ML20080K202

Forwards 830916 Interim Finding on Util 831227 Addendum to Interim Finding,Comments on El Quarantelli Rept & Response to Civil Defense Concerns,Per NRC 830325 Request. Test Plan Exercise Scheduled for 840208

ML20080K202
Person / Time
Site:	Waterford
Issue date:	02/07/1984
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8402150332
Download: ML20080K202 (72)

Text

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j M1 Federal Emergency Management Agency Washington, D.C. 20472 8,f p p FEB 7 1984 MEMORANDUM FOR: Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S uclear Re ulatory Commission

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FROM: mm Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

Interim Finding on Waterford III Steam Electric Station The Federal Emergency Management Agency (FEMA) transmits to the Nuclear Regulatory Commission (NRC) the attached Interim Finding on Waterford III Steam Electric Station dated September 16, 1983, an addendum to the Interim Finding dated December 27, 1983, and comments on the E.L. Quarantelli Report entitled: " Evacuation Behavior: Case Study of the Taft Louisiana Chemical Tank Explosion Incident."

These attachments include a response to the concerns raised by the St. John the Baptist Parish Civil Defense Director as requested in your memorandum of March 25, 1983.

FEMA Region VI staff and the State of Louisiana are continuing discussions on several unresolved elements. When a resolution to these issues has been reached, an addendum will be forwarded to your office. Based on the Region VI review of the Louisiana and St. John the Baptist and St. Charles Parishes' off-site radiological emergency preparedness plans, there is reasonable assurance that the plans are adequate and capable of being implemented in the event of an accident at the site. An exercise to test these plans is scheduled for February 8,1984. A finding on preparedness will be made following this exercise.

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- Denton, Texas 76201 3698 January 17, 1984 MEMORANDUM FOR: RICHARD W. KRUDi, ASSISTANT ASSOCIATE DIRECTOR Office of Natural and Technological Hazards ATTENTION: Gloria Joyner, Program Specialist FROM: R. Dell Greer, Chief I Natural and Technological Hazards Division

SUBJECT:

Interiz Findings for Waterford III (Report of Professor E. L. Quarantelli entitled: " Evacuation Behavior: Case Study of the Taft Louisiana Chemical Tank Explosior Incident")

The attached review is to be included in previous submissions to complete the interim findings for Waterford III.

Region VI, at this time, sees no need to make any recommendations to Louisiana for plan changes around the Waterford III site due to the comments made in the Quarantelli report. Many of the problems sited in the report were covered by changes made to the plans since the Quarantelli report was made. Also problems will be eliminated due to the installation of the A/N system that has been completed since the report was made.

Region VI will be making a complete evaluation of the plans and the preparedness of the State and local parishes around Waterford III in the upcomins exercise to be held on February 8,1984.

A complete exercise report on the Waterford III Exercise will be prepared and furnished to FEMA National as soon as possible after February 8, 1984.

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Review of E. L. Quarantelli's final report of the Evacuation Behavior: Case Study of the Taft, Louisiana, Chemical Tank Expolsion Incident.

Throughout the report are discussions of the activities of the local emergency.

<- organizations, particularly their involvement in the large-scale evacuation that occurred as a result of the chemical explosion.

We have limited our response to Section VII of the report, "An Assessment of-

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Actions in the Incident," since we feel this covers the major discussion items made throughout the report.

VII. An Assessment of Actions in the Incident

1. How well-prepared were the organizations and the community for the ,

incident that occurred?

Discussion: The Quarantelli report states that for this locality, "There was better than average preparations." Therefore, we will not comment on this section except that FEMA will be evaluating the preparedness of the State and l

local parishes during the waterford exercise to be held on February 8, 1984, and will furnish a complete report of the exercise as soon as possible after its completion.

2. How well did the community and the organization learn about the threat?

Discussion: In the event that an accident happens at Waterford III, the public will be alerted by a siren system (now installed and operating, not officially tested) that covers the 10-mile EPZ. The sirens will be controlled and operated by parish emergency preparedness officials. Some fringe areas will be a'erted t

by portable sirens and other means. A Public Information Brochure will be dis-tributed to the public prior to the plant becoming operational. This brochure will describe to the public that if the siren system is sounded they are to listen to certain radio and T.V. stations'for instructions on what actions they.

are to take. There are also direct communication-link-ups between.the utility, local and State emergency operating centers so that infcrcation on the. conditions at the utility can be passed to the decisionmakers and then on to the public for actions to either evacuate'the area, take shelter or other procedures.

3. How well was the evacuation organized?

Discussion: As previously mentioned, the Public Information Brochure will have a map showing evacuation routes that people living in certain sections are to follow to a known reception center. Also-they are told-to listen to' Radio and T.V. stations for additional information on evacuation procedures ~to follow, f This PIB was not in the hands of the public during this~ evacuation. -In' addition,

, prewritten notification messages and-public information materials have been-l developed for the parish emergency plans. These messages specify the personal' 4

items that the public are to take with'them,' procedures to follow, and information about the reception centers to go to'if told to evacuate. JThis.information'will-be repeated regularly over the Emergency Broadcast-System (EBS) radio and T.V.

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ATTACHMENT (2)

4. How well were evacuees sheltered?

Discussion: The plans developed for Waterford call for reception centers (already pre-selected and identified) to be located outside the 10-mile EPZ.

These centers will be managed by emergency personnel of the parishes in which the centers are located. This should remove the only minor problem mentioned in the Quarantelli report that "the management of the shelters was criticized by some persons." The Quarantelli report had no major problems with this section of the evaluation; therefore, no further discussion will be offered on this.

5. How well handled was the return to normal?

Discussion: There are several points made in the Quarantelli report under this heading. One was the need for non-routine interaction among several key organiza-tions and key decisionmakers at the plant. The emergency plans for Waterford already specify a precise network of communications between the State, local parishes, and the utility. The type of information to be passed and the responsi-ble decisionmakers have been identified in advance, and technical support to the EOC is through established procedures.

Convergence at the local EOC's and dealing with the mass media personnel were additional problems.

In the future, security personnel will be stationed at the EOC's to allow entry to only those personnel who have proper identification. The waterford plans have an established method to cover the mass media situation; however, this pro-cedure has not been tested as yet.

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. n f T-7 Federal Emergency Management Agency Region VI, Federal Center,800 North Loop 288 Denton, Texas 76201 3698 December 27, 1983 MEMORANDUM FOR: DAVE McLOUGHLIN, Deputy Associate Director State and Local Programs and Support ATTENTION: Gloria Joyner, Program Specialist State and Local Programs and Support Na 1 and Technologica Hazards Division erry J

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, Reg FROM:

SUBJECT:

Addendum to Interim Findings on Waterford III Steam Electric Station An interim fitJing on Waterford III Steam Electric Station was submitted to FEMA Headquarters on September 16, 1983. The plan review discovered that there were still remaining elements that proved to be inadequate or that needed further explanation. To resolve those remaining deficiencies, FEMA Region VI held a meeting November 8, 1983, in Dallas, Texas, with representatives from the State of Louisiana. Also in attendance were representatives from Louisiana Power and Light Company (LP&L), Argonne Lab, and Region VI RAC.

Attachment I provides a list of those unresolved elements that were specifically discussed at the November 8, 1983, meeting and progress made on resolving those.

elements. As noted, several of the elements have since been resolved while the remaining ones have been agreed upon but resolution not yet completed.

Attachment II is the formal submittal of the State of Louisiana comments to the Consolidated RAC Review (Interim Finding dated September 16, 1983) and also a response to concerns and resolutions pertaining to St. John Parish. FEMA Region VI is satisfied that all concerns pertaining to St. John Parish have been resolved.

You should note that the State of Louisiana included additional information and clarification on the following elements which were previously evaluated as ade-quate by FEMA Region V1. Those elements are as follows: A.l.d., C.2.a., D.4.,

F.1.d., G.I., G.4.a., H.10., 1.8., J.10.i., J.10.1., J.12., K.4., 0.1., P.3., P.8.

Also, please be advised that my staff is in the process of developing a written response pertaining to the Quarantelli Report per your memo dated November 23, 1983. Those comments will be forthcoming as scon as possible.

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Dave McLoughlin Page 2 i

We will continue to maintain close liaison with the State of Louisiana to ensure that the remaining elements are completed to our satisfaction and will notify FEMA National accordingly.

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Should you have any questions pertaining to this information, please contact Mr. Al Lookabaugh, Chief, Technological Hazards Branch.

Attachments J

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WLIERFORD III DISCUSSION OF UNRESOLVED ELEMENTe j A.2.a. Resolved RAC comment: Most agencies do not mantion key individuals by title.

Resolution: The State of Louisiana brought to our attention that key state individuals are specified in the State-Implementing Procedures. Also key Parish individuals are specified in the Parish Implementing Procedures. A cross-reference to indicate.this.will be added to the State Plan.

A.3. Resolved RAC comment: EPA is not listed among the organizations to support the plan.

Resolution: EPA was not listed because DOE and FEMA-are specified as the lead agencies.in the State plan. Support from other agencies will be coordinated through these two Federal agencies. Also, FEMA Region VI agrees that REACT' is not expected to be used by the parishes in emergencies and references to REACT should be dropped in the next revision to the State Plan.

RAC comment: Letters of Agreement need to be formalized and updated before the Plan can be considered to be complete.

This includes updating letters as needed.

, Resolution: State of Louisiana forwarded to FEMA dated November 16, 1983, a copy of all Letters of Agreement that are currently on file at LNED. All letters will not be incorporated in the plans but rather a list will be used to illustrate which letters are on file. State of Louisiana agrees to update Letters of Agreement as necessary and r verification by FEMA would be available for inspection.

Relative to the ambulance service agreements for responding to an accident at Waterford III, an intra-parish mutual aid agreement currently exist which specifies general ambulance support between parishes. This agreement is through the Southeast Louisiana Emergency Medical System Council. FEMA Region VI has reviewed this mutual aid agreement document and approves of it.

C l.b. In agreement but resolution not t>mpleted RAC comment: Inadequate until plans / agreements are completed relating _to specific Federal resources ~ expected.

Resolution: The State of Louisiana has said that resource request will be specified when known to the Louisiana Nuclear Energy Division through final version of the Federal Radiological Monitoring and Assessment Plan'(FRMAP). FEMA'

, Region VI staff and RAC agrea with the State of Louisiana.

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C.l.c. In agreiment but resolution not yat completed RAC comment: Specific support resources are to be out-lined in Letters of Agreement which have not been completed.

Incorrect cross-references.

Resolution: FEMA Region VI staff and RAC agree with the State of Louisiana that only after the final version of the Federal Radiological Monitoring and Assessment Plan should.

specific State and local resources be available to support the Federal response. Reference to Letters of Agreement in Section VII.A.4., page 40, will be deleted in the next revision of the State Plan. Cross references will be corrected in the next plan revision.

C.3. In agreement but resolution not coepleted RAC comment: Plan needs more detailed description pertaining

-to the capabilities and availability of the labs.

Resolution: An updated Letter of Agreement relative to the LSU Nuclear Science Department lab capability will be com-pleted and amplified with the State of Louisiana. Also'the concept of a mobile laboratory has been: dropped by LNED and will be deleted in the next revision of the State Plan.

Samples will be taken back to the Baton Rouge lab which is only an hour's drive.

C.4. Resolved:

RAC comment: No Letters of Agreement found in the Southern.

Mutual Radiological Assistance Plan. Also Letters of Agree-ment with hospitals need to be completed. No specific arrangements for emergency support by other local organiza-tions or individuals could be found in plans.

Resolution: The Southern Mutual Radiological _ Assistance Plan constitutes an agreement (covered by law)~that has been signed by the governors of the respective states. Letters of Agreement with the hospitals and nursing homes have been completed and will be submitted wi,th the other letters. FEMA. ,.

Region VI has since received the hospitals' Letters of Agree-ment. Request for outside resources is detailed in Parish Implementing Procedures and response time has been anticipated.

Also State and Parish Implementing Procedures provide methods for detailing anticipated resource' requirements at different emergency classifications. This.information will be'trans--

mitted to,the proper response organization prior'to exhausting available resources. Thus FEMA Region VI is satisfied that this element has been met.

E.1. Resolved RAC comment: Message verification was not. clear in the plans.

Also EPA has no defined role in plan.'

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E.1. Resolution: The operational Hotline is a self-verifying (Continued) notification system. Initiating calls can only be made from the plant. Also, each message form has a commercial telephone number available for verification. Also as stated in response to A.e., DOE and FEMA are the lead Federal agencies. Any supporting agencies will be notified through these two Federal agencies. Thus, FEMA Region VI

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is satisfied that this element has been met.

E.5. Resolved l 1

RAC comment: It is not clear that a joint public information center coordinates the information to be released. Also 1Lt should be made' clear which public information officers can approve information for release at local level.

Resolution: Federal guidance does not require a joint public information center. Protection action messages will be released-by local and State organizations via local media and EBS as appropriate. The St. Charles and St. John emergency plans call for the release of emergency public information through their respective parish public informa-tion officers. It is specified in the Parish Implementing Procedures that only the Parish President can authorize public information releases. Thus, FEMA Region VI is satisfied that this element has been met.-

H.ll. In agreement but resolution not completed a

RAC comment: What is the concept on kits? _ Plan might benefit-by describing what portion of this equipment is in kits and where those kits are.

Resolution: State of Louisiana states that emergency kits are in a foot locker. Some items are used regularly and are not locked in a kit. There will be a change in the plans to include a listing of all items. Will also change wording in the plan from " sampling supplies" to "LNED i Emergency Response Kits."

I.10. In agreement but resolution not completed RAC comment: Alternative methods for estimating' dose should be described in the plan. Also'the computer _may-not be available when needed.

Resolution: The_ procedures for estimating-dose are those incorporated by EPA-520/1-75-001, Appendix D. A hand l method _for estimating doses will be included in the next I

revision of the State Implementing Procedures.

J.2. Resolved l \

RAC comment: State Plan does not provide for provisions l l

concerning on-cite individuals at the plant.-

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1 J.2. Resolution: This criteria refers to the evacuation of l (Continued) on-site personnel to suitable off-site locations. It does not refer to arrangements for reception or sheltering of the general public in support parishes. Information is provided in Chapter 4.VI.F., enclosures 1 and 2, l demonstrates coordination between the Waterford III Plan and local plans for movement and handling of on-site l

l personnel who may need to be evacuated to an off-site location. Appropriate cross references to State Plan should be added to indicate this information is located in the parish enclosures. Thus, FEMA Region VI is satisfied that this element has been met.

J.9. In agreement but resolution not completed RAC comment: Section IV.A.6.b. of Chapter 7 needs to be revised. The dose levels mentioned there can in no way be considered " limits for routine operations" as stated. Also the note on page 8-5 regarding the bases for the PAG's needs to be expanded or placed elsewhere in the text.

Resolution: State of Louisiana explained the dose levels considered " limits for routine operations" and the EPA RAC representative then agreed. In next plan revision (Chapter 7, IV.A.6.b., page 7-7, the term "for routine operations" will be changed to "for the general population." Also.

(Chapter 7, IV.B.2.b.(1) page 7-9) the term "cvailable" will be changed to " warranted." A correction was agreed upon to change'the note on page 8-5 to indicate that such note is not correct for FDA which refers to critical re-ceptor but is correct for contaminated drinking water supplies. Not correct for food preventive PAG's. Appro-priate changes will be made in the next plan revision by the State of Louisiana.

J.10.e. In agreement but resolution ::ot completed RAC comment: Nowhere in either the State or parish plans does it provide for the quantities and storage of KI.

Also, additional cross-references'needed.

Resolution: Next revision of plan will include a statement

" Quantities of KI, sufficient to meet short term off-site contingencies, will be made available to St. Charles and St. John Parishes by Louisiana Power and Light for storage in their EOC's, and will be administered at the order of the ASOEA in accordance with State policy.

J.10.m. In agreement but resolution not completed I

RAC comment: Interpretation of projected dose must be l clearly-understood by the decisionmakers and carefully  ;

spelled out in the plan. l

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' J.10.m. Resolution: State of Louisiana has agreed to put.a full (Continued) definition of projected dose in a footnote, referenced, and defined in Tab 1, Chapter 6 and 7, in the next re-vision of the State Plan.

L.1. In agreement but resolution not complete RAC comment: There should be a statement in the plan to verify the capability of Ochsner Clinic.

Resolution: State of Louisiana agreed to put a statement of capability in the next revision of the State plan.

RAC comment: Who is responsible for training?

Resolution: The entire issue surrounding training and who is responsible for specific training is still unresolved The Southeast Louisiana Emergency Medical Systems Council is very interested in providing training along with LNED.

A meeting is to be held the week of December 26 to determine who will be responsible for conductin-g specific training.

RAC comment: Are agreements signed with local ambulance services for responding to an accident at Waterford III?

None were in the plans.

Resolution: Intra-parish mutual aid agreements have been completed concerning ambulance support between parishes..

FEMA Region VI now has a copy of the ambulance agreement and approves it as being acceptable.

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November 16,1983 Mr. Al Lookabaugh FEMA, Region VI 800 N. Loop 288 Denton, Texas 76201-3698

Dear Mr. Lookabaugh:

Subsequent to the meeting held on November 8,1983, enclosed is the formal submittal of the State of Louisiana comments to the Consolidated RAC Review of the Louisiana Peacetime Radiological Response Plan, Revision 4, and Attachment 1. A few of the items discussed at the meeting remain open or are awaiting completion.

Please find enclosed, in bold print, the items identified during the meeting which require changes to the State Plan or Attachment 1.

Also enclosed, is our response to your Attechment 1 of the Consolidated RAC Review dated September 28, 1983, St. John the Baptist Pa'..sh Concerns and Resolutions.

If there are any questions or further information needed, please contact Mr.

Thomas Laiche at the address shown below.

Sincerely,

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William H. Spell W HS:TL:st Enclosures 1

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RESPONSE TO RAC REVIEW COMMENTS OF SEPTET 1BER 28g 1983 A.I .d The Director of the Bureau of Emergency Medical Services is identified in the Department of Health and Human Resources, Office of Hospitals, Bureau of ETIS Implementing Procedure;.

A.2.a Key state individuals are specified in the state implementing Procedures (IP's).

Key parish individuals are specified in the parish Imolementing Procedures (IP's). A cross reference will be added to the State P:a to indicate this.

A.3 DOE and FEMA are specified as the lead agencies in the state. plan.

Support from other agencies will be coordinated through these agencies.

A list of Letters of Agreement wul be added to the Plan. Copies of the letters and any verifying statements will be made available upon request.

REACT is not expected to be used by the parishes in emergencies and references to REACT will be dropped in the next revision to the State Plan.

C.1.b Resources will be specified, when made known to the Louisiana Nuclear Energy Division through final version of the Federal Radiological-Monitoring and Assessment Plan (FRMAP).

C.1.c State and local resources available to support the Federal response, will be outlined when Federal response resources and anticipated support needed are specified through final version of FRMAP.

Reference to letters of agreement in Section VILA.4, page 40 will be deleted in the next revision of the State Plan.

Correct cross reference as specified.

Attachment, page iii.

Change page number.

C.2.a Correct cross reference as specified.

Attachment, page iii.

Change page number.

C.3 State Plan Tab 3 to Chapter 6 G.2. page 6-13 Delete sentence which describes mobile laboratory.

Add a description of the LSU Nuclear Science Department capability to support LNED% emergency response.

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l l l C.4 Southern Mutual Radiological Assistance Plan (SMRAP) constitutes an l agree nent (see Chapter 2 of SMRAP) and has been signed by the governors

! of the respective states.

LOA with Hospitals and Nursing Homes have been completed and will be subinitted with the other letters.

Request for outside resources is detailed in parish IP's and response ti ne has been anticipated.

State and parish IP's provide methods for detailing anticipated resource requirements at different emergency classifications. This information will be trant.mitted to the proper response organization prior to exhausting available resources.

D.4 Add a cross reference to the State Plan that indicates this information this information is also available in State IP%.

E.1 The Operational Hotline is a self-verifying notification system. Initiating calls can only be made from the plant. Also, each message form has a commercial telephone number available for verification.

As stated in response A.3, DOE and FEM A are the lead federal agencies.

Any supporting agencies will be notified through these. Federal resource requirements will be listed as soon as they are made available to the LNED.

E.5 Federal guidance does not require a joint public information center.

Protective action messages will be released by local and state organizations via local media and EBS as appropriate. The St. Charles and St. John emergency plans call for the release of emergency public information through their respective 1arish Public Information Offices. It is specified in the parish IP's that only the Parish President can authorize public information releases.

F.1.d Correct cross reference as specified.

State Plan, page vii Attachment, page iv Add page number 3-3 Enclosure 2, change letter I to H G.1 Correct cross reference Attachment, page iv l G.1., add page number 24 G.4.a St. John the Baptist and St. Charles parishes reserve the right to maintain independent public information organizations. Infor nation released is specific to the individual parishes. A TWX capability has been established specifically for coordination of public information between organizations.

The Parish President, as the chief elected official, reserves the right by home rule charter to make this decision.' There may be situations where the designated spokesperson is not the public information officer.

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H.10 Correct cross reference as specified.

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State Plan, page vii Add - H.10 Chapter 6, page 6-13, Tab 3,G

! H.11 Enclosure 1 to Tab 3 of Chapter 6 11.B. page 6-17 Change title Sampling Supplies to LNED Emergency Response Kits These kits are maintained and inventoried in the LNED laboratory after use or semi-annually.

Parish emergency equipment is supplied and maintained by LOEP and is inventoried at each parish EOC after use or semi-annually.

1.8 Add anticipated response times for LNED personnel Add a cross reference to State Plan to show that call our list for LNED personnel is located in the State implementing procedures 1.10 The procedures used are those incorporated by EP A-520/1-75-001, Appendix D.

A hand method for estimating off-site dose projections will be added to State implementing procedures.

Add a cross reference to the State plan that indicates this information is available in the State IP's.

J.2 This criteria refers to the evacuation of onsite personnel to suitable offsite locations. It does not refer to arrangements for reception or sheltering of the general public in support parishes. The information provided in Chapter 4.VI.F, enclosures 1 and 2, demonstrates coordination between the W3 Site Plan and local plans for movement and handling of onsite personnel who may need to be evacuated to an offsite location.

Add a cross reference to the State plan to indicate this information is located in the Parish Enclosures J.9 The statement is intended to say that limitations to exposure for emergency workers will be imposed when radiation doses approach the 5 rem threshold. The intention is to be more conservative, rather than allow emergency workers doses to reach 25 rem.

Chapter 7, IV.A.6.b., page 7-7, change the term "for routine operations" to "for the general population."

Chapter 7, IV.B.2.b.(1) page 7-9, change the term "available" to

" warranted".

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i J.10.e Correct cross reference as specified.

State Plan, page viii Add - Chapter 9, V.B.2, page 9-9 Table to Chapter 9, page 9-13 Change the following:

Chapter 5 to Attachment I V.B.2.b., page 46 Delete the second sentence which reads, "This substance will be supplied by LN ED..." Add the following: " Quantities of KI, sufficient to meet short term offsite contingencies, is available at St. Charles Parish and St. John the Baptist Parish EOC's, and will be administered at the order of the ASOEA in accordance with state policy J.10.i The W3, Evacuation Time Estimate is referenced in the emergency plans and for the respective parishes and is available to those decision makers who J.10.1. will locate in the Parish EOc's.

J.10.m Tabs 1 and 2, Chapter 6, pages 6-7 through 6-10 explain the concept of P A G's. However, the PAG's are not the only criteria used in determining protective actions. The rish parishes use considerable flexibility in making decisions for protective actions.

A full definition of projected dose as stated in EPA-520/1-75-0001, September 1975, page 2.1 - 2.2 will be included in Tab 1, Chapter 6 and Tab 1, Chapter 7 of the State Plan.

J.12 Arrangement for the registering and monitoring of evacuees are available in the support parish plans. The radiation monitoring equipment is also described in support parish plans. Equipment is stored in the support parish Civil Defense offices, with back-up units available through the Louisiana Office of Emergency Preparedness.

K.4 State Plan Chapter 9,III.E. page 9-3, lines 4 and 5:

Change the work "will" to "may".

L.1 1. A statement to verify Ochsner's capability will be included in the revision of the State Plan.

2). Training for local and back-up medical services is provided for by the Southeast Louisiana Emergency Medical Systems Council.

3.) Intra parish mutual aid agrement exist which specifies general ambulance support between parishes. Training will be provided by the Southeast Louisiana Emergency Medical Systems Council.

4.) At this time, the State is re-evaluating its' position with regards to the use of the local hospitals to handle contaminated individuals.

Major hospitals that are near the Nuclear facilities are more capable of handling con; amination problems. Training at the major hospitals i 11-23-83 l

can be more comprehensive than trying to train a large number of smaller, local hospitals that may not be able to cope ivith a contamination situation. When a more definite decision is made Sy the state, you will be notified. Training vill be provided for through the state and the Southeast Louisiana Emergency 11edical Systems Council.

5). See answer number 4 above.

6). See answer number 3 above.

7). St. Charles and St. John the Baptist parishes are unique in their need and development of emergency plans. Yes, the EMS system was involved in the planning stages.

8). NUREG 0654 section L.1. requires the hospital and medical support be arranged for, and that personnel are trained for this support role.

It is our opinion that a description of how a local plan interfaced with the EMS system and how the parishes arrived a' their needs for medical manpower is not required for inclusion in the plans.

9). Medical attendants are provided with ambulances as a normal business procedures. Again, training for drivers and attendants is provided for by the Southeast Louisiana Emergency Medical Systems Council in coordination with LNED.

10). See answer number 1 above.

O.1 LNED has the responsibility of training. At this time, LNED and the licensee are developing a training program and timetable for upcoming training.

P.3 Correct cross reference as specified.

State Plan, page ix Change page number from 22 to 26 P.8 Correct cross reference as specified.

Attachment Add page numbers iv through viii 11-23-83

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ST. JOllN THE BAPTIST P\RISil CONCERNS AND RESOLUTIONS

1. Frequent :nalfunction of the operational hotline phone.

The initial problems encountered with the operational hotline have been resolved. The proper operation of the hotline is being confirmed through monthly tests leading to the Waterford 3 exercise-for-score. Following the exercise, the operational hotline will be tested in accordance with the guidance established in NUREG-0654. Any malfunctions discovered as part of the testing program will promptly be remedied by LP&L. ,

h in addition, a push-to-talk feature and a mouthpiece confidencer device have been installed at St. John's hotline station to reduce background noise from being transmitted through the system. Also, a feature is to be installed which will allow each hotline station to ring-up the Waterford site during an emergency.

2. Prompt notification of individuals in the fish camps within the 10-mile EPZ.

i LP&L has purchased a portable siren for St. John Parish which will be capable of -

notifying 75% of the camps located in the wetlands. 'LP&L is in the process of purchasing two helicopter mounted warning devices for St. John Parish and two for St. Charles Parish.

t to The Louisiana Nuclear Energy Division- has 'made contact with three State agencies. who operate helicopters: the louisiana ' State . Police, the -Louisiana Department of Wildlife and 1 Fisheries, and the Louisiana Department .of Transportation and Development. Each of these ' agencies has given assurance-l that helicopters will be made available .-in. the event of an emergency. In~

addition, St. John Civil Defense is seeking an agreement from a private provider for two helicopters to be used in an emergency. These private helicopters are

'" located several' miles be Jond the perimeter of the 10 mile EPZ and could-be made available on short notice. I i

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.: m 4 s Federal Emergency Management Agency 1 fg Federal Center Denton, Texas 76201 5 E Region VI ~ '

$ September 16, 1983 V.

MEMORANDUM FOR: DAVE MC LOUGHLIN Acting Associate Director [i d Support s

State and Local Progr ms j

Jerry Stephens

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FROM:  ;

Regional Directo V \

SUBJECT:

Interim Findington Waterford III Steam Electric Station k

Attached is a copy of the Federal Emergency Management Agency Region VI Radiological Assistance Conunittee, Argonne National Laboratory, and FEMn Region VI review of the State of Louisiana Peacetime Radiological Response Plan Revision #4 and the St. Charles and St. John the Baptist Parishes' emergency response plans. These off-site plans were developed and submitted to FEMA Region VI in accordance with Paragraph 350.7 of 44 CFR, Part 350 in support of the Waterford Plant.

The review of the plans was based on Section II (A through P), Planning Standards and Evaluation Criteria, NUREG-0654/ FEMA-REP-1, Rev.1.

Also in response to a memorandum dated March 25, 1983, from Edward L. Jordan to Richard W. Krimm, FEMA was requested to review the five concerns expressed by the St. John Parish Civil Defense Director and include our findings as a part of this interim finding.

We also had a concern brought up by Mr. Charles Hackney (NRC Regional Office, Arlington, Texas) to my RAC Chairman concerning how the personnel on the ships that are docked along the Mississippi (loading or unloading cargo) would be evacuated.

This item was discussed by the RAC Chairinan with State and local personnel who advised that the ships' personnel would be considered as part of the industry where the ships were docked. Therefore, the ships' personnel would be evacuated using the evacuation plan for that particular industry.

The inadequate elements discovered by the review of the State and Local Plans will be furnished to the State of Louisiana by letter for comment and/or corrections. We will naintain close liaison with the State to see that the inadequate elements are corrected to our satisfaction and will notify FEMA National at that time.

Based on the review of the State and Parish Off-site Emergency Response Plans, there is reasonable assurance that the plans are adequate and capable of being implemented.

Dave Mc Loughlin Page 2 Many of the remarks in the review of the plans indicate that several elements are inadequate due to the lack of letters of agreement. The State has assured FEMA that most of these letters have already been obtained and they are in the process of obtaining the remainder. They wished to obtain all letters before submitting them to FEMA.

Attachments 4

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, ST. JOHN THE BAPTIST PARISH CONCERNS AND RESOLUTIONS

1. Frequent malfunction of the operational hotline phone, ,

Initially the hotline had several malfunctions. However, the problem -

had been with the South Central Bell Telephone Company. The hotline is presently working satisfactorily; however, additional improvements are in the process of being added. A push-to-talk feature is on order with South Central Bell and will be installed in the very near future.

Also a feasibility study is presently being undertaken by the utility to assess providing St. John and St. Charles Parishes with the ability to ring up Waterford III plant during an emergency.

2. Prompt notification of individuals in the fish camps within the 10-mile EPZ.

1 The utility company has purchased a portable siren for St. John Parish which will enable them to warn 75% of the fish camps in question. This leaves approximately seven additional fish camps that will not be warned by this procedure. A letter of agreement is to be obtained between Louisiana Nuclear Energy Division ar.d the Louisiana Game and Fish Depart-ment regarding utilization of manpower in alerting these additional camps.

The State police also have given a verbal agreement to utilize some of their personnel to warn these camps. However, they have stated they would not furnish a letter of agreement for this purpose. One additional step is being looked into by the utility and parish which is to obtain a letter of agreement for the services of a private helicopter to be used tv notify these camps.

3. Availability of low-range self-reading dosimeters for St. John Parish emergency workers.

This concern is resolved. St. John Parish has now received a sufficient number of low-range self-reading dosimeters.

4. Communication and coordination between the Fixed Resoonse Teams of-the Louisiana Nuclear Energy Division, Louisiana Office of Emergency Pre-l paredness, and the St. John Parish E0C.

i j Louisiana Nuclear Energy Division and the Louisiana Office of Emergency l

Preparedness have agreed to assign an individual to the St. John Parish .

EOC so that coordination can be maintained between the field teams and the EOC's. LNED is also in the process of obtaining radio equipment-which will permit their field teams to communicate with the LNED field response center on 800 MHz band. Once this equipment is purchased and installed, a decision will be made to purchase equipment for the Parishes to allow them to monitor the 800 MHz band.

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- httachment1 Page 2

5. The time required for shutdown of the chemical plants (approximately 15-20 hours) and protection of the shutdown crews.

This concern is resolved. Plans are i conduct another training seminar for industries. The seminars will be developed and coordinated by the Louisiana Nuclear Energy Division, St. John and St. Charles Parish Civil Defense Directors, and the Louisiana Power and Light Company.

Another solution to this concern was to utilize industrial workers as emergency workers and the use of KI under State regulations.

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1 RAC REVIEW COMENTS LOUISIANA STATE PLAN '

l AND ST. CHARLES AND ST. JOHN THE BAPTIST PARISH PLANS ,

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WATERFORD III STEAM ELECTRIC STATION ,

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References:

e State of Louisiana Peacetime Radiolcgical Response Plan l Revision 4

e State of Louisiana' Peacetime Radiological Response Plan

] Revision 4, Attachment 1, St. Charles, Enclosure 1, and St.

j John the Baptist Enclosure 2, Parish Emergency Plans I

e State Implementing Procedures e St. Charles I'mplementing Procedures L

e St. John the Baptist Implementing Procedures Criteria: NUREG-0654, FEMA REP 1, Rev. 1

- The RAC and federal agency designation for the consolidated coments are as follows:

FEMA - Federal Emergency Management Agency NRC - Nuclear Regulatory Commission r DOE - Department of Energy ,

q EPA - Environmental Protection Agency FDA - Food and Drug Administration a DOT - Department of Transportation USDA United States Department of Agriculture .

ANL - Argonne National Laboratories j (FEMA Contractor) l i

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, ST. CHARLES AND ST. JOHN THC BAPTIST PARISH PLANS RAC CONSOLIDATED COMMENTS i

NUREG-0654 Element Agency Comments A.l.a. Adequate l A.l.b. Adequate A.1.c. Adequate

A.l.d. Adequate A.1.e. ,

Adeqeate i A.2.a. Adequate A.2.b. Adequate

! A.3. FEMA Inadequate, there are no agreements or letters of understanding included j in the two Parish plans.

l EPA Parish Plans (Chapter 8) list agree-I ments that will be entered into, but

! no evidence could be found that such i agreements have been finalized yet.

These agreements must be formalized i

before the plan can be considered to be complete.

! DOE Concept okay, but letters must be included.

ANL Inadequate, letters of understanding have not yet been developed. REACT is not included in the list of letters to i be prepared.

f A.4. Adequate I

C.l.a. N/A 1 C.l.b. N/A C.l.c. FEMA Specific local support resources are not included in the plans.

DOE Local requirement but not included in the plans.

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NUR'EG-0654 Element Agency Comments EPA Specific support resources are to be outlined in letters of agreement which have not been completed.

C.2.a. Adequate C.2.b. N/A C.3. N/A C.4. FEMA This element requires letters of agreement which are not found in the plans. Also, shouldn't the hospitals be added to the list?

EPA No specific arrangements for emergency support by other local organizations or individuals could be found in plans.

DOT Letters of agreement are still not in-cluded in the plans. Agencies have been identified and appear to include all of those needed.

DOE Adequate, but outside resources should be requested when it is apparent that local resources will be exhausted, not after they are exhausted, i.e., allow for response time.

ANL Inadequate, as noted in element A.3.,

letters of agreement have not been developed.

D.l. N/A D.2. N/A D.3. Adequate D.4. Adequate E.1. Adequate l E.2. Adequate E.3. N/A E.4.a.-n. N/A

, NUREG-0654 Element Agency Comments E.5. DOE It should be made clear which public information officers can approve information for release.

E.6. Adequate -

E.7. Adequate F.1.a. Adequate F.1.b. Adequate F.1.c. Adequate F.1.d. Adequate F.l.e. Adequate F.1.f. N/A F.2. Adequate F.3. Adequate 4

G.I. Adequate

. G.2. Adequate G.3.a. Adequate G.3.b. N/A G.4.a. DOE Adequate, but local press releases should be coordinated with State and utility public information officers.

ANL It is recommended that a change in wording be used in the cross-reference sentence, General, Chapter 1, V. ,B, 2, page 24. The words "his designee" in the sentence should be changed to public information officer. This will clarify.

who the designateo spokesperson is.

G.4.b. Adequate 1

G.4.c. Adequate

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G.5. Adequate l

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., NUREG-0654 Element Aggney Comments H.l. N/A H.2. N/A

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H.3. Adequate N.4. Adequate H.5.a.-6.c. N/A H.7. Adequate H.8. N/A H.9. N/A H.10. Adequate H.ll. NRC Adequate, however, Plan might benefit by describing what portion of this-equipment is in kits and where those kits are.

EPA Appropriate response equipment will be available, as listed in chapter 6, tab 3, enclosure 1, but the concept of kits (maintaining equipment in designated location where it is readily collectible) is not mentioned ~and evidently not planned.

ANL Inadequate, emergency supplies and protective equipment are not identified.

H.12. Adequately addressed in State Plan.

. I.l. N/A I.2. N/A I.3.a. N/A I.3.b. N/A I.4. and 5. N/A I.6. N/A I.7. DOE No capabilities but adequately addressed in State Plan.

I I.8. DOE No capabilities but adequately addressed in State Plan.

NUREG-0654 Element Agency Comments .

I.8. (Cont'd.) NRC What about estimated deployment times?

EPA Chapter 6 Tab 3, Item C, refers to procedures for notifying response team .

members, but no call lists, or referen.e '

to lists, couTif be found, nor any telephone.

numbers, response times, etc.

I.9. N/A I.10. N/A I.ll.

N/A J.1.a.-d. N/A J.2. FEMA Parish plans only state on page 114 (St. Charles) and page 210 (St. John) that "all arrangements for the reception and sheltering of parish evacuees will be handled by support parishes." Stated that shelter will be provided for the following parishes.

1. Jefferson

2. Orleans

3. La fourche

4. Tangipchoa Does not describe how this will be handled.

~ Nothing in parish plans relates to or provides for on-site individuals, etc.,

in meeting this element.

J.3.-8. N/A J.9. EPA Parish plans page 108 and 204.6.b.

relating to limitation to duration of exposures need to be revised. The dose levels mentioned there can in no way be considered " limits for routine operations" as stated. The guides are taken from the EPA Manual of Protection Action Guides and Protective Actions for Nuclear Incidents, EPA-520/1-75-001, and apply only to post-incident conditions.

Five rem WB and 25 rem thyroid dose are the upper limits of projected dose levels to population groups for which evacuation is not mandatory, and these limits are not related to emergency workers' doses.

M EG-0654 Element Agency Comments J.10.a. Adequate 1

J.10.b. Adequate J.10.c.

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Adequate J.10.d. Adequate J.10.e. FEMA Adequate, however, nowhere in the Parish plans does it provide for the quantities and storage of KI.

J.10.f. Adequate J.10.g. Adequate J .10. h . Adequate J .10. i . DOT The plan makes assurances that the

" Evacuation time estimate information is available to decisionmakers in the event of an emergancy requiring evac-uation. The only question is whether this constitutes substantial compliance with the regulatory requirement for inclusion in the plan.

J.10.J. Adequate J .10. k . Adequate

.J .10.1. DOT Same comments as J.10.i. above.

J .10. m. N/A J.ll. N/A J.12. DOE Adequate, however, additional details such as the approximate number of persons and support parish plans and procedures are needed.

K.l.-2. N/A K.3.a. Adequate K.3.b. Adequate K.4. Adequate K.5.a.-b. Adequate K.6.-7. N/A l

., NUREG-0654 Element Agency Comments L.1. tiPC Local and backup hospital and medical services are provided for. Question remaining, however, concerning assurances that persons providing these services are adequately prepared to handle contaminated . .

individuals. Who is responsible for training?

FEMA The same procedures for handling contaminated patients should be taught to both the hospital ER personnel and EMS personnel.

Again, who is responsible for training?

Agreements have been signed with Ochsner and West Jefferson General Hospitals.

What about agreements signed with local ambulance services?

HHS A progressive system for EMS has been developed in the southeastern region of Louisiana, of which St. Charles and St. John the Baptist are a part. The two parishes should have benefited from ,

this in their plan development. Was this EMS system involved in the planning stages?

There was no reference to this in relation to local and regional Medical Control and communications. It would be most beneficial in evaluating the local cap-abilities if a description of how the local plans interfaced with the Emergency Medical Service System.

Also it was not clear how the parishes arrived at the need for Medical Manpower on pages 151 and 248. Example, need two ambulances and twenty-six ambulance drivers. What about medical attendants for each ambulance?

Also the capability of the Ochnser Hospital should have been verified in the plans.

L.2. N/A L.3. N/A I

L.4. FEMA Adequate, however, plans do'not include .l l agreements signed with the local ambulance services for transportation.

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, NUREG-0654 Element Agency Comments M.l. Adequate M.2. N/A M.3. N/A 'l M.4. N/A N.l.a. Adequate N.l.b. Adequate i'

N.2.a. Adequate i

N.2.b. N/A N.2.c. Adequate N.2.d. Adequate N.2.e. N/A N.3.a.-f. Adequate N.4.-5. Adequate 0.1. FEMA Adequate, however, in general plan states that LNED and L0EP will provide training to the two parishes. Who is the lead agency on training?

0.1.a. N/A 0.1.b. Adequate 0.2. N/A 0.3. N/A.

0.4.a.-d. Adequate 0.4.e. N/A 0.4.f.-h. Adequate-0.4.i. N/A 0.4.j. Adequate P.S. Adequate P.l.-8. Adequate P.9. N/A l P.10. Adequate-l

LOUISIANA STAfE PLAN RAC CONSOLIDATED COMMENTS NUREG-0654 Element Agency Comments A.I.a. Adequate A.l.b. Adequate A.l.c. Adequate A.l.d. HHS Adequate, however, on page 30 of the State Plan, the Department of Health and Human Resources, Office of Hospitals, Bureau of Emergency Medical Services is assigned the responsibility for Health and Medical Services. Does the Bureau of Emergency l Medical Services have a Director or will a designated position in the Office of Hospitals be assigned this responsibility?

A.l.e. Adequate A.2.a. DOE Inadequate, most agencies do not mention key individuals by title. Agency roles are properly delineated but a point of contact and coordination is required.

ANL Inadequate, a list of key individuals by title should be included for tha organiza-tions shown in-the emergency function and j

, responsibility chart, Fig. 3., p. 39 of the State Plan.

A.2.b. Adequate A.3. DOE Inadequate, letters of agreement must be included in the plan, not just listed.

Agreements and procedures from other state agencies would be helpful even though not required.

EPA Chapter 14 of the Plan suninarizes the formal agreements that will be developed.

These agreements must be formalized before the Plan can be considered to be complete.

EPA is not listed among the organizations to support the Plan (table 1).

FEMA Letters of agreement need to be updated as stated in plans. No updates were in-cluded in the State Plan.

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NUREG-0654 Element Agency Comments A.3. (Cont'd.) ANL Inadequate, chapter 14 of the State Plan provides that letters of agreement will i

be developed. They, or a signature page should be included in the State Plan. .

A.4. Adequate C.l.a. Adequate C.l.b. DOE Inadequate until Plans / Agreements are completed.

C.1.c. EPA Specific support resources are to be out-lined in letters of agreement (page 40),

which have not been completed.

DOE Inadequate, letters of agreements not included.

i ANL Inadequate, letters of agreement identified in section VII, A.4, page 40, of the State Plan should be included.

C.2.a. Adequate C.2.b. N/A C.3. NRC State Plan assigns primary responsibility for environmental monitoring to LNED.

Principal laboratory for radiological analyses is LNED's lab in Baton Rouge. To the extent that backup labs, such as LSU's, would be relied upon, the plan would benefit from more detailed description of the cap-abilities and availability of these labs.

In addition, the capabilities for field analysis of samples, if that capability exists, should be described more thoroughly (mobil laboratory mentioned on page 6-13).

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DOE Not adequately described. Could be in-cluded with letters of agreement.

C.4. EPA Southern Mutual Radiological Assistance Plan identified for manpower support (page 41), but no letter of agreement was found.

No specific arrangements for emergency H support by other local organizations or individuals could be found. 1 00E Inadequate until plans and agreements i

are included.

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NUREG-0654 E?cment Agoncy Coments D.3. Adequate D.4. Adequate E.1. EPA Notification procedures are outlined in chapter 2. Initial notification form (tab 1 to chapter 2) does not specify message verification, although the Revision 3 version of this form did so. Verification of messages to State and Parish officials is stated to be detailed in the implementing procedures (page 2-3), but could not be found in attachment 1, " Notification Procedure" or in attachment 2. "Comunica-tions Procedure," which in any case are explicitly excluded as a formal part of the Plan.

EPA has no defined role in plan. If called upon, notification of EPA will evidently be done by DOE (page 40).

Resources relied upon will be listed in tab 6 to chapter 6, which, however, has not yet been developed.

E.2. Adequate E.3. through 4. N/A E.5. DOE Inadequate, it is not clear that a joint public information center coordinates the information to be released.

E.6. Adequate E.7. Adequate F.1.a. Adequate F.1.b. Adequate F.1.c. Adequate I F.l.d. Adequate F.1.e. Adequate F.1.f. N/A F.2. Adequate

NUREG-0654 Element Ag ncy CO.hments.

F.3. Adequate G.I. Adequate G.2. Adequate ', -

G.3.a. Adequate G.3.b. N/A G.4.a. Adequate G.4.b. Adequate G.4.c. Adequate G.5. Adequate H.l. N/A H.2. N/A H.3. Adequate H.4. Adequate H.S. and 6. N/A H.7. Adequate H.8. and 9. N/A

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. . FEMA Adequate, however, State Plan does not give a cross reference for this element. It is missing. The cross reference is Chapter 6, page 6-13, tab 3, G.

DOE Adequate, but cross reference should be included.

H.ll. EPA Appropriate response equipment will be available, as listed in Chapter 6, tab 3, enclosure 1, but the concept of kits (maintaining equipment in designated location where it is readily collectible) is not mentioned and evidently not planned.

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,, NUREG-0654 Element Agency Comments l H.12. NRC Plan might benefit by describing what portion of this equipment is in kits and where those kits are.

I.l. through 6. N/A I.7. Adequate I.8. EPA Chapter 6, tab 3, item C refers to procedures for notifying response team members, but no call lists, or reference to lists, could be found, nor any tele-phone numbers, response times, etc.

DOE Adequate, but deployment times should be estimated.

NRC Estimated deployment times?

I.9. Adequat's I.10. EPA In-house computer capabilities are referenced (page 6-4) and methodology will track EPA's Manual of Protective Action Guides. Since it is conceivable that the computer will not be available when needed, alternative methods for estimating dose should be available and described in the Plan.

Merely noting that computer capabilities exist and a particular methodology referenced does not satisfy the require-ment that " procedures be stated." Add-itional descriptions and procedures, includir:g data forms and specific formulas and/or nomograms, should be included.

I.11. Adequate J.l. N/A J.2. FEMA Inadequate, nothing in State Plan re-leting to provisions for on-site individuals in meeting this element.

J.3. through 8. N/A I

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. NUREG-0654 Element Agency Coments J.9. EPA Sec. IV.A.6.b. of Chapter 7 needs to be revised. The dose levels mentioned there can in no way be considered " limits for routine operations" as stated. The guides ~

are taken from the EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-520/1-75-001, and apply only to post-incident conditions.

Five rem WB and 25 rem thyroid dose are the upper limits of projected dose levels to population groups for which evacuation is not mandatory, and these limits are not related to emergency workers doses.

Sec. IV.B.2.b.(1) directs that potassium iodide will be administered to emergency workers, if available, even though exposure l conditions may not involve any thyroid dose (e.g., projected dose is 10 rem WB but no radioiodine in release). In such a situation iodine blocking may not be desirable, and its use should be based on judgment as in the lower worker exposure categories and for institutionalized persons in the section following.

The note on p. 8-5 regarding the bases for the PAG's needs to be expanded or placed elsewhere in the text. The note appears to be correct for contaminated drinking water supplies and for food ,

emergency PAG's, but as I read the FDA recommendations (Fed. Reg. 58790, Dec.

15, 1978) and supporting documentation of l May 23, 1978, not correct for food pre-ventive PAG's, which refer to the critical receptor.

Implementation of protective actions generally tracks EPA recomendations.

J.10.a. Adequate J.10.b. Adequate J.10.c. Adequate J.10.d. Adequate J.10.e. FEMA . Adequate, however, nowhere in the State Plan does it provide for the quantities

, and storage of KI.

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' . NUfiEG-0654 Element Agency Comments J.10.f. Adequate J.10.g. Adequate

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J.10.h. Adequate J.10.1. DOT Evacuation Time Estimates for Waterford Steam Electric Station Unit Number 3 apparently includes the required informa-tion and has been reviewed by FEMA /NRC.

The plan makes assurances that this in-formation is available to decisionmakers in the event of an emergency requiring evacuation. The only question is whether this constitutes substantial compliance with the regulatory requirement for in-clusion in the plan.

J .10. J . Adequate J.10.k. Adequate J.10.1. DOT Evacuation Time Estimates for Waterford Steam Electric Station Unit Number 3 apparently includes the required informa-tion and has been reviewed by FEMA /NRC.

The plan makes assurances that this in-formation is available to decisionmakers in the event of an emergency requiring evacuation. The only question is whether this constitutes substantial compliance with the regulatory requirement for in-clusion in the plan.

J.10.m. EPA The first sentence in Sec. IV.B. of Chap.

7 " sort of" implies that the EPA PAG's are only applicable at the time of an accident, and dose projections are to be calculated from that time. This is not I the case, but I could not find the concept  ;

of " projected dose" clarified in the Plan.

The intent of the EPA PAG's is to apply the numerical guides as of the time the action is under consideration. For ex-ample, if a population group has already been exposed for 4 rem WB and an additional 2 rem WB is projected, the PAG would not recomend mandatory evacuation. The 5 rem mandatory evacuation guide refers to the (additional) projected dose which in the above example is 2 rem (not 4 + 2 = 6 rem).

If the EPA guidance is being strictly followed, this interpretation of projected dose must be-clearly understood by the decisionmakers and carefully spelled out in the Plan.

. NdREG-0654 Element Agency Comments J.11. Adequate J.12. EPA The means for registering and moaitoring evacuees at relocation centers are out- .

lined in Chapter 9. No lists of equipment and supplies, other than radiation monitoring equipment, could be located. Equipment storage locations and custodians could not be found in the Plan.

K.l. and 2. N/A K.3.a. Adequate K.3.b. Adequate K.4. EPA Adequate, however, would suggest that the wording in Chapter 9,Section III, on page 9-3 be changed to make it more clear that the authorization to exceed established exposure limits is not an automatic process, but rather is based on judgement. Specifically, I suggest the word "will" in lines 4 and 5 be changes to "may."

K.5.a. Adequate K.5.b. Adequate K.6. and 7. N/A

'L.l. HHS The national reputation of Ochnser Clinic leaves little doubt to this reviewer of the capability of this hospital to adequately handle contaminated individuals. However, there should be a statement to verify this capability.

NRC Local and backup hospital and medical services are provided for. Question re-mains, however, concerning assurances that persons providing these services are adequately prepared to handle contaminated individuals. Who is responsible for training?

FEMA Are agreements signed with local ambulance services for responding to an accident at Waterford III? None were found in plans.

L.2. N/A

NUREG-0654 Element Aggncy Comments l L.3. Adequate L.4. Adequate M.1. Adequate l M.2. N/A M.3. Adequate M.4. Adequate N.1.a. Adequate N.1.b. Adequate N.2.a. Adequate N.2.b. N/A N.2.c. N/A N.2.d. Adequate N.2.e.l. Adequate N.2.e.2. N/A N.3.a. through N.3.f. Adequate N.4. Adequate N.5. Adequate 0.1. FEMA Adequate, however, who is responsible for training? LNED or L0EP?

0.1.a. N/A 0.1.b. Adequate 0.2. N/A 0.3. N/A 0.4.a. through 0.4.j. Adequate 0.5. Adequate

NUREG-0654 Element Agency' Comments P ,1. Adequate l

P.2. Adequate .

. P.3. Adequate P.4. Adequate f

P.S. Adequate i

P.E. Adequate

< P.7. Adequate P.8. Adequate P.9. N/A 1

P.10. Adequate l

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LOUISIANA STATE PLAN

, AND ST. CHARLES AND ST. JOHN THE BAPTIST PARISH PLANS EVALUATION OF RADIOLOGICAL EMERGENCY RESPONSE PLANS FOR WATERFORD III STEAM ELECTRIC STATION A. Assignment of Responsibility (Organizational Control) -

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 responsibilities of the various supporting crganizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a con-tinuous basis.

NUREG P.EFERENCE CROSS REFERENCE EVALUATION AND COMMENTS A.1.a. State Plan, section VI and Adequate VII, pages 26-42. Also pages 45 and 46.

St. John Parish Plan Adequate Enclosure 2,page 157 and  ;

page 171 provides responsi- I bility chart.

St. Charles Parish Plan Adequate Enclosure 1 page 57 and page 72 provides responsi-bility chart.

A.l.b. State Plan section IV and Adequate ,

VI, pages 17-20 and 26-38. l St. Charles Parish, concept Adequate -

of operations begin on page 1 67.

St. John Parish, concept of Adequate l oprations begin on page 167.

Also Parish attachments and implementing procedures.

A.l.c. State Plan, diagrams charts Adequate pages 21 and 25.

St. Charles Parish, diagram Adequate chart, page 73.

St. John Parish, diagram Adequate.

chart, page 172.

isoREG REFERENCE CROSS REFERENCE EVALUATION AND COMENTS A.1.d. State Plan Section V, Adequate, however on page 30 of the pages 22-24. State Plan, the Department of Health and Human Resources, Office of Hospitals, Bureau of Emergency Medical. .

Services is assigned the responsibility. ~~

for Health and Medical Services. Does the Bureau of Emergency Medical Services have a Director or will a designated position in the Office of Hospitals be assigned this responsibility?

St. Charles Parish, page 66 Adequate ,

(St.CharlesParishPresident)

St. John Parish, page 167 Adequate (St. John Parish President)

Also Parish attachments and procedures.

A.l.e. State Plan Chapter 3, III, Adequate 4.,5., page 3-2 provides 24 hr. coverage by LOEP and Parish Sheriff's Office.

St. Charles Parish, pages 66 Adequate and 96.

St. John Parish,pages 166 Adequate and 192. ,

l Also Parish attachments and

implementing procedures.

A.2.a. State Plan section V and VI. Inadequate, most agencies do not mention pages 22-38. Table for key individuals by title. Agency roles primary and secondary responsi- are properly delineated but a point of bilities given on page 39. contact and coordination is required.

Parish attachments. Inadequate, a list of key. individuals by title'should be included for the organizations shown in the emergency function and responsibility chart, Fig.

3., p. 39 of the State Plan.

St. Charles Parish, Table of Adequat'e responsibilities,page 72.

-St. John Parish, Table of Adequate responsibilities,page 171.

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NUREGREFEhtNCE CROSS REFERENCE EVALUATION AND COMMENTS A.2.b. State Plan,Section I.B., Adequate page 2.

St. Charles Parish, Adequate attachment 1, page 57.

St. John Parish, Adequate attachment 1, page 157.

A.3. State Plan, chapter 14, page Inadequate, letters of agreement must 14-1. be included in the plan, not just listed.

Agreements and procedures from other state agencies would be helpful even though not required.

Chapter 14 of the Plan summarizes the farmal agreements that will be developed.

1hese agreements must be formalized be-fore the Plan car, be considered to be complete. EPA is not listed among the organizations to support the Plan (table 1).

Letters of agreement need to be updated as stated in plans. No updates were included in the State Plan.

Inadequate, chapter 14 of the State Plan provides that letters of agreement will be developed. They, or a signature page should be included in the State Plan.

St. Charles Parish, page Inadequate, there are no agreements 148. or letters of understaniiTng included in the two Parish plans.

Parish Plans (Chapter 8) list agree-ments that will be entered into, but no evidence could be found that such agreements have been finalized yet.

These agreements must be formalized before the plan can be considered to be complete.

Concept okay, but letters must be included.

h Inadequate, letters of understanding i i have not yet been developed. REACT is 1 l

not included in the list of letters to I be prepared.

St. John Parish, page 245. Inadequate. Same as S.C. above.

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NUREG REFERENCE CCSS REFEkIriCE .

EVALUATION AND COMMENTS A.4. State Plan, V., B., page 22 Adequate and VI., A., 3., 4., page 26.

St. Charles Parish, C. , 2. , Adequate 3., page 66. ~

j St. John Parish, C. , 2. , 3. , Adequate

page 166.

C. Emergency Response Support and Resources Planning Standards Arrangements for requesting and effectively using assistance re: urces have been made, arrangements to accomodate State and local staff at the licer.see's near site Emergency Operations Facility have been made, and other organizations capable of sugmenting the planned response have been identified.

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS C.1.a. State Plan, V., B., page 22 Adequate Parish Plans N/A C.l.b. State Plan, VII., A., page 40. Inadequate until Plans / Agreements are completed.

Parish Plans N/A C.1.c. State Plan, VII., A., 4., Specific support resources are to be page 40. Local Parish Plan outlined in letters of agreement (page cross reference page III 40), which have not been completed, refers to State Plan page 36 which is the wrong cross Inadequate, letters of agreements reference. Should be page not included.

40.

Inadequate, letters of agreement identif4d in section VII., A., page 40, of the State Plan should be included.

St. Charles Parish Specific local support resources are not included in the plans.

i Local requirement, but not included in the plans.

Specific support resources are to be outlined in letters of agreement which have not been completed.

Also note incorrect page number for cross _ reference in local plans.

St. John Parish Same comments as S.C. above.

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NUREG REFERENCE CROSS REFERENCE E#.LUATION AND COMMENTS C.2.a. State Plan, IV., O. page Adequate, however, please note the 19 and VII., C., l., page incorrect cross reference page number l in local plans.

41 Local Parish Plan cross reference page iii refers .

to State Plan page 37 which -

j is the wrong cross reference.

Should be page 41.

C.2.b. N/A C.3. State Plan, VII., B., 1. and State Plan assigns primary responsi-2, page 41. Chapter 6, III., bility for environmental monitoring to B. and C., pages 6-2 through LNED. Principal laboratory for radio-6-5. Chapter 6. Tab 3, pages logical analyses is LNED's lab in Baton 6-11 through 6-15. Rouge. To the extent that backup labs, such as LSU's, would be relied upon, the plan would benefit from more de-tailed description of the capabilities and availability of these labs. In addition, the capabilities for field analysis of samples, if that capability exists, should be described more thoroughlj (mobil laboratory mentioned on page 6-13).

l l Not adequately described. Could be included with letters of agreement.

St. Charles Parish Plans. N/A St. John Parish Plans. N/A C 4. State Plan, VII., A., 1-4, Southern Mutual Radiological Assistance page 40 and VII., B. ,1-3, Plan identified for manpower support pages 40 & 41. General (page 41), but no letter of agreement local plan section IV,page was found. No specific arrangements

! 10. for emergency support by other local j organizations or individuals could be l found.

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Inadequate until plans and agreements I

are included.

St. Charles Parish. chapter This element requires letters of agree-8, page 148 and St. John ment which are not found in the plens.

Parish. chapter 8, page 245. Also, shouldn't the hospitals be added to the list?

No specific arrangements for emergency support by other local organizations or individuals could be found in plans. ,

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NUREG REFERENCE CROSS REFERENCE .VAldATION P,NU COMMENTS l Letters of agreement are still not in-cluded in the plans. Agencies have been identified and appear to include all of those needed. .

Adequate, but outside resources should be requested when it is apparent that local resources will be exhausted, not after they are exhausted, i.e., allow for response time.

Inadequate, as noted in element A.3.,

letters of agreement have not been developed.

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 determinstion of minimum initial off-site response measures.

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS D.l. and 2. N/A D.3. State Plan, chapter 1, Adequate pages 1-1 through 1-7.

Parish Plans, General, Adequate chapter 4, pages 36 through 39.

D.4. State Plan, chapter 6, III., Adequate, in addition, in the State A., 1. and 2., pages 6-1 and implementing procedures plan there are 6-2. Also chapter 6, III., administrative procedures relating to C.l. and 2., pages 6-3 through the emergency classification system 6-5. which is not listed in the cross reference. This should be added next time the plans are revised.

St. Charles Parish, D., pages Adequate 67 through 70.

St. John Parish, D., pages Adequate 167 through 170.

Also section VI pages 4-6 in the State implementing procedures plan.

(

- E'. No'tification 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 followup messages to response .

organizations and the public has been established; and means to provide early notifica-tion and clear instruction to the populace within the plume exposure pathway .

Emergency Planning Zone have been established.

NUREG REFERENCE _ CROSS REFERENCE EVALUATION AND COMMENTS E.1. State Plan, chapter 2, Notification procedures are outlined Implementing procedures, in chapter 2. ' Initial _ notification page 2-1 (Accident form (tab 1 to chapter 2) does not Notification) specify message verification, although the Revision 3 version of this form did State Procedures Plan, so. Verification of messages to State page 1 (Accident and Parish officials is stated to be Notification). detailed in the implementing procedures (page 2-3). but could not be found in attachment 1, " Notification Procedure" or in attachment 2, "Consnunications Procedure," which in any case are explicitly excluded as a formal part of the Plan.

EPA has no defined role in plan. If called upon, notification of EPA o. I ?

evidently be done by DOE (page 40).

Resources relied upon will be listed in tab 6 to chapter 6, which, however, has not yet been developed.

! St. Charles Parish, page 93 Adequate l E0C Implementing Procedures, ,

attachment 6, page A.6-1.

l St. John Parish, page 189 Adequate

E0C Implementing Procedures, attachment 8, page A.8-1.

l E.2. State Plan, VI.,-A.5,, v e A&,quate i 26 and chapter 2, iib 1. ,

l page 2-3. Also state imple-menting procedures (State procedures book), page 1.

St. Charles Parish, Adequate chapter 1, page 93.

St. John Parish, Adequate chapter 1, page 189.

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NilREG REFERENCE CROSS REFERENCE EVALUATIONANdCOMMENTS E.3. N/A J

E.4.a.-n. N/A E.5. State Plan, chapter 4 Inadequate, it is not clear that a Y (Public Alert / Notification) joint public information center page 4-1. coordinates the information to be released.

St. Charles Parish, chapter It should be made clear which public 3,(PublicAlert/ Notification) information officers can approve page 99. information for release.

St. John Parish, chapter 3 It should be made clear which public (Public Alert / Notification) information officers can approve page 195. information for release.

E.6. State Plan, chapter 4, Adequate.

(Public Alert / Notification) page 4-1. Also Parish attachments.

St. Charles Parish, chapter Adequate 3, page 99 (Public Alert /

Notification)

St. John Parish, chapter 3 Adequate page 195 (Public Alert /

Notification) .

E.7. State Plan, chapter 4, IV. Adequate-pages 4-3 and 4-4. Also chapter 4. Tab 1, page 4-6.

Parish attachments.

St. Charles Parish EOC Adequate Implementing Procedures, attachment 6, e1Llosure 3, page A.8-E3-1. ,

St. John Parish E0C Adequate Implementing Procedures, attachment 4, enclosure 3, page A.4-E.3-1.

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

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS F.1.a. State Plan, chapter 3, III, Adequate A. , pages 3-1 and 3-2.

St. Charles, enclosure 1, Adequate chapter 1, III..page 93 and enclosure 1, chapter 2, III.,

page 97.

St. John Parish, enclosure Adequate 2, chapter 1. III..page 189 and enclosure 2, chapter 2, III..page 193.

F.1.b. State Plan, chapter 3, III., Adequate A., pages 3-1 and 3-2 and B., 2., pages 3-2 and 3-3.

St. Charles, enclosure 1, Adequate chapter 2, III., page 97.

St. John, enclosure 2, Adeq'Jate chapter 2, III.,page 193.

F.1.c. State Plan, chapter 3, III., Adequate B.3., page 3-3.

St. Charles, enclosure 1, Adequate chapter 2, III., K., page 98.

St. John, enclosure 2, Adequate chapter 2., III., J.,

page 194.

F.1.d. State Plan, chapter 3., III., Adequate, however, incorrect cross A., pages 3-1 and 3-2. reference on St. John page 194.

Should be "H" instead of "J." Also on State Plan cross reference should include page 3-3 on monitoring teams.  !

St. Charles, enclosure 1, Adequate chapter 2., III., J., page 98.

St. John, enclosure 2, Adequate chapter 2., III., H., page 194.

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NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS F.1.e. State Plan, chapter 3, Adequate III., A., l., 4., pages 3-1 and 3-2.

St. Charles, enclosure 1, Adequate .

chapter 1 III. , C. , page

94. E0C Implementing procedure, attachment 2.

St. John, enclosure 2, Adequate chapter 1, III., D.,

page 190. E0C Implement-ing Procedure, attachment 1.

F.1.f. N/A F.2. State Plan, chapter 3., III., Adequate D., page 3-3.

St. Charles, Enclosure 1, Adequate chapter 6., IV., A., 2.,

d. and e., page 138.

St. John, enclosure 2, Adequate chapter 6., IV., A., 4. and 5., page 235.

F.3. State Plan, chapter 13., IV., Adequate A. ,1. , page 13-3.

St. Charles, enclosure 1, Adequate chapter 2., IV., page 98.

St. John, enclosure 2, Adequate chapter 2., IV. , page 194.

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

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMENTS G.1. State Plan, chapter 5., IV., Adequate.

A., 1 and 4., pages 5-2 and 5-3.

4 NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS 4

St. Charles Plan, General, Adequate, however, should add chapter 1. IV. and V., pages page 24 to cross reference.

22, 23, & 24.

1 St. John Plan, General, Adequate, same as S.C. above. .

chapter 1 IV. and V.,

pages 22, 23, & 24. '

G.2. State Plan, chapter 5., IV., Adequate A., 1., 5., and 6., pages 5-2 and 5-3.

St. Charles Plan, General, Adequate

chapter 1, V., A., 3.,

i page 24.

St. John Plan, General, Adequate i chapter 1. V. , A. , 3. ,

page 24.

G.3.a. State Plan, chapter 5., IV., Adequate C., 1., 2., and 3., page

, 5-5.

, St. Ct.arles Plan, General, Adequate i

chapter 1., V., C., l.,

page 25.

St. John Plan, General, Adequate chapter 1. V. , C. , l . ,

page 25.

i G.3.b. N/A G.4.a. State Plan, chapter 5., IV., Adequate.

B., 1., and 3., pages 5-3 and 5-4.

i St. Charles Plan, General, Adequate, but local press releases

chapter 1. V. , B. , 2. , should be coordinated with State and

page 24. utility public information officers.

{'

It is reconsnended that a change in wording be used in the cross-reference sentence, General, chapter 1. V. . B. ,

2., page 24. The words "his designee" a

in the sentence should be changed to public information officer. This will clarify who the designated spokesperson is.

i St. John Plan, General, Same coments as S.C. Plan above.

chapter 1., V., B., 2.,

page 24.

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS G.4.b. State Plan, chapter 5., IV., Adequate B., 5., 6., 7., and 8.,

page 5-4.

St. Charles Plan, General, Adequate

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~

chapter 1., V., B., 3., page 24.

St. John Plan, General, Adequate chapter 1., V., B., 3.,

page 24.

G.4.c. State Plan, chapter 5., IV., Adequate B., 4., page 5-4.

St. Charles Plan, General, Adequate l chapter 1., V., B., 4.,

page 24.

St. John Plan, General, Adequate chapter 1., V., B., 4.,

page 24.

G.5. State Plan, chapter 5., IV., Adequate C., 4., page 5-5.

St. Charles Plan, General, Adequate chapter 1, V. , C. , 2. ,

page 25.

St. John Plan, General, Adequate chapter 1. , V. , C. , 2. ,

page 25.

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

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS H.l. and 2. -N/A H.3. State Plan, IV., H., J., Adequate and N., pages 18 & 19.

Also Parish attachments.

l NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS j St. Charles, enclosure 1, Adequate Basic, C., l., page 66.  ;

St. John, enclosure 2., Adequate Basic, C., l., page 166.

H.4. State Plan, Implementing Adequate Procedures.

St. Charles, enclosure 1, Adequate Basic, D., 5., page 67.

St. John, enclosure 2, Adequate Basic D., S., page 167.

H.5.a. through 6.c. N/A H.7. State Plan, chapter 6, III., Adequate B., 2., pages 6-2 and 6-3.

Chapter 6. Tab 7, pages 6-28 through 6-30.

t St. Charles Plan, General, Adequate chapter 5., V., B., l., e.,

page 46. Enclosure 1, chapter 9, Tab 1, page 151.

St. John Plan, General, Adequate chapter 5., V., B., l.,

e., page 46. Enclosure 2, chapter 9, tab 1, page 248.

H.8. and 9. N/A H.10. State Plan, chapter 6, Adequate,-however, State Plan tab 3, G. , page 6-13. does not give a cross reference for this element. It is missing. The cross reference is Chapter 6, page 6-13, tab 3. , - G.

Adequate, but cross reference should -

be included.

St. Charles Plan, General,- Adequate chapter 5., III., G., page 42.

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NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS l St. John Plan, General, Adequate chapter 5., III., G.,

page 42.

H.ll. State Plan, chapter 6, Appropriate response equipment will l Tab 3, enclosure 1, pages be available, as listed in chapter 6, 6-16 through 6-19, chapter tab 3, enclosure 1, but t.he concept 6, Tab 3, E., page 6-12. of kits (maintaining equipment in designated location where it is readily collectible) is not mentioned and evidently not planned.

St. Charles, enclosure 1, Adequate, however, Plan might benefit chapter 9, tab 1, page 151. by describing what portion of this equipment is in kits and where those kits are.

Appropriate response equipment will be available, as listed in chapter 6, tab 3, enclosure 1, but the concept of kits (maintaining equipment in designated location where it is readily collectible) is not mentioned and evidently not planned.

Inadequate, emergency supplies and protective equipment are not identified.

St. John, enclosure 2, Same coments as S.C. above.

chapter 9. Tab 1, page 248.

Parish Plans, General, chapter 5, V., B., l., e., page 46.

H.12. State Plan, chapter 6, Tab Plan might benefit by describing what 3, A., page 6-11, chapter 6, portion of this equipment is in kits Tab 3, E., page 6-12. and where those kits are.

Parish Plans refer to State Adequate Plans, chapter 6, Tab 3, F.,

l . , page 6-12.

I. Accident Assessment Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential off-site consequences of a radiological emergency condition are in use.

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NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS I.l. through 6. N/A I.7. State Plan, chapter 6, Tab 3, Adequate pages 6-11 through 6-22. .

Chapter 6, Tab 5, page 6-26 Chapter 6, Tab 7, pages 6-28 through 6-30.

Parish Plans refer to State No capabilities, but adequately Plan, chapter 6, Tab 3, pages addressed in State Plan. i 6-11 through 6-22.

I.8. State Plan, chapter 6, Tab Chapter 6, Tab 3, item C refers to 3, pages 6-11 through 6-22, procedures for notifying response team State Implementing Procedures. members, but no call lists, or reference to lists, could be found, nor any tele-phone numbers, response times, etc.

Adequate, but deployment times should be estimated.

Estimated deployment times?

Parish Plans refer to State No capabilities but adequately Plans page 6-11 through addressed in State Plan.

6-22.

I.9. State Plan, chapter 6, Adequate Tab 3, F., 4., b., page 6-13.

Parish Plans N/A I.10. State Plan, Implementing In-house computer capabilities are Procedures referenced (page 6-4) and methodology will track EPA's Manual of Protective Action Guides. Since it is conceivable that the computer will not be available when needed, alternative methods for estimating dose should be available and described in the Plan.

Merely noting that computer capabilities exist and a particular methodology referenced does not satisfy the require-ment that " procedures be stated." Add-itional descriptions and procedures, includino data fonns and specific fonnulas and/or nomograms, should be included.

Parish Plans N/A-

I NUREG REFERFHCE CROSS REFERENCE EVALUATION AND COMMENTS I.ll. State Plan, Chapter 6, Adequate Tab 3. H., l., page 6-14.

Parish Plans N/A .

J. . Protective Response Planning Standard l A range of protective actions have been developed for the ph:me 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.

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS J.1.a.-d. N/A J.2. State Plan, Nothing Inadequate, nothing in State Plan 4

relating to provisions for on-site individuals in meeting this element.

St. Charles, enclosure 1, Parish Plans only state on page 114 chapter 4 VI., F., page (St. Charles) and page 210(St.-John)

] 114. that "all arrangements for the recep-J tion and sheltering of. parish evacuees St. John, enclosure 2, will be handled by support Parishes."

chapter 4, VI., F., page Stated that shelter'will be provided l

210. for the following parishes:

1 1. ' Jefferson l 2. Orleans

3. La fourche

4. -Tangipchoa.

Does not ' describe how this will be handled.

I J.9. State Plan, chapter 7, IV.,- Sec. IV.A.6.b. of Chapter 7 needs to l

pages 7-4 through 7-11 be revised. The dose levels mentioned Chapter 8, IV., pages 8-3 there can in no way be considered " limits

! through 8-13. for routine operations" as stated. The.

! guides are taken from the EPA Manual of l Protective Action Guides and Protective Actions for Nuclear Incidents. EPA-520/1-

!75-001, and apply .only to post-incident conditions. Five rem WB and 25. rem i

' thyroid dose are the upper limits of pro--

jected dose levels to population groups:

l for which evacuation is not mandatory, and these limits are.not related to j emergency workers' doses.

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NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS i Sec. IV.B.2.b.(1) directs that potassium iodide will be administered to emergency workers, if available, even though ex-posure conditions may not involve any . .

I thyroid dose (e.g., projected dose is 10 -

rem WB but no radioiodine in release). '

In such a situation iodine blocking may.

not be desirable, and its use should be based on judgment as in the lower worker exposure categories and for institution-alized persons in the section following.

The note on p. 8-5 regarding the bases for the PAG's needs to be expanded or placed elsewhere in the text. The note appears to be correct for contaminated drinking water supplies and for food emergency PAG's, but as I read the FDA recommendations (Fed. Reg. 58790, Dec.

15, 1978) and supporting documentation

, of May 23,1978, not correct for food

! preventive PAG's, which refer to the critical receptor.

i Implementation of protective actions generally tracks EPA reconnendations.

St. Charles, enclosure 1, Parish Plans page 108 and 204.6.b.

chapter 4, V., page 108. relating to limitation to duration of E0C implementing procedures. exposures need to be revised. The Fire Services Implemnting dose levels mentioned there can in no

, Procedure, Attachment 4. way be considered " limits for ro tine 4 Radiological Exposure Con- operations" as stated. The guides are trol Implementing Procedure. taken from the EPA Manual of Protection Action Guides and Protective Actions St. John, enclosure 2, for Nuclear Incidents, EPA-520/1-75-001, chapter 4, V., page 204, and apply only to post-incident conditions. ,

E0C implementing procedures. Five rem.WB and 25 rem thyroio dose are Fire Services Implementing the upper limits of projected dose levels Procedure, Attachment 4. to population groups for which evacuation Radiological Exposure Con- is not mandatory, and these limits.are-i trol Implementing Procedure, not related to emergency workers' doses.

J.10.a. State Plan, chapter 6, tab Adequate 7, pages 6-28 through 6-38. Paiish Attachments.

St.- Charles, enclosure 1, Adequate chapter 4, tab 3, page 125.

St. John, enclosure 2, Adequate-chapter 4, tab 3, page 221.

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NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS J.10.b. State Plan refers to Parish Adequate for both State and local Attachments and General, tab plans.

4, page 18 and 132.

1 J .10. c . State Plan, cnapter 4, Adequate, EBS stations are WCKW ~

pages 4-1 through 4-5. and WK07. L0EP is the agency that activates the EBS.

St. Charles, enclosure 1, Adequate chapter 3, IV., c., page 101.

St. John, enclosure 2, Adequate chapter 3, IV., c.,page 197.

J.10.d. State Plan, chapter 7, Adequate III.,E., 4., page 7-4; chapter 7, IV., A., 2., c.,

page 7-5; chapter 7, IV.,

A., S., b., page 7-6; chapter 7. IV., B., 3.,

pages 7-9 and 7-10.

St. Charles, enclosure 1 Adequate basic, B., l., i., page 58.

St. Charles Parish School Services Implementing Procedure. Health and Medical Services Implement-ing Procedure. Law Enforce-ment Services Implementing Procedure, Attahcment 4.

Transportation Services Implementing Procedure.

St. John, enclosure 2, basic, Adequate B., l., i., page 158.

St. John Parish School Services Implementing Pro-cedure. Health and Medical Services Implementing Pro-cedure. St. John, Enclosure i

2, chapter 4, tab 4, page 225.  !

, Transportation Services  !

Implementing Procedure, l 1

'NUREG' REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS J.10.e. State Plan, chapter 7, IV., Adequate, however nowhere in either A., pages 7-6 and 7-7; the State Plans or Parish Palns does chapter 7, IV.,B.,2. and 3., it provide for the quantities and pages 7-8 through 7-10. storage of KI.

Parish Plans, General, Adequate, however, should include chapter 5, V., B., 2., additional cross references when page 46. Additional cross plans are revised.

references that need to be added: State Plan, chapter 9, page 9-9 on use of KI and page 9-13 Radioprotective Drugs.

J.10.f. State Plan, chapter 9, tab Adequate, the A50EA will recomend 1, page 9-13. the use of KI.

Parish Plans, General, Adequate chapter 5. , V. , B. , 2. ,

b., page 46.

J.10.g. State Plan, chapter 7, III., Adequate E., 4., page 7-4; General, III., B., 3., page 10.

St. Charles Enclosure 1, Adequate basic, tab 6, page 81.

Transportation Services Implementing Procedure, Attachment 3.

St. John, Enclosure 2, Adequate basic, tab 6, page 179.

Transportation Services Implementing Procedure, Attachment 3.

f J.10.h. State Plan, Parish Attach-- Adequate, both State and Local , Plans.

ments;St. Charles, Enclosure 1, chapter 4, tab 2, page 117 and St. John, Enclosure 2, chapter 4, tab 2, page 213.

J.10.1. State Plan, Parish Attach- Evacuation Time Estimates for Waterford ments Steam Electric Station Unit Number 3 apparently includes the required infor-mation and has been reviewed by FEMA /NRC.

The plan makes assurances that this in-formation is available to decisionmakers in the event of an emergency requiring.-

evacuation. The only question is whether this constitutes substantial compliance with the regulatory requirement for in-clusion in the plan.

. *s NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS J.10.1. St. Charles, Enclosure The plan makes assurances that the 1, chapter 4, tab 1, " Evacuation time estimate information page 116. is available to decisionmakers in the  ;

event of an emergency requiring evac . .!

uation. The only question is whether ~l this constitutes substantial compliance with the regulatory requirement for inclusion in the plan.

St. John, Enciosure 2, Same comments as S.C. above.

chapter 4, tab 1, page 212.

J.10.J. State Plan, chapter 7, Adequate IV., A., 3., pages 7-5 and 7-6.

St. Charles, Enclosure 1, Adequate basic, tab 3, pages 74 and 75. Law Enforcement Services Implementing Procedure, Attachment 5.

St. John, Enclosure 2, Adequate basic, tab 3, page 173.

Law Enforcement and Traffic Control Implementing Procedure, Attachment 1.

J.10.k. State Plan, chapter 7, III., Adequate E. , 3. , page 7-3 Imple-menting Procedures.

St. Charles, Enclosure 1, Adequate basic, tab 8, page 89.

St. John, Enclosure 2, Adequate basic, tab 8, page 185.

J.10.1. State Plan, chapter 7, In regards to both the State and Local tab 1, page 7-12, Plans, the Evacuation Time Estimates l Parish attachments. for Waterford Steam Electric Station Unit Number 3_ apparently includes the St. Charles, Enclosure 1, required information and has been re-i chapter 4, tab 1, page 116. viewed by FEMA /NRC. The plan makes l assurances that this information is St. John, Enclosure 2, available to decisionmakers in the event chapter 4, tab 1, page 212.

of an emergency requiring evacuation.

The only question is whether this con-I stitutes substantial compliance with the regulatory requirement for inclusion in the plan.

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'l Lj NJJREG JtEFERENCE CROSS REFERENCE EVALUATION AND COMMENIC J.10.m. State Plan, chapter 7. 11., The first sentence in Sec. IV.B. of 1

D., page 7-2 Chapter 7 " sort of." implies that the l EPA PAG's are only applicable at the time of an accident, and dose projections ,

l are to be calculated from that time. -

This is not the case, but I could not find the concept of " projected dose" clarified in the Plan. The intent of the EPA PAG's is to apply the numerical guides as of the time the action is under consideration. For example, if a population group has already been exposed for 4 rem WB and an additional 2 rem WB is projected, the PAG would not recomend mandatory evacuation. The 5 {

)

rem mandatory evacuation guide refers to the (additional) projected dose which in the above example is 2 rem (not 4 + 2 =-

6 rem). If the EPA guidance is being strictly followed, this interpretation of projected dose must be clearly under-stood by the decisionmakers and carefully spelled out in the Plan.

Parish Plans N/A J.11. State Plan, chapter 8, Adequate page 8-1.

Parish Plans N/A J.1". State Plan, chapter 9, The means for registering and monitoring IV., pages 9-3 through evacuees at relocation centers are.out- ,

9-7. lined in Chapter 9. No lists.of equipment )

and supplies, other than radiation '

monitoring equipment, could b? located. .

Equipment storage locations and custodians !

could not be found in'the Plan.

St. Charles Enclosure 1, Adequate, however, additional details chapter 4, VI., F., l., such as the approximate number of perscns page 114. and support parish plans and procedures are needed.

St. John, Enclosure 1, Same coments as S.C. above.

chapter 4 VI., F., 1.,

page 210.

l K. Radiological Exposure Control l Planning Standard Means for 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.

l NUREG _ REFERENCE CROSS REFERENCE ' "ATION AND COMMENTS K.l. and 2. N/A K.3.a. State Plan, chapter 9, Adequate III., A., page 9-2; chapter 9, V., B., l.,

a., pages 9-7 and 9-8.

Parish Plans refer to Adequate State Plan, chapter 9, III., A., page 9-2.

K.3.b. State Plan, chapter 9, tab Adequate.

5, 2-4, pages 9-20 and 9-21; chapter 9, tab 6, page 9-22. General, chapter 5, V., B., l., C.,

and D., page 45.

St. Charles Parish Radio- Adequate logical Exposure Control Implementing Procedures, Attachments 3 and 6.

St. John Parish Radio- Adequate logical Exposure Control Implementing Procedure, Attachments 3 and 6.

K.4. State Plan, chapter 9, V., Adequate, however, would suggest that D., pages 9-10 and 9-12. the wording in Chapter 9,Section III, General, chapter 5, V. , D. , on page 9-3 be changed to make it more page 47. clear that the authorization to exceed established exposure limits is not an automatic process, but rather is based on judgement. Specifically, I suggest the word "will" in lines 4 and 5 be changes to "may."

St. Charles, Enclosure 1, Adequate chapter 4 V., B., 2., C.,

page 111.

St. John, Enclosure 2, Adequate Chapter 4 V. , B. , 2. , C. ,

page 207.

MUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS K.5.a. State Plan, chapter 9, IV., Adequate B., 3., page 9-5; chapter 9, IV., D., 1 and 2, pages 9-6 and 9-7; chapter 9, V., C.,

2., page 9-9.

Parish Plans, General, Adequate chapter 5, V., C., 2, page 47; General, chapter 5, VI.,

B., 3., page 49; General, chapter 5, VI., D., page 51.

K.5.b. l State Plan, chapter 9, Adequate V., C., 2., page 9-9; {

chapter 9, tab 4, pages 9-17 through 9-19.

St. Charles Parish Radio- Adequate logical Exposure Control Implementing Procedure, Attachments 1, 2, 5 and 10.

l St. John Parish Radio- Adequate logical Exposure Control Implementing Procedure, '

Attachments l, 2, 5 and 10.

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

NUREG REFERENCE CROSS REFERENCE EVALUATION AND__ COMMENTS L.l. State Plan, Chapter 10, IV., The national reputation of Ochnser B.,1.,,pages 10-3 and 10-4; -Clinic leaves little doubt to this chapter 10, tab 4, pages reviewer of the capability of this 10-11 through 10-13. hospital to adequately handle contaminated; individuals. However, there should be a statement to verify this capability.

Local and backup hospital and medical services are provided for. Question remains, however, concerning assurances that persons providing these services are adequately prepared to handle contaminated individuals. Who is responsible for -

training?

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS Are agreements signed with local ambulance services for responding to an accident at Waterfore III? None were found in Plans.,

St. Charles, Enclosure 1, Local and backup hospital and medical chapter 6, IV., A., 2., services are provided for. Qeustion page 137. Health and remaining, however, concerning assurances Medical Services Imple- that persons providing these services are nenting Procedure, adequately prepared to handle contaminated Attachment 7. individuals. Who is responsible for training?

The same procedures for handling con-taminated patients should be taught to both the hospital ER personnel and EMS personnel. Again, who is responsible for training?

Agreements have been signed with Ochsner and West Jefferson General Hospitals.

What about agreements signed with local ambulance services?

A progressive system for EMS has been.

developed in the southeastern region of Louisiana, of which St. Charles and St. John the Baptist are a part. The two parishes should have benefited from this in their plan development. Was this EMS system involved in the planning stages?

There was no reference to this in relation.

to local and regional Medical Control and communications. It would be most beneficial in evaluating the local cap-abilities if a description of how the local plans interfaced with the Emergency MeJical Service System.

Also it was not clear how the parishes arrived at the need for Medical Manpower on pages 151 and 248. - Example, need two ambulances and twenty-six ambulance drivers. What about medical attendants for each ambulance?

Also the capability of the Ochnser Hospital should have been verified in the Plans.

I L

, dVREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS St. John, Enclosure 2, Same comments as S.C. above.

chapter 6, IV., A.,

page 235. Health and Medical Services Imple- .

.I menting Procedure, .

Attachment 3.

L.3. State Plan, chapter 10, IV., Adequate B., 2., pages 10-4 and 10-5; chapter 10, tab 2, pages 10-8 and 10-9.

Parish Plans N/A L.4. State Plan, chapter 10, Adequate IV. , A. , pages 10-2 and 10-3; chapter 10, tab 2, pages 10-8 and 10-9.

St. Chrrles, Enclosure 1, Adequate, however, plans do not chapter 6 IV., A., 2., include agreements signed with the page 137. local ambulance services for trans-portation.

St. John, Enclosure 2, Same coments as S.C. abeve.

chapter 6, IV., A., l.,

page 235.

M. Recovery and Reentry Planning 7.nd Post-accident Operations Planning Standard General plans for recovery and reentry are developed.

NUREG REFERENCE CROSS REFLRENCE EVALUATION AND COMMENTS M.l. State Plan, chapter ll, Adequate page 11-1.

St. Charles, Enclosure 1, Adequate chapter 7, page 141.

St. John, Enclosure 2, Adequate chapter 7, page 238.

M.2. N/A

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS M.3. State Plan, chapter 11 Adequate III., B., 2., page 11-3; )

chapter 11, III., E.,

page 11-3. .

Parish Plans N/A M.4. State Plan, chapter 11 Adequate III., I., page 11-4 Parish Plans N/A N. Exercises and Drills Planning Standard Periodic exercises are (will be) cor. ducted 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.

. NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS N.1.a. State Plan, chapter 13, Adequate III., A., pages 13-1 through 13-3.

Parish Plans, General, Adequate chapter 3, II., page 31.

N.l.b. State Plan, chapter 13, Adequate III., pages 13-1 through 13-3.

Parish Plans, General, Adequate chapter 3, III., B.,

page 32. Also State Plan, chapter 13, page 13-1.

N.2.a. State Plan, chapter 13, Adequate IV. , A. , l . , pages 13-3 and 13-4.

General, chapter 3, IV. ,

B., l., page~33.

N.2.b. N/A N.2.c. State Plan. N/A l

Parish Plans, General. Adequate chapter 3. IV., B., 2.,

page 33.

1

'NUR'EG" REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS N.2.d. State Plan, chapter 13, Adequate l

IV., A., 2., page 13-4.

Parish Plans, General, Adequate chapter 3, IV., B., 3.,

pages 33 and 34.

N.2.e.(1). State Plan, chapter 13, Adequate IV., A., 3., page 13-4.

Parish Plans N/A N.2.e.(2). N/A N.3.a. State Plan, chapter 13, Adequate through f. V., page 13-5.

N.3.a. Parish Plans, General, Adequate through d. chapter 3, IV., B., l.,

2., 3., 4., page 34.

N.3.e. Parish Plans, General, Adequate through f. chapter 3, V., B., S.,

6., page 35.

N.4. State Plan, chapter 13 Adequate III., A., 5., page 13-2 and 13-3.

Parish Plans, General, Adequate chapter 3, III., B.,

l., page 32.

N.5. State Plan, chapter 13, Adequate III., A., 5. and 6., page 13-3.

Parish Plans, General, Adequate

, chapter 3 III., B.,

2., page 32.

D. Radiological Emergency Response Training Planning Standard Radiological emergency res on to assist in an emergency. ponse training is provided for those who may be called l NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS 0.1. State Plan, chapter 12, Adequate, however, who is responsible page 12-1. for training? LNED or LOEP?

l

'NUREG' REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS Parish Plans, General, Adequate, however, in general plan chapter 2 , pages 26 states that LNED and L0EP will provide through 30. training to the two parishes. Who is the lead agency on training? - .

0.1.a. N/A 0.1.b. State Plan, chapter 12, Adequate III., A., 2., page 12-2.

Parish Plans, General, Adequate chapter 2 , III., A., 2.,

pages 26 and 27.

0.2. N/A 0.3. N/A 0.4.a. State Plan, chapter 12., Adequate through f. III.,B., pages 12-2 and 12-3.

Parish Plans, General, Adequate chapter 2 , III., B., 4.,

a., pages 27 and 28. .

O.5. State Plan, chapter 12, Adequate III., B., 5., 6., and 7, page 12-3.

Parish Plans, General, Adequate chapter 2, III., B., 5., 6.,

and 8, page 28.

P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans Planning Standard .

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

NUREG REFERENCE CROSS REFERENCE EVALUATION AND C0H9ENTS P.l. State Plan, chapter 12, Adequate IV.,B., l., pages 12-4 and 12-5.

Parish Plans, General, Adequate chapter ? , III., C., a.,

page 29.

l 1

NUREG REFERENCE CROSS REFERENCE EVALUATION AND COMMENTS P.2. State Plan, V., B., and Adequate, ASOEA is responsible for G., pages 22 and 23. emergency response planning.

St. Charles, enclosure 1, Adequate, Emergency Preparedness . .

basic,B.,2.,a.,(1) Director responsible for response ~

pages 59 and 60. planning.

St. John, enclosure 2, Adequate, Civil Defense Director basic,B.,2.,a.,(1), responsible for response planning. I pages 159 and 160. I P.3. State Plan, VI. , A. , 3. , Adequate, however, cross reference page 26; and VI., B., page is incorrect. Should be page 26

26. instead of page 22. ~

Implementing Procedures; Parish attachments.

St. Charles, enclosure 1, Adequate basic,B.,2.,a..(1) pages 59 and 60.

St. John, enclosure 2, Adequate basic,B.,2.,a.,(1),

pages 159 and 160. '

P.4. State Plan, VIII., B., page Adequate 42.

Parish Plans, General, Adequate V., B., I and 4, page 11.

P.S. State Plan, VIII., C., Adequate pages 42 and 43.

Parish Plans, General, Adequate V. , C. ,1 and 2, page 12.

P.6. State Plan, Table 3, Adequate page 49.

St. Charles, enclosure 1, Adequate basic, tab 10, page 92.

St. John, enclosure 2, basic, Adequate tab 10, page 188.

____ __ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ .