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Answer Opposing Applicant Motion for Summary Disposition of Intervenor Contention 22 Re Emergency Planning.Genuine Issues of Matl Fact Remain to Be Heard.Certificate of Svc Encl.Related Correspondence
	ML20063J489
Person / Time
Site:	Comanche Peak
Issue date:	08/30/1982
From:	Ellis J; Citizens Association for Sound Energy
To:	; Atomic Safety and Licensing Board Panel
Shared Package
ML20063J480	List: ML20063J479; ML20063J489;
References
	NUDOCS 8209020431
	Download: ML20063J489 (122)
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BELATED CORRESPONDENCP J ,

8/30/8200,%IfD

h. UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION e BEFORE Till ATOMIC SAFETY AND LICENSING BOARD I

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In the Matter of jfF0C El U I

APPLICATION OF TEXAS tlT!LITIES Docket Nos. 50-445 GENERATING COMPANY, ET AL. FOR I and 50-446 AN OPERATING LICENSE FOR I e I

COMANCHE PEAK STEAM ELECTRIC STATION UNITS #1 AND #2 I ~

(CPSES) l CASE'S ANSWER TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF INTERVENOR'S CONTENTION 22 -

REGARDING EMERGENCY PLANNING Pursuant to 10 CFR 2.749, CASE (Citizens Association for Sound Energy),

s Intervenor herein, hereby files this, its Answer to Applicants' Motion for Summary Disposition of Intervenor's Contention 22 Regarding Emergency Planning.

A3 shall be. demonstrated herein, there are genuine issues of material fact to be heard regarding this contention. CASE therefore urges that the Board in these

, proceedings deny Applicants Motion for Summary Disposition and that hearings be l- ' held on this Contention.

Attached hereto is a concise Answer to Applicants' Statement of Material -

Facts Not Genuinely in Issue. As stated in that Answer and detailed in the following, there are indeed many issues which need to be addressed in hearings prior' to the granting of an operating license for the Comanche Peak facility.

l As set f6rth with specificity herein, there are many deficiencies in the CPSES Emergency Plan, the Texas State Plan, and the Somervell and Hood Counties -

Plans which must be dealt with prior to Applicants' being granted an operating 1

l license or a low-power test license for CPSES.

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Applicants, in their argument on page 4 of their Motion, state:

"The intervenor must be required to oppose this motion and the supporting affidavits with demonstrations by affidavits of competent and qualified affiants that a genuine issue exists as to a material fact. Failing such ;

demonstrations by the intervenor, the Board should ' render the decision -

sought . . . .' 10 C.F.R. S2.749(d); Order (Granting Sumary Disposition nf Contentions 2 and 7), supra,15 NRC at 595, Mere allegations or state-ments of concern by the intervenor's representative are insufficent to preclude summary disposition."

They have again thus set forth an old bone of centention between Applicants and the Board -- whether or not it is required that an Intervenor have expert .

witnesses in order to prevent sumary disposition. As the Board is well aware, CASE is not represented by an attorney in these proceedings. However, it is our belief that the Board acted correctly when they denied the NRC Staff's -

Motion for Sumary Disposition of Contention 25 (on Financial Qualifications) }

as well as Applicants' Motion for Summary Disposition of Contention 5 (on QA/QC and construction practices at CPSES). Further, the regulations set forth in

f 10 CFR 2.749 are not as narrow as Applicants would have one belie've; included

. r in the wording of that regulation are the following statements: .

...a party opposing the motion may not rest upon the mere allegations or denials of his answer; his answer by affidavits or as othemise provided in this section must set forth specific facts showing that there is a genuine issue of fact." (Emphasis added.) -- 2.749(b) ,

"Should it appear from the affidavits of a party opposing the motion that he cannot, for reasons stated, present by affidavit facts essential to justify.

his opposition, the presiding officer may refuse the application for sumary y decision or may order a continuance to pennit affidavits to be obtained or make such other order as is appropriate..." (Emphasis added.) -- 2.749(c) ?

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"The presiding officer shall render the decision sought if the filings in the proceeding, depositions, answers to interrogatories, and admissions on file, together with the statements of the parties and the affidavits,

- if any, show that there is no genuine issue as to any material fact and that the moving party is entitied to a decision as a matter of law..."

(Emphasis added.) -- 2.749(d)

It should further be pointed out that the instance cited by Applicants whereby Sumary Disposition was granted on Contentions 2 and 7 was a far different matter than the one now at issue with Contention 22, in that CFUR (the Intervenor

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sponsoring Contentions 2 and 7) was in the process of withdrawing from these j proceedings and did not file an answer to the Motion for Sumary Disposition I regarding Contentions 2 and 7. Applicants would have the Board believe that (

only if an Intervenor has expert witnesses to testify regarding specific issues should such Intervenor be allowed to participate as a party in these proceedings.

This is clearly not supported by any NRC regulation, and there are clear pmcedents .

for allowing an Intervenor to make its case by pointing out deficiencies in Applicants' case.

CASE had initially planned to have an expert witness to testify regarding .

emergency planning, but we were unable to make arrangements for the Septenber j hearings due to the particular time frame within which we are working and prior comitments of potential witnesses. However, we believe that there are sufficient i

. . deficiencies in Applicants', State, and Counties' Emergency Plans to preclude Applicants' receiving an operating or low-power test license without those deficiencies being cured. F'urther, we are struck by the similarities between l

some of the deficiencies in the CPSES plan and those cited in the Zintner case

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, where it was stated:

- "The state of offsite emergency preparedness 'does not provide reasonable assurance that adequate protective measures can and will be taken in the l -

event of a radiological emergency." (Conclusions of Law, item (6), Zihuner )

The Board should not allow Applicants to obtain an operating license based on vague, unsupported assurances that everything will magically work out all right should ,there be an accident at the Comanche Peak plant.

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1 In the Matter of The Cincinnati Gas & Electric Company, et al. (Wm. H. Zimmer .

Nuclear Power Station, Unit 1), Docket No. 50-358, June 21,1982, LBP-82-48.

pages 24 through 96. Applicants wem required as part of their License Conditions l to demonstrate that deficiencies set forth were cured prior to authorizing operation of the Station at power levels in excess of 5% of rated power.

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Further, this contention deals with an emergency plan which is supposed to protect the public health and safety in the event of an accident at Comanche Peak. This issue is too important to be decided other than in a public hearing, with the lone remaining Intervenor afforded the opportunity to pursue the deficiencies in the Comanche Peak emergency planning and help issure that the health and safety of the public is protected.

GENERAL:

One of CASE's primary and continuing concerns has been the use of " paper people" -- people who exist only on paper and wi.ll not be there physically -

when they are needed. This is still a primary concern, and there is nothing in the Applicants' current emergency planning (including th? State and County

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Plans) to alleviate this concern. Although obviously it is not necessary to identify each person by name, CASE contends that such individuals should be identified sufficiently to assure that there will indeed be someone available p

m physically and not just on paper.

Another continuing concern is that' Applicants have missed one of the basic concepts of the emergency planning as explained in NUREG-0654, Rev.1. November

. 1980 (hereinafter referred to as NUREG-0654):

"NRC and FEMA have deliberately consolidated in this document guidance intended for use by State and local governments and that intended to guide i the emergency planning and preparedness activities of NRC licensees because .

of a shared belief that an integrated approach to the development of response

plans to radiological hazards is most likely to provide the best protection

.of the health and safety of the public. NRC and FEMA recognize that plans -

of licensees, State and local governments should not be developed in a vacuum or in isolation from one another. Should an accident occur, the public can be best protected when the response by all parties is fully integrated. -

Each party involved must have a clear understanding of what the overall level of preparedness must be and what role it will play in the event of a nuclear accident. This understanding can be achieved best if there is an integrated development and evaluation of plans. There must also be an acceptance by the parties and a clear recognition of the responsibility they share _ for safeguarding public health and safety." (Emphases added.)

-- Pages 23 and 24, F. Integrated Guidance and Criteria V -

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As part of CASE's continuing concern regarding the use of " paper people,"

there is the aspect of how and by whum the costs associated with proper imple-mentation of all parties involved in emergency planning. NUREG-0654 addresses this (page 25, G. Funding and Technical Assistance):

"While funding and technical assistance are not addressed in this document, it is a subject which must be discussed between the individual nuclear l

utilities and the involved State and local governments who must prepare l emergency plans to support the nuclear facilities. The nuclear utility may have an incentive based on its own self interest as well as its re- '

sponsibility to provide electric power, to assist in providing manpower, items of equipment, or other resources that the State and local governments may need but are themselves unable to provide. The Federal Regional Assistance. .

Committees, now under the chairmanship of FEMA, .will play an increasing role in the development of these plans. Training programs for State and local

- officials fonnerly sponsored by NRC and now sponsored by FEMA will continue without interruption."

It is not clear in the Emergency Plans that such discussions regarding

! funding and technical assistance have taken place between the various parties involved, or that set policies and procedures are in place to assure that such funding and technical assistance will be available on a continuing basis. An additional concern is that, with the recent cuts in budgets and manpower, FEMA will be unable to take as large a role as was previously anticipated. This should l

be discussed and evaluated in detail in the Emergency Plans.

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NUREG-0654 states (Pages 29, J. Form and Content of Plans): .

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l- "The plan should make clear what is to be done in an emergency, how it l

is to be done and by whom."

One of the specific concerns of CASE is in regards to the fact that there is no definitive planning guide specifying Federal response. However, NUREG-0654

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"Each State and licensee shall make provisions for incorporating the Federal l

l response capability into its operation plan..."

-- Page 40, C. Emergency Response Support and Resources ,

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Another major area of concern is that adequate attention has rat been given to the fact that there are two major metropolitan ci!nters near the Comanche .

\ t Peak site. NUREG-0654 states: .'

" ...the range of possible selection for a planning basis is very large, .

starting with a zero point of mquiring no planning at all because signifi- ,

- cant offsite radiological accident consequences are unlikely to occur, to i planning for the worst possible accident, regardless of its extremely low {

likelihood...

F' "EPZs are defined as the areas for which planning is needed to assure that

/ prompt and effective actions can be taken to protect the public in the event !

@, ; of an accident... j "The choice of the size of the Emergency Planning Zones represents a judgment ],

. on the extent of detailed planning which must be perfomed to assure an adequate response base. In a particular emergency, protective actions might {

well be restricted to a small part of the planning zones. On the other q hand, for the worst possible accidents, protective actions would need to t a be taken outside the planning zones...Although the radius for the EPZ implies !

a circular area, the actual shape would depend upon the characteristics of

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a particular site." ,

-- Pages 6 and 7, 10, and 11, D. Planning Basis s

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s. o Both Applicants and the NRC Staff have consistently attempted to ignore ;

1.. the Dallas / Fort Worth metroplex area in emergency planning concepts, even though

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the Staff admitted that the pmdominant movement of storm cloud fomations in the Dallas / Fort Worth area is from the southwest to the northeast:

"CFUR has challenged the wind-rose pattern used by the Applicants to evaluate off-site re. leases, based on the predominant movement of stom-cloud fomations ,

in the Dallas-Fort Worth area. It is' correct _, as CFUR asserts, that the predominant movement of stom cloud formations in the Dallas-Fort Worth area is from the southwest to the northeast. (Markee, at 6) ." j

-- NRC Staff's 11/20/81 Answer Supporting Applicants' Motion for Sumary Disposition of Contention 9, bottom of page 9 continued

'_ on page 10 It would perhaps be helpful at this point to define what is meant by the Dallas / Fort Worth metroplex area. We can well understand that non-Texains.might not understand the precise meaning of the tem. This is a generally and widely-used term which apparently was first introduced by someone in public relations,

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v. 1 and the phrase caught on and has been absorbed into everyday usage since then.

CASE contacted the North Central Texas Council of Governments, and found ,

that the closest definition to the Dallas / Fort Worth Metroplex area is apparently ,

the Standard Metropolitan Statistical Area (SMSA), which is composed of the following Texas counties: Collin, Dallas, Denton,' Ellis, Hood, Johnson, Kaufman, Parker, Rockwall, Tarrant, and Wise. We have not updated this infonnation since our initial contact over a year ago; we would assume that, if anything, the number of people expected to reside in the metroplex area would probably be greater than that which is indicated following. We have attempted to roughly l outline this area in relation to the Comanche Peak site (see Attachment L,

- - Page 1 of 2) . As can be seen, this area is ~ roughly 6 to 110 miles from the Comanche Peak site. (CASE is not saying that the entire SMSA should be included in emergency planning for Comanche Peak, but that part of the area should be.)

As indicated in CASE Attachment L, Page 2 of 2:

"According to the 1980 Census, the Dallas / Fort Worth SMSA (2,966,342) is the largest metropolitan area in the State. It grew from 1970-80 at an annual rate of-2.3 percent per year with a numerical change of 588,719 persons or 24.8 percent change for the decade. Our (the North Central Texas Council of Government's) estimates show that the SMSA has grown by 91,708 persons or a percent increase of 3.1 percent from April 1,1980 to January 1, 1981. The cities of Dallas, Fort Worth, Arlington, Garland and Irving all show population in excess of 114,000 persons, while the combined population 7 -

of Dallas and Fort Worth represents 42.6 percent of the total SMSA population in 1981. The largest numerical increases were in the cities of Fort Worth (14,771), Plano (5,984), Arlington (5,777), Irving (4,891), Garland (4,701),

Hurst (4,251), and Carrollton (4,059) which represents 48.5 percent of the total numerical change for the SMSA from 1980-81. Several other cities, including Richardson, North Richland Hills, Denton, Addison, Grapevine, and

'Bedford, recorded an increase in excess of 2,500 each from 1980-81."

CASE contends that this large metroplex area must be considered in emergency planning to a greater extent than has been so far. Applicants and Staff have attempted to define the Emergency Planning Zones as being some sort of magical 10- and 50-mile radius from Comanche Peak, totally ignoring the fact (as admitted by the Staff) that the predominant movement of stcrm cloud formations in the 1

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Dallas-Fort Worth area is from the southwest to the northeast. This is especially ;

4 important during the spring months when thunderstorms occur more frequently.

Another major area which has been ignored in emergency planning is the ,

impact on the Dallas / Fort Worth metroplex area of refugees from the imediate area of the Coranche Peak site in the event of an ' accident. The rule of reason dictates that it could logically be assumed that in such event there would be a large influx of refugees into the Dallas / Fort Worth metroplex area. There _

is no indication that this has been considered in the emergency planning. -

There should be consideration given to, and arrangements made for, sheltering, 3 9

food, clothing, and medical care for such refugees. This has not been addressed. .

As far as CASE can tell at this time, there are no plans to even inform anyone in Dallas should there be an accident at Comanche Peak.

There_ is also no indication in the emergency plans to indicate that sufficient -

planning has been done in regar'd to the drinking water sources for the Dallas /

I' Fort Worth metroplex area in the event of an accident at Comanche Peak. This

. vitally important matter deserves much closer attention than it has been given.

CASE maintains that all segments of the public must be considered who may 4 .

be affected by accidents at CPSES, including, in the event of a worst-case acci- ,

dent or an accident with large releases of radiation or radioactive materials into the atmosp,here, the Dallas / Fort Worth metroplex area if there exists the possibility that the air currents may carry radioactive materials to the metro-plex' area.

'NUREG-0654, Appendix 4,11.0., page 4-4, states :

I "Where meteorological conditions such as dominant wind directions, warrant special consideration, an additional sub-area may need to be defined and a s_eparate estimate made for this case."

This has not been done.

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NUREG-0654, states on page 9, 0.b. Ingestion exposure pathway:

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"The principal exposure from this pathway would be from ingestion of con-taminated water or foods such as milk, fresh vegetables or aquatic foodstuffs."

Adequate consideration has not been given to the above in regard to the Dallas / Fort Worth metroplex area and the impact of, an accident at Comanche Peak i

in this regard. :

Major deficiencies exist in regard to the following: Federal agencies are not identified with sufficient specificity to be meaningful. Additionally, the Department of Agriculture is not identified. The Red Cross is not identified.

The fq110 wing should also be identified: personnel responsible for transmission of emergency information, responsible for food and water supplies, medical support personnel, security personnel, and other support personnel. , [

Further, it is not sufficient to identify people without indicating that ,

' they have been properly trained and are capable of carrying out their functions;

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there is nothing to assure that the people indicated are. going to be properly trained. There is also no documen1!ation that the number of people available.

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~will be sufficient to take care of radiological emergencies. There is no indi -

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cation that arrangements have been made to comfort and care for individuals who

.may be suffering from psychological problems and stress due to an accident at Comanche Peak.

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'It should be noted that further guidance is contained in the Federal Emergency Management Agency National Radiological Emergency Preparedness / Response Plan for Comnercial Nuclear Power Plant Accidents (the Master Plan), FEDERAL REGISTER, 12/23/80, pages 84910 through 84917. We have not quoted directly from it in this response, but it should be included as an integral part of the Board's consideration of this contention, along with NOREG-0654, Rev.1, November 1980, and 10 CFR Part 50, Appendix E.

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CASE could write a book about specific problem areas . detailed in the FEMA Master Plan and NUREG-0654 which have not been adequately addressed in emergency planning for Comanche Peak. There are some portions of nearly every area of emergency planning which has not been sufficiently dealt with in the emergency plans at this time. Many of these areas are not just concerns of CASE. We hav'e included as Attachments A through K hereto coments which were received from the NRC, DOE, the Department of Health & Human Services, U. S. Department ;

, of Agriculture, FEMA, EPA, Argonne National Laboratory, and DOT; these coments I were provided to CASE by the Texas Department of Health, by Mr. Clarence L. Born, _

Manager, Emergency Planning Program, Division of Compliance and Inspection, ..

I Bureau of Radiation Control, on August 6,1982 (see his cover letter, Attachment A hereto). We believe that a review of those coments, coupled with CASE's ;f.

coments herein, will be more than sufficient to persuade the Board that l t

t Applicants' Motion fcr Sumary Disposition of CASE's Contention 2? be denied.

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CASE is very concerned about orie aspect of these proceedings, especially h p

in regard to emergency planning. That is the usual procedure by which Applicants I t

and NRC Staff can only be cross-examined on their pre-filed direct testimony. -8

, y This means. that, in the case of emergency planning where most of the deficiencies b.

are simply that certain aspects have not been addressed at all or adequately, k

L both Applicants and Staff can possibly avoid having to deal with those specific P issues by simpl i:

ignoring them in their pre-filed direct testimony. CASE cannot D

T believe that this is the purpose of NRC regulations, and we urge the Board to k t;

take whatever steps are necessary to assure that a full and complete record is made in these proceedings,not only for the matters included in Applicants' !:

and Staff's pre-filed direct testimony but for those deficiencies which have l' f

not been addressed. '

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CASE'S ANSWERS TO APPLICANTS' STATEMENT OF MATERIAL FACTS NOT GENUINELY IN ISSUE:

1. Statement: The Comanche Peak Steam Electric Station ("CPSES") Emergency Plan identifies all state authorities having respcasibility for emergency planning.

Answer: There is nothing to indicate that an integrated approach to emergency planning has been attempted or achieved. See GENERAL coments, pages 4 and 5 especially, preceding.

There is no assurance that the number of people available will be sufficient to take care of radiological emergencies.

There is no indication that arrangements have been made to com-fort and care for individuals who may be suffering from psychologi- ,

cal problems. and stress due to an accident at Comanche Peak. .

The Red Cross is not identified; neither are personnel respon- -

sible for transmission of emergency information, for food and water supplies, medical support personnel, security personnel, and other support personnel. x There is no assurance that the people indicated are going to be properly trained or that they are fully aware of what their responsibilities will be in the event of an accident at CPSES. .

i Letter of Agreement with Texas Department of Health does not

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indicate how they are going to coordinate anything with anybody else; no indication of how it will be accomplished, no procedures, ~

etc.

, 1 There is no assurance that the people who supposedly will be .

h perfonning the functions needed to be accomplished by State

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people exist except on paper -- resulting in the possible use '

..y of " paper people".

( Letter of Agreement with Texas Department of Public Safety does not indicate how any of this will be accomplished.

The Public Health Regions functional statement is "to be developed."

It is indicated that all Bureau of Radiation Control personnel will receive training.

It is indicated that individuals will receive initial and annual ~

. retraining applicable to their duties.

It is indicated that planners will attend or have attended FEMA planning course.

It is indicated that plans will be distributed. -

Fire Protection should be covered by the State, Texas Engineering Extension Service and Forest Service. Only a few. capabilities are indicated in local plans.

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1. (continued): f Reference is made to backup capability from University of Texas and Texas A&M, but capabilities are not given. . ;.

The only discussion of verification by the DPS will be in accordance with S0Ps. S0Ps not available for review.

)f Plans for training include State hersonnel only; they do not [

indicate that any integrated planning for training has been [C done or is anticipated.

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Annex C, Texas Department of Agriculture, not received.

N Texas State Emergency Management Plan has written agreements fr

> between support organizations but does not include the use of . !j v USDA resources. h i

- Maps for recording survey and monitoring data, key land use g a

data (e.g., farming), food processing plants, and dairies, should @

start at the facility and include all of the 50 mile ingestion pathway EPZ. Up-to-date lists of the name and location of all k facilities which regularly process large amounts of food or a agricultural products (originating in the ingestion pathway EPZ, J l[

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.- but located elsewhere) should also be maintained.

A It is stated that the Texas Engineering Extension Service is I; responsible for training of fire fighting personnel, but not for 7

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- ': training of police and security personnel, Annex R is referenced in the cross reference for training of g

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personnel responsible for transmission of emergency information; j Annex R is not available as part of the plan. ,-

9 The cross reference refers to documents that are not available ,

as part of the basic radiological emergency response plan and -

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is not responsive to the criteria. j l

No listing by title of detailed procedures for step-by-step 3 implementation of the plan is included. The sections of the plan to be implemented by each procedure are not identified. j i Federal and private sector response organizations which may ?

be needed to work with State and local officials are not included.

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Sec. IV.D is cited in the cross reference for resources available '

to support Federal response. However, this section shows only the duties of the response support group and no mention is made of available resources.

Annex F,Section V.M states that the Radiological Defense Officer will provide assistance as requested to the Texas Department of Health if resources are available. This does not address the requirements of NUREG-0654-H.7 that each organization, where appropriate, shall provide for offsite radiological monitoring

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1. (continued): i equipment in the vicinity of the nuclear facility. Same comients .'

for H .10, H . ll , a nd H .12. ,

It should be clarified whether or not the county will be depended ~ I, upon to supply radiological data to the state and to the utility .

for use in assessing the magnitude of the emergency; in any event, >

it should be clarified as to precisely what duties each response i organization will .have in this regard. i

-4 Sections VIII.B.8 of Appendix 7 to Annex L of the state plan j

~i states that the Bureau of Radiation Protection will advise the :

local officials in decontamination actions, that are to be con- .

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ducted in accordance with "NCRP Report No. 65." No procedures ]

for the disposal of wastes was found. No procedures were found -

.e i in the Hood County plan for waste disposal. NCRP Report No. 65. , fOQ should be made a part of the plan if it is the appropriate pro- . .Lg cedure to be followed. .n ~Cl q

Section' III.R, Manual of Emergency Procedures, Annex 7 states ' 2; that " details and criteria for recovery and reentry "will be '

3 provided by the Texas Department of Health." However, there N is no evidence in the plan that general plans and procedures 9" '

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have been dcveloped. .

i The cross reference is marked N/A. The state plan, Sections }

XI.B and XI.D, Annex 7 addresses only state plans and changes. '

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Provisions should be made for forwarding local plans and changes i a to all responsible emergency response personnel. .

f With regard to all of the itens listed in the preceding, there 4 will be people needed to do all the things which have not been .i done or which are not yet addressed. The people (specifically) ?

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who will be doing those things should be included, along with ^

an assessment of how many people will be available, when they - >

C . will be available, etc. Where applicable, letters of agreement -

should also be included with those people. :-

l See also GENERAL cormlents, pages 4 through 10, preceding, and Attachments A through K attached hereto.

2. ' Statement: The CPSES Plan identifies all regional authorities responsible j s

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l. Answer:. It is stated that the County Judge is in charge of the Emergency >

1 Organization and directs the operations of the agencies which make -

up the individual Hood and Somervell County Emerge icy Organiza-tions. There is no letter of agreement from either of the Judges; '

F there is no indication that these individuals have been either

informed of their responsibilities or trained to do th'em.

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2. (continued):

The two letters of agreement from the Sheriff's Departments, which are basically identical in content, state that they will:

(1). " Authenticate the notification of an emergency by calling back the agency which made the initial notification." This would seem to be questionable, unless the person calling the Sheriff's Departments will be calling no one else in the meantime.

We would assume that they would be busy calling several other individuals and/or organizations. It is also not clear.how many people are available on a round-the-clock basis with each Sheriff's Department, how easy it would be to get in touch with the appro-priate people at the Department, how quickly the Department could be mobilized, etc. We believe we're dealing with " paper people" again.

The letter of agreement with the Granbury Volunteer Fire Depart-ment is being "re-negotiated and will be added to the plan when it becomes available." Therefore, it is non-existent at the present time. It is not sufficient to say that this will be done in the future. There are many unanswered questions, such as "Why was it necessary to renegotiate the letter of agreement to begin with?" "How will the apparent problem which necessi-tated the renegotiation be solved?" etc.

The Somervell County Fire Department letter of agreement contains the statement, that "The Somervell County dispatcher may verify the authenticity of the request by calling the,CPSES Control Room." There is nothing to indicate that they would get anything but a busy signal if they did. There is also nothing to indi-cate that there fire any dedicated telephone lines to assist wi th vi tal telephone communica tions in any regard. The letter also limits the assi~s tance to be given to extinguishing fires at 'CPSES and on adjacent CPSES property.

The local fire-fighting support consists of approximately 50 -

l volunteers, with one truck, which would be available in approxi-mately 30 minutes. There is no indication of how many volunteers l

could realistically be expected to show up in case of an actual radiological emergency at CPSES.

There are no specifics about training the fire-fighting support personnel.

There is no mention how the ambulances will coordinate with the hospitals or the plant site, how any emergency on-the-spot treat-ment will be administered (if any), how the ambulance drivers l

and attendants will distinguish what is a radiological injury and what protection they will have from radiological contami-nation. It is not clear how the ambulance attendants will be They will also call and get a busy signal trained or by whom. '

' from the CPSES Control Room.

l Who is going to determine who has been exposed to radiation and who hasn't? Hood can only handle 5 injured persons simultaneously

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2. (continued):

(not specified to be radiological injuries); no indication is '

given that Hood County has had any training to treat radiological injuries; it does not say how many personnel, if any, will be trained, and how they will be trained. It states that a physician shall be (in the future?) included on staff (appears to be en-tirely speculative at this time). There is nothing about capa-bilities to handle a large-scale' accident. It refers to back-up medical services from the Radiation Management Corporation and .

their affiliated hospital, but there are no provisions indicated for transportation, how much time it will take to get any assistance either on-site or at RMC's facilities at the Northwestern Memorial Hospital in Chicago, Ill . Further, since this change was just made from RMC's Pennsylvania facilities to their Chicago facilities, it is not clear whether or not the Chicago facilities are fully acquainted with what responsibilities they might have in regard .

to radiological emergencies resulting from an accident at CPSES.

It is stated that TUGC0 will provide technical assistance, radiological monitoring equipment and personnel monitoring devices necessary to evaluate the radiological condition of the patient, ;

but there is no indication of specifically who in TUGC0 can do this.

There is no letter of agreement with Marks General Hospital. '.

The letter of agrcement with Radiation Management Corporation (RMC) is completely generic. There is nothing specific about CPSES. There are no specifics as to procedures, time elements, identification of any people who will act as liason between CPSES, the county, the State, etc. and/or hospital personnel.

No personnel or procedures are identified to detennine at which point RMC will be called on if needed; there is no indication that RMC has done any site-specific evaluation of CPSES or surround-ing areas or facilities; it is never stated that an expert will .

come to the site or surrounding areas if needed; there are no provisions about how long it would take such personnel from RMC to get down to the site, what their capabilities are in terms of how many individuals they can take care of, whether or not the patients will be physically able to be transported

" to Chicago and at whose expense such transportation would occur.

The letter of agreement with Squaw Creek Park, Inc. (SCPI) does not indicate how SCPI will effect the evacuation of Squaw l .

Creek Park, how they will account for all park visitors and I

l personnel; there is not one single person or title named; there is no indication of how many people are available at any given time at SCP; no written procedures have been developed for anything yet; no brochures and emergency information is avail-able yet nor is it clear how the information will be Inade available and who will pay for it.

Provisions for early distribution of personal dosimetry devices from local sources need to be developed so that local workers

. . . ,,w... . . . . n , _;, .. , . .. ,

s ..

s- A

2. (continued):

are covered during the estinuted 4-hour deployment time at the beginning of an emergency.

Procedures should be developed for emergency workers to report dosimeter readings frequently. Additional procedures requiring notification when a worker's dose has reached a specified level should be in place. A special sdt of instructions should be available for a member of the public who must go into an exclusion area. The exposure information should be available before the individual is contaminated.

Provisions for training of local support personnel are not found [

in the local plans. .

t Section VII, Part B of the state plan describes the assignment i of accident assessment responsibilities. The county should -

state what equipment, if any, is available to measure whole body .i gamma exposures and airborne radiciodine concentrations. A :

plan for transmitting these data, if any, to the E0F should be ,-

included. ,t.

J.2. Protective Response,-of NUREG-0654, is not addressed. k The utility is primarily responsible for this, but cooperative [

arrangements for sheltering, decontamination, medical attention.

f etc. , are needed. [

p Attachment K to the llood County plan for Emergency Husbandry I

_ Procedures addresses the problem of contamination of human and ,

animal foods in an ' adequate manner for the most part. Gamma i ray and radiciodine exposures directly from the airborne plume ~

are not adequately addressed, however. The response indicated in the procedures for the Executive Group is one of ordering evacu-ation or sheltering when reconmended by the state or by the utility. .

If this is the case, the cross-reference for J.9 should include -

F a reference to Section I - The Executive Group Procedures, p t

Hood County Annex F,Section V M states that exposure control i is the function of the Texas Department of Health but that the l

l ;

county RD0 will assist as requested if resources are available.

Attachment G - Evacuation - Tab. 3 lists the contents of the list j

p for roadblock personnel. Only a TLD is to be furnished. NUREG 3 0654-K3 requires both self-reading (e.g., pocket ion dosimeter) ?

and permanent record dosimeters (e.g. , TLD). In addition, the ;

self-reading devices must have appropriate sensitivities to J permit meeting NUREG00654, K4. Each emergency worker should be provided a sensitive direct-reading dosimeter (e.g., 0-200 m Rem) plus a higher range direct-reading dosimter (e.g.,

0-20 Rem) plus a pennanent record device (e.g., TLD or film badge).

Improvements are needed in the plan to insure the availability and proper distributions of appropriate dosimeters. Section VII-B-7 of Appendix 7 to Annex L of the state plan (contamina-tion control) implies that all workers entering a contaminated

~ _

area will have dosimeters but the number available, the source 0

) . a

[ , ,t N' ..

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3 j

2. (continued):

of supply, etc., is not detailed. ,

Dose record forms need to be included in the plan and need to be distributed to emergency workers. In addition, require- .

ments need to be developed for frequent reading and timely reporting of doses to the E0Cs by the emergency workers.

The procedure for authorization of emergency workers to incur exposures in excess of PAGs needs to be clearly stated

,; in the county plan. This should clearly name the official who

- is able to authorize this action. The procedure should also -

clearly require that the decision take into account the exposure r

data from the preceding three paragraphs. .a .

Attachment H - Shelter; Monitoring and Precontamination Procedures of the Hood County plan does not specify action levels for decon-tami nation. The Tab 1, Chapter 1, Procedure 5, Part VI does [

specify action levels for initiating decontamination.

~

.,I b Supporting plans and their sources are not listed for the local ",

i > plans. The listing of supporting plans found in Tab.1, Introduc--

tion Sections III and IV,. Annex 7, state plan pertains only to '

, supporting plans for the state. ,'

The cross reference indicates that provisions for updating

' s. . , - ,

telephone numbers are in the utility emergency response plan.

They should also be included in the local plans.

,e ,

(NOTE: Most of th'e preceding applies to both Hood County and Somervell County; the referenced sections in the two county plans may vary somewhat, but the basic infonna-tion is the same.)

Annex C - Shelter Plan - is not included. .

d Annex D - Radiological defense plan - is not included.

l Annex E - Crisis Relocation Plan - is not included.

i Cross Reference for C.l.a. indicates N/A. Base plan VI, A.l.d.

and VIII, indicates County Judges or Mayors may request State, Federal or military assistance through State Disaster Districts.

Can local government request Fedt.ral or military assistance directly?

If so, it should be indicated and the proper procedures for doing so should be detailed. -

Cross reference for C.2.a. indicates this element N/A. Plan should designate local official to serve as representative of local government at the EOF (may be there if he/she so chooses).

Local government relies heavily upon State assistance for techni-cal capabilities. Local resources other than schools and local government not addressed. Letters of agreement with school

L

2. (continued):

districts may be appropriate unless school resources have been specifically comitted previously through legal instru-ments, in which case such instruments should be included.

We are unable to find maps of evacuation areas as such. There is a general lack of precise evacuation procedures in the plans.

Will instructions and procedures

including areas to be evacuated i be included in the public infonnation packages? We are unable to find maps of shelter or relocation areas.

Shelter facilities should be outside the 10 mile EPZ (Glen Rose Senior High, which is within the 10-mile zone, is listed as a shelter facility).

p Where does the temporary clothing come from if an individual's

' clothing is contaminated? This should be addressed specifically.

Local plans should indicate they will participate in appropriate training. If mutual aid pacts or reciprocal agreements exist between government entities, like training will be made available to them. Those organizations listed should indicate their intent to participate in the necessary training to qualify them for ,

response to an accident / incident at CPSES.

- The Plan doesn't say that the Emergency Management Director /

Coordinator will receive any training.

The Plan is to be reviewed each six months and revised or updated annually. While not mentioned specifically, mentions it is as'sumed this review and update process would consider any coments made as a result of exercises. This should be specifically ad-dressed and it should be indicated whro specifically will do such reviewing and updating based on coments received and that such coments will be incorporated into the plan and adopted .

if appropriate.

See also those items under Answer 1 preceding which also apply to regional authorities as well as State authorities. We have

not repeated them here.

With regard to all of the items listed in the preceding, there will be people needed to do all the things which have not been done or which are not yet addressed. The people (specifically) who will be doing those things should be included, along with an assessment of how many people will be available, when they will be available, etc. Where applicable, letters of agreement should also be included with those people.

See also GENERAL coiinnents, pages 4 through 10, preceding, and Attachments A through K attached hereto.

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1 Statement: Texas Utilities Generating Company ("TUGC0") has obtained I 3.

Letters of Agreement from Hood General Hospital, Hood County Sheriff, Hood General Ambulance Service, Somervell County

' .i

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Sheriff, Glen Rose-Somervell County Volunteer Fire Department _

4 and Rescue-Ambulance Service, Radiation Management Corporation, .I Texas Department of Health, Texas Department of Public Safety, ;

[~ U. S. Department of Energy, and Squaw Creek Park, Inc. regard- J.

t ing warning and evacuation of the public and conduct of opera- . .

(

j .

tions in the event of an emergenc#y at CPSES. .: 3

.r 4

(; -

~

Answer: See Answer 2 preceding: Page 14, paragraph 1; paragraph 2;.

.I paragraph 3, 4 and 5; paragraphs 6 and 7; Page 15, 3rd full t-L,,.e ,' paragraph; 4th paragraph; for comments regarding Hood Cc. ty . c .. . - }

W ..y,$ _ and Somervell County Sheriff's letters of agreement, Granbury N.l

' e .. . Volunteer Fire Department letter of agreement, Somervell County". . -

I. ,

9; MS Fire Department letter of agreement, Radiation Management -

W8. 2 . MJ g.%, Corporation letter of agreement, and Squaw Creek Park, Inc.. i.[' .

J.

i b;"; letter of agreement. Also, see Answer 1 preceding: Page ll,- WP@^

C460 paragraph 6; page.ll, paragraph 8; page 11, paragraph 10; for '

'a?

f."dgy, coments regarding Texas Department of Health letter of agree- v1.J <

_j p j p g - ment, Texas Department of Public Safety letter of agreement, , q.y Bureau of Radiation Control. Also Answer 2, page 14, bottom , ,3y f -

7

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. paragraph continued on top of page 15, regarding Hood General . . . . W .p'i 7 M yA y ?. ( ? Hospital letter of agreement. -

.; ws-L. Mi See also other portions of Answers 1 and 2 preceeding which ' ' di :~,I l- ?% are also applicable in many cases to this answer.

repeated them here.

We have .notn & ;-

iY -

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M;. ,', 4

' .-# ' 'S . With regard to all of the items listed by Applicants in their 't i N A. " statement of item 3, it is not clear that the individuals and . -i p..'.%* organizations involved have been made fully aware of'the in- - . .a <

F,,, fonnation contained iri NUREG-0654 and other applicable regu- 3;'

[J3 -

1atory documents, that they are willing to participate in' pro- .

, per training, that they know exactly what their responsibilities will be and that they are capable and willing to perform those

.; ni . <j , y

~ U ' g' . responsibilities and duties; there needs to be further clari- 2

~*: fication of specifically who will be doing each thing, an . -

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H" assessment of how many people will be available at specified v . Y. .;f b '-

times, when and how often they will be available, etc. This- -

should be clarified in each letter of agreement. .; ]

See also GENERAL comments, pages 4 through 10, preceding, ,i;z 3[

. ,. e. and Attachments A through K attached hereto. ^ ;_ M c.

I' .

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..4. Statement: Letters of Agreement obtained by TUGC0 identify the principal officials responsible for warning and evacuation by title and .' !

agency. . .

. . .j Answer: See Answer 3 preceding, especially the third, fourth, andi 'q fifth paragraphs. - -;

5. Statement: A Letter of Agreement with the Granbury Volunteer Fire Depart- '

ment is being renegotiated and will be included in the CPSES -

Emergency Plan when available.

F

s

5. { continued):

Answer: It is not sufficient to state that the above-referenced Letter of Agreement "is being renegotiated and will be included" at some nebulous later date. It should be ascertained why the letter had to be renegotiated to begin with, what the problem was to begin with and whether or not sufficient detailed information is or will be available to assure that regulatory requirements will be met in this regard. +

Further, if and when this Letter of Agreement is executed, it should be stated clearly that the individuals and organi-zations involved have been made fully aware of the information contained in NUREG-0654 and other applicable regulatory documents, that they are willing to participate in proper train ~ing, that they know exactly what their responsibilities will be and that they are capable and willing to perform those responsibilities and duties. There should also be spelled out with some speci-ficity who will be doing each thing, an assessment of now many

- people will be available at specified times, when and how often they will be available, etc. :

This Letter is non-existent at the present time.

6. Statement: Sections 1.3.1.3. ,1 :3.1.4. , and 10.0 of the CPSES Emergency Plan describe arrangements for medical support, including the

services of physicians qualified to handle radiation emergencies '

and arrangements for transportation of injured or contaminated

,i individuals beyond the site boundary. These arrangements are further described in the Letters of Agreement between TUGC0 and L Hood General Hos'pital, Hood General Ambulance Service, Glen Rose-Somervell County Volunteer Fire Department and Rescue -

i; Ambulance Service, and Radiation Management Corporation.

V Answer: See Answer 3 preceding. See' also Answer 1: page 11, paragraphs - '

h.

~

1, 2, 3, 4, 5, 7,11,12,13; page 12, paragraphs 1, 3, 8,11 -

13; page 13, paragraphs 1, 2, 3, 4.

7. Statement: The CPSES Emergency Plan adequately describes plans for testing

' of emergency plans by annual exercises and periodic drills.

Answer':

Reference to the NRC rules are not included in the State plan 2

(as set forth in NUREG-0654, page 71, N. Exercises and Drills, 1

1.a.).

Provision for medical emergency drills could not be located i

in the local plans.

i L'

The State plan does not provide for radiological monitoring drills.

Scenario development should include the infonnation contained i-in NUREG-0654, pages 73 and 74, N.3.a, b, c, e, and f.

1

,Although references to Federal response are made in several locations throughout the plan, there is no definitive planning

.. m

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7

7. (continued):

guide specifying Federal response. NUREG-0654 directs that planning for Federal response be included even though there is no intention on the part of the State to include such resources in the emergency response resource requirements.

There is no reference to unannounced exercises, although i't is indicated that such exercises'will be in accordance with FEMA requirements. The plan does not specifically address exercise objectives and evaluation. It is asserted that drills over and above those conducted during annual exercises are not necessary, since the staff perform such activities routinely.

This may be true at present, but the situation could change.

in the future. It should be specified that additional drills would be carried out if exercise debriefing or critiques should -

indicate this need. Additional drills may also be appropriate as staff assignments are changed, new equipment is acquired, or new procedures are instituted. ,

The State plan identifies only the American Red Cross as private: ,

sector response organizations, although universities and labora- -

tories are given response assignments. _'

No mention is made of provisions for starting exercises between 6:00 p.m. and midnight and between midnight and 6:00 a.m.

The dates, tiomes, places for exercises and drills are not '

mentioned in the State plan. {, 7 _

No time schedule of events is included in the plans. ;

l , No exercises or drills including such things as simulated

i casualties, off site fire department assistance, rescue of l personnel, etc. are mentioned.

A description of the arrangements for and advance materials to be provided for official observers is not included in the sections covering Exercises and Drills.

(NOTE: Most of the preceding items which apply to Somervell County also apply to Hood County.)

The cross reference cites the utility emergency plan, but l

l I the state plan makes some of the exercises and drills the respon-sibility of the utility, the Bureau of Emergency Management, and the Bureau of Radiation Control. There is no evidence in the local plan that local organizations receive training or par-i ticipate in exercises and drills or that training programs for local emergency response personnel have been developed. These coments apply to each item in NUREG Section N. Exercises and Drills, Planning Standard, pages 71 through 74.

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7. (continued):

The cross reference cites the Manual of Emergency Procedures, Sec. IV, Part IV, A, pages 118 and 119 as providing informa-tion for transients. However, the information contained therein "

is specifically for residents. These sections should also con-tain detailed information for transients.

See also those items under Answers 1 and 2 preceding which also apply in part to this item. We have not repeated them here. '

With regard to all of the items listed in the preceding, there .;

should be an identification (specifically) of the people who will be doing those things which need to be done, along with an assessment of how many people will be available, when they 1 will be available, etc. Where applicable, 'c.tters of agreement

~

should also be included for those people. 'j l

See also GENERAL comments, pages 4 through 10, preceding, and (

Attachment A through K attached hereto. j i)

Statement: The CPSES Emergency Plan provides for participation of state

. 8.

and local emergency authorities in emergency drills and exercises.

Participation of state and local authorities is described in

, Letters of Agreement with the responsible agencies.

Answer: See Answer 7 preceding.

9. Statement: Arrangements for medical support include the immediate vicinity of the site and the City of Glen Rose.

l Answer: See Answer 1 preceding: page ll .. paragraphs 1, 2, 3, 4, 5,

! 6, 7, 8, 9,10,11,12,13; page 12, paragraphs 1, 3, 6, 8, ,

l 9,10,11,12; page 13, paragraphs 1, 2, 4, 5 and 6.

10. Statement: The City of Glen Rose-Somervell County Emergency Operations

Plan, Fixed Nuclear Facility Response Plan, and Manual of

! Procedure for incidents Involving the Comanche Peak Steam Electric Station provide for emergency planning in the City l

of Glen Rose.

Answer: See Answer 9 preceding.

l 11. Statement: The Dallas / Fort Worth Metroplex lies outside the ten-mile plume exposure pathway emergency planning zone ("EPZ").

! Answer: This statement is incorrect. Some portions of the Dallas / Fort Worth Metroplex lie outside the ten-mile exposure pathway emergency planning zone ("EPZ"). However, some portions lie wit'hin the EPZ as identified in NUREG-0654, Rev.1. Further, Applicants '

and Staff's interpretation of what is meant by the EPZs is f

not' consistent with what is stated in the regulations (see

t N

11. (continued):

GENERAL, pages 6 through 9 for specific details); their in-terpretation ignores key factors which should be considered in determining the size and shape of the EPZs. ,

12. Statement: Much of Tarrant County and a small portion of Dallas County lie within the fifty-mile Ingest, ion Exposure Pathway EPZ.

Answer: This statement is true in part: Much of Tarrant County does lie within the fifty-mile Ingestion Exposure Pathway EPZ.

The remaining portion of the statement, however (that "a small portion of Dallas County" lies within the fifty-mile ingestion Exposure Pathway EPZ), is too broad and lacks speci- '

ficity to the point of being meaningless. ,

Dear Mrs. Ellis:

In response to your telephone request today, enclosed please find the following documents:

Item: Texas State Emergency Management Plan of 1982 Item: Texas Department of Health's Annex L to the State Plan Item: The Bureau of Radiation Control's Appendix 7 to Annex L (Including Tab 1; Fixed Nuclear Facility Response)

Item: Local Emergency Management Plans for Hood and Somervell Counties Item: Cross Reference of the above cited documents to NUREG-0654, Rev. 1 Item: Copies of the comments of each reviewing agency on the Regional Assistance Committee concerning the contents of the above documents Please be aware that the local plans for Hood and Somervell Counties are the responsibility of the County Judges of the respective countius, and are not a part of the Texas State Emergency Management Plan. Questions concerning those local plans should be directed to the appropriate local official.

Additionally, please be aware that the first four items listed above are only a part of the Texas State Emergency Management Plan. As was stated in the letter of transmittal to FEMA, and explained in person to members of the RAC (Regional Assistance Committee) on June 17th, "Other annexes to the State Plan, along with supporting documentation are on file in the offices of the Division of Emergency Management, and are available for inspection upon request." Because those other annexes constitute a large volume of material, and because they contain information not directly ' germane to radiological emergency response, they were not submitted for review, but are available for your inspection in the offices of the respective State Agencies.

Sincerely, Clarence L. Born, Manager Emergency Planning Program Division of Compliance and Inspection Bureau of Radiation Control

l

[* ""*"*4 UNIT 13 STATt3 g

'O .' NUCtEAR RECULATORY COMMl2SION / I l 3

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! REGION IV Attachment B-1 " W3

s. Ett RYAN PLAZA DRIVE. SulTE 1000 -9 ,

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4

ARUNGToN. TEXAS 74011 **

July 29, 1982 (c.:L T

Al Lookabaugh, Chairman Regional Assistance Committee Federal Emergency Management Agency Region VI Federal Center Denton, Texas 76201

Dear Mr. Lockabaugh:

The following are my comments on the iexas Emergency Management Plan which was submitted to our office for review on June 17, 1982.

Each of the planning element criteria from NUREG-0654 that are assigned to the NRC are listed below followed by the appropriate comment.

! Element C.1.a

The Governor is authorized to request federal assistance,using his disaster declaration authority. The Disaster Response Program Director is designated to coordinate specific requests to the various federal agencies having radiological emergency response capability.

Element C.2.a Provisions are made to dispatch a representative to the licensee's E0F.

l Element C.3 Radiological laboratories are adequately described, however, I could not locate information describing the expected availability during an emergency.

Element D.3 The emergency classification and action level scheme is consistent with that established by the facility licensee.

Element E.1 l Notification and verification procedures are established and are consistent with the emergency classification and action level scheme.

l l .

2 Attachment B-2 s

Element E.2 Alerting and notifying personnel is adequately described but procedures for actually mobilizing emergency personnel are not. Procedures for assembling and briefing field tei.ms at the Bureau Office (or elsewhere) l should be described.

! In the Accident Notification Sequence (Attachment 6 to Appendix 7, page 29),

it appears that considerable time could elapse before the Bureau of Radiation Control is notified (i.e., it appears that 5 agencies are notified before the Bureau). However, it is noted that arrows on the sequence show an " alternate channel of notification". What does this meanir Is the notification of BRC timely?

Element E.6 The local government is responsible for notifying and providing the l prompt instructions. Procedures for this are adequately described in the l local plans.

Element F.1.d l

Communication procedures are adequately described in the Hood County plan for local officials. However, a description of State communication -

procedures could not be located. There should also be a description of

, communication procedures for the field monitoring teams.

Clemer.t G.3.a Points of contact and physical locations have been designated in both State and local plans.

l Element G.4.a

' The local plan designates specific spokespersons by title, but the State plan refers only to " bureau personnel assigned this function." Who are the persons (titles) assigned to coordinate public and news media information?

Element H.3 Emergency operation centers are described in state and county plans.

Element H.4 Timely activation and staffing of EOC.'s is provided for in the plans.

l I

y. . :.

3 Attachment B-3 s.

Element H.7 Offsite radiological monitoring equipment is briefly described but no listing or specific description is given. A list of all monitoring equipment giving make and model number, radiation detected, range and other descriptive information should be included (i.e., such lists are given for backup labs like the UT TRIGA facility).

Element H.10 The State plan calls for semi-annual calibration of instruments. Instrument reserve capability cannot be determined without an inventory list.

Element H.11 Emergency kits are adequately described.

Element H.12 A central collection and analysis point for radiological samples is established by the plan.

Element I.7 Field monitoring in the plume exposure pathway is adequately described.

Element I.8 The plan only partially addresses this element. The USEPA " Manual of Protective Action Guides and Protective Actions for Nuclear Accidents" is referenced, but the plan contains no specific information regarding procedures to be used by the Bureau of Radiation Control . For example, there should be information on computer, or calculator programs (if used),

isopleths, recording data supplied by the, licensee, use of meteorological data, and any deviations from EPA procedures that may be used. Also, no information i provided regarding team communications or estimated deployment times. .

Element I.9 l

Specific information concerning radioiodine monitoring could not be located in the plan.

Element I.10 According to the State plan, dose estimates for the key isotopes can be made based on actual and projected dose rates and EPA protective action guides would be used.

l I

- l 4 Attachment B-4 s

Element J.10.m The basis for the choice of recommended protective actions are given.

Element K.3.a Twenty-four hour capability is provided for. Dosimeter distribution is provided for.

Element K.3.b t

The reading of dosimeters is included in the plan and dose records will be kept according to written procedures in the plan.

Element K.S.a Decontamination action levels are specified.

Element K.S.b -

Decontamination procedures are thoroughly described in the State plan.

Element L.1

' The local plans describe the general capabilities of the county hospitals. However, a list of supporting hospitals was being developed i and was not yet included in plans.

l l ElementLL.3 The hospital list is under development.

Element L.4 Procedures for medical transportation to medical support facilities could not be located in the plan.

Element N.1.a Exercises are provided for and will be conducted ". . . in accordance with requirements identified by the Federal Emergency Management Agency."

(Tab 1: FNF Response, Introduction, Attachment 4-4). Reference to the "NRC rules" mentioned in Element N.1.a are not included in the State plan.

. Element N.1.a l

Communication drills are adequately provided for.

5 Attachment B-5 b -

Element N.2.c Provision for medical emergency drills could not be located in the local plans.

Element N.2.d The State plan does not provide for radiological monitoring drills. The plan states that Bureau personnel routinely perform radiological monitoring and therefore do not need an annual drill.

The value of such a drill is to provide monitoring teams the opportunity to practice in the environment surrounding the nuclear facility. For this

, reason, an annual drill is recommended.

Element N.2.e(1)

Health physics drills are. adequately provided for in the State plan.

Elements N.3.a b, c, e, and f Scenario development is to include the information contained in these elements.

Element N.4 5

Exercise critiques are provided for in the State plan.

Element N.5 Evaluation of obeserver comments and management control over p1a' n revision and corrective. comments is provided for.

. Elements 0.4.a. b, c, d, and f Training programs are described in the State and local plans.

Element P.4 Plan updating is provided for.

Element P.6 The plans contain a detailed listing of supporting plans and their source.

Element P.7 Implementing procedures are included.

6 Attachment B-6 s

l J

This concludes my comments on the Texas Emergency Management Plan. If you have questions or need additional information, please contact this efficy .

Sincerely, c M

James L. Montgomery Regional State Liaison Officer e-a l

J TWh 0

l

'M Attachment C

" ~

Department of Energy Albuquerque Operations Office 2ud P.O. Box 5400 R 2 2 G82 Albuquerque, New Mexico 87115 July 20, 1982 Al Lookabaugh, Chairman, FEMA VI Regional Assistance Committee Federal Emergency Management Agency, Region VI Federal Center '

Denton, TX 76201 .

Dear Mr. Lookabaugh:

As requested by your letter of June 18, 1982, subject, Review of State and Local Plans for Comanche Peak, we have reviewed the subject documents.

In general we find the plans adequately meet the criteria established by NUREG-0654, FEMA-REP-1, Rev. 1. The plans are complete and in depth, both for State and Local agencies.

However, one general comment is offered for consideration by the State.

Although references to Federal response are made in several locations throughouc the plan, there is no definitive planning guide specifying Federal response. NUREG-0654 directs that planning for Federal response be included even though there is no intention on the part of the State to include such resources in the emergency response resource requirements. In the event of an incident at any fixed nuclear facility in the State which affects the offsite area, Federal response will be in evidence without planning. We believe planning should be included to cover such an exigency.

Sincerely, b

Ja R ed r Director Operational Safet, Division 1

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.NIEM' ORANDUM* ^"a *"* at od DEPART.'etENT C2 hI. .lTH *:. HUM AN S22Vic;3

?t;:::.:c aI.u H 51.tVICE FC00 4mD 081.4 (Casl A45 3ATC*

To Al Lookabaugh, Chaiman . July 16, 1982 Regional Assistance Committee

FEMA, Region VI, Federal Center Denton, Texas 76201 ,

FROM ~

(UdY Litsey L.Zellner, RRHR Region VI [j']

.v J{ l g gg.7 -

sunja:T*-

niew te exas Emergency k nagement Plan, Annex L, Appendix 7, Hood and Somervell Counties -

f

u. % &

Comments on the above subject plan are attached.

Enclosure a/c Ge l

v - .

. ATTACHMENT

. Attachment D-2 7

' ~

A.2.a. This section is covered in Annex L, Pages 5-14 and Appendix 7, Pages 7-17 and State Plan. Fire Protection should be covered by the State, Texas Engineering Extension Service and Forest Service. Only a few capabilities in local plan.

A.2.b. This section is covered in State Plan, Page 2, Annex L, Page 1, Appendix 7, Page 1, and local plans - Page 1.

C.2.a. This capability discussed in Tab 1, Ch. 1,Section V.C 1 and 6 (Pages 6 and 8).

C.3. In Tab 1, Ch.1,Section V.c.5 (Page 7) describes the Bureau of Radiation Control's Mobile Lab capability. Tab 1,Section VII I, Page 8, refers to backup capability from University of Texas and Texas A&M, but does not give capabilities.

C.4. The first outside assistance will be requested from the Southern Mutual Radiation Assistance Plan and then from the Federal Govern-ment.

D.J. Emergency classification for State in Tab 1, Ch.1, Sec' tion III, Page 3, locals on Pages 48-50 and 49-51.

E.1. The only discussion of verification, Tab 1, Page 19, by the D.P.S.

will be in accordance with SOPS. SOPS not available for review.

Local plans provide for verification on Pages 147, 148, 158, and 159.

E.2. Procedures for alerting emergency personnel are addr'essed in the State Plan, Annex L, Appendix 7, Hood County and Somervell County.

E.7. This is included in local plans only ch Pages 156-158, 227-231 and 167-168, 237-239.

l G.I. This section is included in local plans only, Pages 117-118, 128 l

and 129.

H.12. A sample coordination team of two individuals will be located at near-site, Emergency Operations Facility, Tab 1, Ch. 1, Pages 7-8.

I.10. This is established in Tab 1, Ch. 1, Procedure 1.

J.9. The state and Counties have capabilities for implementing protective measures. The Department of Agriculture Plan and Department of Healths, Appendices 2 and 9 to Annex L were not available for review.

J.10.e. K.I. use will be recoc= ended for emergency workers and institutionalized persons. The quantity of K.I. and the distribution are not provided ,

for in the plans. ,

J.10.f. K.I. will not be administered to the general population and the predetermined use for workers are identified in the FACs.

,, .v.. .

8.ttachment D-3 J.10.a. Tha b: sis for tha choics of recommsndsd protective actions are in the States', Tab 1, Ch., 1, Procedure 1. There was no reference to the protection afforded by the shelters for direct and inhala-tion exposures and no evacuation time estimates.

J.11. Procedures for detecting contamination, estimating dose commit-ment and protection procedures are in Procedure 1.

Did not see any land use maps, detailed crop information maps

~

and maps of food processing facilities that process and products in the 50 miles EPZ. The Tab 1: Introduction, Page 7, states that the responsibility for maps used for recording survey and monito-ring data and key land use data, will be with the Department of Agriculture.

j M.l. This criteria not discussed as to general plans and procedures ~

for reentry and to describe means by which decisions to relax protective measures are reached. There should be general plans that -

include what levels of exposure would be acceptable from ingestion and/or inhalation pathways. It should also include the potential conditions of buildup of contamination in the food pathways or the transfer of contamination, i.e., drainage from land into potable water supplies.

M.4. This is discussed in Procedure 1. (Pages 1-20).

N.1.a.

Exercises discussed in Tab 1, Introduction, Pages 18 and 19.

, N.2.d. The discussion in Tab 1, Introduction, Page 20, states that Radiological Monitoring Drills will not be conducted in addition to the annual exercise.

N.2.e.l. This is discusse'd in Tab 1, Introduction', Page 20.

N.4. This criteria for observers is discussed in Tab 1, Introduction, l Page 19.

N.5. In Tab 1, Introduction, Page 19, states that observers will be from Federal Agencies; Texas, Arkansas, Louisiana and Mississippi.

S.I. The plans for training include State Personnel only.

i kO

(

l l

e

Attachment E-1

. 2 . United Stat: s Food Sif;ty Offica of Emerg;ncy Plcnning Department of and Inspection cud D fcn23 Mobilizction 4'

Agncultura Servic) 6525 Balersst Rd.. Pa. 853 Hyattsville, MD 20782 b

July 21, 1982 ,

- ~ E' d ,1. .-

Mr. Al Lookabaugh RAC Chairperson . _

.' , (1(2 Federal Emergency Management Agency Region VI Federal Center Denton, Texas 76201

Dear Mr. Lookabaugh:

' The United States Department of Agriculture (USDA) has reviewed the State Emergency Management Plans for the State of Texas and the counties of Hood and Somervell. The principal focal point of this review was directed to radiological emergency preparedness.

We have evaluated the elements and responsibilities relating to USDA and have enclosed our detailed comments.

The State assigned Annex C to the Texas Department of Agriculture for development and maintenance. Annex C was not received by this office. We would appreciate your sending us a copy, if it is avail-able. '

If you have any questions, please feel free to call Mr. Robert Conley or Ms. Dorothy Nevitt of my ' staff on FTS 436-8051.

Sincerely,

. }George n,?.E. Bickerton,4 Director Office of Emergency Planning and Defense Mobilization Enclosure cc:

Charles W. Mayfield, Chairperson USDA State Emergency Board State ASCS Office, USDA, USDA Bldg.

Texas A & M University College Station, Texas 77840 t

l

Attachment E-2 United States Departmtnt of Agricultura Food Safety end Insp:ction Service b -

Washington, D.C.

Evaluation of Radiological Emergency Response Plan State Texas Counties Hood and Somervell Facilities Cemanche Peak Nuclear Power Station Elements Comments A.2.a. , The United States Department of Agriculture (USDA) has established in every State and Assignment of Responsibility County a disaster assistance network.

(Organization Control) All USDA agencies having major emergency responsibilities are represented on the various USDA State and County Emergency Boards and the USDA Regional Emergency Staffs. These boards / staffs are an integral part of the USDA network.

This network can react to emergency situations, including radiological accidents /

i .

. incidents, by utilizing USDA resources to j provide assistance / support as needed and l

requested by the State.

l The primary USDA contact for the State of Texas is:

Charles W. Mayfield Chairperson, USDA State Emergency Board State ASCS Office, USDA, USDA Bldg.

Texas A & M University College Station, Texas 77840 l (713 - 846-8821, Extension 207)

.e 6

. . 1

--s, .

Attachment E-3 Unitcd Statss DeptetmInt of Agricultura Food Safety cnd Inspiccion S3rvice Washington, D.C.

b -

Evaluation of Radiological Emergency Response Plan State Texas .

Counties Hood and Somervell Facilities Comanche Peak Nuclear Power Station Element s Comments A.3 The Texas State Emergency Management Plan has written agreements between support Assignment of Responsibility organizations but does not include the use of USDA resources. Annex C, assigned to the Texas Department of Agriculture, was not received for review by this office.

. A request for USDA services would include the use of the USDA State Emergency Board (SEB), the County Emergency Board (CEB) and the Agricultural Extension Agents to notify farmers in the event of a nuclear

.c accident. The SEB is composed of the .

following agencies: The Agricultural Stabilization and Conservation Service (ASCS), the Statistical Reporting Service (SRS), the Soil Conservation Service (SCS),

the Food Safety and Inspection Service (FSIS), the Forest Service (FS), the Animal and Plant Health Inspection Service (APHIS), the Food and Nutrition Service (FNS), the Cnoperative Extension Service (CES), the Farmers Home Administration (FmHA), and the Rural Electrification Administration (REA). The efforts of these organizations in providing services are directed and coordinated by the Chair-person of the SEB.

The counties of Hood and Somervell have assigned to the USDA County Emergency Board (CEB) the development of Standard Operating Procedures for Husbandry Activities.

2 .

Attachment E-4 Unitcd Statso Departmznt of Agricultura Food Safety and Inspection Service

, Washington, D.C.

Evaluation of Radiological Duergency Response Plan State Texas Counties Hood and Somervell Facilities Comanche Peak Nuclear Power Station I

Elements Comments E.1 The State plan has established procedures for notification of State emergency Notification Methods personnel and the Federal Emergency and Procedures Management Agency.

The initial USDA contact would be the

USDA State Emergency Board Chairperson, Mr. Charles W. Mayfield, (713 - 846-8821, Extension 207).

The counties of Hood and Somervell have established contact with the USDA County

. Emergency Board. Emergency information.

will be disseminated to all affected farmers and other agricultural industries through the County Emergency Boards.

te 3 .

G- - -

. Attachment E-5 United Sectas Departm2nt of Agricultura Food Safety and ' Inspection Service

[, Washington, D.C.

Evaluation of Radiological Emergency Response Plan State Texas Counties Hood and Somervell Facilities Comanche Peak Nuclear Power Station' Elements Comments F.3 The State plan does include instructions for monthly testing of the emergency Emergency Communications communications system. The USDA portion would begin with the Texas Department of Agriculture notifying the USDA State Emergency Board Chairperson, Mr. Charles W. Mayfield, College Station, Texas, (713 - 846-8821, Extension 207).

s l

[

l l

4 .

Attachment E-6 Unitzd States D;pertmant of Agricultura Fcod Safety and Insp2ction S2rvice Washington, D.C.

6 Evaluation of Radiological Emergency Response Plan State Texas Counties Hood and Somervell Facilities Comanche Peak Nuclear Power Station Elements Comments 1 , .

C.1 The plans do provide for the dissemination of information to the public regarding Public Education how they will be notified and what actions and Information should be taken in an emergency as part of the public information program.

At the request of the State, the USDA County l

Emergency Board will assist in the appro-priate protective actions that will be direc~ed to affected farmers and other agribusinesses in the EPZ.

When requested by the State, the USDA State Emergency Board will aid recovery l efforts by providing economic assistance i

from regular Federal Assistance programs.

Cost share financing may be available to farmers and other rural residents in rehabilitation efforts; dairy farmers will be indemnified for milk removed from comeercial channels; loans and other I assistance may be provided to farmers, I

ranchers, agricultural and other rural

~

residents. Other assistance will be available from regular USDA programs as necessary. Assessment of damage to crops and livestock will be performed by the SEB

, through the County Emergency Boards (CEB).

The CEB's will estimate damage based on radiological contamination and monitoring data. Damage reports will be made to the USDA SEB for consideration in emergency relief programs.

l l

5 l

Attachment E-7 United Steccs Depcrts:nt of Agricultura Feod Safaty end ,Inspretien Sarvice Washington, D.C.

s Evaluation of Radiological Emergency Response Plan State Texas Counties Hood and Somervell Facilities Comanche Peak Nuclear Power Station Elements Comments J.ll The plans do include the protective measures to be used for protecting the Protective Responses public from the consumption of contaminated foodstuffs.

The State plan assigns to the Texas Department of Agriculture the development and maintenance of maps for recording survey and monitoring data, key land use data (e.g. , f arming) , food processing plants, and dairies. The maps should start at the facility and include all of the 50

> mile ingestion pathway EPZ. Up-to-date lists of the name and location of all facilities shich regularly process large amounts of food or agricultural products (originating in the ingestion pathway EPZ, but located elsewhere) should also be maintained. A listing of these maps stating their availability, location, and plans for their use would be sufficient.

Annex C of the plan which is assigned to the Texas Department of Agriculture was not received for review.

The counties of Hood and Somervell have assigned the development and maintenance of agricultural protective responses to the USDA Coun y Emergency Board.

O e

6 l

1

Attachment E-8 Unitcd Sectes Dsptremsnt of Agricuiture Fcod Safety 'end Inspection S2rvice Washington, D.C.

s Evaluation of Radiological Emergency Response Plan State Texas Counties Hood and Somervell Facilities Comanche Peak Nuclear Power Station Elements Comments l

N.4 The plans do include instructions for the required exercises, drills and Exercises cnd Drills critique by qualified observers from the State, Federal and local governments.

A USDA designated representative will attend the exercises.

We suggest the alert procedures for USDA be included as follows: The Chairpersen of the USDA State Emergency Board in College Station, Te:. us, (713 - 846-8821, Extension 207) should be contacted.

I J

l t k

7

M

" FEMA rovicw of Texcs REP Plans Attachnent F-1 STATE OF TEXAS EMERGENCY MANAGEMENT PLAN

' TEXAS DEPARTMENT OF HEALTH, ANNEX L BUREAU OF RADIATION CONTROL, APPENDIX 7 (RADIOLOGICAL EMERGENCY RESPONSE TAB 1: FIXED NUCLEAR FACILITY ACCIDENTS CHAPTER 1: COMANCHE PEAK STEAM ELECTRIC STATION PROCEDURES (IMPLEMENTING OR STANDARD OPERATING)

GENERAL:

Plan is well organized with an excellent cross-reference to NUREG-0654. Both the planning and operating concept for the state of Texas are easily identified and portrayed as one in which Radio-logical Emeegency Preparedness is treated as another potential i

l emergency situation with assigned responsibilities being accomp-

&ished in the same manner as they would for any other emergency.

SPECIFIC: (NUREG-0654 criteria)

A. ASSIGNMENT OF RESPONSIBILITY 1.a. The State of Texas Emergency Management plans adequately identify State, Local Federal and Utility response organ-izations. (State Plan p.5 and pp. 1-2-3 of tab 1 to appendix 7) 0.K.

b. At the State level the Bureau of Radiation Control is organized into 3 operational divisions ~on a day-to-day basis and into 3 elements for emergencies. (p. 4, appendix 7) >

O.K.

c. State Department assijnment of responsibilities for radiological emergency response illustrated in block diagram. (p.25 attachment 2 to appendix 7) 0.K.

d. The Director of the Division of Emergency Management as Chairman of the Emergency Management Council has

) overall control. He is advised appropriately,by other state agencies. For radiological emergencies in descend-ing order he would be advised by the Commissioner of Health, theChief of the Bureau of Radiation Control and the Chief of Field Operations.

O.K.

e. Receipt of warning of or actual emergency conditions exists on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months basis both at the district and state level of the Disaster Emergency Management offices. Re-sponse would be initiated at the Public Health Region or State level of response, determined by the Director.

Division of Compliance and Inspection.

O.K.

2.a. Within the state plan, primary and support responsibilities for major elements are shown by table. (Annex L)

Functions functions a and responsibilities defined. (Appendix 7 lists function.) nd title of responsible individual for each

. Attachment F-2 Assignmant of responsibility cont'd 5 -

b. State Emergency Management Plan, Annex L, Appendix 7 all list legal basis for authorities.

O . F. .

3. State plan has signature page for state agencies.

American Red Cross functional statement included.

(Annex L) Tab 1 to Appendix 7 has responsibilities of other state departments and utility listed.

Written agreements with U.T. Austin and Texas A&M.

O.K.

4. State plan. Capability of_ Health Department contained in annex L. State EOC (DPS/DEM) capability for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day operations noted. Appendix 7 under Logistics Support, Emergency Recall Procedures and Supervisory responsibility assignments by individual O.K. (NOTE CORRECTION TO CROSS-REFERENCE OF APPENDIX 7)

3. ONSITE EMERGENCY ORGANIZATION

2. While 0654 does not indicate nor require that this ele-ment should be addressed by State / Local governments you may wish to consider noting the individual (by title) at the licensees facility who is responsible for initiating emergency actions, including recommendations regarding pootective actions to 6ffsite authorities.

C. EMERGENCY RESPONSE SUPPORT AND RESOURCES 2.a. State response. team will consist of a utility liaison team (three, 1-man shifts) which will be deployed to the near-site' EOF.

O.K.

4. SMARAP listed as first option for outside assistance.

Note also that laboratory facilities at U.T. Austin add TEXAS A&M have agreed to prohide assistance.

Letters of agreement and cppabilities included.

O.K.

D. EMERGENCY CLASSIFICATION SYSTEM

3. S State classification scheme is consistent withFederal Guidance and that of the utility.

O.K.

4. State response levels are appropriate and consisten with the ttility's and 0654 warning classification.

O.K.

E. NOTIFICATION METHODS AND PROCEDURES

1. Bases for notification consistent with 0654, appendix 1.

Verification Procedures will be employed.

O.K.

I

.

Attachment F-3 NOTIFICATION METHODS AND PROCEDURES cont'd 6 - 2 State Plan. Each state department designates three individuals to be contacted in time of emergency.

Within DCH, the Director of Disaster Response has Regional and Bureau Chiefs telephone numbers who in turn have designated 3 - 5 individuals for contact.

Appen'ix 7 indicates once the Bureau of Radiation C Control receives notification it is passed to the Director, Division of C & I descending to 3 branch administrators. Attachment 5 indicates recall procedures by name and telephone number. (See also appendix 7, VI B, " Organization for Emergencies" for mobilization of emergency response personnel.

O.K.

3. Appendix 7 only.- Referenced part of plan is a sample message foddwhich includes those objectives addressed in..the 0654. element.

O.K.

5. This item to be addressed by local plans and normal DPS procedures (Annex R) to be followed.

O.K. '

6. Responsibility assumed by local government and DPS.

(Annex R)

OK.

7. Local governmedt responsibility. Bureau of Radiation Control will advise local government re:-protective measures.

O.K.

F. EMERGENCY COMMUNICATIONS 1.a. State plan directs agency heads to develop appropriate notification procedures. Reference DPS (Annex R) and DEM (Annex AA) as primary responsible agencies for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day communications links. Also references local plans.

O.K.

~

b. Annex R (DPS), local plans. Contigugous states not applicable to this site.

O.K.

c. DPS/DEM (Annex R and AA respectively) Tab 1 indicates proper channels are DEM/ FEMA Region VI via telephone, NAWAS and NACOM.

O.K.

d. Annex R. Local plans for communications. Radiation Monitor team members will have radio contact with team leaders.

O.K.

,, Attachment F-4 EMERGENCY COMMUNICATIONS cont'd

e. State plan assigns responsibility to agency heads.

Indicates priority of order call to be established within council agencies. Health Department responsibility for alert and activation of emergency personnel is responsi-bility of the Director of Disaster Response Program.

(Warning and emergency communications is responsibility of DPS. Agency notification is responsibility of DEM)

O.K.

2. Local plan / responsibility only.

G. PUBLIC EDUCATION AND INFORMATION

1. Annex AA and local plan O.K.

2. Local 'lan O.K.

3.a. Responsibility of State Emergency Public Information officer; Bureau of Radiation Control will have spokes-person who will coordinate with licensee and local government counterparts. DPS coordinates all public information. DEMAcoordinates public information from.

State EOC. -

O.K.

4.a. DEM has primary responsibility for dissemination of emergency public information. Single point of contact for EPI release and for persons seeking information is DEM. Bureau of Radiation Control will have public information coordinator.

O.K.

b. Bureau of Radiation Control Public Information coordinator will arrange for timely exchange of information with j appropriate licensee and local government public inform-ation personnel.

O.K.

c/ Same individuals as above will coordinate information realeses to coreect or forestall rumors.

( O.K.

l

5. Local government responsibility. Bureau of Radiation Control will assist in development of Public INformation mateeials to be released for annual exercise of plan.

H. EMERGENCY FACILITIES AND EQUIPMENT

3. State EOC, DPS Austin and State Districe EOC (Waco)

(See local plans)

O.K.

l

Attachment F-5 EMERGENCY FACILITIES AND EQUIPMENT Cont'd

( 4. State agency personnel who have operational responsi-bility will staff State and Distrcct EOC's O.K.

)

i

11. Applicable emergency supplies and protective equipment listed in procedures. Communications equipment DPS responsibility. Radiation monitoring team equipment and l supplies listed in attachment 6 of Chapter 1 of tab 1 l to appendix 7 annex L. Other emergency supplies listed i

as procedures 2 - 6.

O.K.

I. ACCIDENT ASSESSMENT No FEMA assigned rev&&w elements J.,

PROTECTIVE RESPONSE 1

10.a. Map depicting monitoring points located in Chapter 1 of tab 1. Other maps local government responsibility.

l O.K. -

b. Local government responsibility

c. Local Government responsibility

d. Consideration made for mobility impaired through sheltering, respiratory protection (filtering air, limiting outside air intake etc.) evacuation or use of KI.

O.K.

f. No KI to be used for general populace. KI will be ad-ministered to emergency workers in accordance with-Protective Action Guides.

O.K.

g. Local government responsibility

'h h.

i.

l

j. " Contamination Control" addresses control of access to exclusion area and responsibilities f'or control.

O.K.

k. No significant impediments noted l 1. Local government responsibility

11. Annex C and appendix 2 and 9 of Annex L not available for

, review, however, tab .' appears to sufficiently address i this element. Department of Agriculture re.sponsible for land-use maps.

Monitoring points mapa noted.

O.K.

. Attachment F-6 PROTECTIVE RESPONSE Cont'd

12. State plan indicates evacuees are responsibility of hosting government. Local plan responsib_ility.

O.K.

K. RADIOLOGICAL EXPOSURE CONTROL )

3.a. Bureau of Radiation Health Contamination Control team will provide dosimetey. Emergency worker dose record noted.

O.K.

L. Medical and Public Health Support

3. (Appendix 3,11 and 12 to annex L. Appendix 3 contains functional statement for Bureau of Emergency Management.

Appendix 11, Public Health Regions functional statement "to be developed". Appendix 12. Fundtional statement for licensing and certification.)

Tab. 1, Chapter 1 Page 10, item 9 lists 3 hospitals capablie of handling radioactive 1.y contaminated individuals.

Hospitals have agreed to accept chese individuals.

Hospitals do not have letters of agreement (Local plans?)

How many radioactively contaminated individuals can the

-hospitals handle at one time?

> 4. Reference is made to appendices 3 and 11 of annex L.

Functional Statements for the appendices is insufficient to determine the capability for transporting contaminated individuals to medical facilities. Either the functional statements should be expanded to include this or appendices 3 and 11 made available for review. If this is local plan responsibility for addressing, O.K. Needs clarifications.

M. Recovpry and Reentry planning and Postaccident Operations

1. State plan part 3, describes concept of operation by the State for recovery and reentry following a disaster. Annex L, Appendix 7, Procedures 1-5. The Emergency Management Council supervises all disaster recovery operations.

Divi'sion of Emergency Management is focal point for managing all. phases of disaster operations. bureau of Radiation Control (accident assessment team) makes assessment and recommendations to Council. Procedfures for Chapter 1, to Tab 1 describe methodology and reference PAG's.

3. Part 3 of the State Plan references general state procedures for recovery operations. Appendix 7 indicates the Chief of the Bureau of Radiation Control will be responsible for determining when operations may be phased down or concluded.

O.K.

.A\

Att'chment a F-7 j ,

N. EXERCISES AND DRILLS

s. 1.a. Annex L. General. Inherent skills maintained day-to-day. Appendix 7 tab 1. VIII of introduction, page 8 indicates all emergency response personnel will receive initial and annual retraining applicable to their duties.

Attachment 4 addresses training, drills and exercises both generally and specifically. Exercises are to be in accordance with FEMA requirements.

O.K.

b. Criteria addressed in tab 1, attachment 4, II.A. No reference to anannounced exercise however, indication is that exercises .will be inaccordance with FEMA requirements.

O.K.

2.a. Communications drills adqquately addressed. While some drills not conducted explicitly for GNGF accident /inci-dent, in essence capability is exercised through normal day-to-day use more frequently than criteria requires.

O.K.

2.e.. Appendix 7, tab 1. attachment 4, B.2. p.20 indicates H.P. drills to be conducted semi-annually.

O.K.

3.a. Scope of exercises to be in accordance with FEMA re-quirements. Plan does not specifically address exercise objectives and evaluation but is implied if conducted in accordance Olth ; EMA requirements. -

O.K.

b. Same as above.

c.

e.

g, o a n

4. Tab 1. Attachment 4, II. A, p. 19 indicates critique will be conducted, evaluation made of exercise comments and neeessary plan changes made.

O.K.

5. Tab 1, attachment 4, II, A. p.19 addresses evaluation of 6bserver comments and procedural changes in plans. Plan review and up-date is addressed sufficiently in appendix 7, XI, " Plan Maintenance".

O.K. '

Attachment F-8 O. RADIOLOGICAL EMERGENCY RESPONSE TRAINING

1. Training of state response personnel addressed in annex

'- L., Appendix 7, VIII addresses training of response team members. Tab 1, attachment 4 further addresses training. (Not referenced)

b. Training of off-site state response personnel sufficiently addressed. Local emergency response personnel training to be addressed in local plans.

4.a. Attachment 4 to tab 1 indicates all Bureau of Radiation Control personnel will receive training.

b. Planners, utility liaison, accident assessment, monitor-

c. ing, analysis, contamination control, decontamination,

e. medical liaison, instrumhet calibration and maintenance,

h. public information, logistics support personnel are specifically identified for _ training.

d. Identified as local plan items of concern g, .. .. .. .. .. .. ..

H .. .. M

j. Local responsibility primarily. DPS t'o supply capability for communicating emergency information 6f necessary and for field monitoring teams.

O.K.

5. Plans generally indicate the necessary training to perform assigned duties are inherent in position the individual holds. Tab 1 indicates individuals will re-ceive initial and annual retraining applicable to their duties.

O.K.

P. RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS

1. Plan notes responsibility for appropriate training; for planners specifically, they will or have attended FEMA planning course.

O.K.

2

2. Plans indicate the coordinator, DEM is responsible for overall State Emergency Management Plan. The Chief, Bureau of Emergency Management has planning responsibility for the Health Department. Wtihin the Bureau, the Director, Division of Compliance and Inspection has the authority and responsibility for REP plans.

O.K.

3. Same lines of responsibilities and authorities as above.

O.K.

Attachment F-9 RESPONSIBILITY FOR PLANNING cent'd b -

4. Provisions for up-date for all plans. All persons holding plans or having emergency assignments under the plan within the health department will rev&&w and make recommendations for changes annually. Same for appendix 7. If no changes needed, certification of currency will be issued annually.

O.K.:

5. Plans will be distributed; changes will be dated and marked to iddicate where changes have been Made.

O.K.

6. State Plan, part 1. attachment 4 lists state agency and respoective annex.

Annex and 12 appendicws thereto.

L references the State Pland Appendi:- 7 notes tabs, while tab 1 consists of chapter (s) . Supporting plans w&&1 noted.

O.K.

7. Implementing procedures for tab 1 are contained as a .

separate part of the plcn. The procedures are self-explanatory (by name) 'as to that part of the plan they are designed to implement.

O.K.

8.

Table of contents and 0654 cross-reference suppled.

L While the cross-reference is not a part of the plan, constructed separately for the State Emergency Plan, Annex L and Appendix 7 it is more easily referenced by reviewers.

O.K.

10 ;- Telephone numbers of response personnel will be up-dated annhally. 6douco GE QUAArLALV qua N

.g. __

CL'O

/'*%

M '(2 2~'C"7

y Attachment G-1 '

'O 3 UNITED OTATEC ENVIRONMENTAL PROTECTION AGENCY <

REGION VI l

%gd 1201 ELM STREET Q

DALLAS. TEXAS 75270 July 21, 1982 Mr. Albert L. Lookabaugh !

Chairman, Regional Assistance Comittee Natural and Technological Hazards i Federal Emergency Management Agency Federal Center Denton, Texas 76201

Dear Mr. Lookabaugh:

We have completed our review of the Texas Radiologica? Emergency Response Plan as requested in your memorandum of June 18, 1982.. Our comments are enclosed.

In accordance with Fema Guidance Memorandum 16, we did not assign acceptable /

unacceptable / missing designators, but made narrative statements about each element.

l In general, we found the Plan to be a great improvement over the draft version j we reviewed in May,1981. The great bulk of material that was missing from the draft has now found its way into the present Plan.

Our review was greatly facilitated by the effort the preparers of the Plan put into indexing and cross-indexing. Without indexing, our review would have re-quired several times as much effort (and time) because of the sheer bulk of the Plan and its many component parts. Even with all the careful indexing, however, several component parts were difficult to find. The CPSES Plan, for example, was found as Chapter 1 of Tab 1, but does not appear in any of the Tables of Contents.

We strongly recommend that Fema encourage, or, if possible, require future Plan preparers to include a comprehensive cross-index in all plans submitted for RAC review.

In general, we find the parts of the Plan that we reviesed to be workable, and in line with the Fema-Rep-l Criteria.

Mr. Hank May o,f my taff will be pleased to meet with the RAC to explain any of our comments, or will do so by telephone if a meeting is not required.

Sincerely yours, t f S 1' !

u - // / th.

/, Norman E. Dyer, Ph.D. , Chief

- Pesticides & Toxic Substances Branch Enclosure

,, Attachment G-2 s- DETAILED COMMENTS A.2.a. Functions and Responsibilities Responsibilities have been assigned in Apo. 7, chap. VII and in the matrix on p. 31. Appropriate required training is specified in chap. VIII.

Accident Assessment App. 7, p.10 specifies up to 4 persons per shift, with provisions to augment. Responsible official is clearly indicated. Training at Fema's Accident Assessment Course is specified on p.18.

Protective Response Hood Co. Plan p. 49, Radef Officer has responsibility.

Exposure Control Co. plan p. 49 notes this is primarily a T00H function. App. 7 p.11 discusses this under Contamination Control, and responsibility is included as a duty of the Team Leaders, p. 8.

~

Co. plans cover this in chap. VI.

A.3. Written Agreements with Support Agencies The Plan has been devel.oped under the philosophy that most operations are required by statute, and special written agreements are not needed.

It is' assumed that accidents can be handled with State and local re-sources and that no Federal assistance will ever be needed or requested.

This is hopefully correct, but it can never be assured. The Plan should at a minimum recognize that the need for Federal assistance, or a Federal presence, is at least possible, and assign responsibilities and authorities to appropriate staff, and establish procedures for requesting Federal assistance.

C.1.c. RAP /IRAP Support Resources Neither EPA nor IRAP have been designated for potential support roles, since the need for Federal assistance is not anticioated.

C.3. Radiological Laboratory Capability Radiological support laboratories are identified: mobile Health Dept.

lab in Tab 1, Chp.1, p. 7, UT and Texas A&M in Tab 1, p. 8. Federal lab support is not anticipated.

Attachment G-3 C.4. Other Emergency Assistance No outside assistance is anticipated other than that which might be obtained through the Southern Mutual Radiation Assistance Plan (except see C.3. above), or that which is provided by statute.

E.1. Notification of Response Organization Notification forms are Attachment 4 and 5 of Tab 1, Chp. l. Bases for notification are given in Tab 1, Chp.1. Verification procedures are not included for State notifications, since ve'rification is covered by i 50P's. However, verification is indicated in App. 7, Attachment 6.

Local plans specify verification.

E.3. Content of initial notifications are specified in Attachment 4 and 5 ,

of Tab 1 Chp. l, and content is appropriate.

i H.7. Offsite Radiological Monitoring Capability Appropriate offsite monitoring equipment is provided for, as specified in Attachment 6 of Tab 1, Chp. 1.

t H.11. Emergency Kit Inventory ~

l Radiological monitoring Rits do not specifically include operating -

manuals for equipment, check' sources, or site maps.

s.

I I.7. Field Monitoring Within the EPZ Adequate capability and resources for monitoring the plume exposure EPZ is indicated in Tab 1,'Chp. 1. Training and refresher provisions

! are outlined in Tab 1, Attachment 4.

j I.8. Assess Radiological Hazards Capabilities to perform rapid assessments of radiological hazards are indicated in App. 7 and Tab 1. Notification arrangements are shown in App. 7 Sec VI. C and Attachments 5 and 6, are adequate. Provisions include computer graphics terminals with hard-copy output.

I.9. Capability to Measure Radioicdine Radiof odine monitoring provisions use silver zeolite (Apo. 7, p. 9).

Autillary equipment as described in Tab 1, Chp. 1, p. 7 is adequate.

9

, , - - - - ~ ' " , - - - ~ ~ - ~ ~ - ~ ~ - - * ~ - ' * ^ ~ ' " ~ ~ - ^

.. , . - . ~ _ _ . - _ _ - , - . - - . - , ,-

~.. .".

Attachment G-4 3-I.10. Dose Rates from Key Radionuclides Procedure 1 merely references EPA's Manual of Protective Actions and Guides for dose conversion techniques and Attachment 4 to Procedure 1 lists levels for key nuclides in the ingestion pathway. While the methodology is thus included by reference, the Plan would be improved greatly if explicit details were to be included to make the dose projections. Consideration should be given to including nomograms.

EPA's National Interim Drinking Water Regulations are not intended for application to accident or short term situations, but rather chronic long-term exposures. Consequently, the Appendix B levels of nuclides which correspond to 4 mrem /yr annual dose are those calcu-lated for the 50th year of exposure. This makes'little or no differ-ence for short half-life nuclides, but can be important for long-life nuclides, and can lead possibly to excessive conservatism in some cases. Procedure 1 will be improved if it is revised to clarify this point. Also, as with the PAG dose conversions incorporated by reference, the Procedure will be further improved if explicit proce-dural details are added for this pathway. -

I.ll. Track Airborne Radioactive Plume Arrangements to locate and track th_e plume are indicated in Tab 1, Chp. 1, p. 7.

J.9. Implementation of Protective Action Criteria s

The Plans indicate a capability for implementing required protective measures. Protective Action Guides presented in Procedure 1 attach-ments are consistent with' EPA guides.

J.10.m. Bases for Plume Exposure Protective' Action The bases for choice of protective actions are presented in Tab 1, Chp. 1, Procedure 1. Evacuation times are in Local Plar.s Attachment G, the Comanche. Peak Emergency Procedures Manual (p. 209).

J.11. Protective Measures for Ingestion P'rotective measures to be used for the ingestion pathway are pre-sented in Tab 1 Introduction and Chapter 1, Procedure 1 and Attach-ments . Protective Actions and procedures are appropriate.

Attachment G-5 4

s J.12. Registering and Monitoring of Evacuees Monitoring equipment at relocation centers is apparently the Civil Defense instruments. I finally located monitoring procedures in Attachaent H of the CPSES, but I never did find it indexed anywhere.

Monitoring equipment should be specified.

K.3.a. Emergency Worker Dose Determination Contamination Control Team handles this (Tab 1 Chp. 1, p. 9).

Sufficient staff are available to ensure 24-hour coverage. Exoosure record form is presented as Attachment 8 of Tab 1, Chp.1. Limita-tion of worker exposures is also addressed in CPSES Procedure 1,

p. 1-6(6).

K.3.b. Maintain Dose Records Methods for kseping accurate emergency worker exposure records are presented in Tab 1, Chp. 1, V.C. 7.

K.4. Authorize Emergency Overexposure I could not find specific reference to the authority who can authorize emergency exposures of workers to doses in excess of the PAG's. Evi-dently excess exposures are not to be permitted.

K.5.a. Decontamination Action Levels Decontamination action levels are presented 'in Tab 1, Chp.1 Proce-dure 1, Attachment 5.

K.5.b. Decontamination Means Decontamin~ation means are presented in Attachments 4, 5 and 6.

l .

M 1. Reentry and Recovery Plans / Procedures l

l l General plans and procedures for reentry and recovery are presented in Procedures 1, 3, 4 and 5 of Tab 1. Criteria are given in Proce-dure 1, Attachment 5-2, and are appropriate.

M.4. Estimate Population Exoosure Provisions for measuring total population exposure are presented in Procedure 1, p. 1-20.

1

Attachment G-6

> N.2.d. Radiological Monitoring Orills Attachment 4 to Tab 1 Intro. (p. 20) asserts that drills over and above those conducted during annual exercises are not necessary, since the staff perform such activities routinely. This may be true at present, but the situation could change in the future. The Plan would be a better one if it specified that additional drills would be ca 'd out if exercise debriefing or critiques should indicate this neec. Additional drills may also be appropriate as staff assignments are changed, new equipment is acquired, or new procedures are instituted.

N.2.e.(1) Health Physics Drills I

Semi-annual drills are planned (Attachment 4 to Tab 1 Intro.) for each 4-man shift of the Accident Assessment team.

N.4. Observation and critique of Exercises Provisions fer critique by Federal representatives, and by cooperative arrangements with adjacent States, are provided in Attachment 4 of Tab 1 Intro. -

0.1. Training This is covered in Attachment 4 of Tab l' Intro.

0.4.a. Director / coordinator Training This is covered in Attachment 4 of Tab 1 Intro., I.A.

0. 4 .' b . Accident Assessment Personnel J

This is covered in Attachment'4 of Tab 1 Intro., I.B.3.

0.4.c. ' Radiological Monitoring Teams This is covered in Attachment 4 of Tab 1 Intro., I.B.4,5.

l l

m I

l

GN=m is lamspORTaTLOM KE5f4Jstm suitaisq i2 ARCONNE NATIONAL LABORATORY TE!Eph0NE 312/972 4633 l 9K)050urkCA5s AME.Aacpu,lLw 60439

'- Attachnent H-1 July 21,1982 _

. ,i /

I Mr. Albert L. lookabaugh

,/

Emergency Management Specialist, ,

RAC Chairman I FEMA Region VI ,

Loop 288 l', '-

Denton, Texas 76201

Dear A1:

E ' ,, -

Enclosed per your request are our written evaluations oE the #

Radiological Emergency Response Plans of the State of Texas pad #

Hood and So=mervell Counties for the Comanche Peak Steam Electric Station. If you have questions concerning the items relating'to radiological health and safety, please call Lleyd Lewis (8-972-7705). '/ '

Questions concerning other items can be answered,by Floyd Davis i.8-972-6328). They prepared the documents and my review of their '

work indicates that they did a thorough, excellent"$ob.

I hope ,, ;

our input aids your RAC review process. -)' ,

l If you have any trouble reaching either of them directly,

I will be happy to make surre your questions are answered.

' Al, please be sure to let me know as soon as you have a definite date for the October Waterford 3 exercise.

Sincerely,

?f Kenneth M. Bertram Region VI. Coordinator KMB:lb

/

Enclosure cc: T. Surles ,

F. Davis L. Lewis C. Wingo J. Benton p n

Y UElhhiRSITy dOccAqo ARQ"NC MERSITIEs AssoaAnoN /

/

Attachment H-2

,, State of Tsxas Evaluation of Radiological Emergsncy Rasponea Plan For Comanche Pssk Stszm Electric Station A

A. Assignment of'Respons.ibility (Organizational Control)

Planning Standard ~

Primary responsibilities for emergency response by the nuclear facility licensee, and by state and local organizations within the Emergency _

l' Planning Zone have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Location / Item Reference / Comment A.l.a. ? The plan does not identify the Federal organizations that should be part of the overall response organization. The only private sector response organization named is the-American Red Cross, although universities and laboratories are given response assignments.

References are the preamble to the state plan; Part I of the state plan; Tab. 1 of Appendix 7.

A.l.b.

Jec. V.B.5 and Sec. V.B.6 of Appendix 7.

A.l.c. Appendix 7, Attachment 2 and Attachment 1, Tab. 1 of Appendix 7.

( A.1.d.

Sec. VII.A.2 A.l.e. ? The plan does not specifically state that each response organization can provide 24-hour per day response and manning of communication l links. References are Sec. VI.C of Appendix 7 and Sec. VII.A.4 of Annex L.

A.2.a.

Sec. II.B.4 of Appendix 7; Sec. VII.C.6.

( A.2.b.

Sec. I. A of Appendix 7.

! A.3

Sec. VII, Tab. 1 of Annex 7; signature pages are found in the preamble to the state plan.

A.4

Tab. 1, Introduction; Sec. VI.B.4 and Sec. I; Appendix 6, Annex L; Tab.1, Chap.1, Sec. V.

C.S.

l i

i

Attachment H-3 #E*

C. Em2rgency Response and R sources Plcnning Standard Arrangements for requesting and effectively using assistance re-sources have been made, arrangements to accommodate state and local staff at the licensee's near-site Emergency Operations Facilities have been n

made, a'd other organizations capable of augmenting the planned response have been identified.

Location / Item Reference / Comment C.1.a

Sec. 2, B.4, Part 3, Appendix 7.

C.l.b. ?

Sec. VI.B.4, Appendix 7 states that " Requests for Federal operational assistance are not anticipated". However, this does not necessarily preclude the need. Moreover, NUREG-II.C.1 states that "Each state and licensee shall make provisions for in-corporating the Federal response capability into its operation plan".

C.l.c.

See C.1.b. above.

l C.2.a.

Sec. V.C, Tab. 1, Chap. 1, Appendix 7.

C.3

Sec. v.C, Tab. 1, Chap. 1, and Sec. VII.1, Tab. 1 Introduction, Appendix 7 and Appendix 6, Annex L.

l C.4 ?

Sc'c. VI.B.4, Tab. 1 Introduction, Appendix 7, l

states that requests for Federal ass' stance l

are'uot anticipated but the Southern Mutual

, Radiation Assistance Plan is referenced.

A

.e O

l

Attachment H-4 .

Paga 3 6 -

Location / Item Reference / Comment D.3

Sec. III, Chap. I, Tab. 1 in Appendix 7.

D.4

Sec. III and IV; Chap. I, Tab. 1, Appendix 7.

E. Notification Methods and Procedures Planning Standard Procedures have been established for notification, by the licensee of state and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and follow up messages to response organizations and the public has been established; and means to' provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

Location / Item Reference / Comment E.1

Sec. III, Chap. I, Tab. 1 and, Sec. II.B, Attachment 4, Tab.1 Introduction, Appendix 7.

E.2

Sec. VI.C, Appendix 7. .- _

E.5 ? The local government plans and the Department

. of Public Safety Plan, Annex R, Appendix 2 cover dissemination of information to the public. However, this information should also be in the state plan. Appendix R i's not a part of the radiological emergency response plan. Appropriate material should be ex-tracted from the Department of Public_ Safety I and local plans and inserted in the state plan to make the radiological emergency plan more responsive to the needs of emergency response personnel.

E.6 ? Comments in E.5 above apply.

E.7 =

Responsibility for messages giving instructions to the public regarding protective actions are

" delegated to the local governments who are responsible for message contents. However, NUREC-0654,II.E.7 states that messages "shall be prepared and included as part of the state and local plans."

. ... Attachment H-5 Pega 4 s

F. Emergency Communications Planning Standard Provisions exist for prompt communications ameng principal response organizations to emergency personnel and the public.

Location / Item Reference / Comment F.1.a. ? The cross reference cites Annex R and Annex AA for information about 24-hour notification and activation of state and local response networks.

Appropriate sections of these annexes should be included in the state radiological emergency response plan, Appendix 7 to make the plan more convenient for emergency response personnel.

F.1.b . ? Comment F.1.a. applies.

F.1.c.

Tab. 1, Appendix 7.

F.1.d.

Tab. 1, Appendix 7.

F.1.e.

Sec. VI.C, Appendix 7.

l F.1.f. N/A Utility responsibility.

3 F.2 N/A The cross reference states that local governments are responsible for communications for mobile and fixed medical support facilities.

F.3

Appendix 7, Tab. 1, Introduction section.

G. Public Education and Information Planning Standard

Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g. , listening, to a local broadcast station and remaining indoors), the principal points of contact with the news media for dis- ,

semination"of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of inforvation to the public are established.

Location / Item Reference / Comment G.I. N/A Responsibility of local governments only.

G.2. N/A Comment for G.1 above applies G.3.a.

Sec. VII.B.10, Appendix 7; Sec. VII of i

Tab. I Introduction, Appendix 7.

l l

Attachment H-6

... .. Pcg2 5 C.3.b. N/A Licensee responsibility

~

G.4.a.

Sec. VII.B.10, Appendix 7.

G.4.b.

Sec. VII.B.10.a. Appendix 7.

G.4.c.

Sec. VII.B.10.c, Appendix 7.

G.5 ? Coordinated programs for the news media are shown in the cross references as responsibilities of the local governments. However, the references in the local plans make no mention of coordinated programs for the media.

H. Emergency Facilities and Equipment Planning Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Location / Item Reference / Comment H.1 N/A H.2 N/A H.3

Part two,Section III. A.3.a as well as Annex L,Section VII.A.2 and Section VII.A.3

> show that s state EOC is in use at Austin and that the State Disaster District 6A-EOC is in use at Waco.

H.4 ? Part II Section III.A.3,Section III.B.1 and Section III.B.2 provide for the timely activa-tion of the EOCs. Attachment 5 to appendix 7 '

gives the emergency recall procedures for the field teams and EOC liaison staff. The plan Part II Section III indicates that the state coordinator of the Division of Emergency Management and the Disaster District 6A committee chairman activate the Emergency Management Council. The council members are responsible for procedures to maintain operational capability. These procedures should be made a part of the plan.

H.S N/A

4 Attachment H-7 Pcgn 6 H.6 N/A L

H.7

Tab.1 Chap. I;Section V.C.3 adequately describes the field monitoring teams and their

~

functions.

H.8 N/A H.9 N/A H.10

Appendix 7 Section VII.B.11 adequately describes the calibration and maintenance of the emergency instruments.

H.ll ?

Tab.1 Chap. I Attachment 6 lists monitoring team equipment. In general, this is an excellent i

set of instruments. However, there is one deficiency. The Ludlum 14C meter uses a GM tube on the X 1000 range (0 to 2 R/hr).

According to the manufacturer, if the radiation level is more than about 8 R/hr the GM tube avalanches and the meter reading will go to

( zero. A high range, non overloading type meter (e.g. ion chamber) is needed for measurements of high radiation levels in the plume for serious emergencies. Equipment listed in the following references is adequate:

Tab. 1 Chapter 1 Procedure 2 Section IV Tab.'l Chapter 1 Procedure 1 Tab. 1 Chapter 1 Procedure 3 Section IV -

Tab. 1 Chapter 1 Procedure 4 Section IV Tab.1 Chapter 1 Procedure 5 Section IV Tab. 1 Chapter 1 Procedure 6 Section IV H.12

Tab. 1 Chapter 1 Section V.C.2,4,5, and 6 l -

describe adequately the collection and processing of samples & field data. No location for the field van (mobile laboratory) l is given. It should be conveniently located with respect to the EOF.

... Att'achment H-8 Paga 7 I. Accidant Assessmant s Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency conditions are in place.

Item / Location Reference / Comment I.1 N/A I.2 N/A I.3.a,b N/A I.4 N/A I.5 N/A I.6 N/A

, I.7 ? The field monitoring teams' are well equipped except for the lack of a high range non over-loading survey meter. (Sec comment for item H.11).

I.8 ?

Most of the items for Item I.8 are adequately covered in Tab.1, Chapter 1 -Section IV and V.

However, there are concerns about the estimated

deployment time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months especially in a t

rapidly escalating emergency.Section IV clearly gives the individual assigned to Utility Liaison the task of obtaining data to evaluate the event and to advise the l

, Bureau Chief', The Chief of Field Operations and the Accident Assessment Team Leader.

Procedures should be developed that provide for activation and deployment at the earliest appropriate time.

I.9

Appendix 7 Section VII.B.3 and Tab.1 Chapter 1 Section V.C.1 adequately describe the equipment and methods for measuring radioiodine concentrations in air.

I.10

Procedure 1;Section VII A.l.b and Procedure 1;Section V.C adequately describe the methods and procedures for calculating the projected radiation doses and the total population exposure.

l l

... Attachment H-9 Page 8 L-I.11 Appendix 7;Section VII.B.3 and Tab. 1 Chapter 1;Section V.C.3 adequately de' scribe the monitoring capability for the airborne plume.

J. Protective Response Planning Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have'been developed.

Item / Location Reference / Comments J.1 N/A J.2 N/A' J.3 N/A J.4 N/A

J.5 N/A J.6 N/A J.7 N/A J.8 N/A J.9 Appendix 7 Section 7 Parts A,B,C,D,E,G,H, and Annex L adequately establish the capability for implementing protective measures.

J.10.a

Tab. 1 Chapter 1 Attachment 7 adequately locates preselected sampling points.

Evacuation routes, areas, relocation centers and shelter areas are described in the local plans.

J.10.b ? Maps giving the required information should be l

availabic in the State EOC and District EOC for reference. They should be included in the state plan document.

,t . Attachment H-10 Pagt 9 J 10.c N/A - Local gevarnment respensibility.

J.10.d

Tab.1 Chapter 1 Procedure 1 Section A.4.a(3) describes the protective actions for persons.

institutionally confined.

J.10.e

Tab.-l Chapter 1 Procedure 1 Section A.4 describes when radioprotective drugs will be us ed. The utility will maintain a supply of KI at the EOF.

J.10.f

Tab. 1 Chapter 1 Procedure 1 Section VII.3 and

.4 describe conditions for possible use of K I i

for emergency workers and the institutionally confined. No K I will be given to the general public.

J.10.g N/A - Local Government function.

J.10.h N/A - Local Government function.

J.10.1 N/A - Local Government function.

J.10.j

Appendix 7 Section VII.B 7 and Tab.1 Chapter 1

(

Section V.C.7 describe adequately the procedures 5

to be used for the control of access to contaminated areas. '

J.10.k

Impediment to evacuation are adequately covered in the Attachment G - Evacuation Plan in the Hood county and Somervell county plans.

J.10.1

Time estimates for evacuation are covered adequately in the Attachment G - Evacuation Plan in the Hood county and Somervell county plans.

J.10.m

Attachment 7 Tab.1 Chapter 1 Procedure 1 Section VII Parts A3 and 4 together with attachments 1, 2 and 3 to Procedure 1 describe the basis of choice of each protective action.

J.11

Tab.1 Introduction, Tab.1 Chapter 1 and Tab.1 attachment 1, 2, 4 describe adequately the procedures to be used for the ingestion l pathway.

l l

i 1

1^

.T -

Attachment H-11 Pega 10 J.12 N/A - This is a local government function.

5 K. Radiological Exposure Control .

Planning Standard Means for controlling radiological exposure s, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Item / Location- Reference / Comments K.1 N/A K.2 N/A K.3.a ? Tab. 1 Chapter 1 Section V.C.7 states that

~

l the Bureau of Radiation Protection will provide personal dosimetry devices for all emergency workers and members of the public who must enter an exclusion area. Tab. 1 Chapter 1 Attachment 8 - Emergency worker radiation exposure record has provisions for both TLD and pocket dosimeters.

Provisions for early distribution from local

, ; sources need to be developed so that local workers are covered during the estimated 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months deployment time at the beginning of an l

emergency.

i K.3.b ? Procedures should be developed for emergency workers to report dosimeter readings fre-quently to their EOCs. This is especially important for field monitoring reams who go into the plume. Additional procedures re-quiring notification to the EOC by a worker when his dose has reached a specified level (e.g. 1 R) should be in place. A special set of instructions should be available for a member of the public who must go into an exclusion area. The record form Tab. 1, Chapter 1 Attachment 8 is good but the exposure information is not available until the individual leaves the exclusion area.

s . .,

1 *-

Attachment H-12 Pags 11 s

K.4 ? A statement of who authorizes emergency workers to exceed the PACS and under what circumstances was not found.

K.5.a.

Reference Tab.1 Chapter 1 Procedures 1, 4, 5 and 6 give the required action levels.

Reference is made to a Texas Department of Health guideline which should be included in the plan as part of Procedure 4.

K.5.b. * ' Decontamination procedures are adequately described in Tab. 1, Chapter 1 Procedures 1, 4, 5 and 6.

K.6 N/A K.7 N/A L. Medical and Health Support Planning Standard Arrangements are made for medical services for contaminated injured individuals.

L.1

Sec. V.C.9, Tab. 1, Annex 7. s L.2 N/A Licensee responsibility.

L.3 ? Appendices 3, 11 and 12 of Annex L list hospitals capable of providing medical support for contaminated injured personnel. Extractions from these appendices as appropriate should be included in the plan for convenience of emergency response personnel.

L.4 ? Comment for L.3 above applies.

M. Recovery and Reentry Planning and Post Accident Operations Planning Standard General plans for recovery and reentry are developed.

Item / Location Reference / Comments M.1

Procedures 1, 2, 3, 4 and 5, Procedures seqtion.

Tab. 1. Appendix 7.

M.2 N/A Licensee responsibility.

M.3

Sec. VII.A.2.

.s .. ,

Attachment H-13 Pag 2 12 M.4

Sec. VII.C.

h N. Exercises and Drills Planning Standard Periodic exercishs are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Item / Location Reference / Comments N.1.a. Section II. A, Attachment 4, Tab.1 Introduction, Appendix 7.

N.l.b. Sec. II.A, Attachment 4, Tab. 1, Introduction,.

Annex 7. But no mention is made of provisions for starting exercises between 6:00 p.m. and midnight and between midnight and 6:00 a.m.

N.2.a.

Sections II.B.1 and II.C, Attachment IV, Tab.1 Introduction, Appendix 7.

N .2.b . N/A Licensee responsibility N.2.c. N/A Medical Emergency drills are the responsibilities of the licensee and the local government.

N.2.d.

Tab. 1, Introduction Section, II.C.4, Annex 7.

N.2.e.

Sec. II .B.2, Attachment- 4, Tab . 1, Annex 7.

N.3.a.

Sec. II.A, Attachment 4, Tab. 1 Introduction, Annex 7.

N.3.b . ? The dates, times, places for exercises and drills are not mentioned in Annex 7 or elsewhere in the plans.

N.3.c. ? No time schedule of events is included in Annex 7 or elsewhere in the plans.

N.3.e. ? The narrative summaries that describe the conduct of exercises listed in Sec. II.A, Tab. 1, Appendix 7 adequately cover the exercises listed. However, no exercises or drills in-cluding such things as simulated casualties, off site fire department assistance, rescue of personnel, etc. are mentioned.

~

h ' ..

Attachment H-14 Peg 2 13 N.3.f. ?

- - A description of the arrangements for and advance materials to be provided for official observers is not included in the sections covering Exercises and Drills, Sec. II.A, Tab. 1 Introduction; Appendix 7 or elsewhere in the plan.

N.4

Sec. II.A. Attachment 4, Tab. 1 Introduction, Appendix 7.

N.5

Sec. II.A, Tab. 1 Introduction and Sections XI.A and XI.D of Appendix 7.

O. Radiological Response Training Planning Standard Radiological emergency response training is provided for those who may be called upon to assist in an emergency.

Item / Location Refe rence/ Comments 0.1.a. N/A Licensee responsibility.

O.l.b.

Sec. I.A, Attachment 4, Tab. 1 Introduction.

pendix 7.

0.2 N/A 1.icensee responsibility. -

0.3 N/A Licensee responsibility.

0.4.a

Sec. I. A, Attachment 4, Tab.1 Introduction; Appendix 7.

O. 4.b .

Sec. I.B.3, Tab. 1 Introduction Section, Appendix 7.

O.4.c.

Sec. I.B.4 and I.B.5, Tab. 1 Introduction, Appendix 7.

O.4.d. ?

Cross reference for the state plan, Part I, Attachment 5 makes the Texas Engineering Ex-tension Service responsible for training of fire fighting personnel, but not for training of police and security personnel; reference is also made to Annexes R, AA and FF which are l

not available as part of the plan. Relevant information from these annexes should be in-cluded in the plan or the annexes themselves I

Attachment H-15 Peg 2 14 should be included as attachments to Appendix g

7 to make the radiological emergency response plan more responsive to the needs of emergency response personnel.

0.4.e. N/A Licensee responsibility.

0.4.f. ? Same ' comment for 0.4.d. applies.

O.4. g. ' ? Provisions for training of local support personnel are referenced by the cross references to the local. plans. However, this item is not l

1 found in the local plans.

O.4.h. ? The cross reference for training of medical support person'nel in Sec. VIII, Annex L appears not to be responsive. Reference is' made to

" appropriate annexes to this plan." The i

same comment made in O.4.d. above applies.

O.4.1. N/A Licensee responsibility.

0.4.j . ? Annex R is referenced in the cross reference for training of personnel responsible for

transmission of emergency information. The same comment for 0.4.d. applies.

0.5 ? The cross reference refers to documents that f are not available as part of the basic radio-logical emergency response plan and is not responsive to the criteria. The same comment as for 0.4.d. applies.

P. Responsibility for the Planning Effort ,

Planning Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Item / Location Reference / Comments P.1

The cross reference for training of individuals responsible for planning is given as Tab.1, .

Introduction Section I.B.l. The reference should be Attachment 4-2, Sec. I.B.1 in Introduction Section of Tab. 1.

l I

.. "- Attachment H-16 Pega 15

~

P.2

Sec. XI.A, Appendix 7.

s P.3

Section VII, A, Appendix 7.

P.4

Sec. XI.D, Appendix 7.

P.5

Sections XI.B and XI.D Appendix 7.

P.6

Tab.1, Introduction Sections III and IV.

P.7 ?

Section XIII and the Procedures section of Annex 7 contain generalized statements about the status of the plan. However, no listing by title of detailed procedures for step by

{ step implementation of the plan is included.

The sections of the plan to be implemented by each procedure are not identified.

P.8

P.9 N/A Licensee responsibility. '

l P.10

Attachment 5, Appendix 7. -

\

{

i

{

S 1

4

4: -

Attachment H-17 Hood County, Tsxas Evaluation of Radiological Emergency Response Plan 6

For Comanche Peak Steam Electric Station

~

A. Assignment of Responsibility (Organizational Control)

Planning Srandard Primary responsibilities for emergency response by the nuclear facility licensee, and by state and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been. specifically established,

^

and each principal response organization has staff to respond and to augment its initial response on a continuous basis. 1 Location / Item Reference & Comment

, A.l.a. ? Page 22, Sec. VIII and page 43, Sec. III.A and B. are referenced. However, none of those sections identify Federal and private sector response organizations.

A.l.b.

Sec. V.A, page 6 and Sec. IV. A and B.

A.l.c.

Tab.1 of Annex F, p. 52; Annex F, p. 31; Annex F, p. 39; Annex B, p. 41 A.1.d.

Sec. V. A, p . 6; Sec. 7, A.1, p. 7 ; Tab. 1,

p. 52, Annex F.

A.l.e.

Sec. V.B.1, Annex F.

A.2.a.

Sec. VI.A and B, pp. 7-20; Sec. V, Annex F, I pp. 46-47; Tab. 1, Annex F.

A.2.b.

Sec. I, p. 4.

A.3 ? The cross reference N/A indicates that no organizations other than the local governments will have any emergency response role within the Emergency Planning Zones. However, it 2

is conceivable that at least some assistance from state a nd federal agencies could be l

needed.

i A.4

Sec. V.N. Annex F.

f

, C. E=ergency Response Support and Resources Planning Standards i

i

e e.. .., Hood County, Texas Att'achment H-18 Pcg2 2 Arrangements for requesting and effectively using aasistance resources

' have been made, arrangements to accommodate state and local staff at the licensee's near site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.

Location / Item Reference & Comment Col.a. N/A Not a NUREG criteria for local plans.

C.1.b. N/A Not a NUREGjeriteria for local plans.

C.l.c. ? Sec. IV.D is cited in the cross reference for I resources available to support Federal response.

However, this section shows only the duties of the response support group and no mention is- l

~

made of available resources.

C.2.a N/A Only the Bureau of Radiation Control will send representatives to the near site EOF. (See Tab.1, Chap.1, par. c of Sec. V, appendix 7 to State plan).

C. 2.b . N/A Licensee responsibility.

C.3 N/A State plan identifies radiological laboratories. I C.4

Sections III.A sad III.B, Anner F. identify organizations that can be relied on for emergency assistance; but the nuclcar facility should be added.-

D. Emergency Classification System Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and state and local response plans call for reliance on information provided by facility licensees for determination of minimum initial off site response measures.

Location / Item Reference & Comment ,

D.1 N/A Licensee responsibility D.2 N/A Licensee responsibility D.3

Documented in Sec. VI, Annex F.

Sections I through VII; attachments A through D.4 l 3 R, Manual of Emergency Procedures, Annex F.

Cross reference D.4 should be corrected to

., * , -H:od County, Texas Pcgs 3 Attachment H-19 include Sections I through VII, pages53-142.

s E. Notification Methods and Procedures Planning Standard Procedures have been established for notification, by the licensee, of i

state and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and follow up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

Location / Item Reference and Comment E.1

Sections I through VII and Attachments A through C, Manual of Emergency Procedures, Annex F.

E.2

Attachment D and Sec. II, Manual of Emergency Pro-cedures, Anne: F.

E.3 N/A Licensee responsibility.

E.4 N/A Licensee responsibility.

E.5

Attachment F. Manual of Emergency Procedures, Annex F.

E.6

Attachment F and Section VII, Manual of Emergency Procedures, Annex F.

E.7

Provisions are made in Attachment 0, Manual of Eme.rgency Procedures for written messages to the public,. but samples are not included in Attachment O.

F. Emergency Communications Planning Standard Provisions exist for prompt communications among principal response -

organizations to emergency personnel and to the public.

Location / Item Reference and Comment .

Sec. V.B F.1.a.

Annex F.

F.1.b . N/A There are no contiguous state or local governments within the plume exposure path- ,

i way Emergency Planning Zone. Communications with organizations outside the plume exposure

~ '*; - Hood County, Texas . pagg 4 Attachment .9-20 pathway Emergency Planning Zone is a state s

function and is the responsibility of the District Disaster Headquarters at Waco.

F.1.c. N/A Comment for F.1.b applies.

F.1.d.

Attachment D, Manual of Emergency Procedures, Annex F.

F.1.e.

Attachment Ef and Sec. II of the Manual of Emergency Procedures, Annex F.

F.1.f. N/A Licensee responsibility.

F.2

Attachment # and Sec. IV of the Manual of

' Emergency Procedures, Annex F.

F.3 N/A Tab.1, Appendix 7 makes the State Department of Public Safety responsible for testing com-munications systems.

G. Public Education and Information Planning Standard Information is made available to the' public on a periodic basis on

,how they will be notified and what their initial actions should be in an emergency (e.g. , listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dis-semination of information during an emergency (including the physical

^

location or locations) are established in advance, an'd procedures for coordinated dissemination of information to thc public are established.

, Location / Item Reference and Comment G.1

Attachments F and Sec. VII, Manual of Emergency

! Procedures, Annex. F.

G.2 ? The cross reference cites Sec. IV.B.3, page 7 of the Hood- County Emergency Operations Plan and Sec. IV, A, pages 128 and 129 as providing information for transients.

However, the information contained therein is specifically for residents. These sections should also contain detailed information for '

transients.

G .3 . a .

Sec. VII.B.3 and B.4, Manual of Emergency l

Procedures, Annex F.

Hoad C unty, Taxmz 82 5 Attachment H-21 s

G.3.b. N/A Licatnsso rceponsibility J s G.4.a.

Sec. VII, III.A. and III.B Manual of Emergency Procedures, Annex F.

G.4.b. ? The cross reference cites Sec. VII, IV.B.3 and IV B.5 for arrangements for exchange of information between spokespersons. However, these references are directed to media brief-ings.

G.4.c.

Sec. VIII, IV.B.7, Manual of Emergency Procedures, Annex F.

G.5 ? The cross reference cites Sec. VII, III.B but no mention is made therein of a coordinated program to be conducted at least annually to acquaint the media with the emergency response. plans and informatio'n on radiation.

H. Emergency Facilities and Equipment Planning Standard Adequate emergency facilities and equipment to support the emergency

, response are provided..

Location / Item Reference / Comment ,

^

H.1 -

N/A H.2 N/A H.3

Section V, Part B of the Emergency Operations Plans,Section III, Part B of the Hood County Annex F, and Attachment B, Standard operating procedures.

H.4

Section I, Procedures for the Executive Group in combination with Attachment B, Standard Operating Procedure for the EOC. .

a . i H.S.a-d ,

N/A H.6 a-c N/A H.7 ? Annex F,Section V.M states that the Radiological Defense Officer will provide assistance as requested to the Texas Department of Health if resources are available. This does not address the

]

Hood Csunty, Texas

Pcg2 6 Attachment H-22 3 requirements of NUREG 0654-H.7 that each organization, where appropriate, shall provide for offsite radiological monitoring eqdipment in the vicinity of the nuclear facility.

Section VII, Part B of the state plan described the assignment of accident assessment responsi-bilities. The state appears to have adequate equipment and personnel to determine the magnitude of the emergency, and to provide monitoring of the radioactivity. The county should state what equipment, if any, is available to measure whole body gama ex-posures and airborne radioiodine concentra-tions. A plan for transmitting these data, if any, to the EOF should be included.

, H.8 N/A H.9 N/A

, . H.10 ? See coment for H.7 above.

H.11 ? 'See coment for H.7 above. ,

H.12 ? See comment for H.7 above.

I. Accident Assessment Planning Standard .;

, Adequate methods, systems and equipment for, assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Location / Item Reference /Coment 1.1 N/A I.2 N/A I.3 N/A I.4 N/A I.5 N/A -

I.6 N/A 1

1.7 ? Hood County Annex F,Section V.M does not i address I.7 which requires that" Bach organi-zation shall describe the capability and resources for field monitoring within the

,... . Ho:d county, Taxas Paga 7 Attachment H-23 plume exposure EPZ which are intrinsic parts of the concept of operations for the facility." If the county is not depended upon to supply radiological data to the state and to the utility for use in assessing the magnitude of the emergency, the plan should so state.

I.8 ? See comment for I.7 I.9 N/A I.lo N/A 1

1.11 N/A J. Protective Response

< Planning Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emerr,cacy, consistent with i Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been

' developed.

e Location / Item Reference / Comment J.1 .

N/A J.2 ? This is not addressed. The utility is primarily responsible for this but cooperative arrangements for sheltering, decontamination, I medical att'ention, etc. are needed.

J.3 N/A

~

J.4 . N/A I

J.5 N/A J.6 ' N/A .

J.7 - N/A J.8 N/A .

J.9 ? Attachment K to the Hood County plan for Emergency Husbandry Procedures addresses the problem of contamination of human and at.imal foods in an adequate manner. Gamma ray and radio iodine exposures directly from the l

S . Hood County, Texas Attachment H-24 the airborne plume are not adequately addressed.

~

The response indicated in the procedures for j the Executive Group is one of ordering ,

evacuation or sheltering when recommended by )

l l

the state or by the utility. If this is the case the cross-reference for J.9 should include a reference to Section I - The Executive Group Procedures.

J.10.a.

Attachment G, Evacuation Procedures J.10.b.

See J.10.a.

J .10 . c .

Attachment F, Warning.

J.10.d.,

Attachment G, Evacuation Procedures.

< Tab . 2 - Section II.C.3.

J.10.e.

Annex F,Section V, Paragraph L.3.

J.10.f.

See J.10.e.

. J.10.g.

See J.10.d.

J.10.h.

Attachment H - Sheltering.

J.10.1.

Attachment G.

s J.10.j. * ,This is adequately addressed in the plan.

The cross-reference should include a reference to Manual of Emergency Procedures Section.II.

i J.10.k.

Attachment G,Section IV, Tab 2, to Annex F.

J.10.1.

Attachment G,Section IV, Tab 2, to Annex F.

~

l J.10.m. N/A J.11 N/A J.12

Attachment H - Standard operating procedures for sheltering evacuees.

K. Radiological Exposure Control Planning Standard Means f,or controlling radiological exposures, in an emergency, are .

established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protection Action Guides.

Location / Item Reference / Comment K.1 N/A

H:od Caunty, Texas peg 3 9 s, K.2 N/A K.3.a. 7 Hood County Annex F Section V M states that exposure control is the function of the Texas l Department of Health but that the county RDO will assist as requested if resources are available. Attachment G - Evacuation - Tab. 3 lists the contents of the list for roadblock personnel. Only a'TLD is to be furnished.

NUREG 0654-K3 requires both_self reading (e'.g. , pocket ion dosimeter) and permanent record dosimeters (e.g., TLD). In addition the self reading devices must have appropriate a

sensitivities to permit meeting NUREG-0654, K4.

Each emergency worker should be provided a sensitive direct reading dosimeter (e.g.,

0-200 m Rem) plus a higher range direct reading dosimeter (e.g. , 0-20 Rem) plus a permanent record device (e.g., TLD or film badge) .

~

Improvements in the plan are needed to insure the availability and proper distributions of appropriate dosimeters. Section VII-B-7 of Appendix 7 to Annex L of the state plan

_(contamination control) implies that all workers entering a contaminated area will have dosi-meters but the number available, the source of supply, etc., is not detailed.

K.3.b. ? Dose record forms need to be included in the plan and need to be distributed to emergency workers. In addition, requirements -need to be developed for frequent reading and timely-reporting of doses to the EOCs by the emergency workers.

K.4 ? The procedure for authorization of emergency workers to incur exposures in excess of PAGs needs to be clearly stated in the county plan.

- This should clearly name the official who is

tt~ .-

Attachment H-26 Hood County, Texas Paga 10 able to authorize this action. The procedure should also clearly require that the decision take into account the exposure data from K.3.a.

and K.3.b . above.

K.5.a. ? The Attachment H - Shelter; Monitoring and Precontamination Procedures of the Hood County plan does not specify action levels for decontamination. The Tab 1, Chapter 1, Procedure

~

5, Part VI does specify action levels for 1nitia- . '

ting decontamination.

K.5.b. ? Sections VII.B.8 of Appendix 7 to Annex L of the state plan states that the Bureau cf Radiation Protection will advise the local officials in decontamination actions, that are

~

to be conducted in accordance with "NCRP Report No.'65." No procedures for the disposal of vastes was found. No procedures

'were found in the Hood County plan for waste -

disposal. NCRP Report No. 65 should be made a part of the plan if it is the appropriate procedure to be followed.

K.6 N/A K.7 ,

N/A L. Medical and Public Health Support Planning Standard Arrangements are made for medical services for contaminated, injured individuals.

Location / Item Reference / Comment L.1 ? Provisions are made in Attachment Q, Manual of Emergency Operations for listing hospitals.

However, the list is not developed. When added, this section should list other medical facilities for backup and should state the )

- capabilities for evaluating and treating radiological exposure injuries.

Attachment H-27

.kood County, Texas Pagt 11 L.2 N/A Licensee respcnsibility.

L.3 N/A Applies to state only.

L.4

Sec. VI.B.4 of the County Emergency Operations Plan makes the Hood County Fire Chief and the Fire Chief and Marshalls of the cities responsible for transportation of radiological accident victims.

M. Recovery and Reentry Planning and Post-accident Operations Planning Standard General plans for recovery and reentry are developed.

Location / Item Reference / Comments M.1 ? Section III.R, Manual of Emergency Procedures, a

Annex 7 states that " details and criteria for recovery and reentry "will be provided by the Texas Department of H,ealth." However, there is no. evidence 'in the plan that general plans and procedures have been developed.

M.2 N/A Licensee responsibility.

Ii M.3 N/A State responsibility.

M.4 N/A State responsibility. ,

N. Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions

~

of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Location / Item Reference / Comment N. ? The cross ' reference cites the utility emergency plan, but the state plan makes some of the exercises and drills the . responsibility of the t 48 utility, the Bureau of Emergency Management, and the Bureau of Radiation Control There is no evidence in the local plan that local organizations receive training or participate in exercises and drills or that training pro-grams for local emergency response personnel

U l Attachment H-M

~ . .

Paga 12 Hosd County, Texas )

have been developed. These comments apply to l

- each item in this NUREG-0654 section. 1 0.

Radiological Emergency Response Training ,

Planning Standard

. ided for those who

. Radiological emergency response training is prov may be called on to assist in an emergency.

Reference / Comment Location / Item 7

Comment for N, Exercises and Drills, above N

i applies.

. Development, Periodic Review P. Responsibility for the Planning Effort: -

and Distribution of Emergency Plans ,

Planning Standard Responsibilities for plan development and review and for d "

distribution of emergency plans are established, and planners are properly traine .

- Reference / Comment _

Location / Item i

Hood County Emergency Operations Plan P.1 Sec. VI.3.e.p.8h

Hood C<

Imergency Operations Plan 3

. P.2 Sec. , ,.o.p.8.

Hood County Emergency Operations ' Plan P.3 ,

Sec'. VI, 3,-p.8.,

Hood County Emergency Operations Plan P.4 ,

t Sec. XI, , p.23.

P.51 ? The cross reference is marked N/A. . The utate

\ plan, Sections XI.B and XI.D, Annex 7 l

addresses only state plans and cha.nges.

g Providions should be made for forwarding local i

plans and changes to all responsible emergency i

response personnel, k

Supporting plans and their sources a're not '

P.6 ,

7 listed for the local plansi Thb. cross-reference is marked N/A. The listing of

/ ,

supporting plans found in Tab.1, Intro-i k

duction Sections III and IV, Annex 7, state g

1 ,, plan pertains only to supporting plans for 4

the state.

./,<

. . . a H:od C:unty, Texts Pege 13-Attachnent H-29 P.7

Annex A, Sec. VII; Manual of Emergency .4 Procedures, Annex 7.

t 1 /

P.8

Table of Contentsjand Cross References are included.

P.9 N/I Licensee responsibility. /

P.10 ? The cross reference indicates that pro'isions v

for updating telephone numbers are in the '

utility emergency response' plan. They sho,uld

~

also be included iI the. local plans. ,,

s >;-

f[/

I

)

~

r f

J.

E k

b .

O l

e e

2 M

9

, * = G:nsrolly Mects Critarin' Attachment H-30 S:mmervall Csunty, Tcxas Evaluation of Radiological Emergency Response Plan For Comanche Peak Steam Electric Station-A. Assignment - of Responsibility (Organizational Control) s Planning Standard

, Primary. responsibilities for emergency response by the nuclear facility licensee, and by state and local organizations within the Emergency Planning Zones have been assigned, the emergency responsi-bilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Location / Item

Reference / Comments A.1.a. ? Page 20, Sec. VIII and page 43, Sec. III.A and B. are referenced. However, none of those sections identify' Federal and private sector response organizations.

A.l.b.

Sec. V.A. page 6 and Sec. IV.A and B,

- page 44.

A.1.c.

Tab. 1 of Annex F, p. 51; Annex F, p. 31; -

s Annex F, p. 39; Annex B, p. 41.

,' A.l.d.

Sec. V. A, p. 6; Sec. 7, A 1, p.7; 1 i l Tab . 1, p . 51.

~

A.l.et. #

Sec. V.B.1, Annex 7.

A.2.a.

Sec. VI.'A and B, pp. 7 - 17; Sec. V, Annex F, pp. 45-48; Tab. 1, Annex F.

A.2.b.

Sec. I, p. 4; Attachment 2/1, p. 23.

A'. 3 ? The cross reference N/A indicates that no organizations other then the local governments will have any emergency i

! response role within the Emergency Planning Zones. However, it is conceivable that at least some assistance from state and federal agencies could be needed.

A. 4

Sec. V.N, Annex F. '

' Attachment H-31

Paga 2

'Snmmervall County, Taxpo C. Emergency Response Support and Resources L Planning Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate state and local staff at the licensee's near site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.

. Location / Item Reference / Comments C.l.a. N/A Not a NUREG criteria for local plans.

Col.b. N/A Not a NUREG criteria for local plans.

! C.1.c. ? P, age 138, Sec. IV.D, Attachment B, Manual of Emergency Procedures, Annex F, is cited in l , the cross reference for resources available to

' support Federal response. However, this section shows only the duties of the response support group and no mention is made of available resources.

C.2.a. N/A Only the Bureau of Radiation Centrol will send ,

representatives to the near site EOF. (See Tab.1, Chap.1, par. C of Sec. V, Appendix 7 to State plan).

C.2.b . N/A Licensee responsibility.

C.3 N/A State plan identifies radiological laboratories.

j C.4

Sections III. A and III.B, Annex F,. identify organizations that can be relied on for

- emergency assistance; but the nuclear F

facility is not included.

D. Emergency Classification System Planning Standard A standard emergency classification and action level scheme, the basis of which include facility system and effluent parameters, is in use .

by the nuclear facility licensee, and state and local response plans call for reliance .on information provided by facility licensees for determina-tion of minimum initial off site' response measures.

Location / Item Reference / Comments D.1 N/A Licensee responsibility

Attachment H-32

'.. Stamervall County, Tsxas Pcge 3 D.2 N/A Licenssa rsspensibility 6 D.3

Documented in Sec. VI, Annex F.

D.4

Sections I through VII; Attachments A through R, Manual of Emergency Procedures, Annex F. Cross reference D.4 should be corrected to include Sections I through VII, pages 55 - 130.

E. Notification Methods and Procedures - f Planning Standard l

Procedures have been established for notification, by the licensee, of state and local response ~ organizations and for notification of emergency personnel by all resp' onse organizations; the content of initial and follow up messages to response organizations and the public has been established; and means to provide early notification and clear i

instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

Location / Item Reference / Comments E.1 *. Seccions I through VI and Attachment A through D, Manual of Emergency Procedures, Annex F.

E.2

Attachment D, and Sec. II, Manual of Emergency ~ Procedures, Annex F.

~

E.3 - N/A Licensee responsibility.

E.4 N/A Licensee responsibility.

E.5

Attachment F. Manual of Emergency Procedures, Annex F.

E.6

Attachment F, and See, VI, Manual of Emergency Procedures.

E.7

Provisions are made in Attachment 0, Manual of Emergency Procedures for written messages to the public, but samples are not included in ,

Attachment O.

F. Emergency Communications

~

Planning Standard Provisions exist for prompt communications among principal response I

l

i .. Attachment H-33 ,

S:mmervall County, Texas Pcga 4 g

organizations to emergency personnel and to the public.

Location / Item ' Reference / Comment F.1.a.

Sec. V.B, Annex F.

F .1.b . N/A There are no contiguous state or local governments within the plume exposure I pathway Eme.rgency Planning Zone. Com-i munications with organizations outside the .

plume exposure pathway Emergency Planning Zone is a state function and is the responsibility of the District Disaster Headquarters at Waco.

F.1.c. N/A Comment for F.1.b. applies.

F.1.d.

Attachment D, Manual of Emergency Procedures, Annex F.

F.1.e.

Attachment D and Sec. II of the Manual of Emergency Procedures, Annex F.

F.1.f. N/A Licensee responsibility.

F.2

Attachment E and Sec. IV of the Manual of

' Emergency Procedures, Annex F.

F.3 . N/A Tab.1, Appendix 7 makes the State Department of Public Safety responsible for testing I communications systems.

G. Public Education arid Information Planning Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g. , listening to a local broadcast station .ind remaining indoors), the principal points of contact with the news media for dis-

~

i semination of information during an eme.rgency (including the physical location of locations) are established in advance, and procedures for coordinated dissemination of information to the public are established. ,

Location / Item Reference / Comments G.1

Attachments F and Sec. VII, Manual of 2

Emergency Procedures, Annex. F.

Attachment H-34

' Ssamervall County, Taxes -

Paga 5 G.2 ? The cross reference cites the Manual of

~

Emergency Procedures, Sec. IV, Part IV, A, pages 118 and 119 as providing information for transients. However, the information contained therein is specifically for residents. These sections should also contain detailed information for transients.

G.3.a.

Sec. VI.B.3 and B.4, Manual of Emergency

( Procedures, Annex F, page 119.

G.3.b . N/A Licensee responsibility.

G.4.a.

Sec. VI, III.A. and III.B. Ihnual of Emergency

. Procedures, Annex F. '

G .4.b . ? Sec. VI, IV.B.3 and IV.B.5, p. 119.

G.4.c.

Sec. VI, IV.B.7, Ma'nual of Emergency Procedures, Annex F.

l ,

G.5 ? The cross reference cites Sec. VI, III.B. but no mention is made therein of a coordinated program to be conducted at least annually to

, acquaint the media with the emergency

, response plans and information cn' radiation.

l H. Emergency F.acilities and Equipment Planning Standard -

Adequate emergency facilities and equipment to support the emergency respanse are provided:

Location / Item Reference / Comments H .1 . N/A l

H.2 -

N/A H.3

Section V Part B of the Emergency Operating Plan;Section IV Part B of Sommervell County, Annex F ; and Attachment B, Standard Operating Procedures for the EOC. -

H.S a-d N/A

~

H.6 a-c N/A l 3.7 ? Sommervell (County Annex F Section V M states that the Radiological Defense Officer will t

I i

Attachment H-35 Summervall County, Taxus Pcgs 6 s-provide assistance as requested to the Texas Department of Health if resources are available. This does not address the require-ments of NUREG-0654-H.7 that "Each organiza-tion, where appropriate, shall provide for offsite radiol 6gical monitoring equipment in the vicinity of the nuclear facility."

Section VII Part B of the State Plan describes the assignment of accident assess-ment responsibilities. The state appears to have adequate equipment and personnel to determine the magnitude of the emergency and to provide monitoring of the radioactivity.

The county should state what instruments if any are available to measure whole body ganmm exposures and airborne radio iodine concentrations. A plan for transmitting,

, these data, if any, to the EOF should be s included.

H.8 N/A H.9 N/A H.10 ? See H.7 above.

H.11 ? See H.7 above.

H.12 ? See H.7 above.

I. Accident Assessment Planning Standard Adequate methods, systems and equipment for assessing and monitori.ng actual or potential offsite consequences of a radiological emergency l

condition a're in use.

~

Location / Item Reference / Comments I.1 N/A -

I.2 N/A I.3 N/A I.4 N/A I.5 N/A l

Attachment H-36

. S:mmervall County, Tcx2s ,

Pega 7 I.6 N/A Sommervell Countyl Annex F,Section V.M does I.7 ?

not address I.7 which requires that "Each organization shall describe the capability and resources for field monitoring within the plume exposure EPZ which are an intrinsic part of the concept of operations for the facility." If the county is not depended upon to supply radiological data to the state and to the utility for use in assessing the magnitude of the emergency, the plan should so state.

< I.8 ? See comment for I.7.

I.9 N/A I.10 N/A-I.11 . N/A J. Protective Response Planning Standard A range of. protective petions have been developed for the plume '

exposure pathway EPZ for emergency workers and the public. Gaidelines for the choice of protective actions during an emergency, consistent with Federal guidanc_e, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

Location / Item Reference / Comments J.1 N/A J.2 ? This is not addressed. The utility is primarily responsible for this requirement but cooperative arrangements for sheltering, decontamination, medical treatment, etc.

are needed. .

J.3 N/A J.4 N/A J.5 N/A J.6 N/A

l ' *' ' Attachment H-37

.. Pega 8 S:marvsll Csunty, Texso ,

J.7 N/A s.

J.8 N/A J.9 7 Attachment K to the Sommervell County plan is cited in the cross reference. This attachment addresses Emergency Husbandry Procedures in an adequate manner, but Gamma ray exposure and radioiodine exposures directly from the airborne plume are not adequately addressed. The response indicated in the procedures for the Executive Group is one of ordering evacuation or sheltering

when recommended by the State or by the a

Utility. If this is the case, the cross reference should include a reference to Section I - The Executive Group Procedures.

J.10.a.

Attachment G, Evaluation Procedures.

See J.10.a. i ,

J.10.b.

i J.10.c.

Attachment F, warning.

J.10.d.

Attachment G, Evacuation Procedures Tab. 2, .

Section II C 3 J.10.e.

Sommervell County \ Annex F,Section V 4 state that the RDO will assist the State Department of Health in administering radioprotective'd' rugs if requested.

J.10.f.

See coment for J.10.e.

J .10."g .

See coment for J.10.d.

J.10;h.

Attachment H - Shelter - Describes location and procedures. .

J.10.1.

Attachment'G - Evacuation Procedures.

\

This is adequately addressed in the plan.

J.10.J.

The cross reference should include a reference

Attachment H-38

', ,Sommervall Caunty, T o Pcg2 9 to the' Manual of Emergency Procedures -

Section II.

J.10.k.

Possible impediments to evacuation (e.g.

ice on roads) is addressed in the evacua-tion plan, Attachment G.

J.10.1.

The evacuation plan, Attachment C, includes analyses of times required for evacuating each sector under each of several weather conditions.

J.10.m.

N/A J.ll N/d

. J.12

Attachment H - Standard Operati.ng Procedures

< for Sheltering Evacuees.

l K. Radiological Exposure Control Planning Standard Means for controlling radiological exposure, in an emergency, are established for emergency wor,kers. The means for controlling radiological' 3 exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Location / Item Reference / Comments K.1 N/A K.2 N/A K.3 ? Sommervell County.1 Annex F Section V M states that exposure control is the function of the Texas Department of Health but that the county RDO will assist as requested if resources are available. Attachment G Evacuation - Tab. 3 lists the contents of the kit for roadblock personnel. Only a ,

TLD is to be furnished. NUREG-0654-K3 requires both self reading (e.g. p'ocket ion chamber) and a permanent record dosi-meter (e.g. TLD). In addition, the scif

~~

. Attachment H-39

. ,,Sommarvall Ceunty, Texas .

.,Pcg2 10 reading devices must have appropriate b

sensitivities to permit meeting NUREG 0654-K4. Each emergency worker should be provided a sensitive direct reading dosimeter (e.g. 0 - 20 m Rem) plus a higher range direct reading dosimeter (e.g. 0 - 20 Rem) plus a permanent record device (e.g. TLD or film badge). Improvements in the plan are needed to insure the availability and proper distribution of appropriate dosi-meters. Section VII-B-7 of Appendix 7 to

, Annex L of the State Plan (Contamination

, Centrol) implies that all workers entering a contaminated area vill have dosimeters but the number available, the source of supply, etc., is not detailed.

K. 3.b . ? Dose record forms need to be included in the plan and need to be distributed to

, energency workers. In addition, require-ments need to be developed to insure timely j readings and timely reporting of doses to the EOCs by the emergency workers.

l K.4 ? The procedure for authorizing emergency.

workers to incur exposures in excess of l PAGs needs to be clearly stated in the county plan. This should clearly name the official who is able to authorize this action. The procedure should also clearly a require that the decision take into account

- the exposure data from K.3.a and K.3.b above.

K.5.a. ? The Attachment H - Shelter - Monitoring and Decontamination Procedures for the Sommervelli county plan does not specify

, action levels for decontamination. Section l VII B-7 of the State Plan - Contamination

(

l

.., Attachment H-40

' Pega 11 S:mmervall County, Taxes .

Control - does not specify action levels for g

decontamination.

. K. 5.b . ? Section VII B 8 of Appendix 7 to Annex L of the State Plan specifies that the Bureau of Radiation Protection will advise the

local officials in decontamination actions that are to be conducted in accordance with 10CRP report No. 65." No procedure for the-disposal of contaminated wastes was found.

l No procedure was found in the Sommervell '.,

county plan for waste disposal. "NCRP Report No. 65" should be made a part of the plan if it is the appropriate procedure to be followed.

L. Medical and Public Health Support Planning Standard Arrangements are made for medical services for contaminated

,inj ured individuals.

Location / Item > Reference / Comments L.1 ? Provisions are made in Attachment Q, Manual of Emergency Operations for listing hospitals.

However, the list is not developed. When added, this section should list other medical facilities for back up and should state the capabilities for evaluating and treating radiological exposure injuries.

L.2 N/A Licensee responsibility.'

. L.3 N/A Applies to state only.

L.4

Sec. VI.B.4 of the State Emergency Opera-tions Plan.

M. Recovery and Reentry Planning and Post-accident Operations Planning Standard General plans for recovery and reentry are developed.

Location / Item Reference / Comments M.1 ? Section I, Par III S, page 69, Manual of

Attachment H-41

Sommsrvall County, Tsxas Paga 12 Emergency Procedures, Annex F, states that L .

details and criteria for recovery and reentry "will be provided by the Texas Department of Health." However, there is no evidenca in the plan that. general plans and procedures have been developed.

M.2 N/A Licensee responsibility.

M.3

Sec. 3, Par. III L, p. 94. This should be added to the cross reference.

M.4 N/A State responsibility only. Reference to appropriate section of state plan.

N ., bxercisesandDrills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilitien, periodic drills are (will l

be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Location / Item Reference / Comments

( N. ? The cross reference cites the utility emergency plan, but the state plan makes some of the exercises and' drills the responsibility of the utility, the Bureau of Emergency Management and the Bureau of Radiation Control. There is no evidence in the, local plan that local organizations receive training or participate in exercises and drills or that training programs for local emergency response personnel have been developed. These comments apply to each item in this NUREG-0654 section.

, O. Radiological Emergency Response Training Planning Standard Radiological emergency response training is provided for those who may be called on to assist in an emergency.

~

Attachment H-42

. .Sommervall County, Tsxto Pega 13 Location / Item '

Reference / Comments ,

> o ? Comment for N, Exercises and Drills, above applies.

P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans Planning Standard Responsibilities for plan development and review and for'distribu-tion of emergency plans are established, and planners are properly trained.

Location / Item Reference / Comments P.1

Sommervell County Emergency Operations Plan Sec. VI.2,.g, p. 8.

~

P.2

Sommervell County Emergency Operations Plan Sec. VI.2.d, p. 8 P.3

Sommervell County Emergency Operations Plan -

i Sec. VI, 2, p. 8.

P.4

Sommervell County Emergency Operations Plan Sec. XI. p. 23.

- P.5 ? The cross reference is marked N/A. The

' state plan, Sections XI.B and XI.D, Annex 7 addresses only state plans and changes.

Provisions should be made for forwarding local plans and changes to all responsible emergency response perconnel.

P.6 ? Supporting plans and their sources are not listed for the local plans. The cross reference is' marked N/A. The listing of supporting plans found in Tab.1, Introduction y

Sections III and IV, Annex 7, state plan pertains only to supporting plans for the state.

P.7

Annex A, Sec. VI, Manual of Emergency ,

Procedures, Annex 7, p. 132.

P.8

P.9 N/A Licensee responsibility.

Attachment 00-43 l

'*i .Sommervall Councy, Texto Peg 2 14 P.10 ? The cross reference indicates that provisions t

for updating telephone numbers are in the utility emergency response plan. They should also be included in the local plans.

f f

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k-t l

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G 4,

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T? _q yf~

Attachment I-l Hood /Somervell Co. REP Plans s Oroanization Basic Plan - (2 attachments - organization - court order)

Annex A - Warning Annex B - Communications Annex C - Shelter Plan (Not included) -

Annex D - Radiological defense plan (not included)

Annex E - Crisis Relocation Plan (not included)

Annex F - Fixed Nuclear Facility Response Plan Manual of Emergency Procedures (S0P) for Incidents involving the CPSES (called an addendum to county E0P)

(called an extension of Annex F)

Section I 'rocedures for Executive Group Section II - Procedures for Law Enforcement Section III - Procedures for Fire & Rescue Section IV - Procedures for Hospital / Medical Section V - Procedures for Shelter & Transportation Section VI - Public Information Section VII - Attachments Attachments A. Initial Notification B. E0C C. Verification D. Notification / Communications '

E. Call List F. Warning G. Evacuation H. Shel ter J. Transportation K. Husbandry L. Media M. Government Agencies .

N. Situation Form

0. Protective Measures P. Emergency Actions (PIO)

Q. Medical Facilities R. State Disaster Act l (Attachments above have tabs)

GENERAL COMMENT

Plan needs to be tabulated for quick reference. Page numbering is inconsistent for base plan. Plan organization is confusing.

Either should be two separate plans or organization for 1 plan consistent throughout (eg. 1 warning annex and 1 set of attach-ments for entire plan).

Attachment I-2 HOOD /SOMERVELL COUNTY EMERGENCY PLANS e

NUREG 0654 ELEMENT A. ASSIGNMENT OF RESPONSIBILITY 1.a. Plans indicate procedures for requesting support from State, Federal or military. Identified at the local level is Hood County and the incorporated cities of Granbury, Tipan and Tolar; and Somervell County and the city of Glen Rose. The Division of Occupational Health and Radiation Control will assist counties with planning and operations relating to fixed nuclear incident. .

Okay

b. County Judge and Mayors of incorporated towns are responsi-ble for emergency measures including requests for assist-ance. Department / agency responsibilities summarized.

Okay

c. Primary and support responsibilities of agencies shown in

, diagram p. 51 (Somervell) P. 52 (Hood)

Okay

d. County Judge has responsibility for emergency response in the County including unincorporated communities. The mayors of incorporated towns / cities have responsibility in towns /

cities. Each city / county agency has director / chief who is responsible for that agency.

Okay .

e. The Sheriff's Office is responsible for 24-hour manning of communications link and warning-technical response by State.

Other response (fire, law enforcenent, etc.) normal.

Okay 2.a. " Executive group (mayor / council members and County Judge /

_ Commissioners)~ represent command and control . A & N.

Communications - Sheriff - all major elements addressed -

Functional agency responsibility chart included p.51, (Somervell) and p. 52,(Hood).

Okay

b. Legal basis.

Okay

Att'achment I-3

\~

3. Local plans' cross-reference indicates this element is not applicable. American Red Cross is covered by State, however, local volunteer organizations if they are to be used should have letters or agreements as to what with and how they will respond / assist local governments. School busses are to be used. If these are fiscally independent school districts and busses are either owned by the district or are contract busses and are to be used to evacuate people, letters of agreement may be appropriate. I feel local plans should address this element if any resources are to be used other than those connitted by law.

4. County Judges and Mayors of incorporated towns will assure continuity of operations in their respective jurisdictions.

Okay B. ONSITE EMERGENCY ORGANIZATION

2. While not designated as an element to be addressed in local plans, local governments may wish to include the title of the person from the licensees' facility who is responsible for initiating emergency actions and providing recommenda-tions for protective actions to offsite officials.

C. EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.a. Cross reference indicates N/A. Base plan VI, A.l.d. and VIII, indicates County Judges or Mayors may request State, Federal Not FEMA of military assistance through State Disaster Districts, assigned Can local government request Federal or military assistance element directly? If so, it should be indicated and the proper procedures for doing so.

2.a. Cross reference indicates this element N/A. Plan should designate local offical to serve as representative of local government at the EOF. This doesn't mean a representative must be there; on.ly that a representative may be there if he/she so chooses.

4. Local government relies heavily upon State assistance for technical capabilities. Local resources other than schools and local government not addressed. Letters of agreement with school districts may be appropriate unless school re-sources have been committed previously through legal instru-ments.

7 Attachment I-4 .

D.

EMERGENCY CLASSIFICATION SYSTEM

3. Incidents occurring at Comanche Peak have been classified consistent with NUREG-0654 criteria and assumedly that of Utility facility operator.

4. Emergency classification system listed and increased readi-ness action given in basic plan. Lengthy " Manual of Emergency Procedure for Incidents involving the Comancho Peak Steam Electric Station" is included as an addendum to the plan and appears to cover procedures to be employed by various 1

entities consistent with the emergency action level.

E. NOTIFICATION METHODS AND PROCEDURES .

1. Procedures for verification are found on pp.147 and 148.

Proper response by organizational entity noted.

2. Page 71 gives procedures for notifying response organizations for unusual event. Similar procedures for all action levels given.

3. Cross reference indicates 'N/A', however, feel this element should be addressed by S and L. I do not find copy of initial emergency message or any indication that local government is aware of the contents of such a message (See p. 156, warning message "similar to")

5. P. 156 addresses type information which might be broadcast to the public in the event of an accident / incident at Comanche Peak.

6. Siren coverage on P. 40 appears to provide notification to the public. Means for providing instructions to the public by EBS or mobile PA units (pp. 157-162)

E.7. Pp. 227-231 gives sample message format for press for pro-tective measures and evacuation procedures.

F. , EMERGENCY COMMUNICATIONS 1.a. _ P.45 indicates sheriff's office to maintain 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day communications capability. Capability consists of telephone and radio with DPS (currently not with utility).

b. N/A according to cross-reference however, it should be indicated what provisinns 'are made for communications with contiguous local (county) governments within 50 mile ingestion pathway. (eg.

through DPS District Office, Waco).

Attachment I-5 '

c.

Cross reference N/A. State responsibility (See coment C.la.)

d. Comunications from utility is apparently only through DPS District Office to local government at this time. Radiological monitoring teams and comunications between teams and local E0C or utility's EOF not addressed at local level. (State responsibility for monitor team comunication)

Okay

e. Plans have sufficient provisions and procedures for alerting emergency response personnel.

i

2. Plans indicate N/A as does State REP Plans. Local plans should address this element. (Capability to comunir. ate between ambulance / hospital)

G. PUBLIC EDUCATION AND INFORMATION 1.a. Public education and information is generally well-addressed,

b. I question the need to distribute the information package

c. annually to each residence. (IV.A.2,p.118) as changes occur

d. or bi-annually would seem more feasible. (Criteria says info will be distributed annually, not necessarily the same info package as the plans imply) The plans also indicate public meetings will be held annually. This is not required but is certainly okay if it is desired by local government.

2. The resident populace appears to be well covered regarding public education and information. I do not find provisions for assuring the transient populace has access to such intor-mation. Placing signs in public places, hotels, motels, _

stores, P.0's, etc. and publishing of info in telephone d_i-rectories would be some ways of making the infonnation avail-able to the transient populace.

3.a. The Waco District DPS office is noted as the point of contact for the media briefings schedule. The utility's operations facility (EOF) is designated as the site for the city and county news media. The alternate for the city / county will be the commissioners courtroom.

4.a. The chief executive of the County (Judge) and the Cities (Mayors) will be spokespersons for their jurisdictions (or their appointed representative) l 1

'~

Attachment I-6

'~

b. Press briefings will be scheduled and conducted for all news media at which time any exchange of information will occur.

c. The cross reference indicates the county and city will dis-courage independent news dissemination to the press; this may discourage some rumors, however, there will no doubt b_e some rumors and unsubstantiated info passed in the event of an ~

accident / incident at CPSES. There should be a telephone num-ber to call or a central location where one can go for factual information and where rumors can be verified or corrected.

5. I do not find specific provisions for programs to acquaint the news media with p}ans, radiation _ and points of contact on an annual basis. The plans should provide for this.

H. EMERGENCY FACILITIES AND EQUIPMENT 3.

Both counties have established E0C's (Somervell Co. has alternate E0C also).

4. Activation and staffing of E0Cs addressed satisfactorily.

7. State Health Department is primarily responsible for mon-itoring but County RDO will provide assistance if resources are available.

11. primarily responsibility of State Health Department.

I. ACCIDENT ASSESSMENT (No FEMA assigned element review)

J. PROTECTIVE RESPCNSE, 10.a. Maps showing evacuation routes are included but I do not find maps of evacuation areas as such. There is a general lack of precise evacuation procedures in the plans. I assume instructions and procedures including areas to be

" evacuated will De included in the public information package.

.. Radiological sampling and monitoring points are included in State Plan. I do not find maps of shelter or relocation areas.

These may not be needed due to common knowledge of area by all and the low evacuee population. Plans should so state if this is true.

Attachment I-7 h- b. Segmented population totals shown on p.192.

Okay

c. Outdoor warning devices to cover entire 10 EPZ. How to locate and warn hard-of-hearing or deaf?

d. Institutionalized persons compensated for: No mention of hard-of-hearing or handicapped persons not institutionalized.

f.

Decision is State's - County may assist in administration of KI if reque:;ted.

g. Means of relocation is primarily by auto (or school busses if duringschool). Assumes what few residents who do not have autos, have access to rides with friends, neighbors or relatives.

Plans should identify such persons and assure they will be evacuated.

h.

Shelter facilities should be outside the 10 mile EPZ (Glen Rose Senior High is listed as shelter facility) 1.

Projected traffic capacities of roads are cited and sup-porting studies referenced.

j.

County Sheriff is responsible for control points for evacua-tion )p. 47) and Tab G. VI indicatese control will be maintained over access to 5vacuated area (cross reference should indicate appropriate procedures which address this element).

k.

The only impediments (highway) noted would be icing or roadways.

Okay

1. Table 2 - misspelled word. " Area" section is upside down.

Summary of evacuation time analysis appears viable considering population.

12. Shelter registration form included in plan as Tab 2 to attach-ment H. Decontamination procedures seem reasonable.

Not (Where FEMA does the temporary clothing come from if individual's clothing is contaminated?)

K. RADIOLOGICAL EXPOSURE CONTROL 3.a. State responsibility primarily - County RD0 may assist.

Okay

~.~:

Attachment I-8 w

4. State responsibility primarily - County RD0 may assit.

Okay L. MEDICAL AND PUBLIC HEALTH SUPPORT

3. Cross reference indicates N/A. State plan implies some local responsibility. Letters of agreement may be appro-priate to assure a willinsness and capability to accept radioactively contaminatec individuals. How many R.C.

patients can hospitals

' accommodate? Do they have capability to monitor? ,

i

4. Cross reference indicates p. 3 item f. of plan. This merely indicates the Sheriff's Office has the responsibility to dis-patch ambulances. Is this private ambulance service? Does utility have medical transfer capability? If private ambu-lance service,are personnel trained in handling R.C. patients?

How many ambulances are available?

M.

REC 0VERY AND REENTRY PLANNING AND POST ACCIDENT OPERATIONS

1. Plan indicates procedures and information regarding recovery

, and reentry will be provided by State Health. State plan does not address details of recovery and reentry such as time phased movement, etc.

This decision to be made based on time and circumstance of occurrence?

N. EXERCISES AND DRILLS i

1.a. Exercising, scenario development and drills are primarily

b. responsibility of State and Utility according to plan; 2.a. however, local plans should address willingness of local

b. governments to participate in exercises and drills noted and with the frequency recommended by NUREG-0654.

(note communication, medical drills required for locals) 3.a . 2 All same as above - Local covernment plans should indicate

! b. ~ its willingness to participate and support where necessary i c. all elements noted that are related to and appropriate for

e. local government.

f.

4. Same as above.

5. Same as above.

l

" Attachment I-9

-8 s-

0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING 1.b. Local plans should indicate they will participate in appro-priate training. If mutual aid pacts or reci]rocal aoree-ments exist between governmental entities, li ce training will be made available to them.

4.a. _Same as above. Those organizations listed should indicate

b. their intent to participate in the necessary training to

d. qualify them for response to an accident / incident at CPSES.

f.

9 h.

j.

5. Same as above.

P. RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC -

REVIEW AND DISTRIBUTION OF EMERGENCY PLANS 1.

The Emergency Management Director / Coordinator is assigned responsibility for the planning effort. Plan doesn't say that person will be trained but must be assumed he has planning on experience and training to qualify him for the position.

2. Emergency Management Coordinator / Director designated.

3.

Emergency Management Coordinator / Director (who is the County Judge or his appointee) is responsible for emergency plans preparation, review, revision and coordination with other plans, 4.

Plan will be reviewed each six months and revised or updated annually. While not mentioned specifically, mentions it is assumed this review and update process would consider any coments made as a result of exercise.

5, Cross reference indicates N/A. Plans should contain a dis-tribution list of plan and indicate changes to plan will be dated and marked appropriately.

6. Cross reference indicates N/A. Supporting plans and authority for plan are found on p. 2 as II and I respectively.

7. .

Listing of implementing procedures found on p.132 (Somervell Co.)andp.142(HoodCo.)

8. Table of Contents and Cross Reference are contained in plan.

Suggest that plan organization and addenda be better defined and tabbed for easy reference. .

a, .

Attachment I-10

.g.

10.

While telephone numbers should not be a part of the plan,_the plan should contain provisions for updating these numbers on a quarterly basis as outlined in 0654.

O I

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^ ' - - -, --

7 -

)[ SE.MRT.*iENT OF HEa!.T:. x ht. .'.n.sN .iE2 VICES , Attachment J-l

%gy

1 N- Memorendum

,D D:t2 July 21, 1982 [(c. y' Frrrn Tom Carroll, Public Health Advisor '

Region VI d Sub:ect Review of State and Local Policies for Commar M Peak To 0. L. Lookabaugh, Chairman F.E.M.A. VI Regional Assistance Com.sittee A. Assignment of Responsibility .

1-A thru C - Addressed in Annex L - State Plan 2-A - State Plan Annex L - very generally stated. Evidently the individual Bureaus and Divisions have their specific policies and procedures under which they function. This material had not been made available to the Reviewer.

L - Medical and Public Health Support.

Annex L, Page 28 - State Plan. .

"his again relates to specific operational plans and procedures to be provided by the Bureau of Emergency Management. This material has not been made available to the Reviewer.., Can not evaluate, Local Plans

~

Hood County

, 1-A - Assignment of Responsibilities Health and Medical, Pages 14 & 15 Section should be tabled.

1-B - Described in Section IV & V (should be tabled) .

1-C-Nb#1,Page052 1-D - Section IV & V l-E - Section IV & V 2-A - Section IV & V 2-B - No Comnent 3 - N/A 1

~

Attachment J-2 i

Page 2 - O. L. Lookabaugh

4. Could not find

, L - Medical and /ublic Health Support 1 - No mention of back-up support unless it is contained in Hospital Plan.

2 - No mention of transporting victims.

Somervell County - Do not understand numbering sequence of plan especially using the cross-reference.

Same as Hood County in organization and content.

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CURRENT r: . POPULATION ESTIMATES
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1981 M 4 fft
.+ . p ,;se W;3 4
The N:rth Central Texas Council of (7,488), Dallas (27,803), and Tarrant
' Govsrnments, in its continuing effort to (43,349) counties continued to show the - '
l provide planning and technica! assistance largest numerical increases in population 3 to its member governments, presents the from 1980-81, while Denton (5.6%) Collin ,
(5.2%), Rockwall (5.0%), and Tarrant (5.0%)>J f:1 cighth issue of " Current Population Estim;tes. " Due to the availability of record the largest percent change from 1f Census data, we have slightly revised our 1980-81. In 1970 Dallas and Tarrant cou ,,1 l mstbod of estimating household size. In. captured 81.5 percent of the regional ,
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tha past we have utilized the Census population, however in 1981 they account
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, catim*,te of national household size in order for 77. 6 percent of the region. This decline' to calculate a reducticn factor. This factnr reflects the national trend toward increased .p-was then applied to each cities' 1970 growth in counties surrounding the central, j-household size. With the availability of urban core. p[
l preliminary Census figures, we were able ' ;.g?43 to incorporate more accurate household size According to the 1980 Census,h t' e Dallask , ' d figures into our methodology. Therefore Fort Worth SMS A (2,966,342) is the largest: ; (:"
~hin provided, we utilized the Census metropolitan area in the State. It grew fromy -
prcliminary household size which was released 1970-80 at an annual rate of 2.3 percent perf f j year with a numerical change of 588,719, ~~ ~~/
to tha highest elected official of each city.
Wa da not recommend comparison between the Persons or 24.8 percent change for the .
43 decade. Our estimates show that the SMSA . , f,'
1980 and 1981 NCTCOG estimates due to the a abova mentioned revisions. However, a has grown by 91,708 persons or a percent comptrison between the 1980 Census and the increase of 3.1 percent from April 1,1980 to. ;
1980 COG estimates is available upon request. January 1,1981. The cities of Dallas, Fort-Worth, Arlington, Garland and Irving all ,
show population in excess of 114,000 persons, l
North Central Texas while the combined population of Dallas and -
Regional Population Trend Fort Worth represents 42.6 percent of the total SMSA population in 1981. The largest
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numerical increases were in the cities of '
3 2 Fort Worth (14,771), Plano (5,984), ,
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ga 2m Arlington (5,777), Irving (4,891), Garland * '~
( 4,101), Hurst (4,251), and Carrollton '
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{' (4,059) which represents 48.5 percent of I o . . . _ _ . _ _ .
the total numerical change for the SMSA i" 1*
~~from 1980-81. Several other cities, including~~
""' Richardson, North Richland Hills, Denton, .4 l
Addison, Grapevine, and Bedford, recorded-l an increase in excess of 2,500 each from Ovsrall, the NCT Region showed a percent 1980 81.. [
chrnge in population from 1970 !!0 of 74.0 percent and 3.0 pert ent from 1980-1981, For additional copies of the estimates,. contact ,
which. reflects the general economic stability the librarian at (817) 640-3300. For x of the region. The annual rate of growth technical questions or comments, contact .k
,within the region from 80-81 (4.1%) compares Billie Villars or Deborah fiindlay, P. O. W favorr,.bly with previous years. Collin Drawer COC, Arlington, Texas 76Q11. Q lb
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STATE OF TEXAS )
Juanita Ellis, being duly sworn, deposes and says:
That she is President of CASE (Citizens Association for Sound Energy),
and Knows the contents of the foregoing CASE's Answer to Applicants' Motion for Summary Disposition of I'ntervenor's' Contention 22 Regarding Emergency Planning and CASE's Answer to Applicants' Statement of Material Facts Not Genuinely In Issue and that the same is true of her own knowledge and belief, e-) ,
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.Juanita Ellis SWORN TO and Subscribed
-before me on this 30th day of August ,1982.
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- Notary Public _ .
/>/// /N My Commission Expirt3:
( (SEAL);
' The original of this page is being mailed under separate cover, First Class Mail,
,o*he Secretary, U. S. Nuclear Regulatory Commission, Washington, D. C. 7.;35, August A'.t.e ntion : Chief, Docketin6 and Service Section, on this 30th day of ,
1982.
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21h/946-9hk6
- J (CITIZENS ASSN. FOR SOUND ENERGY) ,
August 30, 1982 Occketing and Service Section l Office of the Secretary U. S. Nuclear Regulatory Conmission Washington, D. C. 20555
~~Dear Sir:~~
~
~~Subject:~~
In the Matter of Application of Texas Utilities Generating Company, et al.
for an Operating License for Comanche Peak Steara Electric Station Units #1 and
~~2 (CPSES) .~~
CASE'S Answer to. Applicants' Motion for' .
Summary Disposition of Intervenor's
~~Contention 22 Regarding Emergency Planning and CASE's Answer to Applicants' Statement~~
, of Material Facts Not Genuinely In Issue i i
We are attaching the original certification and deposition for subject Answers.
I' Respectfully submitted, CASE (Citizens Association for Sound Energy)
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. (Mrs .) Juanita Ellis President l
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L-UNITED STATES OF AMERICA ., ,
NUCLEAR REGULATORY COMMISSION i j i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of I I
APPLICATION OF TEXAS UTILITIES I Docket Nos. 50-445 GENERAT.NG COMPANY, ET AL. FOR AN I and 50-446 OPERATING LICENSE FOR COMANCHE I PEAK STEAM ELECTRIC STATION I UNITS #1 AND #2 (CPSES) I CERTIFICATE OF SERVICE ,
By my signature below, I hereby certify that true and correct copies of CASE's Answer to Applicants' Motion for Summary Disposition of Intervenor's Contention 22 Regarding Emergency Planning & to Applicants' Statement of Material Facts day of August , 1982, by:.
have been sent to the names listed belo'4 this 30th Express Mail where indicated by
~~and First Class Mail elsewhere. .~~
~~~. . . _ . . _~~
~~Administrative Judge Marshall E. Miller David J. Preister, Esq. ,~~
Asnistant Attorney Geheral j U. S. Nuclear Regulatory Commission -
Atomic Safety and Licensing Board Panel Environmental Protection Division '
20555 P. O. Box 12548, Capitol Station p !hington, D. C. Austin, TX 78711 '
-
~~Dr. Kenneth A. McCollom, Dean Ms. Lucinda Minton -~~
Division of Engineering, Architecture, Panel Law Clerk and Technology Atomic Safety and Licensing Board Panel -l (
Oklahoma State University V. S. Nuclear Regulatory Conmission .
Stillwater, Oklahoma 74074 Washington, D. C. 20555 4
~~Dr. Richard Cole, Member Atomic Safety and Licensing~~
~~Atomic Safety and Licensing Board Board Panel~~
.U. S. Nuclear Regulatory Comminuion U. S. Nuclear Regulatory Commission W2hington, D. C. 20555 Washington, D. C. 20555
Nicholas S. Reynolds, Esq. Atomic Safety and Licensing Debevoise & Liberman Appeal Panel 1200 - 17th St., M. W. U. S. Nuclear Regulatory Commission , ,
~~WAchington, D. C.,, 20o36 Washington, D. C. 20555 -~~
~~Marjorie Ulman Rothschild, Esq. Docketing and Service Section~~
Office of Executive Iegal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission W:shington, D. C. 20555 Washington, D. C. 20555
( -.E XRrf.u _. A) Jua'ni~ta Ellis, President Dli ACASE (Citizens Association for Sound Energy)_
. e 6

ML20063J489

Text

SUMMARY

Dear Mrs. Ellis:

Dear Mr. Lockabaugh:

Dear Mr. Lookabaugh:

Dear Mr. Lookabaugh:

Dear Mr. Lookabaugh:

Dear A1:

GENERAL COMMENT

Dear Sir:

Subject:

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