ML20054F888
| ML20054F888 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/02/1982 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8206180129 | |
| Download: ML20054F888 (14) | |
Text
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4 pr 4 Federal Emergency Management Agency
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Washington, D.C. 20472 O
O JUN 2 1982 4 {$
MEMORANDUM FOR: Brian Grimes Director Division of Emergency Preparedness U.S. Nuclear Regulatory Commiasion FROM:
Assistant Associate Director Office of Natural and Technological Hazards
SUBJECT:
Evaluation of Offsite Emergency Preparedness for the Browns Ferry Exercise Attached herewith are two documents relative to the September 9-10, 1981, exercise at Browns Ferry in Alabama. : Letter from Region IV RAC Chariman to State of Alabama dated September 22, 1981.
Includes report entitled " Deficiencies Noted in the Plant Browns Ferry Exercise Conducted in the State of Alabama, September 9-10, 1981." : Document entitled " Enclosure 1, Browns Ferry Nuclear facility Radiological Emergency Exercise, September 9-10, 1981, Regional Assistance Committee Observations and Recommendations and State of Alabama Response", undated.
This enclosure was included in a detailed review of the exercise by the State of Alabama dated December 8,1981.
If you have any questions regarding this matter, please contact Vernon E. Adler, Chief, Technological Hazards Division at 287-0200.
Attachments as stated 8206180129 820609 PDR ADOCK 05000259 F
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/ %[f y Federal Emergency Managernent h
Region IV 1375 Peachtree Street, NE Atlanta, Georgia 30209 Septembe r 22, 1981 Ira L. Myers, M. D., State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36210 Mr. Sam Slone, III Director, Civil Defense Department State of Alabama State Administrative Building Montgomery, Alabama 36130
Dear Dr. Myers and Mr. Slone:
Enclosed is a list of deficiencies noted in the Plant Browns Ferry REP Exercise conducted September 9-10, 1981.
These deficiencies were observed by the Regional Assistance Committee and FEMA IV staff.
We are aware that corrections are currently being made in the Plant Brovms Ferry Site-Specific Plans as a result of the exercise and participant critique conducted on September 10, 1981. Thus, at the earliest convenience, please provide the FEMA IV Regional Director with a report on how and when the noted deficiencies will be correc'ed. Upon receipt of this report, the process of plan review and acceptance ma3 proceed.
We compliment Alabama for the excellent radiological emergency preparedness effort, and assure you RAC IV and FEMA IV staff remain committed to future support of REP activities in your state.
Since rely, e
- ~ _
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%> Jack D. Richardson
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Chairman, RAC IV l
Enclosure l
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DEFICIENCIES NOTED 3
IN THE i
PIANT BROWNS FERRY EXERCISE l
l CONDUCTED IN 1
i THE STATE OF ALABAMA I
1 SEPTEMBEI;. 9-10, 1981 i
l l
DEFICIENCIES NOTED IN THE PLANT BROWNS FERRY EXERCISE 1.
Notification and Alertinc of Officials and Staff Lauderdale, Lawrence and Limestone counties experienced delays in contacting officials and staff because of limited communications capabilities.
2.
Notificatian and Alertinc of the Public The current alerting and notification system does not meet the requirements set forth in NUREG 0654/ FEMA REP 1, Rev. 1.
While EBS, by exercise ground rule, received limited use in this exercise, additional and continuous use of this system should have been simulated during the entire exercise period. This would have allowed the public information staff to develop a number of specific releases for the EBS system.
3.
External Communications Capability Between Sites Additional telephone and radio communications are needed for effective emergency operations in Lauderdale, Lawrence and Limestone County EOCs.
The State CEOC telephone system should be reviewed to ensure adequacy in the event of an actual emergency. Plans and procedures should be revised to reflect a rapid installation and expansion capability.
The need for a communications link (ring-down telephone) between the Browns Ferry Plant Site and State / local government operating locations should be considered by all parties.
4.
Emergency Operations Center (EOC) Facilities Space allocation in the State CEOC should be reevaluated to ensure adequate work area for Rad Hemith and Utility / Federal Liaison personnel who may be present.
Co-location of key State decision makers should be considered, also, hwrence and Limestone County EOCs lack space and equipment necessary for effective sustained operations.
5.
EOC Internal Communications and Displays Space constraints in the State CEOC (Rad Health Area) interfered with maintaining informational displays and in the conduct of periodic operational situation briefings for key personnel.
2 Display maintenance procedures and responsibility should be established. This will prevent display of incomplete / outdated operational information. Ope rations maps at all State and local operating locations should be standardized (this should include TVA Center in Chattanooga).
Maps which display the 50 mile EPZ (includes Tennessee) were not available at all operating locations.
6.
Adequacy of Staffing l
We would recommend a close review of possible multiple shift operations, over a protracted period of time, for' Rad Health Accident Assessment Operations. While DOE and other federal agencies would provide support, the overall responsibility for the assessment of off-site hazards to the public will remain with state govern-ment for the duration of the emergency.
7.
Facility Access Control / Security No deficiencies were noted.
8.
Support of Responsible Elected and Appointed Officials No deficiencies noted.
9.
Direction and Control No deficiencies noted.
- 10. Coordination (Between Officials, Agencies, Federal Government)
State Rad Health, Utility and Federal Agencies should coordinate in the review /
revision of internal operating procedures to ensure more effective field coordina-tion and communications during an emergency. In view of limited state resources, consideration should be given to lead time for initial notification of Federal Agencies:
Improvament is needed in the area of State CEOC to County EOC operational information flow. This was addressed in depth during participant critique.
Operational procedures should include more frequent and formalised situation briefings for CEOC and EOC staffs.
1 i
- 11. Emergency Plans No deficiencies noted.
O
3 12.
Public Information We recommend a review of current public infornation plans and procedures to ensure that State (CEOC), Counties and Utility Organizations are in concert on all public irdormation activities. Some of the factors which should be considered in this effort are:
Release of information from a single source e
Use of technical language in public releases should be minimized i
Education of area media resources during non-emergency periods e
i Assurance that CEOC/ Utility PI releases and actions are provided e
to County PIOS in a timely manner Plans and procedures should also be developed to accommodate the e
possible influx of National and International media organisations (press kits for non-local media would be needed)
Presidential / Congressional interest and response will be a key public
{
e information requirement should an accident occur
- 13. Accident Assessment (Monitoring, Projections and Coordination)
Use of incorrect terminology in communicating techhical informatirm between sites caused some confusion and delay. Stand = rdination of terms and communi.
cator training is needed.
Consideration should be given to identification of monitoring team vehicles when in the field on assignment, 14.
Protective Actions (Evacuation Shelter, Reception and Care) j The rapidly developing situation (forced by scenario) in Limestone County demonstrated a need for more field personnol, especially Law Enforcement, to notify residents and transients of the need for evacuation.
- 15. Exposure Control (Access and Traffic Control, Use of KI, Recording Dose)
I Access and traffic control needs more emphesis in future site-specific exercises.
The purpose / decision for issuance of KI was not clearly understood at the local level.
4 Decontamination monitoring stations for emergency personnel and vehicles were not observed in tne field or at emergency operating center locations.
One Rad Health Field Monitoring Team was not equipped with self-reading dosimete ry.
Monitorin;; teams were not provided information on plant condition before dispersal to field assignments.
It appears additional training is needed in exposure control procedures for emergency workers.
- 16. Reentry and Recovery The initial phase of reentry and recovery operations was addressed in this exercise. However, the Utility decision to terminate play ahead of the scripted schedule caused problems for off-site participating organizations.
- 17. Adequacy of Scenario to Test State and Local Plans As indicated above, deviations created unnecessary problems.
The scenario did not provide for exercising off-site medical response capabilities.
This should be addressed in future exercises.
- 18. Benefit of the Exercise to the Participants No deficiencies noted.
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- 19. Capability of Observed Jurisdiction, Agency and/or Function to Execute REP Plans to Protect the Public While irnprovements are needed, and specific lessons were learned, Alabama and the affected local counties / governments are capabl, of executing site-specific plans for the Plant Browns Ferry Fixed Nuclear Facility.
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ENCLOSURE 1 3 RO'CIS FERRt NUCLEAR FACILITY RADIOLOGICAL EMERGENCY EXERCISE September 9-10, 1981 Regional Assistance Committee Observations and Recommendations and State of Alabama Response 1.
Notification and Alertino of Officials and ~ Staff Lauderdale, Lawrence and Limestone Counties experienced delays in contacting officials and staff because of limited communications capability.
Response
Concur.
Negotiations are currently underway with TVA to acquire additional pagers for the key per-sonnel of these counties.
This will eliminate the need to contact each person by telephone in 1
the future and should speed up the notification process.
2.
Notification and Alerting of the Public The current alerting and notification system does not meet the requirements set forth in NUREG 0654/ FEMA REP 1,
Rev.
1.
Response
The prompt notifigation system is in the process of being installed by TVA and should be operational by early January 1982.
i While EBS, by exercise around rule, received limited i
use in this exercise, additional and continuous use of I
this system should have been simulated during the entire exercise period.
This would have allowed the priblic in-formation staff to develop a number of specific releases for the EBS system.
b N
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Response
fjt Excellent suggestion.
Future exercies will incorporate simu-i
k lated use of the EBS.
This will also assist in decredsing lag time for the participants.
s
't 3.
External Communications Capability Between Sites p
Additional telephone and radio communications are needed for ef-fective emergency ope ations in Lauderdale, Lawrence and Lime-stone County EOCs.
Response
Lawrence and Limestone County EOCs will have additional tele-phones installed when the new facilities are constructed.
They will also have an expansion capability.
All three coun-ties are in the process of increasing their radio communica-tions capability.
The State CEOC telephone system should be reviewed'to ensure adequacy in the event of an actual emergency.
Plans and pro-cedures should be revised to reflect a rapid installation ~ and expansion capability.
Response
The system in use during the exercise was not thecomhle_sys-tem to be installed by TVA.
The final system should'be'ade-quate for an actual emergency.
The need for a communications link (ring-down telephone) be-tween the Browns Ferry-Plant Site and State / local government operating locations should be considered by all parties.
Response
The State of Alabama concurs that there should be a direct telephone access between the Browns Ferry site and off-site officials.
This has been discussed with TVA in the?past with negative results.
4.
Emergency Operations (EOC) facilities Space allocation in the State CEOC should be reevaluated to en-sure adequate work area for Rad Health and Utility / Federal liaison personnel who may be present.
Collocation of key State decision makers should be considered also.
Lawrence and Lime-stone County EOCs lack space and equipment necessary for effec-tive sustained operations.
Response
The replacement of the desks and tables in the RMDA with cus-l tom made narrow tables should i.morove the crowded conditions.
l The Director of the Radiation Control Agency and the Director of Civil De fense are located in adjoining of fices and do con-verse with each other on decisions.
TVA has agreed to fund a portion of the construction of new larger EOCs in Limestone and Lawrence Counties.
This, along with the equipment that will be plac;d in the new facilities, should resolve the crowding and operational problems.
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iN 5-EOC_ Internal Communications and Displays v
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k. \\v Space constraints in the State CEOC (Rad Health Area) interferdd with maintaining informational displays and briefings for key personnel.
Response
The.shaceconstraintsshouldbesolvedbythe-in-
?F stallation of the narrow tables.
Procedures have been: revised to include periodic display updates' and operational situation briefings in the RMDA.
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Display maintenance procedures and responsibility'should be established.
This will prevent display of incomplete /
outdated operational information.
Operations maps at
+
all state and local operating locations should be stan-dardized (this should include TVA Center in Chattanooga).
Response
. 7
- 4
/ The State efficials in the Albama CEOC are not re-s'ponsible for radiation in Tennessee; therefore, all maps need not include Tennessee.
One map that displays all of the injuestion pathway will be added in the RMDA room of the CEOC.
Maps which display the 50 mile EPB (includes Tennessee) were not available at all operating locations.
Response
U Maps',that display the 50 mile EPB are being acquired of for all operating locations.
r (llequacy of Staf fing 6.
A N
We'QouId recommend a close review of possible multiple tshift operations, over a protracted period of time, for Rdd Health accident assessment operations.
While DOE and other federal agencies would provide support, the overall > responsibility for the assessment of of f-site hazardsito the public will remain with state government
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for thy duration of the emergency.
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Response
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The State Radiation Control Agency has only suffi-(, '? j cient health physics staff for two 12-hour shifts in the RMDA.
This precludes any health physics
> Jstaffing in the State EOC.
After day one this can be revised to three shif ts provided DOE technical assisr.ance can assume the non-decision making func-t i,o n s.
3
i 7.
Facility Access Control / Security No deficiencies were noted.
8.
Support of Resconsible Elected and Appointed Officials No deficiencies were noted.
1 9.
Direction and Control No deficiencies were noted.
10.
Coordination (Between Officials, Agencies, Federal Government)
State Rad Health, Utility and Federal Agencies should coordinatein the review / revision of internal' operating-procedures to ensure more effective field coordination and communications during an emergency.
In view of limited state resources, consideration should be given to lead time for initial notification of Federal agen-cies.
Response
Standard Operating Procedures have been jointly re-vised by the State and Utility to eliminate the problem.
The State of Alabama has on file at DOE standing IRAP requests which provide infinite lead time for the possible needs by'the State in the event of a classified emergency.
The State Radia-tion Control Agency will endeavor to keep DOE better informed of classified incidents at reactors within Alabama.
Improvement is needed in the area of State CEOC to County operational information flow.
This was addressed in depth during participant critique.
Response
The State is requestin: that TVA place telecopiers and tape recorders cesa e of recording telephone conversations in PbA Cm Tty EOCs.
These two pieces of equipment shosl m'
eliminate the problems ex-perienced with tr. - e x. - /.ge of data between the State and the counties.
Operational procedures should include more frequent and formalized situation briefings for CEOC and EOC staffs.
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Response
The need for situation briefings for CEOC and-EOC staffs has been discussed with the Directors and there is a general concensus that personnel in the two areas need to be kept informed on the-status of the emergency, be it simulated or-real, 11.
Emergency Plans No deficiencies noted.
12.
Public Information We recommend a review of current public information plans and procedures to ensure that State (CEOC), Coun-ties and Utility organizations are in concert on all public information activities.
Some of the factors which should be considered in this effort are:
- Release of Information
Response
Steps have been taken to have only one point from which information will be released at the State level.
This point of contact will be the Governor's Press Secretary.
- Use of technical language in public releases should be minimized
Response
Technical language in the public releases will be carefully edited and kept to a minimum.
- Education of area media resources during non-emergency periods
Response
Attempts to educate the media have been met with apathy.
Prior to the exercise at Browns Ferry, a class for media personnel was conducted in the Mor-l gan County EOC.
Representatives from TVA, State and County Civil Defense and State Radiation Con-l trol Agency were available to brief the media participants and to answer any questions they i
might have.
Although the initial turnout was good, by noon only approximately four media personnel were left in attendance.
i I
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- Assurance that CEOC/ Utility PI releases and actions are provided to County PIOS in a timely manner
Response
Steps are being taken to get the equipment'neces-sary to keep the Counties informed in a timely manner.
- Plans and procedures should also be developed to accommodate the possible influx of National and International media organizations (press kits for non-local media would be needed)
Response
Plans are being developed to transfer the Near-site Press Center to a larger facility with adequate work space and outside telephone lines in the event the EOC auditorium proves to be too small to accommodate the press.
- Presidential / Congressional interest and response will be a key public information requirement should an accident occur
Response
The State recognizes the potential for Presidential /
Congressional interest and feels current procedures should accommodate any public information require-ments that might be generated.
13.
Accident Assessment (Monitoring, Projections and Coordi-nation)
Use of incorrect terminology in communicating technical information between sites caused some confusion and de-lay.
Standardization of terms and communications training is needed.
Response
The RAC comment does not contain suf ficient infor-mation about where the incorrect terminology caused l
confusion and delay for the State to take correc-tive measures.
Consideration should be given to identification of monitoring teamivehicles when in the field on assign-ment.
(
l,
Response
TVA has'been requested to fund the purchase of mag-netic stick-on signs for vehicles used by Public Health employees while doing emergency environmental monitoring.
14.
Protective Actions (Evacuation, Shelter, Reception and Care)
The rapidly developing situation (forced by scenario) in Limestone County demonstrated a need for more field personnel, especially Law Enforcement, to notify resi-dents and transients of the need for evacuation.
Response
This problem probably would not exist during an actual incident.
For exercise purposes the County cannot afford to pay overtime and many of the auxiliary personnel cannot take off time from their normal jobs.
15.
Excosure Control (Access and Traffic Control, use of KI, Recording Doses)
Access and traffic control needs more emphasis in future site-specific exercises.
Response
This item will receive added emphasis.
l The purpose / decision for issuance of KI was not clearly understood at the local level.
Response
The State Radiation Control Agency will place more emphasis on KI during future training sessions.
The subject has apparently not received enough attention in the past; this was due in part to a lack of adopted federal guidelines on the subject.
Decontaminatiori monitoring stations for emergency per-sonnel and vehicles were not observed in the field or at emergency operating center locations.
Responsa Decontamination monitoring stations are estab-i lished in the plan.
All of these were at least particlly exercised except the Environmental i
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