ML20049A566
| ML20049A566 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/28/1981 |
| From: | Richardson J Federal Emergency Management Agency |
| To: | |
| Shared Package | |
| ML20004B928 | List: |
| References | |
| NUDOCS 8106010354 | |
| Download: ML20049A566 (31) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SOUTH CAROLINA ELECTRIC & GAS Docket No. 50-395 COMPANY
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Virgil C. Summer Nuclear Station, Unit 1
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TESTIMONY OF JACK D. RICHARDSON ON INTERVENOR BURSEY CONTENTION 8 AND FAIRFIELD UNITED ACTION CONTENTIONS 7, 9, 10, 11 AND 12*
Q.1.
Could you please state your name, place of employment and professional qualifications?
A.
My name is Jack D. Richardson.
I an employed by the Federal Emergency Management Agency (FEMA) as the Acting Regional Director, Plans and Preparations (P&P) Division, Region IV and ds Chairman of the Regional Assistance Committee (RAC), Region IV.
A copy of my professional qualifications is attached (AttachmentB).
Q.2.
Could you briefly describe-the responsibilities of your position with FEMA?
A.
As the Acting Regional Director P&P Division, Region IV, I am in charge of all radiological emergency preparedness, personnel dnd planning within the southeastern Federal
- See statement of these Contentions in Attachment A.
2 810601036%.
-2 region. As the regional assistance committee chairman for Region IV I coordinate the review and technical assistance to States within FEMA Region IV on matters involving radiological emergency preparedness.
I have at my disposal personnel from several Federal agencies who assist in review and technical assistance.
Q.3.
Could you briefly describe your role with respect to the review of emergency planning for the Summer nuclear plant?
A.
As the Regional Assistant Committee chairman I coordinated the review of the State and local off-site emergency planning for the Summer Plant and participated as an observer in the exercise of those plans.
As the Acting Director, Plans and Preparedness, Region IV, FEMA, I am responsible for assisting State and local governments to insure that the off-site radiological emergency preparedness at the-Summer Plant is adequate to protect the general public. Technical assistance that is not available within the State or local governments can be obtained through the talents of personnel in the RAC.
Q.4.
Intervenor Bursey Contention 8 asserts that the Applicant has made inadequate preparations for the implementation of its emergency plan in those areas whare the assistance and l
cooperation of state and local agencies are required.
Does the i
witness have a position on this matter?
l i
l i
A.
Yes. After an extensive review of the State disaster operations plan, radiological preparedness sections, and observation of the May 1,1981, exercise of the State plan, I feel that the plan when used to protect the public in a case of a general emergency at the Summer Plant would be effective in reducing injury or hardship to local citizens and is capable of being implemented with a few minor exceptions and deficiencies which have been noted to responsible State officials.
The limited number of deficiencies noted in the exercise indicates that the applicant and the State and local governments have engaged in extensive coordination of their plans.
Q.5.
Could you briefly describe the nature of the emergency exercise conducted at the plant on May -1 to which you refer?
s A.
On May 1, 1981, the applicant, the State of South Carolina, and local governments in the area surrounding the Summer Nuclear Power Plant exercised their radiological emergency preparedness plans. This was a substantial exercise involving all major components of the emergency response forces.
It provided for a real time review of individuals and organizations in their knowledge and abilities to protect the public in the case of a general e,nergency.
Q.6.
Could you briefly state the results of FEMA's evaluation of the emergency exercise?
I l
A.
In qy letter of May 8,'1981 (Attachment C), I have provided to Brigadier General George P. Wise, Director, Emergency Preparedness Division, State of South Carolina, a list of deficierscies which were observed during the exercise.
If the State corrects these deficiencies, I would have no reason to believe that the plan could not be implemented as~well, if'not better than the exercise.
Q. 7.
Could you please explain the objective in bringing these deficiencies to the attention of the state?
A.
Deficiencies noted during the exercise and provided to General Wise are a basis for obtaining improvements in the state emergency planning capability. The planning process for radiological emergency preparedness is a continuous one and deficiencies noted are provided for the purpose of improving the planning in order to improve the protection provided to the public -
in the case of a general emergency.
Q.8.
Could you explain the nature of the actions required to address these deficiencies?
A.
Deficiencies noted in my flay 8,1981 letter to General Wise concerning deficiencies in the May 1,1981 exercise of the State disaster operations plan will be reviewed by members of the RAC and the State of South Carolina. Members of the RAC with specific expertise in creas such as communications, transportation and radiological monitoring will be made
j
'. available to the State of South Carolina on an as needed basis.
for the purpose of assisting in upgrading their plan to correct noted deficieanies.
Q.9.
.With respect to Fairfield United Action (FUA) Contention 7, I understand that you are only offering testimony on subparts (c), (d), (f), (g), (h), (j), (k), (q), (r), (s), and (t) thereof.
Is that correct?
A.
Yes.
Q.10.
FUA Contention 7(c) asserts that the Applicant has failed to demonstrate the ability to notify local emergency preparedness officials within 15 minutes.
Does the witness have a position on this?
A.
In the event of a general emergency the applicant will notify the State Department of Health and Environmental Control and the county Emergency Operations Centers (E0C) via dedicated telephone lines. The E0C's will contact the county civil defense directors, who will provide notification to county emergency preparedness officials as necessary.
The EOC communications centers are manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 365 days per year and are in some cases colocated with other police and/or fire department communications facilities. The alert notification system for the general public will be activated by county officials notified by the E0C in each county.
As noted in paragraph 2 of the May 8, 1981 report on exercise
deficiencies, the time between site emergency declaration and EBS activation exceeded the NUREG-0654 guidelines.
The State of South Carolina is working to improve the time.
Q.11.
FUA Contention.7(d) asserts that the Applicant has not adequately planned for the distribution of informational materials.
Does the witness have a position on this?
A.
The applicant has financed the development and distribution of a public education brochure for residents.of the 10 mile EPZ.
The brochure provides information on recommended individual courses of action in the event of a general emergency at the Summer Nuclear Power Plant.
Q.12.
FUA Contention 7(f) asserts that the Applicant has failed to provide adequate means for protecting those whose lack of mobility is impaired by lack of vehicles.
Does the witness have a position on this?
l A.
The State and local plans provide for utilization of available buses and county vehicles for the evacuation of citizens without 1
i private vehicles.
In cases of need for additional transportation, private vehicles will be pressed into action.
Q.13.
FUA Contention 7(g) asserts that no plans have been made for the distribution and use of radioprotective drugs, such as potassium iodide (KI), as a protective response for the general public.
Does the witness have a position on this?
i
_7 t
A.
No plans have been made for distribution to the general public of radioprotective drugs such as KI.
NUREG-0654 provides that radioprotective drugs shall be made available to emergency workers and persons whose ability to evacuate the EPZ is impaired.
FEMA is currently studying the effectiveness of radioprotective drugs as a protective action measure for persons within the EPZ. Additionally, NRC has requested that the Food and Drug Administration and FEMA conduct extensive studies into the utilization and distribution of KI to the general public as a protective action measure.
The results of these studies are not yet available. Discussions are currently being conducted between the Federal Emergency llanagement Agency and the Veterans Administration on centralized regional storage of K1 individual doses for emergency workers and the persons covered by NUREG-0654 guidelines. The State plan is currently in accordance with NUREG-0654 guidance.
Q.14.
FUA Contention 7(h) asserts that relocation centers are not l
located at least 5 miles from the Plume Exposure Pathway Emergency Planning Zone (EPZ) in that the Winnsboro High School is a scant 2-3 miles from the EPZ.
It is further asserted that l
all of the relocation centers in Fairfield County are within 10 miles of the EPZ.
Does the witness have a position on this?
A.
Af ter extensive study and public comment NUREG-0654 established a preliminary EPZ for areas surrounding nuclear power plants at 10 miles, except in those cases where specific circumstances i
I L
.. require a larger EPZ.
I am unaware of any special circumstances which would require the EPZ around the Summer Nuclear Power Plant to be larger than that required by NUREG-0654.
The relocation centers in all cases are located beyond the EPZ and therefore, barring any special circumstances which have not yet been brought to my attention, the centers should be in the safe zone. Those centers and functions which have been located in close proximity to the EPZ, have been pointed out to the State of South Carolina and South Carolina officials have assured me that they will consider relocating the centers to safer locations.
Q.15.
FUA Contention 7(k) asserts that hospital and medical services for the general public are not provided for.
Does the witness have a position on this?
A.
The State plan identifies 22 hospitals in the State as being capable of handling radiologically contaminated patients. The plan lists hospitals which can receive and process for further treatment specific cases of radiological contamination. Minor cases of contamination will be treated by showers and new clothing, while more serious cases will be treated by medical personnel in local hospitals and transfer to regional medical centers as necessary.
Q.16.
FUA Contention 7(q) asserts that the Applicant and local plans
9_
demonstrate a lack of cooperation in their development and planned implementation.
Does the witness have a position on this?
A.
As a result of the May 1, 1981, exercise of the State and local plans it is apparent that the applicant and the State and local-governments have coordinated their activities in planning to the degree that the deficiencies were limited to those noted in qy llay 8,1981 letter to Brig. Gen. George R. Wise, Director, Emergency Preparedness Division, State of South Carolina.
Deficiencies that were noted are being corrected by further coordination, which is being assisted by members of the FEMA, Region IV, RAC.
Q.17.
FUA Contention 7(r) asserts that the Plume Exposure Pathway EPZ boundaries established in local plans are not based upon reasonable criteria which have been explicitly stated and -
demonstrated.
Does the witness have o position on this?
A.
The EPZ boundaries utilized by the State are in accordance with NUREG-0654 and are based upon local conditions and topography.
I am unaware of any special circumstances which would require a larger or smaller EPZ in the case of the Summer Nuclear Power Plant.
The EPZ criteria in NUREG-0654 were established af ter notice and public comment.
It is qy understanding that it is based on technological and practical considerations, thoroughly researched by the Federal Emergency Management Agency and the Nuclear Regulatory Commission.
h-1
, Q.18.
Contention 7(s) asserts that the failure to base Plume Exposure Pathway EPZs on rational and scientifically defensible bases which give reasonable assurance that the health and safety of the public will be. protected exposes-students at Kelly Miller Elementary School and Gree 5 brier Head Start Center in Fairfield County to unwarranted risks'to their health and safety.
Does the witness have a position on this?
A.
Asstatedinthepreviousanswer,thePlume$PZfortheSummer Nuclear Power Plant was established in accordance with the criteria set forth in NUREG-0654 and determined to be v'
applicable by the absence of special circumstances in the area surrounding the Summer Nuclear Power Plant.
Kelly Miper.
e; Elementary School and the Greenbriar. Headstart Center are beyond 10 miles from the plant.
The students in these educational facilities, as well as other members in the general J
public in the surrounding area, have been considered in the Fairfield County emergency action plan which is a component of the State disaster operations plan. As indicated by my report a
of Itay 8,1981, on deficiencieg noted as a' result of the May 1, 1981, exercise of the State emergency disaster plans, no l
l special difficulties in protecting health or, safety of individuals in these two schools were noted as a result of the Stateandlocaloffkcials,attherequestofFEMA, i-exercise.
are considering additional emergency planning. for these i
l institutions.
t.
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Q.19.
Contention 7(t) asserts that the Applicant, state and local plans otherwise fail to comply with some unspecified requirements not set forth therein.
The basis for this Contention in the FUA intervention petition is that the final plans have not been available to FUA members from the four counties. Does the witness have a position on this?
A.
As noted in the public announcements for the April 30, 1981, public meeting conducted in Monticello, South Carolina, the plans referred to in the intervenor's contention were made available to the general public, without charge, for review and study at several locations,within close proximity to the Summer Nuclear lant.
(
Q.20.
FUA Contention 9 asserts
- that the State of South Carolina and r
the counties surrounding.the Summer station do not have the capability for implementing protective measures based upon protective action guides 'and other criteria as they apply to residents of the Plume Exposure Pathway who do not own or have ac, cess at all times to private vehicles.
Does the witness have a position on this?
A.
This Contention is analogous to Contention 7(f) and, therefore, my answer is.the same as that to question 12.
/
Q.21.
FUA Contention 10 asserts that the Applicant, State and local plans have been formulated without reference to the Supplement to the Dref t Environmenta] Statement (NUREG-0534) and thus fail
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to address appropriate protective measures' needed to provide radf ological protection to all'cesidents in the v'icinity of the Eumaer station who might be threatened with injury 'or death f*on an accident, greater thi,n a design, basis accident.
Does thewitnesshave'apositior/onthis?
v A.
Scenarios for accidcnts of magnitudes greater than Mesign basis accidents were considered in the ' development of fiUREG-0654/ FEMA-REP-l'Rev. 1.
State and local e v9encf
+
r planning is based on NUREG-0654 and contemplates public protection in greatar than design basis accidents.
Q.22.
FUA Contention.11 asserts that the Applicant and the suirounding counties d'o'n'ot possess the experignce and
/. '
/
technical ability adequatel to plan for emergency preparedness, to,' prepare for a radiological emergency, or the capability for implementing protective measures basedupon 1,
protective action guides and other criteria as. required under '
NUREG-0654, Rev. 1, at II.J.9.
Does the witngs have a
'~
positicn on this?
l A.
The State and counties, with the assistance of the Federal i
Energency Management Agency and the several agencies which contributed technical assistance to the RAC have coordinated in preparing the planning which was exercised on May 1,1981.
Deficiencies noted in the May 1 exercise have been referred to the State for correction.
Federal technical assistance has been and will be made available to State and local officials in
( /
v upgrading plans on a continuous basis in order to protect the health and safety of individuals living in the EPZ. Training of emergency workers has been conducted by the State and Federal governments as part of a continuing program.
In the event of a general energency at the Suraner Plant Federal technical assistance will be available to assist less technically qualified State and local officials in making determinations which only the State and local governments have authority to make.
It is assumed that local officials will receive interpreted technical information fro 1 several sources in making non-technical emergency decisions for the protection of the general public.
Q.23.
FUA Contention 12 asserts that the Applicant and the surrounding communities lack Radiological Energency Response plans which would permit quick and adequate response to an accident involving the transportation of radioactive wastes, especially irradiated fuel assemblies.
Does the witness have a position on this?
A.
State officials indicate that they consider both of their radiological emergency plans (non-operational and operational) for commercial nuclear power plants to have application and relevance to transportation accidents involving radioactive materials.
While FEMA is preparing State and local government planning guidance for transportation accidents, this is not being done to meet our responsibilities for commercial nuclear
_ 14 -
power plant preparedness, fiUREG-0654/FEfM-REP-1 does not address transportation accidents involving radioactive materials. Therefore, our review and approval of State and local emergency plans for the Summer nuclear power plant does not' encompass emergency plans for transportation accidents involving radioactive materials.
The planning guidance mentioned is being prepared by a Federal Task Force on Transportation Accidents co-chaired by FEfM and the Departient of Transportation.
The Task Force also has nenbers from the Departments of Energy, Health and Hunan Services, and the Environmental Protection Agency and the fluclear Regulatory Commission.
A draf t document was prepared by the Task Force and reviewed by persons representing the State of Colorado, the Interorganizational Advisory Committee (consisting of representatives of the Conference of Radiation Control Program Directors, the flational Emergency Management Association and the U.S. Civil Defense Council), Sandia fiational Lab., the Southern States Energy Board and the Western Interstate Energy Board.
A new draft is being prepared based upon this review. This draft will be distributed to the organizations mentioned and to others upon request.
A final document is expected in September, 1981.
As we have stressed repeatedly in the past, most emergency response functions are independent of the agent causing the
accident or the response.
It is only the unique characteristics of the hazardous substance which requires special care. Therefore, normal emergency response forces could be activated and isolate accident areas regardless if the hazardous agent is a radioactive material or a hazardous chemical.
Experts would then be called in to analyze the situation.
This is not to say that all responders should not have some knowledge of the hazardous material with which they are dealing.
Ideally, they should be knowledgeable in all such materials.
Until such time that FEMA can formalize and provide specific training in radioactive materials to all such responders, however, FEftA encourages that members of State and local response teams avail themselves of training programs which currently exist.
One of these is a course which is designed around a series of accident scenarios to which the students respond.
One such accident is a simulated transportation accident involving a burning truck which contains radioactive material.
Eighteen people from Columbia (located in Richland County) have already attended this course and one person from Fairfield County has attended.
Nine more individuals from Columbia are scheduled to attend during the remainder of FY-81.
ATTACHMENT A 0:r:e-i:n 7 L
The Er.ergency P.esponse Plans cf the A::li: ants, tr.e surrouncin;
- unties, and t*.e State of Soutn Car: lina c: n: pr:,i:e reas: a::e assurance that adequate protective reasures can ar.d will te taken ir
- e e*.ir; c.' a re:iological ere ;en:y and :: net cor. :r
- :r.e re:u re-e-:s of NUEE3 CE54, Rev. 1, in tnat:
{
a)
(!!.E.1.) The Applicants plan does net reet tr.e mini. s-staffing re:uire ents as set forth in Table B-1.
i b)
(I:.E.9.) The Applicants's plan includes a; se ents wi:n 10:a; cr;ani:stions which fail to delineate' the.au:nority, resper.sibilities, and li.-its en tneir actions.
i c)
(::.E.1.)
The Applicants have faf*e: to ce :rstra:e :re at31i:y I
- s n :ify 10:21 Ener;ency Preparedness of#i:ials, as distinguisnet f-:-
c - ;ricati:ns centers, within 15 minutes.
d)
(11.3.1.)
The Applicants have n:
adec.ately':la-re: #:r ne cistri:.: ion of informational materials.
f el (II.J.S and Appendix 4.)
The Applicar has n t cevel::e: re-alis:i: estimates of evacuation times and has not e :leyed ne re:n:-
i ccle;y se: forth in Appendix 4 f)
(!I.J.10.c.)
The Applicants have faile: :: :rovide a:e:aate i
rea s fer protecting those whose la:i of metility is ir:ai e: by la:L of ver.icles.
g)
(II.J.10.e.)
No plans have been ma:e for the distribution ar.d i
use of radioprote:tive drugs, such as Fotassiu-Io:i:e, at a r :e::ive i
response for the general public.
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(II.J.30.h.)
Felo:ation centers are not le:ated at least 5 *,
miles from the Plure Esposure Pathway EPZ e.g., Winnsboro High School is a scant 2-2 c.iles fr:n the E:2. All of tne relocatien centees in f airfield Cour.ty are within 10 miles of.the E:2.
i)
(II.J.13.)
Ta le 6.2-in Applicant's Plan suggests ina: shel-
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tering is the only Frotective Action conte Dlated for t.re general out-I lic.
j)
((II.J.10.M.)
The plans do not set forth the bases for tne cnoice of reccarended Protective Ac.tions from the plume ex osure ca:n-way during erergency conditiens.
k)
(II.L.I.)
Mesoital and redical services for the general Out-lic are not pr vided for.
1)
(II.L.2.)
Or.-site erergency first aid ca: ability is inacetua e.
c)
(:1.G.3.b.) The News Media Center is not located at t.ee
- licant's E ergency Coerations Facility.
n)
(II.H.2.) The Interim Emergency 0:erations facility coes n:-
f con:ly with the recuirements of NUREG 06?5, Rev.1.
a n)
(Appendix 2.) The Apolicant's reteorological monitoring e:uir-re r,: de.es not reet the re:uirerents of Accendix 2.
It lacks a via:le da:L-up system with ecer;ency power and is not seismically cualified.
i o)
(Appendix 3.B.2.)
The Apolicant has failed to denonstrate i
- nat its siren system will reet the recuirerents of Appendix 3, t.at
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the tests conducted by the Applicant on audibility were sufficient. and-that the siren systen to be installed has a high level cf reliability including under seismic conditions which r.ight occasion a radic1:;ical I
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e~ergency.
p)
(Appendix 4.)
The Applicant has failed to coroly with the ce:uirenents of Appendix 4 for determining and describing evacuation tires, has ' ailed to establish the acceptatility of criteria used to establish evacuation tires, and has failed to demonstrate the capabili-ty of Acclicant and State and local goverr. rents to assure tirely evacu-ation under accident conditions.
q)
Acolicant's and local plans der.onstrate a lack of cooperation in ineir developrent and planned imolementation.
r)
The Flure Exocsure Pathway EPZ boundaries established in local clar.s are not based upon reasonable criteria which have been explicitly stated and :er:nstrated.
s}
The failure to base Flure Exposure Tatnway E s on rational an: s:ienti#i: ally defensible bases which give reasonaole assurance tra the healin and safety of the general public will be Orc ected 1
ex:cses students at Kelly Miller Elementary School and Greenbrier feed Star: Certer in Fairfield County to unwarranted risks to tneir health and sa's:y.
- ) And in other ways the Radiological Erergency F.esponse Flans c' the ', licant, the State of South Carolina, and the surrounding courties fail te coroly with the requirements set forth nerein.
EASIS F00, COVENT10N 7 Fetitioner and itsmembers possess unicue knewledge of the recole, roads, traffic patterns, and topograohy of Fairfield County and nearby co.nunities and would assist the Licensing Scard tc bsild a record on
- e a:e:ua:y e' ener;ency planning for the region.
A-4 In addition to tases effered in tr.e statement of the contention,.
Petitioner would show that: (tases are listed by sub-contentien letter')
~
a) Applicar;'s Ta:le B-1 sets forth that Applicant woulc be un-able to provide back-vo succort for several functions within the re-quired thirty rinutes.
That the Chemistry / Radiochemistry functicn would not be staf#e: at all times.
d) Apolicant plans only to mail informational materials to every postal holder.
Many mail addresses in the area serve several hcuse-holds, so that a single " Occupant" mailing to each postal box would not reach every household.
Posting' of informational materials in local businesses will n:: sufficiently supolement inade:uate cailings.
4 ditional cistribution rethods snould be re aired.
]
k) Arrangerents for redical servi:es at the Finner Clini: in Faer, 1
South Carolina, and F.icnland v orial Hospital in Coluncia, Soutn Carc-e lina, a;paren:1y apoly only to employees of the Applican: and n:
to the general public.
- 1) Applicant's plan : alls for only one person qualifie: in 'i-st aid techniques en each shift.
Injury to that person or accident con-ditions repuiring first attertion to accident control duties could i
nullify that capability.
n) The Interim Emergency Operations Facility is located on-si e.
The facility is a terporary office structure which is n:t engineered i
for the design life of the plant, does not provide a protecticn fe::ce equal to or greater than 5. and lacks adequate ventilation pe :e:: ion l
as required in N.'D.EG 0595, Rev. 1, Table 2.
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Fer exa ;1e.
All persons in Fairfield County are ex;ected t5 evacuate te *Winrsboro High School.
Under typical wind conditions, that wculd be the least appropriate response for the majority of persons in
- ne E:2 in Fairfield County.
These in the southern part of the County oculd be sa'er evacuating towards the Richland County facility.
Those in tr.e n:rtnern ; art of the E?2 would m0re wisely evacuate to the Neaberry C0unty center.
No such coordination exists, however.
s)
Young persons are especially susceptible to radiation injury.
Her.e'.er, t',e Plur.e Exposure Fathway. EPZ, which extends to nearly 12 miles just north cf Kelly Miller School in Fairfield County, swings in to miss inclu:ing that school in the EPZ by, cuite literally, " shouting cistaa:e".
Kelly Miller is an all-black ele.mentary school. The Green-brie- 'ead Start Center is located nearby and also within view of the E:2 tut nct included in it.
t)
Final plans have not been available to Petitioners from the four counties and the State of South Carolina.
l i
A.6 Cententien _9 The State of South Carolina an tne courties surreur.:ing ins Summer station cc not have the ca:a:ility for ir:le e-:in; : rete::ive reasures base: upon protective action guides and c her criteria as tr,s a::ly to residents of the Flu e Ex::su-e :a:naay wr: :: n:: co-or have a::ess at all times to Orivate ve'.icles.
54.5:5 FC CONTENTION 9 The area witnin the Place Exp0su-e ratnway is :-e:o-iran:1y rural and no public transportation system exists.
Many c' the residents of the area are old, sick, or poor and ce not have transe:rtation r are witn v: trans:or:ation during significant Oe-icds cf the cay.
E>istin; plans in Fairfiele County, for exar:le, call f:- :ne use c# a s :cl busses w en s:h:01 is not in session, b) vans fr:r tne C u. il en ;ing ar.c C:mrur.ity Action Program, or c) ci::. Dasses br u;*: in f-r Colurtia.
5:50o1 busses in South Car: lina are criven by hi;n s:no:1 stu:ents.
If sch::1 were not in session, the crivers w:ui: c
- be available. The nur:er of vans is limited and inace:uate.
The city busses fr r Cola :ia could n:: arrive in time, are unsuited to many of our country roads, and would be driven by drivers unfamiliar with the many nocks an crannies of the county.
Moreover, no door-to-door survey : identify the nes: nas beer under-taken.
fiewspaper ads were placed in tne Winnsber: pa:e-s askin; pe: Ole who needed transportation to call the Emergency Pre:a*edness Dire:: r's office. A good many people in rural Fairfiei: County d: n:: read.
Few
A-7 Ctete-ti:n _1_:
Radiologi:a1 Erergency Response plans of tne Acciicant, the State
- f South Carolina, and the surrounding communities base been formulated without referen:e to tne Draft Environmental State en:, Surelement
(*,.:E3 CE3 *, SL::le ent) and :nus fail to a::ress a::r::riate prote -
tive reasa-es ree:ed :: pr: vide radiological protectice to all residents in the vicinity Of the Sucrer station who might be tnrea:ened with in-jury er deatn frer an a :ident greater than a design basis accident.
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-,e. Cn.1 :.~ts.......-._._q e.
During testinecy before the ACP.5 Subcommittee on Electric Power f;e: ua 3 25, 19E'.', E.ergen:y Coorcinator Ken Eeale conce:ed that no
-e#e e,ce ha: tes r.ade :: :ne Draft E5 in pre:arin; :ne emergency plans.
Tre #irst E5 we.ich evaluates the environmental it;at:s
- a so-called Class 9 a::i:s-:, inis Sur:ler.ent shculd have served as One cornerstone c' e erger:y :lanring.
Instead, it was ignored.
A-8 Contentict _11 The Applica*.! and tne surrounting counties do not possess tne experience and te:9" ital atility a:e:vately to plan for erergen:y pre-paredness, to cre:are f:r a radiological emergency, or tne capability for imple er. tin; Or:te:tive reasu*es base: u en prote:tive a:tien guices an:
other criteria as re: iee: un:er N'JRE3 065t, Rev. 1, at I:.J.9.
t B1515 " C C',T E *.T :S _1_1 The ec tilit to :lan and carry out protective measures in tne event of a radicio;ical er.ergency presumes the personnel with experien:e and training in eme ;en:y planning and an understanding of the chara: e-istics of reticie;i:a1 eiuents and their potential healtn effe::s.
The :::licart an: the ;; verr ents of the surrounding cou. ties la:t that ca:atility.
Cer::cate Ere ;en:y Cc:rtinater, Ken Beale, of tne A: lica.t, nas training and ex:e*ience as a Healtn Dnysicist.
His resure reveals neitner training r.cc ex ecience wnien would cualify him for his current oesition and rescer.sibilities.
His assistant, Site Emergency Cocrcinator, is totally lacking in any cualifications for a role in emergency plannin; or any training beyond a brief practicum on nuclear ocwer ger.eration at an elementary level.
Fairfield County Direct 0r of Emergency Preparedness ad-its tnat he knows nothin; about nuclear power or the health effe:ts cf radiation.
1 A-9
- eccle in western Fairfield County read the Winnsboro pa
- ers.
Maay people in the area do not have telephone, and for many it is a long-distance tele 3nor.e call t: Winnstero.
Not surprisingly, tne a:s crea no response.
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A-10 Centea.tien _1_2-The Applicant an: the surrounding connunities lack Radiological Emergency Reso:nse plans wnich would pernit o,uick and adepuate response to an acciden; involving the transportation of radioactive wastes, es-
- ecia'.ly irra
- iated fuel asse=Diies.
With:ut sa:5 plans, the health and sa#ety Of tre general public cannot be reas:nably assured.
The Ap-plicant sh:uid n:: be granted a license to operate the Sunmer plant until such plans are develeted.
BASIS FO?. C0% TENT 10'; 12_
The ccunties surrouncing the Suncer station d0 not have plans for res;0nding :: e ergen:ies involving radica:tive materials other than at fixe: sites.
- e-ation of the Sunrer plant would re:uire transsniorent cf low-leve' wastes and, perha:s at some future date, irradiated fuel assertiies (:5;? 3.5-1 and 2).
Tne counties lack the ability to respond to an at:ident involving such materials.
No operating license should be granted the A:plicant wnien coul: result in the movement of such materials until tre affected counties are prepared to deal with potential accidents.
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. ATTACHMENT B 5! AID'bC CT PROTtSSITU.:. CVAUTICATIONS yA_CK D. RICF1.MD.:05 Ja:k D. Ticlardson received the 5. S. Degree in Education fro: Inst Icxas College in 1956. Mr. Rich::s e catered the U. 5. Air Torce in 1956 and served as a pilot until 1960. Tre: 1960 to 1973, lar. Richardsen served as a Tield Censultr.nt and knior Technical Advirer to.% age ent, Syste Dcyclopncat Corporatien, 56nta,,
- }bnica, California. He served as a Regional Tield Officer ei the Defense Civil Prepared:ess / gen:y end Director of the TicId se:eices Of fice f re: 1973 to IN9 when F.'214 was forced by executive order of the Tresident.
Durint '950 and until the present time, Mr. Richardsen sc:ved as Ch2irran of the Region IV F.adiological Assistance Co _i::ce (TAC) which is cenpesed of nerbers fro: the following federal agencies /depar::cntst.
s e Departrent of Encrgy Depart:cnt of Iransportation e
e Inviron= ental Pretortion Agency Toad and DruE Ad inistratica e
s*
Ecal:h and Hum.n Set;? ices i
e Nuclear ?.egulatory to::ission, and
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e U. S. Depair: rent of Agriculture e
B: pricsry tission of the RAC's is to assist State t.nd Iccal governments in develcping, re.ic -ing and evaluating Radiological Trergency plans and preparedntss.
Ibrther, in 1981, Mr. Richardson was appointed as Acting Director, Plans and Pre-paredness Division, FD'A Region IV. Within the reshensibilicies and autherities delega:cd by the Regicnal Director, the Director, Plans and Freparedness Division is charged vi:h the :anastran: and direction of plans and preparedness prograss sad staff. 0:her than T.adiological E=argency Preparedness, the Divisien's pro-gra:s include:
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Nuclear Civil Pretection Planning e
Radiological Nfense, and e
Govern:ent Freparedness e
All of these prograts Sr.volve federal funds, and therefere, regire ef fec:ive progran directica, c::rdinatica and nansgerent.
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ATTACHMENT C f-- i.
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FEDERAL. EMr.RGENC'i
. 'J l..UE." :i.NT AG E NCY Q....,;
f;e.p e. Iy a u '.. < ' m
- 1 G. o. ;., io I.tAY 8 ISbl l'.riga.!!er General Ccorge it. Wisc Director Fr.,ergency Preparedness liivisien 3429 Senate St re.rt Columbia, Sout h Carolina 29201
Dear General Uise:
faclosed is a list of deficiencies noted in the V. C. Sun:.cr lil:P er.ercise conducted on L y 1, 1981. These deficiencies ecre observed by the Regional lu.d i t t;.nce Ca:mit t ca and IT"A IV ntaf f.
Ue are ware that. correct ions are current ly being r ide in the V. C. Sur..er Sit t -Specific plan as a result of the excreise and t iu cri t iquec conduct ed en tLiy 1 and 2, 1 *>S l.
Thus, at the earlie.t roov.ni<nce, pleace provide the A.: ting Regional Director with a report on ho.7.ind s. ben the noted deficiencies will be. corrected, l'pon receipt of this reliort, the prou ss of pinn revleu
- .ud cecept: nee
- t. e proceed.
1:c ca clitent
e u t i: Caralina for ti e excelJ c t
- r..l i o t er,! ca l erv rgen. - pre pared-t w s t.
eifart,.. ; d.srure you that FAC 1 V.. n d. :.'. JV :tafi remain cortitted to in your S! :.
f ut ut e up;at. of II'!' ac t I v; t :.
Sincersly yours.,
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/ :'.J c M.o.. s. L,. _..,...,...... u-it icha ra :an
, C hit i r, Lil, }'dC 1V n o..s m cc:
2.c m.scrs v
4 DEFICIENCIES NOTED IN Tile V. C. Sulf!ER REP EXERCISE CONDUCTED AT WINSBORO, SOUTil CAROLINA MAY 1, 1981 l
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DEFICIENCIES NOTED IN THE V. C. SUMMER EXERCISE 1.
Notification and Alerting of Officials and Staff It appeared that the alerting and notification system at the State Agency level I
was not fully tested due to-the arrival of State agency officials at the State cuergency operations center prior to their being notified.
l 2.
Notification and Alerting of the Public A Site emergency was declared at 10:15 a.m. but the'EBS system was not activated until 10:50 a.m.
Thus, the required time to notify the public was greater than i
the 15 minutes criteria. -The. current public alerting and notification system I
does not meet NUREG 0654/ FEMA-REP-1 Rev. I criteria.
Significant of f-site radia-tion Icvels existed (simulated for exercise play) and the public was not notified in a timely manner.
I 3.
External Communications Capability Between Sites Telephone problems between DHEC (Columbia) and the site technical center created a delay in information exchange and DHEC's initial evaluation of the off-site i
situation. Mobile Radiological moni oring team radio " break-down" caused a situation where a monitor may have received excessive exposure.
Telephone communications out of the Lexington County EOC were virtually impossible at certain intervals during the exercise.
4.
Emergency Operations Center (EOC) Facility (space, comfort, etc.)
The size and location of the forward Emergency Operations-Center were' adequate but the layout for emergency operations was not opti=um.
Space allocated to DHEC was too small which resulted in congestion in the DHEC area of operation.
The EOC in Fairfield County was not adequate for emergency operating periods of long duration due to lack of space.
i S.
EOC Internal Communications and Displays (Message Handling,- Mcps, etc.)
Message handling at the State EOC vas difficult.
The method of sending runners for information exchange is not suf ficient. Perhaps a public address system could alleviate the message handling problem.
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There was limited central display of pertinent information at the FE0C and Fair-field County EOC.
Information which is essential to the decision-making process was available only in a fragmental fashion.
It was difficult for various State and local agencies to find a sur. mary of the essential information. The initial briefing at the FEOC did not provide information regarding internal operations, FEOC layout, and internal communications. Acoustics were very poor.
- Thus, announcements over the PA system were very difficult to understand.
Briefing intervals were probably not realistic.
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2 6.
Adequacy of Staffing (Multiple Shifts, Competency, etc.)
No deficiencies noted.
7.
Facility Access / Security No noted deficiencles.
8.
Support by Responsible Elected and Appointed Officials
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It seemed that agency heads and elected officials relied too heavily upon the CD Director and County Manager in Fairfield County.
Support by Richland_ County elected or appointed officials was not apparent in the EOC as indicated on page 6, paragraph V A (1) of Richland County - City of Columbia (SOP).
9.
Direction and Control (timely decision makinn. manacement. etc.)
Radiological monitoring missions directed from the mobile lab were not assigned in a timely fashion.
The release from the plant occurred at 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> and the air monitoring team was dispatched at 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />. No advice was given the team on exposure rate levels, wind direction, turn back doses or other personal pro-tective measures.
10.
Coordination (between officials, agencies, federal agencies, etc.)
While proper direction and control actions were initiated early in the exercise, there seemed to be some confusion and lack of coordination between EPD and DHEC.
11.
Emergency Plans (Adherence, SOP's and Checklists Consulted)
No noted deficiencies.
12.
Public Information (Interface with News Media)
No noted deficiencies.
13.
Accident Assessment (Monitoring, Reporting, Projecting, Coordination)
Accident assessment was good at the mobile laboratory.
There seemed to be a I
problem of prompt teporting of monitoring data. Actual sample collection may be more appropriate than simulation. Monitoring team communications via radio i
to the mobile lab were not adequate at times. Message " break-up" occurred at distances near tLe plant site.
l 14.
Protective,ictions (Evacuation, Shelter, Reception and Care)
No noted deficiencies.
15.
Exposure Control (Access and Traffic Control, Use of KI, Record Keeping) l Advice to monitoring teams to take KI was given, however team members could have been exposed to the plume before taking KI.
Information regarding radiation i
levels was not displayed in Fairfield County E0C.
There was no vehicle monitoring and decontamination station established near the mobile laboratory.
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Recovery and Reentry Recovery and reentry operations were observed only in the initial stages. No deficiencies were noted.
- 17. Adequacy of Scenario to Test State and Local Plans No major deficiencies were noted.
18.
Benefit of Exercise to Participants Radiation level. inputs from the scenario seemed to be inconsistent with the exercise sequence of events. Thus, the monitoring teams were confused by con-troller inputs.
The scenario did not seem to provide enough action for State agencies located at the SEOC. Neither did the scenario provide enough action for Lexington County. Thus, State and local agency personnel did not gain the experience which could have been gained given a greater amount of exercise play.
19.
Capability c; Observed Jurisdiction, Agency and/or Function to Execute REP Plans to Pr,ptect the Public While improtements are needed, and specific lessons were learned, South Carolina and the a:dected local counties are capable of executing site-specific REP plans for the V. C. Summer Nuclear station.
The lack of adequate space in the Fairfield County ~EOC creates difficulty for county officials to implement the county plan.
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