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 PROD. & UTIL FAC........gT... g g4 Columbia, SC 29201

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 34 Region IV 1375 Peachtree Street, NE Atlanta, Georgia 30309 COMMENT NUREG ITEM Correlate with cited " Applicability and Cross-Reference to Plans"t (Note:

A.1.a.

Statement in IV.c.

(York Co. Plan)" municipal-ities' responsibilities is inconsistent with t

organizational concept on page iii,Section III.

A.l.b.

Cross-reference inaccurate.

(Possibly Q, 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 unnecessary technical information, e.g.,

curies I

and projected doses.

Was ad hoc respiratory protection considered in development of messages?

(No.

4, page d-11)

G.I.

No plant brochure.

e

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

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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 l

practicable after an exercise.

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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