ML20092E260

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Intervenor Exhibit I-EP-30,consisting of Gc Woodard Forwarding Regional Assistance Committee Informal Evaluation Comments on Offsite Radiological Emergency Response Plans
ML20092E260
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 05/09/1984
From: Woodard G
Federal Emergency Management Agency
To: Johari Moore
SOUTH CAROLINA, STATE OF
References
I-EP-030, I-EP-30, OL, NUDOCS 8406220358
Download: ML20092E260 (4)


Text

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. [' D Federal Emergency Management Agency i' Region IV 1375 Peachtree Street, NE Atlanta, Georgia 303093QETED g August 9, 1983

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Mr. Joshua P. Moore, Director '

South Carolina Emergency Preparedness , {p, gg Division f 7 Rutledge Building 1429 Senate Street DOCKET NUMBER g g4 Columbia, SC 29201 PROD. & UTIL FAC.. . . . . . .gT. . .

Dear Mr. Moore:

Enclosed for your review are the Regional Assistance Committee's (RAC's) iriformal evaluation comments on the Off-Site Radiological Emergency Response Plans for the Catawba Nuclear Station.' These comments are submitted to your office for appropriate action.

i The evaluation comments are the result of RAC meetings held on July 26-27, 1983, and represent con' curring opinions of all repre-sentatives of agencies present (i.e., FDA, EPA, NRC, and FEMA) .

!' Should you have questions or need clarification on any of the items, please contact John Heard at (404) 881-3442. -

Sincerely, Glenn C. Woodard, Jr., Chief Natural and Technological Hazards Division Enclosures i

NUCl[AR REGULATORY COMiftSSION l

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o' Federal Emergency Management Agency Region IV 1375 Peachtree Street, NE Atlanta, Georgia 30309 34 l

NUREG ITEM COMMENT (Note: Correlate with cited " Applicability and Cross-Reference to Plans"t A.1.a. Statement in IV.c. (York Co. Plan)" municipal-t ities' responsibilities is inconsistent with organizational concept on page iii, Section

' III.

Cross-reference inaccurate. (Possibly Q, A.l.b.

pp. 54-55)

  • i i A.l.c. Cross-reference inaccurate. .-

j A.2.b. Legal basis ambiguous in that it doesn't specifically include radiological hazards.

A.3. Letters of Agreement for several private sector organizations are missing. Also, agreements should "---identify the emergency measures to be provided and the mutually acceptable criteria for their implementation,

and specify the arrangements for exchange of information."

A.4. Cross-reference inaccurate.

C.2.a. Cross-reference inaccurate.

C.3. State Plan should be referenced.

C.4. Cross-reference inaccurate; also, some private sector L.O.A.s missing.

E.1. No reference for message verification.

E.2. Cross-reference - Table E, Page C-13. .

E.6. Needs statement: " Final acceptance of the A & N systems is pending final FEMA guidance."

' E.7. Sample release for General Emergency includes I unnecessary technical information, e.g., curies and projected doses. Was ad hoc respiratory protection considered in development of messages? (No. 4, page d-11)

G.I. No plant brochure.

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NUREG ITEM (con ' t) COMMENT (con't)

G.2. No brochure.

G.4.c. - No arrangements for rumor control.

G.5. No programs indicated for acquainting news media with emergency plans. (First cross-reference not included).

H.ll. Emergency equipment not listed for York County.

J.10.a. Evacuation routes within 10-Mile EPZ not marked on Radiological Emergency Response Map; also, radiation monitoring points are "

. not indicated.

J.10.c. See E.6. comment.

J.10.d. Plan does not indicate the County has iden-tified the mobility-impaired. Plan does not define "special facilities." (e.g., 0-28, item C-8)

J.10.k. Plan needs clarification of procedures by ~

which the transportation coordinator deals with special evacuation problems. Potential

. impediments in evacuation routes not addressed.

J.12. Need more description (procedures) of the means for registration and monitoring.

K.3.a. No provision made for permanent record devices or 24-hour capability to determine dosage.

K.3.b. No prescribed frequency for reading and record-ing dosimeters.

X.5.a. No action levels established for decontamination.

i K.5.b. Not adequately addressed. -

N.2.d. No provision for drilling of County personnel who have monitoring responsibilities as listed in 0-29.

N.4. Clarification of critique procedure is needed.

Plan does not mention a critique as soon as practicable after an exercise.

l N.5. The means and management controls for imple-menting corrective actions are not specified.

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NUREG ITEM (con't) COMMENT (con't) 0.1.b. If mutual aid agreements exist, the training of the personnel listed on page O-39 should be included.

O.4.j. The York County plan identifies training ~ for the P.I.O.; however, this person is not

' usually responsible for, or involved in, the transmission of emergency communications.

This appears to be the wrong emergency re-sponse role for the training.

P.2. Cross-reference inadequate. Individual not specified as " person responsible for REP planning." ,

P.S. Not addressed. .

P.S. Errors exist. Some have been described above.

P.10. No provision for quarterly updates of tele-phone numbers.

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