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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K4391999-10-18018 October 1999 Provides Response to RAI to Support USI A-46 Program Submittal for North Anna Power Station,Units 1 & 2.Rev 10 to BNL Rept 52361,encl ML20217H3301999-10-14014 October 1999 Forwards Rev 0 to COLR for North Anna 2 Cycle 14 Pattern Su. No New Commitments Intended by Ltr ML18152B3541999-10-12012 October 1999 Requests Use of Code Case N-532 & N-619,per Provisions of 10CFR50.55a(a)(3).Detailed Info Supporting Request,Encl. Attachment 2 Includes Technical White Paper That Provides Further Technical Info ML20216K1681999-10-0101 October 1999 Forwards Vols I-VIII of Rev 35 to UFSAR for Naps.Rev Also Includes Update to Chapter 17 of Ufsar,Which Contains Operational QA Program.Changes to Program Description Do Not Reduce Commitments Contained Therein ML20212J9101999-10-0101 October 1999 Forwards SE Accepting Licensee 990916 & 27 Relief Requests IWE-3 for Plant.Se Addresses Only IWE-3 Due to Util Urgent Need for Relief.Requests IWE-7 & IWE-8 Will Be Addressed at Later Date ML18152B3391999-09-27027 September 1999 Forwards Revised Relief Request IWE-3,which Now Includes Addl Visual Exam Requirement After post-repair or Mod Pressure Testing Is Completed,Per Telcon with NRC ML20212G5091999-09-22022 September 1999 Forwards in Triplicate,Applications for Renewal of Licenses for Listed Individuals.Encls Withheld,Per 10CFR2.790(a)(6) ML18152B6671999-09-17017 September 1999 Forwards Two NRC Forms 536,containing Info on Proposed Site Specific Operator Licensing Exam Schedules & Estimated Number of Applicants Planning to Take Exams And/Or Gfes,In Response to NRC Administrative Ltr 99-03 ML18152B3331999-09-17017 September 1999 Forwards Revised 180-day Response to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML18152B3341999-09-16016 September 1999 Requests Relief from Specific Requirements of Subsection IWE of 1992 Edition with 1992 Addenda of ASME Section XI Re Containment Liner Examination Requirements,For North Anna & Surry Power Stations ML20211N2531999-09-0808 September 1999 Responds to Request to Exceed 60,000 Mwd/Mtu Lead Rod Burnup in Small Number of Fuel Rods in North Anna Unit 2.Informs That NRC Offers No Objection to Requested Use of Rods in Reconstituted Fuel Assembly.Se Supporting Request Encl ML18152B4471999-09-0101 September 1999 Requests That NRC Remove Listed Labels from Distribution ML20211L9151999-09-0101 September 1999 Forwards Response to NRC Request for Comments Re Closure of Review of Response to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20211J2211999-08-31031 August 1999 Approves Request to Remove Augmented ISI (Aii) Program for RCS Bypass Lines from North Anna Licensing Basis.Se Re Request to Apply LBB to Eliminate Augmented Insp Program on RCS Bypass Lines Encl ML20211H4131999-08-27027 August 1999 Informs That Util Revised Encl Bases for TS 2.2.1, Reactor Trip Sys Instrumentation Setpoints, Discussing Steam Flow/ Feed Flow Mismatch Portion of Steam Flow/Feed Flow Mismatch & Low SG Water Level Reactor Trip Setpoint ML20138B3241999-08-23023 August 1999 Forwards Draft Response to Question 1 Re NAPS USI A-46 ML20211D9041999-08-20020 August 1999 Forwards Revised Pages to Third Ten Year ISI Program & Relief Requests, Replacing Pages in 990408 Submittal ML20211B3871999-08-17017 August 1999 Requests Permission to Routinely Discharge from SW Reservior to Waste Heat Treatment Facility Under Existing Vpdes Permit Through Outfalls 108 & 103.Discharges Are Scheduled to Commence on 990907,due to High Priority Placed on Project ML20210T0671999-08-13013 August 1999 Informs of Completion of Review of Proposed Revs of Schedule for Withdrawal of Rv Surveillance Capsules Submitted by VEPCO on 981217.Approves Proposed Revs.Forwards Safety Evaluation ML20210Q9841999-08-12012 August 1999 Forwards Rev 1 to Vepc COLR for North Anna Unit 2,Cycle 13 Pattern Ud, Per TS 6.9.1.7.d.COLR Was Revised to Include Temp Coastdown Operation at End of Cycle 13 ML18152B4081999-08-0606 August 1999 Forwards Response to NRC 990520 & 0525 RAIs Re North Anna & Surry Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves. ML20210Q7661999-08-0606 August 1999 Requests Exception to 10CFR50.4 Requirement to Provide Total of Twelve Paper Copies When Submitting Surry & North Anna UFSAR Updates.Seek Approval to Submit Only Signed Original & One CD-ROM Version,Per Conversation with J Skoczlas ML18152B4091999-08-0505 August 1999 Forwards Vepc semi-annual fitness-for-duty Program Performance Data Rept for 990101-990630,IAW 10CFR26.71(d) ML20210N2921999-08-0505 August 1999 Discusses Which Submitted Proposed TSs Bases Change for Containment Leakage. Licensee Changes to Bases May Be Subj to Future Insps or Audits ML20210J8861999-08-0202 August 1999 Provides Clarification to Commitment Made in Identifying Extent by Which Existing Plant Design Complied with RG 1.97,specifically Re Variable, Radiation Exposure Rate ML20210F6121999-07-28028 July 1999 Forwards Supplemental Info on Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit,Documenting Info Provided During 990624 Meeting & Suppl Original Submittal ML18152B3971999-07-26026 July 1999 Provides Estimates of Licensing Actions Expected to Be Submitted in Fys 2000 & 2001,in Response to NRC AL 99-02 ML20209E7621999-07-0909 July 1999 Provides Addl Info to Justify Use of Less than One Gpm Detectable Leakage Rate to Establish Required Margin for Crack Stability in LBB Analysis,Per 980623 Application on Reactor Coolant Loop Bypass Lines 05000338/LER-1999-005, Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl1999-07-0808 July 1999 Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl ML20209E3711999-07-0202 July 1999 Forwards Insp Repts 50-338/99-03 & 50-339/99-03 on 990425-0605.Violations Being Treated as Noncited Violations ML18152B4401999-07-0101 July 1999 Informs NRC That on 990511,Dominion Resources,Inc,Executed Amended & Restated Agreement & Plan of Merger with Consolidated Natural Gas Co ML18152B4371999-06-24024 June 1999 Forwards Response to NRC Request for Clarification of Relief Requests Submitted on 990212,requesting Relief from Performing Hydrostatic Testing for Certain Small Diameter Class 1,RCS Pressure Boundary Connections ML20196G2581999-06-23023 June 1999 Discusses Closure of GL 92-01,rev 1,suppl 1,reactor Vessel Structural Integrity ML20212J2951999-06-22022 June 1999 Forwards Corrected Markup & Typed Version of Affected Pages. Requests That Attached Pages for Those Previously Provided in 990506 Submittal Be Replaced & Incorporated Into NRC Review of Proposed TS ML18152B4361999-06-22022 June 1999 Forwards Response to RAI Re Surry & North Anna Power Stations,Units 1 & 2,per GL 96-06 ML20196F1151999-06-22022 June 1999 Forwards Relief Requests NDE-047 & NDE-048 for North Anna Power Station,Unit 1 Re ASME Section XI ISI Program ML20196G2211999-06-21021 June 1999 Forwards Licensee Sampling & Testing Obligations Re Vpdes Permit VA0052451 Reissuance Application.Details of Requests for Sampling & Testing Waivers,Included ML20195J7011999-06-15015 June 1999 Forwards Revised EPIP 2.01 Which Corrects Typo That Was Found in Step 10 of Procedure.Rev Does Not Implement Actions That Decrease Effectiveness of EP ML20195J1391999-06-11011 June 1999 Submits Addl Info as Addendum to Original Application Which Proposed Use of Three Chemicals in Bearing Cooling Tower at North Anna Power Station,Per Reissuance of Vpdes Permit ML18152B4301999-06-0303 June 1999 Informs of Util Intention to Revise Schedule for Submittal of License Renewal Applications for Surry & North Anna Power Stations to March 2002 ML20195C6601999-06-0101 June 1999 Forwards Response to NRC 990216 RAI Re Summary Rept of USI A-46 Program ML20207C9851999-05-28028 May 1999 Requests Regrading of Rt Robinson 990408 Written Exam,Based on Listed Reasons.Answer C for Question 18 Is Requested to Be Reconsidered as Correct or Question Be Deleted ML18152B4261999-05-28028 May 1999 Provides Formal Notification of Effect of Recent Organizational Restructuring on OLs of North Anna & Surry Power Stations,Per NRC 990513 Telcon Request ML18152B4221999-05-27027 May 1999 Forwards Info Concerning Changes to ECCS Evaluation Models & Application in Existing Licensing Analyses for Surry & North Anna Power Stations,Units 1 & 2 ML18152B4231999-05-26026 May 1999 Informs That Vepc Will Revise 180 Day Response to NRC GL 96-05,within 120 Days of Date of Ltr to Incorporate Commitment to Participate in Joint Owners Group Program as Applicable ML20206U7441999-05-20020 May 1999 Informs That NRC Unable to Conclude That NAPS Has Met Intent of Supplement 4 to GL 88-20.RAI Re Fire Area of IPEEE Encl. Response Requested within 90 Days of Submittal Date ML20207A8541999-05-20020 May 1999 Forwards RAI Re Licensee Listed Responses to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Response Requested within 90 Days of Submittal Date ML20195B5381999-05-14014 May 1999 Forwards Rev 8,Change 2 to North Anna Units 1 & 2 IST Programs for Pumps & Valves. Summaries of Program Changes Provided for Each Unit IST Program.Relief Requests Have Been Removed from IST Programs ML18152A3701999-05-13013 May 1999 Submits Proposal to Use Provisions of ASME Section XI Code Case N-597 for Analytical Evaluation of Class 1,2 & 3 Carbon & Low Alloy Steel Piping Components Subjected to Wall Thinning as Result of Flow Accelerated or Other Corrosion ML20206L4661999-05-10010 May 1999 Forwards SE Accepting Request to Delay Submitting Plant, Unit 1 Class Piping ISI Program for Third Insp Interval Until 010430,to Permit Development of Risk Informed ISI Program for Class 1 Piping 1999-09-08
[Table view] Category:EXTERNAL CORRESPONDENCE
MONTHYEARML20211B3871999-08-17017 August 1999 Requests Permission to Routinely Discharge from SW Reservior to Waste Heat Treatment Facility Under Existing Vpdes Permit Through Outfalls 108 & 103.Discharges Are Scheduled to Commence on 990907,due to High Priority Placed on Project ML20196G2211999-06-21021 June 1999 Forwards Licensee Sampling & Testing Obligations Re Vpdes Permit VA0052451 Reissuance Application.Details of Requests for Sampling & Testing Waivers,Included ML20195J1391999-06-11011 June 1999 Submits Addl Info as Addendum to Original Application Which Proposed Use of Three Chemicals in Bearing Cooling Tower at North Anna Power Station,Per Reissuance of Vpdes Permit ML20206M7921999-05-0707 May 1999 Advises That Vepc Is Proposing to Use Three Chemicals in Bearing Cooling Tower at Naps,That Were Not Addressed in Licensee Last Application for Reissuance of Vpdes Permit ML20196H6431998-12-0303 December 1998 Informs That Util Is Seeking Approval to Discharge Chlorinated Blowdown from Bearing Cooling Tower for More than 2 H Per Unit as Specified in Special Condition 10 of Vpdes Permit.Meeting During Wk of 981214,requested ML20153G0131998-09-22022 September 1998 Requests Approval for Extended Compliance Schedule for Specific Provisions of Part III (9 VAC25-91-130,Pollution Prevention Requirements) for North Anna Nuclear Power Station ML18152B8171998-05-18018 May 1998 Discusses Results of Data Contained in Discharge Monitoring rept-QA (Dmr/Qa) Dtd 980114 ML20217Q7691998-05-0404 May 1998 Forwards Revised Application for Exclusionary General Permit for NAPS as Requested by D Vaughan in ML20198P8791998-01-12012 January 1998 Submits Application for Exclusionary General Permit for Plant ML20203H6111997-12-15015 December 1997 Forwards Application for General Storm Water Permit for Construction Activity at Naps.Local Government Ordinance Form,Pink Copy of Permit Application Fee Form & Copy of Check for Application,Encl ML20198P2871997-10-29029 October 1997 Requests That Vpdes Permit Be Amended to Reflect That Three Small Package Sewage Treatment Plants Were Permanently Removed from Svc ML20210G9721997-07-22022 July 1997 Submits Proposal to Pressure Test Piping within 10 Days Prior to Normal Fuel Oil Unloading Into Ast,Beginning No Later than 980101 ML20138B3381997-04-23023 April 1997 Provides Info to Support Proposal to Perform Annual Pressure Testing as Method of Leak Detection for Underground Line That Runs from Loading Area 5,000 Barrel Aboveground Storage Tank ML18153A1171997-03-19019 March 1997 Discusses Discharge Monitoring report-quality Assurance (DMR-QA) Results for VA Power Facilities ML20149M8131996-12-0505 December 1996 Submits Conditions Which Are Part of 961202 Approval of Temporary Conditional Use Permit Which Allows Construction of Temporary ISFSI or Dry Cask Storage as Listed ML20101R2521996-04-10010 April 1996 Responds to Unacceptable Results Noted in Discharge Monitoring rept-QA Rept for North Anna Power Station (Permit VA0052451) & Yorktown Power Station (Permit VA0004103) ML20101J0511996-03-21021 March 1996 Provides Notice of Intent to Increase Amount of Reverse Osmosis Reject Water Discharged at Outfall 020 ML20100B9061996-01-24024 January 1996 Submits Annual Statement Verifying That Each Spillway Gate Operated at Least Once During Twelve Months Preceding Annual Insp by Ferc,Per 18CFR12.44(b)(2).Main Dam'S Five Spillway Gates Satisfactorily Tested as Specified on Attached Form ML20087L3411995-08-21021 August 1995 Notifies of Minor Change in Discharge or Mgt of Pollutants at Plant ML20083K7181995-05-0404 May 1995 Forwards Application for Reissuance of Vpdes Permit for North Anna Power Station W/Addl Data Requested by ML18153A8081995-04-28028 April 1995 Provides Comments on EPA Pr Re Criteria for Certification & Determination of Waste Isolation Pilot Plant Compliance W/ Environ Standards for Mgt & Disposal of SF,high-level & Transuranic Radwastes.Guidance Re Categorization Needed ML18153A7921995-04-12012 April 1995 Submits Comments Re Proposed Revs to Guidance Provided to Federal Agencies on Radiation Protection ML20080J9181995-02-22022 February 1995 Submits Annual Statement Verifying That Each Spillway Gate Has Been Operated at Least Once During Twelve Months Preceeding Annual Insp by FERC Regional Engineer ML20080K8561995-02-22022 February 1995 Submits Notification for Spillway EDG Corrective Maint & Start Failure for Plant Hydroelectric Project ML20078M1481995-02-0808 February 1995 Discusses Series of Problems at Sewage Treatment Plant Re Exceedance in Bod ML20078H0711995-01-30030 January 1995 Discusses Conditions Affecting Safety of Project That Documents Problem Encounter W/Spillway EDG at Plant Main Dam & Informs on 950103 Spillway EDG Failed to auto-start During Performance of Monthly Periodic Test ML20078E1251995-01-25025 January 1995 Submits Notification Re Stationary Source Permit to Construct & Operate an EDG ML20080C1381994-11-30030 November 1994 Responds to Issues Identified in Repts for Technical & Lab Insps on 941018 & 20.Corrective Actions:Corrected DMR Forms Completed & Submitted to Dept of Environ Quality & TSS Worksheet Form Revised ML20077C2481994-11-22022 November 1994 Discusses Licensee Request for Relief from Ph Limitations in Plant Current Vpdes Permit at Outfalls 003 & 004 ML20078G8421994-11-0909 November 1994 Submits Response to Violations Noted in Insp Repts 50-338/94-10 & 50-339/94-10.Corrective Actions:Upset Conditions Corrected & Facility Performance Inproved ML20071L6281994-07-28028 July 1994 Ack Receipt of Detailed Response to NPDES Insp Rept ML18153B0261994-07-25025 July 1994 Forwards Update on Containment & Accumulator Initial Temp Assumptions for LB-LOCA Analysis ML20071H5761994-07-13013 July 1994 Notifies That Station Blackout Generator at Util Scheduled for Startup on or Around 940820 ML18153A9891994-07-0101 July 1994 Responds to VEPCO 940614 Ltr Re Proposed Procedure for Disposing of Low Level Radioactive Contaminated Asbestos Waste from Surry & North Anna Power Stations ML18153A9681994-06-14014 June 1994 Confirms Agreements Reached During 940419 Telcon Re Util Proposed Procedure for Tracking low-level Radiologically Contaminated Asbestos Waste Once Shipped to Interim Processor for Vol Reduction ML20069K2581994-06-0909 June 1994 Responds to Insp Rept & Deficiency Notice Received at Plant Following 940322 Insp.Since No Prior Notice of Changes to Std Methods Rule Given,Impacted Permittees Should Be Allowed Reasonable Time to Come Into Compliance W/Any Changes ML20065R3591994-05-0202 May 1994 Forwards Caterpillar 940210 Memo Addressing Issues Re Emission Limits in Permit Issued on 931020 Which Differ from Limits Requested in 930830 Application for Permit to Install Emergency Standby diesel-powered Generator at Plant ML20065F2761994-04-0505 April 1994 Proposes to Discontinue Survey Between North Anna Main Dam Ref Monuments & Us Coast & Geological Survey Monuments Performed Once Every 10 Yrs to Verify Locations of Ref Monuments ML20058F8811993-12-0202 December 1993 Submits Plan & Schedule for Development & Submittal of Annual Repts of Embankment Instrumentation & Survey Data,As Result of Annual Insp of North Anna Hydroelectric Facility ML20058D5901993-11-19019 November 1993 Submits Annual Statement Verifying That Each Spillway Gate Operated at Least Once During Twelve Months Preceding Annual Insp Conducted by FERC on 930921,per 18CFR12.44(b)(2) ML20057A9861993-09-0808 September 1993 Documents Understanding That,Due to Current Workloads at Agency,Recipient Will Not Be Available for Meeting Until After End of Sept,Per in Ref to Contested Findings of 930518 RCRA Insp at Plant ML20056G4091993-08-20020 August 1993 Responds to Util Rebutting Violations of Virginia Hazardous Waste Mgt Regulations Cited in 930607 ML20045G4031993-07-0707 July 1993 Responds to State 930607 Ltr Re Findings Noted in RCRA Insps on 930518.Licensee Has Demonstrated That No Violations W/Respect to Unmarked Drum & Accumulation Time & Annual Rept & Contingency Plan Occurred ML20126C6071992-12-18018 December 1992 Forwards Water Temperature Data Collected for Third Quarter of 1992,July-Sept at North Anna Power Station in Compliance W/Vpdes Permit VA0052451 Under Special Condition 8.Plant Operation Data Through Sept Shown in Figure 3 ML20116J2641992-11-0909 November 1992 Forwards Completed Oil Response Questionnaire for 921002 Oil Discharge.Discharge Was Contained within Treatment Facility & No Discharge to Waters Outside Facility Occurred ML20105A9731992-09-0909 September 1992 Responds to Telcon & Re Method of Compliance W/ Dates for Training in Fire Extinguisher Use.Under Proposed Procedure,Util Will Need to Maintain Internal Record Available for Review by State of VA for Min of 12 Months ML18153D0931992-08-12012 August 1992 Suppls 911223 Ltr Re Disposal of Asbestos,Containing Matl from North Anna & Surry Stations.Asbestos Shipment Left North Anna on 910828 for Quadrex for Processing.Remaining Portion Buried at Barnwell on 920629 ML20141M3391992-08-0505 August 1992 Responds to Telcon W/W Butler (Air Pollution Control Inspector) Re Fire Watch Training Program & State of VA Dept of Air Pollution Control Open Burning Notification Requirements ML20099A8571992-07-23023 July 1992 Advises That Settlement Offer,Described in , Acceptable to Util.Item 3 of Proposal Re Employee Environ Awareness Video Awarded to Echo Films,Inc.Site Barriers Constructed to Cover Entrances to Security Blockhouse ML20101S6181992-07-0909 July 1992 Forwards NPDES Discharge Monitoring Rept for June 1992 for North Anna Power Station. High Ph Problems in Turbine Bldg Sumps May Be Due to Residual Effects of Earlier Hydrazine Spill 1999-08-17
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. i a *k: I: Federal Emergency Management Agency l t
Region Ill !
Liberty Square Buuding (Second Floor) g :
lT 105 South Seventh Street Phundelphia, PA 19106
\
i AUS 171990 Addison-E. Slayton-
- Coordinator Virginia Office of. Emergency Services 310 Turner Road Richmond, Virginia 23225 Tear Mr. Slayton:
Ii The purpose of ,his: letter is to officially inform you of the l.
i:lentification of .t w o Deficiencice which occurred during the ;,
tior-h Anna REP Exercise which took place en August 7 and 8, 1990, l'
' The.firet _ problem involves the lack of coordination of siren and EBS: activations with-the fivetrisk county decision-makers and the
" information.which is contained in-the EBS messages. '-
- The'= protective action decision was made by. the Governor's t desianee at 1307. At- 1309, all. risk. county dispatchers were advised .via insta-phone- of the. protective action. None were advised at thatitime that eirens would be activated. At that ,
point,- the siren activation. sequence was performed by the State I
' Communicator and- the Louisa County Dispatcher. Sirens-were
-activated at :1310 and confirmed by the risk county dispatchers at 1312.-:Three of the five risk county coordinators were not aware that eirens had been' activated. .
)
- Alliimportant emergency instructions should bel discussed between
'ithe' State . decision-makers and the-County . Coordinators, who :are - i responsible for implementation. It should be noted that neither l Caroline nor Hanover County are' equipped- with an insta-phone J extension. separate from.the County Dispatch Offices and that both
- Louisa and Spotsylvania Counties.had equipment- problems with;the insta-phone extensions 'in the EOCs. The existing system (insta- ,
n phone) should be used as intended to provide a direct link 1 between the Commonwealth decision-makers and County' Coordinators 1 enlall emergency'information and instructions. Formal procedures 'I should be developed ~and included in the plans, and training'to the. Coordinators should be provided for activation of the' Alert' L
and-Notification System (Sirens, EBS).
9 The cecond part of this deficiency involves the EBS message ,
content. The EBS messages used during the exercise only ll identified the protective actions as they applied to evacuation 9011160109 901106 .
PDR ADOcy 05000339 1 F PNU l 4
zones (1, 2, 3, 4, etc..). Specific information should be included in the messages on the areas affected by the protective action to include -landmarks, geographical boundaries, the appropriate aspects of sheltering, ad hoc respiratory protection. This information is available and should be included in the EBS messages. It is recommended that prescripted messages be used to-cut down the preparation time for the EBS message and to insure that all required instructicas have been included. Al'1 pre-scripted messages should be inc3oded in the plan.
The second deficiency involves the entire accident assessment process from the initial protect'.ve action recommendation through the decision making process ant. on into the verification process through the use of field teame and laboratory analyses.
The Virginia Flan. Appendix 5, paragraph all), page 5-3.
describes the flow of radiological information. The Radiological Jfficer in the EOC has the responsibility to " advise the State EOC ctaff of the. radiological situation". This was not how the exercise was conducted.
The utility made an initial protective action recommendation at 1236, two minutes after declaration of General Emergency. This recommendation was made to both the OES and BRH personnel at the EOF. At 1240, thic recommendation was revised because the release was unmonitored. The protective action recommendation was faxed to the EOC (OES staff) by the OES liaison in the EOF at 1240.
' Contact between the'BRH staff at the EOF and the Radiological j Officer in the EOC did not occur until 1256. This left the !
Radiological Officer with a' protective action recommendation !
(provided to him by .the EOC OES staff) he could not explain for a ,
period of 16 munutes. 'During this critical time, he could not j perform his responsibility (as stated in the plan) to provide sound. technical advice to the OES staff in a timely manner.
On day 2 of the exercise- (evening of August 7, 1990) a meeting I was. held at the Emergency Operating Facility to develop a sampling plan to verify .the presence of radiation within the plume emergency- planning cone and the ingestion planning cone.
However, the campling plan which was developed was, except for
_two locations, restricted to the 10-mile- EPZ. Little or no l consideration was given to farms,- -dairies, etc., in the determination- of_ sampling points. The. philosophy demonstrated was geared to getting residents who had been evacuated and/or sheltered within the 10-mile EPZ back to normal living conditions in their homes. Little or no consideration was given to the campling requirements within the ingestion pathway. -
This was confirmed during day three of the exercise when field teams concentrated on the 0 to 10-mile EPZ and only took two 4
l samplee in' the 10 to 50 mile area (one at 11 miles and one at 12 miles). The sampling- plan failed to include indicator samples from the moet eeneitive ingestion pathway (pacture-cow-milk-consumer). This initial campling plan and misinterpretation of the DOE AMS flyover data initially led BRH to concluded-that there was no ingestion problems beyond the 10-mile EPZ. This conclusion was reevaluated based upon a controller message which injected additional data from dairy farms located at a distance of 26 miles. At that point the additional data was properly assessed and appropriate technical recommendations were made.
The overall concept for field monitoring and campling ehould be reviewed and plane and procedures developed and/or updated.
Three different organizations were performing field monitoring during the two day exercise (Commonwealth field teams, utility i field- teams and local field teame). However, none of these activitice were coordinated. In fact, at times the Commonwealth teams and the utility teams were monitoring and campling in the same locatione.which constituted a duplication of efforte and unneceecary exposure to radiation.
The procedures provided on day one of the exercise 1for taking samples and recording data- "ere not followed. However-, no controller data was provided the teams to record or forward to the LEOF, In addition many v. .. e procedures should be revised to reflect current guidance.
New team members have not been provided initial train'ing and existing _ team members were last trained five years ago.
Additional training (both initial and follow-on) is needed in the L areas of sample taking, monitoring procedures, reporting and <
recording requirements and radiological exposure control. t once team. members had taken each sample, they were instructed to take the sample to the mobile laboratory .for analysis. .This j resulted in a waste of time and could better be accomplished by a :
runner, leaving the team avai'lable to take further samples, i The mission exposuree for the field teams were 1R/ hour and 500 l mR/ hour. If these conditions were encountered, the emergency L worker was to immediately leave the area. IR/ hour is not an' area >
in which an emergency worker should remain, but should only be entered after a conscious decision is made by an appropriate _
manager, that essential data is needed, or that a neccessary task ;
must be accomplished. However, the 500 mR/ hour is less than the general population or non-escential personnel can receive. The i 500 mR/ hour is supposedly intended to be an administrative reporting level. County team members are only provide 0-200R eelf-reading dosimetere. County plans are vague as to what equipment should be available. One cannot measure accurately .5R g on a 0-200R dosimeter. Equipment provided must meet the lowest exposure limit for the mission.
l t
a
- l. *. .
.?,; . . .
As you are aware FEMA is tasked with the responsibility to periodically review' the overall plane and procedures under the normal review procese. FEMA Region III will be initiating a updated review of the Virginia Radiological Emergency Planning Proceec. This review will include any changes in the plans due to ingestion pathway planning procece, changes in responsibilities, and changes in concepte of operation. In j..
addition, we will be revaluating the plane as they pertain to- :-
planning problems that have been identified during exercices. . '
Some of these problems are as listed below:
Procedures that do not comply with current regulations and guidance.
Lack of procedurce.
Appropriate coordination between responsible agencies.
Appropriate. Letters of Agreement, j-
-Lack of. appropriate training to emergency responders Lack of proper equipment to perform assigned tasks On-going problems with the performance of equipment.-
We look forward to your cooperation in resolving these
-deficiencies. If' you have any questions, please contact RAC Chairman Joseph McCarey at-(215) 931-5520.
Sincerely, 6M Joseph M. McCarey, Chairman Regional Assistance Committee cc: Bobert Trojanoweki, NRC Dennie Kwiatkowski, FEMA National 4