Assistance Committee (RAC), which is chaired by FEMA.
- 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 (DHHS)
- U.S. Department of Transportation;(DOT)
U.S. Department of Agriculture (USDA)-
U.S. Department of Interior (DOI)
U.S. Food and Drug Administration (FDA) l V
1 1 EXERCISE BACKGROUND The September 27, 1989 Grand Gulf Nuclear Station (CCNS) Emergency Preparedness Exercise was the seventh such exercise at chis facility.
It was designed to test and demonstrate the emergancy response capabilities of off-site organizations within the Plume EPZ of the Grand Gulf Nuclear Station.
Previous exercises at this facility, during the initial six year exercise cycle, have demonstrated all of the 36 required FEMA exercise objectives.
A standard exercise interval for redemonstrating each of the objectives has now been established.
The previous exercises were held on November 4, 1981; January 26, 1983; April 11, 1984; February 27, 1985; December 3 4, 1985 and November 17 18, 1987.
Remedial drills designed to correct deficiencies discovered in these exercises have also been held.
The Federal Emergency Management Agency, Region VI, evaluated the 1
off site emergency response capabilities of Louisiana State and/or local jurisdictions during each of these exercises.
The State of Louisiana partially participated and Tensas Parish fully participated in the 1989 exercise.
The Grand Culf Nuclear Station is located on the east bank of the Mississippi River near Port Gibson, Mississippi.
Portions of the 10 mile Plume EPZ extend across the river into Tensas Parish, Louisiana and the 50-mile Ingestion Pathway EPZ extends well into Louisiana.
FEMA Region VI is responsible for evaluation of off site emergency response capabilities of State and local governments in these areas.
On September 28, 1989, three post exercise meetings were held. The first, an 8:00 a.m. meeting of the 11 member Federal evaluation team at the Ramada Inn, Natchez, Mississippi, provided the FEMA Region VI RAC chairman with a detailed preliminary evaluation.
The second, a 1:30 p.m.
Federal / State / Local Critique, also held at the Ramada Inn, < resented preliminary results of the exercise to representatives of 6: ate / local participating organizations.
The third, a 6:00 p.m. Public Critique, held at the Tensas Parish Courthouse, St. Joseph, Louisiana, presented the preliminary exercise results to the public and provided an opportunity for public comment.
Section 2 of this exercise report provides narratives and evaluations of exercise performance by participating response organizations, as well as descriptions of any Deficiencies, Areas Requiring Corrective Action or Areas Recommended for Improvement noted by the exercise evaluators.
No Deficiencies were identified at this exercise.
Section 3 of thit report is a tabulation of any Deficiencies or Areas Requiring Corrective Action observed during the 1989 exercise, and provides, in Table 1, a tabular listing of any recommended corrections, space for State / local response, proposed dates for acccmplishment, and FEMA evaluation of the proposec actions.
Section 4 of this report compiles, in tabular format, the current status of all FEMA objectives required to be demonstrated at this location, based on the standards established in NUREG-0654/ FEMA REP 1, Rev.1 and GM EX 3.
2 The findings presented herein have been reviewed and have been approved by the RAC Chairman for FEMA Region VI.
FEMA suggests that State and i
i local jurisdictions take remedial actions in response to each of the issues (if any) indicated in this report and that the State submit a schedule for addressing these issues. The FEMA kegion VI Regional Director is responsible for certifying to the FEMA Associate Director for State and Local Programs and Support, Washington, D.C., that any Deficiencies and Areas Requiring Corrective Action have been or will be corrected and that such corrections have been incorporated into State and local plans, as appropriate.
The following provides a brief overview of the 1989 exercise performances of the State of Louisiana and Tensas Parish government organizations. More detailed explanatory discussions of performance at individual exercise locations are provided under the appropriate headings in Section 2 of this report.
1.1 EXERCISE
SUMMARY
State of Louisiana Operations State operations for the Grand Gulf Nuclear Station exercise were directed, prior to the declaration of the Site' Area Emergency (SAE), from the offices of the Louisiana Nuclear Energy Division (LNED) in Baton Rouge.
Following the SAE declaration, direction and control shifted to the State EOC
[ Louisiana Office of Emergency Preparedness (LOEP) offices), also in Baton Rouge.
At the State EOC, the LNED and LOEP Directors act in concert to manage State response.
State agencies having designated emergency response assignments also are represented at the State EOC so that response activities may be directly coordinated among these agencies.
The State was represented at the Emergency News Media Center at Port Gibson, Mississippi by an LNED technical liaison representative assigned to ensure coordination of all media releases and provide Louisiana representation at all media briefings.
All State agencies participating in the exercise demonstrated an adequate level of readiness for dealing with a radiological emergency.
Individual narratives which follow in Sec. 2.1 of this report provide detailed explanations of State activities demonstrated during the exercise.
Local Government Operations Tensas Parish is the only Louisiana Parish within the 10 mile Plume EP2 for the Grand Gulf Nuclear Station, with the exception of a small, uninhabited area of Madison Parish for which Tensas Parish has agreed to provide emergency response management.
All or part of eight additional parishes are included in the 50. mile Ihgestion Pathway EPZ.
The eight additional parishes did not participate in this exercise as the State has primary responsibility for all ingestion pathway activities.
Tensas Parish fully partic.ipated in all phases of this exercise.
4 3
Tensas Parish demonstrated an adequate level of preparedness for dealing with a radiological emergency.
Individual narratives which follow in Sec. 2.2 of thi.s report provide detailbd descriptions of activities demonstrated during the exercise.
1,2 FEDERAL EVALUATORS Eleven Federal evaluators participated in evaluating the September 27, 1989 Crand Gulf Nuclear Station exercise.
These individuals, their agencies and their evaluation assignments are listed below:
Evaluator Atency Evaluation Assignment Cary Jones FEMA Overall Evaluator Coordination RAC Chairman Jim Cox DOT State EOC, Baton Rouge, LA Carl McCoy FEMA State EOC, Baton Rouge, LA Frank Wilson ANL LNED Operations, GCNS EOF Dana cessna FEMA Emergency News Media Center, Port Gibson, MS Bobbye Harris FEMA Emergency News Media Center, Port Gibson, MS Bill Casper ANL Tensas Parish EOC, St. Joseph. LA Nancy Culp FEMA Tensas Parish EOC, St. Joseph,,LA Lee Peyton FEMA Mahoney Ambulance EMS Service, St. Joseph, LA Tom Carroll ANL MAhoney Ambulance EMS Service, St. Joseph, LA Al Lookabaugh ANL Winnsboro Reception / Care Center, Winnsboro LA 1.3 0FF SITE AGENCY EXERCISE OBJECTIVES (AS SUBMITTED BY THE STATE OF LOUISIANA)
(Objectives are numbered in accord with FEMA Region VI standard list)
STATE OF LOUISIANA LNED OBJECTIVES OBJECTIVE 1:
EMERCENCY CLASSIFICATION LEVELS Demonstrate the ability to monitor, understand and use emergency Classification Levels (ECL) through the appropriate implementation of emergency functions and activities correspaachng to ECLs as required by the scenario.
The four ECLs are:
Notification of Unusual Event, Alert, Site Area Emergency and General Emergency, i
i 4
l j
OBJECTIVE 2:
MOBILIZATION OF EMERGENCY PERSONNEL Demonstrate the ability to fully alert, mobilize and activate personnel for both facility and field based emergtney functions, i
OBJECTIVE 3:
DIRECTION AND CONTROL Demonstrate the ability to direct, coordinate and control emergency activities.
OBJECTIVE 4; COMMUNICATIONS Demonstrate the ability to communicate with all appropriate locations, organizations, and field personnel.
OBJECTIVE 5:
FACILITIES, EQUIPMENT AND DISPLAYS Demonstrate the adequacy of facilities, equipment, displays and other materials to support emergency opera tions.
OBJECTIVE 6:
EMERGENCY WORKER EXPOSURE CONTROL Demonstrate the ability to continuously monitor and control emergency worker exposure.
OBJECTIVE 10:
PLUME DOSE PROJECTION Demonstrate the ability, within the plume exposure pathway, to project dosage to the public via plume exposure, based on plant and field data.
OBJECTIVE 11:
PLUME PROTECTIVE ACTION DECISION MAKING
[
Demonstrate the ability to make appropriate protective action decisions, based on projected or actual dosage, EPA PAGs, availability of adequate shelter, evacuation time estimates and relevant factors.
OBJECTIVE 13:
ALERT, NOTIFICATION AND EMERGENCY INFORMATION PUBLIC i
INSTRUCTIONS Demonstrate the ability to coordinate the formulation and dissemination of accurate information and instructions to the i'
public in a timely fashion after the initial alert and notification has occurred.
STATE OF LOUISIANA - LOEP OBJECTIVES l
OBJECTIVE 4:
COMMUNICATIONS Demonstrate the ability to communicate with all appropriate locations, organizations, and field personnel.
1
7_
s Y..
i TENSAS PARISH EOC OEJECTIVES f
OBJECTIVE 1:
EMERGENCY CLASSIFICATION LEVELS Demonstrate the ability to monitor, understand and use i
Emergency Classification Levels (ECL) throu5h the appropriate implementation of emer.gency functions and activities 3
corresponding to ECLs as required by the scenario.
The four ECLs are:
Notification of Unusual Event, Alert, Site Area Emergency and Geraral Emergency.
OBJECTIVE 2:
MOBILIZATION OF EMERGEb'CY PERSONNEL-Demonstrate the ability to fully alert, mobilize and activate personnel for both facility and field based emergency functions.
L OBJECTIVE 3:
DIRECTION AND CONTROL Demonstrate the ability to direct, coordinate and control emergency activities.
OBJECTIVE 4:
COMMUNICATIONS Demonstrate the ability to communicate with all appropriate locations, organizations, and field personnel.
OBJECTIVE 6:
EMERCENCY WORKER EXPOSURE CONTROL Demonstrate the ability to continuously monitor and control emergency worker exposure.
OBJECTIVE 5:
FACILITIES, EQUIPMENT AND DISPLAYS Demonstrate the adequacy of facilities, equipment, displays and other materials to support emergency operations.
OBJECTIVE 12:
ALERT, NOTIFICATION AND EMERGENCY INFORMATION INITIAL ALERT AND NOTIFICATION Demonstrate the ability to initially alert the public within the 10 mile EPZ and begin dissemination of an instructional message within 15 minutes of a decision by appropriate State and/or local official (s).
OBJECTIVE 13:
ALERT, NOTIFICATION AND EMERCENCY INFORMATION PUBLIC INSTRUCTIONS Demonstrate the ability to coordinate the formulation and dissemination of accurate information and instructions to the public in a timely fashion after the initial alert and notification has occurred.
OBJECTIVE 14:
ALERT, NOTIFICATION AND EMERGENCY INFORMATION MEDIA Demonstrate the ability to brief the media in an accurate, coordinated and timely manner.
OBJECTIVE 15:
ALERT, NOTIFICATION AND EMERGENCY INFORMATION RUMOR CONTROL Demonstrate the ability to establish and operat'e rumor control in a coordinated and timely fashion.
V
)
s a-OBJECTIVE 19:
IMPLLMENTATION OF PROTECTIVE ACTIONS EVACUATION OF SCHOOLS Demonstrate the ability and resources necessary to implement appropriate protective actions for school children within the plume EPZ.
OBJECTIVE 25:
DECONTAMINATION Demonstrate the adequacy of facilities, equipment, supplies, procedures and personnel for decontamination of emergency workers, equipment and vehicles and for waste disposal.
t TENSAS PARISH MEDICAL OBJECTIVES t
OBJECTIVE 2:
MOBILIZATION OF EMERGENCY PERSONNEL Demonstrate the ability to fully alert, mobilize and activate personnel for both ficility and field based emergency l'
functions.
OBJECTIVE 4:
COKMUNICATIONS Demonstrate the ability to communicate with all appropriate locations, organizations, and field personnel.
OBJECTIVE 6:
EMERGENCY WORKER EXPOSURE CONTROL Demonstrate the ability to continuously monitor and control emergency worker exposure.
OBJr.CTIVE 23:
MEDICAL SERVICES TRANSPORTATION Demonstrate the adequacy of vehicles, equipment, procedures and personnel for transporting contamir.ated, injured or exposed individuals.
TENSAS PARISH RECEPTION CENTER AT WINNSBORO, LOUISIANA - OBJECTIVES OBJECTIVE 2:
MOBILIZATION OF EMERGENCY PERSONNEL Demonstrate the ability to fully alert, mobilize and activate personnel for both facility and field based emergency functions.
OBJECTIVE 4:
COMMUNICATIONS Demonstrate the ability to communicate with all appropriate locations, organizations, and field personnel.
OBJECTIVE 6:
EMERGENCY WORKER EXPOSURE CONTROL Demonstrate the ability to continuously monitor and control emergency worker exposure.
OBJECTIVE 21:
RELOCATION CENTERS REGISTRATION, MONITORING, AND DECONTAMINATION Demonstrate the adequacy of procedures, facilities, equipment and personnel for the registration,' radiological monitoring and decontamination of evacuees.
)
7
?
OBJECTIVE 22:
RELOCATION CENTERS CONGREGATE CARE Demonstrate the adequacy of facilities, equipment and personnel for congregate care of evacuees.
1.4 EXERCISE SCENARIO
SUMMARY
The 1989 Grand Gulf Nuclear Station Radiological Emergency Preparedness Exercise, to be conducted on September 27, 1989, will test and provide the opportunity to evaluate CGNS's Emergency Plan and Procedures.
It will also test the emergency response organization's ability to assess and respond to emergency conditions and coordinate efforts with other agencies for protection of the health and safety of the public.
The scenario will depict a simulated sequence of events, resulting in sufficiently degraded conditions to warrant the mobilization of CCNS, State and local agencies to respond to the emergency.
The evaluated exercise will have full participation by the GCNS emergency response organization, and State of Mississippi, Claiborne County, and Tensas Parish, and partial participation by the State of Louisiana.
Vhenever practical, the exercise vill incorporate provisions for " free play" on the part of the participants.
1.4.1 Master Sequence of Events (As Submitted by the Scenario Committee)
Actual Scenario Time
_ Time Summary 0700 00/30 INITIAL CONDITIONS
- Grand Gulf Unit 1 is operating at 100% power for 300 full power days, following a routine refueling outage.
GCNS did, however, experience problems with condenser circulating water in. leakage, so the condenser waterboxes have been entered recently (within the last two weeks) for leak detection and condenser tube plugging.
Unit 2 remains under construction.
- The HPCS pump is out of service due to a severe bearing problem causing excessive vibration. HPCS is torn down to allow bearing replacement.
A 14 day LCO has been in effect since noon yesterday.
Repairs will take at least two more days.
- A reactor coolant leak rate test is in progress to determine whether an existing 2 gpm unidentified leak has worsened.
l
an l
8 Actual Scenario Time Time Summary
- The "B" CRD pump is out of service for pump seal _ replacement.
It is expected to be sepaired within 4 days.
- The "A" SLC pump is inoperable due to failed heat tracing at the pump suction.
"A" SLC' is tagged out and its piping is opened to remove solidified sodiu.n pentaborate.
The i
- The site ambulancs is in Vicksburg for replacement of a blown engine.
It is expected to be returned to the site within three days, The grid is unstable due to unusually high e
demand caused by a heat wave, coupled with unexpected forced outages at Waterford 3 and ANO 1.
The load dispatcher has requested that Grand Gulf provide full power to the grid to avoid industrial load shedding.
LER 87 235 20, which describes the failure o
of the SRV electrical function at the Brunswick Steam Electric Plant (BSEP). has been forwarded to all licensees for review, regardless of the type of valves installed in the plant.
The LER describes a condition caused by the hardening of LOCTITE' sealer around the actuating solenoids, which prevents electrical functioning of the SRVs.
while allowing the mechanical function to i
I remain operable. GGNS management has decided to continue full power operation while engineering investigates this issue.
Management has directed that no SRV testing be performed until engineering has completed its investigation.
0730 00/00 Initisi ecai.tions are established.
Commence Grats Gulf 1989 Evaluated Exercise.
0740 00/10 A minor fire is reported in the oil storage locker of the Turbine Building 93' i
elevation.
Off-site fire fighting assistance is not required, j
0748 00/18 The fire is extinguished by the Fire Brigade.
p i
9 Actual Scenario Time Time SumrntII 0800 00/30 Control Room indications show that RCS unidentified leakage has increased to i
greater than 50 gpm.
A controlled shutdown j
may be commenced.
ALERT An ALERT should be declared per 10.S 01 1, page 5, No. 2.2, " Abnormal Primary Leak Rate, Coolant leak rate greater than 50
[
gpm".
]
0815 00/45 The RCS leak rate is stable at $$ gpm.
Shutdown is continuing.
0900 01/30 Debris inadvertently left in the condenser from the recent condenser tube plugging job breaks loose and partially clogs the suction piping for the condensate pumps.
This causes the condensate pumps to have reduced flow and discharge pressure and results in low suction trips of all the running feedwater pumps and a complete loss of feedwater.
This total loss of feedwater'results in a reactor scram and recirculation pumps trip.
Level drops rapidly to below the HPCS/RCIC initiation setpoint.
The HPCS system is out of service; and though the RCIC system automatically starts, the pump does not deliver rated flow due to a malfunctioning governor valve.
Containment isolation in response to this event is successful.
This isolates the unidentified leakage to the drywell from the drywell chilled water system if not previously accomplished by operators via "freeplay".
The MSIVs close and the EDCs start as RWL drops below 150.3", and then begins to recover.
SBGT automatically starts.
LPCI/LPCS pumps automatically start and run on minimum flow.
The reactor is stable but pressure remains high.
0920 01/50 An operations / maintenance team checking the RCIC turbine governor finds that the governor will have to be replaced.
10 Actual Scenario Time-Time Summary 0925 01/55 The operations / maintenance team in the RCIC equipment area checking the turbine governor observe steam leaking through a crack in the upstream pipe to valve body weld on E51 F045.
The crack is beginning to worsen and a large puddle is beginning to form.
0930 02/00 The RCIC turbine steam supply line crack widens rapidly.
All personnel move to rapidly exit the area; however, a technician trips and falls in the puddle.
(DAMAGE TO INDIVIDUAL DESCRIPTION LATER)
A short time later, it is determined that the injured individual is contaminated and does require transport to offsite medical facilities.
Annunciators are received in the CR indicating that the RCIC has experienced a pipe rupture in the RCIC room.
RCIC fails to isolate.
Reactor water level begins to drop slowly as only CRD pump "A" is providing makeup to the reactor.
A radioactive release to the environment begins via SBGT exhaust.
SITE AREA EMERGENCY A SITE AREA EMERGENCY should be declared per 10.S 01 1, page 8, No. 5.4, " Steam Leaks, RCIC steam line break outside the containment which cannot be isolated".
100$
02/35 Any attempts to depressurize the reactor using ADS are unsuccessful due to "frozer" solenoids on the SRVs due to excess sealant that has solidified, the safety valve function of the SRVs remains operable (SRVs will lift due to excess pressure if encountered).
Attempts to re-open MSIVs and dump steam to the condenser also fail due to mechanical binding of the inboard MSIVs.
Reactor level drops slowly with reactor pressure dinpping, but remaining higher than LPCI/L?CS pump shut off head.
Swell of the incoming cold water eventually stabilizes and then slowly raises reactor water level.
1100 03/30 The operating CRD pump fails.
Reactor water level begins to lower.
f.
f 4 i Actual Scenario Time Time Summary l 1115 03/45 Reactor level has dropped to the top of i active fuel (TAF), with pressure remaining far above RHR/LPCS capability. The steam i release continues. CENERAL EMERGENCY A GENERAL EMERGENCY should be declared per 10.S 01 1, page 17 No. 12.5, " Plant Shutdown Function, Reactor shutdown' sad Loss ~; of decay heat removal capability and CORE DAMAGE tiredicted within several hours and Subsequent Containment Failure". 1115 03/45 The Auxiliary Building RCIC Area ARM begins to show sisvated radiation levels and the SBGT Exhaust Monitors show that a significant rcdioactive release is in progross. Reactor pressure remains in excess of the low pressure ECCS shut off head. 1215 04/45 Reactor level has dropped to.245. LPCS begins to inject as reactor pressure has decreased to below LPCS shut off head. Severe clad damage has occurred. RHR begins to inject a short time later. 1230 05/00 The core has been re. flooded. The release continues as operators attempt to depressurize the reactor.- Reactor pressure drops below the shutdown cooling permissive. 1240 05/10 Shutdown cooling is placed in service. Repair teams successfully isolate-RCIC by closing the inboard steamline isolation valve. The release is terminated. A storm is brewing in the vicinity of GGNS and meteorological conditions change rapidly. 1300 05/30 The plume is dispersed out of the 10 mile EPZ by high winds. The reactor is placed in cold shutdown condition. Downgrade discussions are in progress, 1345 06/15 offsite doses are returned to background. A Recovery organization is established.
E-12 i j Actual Scenario j i Time Time Summary Recovery planning is initiated, with long i term organization and response plans formulated. 1430 07/00 The 1989 Grand Gulf Evaluated Exercise is te rmina ted. 1.5 EVALCATION CRITERIA The GCNS exercise evaluations that follow in Section 2 of this report are based on applicable plannin5 standards and evaluatict criteria set forth in Section II of NUREG 0654/ FEMA REP 1, Rev. 1 (November 1980). FEMA Region VI evaluated the exercise using the current Exercise Evaluation Methodology (EEM) format. Federal evaluators were instructed to mark those sections of the EEMs "not applicable" which did not correspond to the objectives of the exercise. Following the narratives for each jurisdiction or off site response activity, Deficiencies, Areas Requiring Corrective Action (ARCA) and Areas-Recommended For Improvement (ARFI) are presented with accompanying recommendations..Any identified Deficiencies would cause a finding that off-site preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken to protect the health and safety of the public living in the vicinity of the GCNS plant in the event of a radiological emergency. At least one Deficiency in this category would necessitate a negative finding and require that a Remedial Drill, to demonstrate correction, be scheduled within 120 days. No Deficiency was noted in this exercise. Areas Requiring Corrective Action include those activities where demonstrated performance during the exercise was evaluated and considered faulty; corrective actions are considered necessary but other factors indicate that reasonable assurance could be given that, in the event of a radiological emergency, appropriate measures can be taken to protect the health and safety of the public. This category should be relatively easy to correct in comparison to those classified as Deficiencies, and correction must be demonstrated at, or before, the next regularly scheduled exercise. No ARCAs were noted in this exercise. Areas Recommended For Improvement are also listed, as appropriate, for each jurisdiction or off site activity. These recommendations are advisory in nature and the appropriate jurisdiction may or may not act on them as they see fit. l i t
13 2 EXERCISE EVALUATION On the basis of general criteria set forth in RUREC.0654/ FEMA REP.1, Rev.1 and exercise objectives and observations, an evaluation has been made of the September 27, 1989 exercise at Grand Gulf Nuclear Station. This evaluation is presented herein. FEMA Region V1 will maintain close liaison with the state of Louisiana, and local governments, in determining the corrective actions (includit.g time frames) needed to resolve each issue noted' in this report in accordance with established criteria and guidelines. As previously noted, no Deficiencies or ARCAs were identified in this exercise. 2.1 LOUISIANA STATE OPERATIONS The following narratives include evaluations of the partial-participation operations of the Louisiana Office of Emergency Preparedness (LOEP) at the State EOC in Baton Rouge and the Louisiana Nuclear Energy Division (LNED) at the GGNS EOF. LNED also positioned a representative at the Emergency News Media Center in Port Gibson, Mississippi to respond in the event the need arose. 2.1.1 LNED Operations at CGNS EOF 1 RED dose assessment personnel were prepositioned at the Ramada Inn in Natches, Mississippi. Following receipt of the Alert notification, a briefing was held to update the staff on activities at GCNS. A Site Area Emergency notification was received at 9:30 a.m. and the dose assessment staff departed for the CGNS EOF, arriving at 10:40 a.m. Upon arrival, the team set up their equipment in their work area and began operations. The GCNS EOF is an excellent facility with sufficient equipment, status boards and an adequate work area. LNED, the Mississippi dose assessment group and the utility's dose assessment staff,were co located, making for good interaction of all involved in the exercise. In accordance with their plans and procedures, the LNED staff received plant data, made calculations and forwarded recommendatfxRa to LOEP in Baton Rouge. Throughout the exercise, the LNED staff demonsttsted good techniques in generating and confirming data and in making correct protective action recommendations. In summary, FEMA exercise objectives 1, 2, 3, 4, 5, 6, 10, and 11 were met at this location. DEFICIENCIES: None. AREAS REQUIRING CORRECTIVE ACTION: None. AREAS REC 0KMENDED FOR IMPROVEMENT: None.
14 b 2.1.2 Louisiana State EOC (LOEP Offices) Note: Since the State LOEP had participated in an evaluated full-participation exercise earlier this year, they were activated and participated only to the extent necessary to support Tensas Parish participation. The' State Emergency Operating Center (EOC) is located in the basement of the State Land and Natural Resources Building in Baton Rouge, Louisiana. It is located in the office suite complex of the Louisiana Office of Emergency Preparedness (LOEP). The EOC is adequate to support all anticipated emergency operations, with appropriate communications, adequate space, furnishings, climate control, lighting, furniture, equipment, emergency generator, kitchen and other resources required to maintain personnel for 24 hour shift i operations. Maps and displays in the EOC are of good quality, providing summary and trackinB information necessary for management decision making. These include map / display boards for all anticipated requirements including Plume EPZ, evacuation routes, and EPZ population by planning areas. State EOC communications equipment and systems functioned appropriately and procedures are excellent. The facility is equipped with VHF/FM, HF radios. It is manned on a 24 hour basis by two well trained operators. Additional communicators, runners, and log keepers are predesignated to respond to the communications center for major drills and events. Eleven telephone lines, all with conferencing capability, are available. This includes one for each agency representative designated to respond to the EOC. Tacsimile machines and printers provide hard copy to and from all appropriate locations, with multiple redundancies in case of failure of one or more systems. All incoming and outgoing communications are appropriately logged on summary sheets and numerically sequential standard message forms, duplicated and passed to the EOC staff for action or information. Mobilization of personnel was &ccomplished in ten minutes since all personnel were already on duty in tne EOC. The EOC staff, led by the Director for Operations for this event and the LOEP staff, including individuals designated as responsible for functions of Executive, Resources, Message Recorder, Communicator, Radiological Safety Officer, and Public Information Officer (PIO), demonstrated a thorough knowledge of emergency operations, requirements, and procedures. The facility is activated by setting up the communications center, the operations room, and the executive group room (LOEP director's conference room). At 11:41 a.m., the Operations room received the message that a General Emergency had been declared at 11:15 a.m. This is an excessive delay in transmitting the message to the State EOC from the utility. The EOC Operations Officer was effectively in charge of the EOC. She held frequent briefings to insure that all present were knowledgeable regarding the status of events and also involved the staff and other agency representatives in discussions prior to making decisions. She frequently referenced the plan and written procedures to insure that all items requiring attention and action were adequately addressed. Frequent status reviews were i
1 r 15 held to insure that no required actions or responses were overlooked. In addition, the EOC Operations Officer maintained a timeline and activities log of significant events. Emergency Classification Levels were posted and were utilized 1 throughout the exercise to drive events, response and protective actions. Since the State EOC staff had participated in a full participation exercise ) earlier this year, their only responsibility in this exercise was to provide the necessary support for Tensas Parish. Other agency personnel were alerted but advised to stand by at their normal duty stations. Calls were made to: LNED to insure that they had received the Alert message; LNED by the PIO to simulate coordinating their trip to the Emergency News Media Center (ENMC) in Port Gibson, Mississippi; and to Tensas Parish to insure that they had received the message. Calls were simulated to the National Guard to simulate requesting support for Tensas Parish which had reported a bridge out on Highway 65 between Newe11 ton and Tallulah. P In summary, TEKA exercise objective 4 was met at this location. DEPICIENCIES: None. AREAS REQUIRING CORRECTIVE ACTION: None. AREAS REC 0KKENDED,FOR IMPROVEMENT:
== Description:== There was a 26 minute delay in the General Emergency e message being received by the State EOC. Recommendation: Investigate the reason for the 26 minute delay in the General Emergency message bein5 received by the State EOC from the utility and make appropriate corrections. 2.1.3 Emergency News Media Center Media activities for this exercise were conducted at the Emergency News Media Center (ENMC) at the Port Gibson/Claiborne County, Mississippi EOC. Representatives from LNED and Tensas Parish adequately demonstrcted their capability to conduct Louisiana State and local media response duties. At 8:21 a.m., the ENMC manager was notified that an Alert had been declared at 8:07 a.m. He arrived at the ENMC at 8:49 a.m. and began a mobilization call.down. The Center was declared operational at 9:56 a.m. A bank of 15 commercial telephones, some with conferencing capability, and a fax machine adequately demonstrated the ability to communicate with key organizations in Louisiana and Mississippi. The evaluation process for this location was limited to observing the coordination and interaction between the State and local agencies, the utility media staff and Mississippi State and local media officials. The LNED and Tensas Parish representatives demonstrated an adequate ability to carry out their assigned responsibilities, using available resources and planned
16 l procedures appropriately. Although no exercise objectives were listed for the State of Louisiana (LOEP) to demonstrate, it is suggested that, in the future, LOEP send a representative to the ENMC to coordinate activities with LNED and act in support of Tensas Parish. Ample space, furnishings, lighting, restrooms and ventilation to support emergency operations were available. Adequate use was also made of maps and displays in the ENMC including several protective action status boards and evacuation / shelter maps. Maps depicting evacuation routes and reception sites were also included as part of the media press kits. However, several of the displays used during the news briefings were too small and illegible for the news briefing audience to read from the floor. To counteract this problem, the Mississippi Emergency Management Agency (MEMA) spokesman punctuated his news briefing presentations with continuous reference to the maps, etc. displayed in the media press kits. Again, because the exercise created little, if any, reason for the State of Louisiana or Tensas Parish to pubiteize disaster activities. Response by LNED and Tensas Parish media representatives was limited to telephone contact with their respective headquarters to coordinate any media response which might become necessary and to monitor information regarding changing emergency cond!tions. If needed, telefax machines at LNED headquarters in Baton Rouge and at the Tensas Parish EOC in St. Joseph. Louisiana, were available to transmit or receive appropriate media information. Four timely news bricfings were conducted by officials of the utility and MEMA in a large auditorium adjacent to the ENHC work area. The LNED and Tensas Parish spokespersons received sufficient recognition by utility and Mississippi briefing officials at these briefings. Rumor control was implemented in a timely manner through the LNED Office in Baton Rouge and the Tensas Parish EOC which, if necessary, were equipped to coordinate any required response with their representatives operating at the ENHC; thus correcting an ARCA from the previous exercise. In summary, FEMA exercise objectives 2, 4, 5, 13, 14, and 15 were met at this location. DEFICIENCIES: None. AREAS REQUIRING CORRECTIVE ACTION: None. AREAS RECOMMENDED FOR IMPROVEMENT:
== Description:== LOEP did not have a media representative participate in the exercise. Recommendation: Although no objectives were required to be demonstrated, it is suggested that, in the future, LOEP provide a media representative to coordinate response activities with LNED and to act in support of Tensas Parish'. (
I 17 v 2.2 LOCAL JVRISDICTIONS AND SUPPORT ORGANIZATIONS 2.2.1 Ten'sas Parish EOC The Tensas Parish EOC is located in a new building adjacent to the Parish Courthouse in St. Joseph, Louisiana, approximately 13 miles west. southwest of the Grand Gulf Nuclear Station. The joint Emergency Management / Sheriff's communications center is located in the same building where all communications are monitored on a 24. hour basis. A Sheriff's communicator was on duty when the NOUE was received from GGNS on the hot line system. An EOC communicator was immediately assigned to the center for the duration of the exercise. The Parish EOC Director was already in place as the call was received during normal working hours, i Following receipt of the NOUE, the Parish EOC Director instructed his two assistants to initiate a stand by alert call to all EOC personnel using a written roster. Following the Site Area Emergency declaration, a second (activation) call was made to all participants. The EOC was fully staffed by 9:50 a.m. The Parish EOC Director and his two assistants were effectively in charge of the emergency response activities. The two assistants were performing for the first time at a FEMA Svaluated exercise. They were well versed in the EOC. procedures and knew what was expected of them. Responsibilities for EOC operations were divided between the administrative staff with overall direction and control assumed by the Director. Written procedures were referenced and followed as necessary and the written plan was available for use by the staff. Staff briefings were conducted periodically. However, additional involvement by all EOC personnel would enhance the overall response. Each organization represented at the EOC should have the opportunity during staff briefings to update the status of their organization's activities. This would help to inform the entire staff of the overall EOC response. In addition, the technical advisor provided by the utility should be called upon more frequently to discuss with the staff the current status at the plant and predictions or projections based on the information provided. The staff was very knowledgeable and familiar with their procedures and duties. The new EOC is an excellent facility featuring an operations room, communications room, restrooms, kitchen facilities, bunks and showers (Sheriff's jail facilities) and is equipped with emergency power. Should evacuation of the EOC be required, the Parish Emergency Management Office has developed a well equipped mobile command post with radios, road block materials, status boards, entry suits, auxiliary power, etc. The parish also has a four wheel drive vehicle with radios, speaker system, winch and auxiliary power. EOC security was provided by Sheriff's deputies and was very i effective, EOC maps and displevs were adequate and frequently used throughout the day for posting significant events and emergency classification levels (ECLs).
18 Communication systems in the EOC include dedicated landline (hot line) to CCNS, LNED, 1.OEP and Mississippi, police radio, CD radio, law enforcement teletype, facsimile and commercial telephones. The landline systems are equipped with an automatic recorder for record purposes, and a remote speaker. The Sheriff's Departe.ent dispatcher also receives all calls on a dedicated landlint. Message handling was very effective. Radiological exposure control was managed effectively at the EOC. A local high school student, working on a science project, assisted the director throughout the exercise. Two dosimeters were distributed to each EOC staff member (0 200mR and 0 200R) along with a dose record card. Announcements were made periodically to remind the staff to read and record the dosimeters. It is recommended that a thorough briefing on dosimeter use, maintenance and operation be provided to the entire EOC staff upon issuance of the dosimetry equipment. Several of the new staff members were unfamiliar with the equipment and its operations. The high school student conducted periodic surveys of the entire EOC using a survey meter. Alert and notification (A/N) of the public, and the dissemination of an initial instructional message, was effectively demonstrated by the EOC administrative staff, as directed by the emergency coordinator. At 10:42 a.m., the exercise controller provided by the State, injected a message which took the Tensas Parish EOC out of the primary exercise scenario and initiated a separate scenario for the parish, thereby ensuring the demonstration of all objectives. The injected message contained meteorological and plant data that provided the parish with protective action recommendations. The parish emergency coordinator, in concurrence with appropriate officials, accepted the recommendations and acted on them at 10:50 a.m., by ordering the evacuation of sectors B, 9, and 12. Concurrently with these actions, the Parish School Superintendent issued an order to evacuate the schools in these sectors. The coordinator directed the activation of.the siren system at 10:53 a.m. and an instructional message was produced and relayed to the EBS radio and TV station at 10:54 a.m. These two activities (sirens and EBS) were executed concurrently by the two assistants. The entire A/N process was completed within five minutes. This was the only activation of the A/N system during the exercise. No additional protective action recommendations (PARS) were made that impacted Tensas Parish. A representative from the parish was dispatched to the Emergency News Media Center in Port Gibson to ensure the timely and accurate coordination of all parish media releases with the other agencies represented there. Information intended for public release is coordinared with the Police Jury President, Mayor and other staff members. Due to the limited scenario play in Tensas Parish, there were no news releases generated by the EOC for distribution to the media. Rumor control within the parish is handled by the EOC staff. A published rumor control number is available and another new telephone number will be published with the next emergency information brochure distributed to the public on a yearly basis. This new number is for a telephone in the new portion of the EOC located adjacent to the administrative area. This location facilitates the use of the' coordinator's knowledge and assistance without having him directly answer the phone. Because this is a new phone number and has not been officially published, there were no rumor control calls answered
t
- ?
19 f at that location. Inquiries werc received at the old, published number and handled effectively. In summary, FEMA exercise objectives 1, 2, 3, 4, 5, 6, 12, 13, 14, 15, and 19 were met at this location. DEFICIENCIES: None. AREAS REQUIRING CORRECTIVE ACTION: None. AREAS RECOMMENDED FOR IMPROVEMENT:
== Description:== Periodic staff briefings were conducted at the EOC; however, each individual was not given the opportunity to present their agency's/ organization's status to the other staff.
- Also, the technical advisor from the utility was not utilized.
Recommendation: All staff members at the EOC should be included in periodic staff briefings and the technical advisor should be used.
== Description:== Better briefings by the RDO should be given to the e EOC staff concerning dosimetry use, maintenance and theory. Recommendation: The RDO should provide briefings on the use of dosimetry and a briefing should be conducted upon issuance of the equipment. 2.2.2 Emergency Worker / Vehicle Monitoring / Decontamination The emergency worker monitoring / decontamination center, located at the Tensas Parish EOC, was activated when a radio call was received from a worker in the simulated contaminated area, indicating that he had possibly been contaminated. Parish radiological personnel immediately dressed in protective l clothing, boots, gloves and appropriate personal dosimetry and prepared their monitoring equipment to receive the vehicle. 1 When the vehicle arrived, it was directed to a grassy area behind the EOC where its exterior was carefully monitored. The driver then exited from the vehicle onto a step off pad where he was fully monitored. The interior of the vehicle was then monitored. The parish radiological personnel demonstrated a high state of training and competence in monitoring activities. Had contamination been found, the vehicle would have been washed on the grassy area and the contaminated soil later removed for disposal. Personnel decontamination would take place in a mobile, shower equipped trailer parked adjacent to the vehicle monitoring area. Vaste water from the I mobile shower'could be held in a tank for later disposal. l 1 l In summary, FEMA exercise objectives 6 and 25 were met at this location. l l
L i 20 DEFICIENCIES: None. AREAS REQUIRINC CORRECTIVE ACTION: None. AREAS RECOMMENDED FOR IMPROVEMENT: None. 1 2.2.3 Winnsboro Reception / Care Center The Winnsboro Reception and Care Center, located at the Winnsboro High School gymnasium in vinnsboro, was ready to receive evacuees about 45 minutes after receiving notification from the Tensas Parish EOC to activate. 1 The staff members were notified by telephone, using an updated call list, by the Franklin Parish Civil Defense Director and his staff.. The Center was staffed by volunteers representing the Sheriff's 1 department, Civil Defense office, Family Services, Council on Aging, Agriculture Extension Service, Fealth Unit, American Red Cross and Winnsboro school workers. These volunteers are to be commended for their dedicated and enthusiastic service to the community and for their participation in this 1 exercise. The Center has telephone and radio communication connections with Tensas Parish. They have radio capability with the State Police, the Sheriff's office and CCNS. The workers at the Center, who might possibly come in contact with contaminated evacuees, had been issued and were wearing dosimeters and had instructions on their use and purpose. The dosimeters had been zeroed and the initial readings were recorded on an exposure record card. The workers knew what to do in esse of radiation exposure. With sufficient staff available to register them, evacuees were brought into the Center through the front door after their vehicles had been monitored for contamination. The evacuees, all at the same time, were then sent to another location down the hall to be monitored for. contamination. The evacuees were monitored while standing on disposable paper. It was noted that, although paper was available, it was not placed on the floor loading from the front door to the monitoring area where evacuees entered the building. During the monitoring process, it was observed that some of the evacuees' feet were improperly surveyed. However, the remaining monitoring techniques were all adequately demonstrated. After the evacuees were monito. red, they were, if found clean, sent to the registration desk for processing. It was also determined that if further assistance were needed, the evacuees would be sent to another area of the Center where representatives of support agencies (listed earlier in this text) i would be available to aid them. If evacuees were contaminated, they would walk on paper to the showers. They would be monitored again, undress with l their clothing stored in plastic bags, shower,-and be re monitored. If clean, L they would be sent to the registration desk, following a different route from l the showers.
y 21 The Center is an excellent facility equipped with enough toilets, drinking water, storage, parking facilities, sleeping accommodations (50 cots on hand) and feeding capabilities in the school cafeteria to meet the needs of Tensas Parish evacuets. Additional cots, food, etc. can easily be obtained. In summary, FEHA exercise objectives 2, 4, 6, 21 and 22 were met at this location. DEFICIENCIES: None. AREAS REQUIRING CORRECTIVL ACTION: None. AREAS REC 0KMENDED FOR IMPROVEMENT:
== Description:== Disposable paper.was available, but was not used on the walkway from the entrance to the monitoring area in the Reception Center. Recommendation: Spread disposable paper over the entire walkway from the entrance area to the monitoring area.
== Description:== Some of the evacuees had their feet improperly surveyed. Recommendation: Make sure the feet of all evacuees are properly surveyed. 2.2.4 Mahoney Ambulance Service As reported following previous exercises, there are no fixed medical facilities in Tensas Parish. Therefore, in the event of a nuclear accident affecting the Parish, injured contaminated individuals will be transported to preselected medical facilities in sither Vicksburg or Natchez, Mississippi. Mahoney Ambulance Service, located in St. Joseph, Louisiana,' will provide emergency care and transportation. The Tensas Parish Sheriff's dispatcher was notified, at 9:03 a.m.. that there was a simulated injured, possibly contaminated person at the old ferry landing on the west bank of the Mississippi River. The She'iff's dispatcher notified the ambulance service, by radio, of the location and possible condition of the individual requiring transportation. The ambulance, with a crew of two, arrived at the incident scene at 9:09 a.m. The crew, wearing protective gloves and booties (other protective clothing was available but not worn during this exercise) and equipped with appropriate dosimetry and monitoring inst uments immediately initiated medical treatment and careful monitoring of the patient. The patient was then placed on a stretcher, appropriately wrapped to prevent the spread of contamination and moved to the ambulance. Meanwhile, the vehicle had been prepared, by covering exposed surfaces, to receive the patient. The ambulance crew demonstrate'd a high level of training and capability in handling injured and potentially contaminated patients. Two
22 procedural errors in contamination con' trol were identified by the ambulance crew themselves and corrected on the spot. The ambulance then proceeded to the rear entrance of the Parish EOC (simulating the hospital), where the patient was properly unloaded and the vehicle was secured until it could be fully monitored prior to release. While en route, radio communications were' maintained. Parish radiological personnel then monitored the ambulance and crew and, discovering no contamination, released the vehicle for further duties. In summary, FEKA exercise objectives 2, 4, 6 and 23 were met at this location. DEFICIENCIES: None. AREAS REQUIRING CORRECTIVE ACTION: None. AREAS REC 0KMENDED FOR IMPROVEMENT: None. 2.3 SCHOOL EVACUATION DEMONSTRATION Tensas Parish schools carried *out a full evacuation drill on September 20, 1989. The written results of that drill were provided to the exercise evaluators. When-the recommendation to evacuate portions of Tensas Parish was approved at the EOC, the parish school representative immediately contacted, by telephone, the principals of the Newe11 ton schools to pass-the evacuation order. The previous week's drill indicated that all students could be aboard the appropriate transportation, ready to move to the reception centers, within three minutesiof the receipt of the evacuation order. Sufficient buses, or other transportation, with teachers as drivers, are available at each school in the parish to transport the entire student body, in convoys, in the event of an evacuation. The buses are not equipped with communications, but local plans provide for contact with them through the radio equipped law enforcement vehicles that will accompany the convoys. All buses and drivers with their student passengers will depart _the risk area for reception centers. They will not return for additional loads. Therefore, no personal dosimetry is necessary. All arriving evacuees will be monitored at the reception centers and, if required, decontaminated. In summary, FEMA exercise objectives 2, 4 and 19 were met at this location. DEFICIENCIES: None. AREAS REQUIRING CORRECTIVE ACTION: None. AREAS RECOMMENDED FOR IMPROVEMENT: None. i l l
23 2.4 UTILITY ISSUEG AREAS RECOMMENDED FOR IMPROVEMENT: I
== Description:== Several display boards were too small and illegible for the news briefing audience to read from the floor. Recommendation: Enlarge the size of the news briefing display boards and make them more legible.for the audience to read from. the floor.
== Description:== There was a 26. minute delay in the General Emergency-o message being received by_t'he State EOC from the utility. Recommendation' Investigate the reason for the delay in the message being received by the State EOC from the utility and make appropriate corrections. f a L e
0 24 3 TRACKING SCHEDULE FOR STATE / LOCAL ACTIONS TO CORRECT DEFICIENCIES AND AREAS REQUIRING CORRECTIVE ACTION Section 2 of this report has provided descriptions of any Deficiencies or Areas Requiring Corrective Action resulting from this e'xe rcis e, or remaining to be corrected'from previous exercises, with recommendations noted by the FEMA ReS on VI RAC Chairman. The evaluations and i recommendations were based on the applicable planning standards and evaluation criteria set forth in Section II of NUREG 0654/ FEMA REP 1, Rev. 1 (November 1980), and preapproved exercise objectives. TABLE 1 provides a consolidated listing of these exercise Deficiencies and Areas Requiring Corrective Action, by exercise activity location. The table has been designed so that space has been allowed for the addition of: (1) proposed corrective actions that will be undertaken and (2) the projected and actual dates of completion of these actions. Because no Deficiencies or Areas Requiring Corrective Action (ARCAs) were noted during this exercise, Table 1 contains no entries regarding these categories. The FEMA Region VI Director is responsible for certifying to the FEMA Associate Director, State and Local Programs and Support, Washington, D.C., that any Deficiencies and Areas Requiring Corrective Action noted-in the exercise have been or will be corrected, and that such corrections will also be incorporated into emergency plans as appropriate. e
~' ,m ^ t Tall.E 1 -- Remedfel Act1ons for the 1999 Crand Culf Nuclear Stetton Exercise Proposed FEMA Evaluation of State and . Actuel FEMA Corrective Action -- Ulth FEMA /RAC Objective NUREC 0454 State (S) and local (L) Proposed Completion local Corrective Actions and Ceeplettec Deficiencies and/or Areas Requiring Exercise Recommendations for Correction Wo(s) Reference Corrective Actions Date Deteretnetton of Adequecy Date-NO DEFICIENCIES OR AREAS AREAS REQUIRING CORRECTIVE ACTIOtt NOTED lit THIS EXERCISE. m (P i m.
e 26 d 4 EVALUATIO OF OBJECTIVES 4.1
SUMMARY
OF FEMA OBJECTIVES REMAINING TO BE MET Table 2 provides a location specific listing of FEMA objectives which, according to FEKA records, have not been satisfactorily demonstrated during the current six year exercise interval appropriate to the listed location. The objtictives listed should be taken into consideration during the planning of future exercises to ensure that all required objectives are demonstrated at the appropriate locations during the current six year interval. These are in addition to those Category A objectives that must be demonstrated during every full participation biennial exercise, 4.2 FEMA OBJECTIVES TRACKING - GRAND GULF NUCLEAR STATION Table 3 provides a comprehensive tracking system of FEMA Objective, NUREG 0654 Reference Elements, Latest Exercise objectives, Jurisdictional Responsibility, Exercise Dates, Identified Deficiencies / Required Corrective Actions and the Date objectives were met by State and local agencies. This system tracks the status and progress of this data through the six year exercise interval.during which all objectives must be met at specific locations. a I \\
37 TABLE 2 Summary of FEMA Objectives Remaining to be met as of November 18, 1987. Grand Gulf Nuclear Station All FEMA Region VI Exercise Objectives except. Objective 36 have been met during the current six year interval. 36. Demonstrate the ability to carry out emergency functions (i.e. t activate EOCs, mobilize staff at EOCs, establish communications and complete call down during unannounced or off hours drill or exercise. i 6
I l'ege 1 of 9 rr.Ct.E 3 -- TEMA Eweretse objectives Tracking Chart Defielency or Area Objective Requiring Corrective _Date Ob1g etive Net At This Jurisdictfenal WUREC-0656 Eweretse Responsibility Date of Action (By tracking - 14 cal (s) Mumber and Dete) State tocal Exeretse Reference (Tes/No) State j FDtA thjective Number and Description 9/27/89 9/27/89 D.4 (S&L) Y K X 9/27/89 OBJECTIVE 1 - (Old Obj. No. 37) OtERGENCY CLASSIFICATION LEVE13 u emonstrate the ability to monitor, tD Dnderstand and use emergency class-uificction levels (ECL) through the appropriate implementation of emergency functions and activities cerretg., ding to the ECLs 9/27/89 9/27/89 E.1. E.2. 1.8 Y X X 9/27/89 OBJECTIVE 2 - (Old Obj. No. 1 & 6) N0811.12ATION OF UtERCENCY FERSONNET. (S&L) Demonstrate the ability to fully stort. mobilize and activate personnel for both facility and fisld based emergency functions i 9/27/89 9/27/89 l A.I.d. A.I.e. Y X X 9/27/89 OBJECTIVE 3 - (Old Obj. No. 3) l DIRECTION AND CONTROL A.2.s Demonstrate the ability to direct. (S&L) coordinate and control emergency activities 9/27/89 9/27/89 l OBJECTIVE & - (Old obj. No. 5) C.3.s. H.2 Y K X 9/27/89 + f CONNUNICATIONS II.3 Demonstrate the ability to communt-(S&L) crts with all appropriate locatione l i organizations and field perannnet +oa d-
j\\]l\\l!! i ll 1j 7 nD 4 . ~--., . ~ 77 ) 9 9 t s 8 8 I e ( / / M l 7 a 7 2 ,e c 2 2 / / v o. 9 9 i l
- S t
7 7 c F e 8 8 1 / / 9 9 8 8 b 8 8 O 1 1 e / / 7 7 7 7 e t 1 t a 2 1 D S / / / / a t 2 1 1 9 9 1 1 e svg ein). rti e t ck t ec a aD Vrr r otd ,C n c ya n gB en( r ii e crnb iiom f uiu eqtN Dec RA e 9 W f s 8 oi c / / 7 7 er t e 2 2 ax / / DE 9 9 l yl at a X nic X ol o i il tb ci is' d n soe i pt .X X X rsa X uet JRS e v's e ) iiso thin cTc/ Y Y M N e rs jt ee bAxY O E( 3
- b. H b.
1 0 t 5 e
- 1. 2 )
3 1 4 ) r 6 c 1 ) S a 0 n J .L K )L S ( .H& ,( - e h
- a. a, S
- a. (
8, 9 C Gr S ( E e I I g Rf 3 n U e 0 13 NR K i k JC ca t tf r T n nd no o el e sn r i me mt ni e s S h L' pi pno t e Y lt )iO if ieic v p u umt c A io i i c c )P ad y 0 ii n ) qg qea t r t c e s 4S f nc 2 m ol 7 en ' errr i ) ut e an co en 8 es nps e .I .u r .ti j o osg o ot o t ae e D f e b D d ND yr NE t ne N am aecss e n N yae .R or i r o. O imnea re N r oig . A cl m U ycu j ape jS t s j pt s pecr s a oh ue r bT us bO ido b oet i r e ON qi t OP l np O rdn jG rt ecl E edr X iax p e bN p nob c dE b e d prm OI priro e b p l ar l aoe L aodcn x m dM d ,o N OI t p OR or OG f r dP f oi E u lP a (U enu ( E et e (N e u lM e t mf M e O hes K hik I hss OA hso o A e i '0 e - E t m - R t nr - R t ea (S t rd E v po O oo O re F 5. eit 6U emw 7T eum 8E eua1 c i S t u s t 1 td N tdr n t e EE aqsn EY ayy EH aen EI ae se c VI rel o VC rl c VO rco VD rcaas 3 b IT t ai IN t sn I M t oi IO t on e j O TI s ,it TE sue T srt TI srrwr CL nsra CC nog CD npa CG npoop A EI oeer ER.our Et o i EI o bl E. mdr e mdd MD enish mne ME ena MFH eim C mt t e I A B M MA I T F OF Di mo OE Dt e OF Dar OR Daaat et a p A E
? TA'sLE 3 -- FEMA Exercise Objectives Tracking Chart -- Page 3 of 9 ~ Objective Deficiency or Area At This Jurisdictional Requiring Corrective .Date Obt+ctive Met NUREC-0654 Exercise Responsibility Date of Action (By tracking FEMA Objective Number and Description Reference (Yes/No) State local Exercise Number and Date) State local OBJECTIVE 9 - (New Objective) PARTICUIATE SAMPLINC 1.8, 1.11 N X 8-30-89 Unterford 3 Demonstrate the ability to obtain (S) staples of particulate activity in w-tira airborne plume and promptly O-perform field analysis OBJECTIVE 10 - (Old Obj. No. 10) PilME DOSE PROJECTION I.10 (S) Y X 9/27/89 9/21/89 Demonstrate the ability, within the plume exposure pathway, to project domsge to the public via plume expo-zure, based on plant and field data 02JECTIVE 11 - (Old Obj. No. 10) Pl.UME PROTECTIVE ACTION DECISIONS J.10 (S) Y X 9/27/89 9/27/89 Demonstrate the ability to make appropriate protective action dect-alons, based on projected or actual .toas:ge. EPA PACS, availability of ad1quata shelter, etc. OBJECTIVE 12 - (Old Obj. No. 13) 9/27/89 PUBLIC AI.ERTING AND NOTIFICATION E.6 App. 3 Y X-9/27/89 Demonstrate the ability to initially (L) alsrc the public within the 10-mile 6 EPZ and begin disseelnation of an Inztructional message within 15 minutes of a decision by appropriate State and/or local official (s) o ~ __------"+-N"m* * = * " * " " " " * - " ^
- h*Mh*'
2 e TAbtE 3 -- FEMA Exercise Objectives Tracking Chart -- Fage 4 of 9 Objective Deficiency or Area At This Jurisdictional Requiring Corrective Date Obiective Met NUREC-0654 Exercise Responsibility Date of Action (By tracking FEMA Objective Number and Description Reference (Yes/No) State Local Exercise Number and Date) State local OMECTIVF.13 - (Old Obj. No. 14&25) EMERCENCY PUBLIC INFORMATION E.5, E.7 Y X X 9/27/89 9/27/89 '9/27/89 Demonstrate the ability to coord-C.4.b inste the formulation and disseelna-(S&L) tien cf accurate information and u w in2tructions to the public in a timely fashion after the initial alert / notification has occurred C M ECTIVE 14 - (Old Obj. No. 24) MEDIA BRIEFINGS C.3.a. C.4.a Y X X 9/27/89 11/17-18/87 9/27/89 s Demonstrate the ability to brief the (S&L) media in an accurate, coordinated and timely manner OMECTIVE 15 - (Old Obj. No. 26) Rt!MCrt CONTROL C.4.c (L) Y X 9/27/89 .9/27/89 Demonstrate the ebility to establish end operate rumor control in a co-ordinsted and timely fashion OMECTIVE 16 - (Old Obj. No. 21&22) KT FC FNERCENCY UORKERS J.10.e J.10.f N. X X 11/17-18/87 11/17-18/87 Demonstrate the ability to make the (S&L). decision to recommend the use of KI to energency workers and institution-slized persons, as well as to distri-bute (nd administer it once the de-cision has been made g%e w e 4 g M-y n a b 13 -i-
- u
-'>e
L 2 Tagt.E 3 -- FEMA Exercise Objectives Tracking Chart -- % ge 5 of 9 Deficiency or Area Objective At This Jurisdictional Requiring Corrective .Date Ob1retive Net NUREC-0654 Exercise Responsibility Date of Action (By tracking Reference (Yes/No) State local Exercise Number and Date) State - Imal FEMA Objective Number and Description I)MECTIVE 17 - (Old Obj. No. 21&22) 11/7-18/87 11/17-18/87 Ki IT/1 Tite CENFRAL PUBLIC J.10.e J.10. f N -X X l I Demonstrate the ability to make the (S&L) rtic ision. if the State plan spect-g f tes, to recommend the use of KI u. l for the general public, as well as l to distribute and administer it once the decision has been made I OBJECTIVE 18 - (Old Obj. No. 15&l8) 11/17-18/87 11/17-18/87 Pl.UME PROTECTIVE ACTIONS J.9, J.10 N X X Demonstrate the ability and .tL) resources necessary to implement appropriate protective actions for the impacted plume EPZ population SCllOOL PROTECTIVE ACTIONS J.9, J.10.g Y X 9/27/89 9/27/89 OBJECTIVE 19 - (Old Obj. No. 19) Demonstrate the ability and (L) resources necessary to implement appropriate protective actions for school children within the plume EPZ ')BJECTIVE 20 - (Old Obj. No. 16617) 11/17-18/87 rRAFFIC ANI) ACCESS CONTROL J.10.j,J.10.k N X Demonstrate the organizational (L) ability and resources necessary,to control evacuation traffic flow and to control access to evacuated and sheltered areas s
== m e- ~.rr-a.a.-- .w.w ..o __m__,__, .,__m_,,,,s,, _ ..,_l_,
.n..
- . y * ^
4 T +.. TLBLE 3 -- FEMA Exercise Objectives Tracking Chart -- Foge 6 of 9 Objective Deficiency or Area At This Jurisdictional Requiring Corrective Date Obteetive Met NUREC-0654 Exercise Responsibility Date of Action (By tracking FEMA Objective Number and Description Reference (Yes/No) State local Exercise Number and Date) State Iscal OBJECTIVE 21 - (Old Obj. No. 27) RECTSTRATION. MONITORING AND DECON. J.12 (L) Y X 9/27/89 9/27/89 Demonstrate the adequacy of proce-dures, facilities, equipment and per-(d sonnel for the registration, radio-W le'gical monitoring and decontamina-tion of evacuees 1/26/81 GBJECTIVE 22 - (Old Obj. No. 28) (Tallulah) CONCRECATE CARE OF EVACUEEE J.10.h (L) Y X 9/27/89 1/26/83 & Demonstrate the adequacy of facil-9/27/89 itles, equipment and personnel for (Vinnsboro) tha congregate care of evacuees 11/17-18/87 (Ferriday) OBJECTIVE 23 - (Old Obj. No. 30) FMERCENCY MEDICAL TRANSPORTATION. L.4 (L) Y X 9/27/89 9/27/89 Demonstrate the adequacy of vehicles i equipment, procedures and personnel for transporting contaminated, injursd or exposed individuals O!UECTIVE 24 - (Old Obj. No. 31) MEDICAL SERVICES FACII.lTTES L.1 N N/A N/A N/A N/A I)emonstrate the adequacy of hospital i facilities, equipment, procedures and personnel for handling contamin-- atsd injured or exposed individuals ~
s
- g; l
l f l l TABLE 3 -- FEMA Exercise Objectives Tracking Chart -- Fage 7 of 9 Objective Deficiency or Area At This Jurisdictional Requiring Corrective Date Oblective Met NUREG-0654 Exercise Responsibility Date of Action (By trocking FEMA Objective Number and Description Reference (Yes/Ne) State local Exercise Number and Date) State local' OBJECTIVE 25 - (Old Obj. No. 29) DECONTAMINATION K.S.a. K.S.b Y X 9/27/89 9/27/89 Demonstrate the adequacy of facil-(L) ities, equipment, procedures and g psrsonnel for decontamination of a emergency workers, equipment and vshicles, and for waste disposal 0BJECTIVE 26 - (Old Obj. No. 32635) SUPPLEMENTARY ASSISTANCE (FED /0THER) C.1.a. C.4 'N X X 11/17-18/87 11/17-18/87 Demonstrate the ability to identify (S&L) tha need for and call upon Federal and other outside support agencies far assistance OBJECTIVE 27 - (Old Obj. No. 9) INCESTION PATlWAY SAMPLE COLLECTION 1.8 (S) ~N X 18/17-18/87 Demonstrate the appropriate use of equipment and procedures for collec-tien and transport of samples of l vtgatation, food crops, milk. meat. poultry, water and animal feeds OBJECTIVE 28 - (Old Obj. No.' 9) 11/17-18/87 INCESTION 1ABORATORY OPERATIONS 1.8 (S) -N X Demonstrate the appropriate labora-tery operations and procedures for analyzing samples obtained under objective 27 by field teams h n. .~ n n-g -- + .wr n...~ ~,., - -.,..,, -,. -,~n.., .w.. ,n,
. 'h s ' s. 9* 5 e i i 4 1 Tart.E 3 -- FEMA Exercise objectives Tracking Chart -- Foge 8 of 9 Deficiency or Area Objective - At This Jurisdictional Requiring Corrective Date cblective Net NUREC.0654 Exercise Responsiblitty Date of Action (By tracking Reference (Yes/No) State local Exercise Nsamber and Date) State local FEMA objective Number and Description OMECTIVE 29 - (Old Obj. No.11) INCESTION DOSE PRnJECTION 1.10. 1.11 N X 11/17-ISfW' Demonstrate the ability to project J.11 dossg) to the public for ingestion (S) g pithw2y exposure and to determine os appropriate protective measures based on field data. FDA PACS and other relsv;-nt factors OMECTIVE 30 - (Old Obj. No. 12) 11/17-18/97 11/17-18/87 INCESTION PROTECTIVE ACTION IMPLE. J.9. J.11 N X X Demonztrate the ability to implement (S&1.) t>oth preventive and emergency pro-tactive actions for ingestion pathway hazarda l l OMECTIVE 31 - (Old Obj. No. 33) TOTAL POPUtATION EXPOSURE M.4 (S) N 1 11/17-18/97 I Demon 2trate the ability to estiente tctal population exposure l l OMECTIVE 32 - (016 Obj. No. 3f ) 11/17-18/87 11/17-18/87-i CONTE 01.1.ED REENTRY AND RFCOVERT M.1 (S&1.) N K K Demon 2trate the ability to determine l r ppropriate measures for. controlled l i rsentry and recovery based on esti-l esated population exposure. EPA PACS tnd other relevant factors- --e
dp t< A 6 = *
- e t
d 7 7 e 8 8 t / / s 9 t 8 8 e f e 1 1 t o N l a 7 7 t 1 9 e c 1 o v o / / N 1 1 e i l 1 g t 1 a c d P e 7 7 n t b 8 8 9 e / / 8S O ' e 8 8 /r' e t 1 1 1 E a t 7 7 /e ~ t a 3 v D ' S 1 1 i / / R 1 1 1 1 e nvg ein) ' rti e Ack t eca rraD orr otd yC n c ya n gB en( t i i crnS eqtM ii o f ui DecRA e f s oic .er t e ax DE l yl nic 1 X K X at a ol o iil tb ci n' s i dsoe rsa 1 X X i pt uet JRS evse) iiso thin N N N cTc/ N e rs jt ee bAxY O E( 4 ) 4 ) t 5 e L A) L 1) r 6 c .L L ( R& a 0n S
- a. (S 2
PS h e ( ( C Cr J E e 1 2 g Rf A n Ue M i NR kc a l r e T n t St - l s Nnd n a-N ueb ar o t nn O ot acu Ii!,I i f :. a:s s i i v p I ml a io )I at o t O ee e t r ) d tT yvseh t r 4A l o ) nue 3Lrf nA riet - i )T el i c c 3T pr 2 iog 2E oo eR rt ef .N mt ahn .N o mE ac ,lf a N cn eP caspo e s mh oO o rO ,C m E i n j e 4 b D oM o o .Oor NE oc N o2 c NS oi i o Eco t t R t t uS t O d .L
- e. t d d P
r st .E a qR s a jN yo j yuf jP yu eU y e n bI tf b t oi b t c RO ti ane r O i O iuh OE ia H i( ac i r e Y l sy l ns T l v 1 l f n c - F isf su e b dR ier d ii dI ie x m l E bre l btl lS b RF b nano E u OV auv O ana O ae FO aot one N (O s o (G ou ( N h ( i sins C eac N ect O et D et t ai M e - E hee - I h c h l - N hceanc A E v R t mr F t aa F t oe A t nzcur i 3 4F 5O t n 6 uii e t 3D eed 3A enn 3 e n 3D efl ngx F c N t t n T t oa N t eo E t i une e EA aaa ES a EO acs EC a yb m i j V ri V rgy VI rnr VN rcomrr i t ry I R t nb I T t ae I U t nmouo O Ti s pr TU si TA st p TO se cd 3 b IY C i not CO nf s CU ns CN ng l L A E n, orn EH ofi EC oie EN orshnl E mst JA meCswi mas MAV esi BN emO1 or B M J e mpe M4 A E B t epe et a F ORD a r O2 Dsb OE D as OU DeE1 dd T}}