ML20092G078

Forwards Final Rept for 830517 Offsite Radiological Emergency Preparedness Exercise & State of Nc Corrective Action Schedule.Exercise Satisfactory

ML20092G078
Person / Time
Site:	Brunswick
Issue date:	06/19/1984
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20092G080	List: ML20092G078
References
NUDOCS 8406250050
Download: ML20092G078 (12)

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N 4 Federal Emergency Management Agency (n)

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Washington, D.C. 20472

>J gg.yd JUN I 91984 gd MEMORANDUM FOR:

Edward L. Jordan Director, Division of Emergency Preparedness and Engineering

Response

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission FROM:

ic im Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

Final Report for the Brunswick Nuclear Power Plant Exercise Attached is the final report for the joint offsite radiological emergency preparedness exercise conducted on May 17, 1983, for the Brunswick Nuclear Power Plant with the State of North Carolina and New Hanover and Brunswick fQ)

Counties.

Also attached is the schedule of corrective actions which address s'/

each deficiency.

Although there were deficiencies observed at this exercise, they did not detract from the overall demonstrated capability by the State of North Carolina and New Hanover and Brunswick Counties to protect the health and safety of the public.

If you have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 287-0200.

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116 West Jones Street Raleigh 27611 James B. Hunt, Jr., Governor Division of Emergency Management Hcman R. Clark, Secretary (919) 733-3867 August 12, 1983 Mr. Glenn C. Woodard, Jr.

Federal Emergency Management Agency Region IV 1375 Peachtree Street, N. E.

Atlanta, GA 30309

Dear Mr. Woodard:

Enclosed is the response to the final report for the Brunswick i

Nuclear Power Plant exercise. Each NUREG-0654 item listed in Sections IV and V of the report has been addressed. When appropriate, the dates for correcting the deficiencies have been indicated by t

underlining.

New Hanover County plans to more fully activate its E0C during the next exercise.

Sincere

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l J sse T. Pugh, III kl Enclosure l

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r BRUNSWICK NUCLEAR POWER PLANT -- 1983 EXERCISE l

Correction Schedule - Significant Deficiencies s

NORTH CAROLINA Public Education and Information (G.4.b.?: The SERT PIO will arrange a train-ing conference for public information officers directly concerned with incidents at the Brunswick Nuclear Plant. This conference will be conducted prior to September 19, 1983.

l NEW HANOVER COUNTY Assignment of Responsibility (A.1.a.): The exercise in this county was intentionally designed to limit partncipants to selected agencies. The agencies selected to participate were identified and the extent of their involvement was decided prior to the exercise. A greater number of agencies will participate in the next exercise.

Public Education and Information (G.2.):

Public information activities did take place during the exercise. 7he Public Information Officer wrote, coordinated, and released the first EBS message during the exercise. There-after, there was no public information that required a unilateral release by New Hanover County. An effort will be made to more fully demonstrate this function during the next exercise.

V Public Education and Information (G.3.a..G.4.a..G.L.b..G.4.c. ): The agency identified in the olan as being responsible for pu)lic information fulfilled that role during the exercise. The procedures regarding this function are clear and work well.

In this case, the evaluator seemed to think that a single individual should be appointed as the public information officer.

Very few county governments can afford such luxury. The plan does assign the responsibility and describe the manner in which the PIO function is to be accomplished. Also, as stated earlier, an effort will be made to more fully demonstrate this function during the next exercise.

(Seealso Significant Deficiencies - North Carolina. The necessary training will be conducted by September 19,1983.)

Protective Response (J.IO.d.): The plan provides for protecting mobility-impaired people.

It wac not intended to exercise this portion of the plan.

An effort will be made to more fully demonstrate this function during the next exercise.

Radiological Exposure Control (K.3.b.): The instruments being used were in current calibration (the evaluator might have been referring to an operational check).

In any case, refresher training will be initiated by September 19, 1983.

This training will include instruction in the proper use of the instrumentation and record-keeping by emergency response organizations.

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Exercise and Drills (N.1.a. and N.I.b.): As stated earlier, an effort will be made to more fully demonstrate the ability of the county's staff during l

the next exercise. However, the evaluator who rated New Hanover County should take r.ote of two facts: one, the exericse plan was approved by FEMA i

Region IV; and secondly, NUREG-0654 (N.1.b.) does not require that all major i

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elements of plans and preparedness organizations be tested during every exercise.

It appears that in this case, the evaluator's knowledge of require-ments and response procedures was limited to a checklist.

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BRUNSWICK COUNTY l

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l Emergency Facilities and Equipment (H.3.): An effort to find a larger space in which to locate the county EOC is underway. The decision concerning this move will be made by September 19.1983.

t Public Education and Information (G.4.b.):

See the comment under Significant I

Deficiencies - North Carolina. The necessary training will be completed by i

September 1, 1983.

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Correction Schedule - Minor Deficiencies

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NORTH CAROLINA Emergency Comunications (F.1.d.):

Pehmanent antennas will be installed at the pre-selected State Emergency Response Team (SERT) operations facility in Wilmington. These antennas will be higher than.the portable antennas pre-vicusly used and should improve comunication between SERT and the radio-i logical mobile laboratory. The antennas have been ordered and should be installed by September 30, 1983.

Assignment of Responsibility (A.4.): The Radiation Protection Section has i

recently added four fulltime staff members qualified to serve as field survey team members.

This addition gives us 13 fulltime technically qualified l

staff members; and, combined with 5 secretaries, we will possess ~a staff of 23 individuals who can serve as comunications personr.el during an emergency.

Two additional staff menbers (one Deputy Chier and one Technical Planner /

Trainer) are in the process of being hired. These additions will bring our l

personnel strength up to 25 members.

Our TOREV (Team of Radiological Emergency Volunteers) members from the Health I

Physics Society are programed to augment our regular staff as comunication.,

and technical supporters during a continuous operations mode. TOREV support j

is currently estimated to be 32 individuals during a protracted situation.

i Monetary restraints restricted the numbers of comunications personnel that i

i could be committed to the May 17, 1983 Brunswick Exercise.

Further, a SERT Interagency Comunication Support Team has been organized to

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j provide support during protracted exercises or real emergencies. Adequate

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staffing, then, is already available.

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A Emergency Classification System (D.3.):

Large, easily read plaques have l

been ordered to display the appropriate emergency classification in the SERT I

operation room. These plaques will be on hand by September 1,1983.

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Public Education and Information (G.3.a.):

Space for the media at the SERT facility is deemed adequate; it is the largest room available. Telephones

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were not installed for the exercise because of the expense and because media representatives were not expected (and did not visit) at the facility in great numbers. Within the limits imposed by physical restrictions, facilities for media representatives will be provided during real emergencies.

v Public Education and Information (G.4.a.): See the corrnent on G.4.b. under Significant Deficiencies - North Carolina. The necessary training will be conducted prior to September 19, 1983.

Public Education and Information (G.4.c.): The rumor control function was v

not played during this exercise.

It was emphasized during the Brunswick Exercise in August 1981.

Rumor control procedures in the North Carolina Emergency Response Plan are considered adequate as written.

Also see the consnent under Significant Deficiencies - North Carolina; training in this functional area will be conducted by September 19, 1933.

Accident Assessment (I.8.): We do not agree that there was any confusion with respect to the difference between " population dose" and " individual dose" projections. No Radiation Protection Section staff member even considers

" population dose" (meaning number of people multiplied by projected exposure)

O the confusion which the evaluators felt had occurred.

for the very reason that it can create a multitude of numbers subject to We will continue to deal only in terms of INDIVIDUAL DOSE PROJECTION OFF5ITE.

Nor does Carolina Power and Light Company employ a concept of " population dose" meaning population multiplied by the individual dose to a member of the population. The 70,000 REM iodine thyroid dose projection which was referred to actually occurred and in retrospect resulted from faulty controller information on radiation measurements in the field, which resulted in back calculations to disturbingly high numbers. These back calculations were later redone and came up with a lower number on the order of 7,000 REM thyroid dose.

With respect to these very high dose projections, both CP&L and the Radiation Protection Program personnel came up with comparable numbers. Again, there was never any consideration of " population dose."

It was never interpreted to be " population dose," rather " individual dose."

i Protective Res)onse (J.10.n..): The Radiation Protection Section planned compliance witi J.10.m. is by reco" mended protective actions, based on PAGs in the plume EPZ, to be available from three sources if needed, i.e., SERT Radiation Protection representative, Radiai. ion Protection computer center as 1330 St. Mary's Street, and the mobile lab in the field.

It is expected that the primary source of recommended protective actions will come from the Radiation Protection Section's representative in SERT who will most likely make use of computer and computation personnel at 1330 St. Mary's Street.

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L Better direction of mobile laboratory personnel is expected during future

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exercises _ as a result of a planner / trainer person being on the staff of the N

Radiation Protection Section.

In addition, key personnel assigned to the mobile laboratory are now more familiar with their responsibilities.

Protective Res)onse (J.9.): The Licensee advises that, according to the i

U. S. Nuclear Regulatory Commission report on the exercise, they followed their procedures correctly. However, in light of this comment, the Licensee will reevaluate their procedures for recomending protective actions by September 1, 1983.

Protective Response (J.10.e.): Standard Operating Procedure (SOP) of the Radiation Protection Section requires that the decision to use Radioprotective Drugs (KI) be made at SERT by the Radiation Protection Section's representative.

The Radiation Protection Section has the delegated authority to administer the first KI to its field personnel, based upon its own judgment. More training coupled with hardcopy communications will speed up the decision to dispense Radioprotective Drugs (KI) and implementation of the decision in future exercises or emergencies.

Recovery and Reentry and postaccident Operations (M.4.): This function was not played during this exercise. Consideration will be given to demonstrat-i ing this function during the next full-scale exercise.

NEW HANOVER COUNTY Assignment of Responsibility (A.4.): The exercise, as approved by FEMA Region IV, was not of sufficient length to require two or more shifts.

Con-sideration will be given to demonstrating this capability in a future exercise.

Also, see earlier coments on exercise design.

Assignment of Responsibility (A.1.d.):

It is physically impossible to place 1

I a full emergency operation center staff in the 911 emergency communication center that functions as the county warning point. Therefore, even if the E0C was located in the same building, a solit operation would result.

Coordination between the two sites has been effective in the past. Careful attention will be devoted to the coordination between the two sites in future exercises.

l Assignment of Responsibility (A.2.a.):

See earlier coments on exercise design, requirements, staffing and future exercises.

Emergency Facilities and Equipment (H.4.): The complete emergency staff was i

alerted during the initial notification process, and the complete emergency l

staff was advised each time the plant emergency status changed. The evaluator I

must not have checked the logs. As earlier stated, the staff was mobilized i

on a selective basis.

See earlier comments on exercise design, requirements, staff, and future exercises.

Emergency Classification System (D.4.):

See earlier coments on exercise p

design, requirements, staffing, and future exercises.

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[7 Protective Response (J.10.c.): The exercise permitted free play by local

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government. Specific actions were to be demonstrated. Some of these actions were not evaluated because the single field evaluator became lost. Further, this function has been informally tested many times in prior exercises.

It is our understanding that FEMA has not yet devised an accepted scientific method to test siren systems.

In any case, this function will continue to be tested in future exercises.

Protective Response (J.10.c.?: 'See earlier coments on exercise design, requirements, staffing, anc future exercises.

Protective Response (J.10.e.): The sheriff's vehicle intended to pick up KI for emergency workers departed the sheriff's office on a back-up alerting task prior to receiving instructions regarding KI. The personnel responsible for this function have already been re-briefed.

Protective Response (J.10.J.): Because the federal evaluator lost his way, this action was carried out twice.

In the judgment of local law enforcement officials, one officer at the control point in question was sufficient because of the small population involved, and because access to the area is limited.

Further, additional traffic control personnel will be available if needed.

Consideration will be given to a more extusive demonstration of this function in the next exercise.

Radiological Exposure Control (K.3.a.):

Emergency response personnel will receive refresher training in the use of survey meters, dosimetry and p) dosimetry records. This training will be initiated by September 19, 1983.

(v Radiological Exposure Control (K.5.a.): An actual wash-down of a contaminated (simulated) vehicle was not scheduled as a part of the exercise. Considera-l tion will be given to demonstrating this function during the next exercise.

i Notification Methods and Procedures (E.2.): As stated earlier, the complete EOC staff was alerted when the exercise began and notified each time the emergency classification changed. Consideration will be given to participation by a larger part of the E0C staff during the next exercise.

BRUNSWICK COUNTY Notification Methods and Procedures (E.5.): See the coment under Significant Deficiencies - North Carolina. The necessary training will be conducted by September 19, 1983.

Notification Methods and Procedures (E.7.): See the comment under Significant Deficiencies - North Carolina. The necessary training will be conducted by September 19, 1983.

"ublic Education and Information (G.4.c.): See the coment on G.4.c. under f

Minor Deficiencies - North Carolina. The necessary training will be conducted j

by September 19, 1983.

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Protective Response fJ.12.): The radiological monitor assigned to the West Brunswick High School did not report to the shelter. The Emergency Operations Center was not informed of this problem until near the end of the exercise.

Assignments and procedures to report operational problems will be corrected during refresher training conducted by the county prior to September 30, 1983.

i Protective Response (J.10.J.): An inventory of all raidological defense.

l equipment and refresher training on the instruments will be completed by Seotember 30. 1983.

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Thank you for the observations contained in the final report of the April 6, 1983 Oconee Nuclear Station Full Scale Local fT Txercise.

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V The deficiencies identified by the rederal Evaluation Team have Con ents relative to the been reviewed by this division.

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report follcw the appropriate noted deficiencies.

1.

Emergency Facilities and Equipment (NUREG H.3):

The Pickens County EOC is not a permanent facility.

Working space is at a minimum, but adequate.

The facility would probably not be effective for a sustained operation.

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The State and the Pickens County Director are aware of this deficiency.

Pickens County has plans for construc-tion of a new EOC or renovation of an existing building.

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For fiscal reasens, these plans have been delayed; however, the plans exist.. Application will be made to obtain federal matching funds t.o unke the EOC meet federal

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Rumor Control did not appear to be udcquatelyladdressed.

No observed attention given to t his aspect of?Public and l

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Media Relations.

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. control.

There are ongoing training programs at the l

. county level to brief PIO's on such matters.

Special emphasis will be placed on rumor. control procedures during _.

future exercises and in the event of a radiological incident.

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3.

Emergency Pacilitics and Equipment (NUREG H.7.') :'

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Accident Assessment:

1 Need additional monitoring equipment to perform duties at the county level.

t COF"4ENT The counties surrounding Fixed Nuclear Facilitics in South Carolina have no responsibility for off site field

- l'mi nonitoring.

This is a DHEC/ Utility responsibility in that

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the type of equipment needed to effectively monitor off-site doscs is maintained by DHEC and the Utilities.

The counties have a responsibility to L.onitor evacuees at ;

their respective reception centers.

This was demonstrated at the Pickens High School.

Pickens Ccunty has 96 trained and equipped monitors; however, only 5 were used during the last exercise.

4.

Protective Response (NUREG J.10.J):

Access control of evacuated areas was handled adequately;

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however, the plan calls for this activity to be a county function.

The state actually assumed functional respons-ibility.

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'm__......The county does hr.ve the r.espcnnibility'to control access l

1. .n._ r into evacuated areas of the EPZ.

The. state cnly assumed l

id%g responsibility for the 2-mile EPZ, which is outlined in rGr the Emergency Action Levels of SCORERP and the State Law f <.;Ac Enforcement SOP.

If the county needs assistance in this i

area, the state wi11 provide additional lawl.e~nforcement A

personnel.

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Integrated capabilities were only superficially. exercised.

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The exercise could have been a better' training _ tool.

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The e.xercise format in South Carolina is being "over-hauled" to be able to inject more realism into play.

No notice exercises and other scenarios are being contem-i plated.

Integrated capabilities are better demonstrated in full scale state and local exercises rather than fullscale local exercises.

In Pickens County, the County Administrator was present in the EOC.

The County Council was briefed periodically but was not needed in the EOC Operation.

He are grateful for the participation of your staff in the latest Oconee Exercise and the ensuring comments and recommen-dations.

They will contribute significantly to the enhancement of our response capability.

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67 SIIUA P. MOORE Director JPM:WMMc:ncs t

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