ML20084L216
| ML20084L216 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 05/04/1984 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-84129, NUDOCS 8405140386 | |
| Download: ML20084L216 (2) | |
Text
r public Servlee Company f' OcBondo C
16805 WCR 191/2, Platteville, Colorado 80651 9
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9 May 4, 1984 Fort St. Vrain Unit #1 P-84129 John T. Collins Regional Administrator U.S. Nuclear Regulatory Commission MAY - 91984 Region IV s
611 Ryan Plaza Drive, Seite 1000 Arlington, TX 76011
SUBJECT:
Exemption From State Participation in Annual Emergency Exercise
REFERENCE:
- 1) IE Information Notice No. 84-05, Revision 1
- 2) P-84106, dated April 10, 1984
Dear Mr. Collins:
In support of our request for exemption from State participation in the 1984 Fort St. Vrain Radiological Emergency Exercise, please find attached the FEMA report on the State of Colorado's performance in the 1983 exercise. Also attached is correspondence from FEMA to NRC, dated April 25, 1984, which transmitted 1982 and 1983 exercise reports, and which states that FEMA's approval of the State plan in conjunction with 44 CFR 350 remains in effect.
Please also find attached a FEMA interagency memo stating that Fort St. Vrain qualifies for the biennial frequency of exercising State and local emergency plans.
These items should be helpful in expediting approval of the request for exemption from the requirements regarding State and local government participation set forth in Section IV.F.1 of Appendix E to 10 CFR Part 50.
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.- Please be advised that scheduling conflicts recently discovered may necessitate postponement of this year's emergency preparedness exercise to sometime in July. We will advise you accordingly, should such a change be required.
If there is any other information that could be supplied that would be useful in considering this request, please contact me at
.(303)785-2223.
Very truly yours, WWW
'L Don W. Warembourg
/
Manager, Nuclear Production Attachments cc: John P. Byrne, Director, Colorado D0 DES (w/o attachments)
James C. Baker, FEMA Region VIII (w/o attachments)
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5 Washington, D.C. 20472 APR 251984 i
MEMORANDUM FOR:
Edward L. Jordan Director Division of Emergency Preparedness t
and Engineering Response Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission FROM:
<Ri ri Assi tant Asso e Director Office of Natural and Technological Hazards Programs SUBJECTr Exercise Reports for the Fort St. Vrain Nuclear Power Station Attached are exercise reports for the joint offsite radiological emergency preparedness exercises conducted on June 3, 1982, and June 10, 1983, for the Fort St. Vrain Nuclear Power Station with the State of Colorado and Weld County, Colorado. These reports cite that the State of Colorado and Weld County demonstrated the capability to protect the public in the event of a radiological emergency at the Fort St. Vrain Nuclear Power Station.
Although there were deficiencies observed at these exercises, they did not detract from the overall demonstrated capability by the State of Colorado and Weld County to protect the health and safety of the public.
In light of this, the Federal Emergency Management Agency 44 CFR 350 approval of the State and local plans for the Ft. St. Vrain Nuclear Power Station will remain in effect.
If you have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 287-0200.
Attachments As Stated y
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FEMA REGION Vll!
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NEMORA';DUM FOR: Louis O. Giuffrida. Director Federal EmerEency Management Agency FROM:
Alton Cook.
Regional Director
SUBJECT:
Fort St. Vrain Nucient Facility Exercise j
Enclosed in the Final Report of Fort St. Vrain Nuclear Facility Exer-I cise held June 15, 1983.
i Enclosurc r
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- s nemn t' AFOAV
Summary Section:
At this time no further conments have been received relative to our initial draft report.
We do expect a response from the State of
- Colorado, Division of Disaster Energency Services ' that is likely to enphasize the nood to clearly define the exercise conditions and the role of the Federal agencies including recovery phase operation.
We concur with this need and are anticipating close cooperation with the State of Colorado, Public Service Conpany of Colorado and the Nuclear Regulatory Agency.
As a result of the Regional Assistance Conmittee (RAC)
Evaluation, we have concluded that the health of the population surrounding the Fort St.
Vrain fixed nuclear facility would have been protected in an event of that given scenario.
The state energency plan has been
- tested, activated and exercised under a variety of conditions with increasing effectiveness.
The problems identified with conmunication deficiencias between the field monitors and the forward connand post do need to be addressed on a continuing basis.
FE!:A may have a substantive contribution to nahe in assisting the State in reversing these problems.
If there are further questions, contact Janos C. Daker, Ph.D., FTS 234-2565.
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!!EMORANDUM FOR:
ALTON D. COOK, REGIO!!AL DIRECTOR FROM:
Jerone Olson, Chief tiatural and Technological Hazards Division
SUBJECT:
Fort St. Vrain Exercise, 1983 ISSUE:
Whether the State of Colorado and Ucid County ecorgency and preparedness plans as exercised in thin limited scenario arc adequate to protect the health of the population from the off-site offects of a
radiological energency of the Fort St. Vrain 1;uclear Power Plant?
SUMi%RY:
The health of the citizens in the areas surrounding the Fort St.
Vrain Nuclear Power Plant would have been protected by the utilization of the Radiological Emergency Responso Plan by the Colorado Division of Disaster Energency Services, Colorado State Health Department, State Police and the Wold County Sheriff's Department and otherc.
DACKGRotniD:
The Stato Radiological Energency Response plan for Fort St. Vrain was approved by all necessary regulatory agencies in 1980.
This exerciso reflects an extensive sito, however linited
- offsite, neonario for a
defined Site Energency at a fixed facility nuclear power plant.
W objectives for FOSAVEX-83 exercine, jointly developed by the State of Colorado and Public Service Company of Colora60 vore forwarded to FEMA VIII,!! arch 24, 1983.
the scenario van not received by FEMA until June 10, 1083.
The objectives and the resultant scenario are the critoria against which the exercisc will be evaluated.
The evaluation is based upon the MUREG-0654-FEMA-REP-1 (Rev. 1), the proposed rulo 44 CFn 350 and the Guidance Menorandur.,
1;unber 17, utilizing a
nodule-oriented evaluation tool developed, under a contract, by the Argonne Laboratory.
The off-site observation tcan was comprised of the Regional Assistance Com:alttee, additional FES% staff members, and Red Cross volunteers.
A joint !!uclear Regulatory Agency (NPC),
- Colorado, Ucid County, Public Service Conpany of Colorado, and FElm critique was held June 16, 1983, at Fort St. Vrain Visitor Center.
R8/ NTH 7/6/83 21 6 JBaker/js DGore
2 CONCLUSIONS:
The requirements of UUREG-0654-FEMA-REP-1, TRev. 1) and proposed rulo 44 CPR 350 limits the scope of FEMA's evaluation to the single question relating to the adequate protection of the health of the population around a fixed nuclear facility.
The conclusion of the Regional Assistance Comnittec is that the health of the pcpulation was and would have been protected under the conditions stated for the objectives and scenario.
The objectivos and scenario were jointly developed by the State of Colorado and Public Service Company of Colorado.
A judgement that the health of the population uns protected does not imply that all aspects of the exorcise were 100%
effectively executed.
In the past, a major deficiency has been the inability to communicato offectively with the Colorado State Health Departments field health assessment tcans.
A portion of these concerns has been alleviated by the availability of the State of Colorado communication van.
The 5 watt receiver /trancmitters were shown once again to not be an effective communication device under those circumstancos.
A more powerful receiver / transmitter unit or the utilization of a repeater would be recommended in part to help solve this problem.
ASSESSMEUT:
The najor annossment modulen as developed by the J
Argonne Laboratory utilized by the RAC to evaluate this exercise were:
1.
Emergency Operation Center 2.
Porward Command Post 3.
Media 4.
Medical Support 5.
Decontamination G.
Field nonitoring 7.
Radiological Laboratory Emergency Operations Center (EOC)
The manning of EOC was by design limited.
The anticipatory climate surrounding the exercise mado critical evaluation difficult.
Staffing was effectively accomplished with the apparent ability to upgrade involvement if necessary.
Duties were perforned in a very professional non-crisis atmosphere.
- Data, information and recommendations wore
- received, evaluated, discussed, and verified in a direct manner.
The necessary State representativos were in attendance.
Media briefing was developed and delivered effectively.
The TCP management tean was dispatched to forward command post with
- speed, reflecting the anticipatory atmosphere of the EOC.
Some confusion resulted fron apparent procedural errors at l
the powcr plant control room.
The NRC will evaluate those l
4
W incidents.
FEMA uned the exercise to activate the Regional Energency Response Team and were provided space to function.
Fort Lupton Forward Command Post (FCP)
After the activation of the PCP tean, the staffing was accomplished rapidly.
The power plant control room connunication errors, of failing to adequately notify the Weld County dispatcher and Sheriff's department, resulted in a delayed arrival of the security force and field patrol units.
Little confusion resulted at the PCP as a result of the connunication delay except for the presence of media reprocontatives and the failure to utilize a
badging procedure.
The FCP operated with an organized, informal effectiveness that could possibly break down in an actual incident.
An argument can be effectively advanced to tighten nanagerial control.
Independent of this possibic criticism, data were collected, directions
- given, and recomnendations woro developed involving the several stato, local, and utilitics representativos Decisions were carried out in a
free-flowing, professional manner utilizing direct and rapid connunications with the EOC.
Linitation imposed by the scenario resulted in some confusion, verification delays, and increased decision naking.
The major contributor to any delay was the inability to communicate quickly, directly, and effectively with the field nonitoring and assessment toans.
The police component represented by the Colorado State Polico and the Ueld County Sheriff's Departncnt functioned in a nost professional manner.
Informational road blocks were established, marginal security was establiched at the FOC, and details for specific evacuation procedures were quickly developed.
Field Monitoring and Radiological Laboratory The Colorado State Health Department field assessment tean (as per the scenario) played the exercise very low key with only one team being deployed.
Radio equipnont shown in previous exercises to be ineffectivo limited the training opportunity for Health Department personnel as well as conpronising field communications for the exercise.
At least two pieces of equipment in the field van were labeled with expired calibration date.
Significant backup equipment and analytical capabilities by scenario design vero isolated from the field exercise with the supply van stationed at the FCP.
This reserve of equipment if brought into service would have extended the departments' activities.
The field tonn 3
(I Federal Emergency Management Agency Region VIII Denver Federal Center, Building 710 Denver, CO 80225 MEMORANDUM FOR: DAVE MCLOUGELIN, ACTING ASSOCIATE DIRECTOR Office of the Associate Director, SL FROM:
Alton D. Cook, Regional Director Federal Emergency Management Agency
SUBJECT:
Interim Guidance for Scheduling of Radiological Emergency Preparedness (REP) Exercises The Federal Emergency Management Agency, Region VIII, has received the " Interim Guidance for Scheduling of Radiolodical Emergency Preparedness (REP) Exercises Per Final Rule, 44 CFR Part 350 and we are in agreement.
The Fort St. Vrain Nuclear Power Plant qualifies for the biennial frequency of exercises. There are no other f acilities in Region VIII affected by this guidance.
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4 was not adequately prepared to respond to the deficiencies in conmunications.
No rapid or consistant communications were possible until the arrival of the National Guard unit.
Inappropriate notification via FEMA observer equipment resulted in the National Guard deployment.
One source of confusion arose when the decision was made to hold the wind direction constant.
Thic decision was consistent with tae pre-set scenario.
Pield and prompted data were co-mingled causing apparent inconsistencies.
Verification of this data did demonstrate effective action by the forward command post personnel.
This effort would have been greatly simplified by additional direct communication links with the field health assessnent toans.
Medical Support and Decontamination The 1983 scenario started with an electrical fire, equipment failure, and a personnel injury.
A clear message was not sent from the plant command center to the anbulance service.
Therefore, even though the " victim" was located and treated effectively on site and the St.
Luke's Hospital was ddequately prepared to treat an injured, contaninatc6 victin, the whole schema was not completed, Tone Alert Systen j
u The Tone Alert Systen was activated and an appropriate nessage broadcast.
The Emergency Broadcast Systen was nierted by a no message broadcast.
Data to deternine the
/i officiency of th.: inne Alert System relative to this exercise is being collected by Mr. Robcrt Heggis, a RAC menber, of Human Health Services.
The preliminary results suggest similar findings to last yenr.
The evaluation tool, tining and procedurcs may not have tae sensitivity required to prove effectiveness.
Recomocndations specific to this problem uill be developed over the next few months.
RECO"MENDATIOUS:
.i, 41.
A full scale, unannounced, nultinedia hazards exercise
'L should be developed involving the Port St. Vrain nuclear
/, power plant.
Particular emphasis should be given to the
' realities of the plant's operation and design.
A recovery f
phase operation that would necessitate federal, state, and local coordination should be included in the developnent and execution of the scenario (POSAVEX-84).
5 2.
The communications system should be independently evaluated and expanded if the primary system is inadequato to provide field communication with the capacity for direct FCP - field assessment team comr.unications.
Cc3 l'E. Pat Byrne (2)
Ib. Al liazel Regional Assistance Committee (12}
l'.r. Marlow Stangler
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MEMORANDUM FOR: All Regional Directors g
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FROM:
ve McLoughlin N
Deputy Associate Director State and Local Programs and Support
SUBJECT:
Interim Guidance for Scheduling of Radiological Emergency Preparedness (REP) Exercises Per Final Rule, 44 CFR Part 350 The purpose of this memorandum is to provide interim guidance for the 4
scheduling of radiological emergency preparedness exercises in support of the publication in the " Federal Register" on September 28, 1983, of 44 CFR Part 350. The effective date for implementation of the final rule is October 28, 1983.
The Federal Emergency Management Agency (FEMA), through the publication of this final rule, has changed the REP exercise frequency requirements for State and local governments from an annual to a biennial (every two years) frequency.
With the inclusion of a " grandfather clause" in 350.9(a), State and local governments that have fully participated in a joint exercise one year prior to the effective date of this rule (interpreted as the period from 10/1/82 to 10/31/83), will proceed to a biennial frequency for their next scheduled full participation, joint exercise. Those State and local governments which have not fully participated in a joint exercise within the time provisions (October 1,1982, to October 31, 1983) of this clause will proceed to the biennial frequency subsequent to the completion of their next scheduled, joint exercise.
While FEMA has adopted the biennial exercise frequency, the Nuclear Regulatory Commission (NRC) has not yet amended its rule, 10 CFR Part 50, with respect to changing its annual exercise frequency requirement. It is our understanding that the NRC staff will recommend exercise frequency language consistent with our final rule to the Commissioners in November or December of 1983. The following interim guidance is provided to aid the Regions in working with State and local governments to establish exercise schedules until these differences are reconciled.
For State and local governments that do not qualify for the o
biennial frequency provisions established under the " grand-father clauce," your Office should continue to coordinate the planning and preparation for their next annual, full participation, joint exericse.
4
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., For State and local governments that qualify for the biennial o
frequency provision, your Office should defer scheduling of exercises until the differences between the NRC and FEMA exercise frequency requirements are resolved.
For State and local governments that qualify for the biennial o
frequency, but whose annual exercise has been scheduled and the preparation for the conduct of this exercise has progressed with respect to establishing objectives and developing an exercise scenario, your Office should assist the State and local governments in carrying out the scheduled, annual exercise.
If a State or local government that qualifies for the biennial frequency does not desire to participate in another annual exercise, refer such cases to Headquarters.
In order to assist Headquarters in determining the potential impact of the final rule for exercise scheduling, please submit a list of all State and local governments that do not qualify for the biennial frequency per the provisions of the final rule to Craig Wingo as soon as possible. To accommodate the preparation of these lists for facilities that are impacted by two FEMA Regions, the Region wherein the facility is located should assume responsibility for forwarding the list to Headquarters.
Additional guidance on exercise scheduling will be forthcoming as well as guidance on other concerns and issues (e.g., public meetings) related to the requirements set forth in the final rule. In the meantime, refer specific problems to Headquarters.