ML20072F240
| ML20072F240 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/22/1983 |
| From: | ARGONNE NATIONAL LABORATORY |
| To: | |
| Shared Package | |
| ML20072F232 | List: |
| References | |
| NUDOCS 8306270308 | |
| Download: ML20072F240 (19) | |
Text
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4 4
ELEMENT-BY-ELEMENT REVIEW OF THE LILCO TRANSITION MODULE of the SHOREHAM NUCLEAR POWER STATION OFFSITE RADIOLOGICAL EMERGENCY RESPONSE PLAN June 22, 1933 i
I.
I i
(
Argonne National Laboratory 8306270300 830623 PDR ADOCK 05000322 F
PDR l
PREFACE This is a review of the LILCO-transition module of the Shoreham Nuclear Power Station Local Offsite Radiological Emergency Response Plan and Pro-cedures (Rev. 0), and Appendix A, Evacuation Plan, with Addendum. The review o
is presented in a chart format.
The first column, labeled "NUREG Ref erence,"
refers to those Planning Standards and Evaluation Criteria in NUREG 0654/ FEMA-REP-1, Rev.1, section II, which ar'e applicable to state or local governments.
The second column, labeled " Cross-Reference," refers to the section of the Plan corresponding to the NUREG Reference. The third column, labeled "Evalua-tion and Comments," states whether the element is adequate or inadequate ard includes relevant comments.
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ABBREVIATIONS App.
appendix BNL Brookhaven National Laboratory EBS Emergency Broadcast System EOC emergency operations center EOF emergency operations f acility EPZ emergency planning zone FEhA Federal Emergency Management Agency KI potassium iodide LERO Local Emergency Response Organization LILCO Long Island Lighting Company NRC Nuclear Regulatory Commission ORS off-site radiological survey REPP radiological emergency preparedness plan Sec.
Section SNPS Shoreham Nuclear Power Station
1 NUREG Cross-Reference Reference Evaluation and Comments A.I.a
- Sec. 1.4, p.
Inad equate; first, the plan does not 1.4-1-3 specify whether Suff olk County will or will Se c. 2.1, p. 2.1-1-7 not be part of the overall response organ-
- Se c. 2.2, p.
ization.
Instead, it leaves this as an 2.2-1-4 option, apparently to be decided during an accident.
The plan must define what role, if any, Suffolk County is to have.
Se cond,
the plan gives no explanation of the role New York State is to play. Although New York State has written its own Radiological Emergency Preparedness Plan (REPP), this plan does not mention it.
Therefore, it is unclear whether this plan is to operate in conjunction with the REPP, or whether this plan is intended to supplant it, covering both the State and local response.
If this plan is intended to be integrated with the REPP, it may conflict with the compensating measures of the REPP, which create a special concept of operations for situa-tions where counties decline or are unable to implement their response plans.
A.I.b Sec. 2.1, p. 2.1-1-7 Inad equate; this element is adequate, Se c. 2.2, p. 2.2-1-4 except that it omits a complete description of the operational role of Suff olk County.
In the event of an accident at SNPS, Suffolk County's place in the response must be defined in the plan.
Four possibilities i
l exist:
(1) Suffolk County may choose not l
to respond and may not be ordered to i
respond; (2) Suff olk County may choose not i
to respond voluntarily and may be ordered to respond by the Governor; (3) Suffolk County may choose to respond in accordance with this plan, such as by placing County resources and personnel at the disposal of the Director of Local Response; or (4)
Suffolk County may choose to respond in a manner not in accordance with this plan.
l While this plan is written on the assemption that Suff olk County either will do nothing or will respond in accordance with this plan (possibilities 1 and 3), the others are not covered.
The plan should prepare for these additional contingencies.
Moreove r, the concept of Suf f olk County 's i
. ~. -
2 NUREG Cross-Reference Reference Evaluation and Comments A.1.b (Cont 'd )
operations in case it responds in accordance with this plan is not suf fi-ciently detailed.
In several places, the plan states that various Suffolk County personnel will be used if they respond f or certain functions, but does not detail their role.
Thus, arrangements would have to be made to accommodate them on the spot.
Allowing SuffoDc County personnel to take over important response functions at the last minute seems certain to cause con-siderable confusion.
A.1.c Se c. 2.1, Fig. 2.1.1 Ad equat e.
Sec. 2.2, Fig. 2.2.1 A.1.d Sec. 2.1, p. 2.1-1 Inadequate; the title of an individual Se c. 3.1, p. 3.1-1 LILCO employee who will serve as the Procedure 2.1.1 Director of Local Response is not given.
A.1.e Se c. 3.3, p. 3.3-'1 Ad equa t e.
Sec. 3.4, p. 3.4-1,2 A.2.a Sec. 2.1, Fig. 2.1.2 Inadequate; first, the organizational Procedurc 2.1.1 matrix (Fig. 2.1.2) does not include a designation of responsibility f or taking protective actions, although Procedure i
2.1.1 states that this is the responsi-bility of the Director of Local Response.
l The matrix should be changed to reflect l
this responsibility.
Second, responsi-bility for emergency law enforcement j
activities is not assigned (Ref erence A.2.b).
No provision is made f or the likely need for large numbers of police officers.
For example, the assignment of traffic control responsi-bilities to persons who are not police officers is inappropriate given the l
necessity of blocking public thoroughf ares, l
ordering drivers to follow specified l
routes, and other extraordinary changes in
(
legal driving patterns.
A.2.b Sec. 1.4, Attachment Inadequate; first, the legal authority l
1.4-1 cited in Attachment 1.4.1 to the plan (10 C.F.R. 50.47) d oes not specifically grant the necessary police powers to a licensee
3 NUREG Cross-
- Reference Reference Evaluation and Comments A.2.b (Cont 'd )
to implement those aspects of an off-site emergency response requiring the exercise of governmental authority. Second, the underlying assumption of both FEMA and NRC off-site emergency preparedness regulations is that the responsibility for responding to a radiological emergency at a commercial nuclear reactor rests cooperatively with State, local, and federal governments.
Part I.F. of NUREG 0654/ FEMA-Re p-1, Rev. 1, states at p. 22-23 that "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 9 hen the response by all parties is fully inte-grated." Part 1.H. emphasizes at p. 25 that "NRC and FEMA agree that the licensees of nuclear f acilities have a primary responsibility for planning and implement-ing emergency measures within their site boundaries" (emphasis in original).
In designating an emergency response organiza-l tion relying exclusively on LILCO employees, this plan contravenes these standard s.
A.3 App. B Inadequate; no written agreements are included in this plan.
A.4 Se c. 2.1, p. 2.1-2 Ad equate.
l C.1.a Sec. 3.11, p. 3.11-1 Adequate.
C.1.b Sec. 2.2, Attachment Ad equat e.
2.2.1 l
C.I.c Sec. 3.11, Attach-Adequate; this is primarily a State func-l ment 3.11.1 tion, but the local pian lists additional i
resources.
C.2.a
l C.3 Sec. 2.2, *At tach-Adequate; however, the availability of ment 2.2.1 radiological laboratories is not speci-Sec. 3.5, p. 3.5-2 fically addressed.
4 NUREG Cross-Reference Reference Evaluation and Comments C.4 Sec. 2.2, p. 2.2-1-4 Inadequate; no letters of greement are Se c. 3.5, p. 3.5-2, included in the plan.
App. B 4
D.3 Sec. 3.2, p. 3.2-1-3 Ad equate.
D.4 App. C-List of Ad equate.
Implementing Irocedures Implementing Procedures E.1 Sec. 3.3, p.
/
.e.
3.3-1-4, Fig.
3.3.2-4 Procedures 3.3.1.
3.3.2 E.2 Sec. 3.3, p. 3.3-1-2 Ad equa te.
Procedures 3.3.1, 3.3.2 E.5 Se c. 3.3, p. 3.3-4-7 Adequate; radio station WALK is the Se c. 3.8, p. 3.8-6, primary EBS station to be tsed..8-1
- Procedure 3.8.2 Sec. 3.4, p. 3.4-5-6 E.6 Sec. 3.3, p. 3.3-4-7 Adequate; however (1) the plan states that Se c. 3.4, p. 3.4-5-6 a dedicated line is to be used to contact Sec. 3.8, p. 3.8-6 the EBS station from the EOC, whereas, in
- Procedure 3.3.4 Procedure 3.8.2, the Coordinator of Public
- Procedure 3.8.2 Information is instructed to call a regular telephone number. Moreover (2) the two procedures regarding notification and instruction -- Procedures 3.3.4 and 3.8.2
-- tend to overlap and conflict, especially with regard to the " fast track" procedure.
The two should be clarified and possibly combined.
Step by step procedures for the operator should be provided.
In addition, (a) the route alerting procedures in Procedure 3.3.4 and (b) the EBS activation in Procedure 3.8.2 incorrectly identify the
" FEMA operator" as authorized to activate EBS.
5 NUREG Cross-Reference Reference Evaluation and Comments E.7 Sec. 3.8 Inadequate; the system for identifying the Attachmen: 3.8.1 areas which are to take protective actions
- Procedure 3.8.2 is inadequate.
The messages designate alphabetical zones and refer listeners to brochures, telephone book inserts, and posters.
The zone designation maps in the poster and especially in the telephone book insert are difficult to read.
The written messages should give descriptions of the protective action areas. Evacuation routes should also be described in those messages to which they apply.
Reliance on the information brochure is not adequate.
F.1.a Se c. 3.3, p. 3.3-1-2 Ad equat e.
Sec. 3.4, p. 3.4-1-2 F.1.b Se c. 3.3, p. 3.3-3 Ad equate.
F.1.c Sec. 3.4, p.
Inadequate; no radio or dedicated telephone 3.4-1,4, links to any federal agencies are listed.
Fig. 3.4.1 F.1.d Sec. 3.4, p.
Adoquate; however, the plan leaves unclear 3.4-1-4, how communications with BNL field monitor-Fig. 3.4.1 ing teams will be ef f ected. Will they be equipped with LILCO emergency band radios?
F.1.e Se c. 3.3, p.
Adequate.
3.3-1-4, Figs. 3.3.2-l 3.3.4 Procedure 3.3.2 Se c. 3.4, p. 3.4-4,5 i
F.2 Sec. 3.4, p. 3.4-3 Inadequate; the plan essentially repeats the criterion, without explaining how it will be met, Detail is needed with respect to what medical f acilities are involved, and how communication with each will be effected.
i F.3 Sec. 3.4, p. 3.4-7 Ad equate.
Sec. 5.2, p. 5.2-2
- Procedure 3.4.1
6 NUREG Cross-Reference Reference Evaluatien and Comments G. I.a-d Sec. 3.8, p. 3.8-1-3 Adequate; however, see evaluation under NUREG Reference G.2 for comments related to the " Emergency Procedures" documents.
G.2 Se c. 3.8, p. 3.8-1-3 Inadequate; the " Emergency Procedure"
- Procedure 3.8.1 documents are incomplete.
Tht brochure is missing all specific information including
~
transmittal letter; other participants in the Emergency Broadcast System; detailed zone and evacuation maps; and identifica-tions of Relocation Centers, school districts and schools.
The response card for people requiring special emergency assistance does not have a line f or the person's name.
G.3.a Sec. 3.8, p. 3.8-4 Inadequate; although representatives of the
- Procedure 3.8'.1 news media would be at the Emergency News Center, the plan should designate that they will have facilities for their use, and what these facilities are.
G.4.a Sec. 3.8, p. 3.8-1 Ad equat e.
- Procedure 3.8.1 G.4.b Se c. 3.8, p. 3.8-4-5 Ad equate.
- Procedure 3.8.1 C.4.c Sec. 3.8, p. 3.8-5 Adequate; however, experience has shown
- Procedure 3.8.1 that rumor control cctivities are more effective if they are operated f rom one centralized location with one telephone number includ ed in all information distri-l buted to residents and available' to the transient population.
G.5 Sec. 3.8, p. 3.8-4 Ad equat e.
j
- Procedure 3.8.1 H.3 Se c. 4.1, p. 4.1-1 Adequate.
H.4 Sec. 4.1, p. 4.1-1 Ad equate.
H.7 Sec. 3.5, p. 3.5-2 Ad equate.
Procedure 3.5.1 Sec. 5.2 H.10 Sec. 5.3, p. 5.3-1-2 Adequate.
I
7 NUREG Cross-Reference Reference Evaluation and Comments H.11 Sec. 3.4, p. 3.4-1-5 Ad equat e.
Se c. 4.1, p. 4.1-3-4 Sec. 4.4, p. 4.4-1-4
- Procedure 5.3.1 H.12 Sec. 3.5, p. 3.5-2 Adequate; data and samples are to be col-lected at the local EOC.
However, the plan should clarify how plume data will be communicated to the local E0C.
(What radio system will be used by the BNL ORS teams?)
I.7 Se c. 2.2, p.
Adequat e.
2.2-3-4, Attach-men t 2.2.1 Sec. 3.5, p. 3.5-1-2 Se c. 4.4, p. 4.4-1 I.8 Sec. 3.5, p.
Inadequate; deployment times of monitoring 3.5-1-4, teams are not estimated and the plan does Procedure 3.5.1 not indicate where to pick up the monitor-ing kits.
1.9
- Se c. 2.2, At tach-Ad equa t e.
me nt 2.2.1 I.10 Procedure 3.5.2 Adequate; however, except f or radioiodine, Se c. 3.5, p. 3.5-3,4 no procedure is described for determining Se c. 3.6, p. 3.6-3,4 dose rates f or significant isotopes listed in NUREG-0654, Table 3.
I.11 Sec. 2.2, Attachment Adequate.
l 2.2.1 l
Sec. 3.5, p. 3.5.2 l
(
J.2 Sec. 3.6, p. 3.6-8 Inadequate; criterion stipulates that l
alternate routings be identified for
" inclement weather, high traffic density, i
and specific radiological conditions." No such alternates are described here.
The I
one route described in the referenced section could pass directly through the release plume, or could encounter heavy traffic conditions on the Floyd or Long
, Island Expressvays if an evacuation is in progress.
J.9 Se c. 3.6, p. 3.6-1-8 Ad equate.
l
8 NUREG Cross-Reference Reference Evaluation and Comments J.10,a App. A, Figs. 9-10, Inadequate; while evacuation areas, evacua-12-27 tion routes, and relocation centers in host Se c. 3.5, Fig. 3.5.1 areas are shown, public shelter areas are
- App. A, Fig. 11 not shown.
Fig. 3.5.1 is missing f rom the
- Procedure 3.5.1, review copy of the plan, but an unnumbered 0 figure entitled SNPS EPZ (Nov 82) is in-cluded which d oes show where the monitoring points are.
(These points are also listed in Attachment 10.)
J.10.b App. A, Table 3 Adequate; meets criterion as stated. H ow-Sec. 1.1, Fig. 1.1.2 ever, population by evacuation area is shown in a table rather than on a map.
For two evacuation areas, population is broken out by subarea but maps indicating the boundaries of these subareas should be referenced.
Further, while residential population is apparently shown, total daily population (accounting for employee popula-tion in the EPZ and peak summer weekend transient population) is not.
J.10.c Sec. 3.3, p. 3.3-4-6 Inadequate; no specific provisions are discussed f or alerting deaf or hearing-impaired individuals.
In the LILC0/ County plan, it is indicated that the Suff olk Co.
Fire Dept. would keep a list of those who are deaf or hearing-impaired in order to contact them during an emergency. No such list is indicated in this transition plan.
Further, while WALK is listed as the EBS station which will broadcast specific instructions to the public, the other stations which will be broadcasting this inf ormation should also be listed.
In addition, Fig. 3.3.6 referred to on p.
3.3-5 is supposed to illustrate procedures in case tha initial notification from the i
plant is of a general emergency; it does not.
l J.10.d Sec. 3.6, p. 3.6-4-5 Inadequate; hospitals, adult / nursing homes,
- Procedure 3.6.5 group homes for the handicapped and cor-
- App. A, pp.
rectional f acilities are identified and AII-28-30 procedures f or their evacuation (sheltering in the case of the correctional f acilities) are discussed. Evacuation of invalids /
disabled people from private residences is i_
9 4
NUREG Cross--
Reference Reference Evaluation and Comments J.10.d (Cont 'd )
cove red.
However, specific resources i
j required to evacuate these f acilities (i.e., the number of buses and ambulances required, the number of runs they will make, the number of drivers required, how many trains will be brought in by Loag Island Railroad under different scenarios to evacuate hospitals) are not provided.
Further, with respect to evacuation of mobility-limited f rom private residences, the interim plan apparently assumes that individuals who do not answer the phone (if called by LERO to determine if they want evacuation help) are not at home - which may not always be the case.
~J.10.e Sec. 3.6, p. 3.6-5 Inadequate; the quantity stored by LILCO Procedure 3.6.2 is not specified. Furthermore, the use f or institutionalized persons in the plume is not discussed.
J.10.f Se c. 3.6-3,5 Inad equate; the text (p. 3.6-5) says that the radiation health coordinator (BNL) is responsible for decisions on KI.
Procedure i=
3.6.2 says that the health services co-ordinator is responsible for these decisions.
It does not seem appropriate to have someone from BNL in charge of deci-sions on the use of KI.
Where is this authority vested, if legal problems arise?
J.10.g App. A, Sec. IV Inadequate; the detail provided with Sec. 3.6, p. 3.6-6,7 respect to the provision of transportation
- App. A, Sec. III, service to the general population without
- p. AIII-36 access to personal vehicles is excellent:
estimated service demand, number of buses and runs. required, route times, bus routes, and transf er points are provided f or each evacuation area. However, the specific resources (vehicles and drivers) required to provide this service are not identified:
no formal agreements have been made f or provision of the service.
Further, while in general, emergency dismissal of schools with children returning to their homes is the approach to be taken in this EPZ, (a) there is no indication that formal agree-ments have been made with the bus companies
- _ ~,.. -. - -
.v.
L,.
10 NUREG Cross-Reference Reference Evaluation and Comments
- w y.10.g (Cont 'd )
(if buses are not owned by the schools) and drivers that would ensure that this service would be provided during a radiological t
\\
emergency and (b) there are a few schools (St. Anselm's Nursery School, f or example,
- p. AIV-184) in the area adjacent to the plant that may require buses f or evacuation to a relocation center, but the resources for these buses are not identified.
v Identification of resources to evacuate institutionalized population is also not adequate (see J.10.d).
Further, with
~\\
respect to the bus service to be prcvided N,
to the noninstitutionalized population, (a) no indication is given that the route times have been tested and (b) service demand apparently is based on nonseasonal popula-
+
tion: it may be somewhat higher in the 1
summer.
J.10.h Ap p. A. p. AIII-8 Inadequate; three relocation centers (and Sqc. 4.2, p. 4.2.1 two alternativas) have been selected which are at least 5 miles beyond the boundaries
~~
s of the plume exposure EPZ.
- However, letters of agreement are not provided indi-cating that centers' f acilities will be V
made available.
App. A, p. AIII-8, cross-referenced in the plan, has no bearing on the NUREG element.
i J.10.1 App. A, Sec. III, l
Table IV Ad equate.
y App.',,Sec. IV,
- s A
Inadequate; with respect to traffic J.10.j i Firs. 8, 8.1
' control, traffic control guides will not l ',
be able to put signals on " flashing" opera-
, atc. 3.6,
,' tion as could be done by police in LILC0/
Ly s, p. 3.6-6,7
- P,rocedure 3.3.2 County plan (Reference A.2.b).
This is a
- Procedure 2.1.1, disadvantage since existing signals may be l
- p. 28 counter to the control stragegy the guide s
, ~_, '
f
- is trying to implement.
The confusion
~
which may be generated by traffic signals l
t^
differing from traffic control guide T
e
' L' ?
strategies could reduce intersection 1
capacity and increase evacuation time.
Further, with respect to access control,
.h LERO guides will not be perceived by I
g
,s s
- -a, 11 NUREG Cross-Reference Reference Evaluation and Comments J.10.j (Cont 'd )
public as having the same authority as policemen.
Additionally, perhaps the criteria used'in the selection of the traffic guides should be indicated, i.e.,
reasonable proximity of their residences to the posts they will staff is necessary, especially in non-work-hours deployment.
J.10.k Sec. 3.6, p. 3.6-6 Inadequate; no discussion of means f or App. A, p. AIV-9, snow removal is provided.
The number of A1V-86 LERO tow trucks available to respond to
- Ap p. A, Se c. IV,.
vehicle disablements is not stated. The Fig. 8.1 plan states " radio for tow trucks or any
- App. A. p. A1V-5 other assistance required" but does not
- Sec. 2, Fig. 2.1.1 indicate whether such radio communication between LERO and all tow ' trucks to be used (including private) is available.
Police cars, motorcycles, and ' helicopters were to ;
have been used in the LILC0/ County ' plan --
no indication is given that motorcycle's and helicopters will be available f or evacuak tion route patrol in transition plan.
Aertal observation would be a far superior
' and effective procedure.
Another concern is what the response of the general public will be to LERO route patrol vehicles, operating without police sirens and flashers (Reference A.2.b).
According, to Sec. 2, Fig. 2.1.1, there would be -
g
,\\
only 2 e,vacuation route spotters to patrol 10 evacuation routes.
This is insuf ficien t.
J.10.1 App. A, Sec. V Inadequate; time estimates are not shown -
- App. A., App. E for the following distinct groups as
- Procedure 3.6.1, stipulated in App. 4 of NUREG-0654:
p p. 15-18 permanent population, transient population, special f acilities p'opulation.
The time required to evacuate the transit-dependent
. population has apparently not been speci-fically incorporated into these estimates though the capacity estimates of the road-
- waysido account for1the presence of buses, ambulances, etc. Taible DHS-11'd oes not include an estimated time for the evacua-tion of all zones though App. E does f or all sectors.
(Table LHS-Il is to be used r
e-e.-
,w m
we w-,
,,w r--,,
t,
p-
,,w-r a.-w-,,-,,,.,,---ne
-~--.+---n
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12 NUREG Cross-Reference Reference Evaluation and Comments J.10.1 (Cont 'd )
during the course of a radiological emergency to determine whether or not to shelter or evacuate various zones.) There is no way to compare the results shown in Sec. V and App. E with those shown in Table DHS-11.
The time estimates shown in Table DHS-11 are shown f or weekdays and week-nights, yet the time estimates in Sec. V and App. E, upon which Table DHS-11 pre-sumably would have been based, do not make this distinction.
Further, Sec. V indi-cates the study assumed school was in session even in the summer: why should this assumption be mad e?
J.10.m Sec. 3.6, p.
Mequate.
3.6-1-4, Fig. 3.6.1 J.11 Sec. 3.6, p. 3.6-7-8 Mequate.
Procedure 3.6.6 J.12 Sec. 3.9, p. 3.9-5-6 M equa t e.
3
- Procedure 3.9.2 K.3.a Sec. 3.9, p. 3.9-1-3 Mequate.
Procedure 3.9.1
/Sec. 4.4, p. 4.4-1 f,
l K.3.b Sec., 3.9, p. 3.9-1-3 Inadequate; readings taken at 30-minute
(
intervals may not be frequent enough to allow informing supervisor in a timely f ashion that a person has exceeded 150 mR and should leave the radiation area.
3 Frequency of readings is dependent on the dose rate which the person is receiving.
K.4 Se c. 3.9, p. 3.9-2.
Mequate.
K.5.s Sec. 3.9, p.
Inadequate; it is not apparent why there 3.9,3,4, are two thyroid radiation levels at which Table 3.9.1, evacuees are sent to the hospital, 0.13 mR/
Table 3.9.2 hr and 10 rads.
Furthermore, it is not
- apparent that cumulative dose will be known for evacuees.
j n,.
i
.4 I
ie 4
- 6-.- - -. -
13 NUREG Cross-Reference Reference Evaluation and Comments K.S.b Sec. 3.9, p. 3.9-4 Ad equa te.
Procedure 3.9.2 Se c. 4.3, p. 4.3-1-3 L.1 Sec. 2.2, p. 2.2-2 Adequate; however, it is not clear whether Se c. 3.7, p. 3.7-1 the trained emergency medical technicians are LILCO employees, employees of hospitals, or otherwise employed.
L.3 Procedure 4.2.2 Adequate; however, the 47 hospitals should be listed by rank according to their capability to provide radiation health service s.
L.4 Sec. 3.7, p. 3.7-1 Inadequate; the private ambulance organiza-tions should be listed together with the field medical services they can provide, especially in cases of radiation contamina-tion.
M.1 Se c. 3.10, p.
Ad equate.
3.10-1-2
- Se c. 3.11, p.
3.11-1-2 Procedure 3.10.1 M.3 Sec. 3.10, p. 3.10-1 Ad equate.
i l
M.4 Se c. 3.10, p. 3.10-2 Ad equate.
i N.I.a Sec. 5.2, p. 5.2-3 Ad equa te.
1 N.1.b Sec. 5.2, p. 5.2-3 Adequate N.2.a Sec. 5.2, p. 5.2-2 Inadequate; d oes not provide f or quarterly
- Procedure 5.1.1, testing of communications with the federal Sec. 5.2.1.5 emergency response organization and states I
within the ingestion pathway; does not provide f or understanding the content of messages.
N.2.c Se c. 5.2, p. 5.2-2 Ad equate.
- Procedure 5.1.1, Sec. 5.2.1.6 N.2.d Sec. 5.2, p. 5.2-2 Ad equate.
- Procedure 5.1.1, Sec. 5.2.1.2 l
,q,
-r
_y..._
14 1
NUREG Cross-Reference Reference Evaluation and Comments N.2.e(1)
Sec. 5.2, p. 5.2-2 Ad equa t e.
N.3.a-f Se c. 5.2, p. 5.2-1 Inadequate; does not include provisions to
- Sec. 5.2, p.
allow f ree play f or decisien making.
5.2-2-3
- Procedure 5.1.1, Sec. 5.2.3 N.4 Sec. 5.2, p. 5.2-3-4 Inadequate; confusing as to who does the
- Procedure 5.1.1, post-exercise critique and formal written Sec. 5.2.3 critique. The procedures have the critique
- Procedure 5.1.1, done by Emergency Planning Coordinator.
Sec. 5.2.4 This element calls f or a critique by federal, state, or local governments.
Federai exercise observers do not comment on the Controller / Observer comment f orms.
N.5 Sec. 5.2, p. 5.2-4 Inadequate; does not provide for means to
- Procedure 5.1.1, evaluate federal observer commente.
Sec. 5.2.4
- Procedure 5.1.1, Sec. 5.2.5
- Procedure 5.1.1, Sec. 5.4.1 0.1.b Sec. 5.1, p.
Adequate; however, courses f or training of l
5.1-1-7, nonprofessionals in transportation emergen-Table 5.1.1 cies and accident assessment activities are
- Procedures 5.1.1-shown as being still "under development."
5.1.5 0.4.a Sec. 5.1, p.
Adequate.
5.1-3-7, Fig. 5.1.1-7
- Pr ocedures 5.1.1-5.1.5 l
0.4.b Sec. 5.1, p.
Inadequate; monitoring teams do not have a j
5.1-3-7, specific module to attend.
l Fig. 5.1.1 0.4.c Se c. 5.1, p.
Ad equate.
5.1-3-7, Fig. 5.1.1 0.4.d Sec. 5.1, p.
Adequate.
l 5.1-3-7, Fig. 5.1.1 l
l n
15 NUREG Cross-Reference Reference Evaluation and Comments 0.4.f Sec. 5.1, p.
Inad equate; courses still under develop-5.1-3-7, ment, program not clearly defined. No Fig. 5.1.1 training shown f or nonprofessional fire-.1.1 fighting and rescue personnel.
0.4.g Sec. 5.1, p.
Mequate.
5.1-3-7, Fig. 5.1.1 0.4.h Se c. 5.1, p.
Mequate.
5.1-3-7, i
Fig. 5.1.1 0.4.j Sec. 5.1, p.
Mequate.
5.1-3-7, Fig. 5.1.1 0.5 Se c. 5.1, p. 5.1-1-7 Meguate.
P.1 Sec. 5.1, p. 5.1-2 Mequate.
- Se c. 5.1, p. 5.1-3,
'.1.1
- Procedure 5.1.1 i,
P.2 Sec. 5.4, p. 5.4-1 Mequate.
- Procedure 5.4.1 P.3 Sec. 5.4, p. 5.4-1 Mequate.
- Procedure 5.4'.1 P.4 Sec. 5.4, p. 5.4-1-2 Mequate.
- Procedure 5.4.1 P.5 Sec. 5.4, p. 5.4-1,2 Mequate; add sentence stating that revised
- Procedure 5.4.1 pages, (not just documents) should be dated and marked to show where changes have been mad e.
P.6 Sec.1.4, Attachment Mequate.
1.4.2 l
P.7 Procedures, Appendix Mequate.
C f
P.8 Table of Contents Inadequate; cross-referen'ce missing many Cross-Reference citations, especially procedures.
Items with an asterisk in the Cross-Reference column are not included in the Cross-t i
m
16
)
NUREG Cross-Reference Reference Evaluation and Comments P.8 (Cont 'd )
Reference Lists in the plans.
They were identified during the review process and should be incorporated in the appropriate Cross-Reference List.
P.10 Se c. 5.4, p. 5.4-2 Adequate.
- Procedure 5.4.1
- Not included on NUREG Cross-Reference List which is provided in plans.
j f
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