ML20086L295
| ML20086L295 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/05/1984 |
| From: | Cassidy B Federal Emergency Management Agency |
| To: | |
| References | |
| NUDOCS 8402080174 | |
| Download: ML20086L295 (29) | |
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84 FEB -5 T'n :?3 INTERIM FINDINGS ON THE ADEQUACY OF RAD'IOLOGICAL
- EMERGENCY RESPONSE PLAT!NING BY STATE AND LOCAL GOVERNMENTS AT THE WOLF CREEK GENERATING STATION, BURLINGTON, KANSAS Office of the Director Federal Emergency Management Agency, Region VII 911 Walnut Street Kansas City, MO 64106 December 13, 1983 Revised January 5, 1984 8402000174 840105 PDR ADOCK 05000482 Q PDR
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- 1. 0 INTRODUCTION This document constitutes the interim findings of tne Region VII .
Director of the Federal Emergency Management Agency (FEMA) on the adequacy of emergency radiological response preparation of State and local governments for incidents with potential off-site consequences at the 'Welf Creek Generating Station, located near Eurlington in Coffey County, Kansas. It compiles and summarizes evaluations of the relevant portions of the State of Kansas Annex A,,
Nuclear Facilities Incidents Response Plan to Assistance R, Nuclear Emergencies of the State Disaster Emergency Plan ,a and of the Coffey County Contingency Plan for Incidents Involving Commercial Nuclear Power.b It does not reflect changes in either Plan made after November, 1983 Moreover, it addresses only the consistency of plans and procedures with Federal guidance criteria and does not attempt to assess the actual response capabilities of State and local gove.nments with assigned responsibilities in the event of a radiological emergency at Wolf Creek. As of January 5,1984, no formal exercise of emergency response preparedness has been conducted by organizations with off-site responsibilities in the 10-mile inhalation pathway Wolf Creek emergency planning zone (EPZ).
aversion of' September, 1983 bVersion of September, 1983 4
1.1 Fall' l!Y AND SURnCUNDINGS The Wolf Creek Generating Station (WCGS) comprises a single-unit 1150 electrical megawatt (Net !Ge) pressurized water reactor for which construction is approaching completion. Fuel loading date is currently scheduled for August .
1984, fellowed by low power operati'on until commencement of full rated operation in the spring of 1985. The WCGS site is located east of the approximate geographic center of Coffey County, and includes a cooling lake for the facility with.a surface area of about eight square miles.
The surrounding land is rural in character, a gently ~ rolling landscape with no outstanding topographical features. Elevation ranges from 980 to 1200 .
Teet above sea level, with the plant itself at an altitude of 1110 feet.
The estimated populction of the 10-mile EPZ is 5,964 based on 1980 census data, at an average density of 14 persons per square mile. This population resides entirely within Coffey County. WCGS lies 3 5 miles northeast of Burlington (pop. 2,700), county seat of Coffey County, and 75 miles southwest of Kansas City, Kansas. Largely contained within the EPZ is the John Redmond Reservoir, a man-made recreational / flood control lake sited on the Neosho River, which is in extensive warm seasonal use for water recreation by visitors both from within and outside the EPZ. The John Redmond Da= is located 3.5 miles west of WCGS. Other centers of population within the EPZ in:lude New Strawn (800),
LeRoy (600), Ottumwa, Sharpe, Halls Summit, and Aliceville (all under 100) .
Three additional population centers, Lebo (950), Waverly (700), and Gridley (400), are outside the EPZ but have been included in planning provisions for protective response.
_ ___--_______1-____
l The fifty-mile ingestion pathway EPZ includes all or part cf the following Kansas counties: Allen, Anderson, Ecurbon, Chase, Coffey, Douglas, Franklin, Greenwood, Linn, Lyon, Miami, Norris, Neesho, Osage, Shawnee, ,
Wabaunsee, Wilson, and Woodson. The largest population center in this EPZ is Emporia (25,000), followed by Ottawa (12,000), Chanute (11,000), Icla (7,000),
and Garnett (3,000). Total population of this EPZ is approximately 200,000.
1.2 EMERGENCY PLANNING AUTHORITY AND ORGANIZATION In accordance with Kansas State Acts (K.S.A.)48-924, the Governor of the State of Kansas is empowered to issue a proclamation of a State of Disaster Emergency, which condition is defined by K.S. A.48-904 as t'the occurrence or immenent threat of widespread or severe damage, injury or loss of life or property resulting from any natural or man-made cause." The State Disaster Emergency Plan was developed to provide a framework for the authority, responsibilities, and' operations of state government under such a condition, and to effectively integrate the combined efforts of state, local and Federal-governments. Assistance R to this Plan defines the roles of state agencies in nuclear facilities incidents. K.S.A.48-905 establishes within the Adjutant General's Department, the Kansas Division of Emergency Preparedness (KDEP). The Adjatant General, in accordance with K.S. A.48-919, has designated within the KDEP an emergency preparedness programs administrator to carry out responsibilities empowered by K.S.A.46-907 that are required for meeting the provisions of the State Disaster Emergency Plan.
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K.S.A.45-929(d) provides that, in accordance with the standards and requirements for disaster emergency plans promulgated by the KDEP, ". . .each county, city and interjurisdictional disaster agency shall prepare and keep currect' a disaster emergency plan for the area under its jurisdiction, which has been approved after examination and periodic review by the division of emergency ,
preparedncss." The Coffey County Contingency Plan, for Incidents Involving
- Ccmmercial Nuclear Power was developed under this authority. In general,'the structure and philosophy of emergency response in the State of Kansas assi 6ns primary responsibility to local and county authoritics in the affected area, with the State providing support and resources on request. However, upon declaration of a state of disaster emergency by the governor, he or she becomes,
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by authorization of K.S. A.98-924, commander in chief over all emergency ,
resources and may ". . . require and direct the cooperation and assistance of State and local governmental agencies and officials" [(K.S.A.98-925(c)(10)].
Powers thus vested in the governor during such an extraordinary situation [(ref.
K.S. A.98-925(c)(1-9)) would effectively subordinate local and county emergency response plans and procedures.
Annex A to Assistance R (State Plan) is organized in parallel to the criteria elements of NUREG-0654/ FEMA REP-1 (Rev. 1), in that sections defining' the concept of operations, respective assignments of responsibility to Federal, State, local government and private sector agencies, and the interface responsibilities of licensees and volunteer agencies are followed by statements of procedure (tabs) each labeled according to'the corresponding criteria element (letter) of NUREG-0654 Additional materials, including a glossary, cross-reference table and draft letters of agreement conclude the document. The Coffey County Contingency Plan is subdivided into six principal sections 5
(Organization, Emergency Classifications and Action Levels, E=ergency Measures, Energency Facilities and Equipment, Maintaining Emergency Preparedness, Recovery), followed by appendices covering definitions, legal authority, tne e:ergency classification system for WCGS, a plan cross-reference, and evacuation time estimates for the 10-mile EPZ.
1.3 GENERAL STATUS OF PLANS AND PREVIOUS EXERCISES The status of plans and exercise demonstrations for the WCGS as of January 5, 1982 is as described in Section 1.0 of these Interim Findings.
1.4 MATERIALS AVAILABLE FOR EXAMINATION Kansas State Acts (48-900 through 48-934;19-813)
State of Kansas Disaster Emergency Plan Annex A, Nuclear Facilities Incidents Response Plan to
. Assistance R, Nuclear Emergencies -
Coffey County Contin 5ency Plan for Incidents Involving Commercial Nuclear Power Wolf Creek Generating Station Radiological EmerEency Response Plan Wolf Creek State and County REP Plans Technical Review (11/15/83) 6
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2.0 EVA*UATICN OF PLANS Evaluation of radiclogical emergency response planning of State and local, governr.ents for WCGS is by the FEMA Region VII Director, who is advised by tne Region VII Regional Assistance Cc=mittee (RAC). The Region VII RAC charged ,
with reviewing State and County Plans for WCGS is c.omposed of representatives of the following agencies:
- Federal Emergency Management Agency - Region VII -
- United States Department of Energy - Albuquerque Operations Office
- United States Department of Transportation - Region VII
- Environmental Protection Agency - Region VII ,
- United States Department of Agriculture
- United States Department of Health an'd Human Services - Region VII
- Food and Drug Administration
- Public Health Service
- United States Nuclear Regulatory Commission - Region IV The RAC Plan review was submitted in final form to the FEMA Region VII Director en November 15, 1983 A discussion of inadequacies with respect to planning standards that were identified by this review is presented below.
2.1 STATE OF KANSAS: ANNEX A, NUCLEAR FACILITIES INCIDENTS RESPONSE PLAN TO ASSISTANCE R, NUCLEAR EMERGENCIES, OF THE STATE DISASTER EMERGENCY PLAN 7
2.1.1 Assigr. ment of Responsibility (Organizatien Conteci)
- Plan Tab E. Sections 1.0 4.0 Although it clearly identifies and illustrates the operational roles of the agencies' to be involved in emergency response, the State' Plan neglects to identify a specific individual by title who shall be in charge of the emerger.cy response for each organization (NUREG-0654, Criteria Element A.1.d) or to specify responsibilities and functions in certain key areas of need (Criteria Element A.2.a), including accident assessment, protective response, and radiological exposure control. Where no primary responsibility is identified by the state for a particular function, other plans which assign this responsibility should be referenced (Criteria Element A.2.a).
The document reviewed contains no copies of signed Letters of Agreement with Ransom Memorial Hospital, the University of Kansas Medical Center and Federal agencies which have been assigned responsibilities in the Plan (Criteria Element A.3').
2.1.2 Emergency Response Support and Resources - Plan Tabs B, C. E. F, H, I Air field resources, command posts, telephone lines, radio frequencies and communications centers to support the Federal response are not identified (NUREG-0654, criteria Element C.1.c). Capabilities of all participating laboratory facilities are not fully described (Criteria Element C.3).
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The State Plan needs formalized (not draf t) letters cf agreement with Ransom Memorial Hospital and KU Medical Center. U.S. EPA response authority and capability are not correctly represented. Health physics support agreements should be considered with Cooper and Catlaway nuclear power facilities (Criteria Element C.4). .
2.1 3 Energency Classification System - Plan Tab D The Plan adequately meets the relevant planning standards. .
2.1.4 Notification Methods and Procedures - Plan Tabs E,G The Plan should specify that means for verification of messages are in place even if details are not included (NUREG-0654, Criteria Element E.1).
Otherwise, the relevant planning standards are adequately met.
Emergency Communications - Tabs E, F, L, N 2.1.5 The Plan should be more specific with respect to the means for backup communications from the near-site EOF to the Stat: EOC (NUREG-0654, criteria Element F.1.d). Otherwise, the relevant planning standards are adequately met.
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2.1.6 Public Education and Information - Tab G The Plan lacks needed detail regarding hew tile public " hot lines" to be set up in Kansas City, Topeka, and 'n'ichita will perform ru=0r centrol functions in a coordinated and consistent canner (NUREG-0654, Criteria Element G.L.e).
Specific content, organization, and State's role in annual news media briefing are lacking (Criteria Element G.5).
2.1.7 Emergency Facilities and Eculpment - Tabs C, E, F, H, I It is not clear in the Plan that reserve supplies of radiation detection equipment are adequate to replace those being calibrated (NUREG-0654, Criteria Element H.10). Moreover, available supplies are not described in terms of emergency kits, and the list is not sufficiently detailed for co: unications equipment and emergency supplies such as maps, forms, procedures, check sources, and consu= ables (Criteria Element H.11).
2.1.8 Ac~cident Assessment - Tabs H and I Specific instrumentation and proc (dures capable of ' detecting and neasuring radiciodine concentrations in the plume EPZ to the required resolution under field conditions are not identified in the Plan (NUREG-0654, Criteria Element I . 9 )'. The Plan is deficient with respect to the detailed information needed to determine whether measurements can be successfully related to esticated dose rates and to computation of projected and actual integrated dose.
The State does not identify any capability for itself in this role. Therefore, ccre information about specific procedures to be followed must be provided 10
(Oritoria Elor.ont I.10). Radiological monitoring procedures to be used in performing airberne plume tracking surveys are not described (Criteria Element
!.11).
2.1.9 Protective Response - Tab J Maps shown in the State Plan do not identify radiological sampling and monitoring points (NUREG-0654, Oriteria Element J.10.a). A decision chain for administering radioprotective drugs to the gereral population (Criteria Element '
J.10.f) is lacking in the State Plan, as is specific information on expected local protection afforded in residential units and other shelter (Criteria Element J.10.m). A decision has to be made whether or, not KI will be administered. If it is going to administered, a decision chain must be ou'tlined. If not a decision has to be made concerning alternate measures which will be taken.
No reference is made to maps for recording survey and monitoring and key land use data arid identifying water sheds, water supply intake, treatment plants and reservoirs in the ingestion pathway EPZ. Nor are there maps showing shelter areas. Procedures described for diversion of affected meat and poultry products are unclear, and detailed crop maps are not referenced (Criteria Element J.11).
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2.1.10 Radiolecical Excesure Control - Tabs H and K The State Plan does not stipulate that all personnel be provided both self-reading and permanent record devices (NUREG-065t, Criteria Element K.3.a).
In areas of possible high radiation exposure, the State Plan' stipulation that self-reading desimeters will be zerced and a record made of the readings on a daily (rather than an hourly) basis is insufficient (C'riteria Element K.3.b).
Action levels for determining the need for decontamination are not provided (Criteria Element K.5.a). Means for waste disposal not provided.
(Criteria Element K.5.b).
2.1.11 Medical and Public Health Support - Tab L Draft Letters of Agreement presented in the State Plan must be finalized and signed in order to complete required medical support arrangements (NUREG-0654, criteria Element L.1). Letters of Agreement with Ransom Memorial Hospital and EU Medical Center have not been signed, and the available capacity of neither of these facilities is discussed (Criteria Element L.3). Specific arrangements and a Letter of Agreement with the Coffey County Ambulance Service must be finalized (Criteria Element L.4).
2.1.12' Recovery and Reentry - Tab M A method, for periodically estimating total population exposure during reentry and recovery is not describec or mentioned in the Plan (NUREG-0654, Criteria Element M.4).
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2.1.13 Exercises and Drills - Tat N
. There is no explicit provision in the Plan for conducting exercises in conformance with the requirement that one start between 6:00 p.m. and midnight, ,
and another between midnight and 6:00 a.m. once ev.ery sih years. There is no provision for exercises to be conducted unannounced or under various weather conditions (NUREG-0654, Criteria Element N.1.b).
H.ealth physics drills are not specifically covered in the referenced section of the State Plan (Criteria Element N.2.3). Plan language should be revised (p. N-2) to permit non-FEMA Federal observers.(Criteria Element N.4). ,
s 2.'1.14 Radiological Emergency Response Training - Tab 0 The Kansas Plan's training provisions should be revised to include the followinF.
1.) Provide training to the Kansas Fish and Game Commission personnel in " Radiation Survey Instrumentation" to complemeat their role in' the Plan.
2.) Provide training to the Kansas Department of Social and Rehabilitation Services personnel in " Overview of the Three Emergency Plans" to complement their role in the Plan.
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3.) Provide training to the Governor's Cffice in " Overview of the Three Emergency Plans" and " Position and Role in Emergency Plan."
t.) Provide training to emergency workers to comple ent their roles in the State Plan.
S.) Provide training for the U.S. Corps of Engineers and the U.S. Fish and Wildlife personnel for their roles in the State Plan.
2.1.15 Responsibility for the Planning Effort - Tabs P and M The State Plan adequately meets the relevant planning standards.
2.2 COFFEY COUNTY CONTINGENCY PLAN FOR INCIDENTS INVOLVING COMMERCIAL NUCLEAR POWER 2.2.1 Assignment of Responsibility - Sees. 0.1. 0.3. 1.2, 1.2.1. 1.2.2, 1.4, Appendixes B and D Table i-1 of the County Plan appears to be inconsistent with assignment of responsibility in the State Plan, which identifies a support role for the County in provision of social services that Table 1-1 does not acknowledge (NUREG-0654,' Criteria Element A.2.a) .
The County Plan does not in:lude Letters of Agreement with the Kansas Forestry Conmission; the U.S. Fish and Wildlife Service; the U.S. Army Corps of Engineers; Unified School Districts No. 243, 2tu, and 245; the Coffey County u____________._______--________-____--_--_--.----- - - - - - - . - - - - - - - - - _ _ _ - - _ _ _
Fire Sapartment; and county schoci bus services; all of which would be involved in alert notification and possible evacuation of institutional and transient populations, and in ether response activities. It is important that, where State agencies will be relied upon by the county to perform or augment emergency functions, written agreements with those agencies be in' place (Criteria Element * .
A.3), where the agencies' responses are'not accounted for under the Kansas State
. Acts.
2.2.2 Emergency Response Support and Resources - Sec. 1.4, 4.0 and Appendix 0 Resources to support Federal response not identified (NUREG-0654, Criteria Element C.1.c). Key Letters of Agreement are lacking from the County -
Plan, as described above (Criteria Element C.4).
2.2.3 Notification Methods and Procedures - Sees. 3.2-3.4 The County Plan provides a description of how the tone aiert program will be administered in Appendix H, p. H-8. However, additional information will be required in order to bring it into compliance with the " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants,.
FEMA 43."
The Plan contains draft procedures for the U.S. Corps of Engineers, U.S.
Fish and Wildlife Service and Kansas Fish and Game Commission concerning their alerting roles for the John Redmond Reservoir. Thus far only the Kansas Fish and Game Cc= mission has signed a Letter of Agreement committing itself to the Plan.
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l Also, in crder to evaluate the adequacy of these procedures, a descriptien should be available of how individuals in the recreation areas can be provided an alert signal within 45 minutes. Further information is required on how this 25 minute notification criteria is to be met.
2.2.4 Emerzency Cemmunications - Sees. 1.2, 1.2.2, 3.2. 3.10, 4.2, 5.2 A primary and back-up means of communication for alerting, notifying and mobilizing emergency resources is required (NUREG-0654, Criteria Element F.1).
The County Plan indicates that the fire departments, school superintendents and school buses in Coffey County do not have a back-up means of communication with the County EOC. The County Plan indicates that a radio system has been preposed which would serve this purpose. This system should be implemented to fulfill the planning standards.
Public Education and Information - Sees. 1.2.4. 3.4, 5.4 2.2.5 More detail is needed in the County Plan regarding the County's arrangements for rumcr control. Procedures for collection and transmittal of rumor reports to the State PIO and KG&E are inadequately described. The Ccunty PIO's responsibility regarding confirmation, denial, and follow-up on rumors is not clear (SUREG-0654, criteria Element G.4.c).
'The Plan does not adequately specify the content of the annual training program and briefing for news media - see comments for this standard under review of State Plan (Criteria Element G.5).
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L r, 2.2.6 Emergency. Facilities and Equipment - Sec. 3.2, 3.10. u.1, 4.3.1 There is insufficisnt ipformation in the County Plan regarding supplementary emergency e;uipmenti3uch as check sources, maps, forms, ,
procedures, and consumables (EUREG-0654, Criteria . Element H.11). This equipment is alluded to but not listed'.
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AccideAt Assessment O Sees. 3.10, 4.3.1 2.2.7 Cou'nty activity will be very limited in this area. County Plan adequately meets relevant planning standards. , ,
I 2.'2.8 Protective Response - Sees.- 0.3, 3 2, 3.3, 3.3.1, 3.3.2, 3.6-3.8
' Preselected radiological sampling'and monitoring points are not shown on
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any map (NUREG-0654, Criteria Element J.10.a). If missing from the State Plan, such a map must be includ.ed in the County Plan.,
i No provisions are made in the Plan for. sheltering or . evacuation of the incarcerated as an institutionalized populstion (Criteria Element J.10.d).
Ambulance and school' evacuation capability is unclear without signed Letters of Agreement with 'ambulan6e and school bus companies (see above) (Criteria Element J.10.g). ,
" _ _ _ _ _ _ _ - - - _ - - - . _ _ _ - _ _ _ _ _ _ _ _ _ - - - - _ - . - _ - _ _ _b
The County Plan's Evacuation Time Estimates ( Appendix K), provide the summary evacuation times for two conditien - average and adverse. But the adverse weather frequency used in the analysis is not identified, nor is its seversity specified,in order to define the sensitivity cf the analysis to the selected events. (NUREG -0654, Appendix 4, sec. IV. A., p. 4-6). There is not, therefore, an indication of the range of adverse weather to which the evacuation times apply.
The County Plan's Evacuation Time Analysis (Appendix K) indicates that, the population at risk was divided into three groups: permanent residents, transients, and specia'l facility populations. But the analysis does not indicate that the permanent residents were divided into two subgroups: 1) those using autos, and 2) those without autos; nor does it give attention to those households not having autos (NUREG-0654, Appendix 4, sec. II. A. , pp. 4-2&3) . A list of these households which do not have autos or who are otherwise transportation dependent should be obtained and r.aintained.
The County Plan's Evacuatioa Time Analysis ( Appendix K, p. K-5) indicates that special population groups include Coffey County Hospital, Golden Age Lodge, and schools, preschools and day-care centers (NUREG-0654, Appendix 4, sec. II. C., p. 4-3). But there is no indication of how the schools are accounted for in the evacuation time estimates. The summary evacuation times account for the County Hospital and Golden Age Lodge, but not the schools (Table K-7, p. K-19). The summary evacuation times do not provide for both average and adverse weather condition time estimates for the Hospital and Golden Age Lodge,,
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The~~,cunty Plen's Evecuation Tima Analysis (Appendix K, p. K-5).
indicates that the transient populacion includes the work force at the WCGS site (NUREG-0654, Appendix 4, sec. II. B. p. 4-3). But this portion of the transient population is,not ind'icated to be inc luded.'in the estimates for either of the -
two cases of weather condition (Table.K-3, p. K-12; Tab'le K-7, p. K-19) .
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. The County Plan's Evacuation Time Analysis ( Appendix K, p. K-5) indicates that the transient population includes the occupants of motels and hotels (NUREG-0654, Appendix 4, sec. II. B., p. 4-3). But there 13 no.
indication of how the portion of the transient population is accounted for in the evacuqtion time estimates. The summary evacuation times. account for trans ents at the John Redmond Reservoir, but not other transients (Table K-7,
- p. K-19).
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- 2. 2.' 9 ' Eadiological Expvaure Ocathc1-Oscs.3.7,72 jThe County Plan does not adequately address the issue of' disposal of liquid or solid waste of decontamination, nor, of the treatment of persons with s contaminated wounds or possible internal contamination. ;No list of supplies, instruments or equipment was found, nor was there a list of the number of
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emergency workers who will need to be supplies with this equipment. T1.e Plan should also specify the location of the supplies, instruments and equipment as well as procedures fort distribution (NUREG-0654, Criteria Element K.3.a and K.5.b). -
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2.2.10 M2 dical and Public Health Support - Secs. 1.2.7. 3.11 5.1
.The County involvement in this activity is very limited. However, participation of Coffey County Hospital and A=bulance Service in transporting victics of radiological ac,cidents is alluded to in the County Plan, yet no ,
formal agreene.qt is in place (NUREG-0654, Criteria Element L.4).
'2.2.11 Recovery' and Reentry Planning and Postaccident Operations - Sec. 6.0 The County Plan adequately meets the relevant planning standards. Most responsibility in this area is deferred to the State.
2.2.12 Exercise and Drills - Sec. 5.2 reenty Dlan adannatel y maats the relevant planning standards . . -
2.2.13 Radiological Emergency Response Training - Sec. 5.1 The County Plan's training provisions should be revised to provide the following.
1.) Trair.ing for bus drivers .in " Basis Radiation Effects and Protection."
2.) Training for volunteer teams that are to provide medical care in "Easic Radiation Effects and Protection." .
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k 3.) Training for the County Hamith Officer, Traffic Centrol, the Health and Medical Management Team and The Nursing Home Administrator and staff in " Basic Radiation Effects and Protectio'n."
4.) Training o'r the Fire Leader and personnel'should include " Basic .
Radiation Effects and Prot'ection" and "Self-Protection Radiation Monitoring" for those who may be exposed to radiation.
5.) Training of emergency workers should be considered an important part of the County Plan. More attention should be given to these workers, and they should be provided with Eroup and individual training programs.
6.) Provide training for U.S. Corps of Engineers and U.S. Fish and Wildlife personnel for their roles in the Coffey County Plan.
2.2.14 Resoonsibility for the Planning Effort - Sees. 0.1, 1.2.'1, 1.2.3, 5.1, 5.3 .
The list of contingency plan implementing procedures in the County Plan document does not reference the section of the Plan to be implemented by each procedure (NUREG-0654, Criteria Element P.7).
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SUMMARY
07 FINDINGS The Regional Director of FEMA Region VII has determined that State and County response Plans and procedures for a radiological emergency at Wolf Creek Generating Station are generally adequate in complying with the planning standards set forth in NUREG-0654/ FEMA Rep-1 (Rev. 1) guidance document, and are capable of being implemented. At this time.the Regional Director can make no finding regarding the actual degree of emergency. preparedness of agencies charged with'off-site responsibilities for such an incident, as no exercise of such preparedness and capabilities has yet been conducted. The following suggestions for bringing Plans and procedures into full compliance with
.NUREG-0658 are presented first with reference to the State Plan, then to the Coffey County Plan,. then for the two plans jointly.
'31 STATE OF KANSAS
- Key individuals in the emergency response command and control structure are identified by organization but should also be named by title. (NUREG-0654, Criteria Element A.1.d) . The Plan needs a more
, thorough discussion of specific responsibilities and functions in the ,
creas of accident assessment, protective response, and radiological exposure control. References to an SOP may be useful. (Criteria Element A.2.a) 22
The Stato should specify that means for verification of messages transmitted over non-dedicated communications links are in place.
(Criteria Element E.1) Federal support resources are missing (C.1.c). -
- The Plan should more specifically identify the' backup communications links among the nuclear facility, the EOF, the State and County EOCs, and state radiological monitoring tetms. (Criteria Element F.1.d)
- The Plan lacks detail regarding how rumor cont ' ol functions are to be performed and coordinated. (Criteria Element G.4.c)
- Specific content, orSanization, and role of the State in the annual news media briefing and training program should be described.
(Criteria Element G.5)
- The inventory of radiological monitoring equipment'and discussion of procedures do not include instrumentation for monitoring ambient concentrations of radiciodine. (Criteria Element I.9)
- T'he Plan should identify a decision chain for possible administration of radioprotective drugs for the general population. (Criteria Element J.10.f)
- The Plan must include maps for monitoring locations, land use data, and water source data (J.10.1).
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- Self-reading dosimeters -issued to -ccergency workers -should be read ati ,
least ac heurly intervals, rather than daily as indicated by the Plan. (Criteria Element. K.3.b) Action levels for determining the need for personnel decontamination should also be provided. (Criteria, Element K.5.a) .
-- All draft and/or missing Letters of' Agreement with response organizations identified by the Plan but not covered by blanket provisions of the Kansas Stste Acts or other status must be finalized andfprovided in the_ Plan. (Planning Standards A, C, and L)
- The Plan should include or reference a_ method for periodically estimating total population exposure durin6 and after reentry.
i (Criteria Element M.4).
- Need 'to include many factors regarding exercises and drills (N.1.b, N.2.e, N.4)
- The Plan's training provisions should be revised and expanded for
,vario'us state and federal agencies and other emersoney workers (Criteria Element 0.1).
t-J3.2 COFFEY' COUNTY -
- The Plan's evacuation time estimates need to be described in more -
detail. _ Consideration needs to be given to the segment of the population at risk that does not have automobiles. The schools, l 24
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' transient population of hotels and motels and work force at the Wolf Creek Generating Station site must be accounted for in the evacuation time estigates (NUREG-0654, Appendix 4, Sections II. A, II.B, II.C, IV.A). .
- The Plan's training provisions should be revised and expanded for
. various local emergency responders (Criteria Element 0.1).
- Letters of Agreement with key Federal agencies responsible for -
protection of the transient population in and around the John Redmond Reservoir have not been finalized. Letters of Agreement with the
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State of Kansas and.with the County Fire Departesnt, three unified school districts, and with identified school bus and ambulance .
services also appear to be necessary. (Planning Standards A, C, and L)
- The~ Plan should provide lists of emergency equipment (K.5.b) (H.11)
- Maps missing (J.10.a)
--Lacks decontamination procedures (K.5.b) t 33 COMBINED STATE AND COUNTY ISSUES
- In comparing the State and County Plans, the responsibility for arranging for or providing social services support ir not clearly defined and may be inconsistent. (Criteria Element A.2.a) 25
County / State interface in the'following areas remains insufficiently
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specified: rumor control, treatment of contaminated / injured patients, disposal of decontamination wastes, provision and content of ,
emerEency kits., (Criteria Elements G.4.c, K.3.b, H.11) 6 e
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t e
d e
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UNITED STATES OF AMERICA C y,L.'3 7f '
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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
'84 FEB -6 AK):2B
<-.:.v in the Matter o' C 5I
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KANSAS GAS and ELECTRIC CO., et al ) Docket No. STN 50-482
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(Wolf Creek Generating Station, Unit 1) )
CERTIFICATE OF SERVICE 1, Brian P. Cassidy, state that copies of the Interim Finding of the Federal Emergency Management Agency, were served by mailing franked enveloos, or by delivering in hand, to the persons identified on the attached service list, on this 3rd day of February,1984. c__. .
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- _, _m-L BRtA4-P. CNSSIDY Regional Counsel Federal Emergency Man ment Agency SERVICE LIST Sh~eldon J. Wolfe Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U. S. Nuclear Regulatory Comnission U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. George C. Anderson Docketing and Service Section Department of Oceanography Office of the Secretary University of Washington U. S. Nuclear Regulatory Commission Seattle, Washington 98195 Washington, D.C. 20555 Dr. Hugh C. Paxton Atomic Safety & Licensing Board 1229 41st Street U. S. Nuclear Regulatory Commission Los Alamos, N.M. 87544 Washington, D.C. 20555 C. Edward Peterson, Esq. A. Scott Cauger, Esq.
Asst. General Counsel Asst. General Counsel Kansas Corporation Commission Missouri Public Service Commission State Office Building 4th Floor P.O. Box 360 .
Topeka, KA 66612 Jefferson City, M0 65102 l
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s Kent M. Ragsdale Myron Karman. Esq.
General Counsel -
Office of the Ex~ecutive Missouri Public Service Commission Legal Director P.O. Box 360 U. S. Nuclear Regulatory Commission Jefferson City, M0 65102 Washington, D.C. 20555
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Eric A. Eisen, Esq. Jay E. Silberg, Esq.
Birch. Horton, Bittner & Monroe Shaw, Pittman,.Potts & Trowbridge 1140 Connecticut Avenue, N.W. 1800 M Street, N.W.
Washington, D.C. 20036 Washington, D.C. 20006 John M. Simpson, Esq,. A. Rodnan Johnson, Esq.
4350 Johnson Drive 820 Quincy, Suite 120 Suite 120 Topeka, KA 66612 Shawnee Mission,'KA 66205 Alan S. Rosenthal, Esq. Dr. John H. Buck Atomic Safety Licensing Atomic Safety and- Licensing Appeal Board Appeal Board U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555-Thomas S. Moore, Esq.
Atomic Safety and Licensing Appeal Board U .S. Nuclear Regulatory Commission Washington, D.C. 20555 G
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Pr.c 2IQ -
. O '0 U 2iDtH TDP.; Educrd L. Jorden Dirtetor Divicion of Ere gency Prcptrednees
' Ind Engineering Rerpsara Dffice of Inspection cad Enforcer.ent -
U.S. Nuclecr.teguletory Connierion I't7d: P 6NC
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p) C J.scircr.nt Associcte Director o!! Lee of Naturcl and Technologice.1 Estr.eds Prograr.a ECEJE C:
Interie Yinding Eurlingtor., Kensason ths Volf Creek Generatin Stetion, t.t the Atonic Scietr cud Licencing Lots Eecrings the veek of January 16
, 1984, Judge Felic indicc:ed c preference for :sching esci1rble to the Esard the interic findins;
- .._nerendue en Vcif Creek which was referred to 1n ey Janus.ry 13, 1984, to ye.
by TEMi f,egion VII, dsted Dece=ber 13,19E3, as revised Janua.y 5 This interit 1982 (Sep:enber Finding is based only on a review cf 5 tete and icesi plans revicien).
July 10,1954, A que.lifying exercise is scheduled for cffti:e preparedness at Wolf Creak.cnd the resultc vill enable Frf'.A to report on the status o
/. fin:!ing as to whether State and locc1 emers;eney piens are capable of being i=planented is contingent upos:
D the correction of deficiencies noted in the Interir. Finding end 2) the tdcquacy and r.aintencnce of proceduras, treining, resources , a:affing Icvcic and iguelifiestions, s.nd equipnent cdequacy.
The ette:hed letter l'.Ocn the T.cosas
- 2. F.er, ion VII, deted January Diricles cf tetrgency Prsperet. ness to the~ P.e;:icntl Director 23, 1984, indicatts the co.nents fron the ,
t::r.che.d li t t. . Interis Yinding vill be incorporated into the State plan by June 29 ,
iiovaver, the Str.te of Kanses has still been requested te subnit e
(-~:tled'
... h: picns. schedule of corrective actiotts relcted to any deficiencies fo und - -
then
-f ~.1 changes be fc:ve,rded in thetoetetus of cffsite plans and preparedness occur, addenda your offict,
/.*.t t t): ent s .
LC Stcted C.i)nT/ 51. Reading / Speck /SL:NT:T.rin /SL:l!!:7E:Chron, Pile MI "r:rGREE!
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