ML20112E499

Testimony of RO Shapiro Re Emergency Planning Contentions a, M,P,Q,U,Z & Bb

ML20112E499
Person / Time
Site:	Perry
Issue date:	03/24/1985
From:	Shapiro R Federal Emergency Management Agency
To:
Shared Package
ML20112E497	List: ML20112E493 ML20112E499
References
OL, NUDOCS 8503260608
Download: ML20112E499 (65)

Text

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UNITED STATES OF AMERICA

^

NUCLEAR REGULATORY CCMMISSION '

z. - g BEFORE THE ATOMIC SAFFTY AND LICENSING BOARD 5 ' 3 ,1) ,*7J In the Matter of ) -

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CLEVELAND ELECTRIC ILLUMINATING ) Docket No. 50-440 OL COMPANY, ET AL. )  ; 50-441 OL

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(Perry Nuclear Power Plant, ) , ., ,

Units 1 and 2) )

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TESTIMONY OF ROBERT O. SHAPIRO, FEDERAL EMERGENCY MANAGEMENT AGENCY REGARDING EMERGENCY PLANNING CONTENTIONS A, M, P, Q, U, Z, BB I, Rebert O. Shapiro, am employed by the Federal Emergency Management Agency (FEMA), Technological Hazards Branch, Pegion V, Battle Creek, Michigan, Emergency Management Specialis t. I am responsible for providing assistance to State and local governments in the preparation of Radiological Emergency Response Plans (RERPs), reviewing those RERPs to assure compliance with NURPU-0654/ FEMA REP-1, Revision 1 (1980) (hereinaf ter referred to as "NUREG-0654/ FEMA REP-1 ") and 44 C.F.R. Part 350, 48 Fed. Reg. 44332 (September 28, 1983). A s tatement of my professional qualifications is attached to my testimony.

This testimony is provided at the request of the Nuclear Regulatory Commission (NRC) Staff pursuant to the Menorandum of Understanding (MOU) between FEMA and the NRC, as revised on November 11, 1980, 45 Fed. Reg. 82713, and incorporated in FD4A regulations at 44 C.F.R. 4 350.3 (f) which states:

Notwithstanding the procedures set forth in these rules (44 C.F.R. Part 350) for requesting and reaching a FD4A administrative approval of State and local plans, findings and determinations on the current status of emergency pre-8503260608 850324 PDR ADOCK 05000440 T PDR

2 paredness around particular sites may be requested by the NRC and provided by FEMA for use as needed in the NRC licensing process. These findings and determinations may be based upon plans currently available to FEMA or furnished to FmA by the NRC through the NRC/FMA Steering Committee (emphasis added) .

FmA's testimony is based upon a review of the following documents:

1. State of Ohio Plan for Response to Radiation Emergencies at Licensed Nuclear Facilities (Revision 1984) (hereinaf ter referred to as the " State Plan");

. 2. Ashtabula County Radiological Emergency Preparedness Plan (May 10, 1984)

(hereinaf ter referred to as the " Ashtabula RERP").

3. Geauga County Radiological Emergency Response Plan (Decembe,r,1983)

(hereinaf ter referred to as the "Geauga RERP").

4. Lake County raergency Response Plan for the Perry Nuclear Power Plant (hereinaf ter referred to as the " Lake RERP").

This testimony incorporates comments from reviews by the Regional Assistance Committee (RAC), an interagency committee chaired by FMA with members from seven Federal agencies including the NRC, an in-depth review of these plans by the Technological Hazards Branch of FEMA Region V against the criteria of NUREG-0654 and 44 C.F.R. Part 350, and an exercise of these plans held on November 28, 1984.

My tes timony is as follows:

• 3 CONTENTION At Evacuation Time Estimates have not been reviewed by State or . local organizations.

RESPONSE

NUREG-0654/ FEMA REP-1, Appendix 4 entitled " Evacuation Time Estimates Within the Plume Exposure Pathway Emergency Planning Zone", Part V, Other Requirements, states that the views on the draf t submittal shall be solicited from the State and local governments and comments resulting from such review shall. be included with the submittal of the Evacuation Tica % stimate ( ETE) .

NUREG-0654/FENA REP-1, p. 4-10.

Contrary to the Intervenor's assertion, the State and three Counties in the EPZ did provide comments on the study to the Applicant. The current ETE study was prepared by HMM Associates. By letter dated Mardt 9, 1984, the Applicant sent copies of the le1H Associates ETE study to the State of Ohio, the disaster service agencies for Astabula, Geauga, and Lake Counties, and the Sheriff s in Ashtabula, Geauga, and Lake Counties ( Attachment 1) . Lake County DSA responded by letter dated March 26,1984 ( Attachment 2); Geauga DSA responded by letter dated March 26, 1984 (Attachment 3): Ashtabula ENA respond-ed by letter da ted January 23,1985 ( Attachment 4); and, the State of Ohio DSA responded by letter dated January 29, 1985 ( Attachment 5) .

Neither the State nor any of the Counties in the plume exposure EPZ have ever indicated to FENA that they were not provided an opportunity to comment on the ETE. It is FEMA's understanding that the ETE has not yet been submitted to the NRC with the State and local government's comments (see, SSER 4, Item 13.3.2.10 ( 3) ) . With that exception the guidance of NUREU-0654/ FEMA REP-1, has been complied wi th.

4 CONTENTION M Independent Data Monitoring Systems should be installed within all counties in the Emergency Planning Zone (EPZ).

RESPONSE

NUREG-0654/ FEMA REP-1, Planning Standard I requires that "( A}dequate methods, systems and equipment for assessing and nonitoring actual or potential of fsite consequences of radiological emergency conditions are in use." The general requirement established by these Criteria is that each organization has the capability, resources and expertise to measure a release in the field.

An ef fective accident assessment program requires the use of costly specialized eauipment and highly trained technicians to manage it. Such an accident assessnent program is of ten beyond the financial capabilities of most counties to establish and maintain. Therefore, it is generally in the best interest of the counties to rely on the State to provide this f unction.

The Ashtabula and Geauga County Emergency Plans indicate that they will rely on the State of Ohio to provide accident assessment ( Ashtabula RERP,Section I, I.I and the Geauga RERP,Section I, I. I, Page I-1 ) . Lake County will utilize information from a fixed monitoring system it plans to install and the State of Ohio monitoring teams (Lake RERP,Section I, p. 112-115).

The RAC found the Lake RERP provisions regarding monitoring inadequate in several respects (see, FEMA Exhibit 3, Lake County, p. 3 and 4) .

However, it is the State that has primary responsiblity for offsite moni toring. The State Plan,Section II, Part I, provides that the State will assure that radiological data will be collected by the State accident assess-ment teams during an emergency situation at nuclear power plants af fecting Ohio. This assessment will be accomplished independent of the utility. The State Plan describes comprehensive equipment systems and methods to be used

5 for this purpose. Specific monitoring locations are decribed in the state Plan in Figure II-J-35 (unnumbered page) and marked on the maps for Ashtabula, Geauga, and Lake Counties in Figures II-J-37, II-J-38, and II-J-39, respectively.

The technical information is to be provided, as it is gathered and analyzed to County decision makers in terms which they can understand and base their protective decisions on. The State of Ohio has demonstrated their abilities to perform accident assessment during exercises at Zimmer, Davis-Besse, Beaver Valley and Perry.

The RAC review and the FEMA Interim Report (FEMA Exhibit 1) found the offsite monitoring system for the Perry plant sufficient to provide adequate data for emergency response. A " Class B" deficiency, that is, one which would not af fect the public health and safety, and several recanmendations for improve-ments were made as a result of the November 28, 1984, exercise (Exercise Report, Perry Nuclear Power Plant, November 28, 1984, FEMA Exhibit 2 at pp. 73 and 74). This does not af feet the conclusion stated in the Interim Report that offsite monitoring for PNPP is suf ficient.

The State has indicated that it will provide additional training for the field monitoring teams by May 31, 1985 (Ietter from Richard Lockhart, Ohio DSA to Wallace Weaver, FEMA da ted March 18, 1985, Attachment 6, " hereinafter referred to as " Corrective Action letter") . This should eliminated the deficiency identified in the Exercise Report.

6 CONTENTION P:

Emergency plans are deficient with respect to hospital designations and medical services as well as procedures required to assist contaminated indivi-duals.

RESPONSE

NUREG-0654/ FEMA REP-1, Planning Standard L, requires that arrangements be made for medical services for " contaminated injured individuals". Three of the four evaluation criteria under Planning Standard L apply to to State or local governme n t. Each is addressed below.

Criteria L.1. requires arrangements for " local and backup hospital and medical services having the capablity for evaluation of radiological uptake and exposure, including assurances that persons providing these services are adequately prepared to handle contaminated individuals." The Lake RERP designates two county hospitals as capable of assessment and treatment of radiation injuries (section L-03). Ashtabula and Geauga RERP each indicate one such hospital (Section L in both plans) . During the November 28, 1984, exercise of the of f site plans for PNPP, FEMA exercised the capabilities of the Ashtabula County Medical Center. The exercise found that certain items were unavailable to the staf f (whole body pans, rinse water retention vessels and hose connectors for decontamination water) . Howe ve r, the exercise did show the hospital staf f's knowledge of proper decontamination procedures and their ability to improvise in the absence of required equipment (Exercise Re port, Perry Nuclear Power Plant, November 28, 1984, p. 58 and 79, FEMA Exhibit 2) .

Criteria L.3. requires the State to develop a list of medical f acilities l- capable of providing medical support for contaminated injured individuals.

l The State Plan (Figure II-L-2) provides a " Ohio Directory of Medical Facilities" l

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7 having emergency room capability. This listing also indicates whether the medical f acility has a burn care unit and a diagnostic and/or therapeutic radioisotope f acility available. The list identifies some 49 medical f acili-ties within the Perry planning area, 39 of which have diagnostic and/or thera-peutic radioisotope capabilities. According to infornation provided to FEMA by the State of Ohio, the hospitals identified as having diagnostic and/or therapeutic radioisotope capablities are licensed to diagnose and treat patients with radioisotopes. They also have the capablity to determine the amount of radiation exposure received an the extent of radiation damage to a an individual, if any. The State Plan (Section II, 1 L.5.b.(1)) further designates the Cincinnati General Hospital and the Monsanto Laboratory as the specialized f acilities located in Ohio that have the capability of whole body counting.

Criteria L.4. requires the State and local governments to arrange for the transportation of victims of radiological accidents to medical support facili-ties. The State Plan (Part L, 1 L.6.a. and b. ) indicates that victims of radiological accidents will be transported to medical f acilities by the most accessible local means as pre-determined in the Lake, Ashtabula and Geauga Counties ' RERPs. If additional transportation assistance becomes necessary within the Perry EPZ, the State Plan (Figure II-J-L) indicates that upon r eques t, the Ohio National Guard (ONG) will be prepared to furnish up to sixty-five (65) ambulances for the transportation of contaminated individuals to appropriate medical facilities.

The FEMA Interim Report found the designation of medical f acilities and services available within the State and local area to be suf ficient for ef fect-ive treatment of potential radiation and other injuries in an emergency response.

However, the RAC review of the plans for PKPP dated November 20, 1984, and l

8 transmitted to the state of Ohio by letter dated January 31, 1985, held these items to be inadequate pending submission and review of letters of agreement (Regional Assistance Committee, Consensus Review, November 20, 1984, FEMA Exhibi t 3 ) . The Counties have indicated that they are in the process of obtaining letters of agreement to comply with the deficiencies indentified 1

by the RAC (see, Corrective Action letter, Attachment 6).

- 9 CONTENTION Q:

There are no letters of agreement regarding the availability of school buses.

RESPONSE

A letter da ted May 27, 1983, from Herman L. Massie, Chief Pupil Transport-ation, Ohio Department of Education to Ohio DSA interpreting Chio Board of Education Rule 3 301-83-12 (L), permits the use of publicly owned school buses for the purpose of evacuation of persons within ten miles. The letter f urther indicates that since the school buses are owned and controlled by local school districts it will be necessary to secure the cooperation of each of the af fected school districts. The County RERPs presently do not contain these letters of agreemen t. All three Counties have indicated that they are obtaining the neces-sary letters of agreement (corrective Action letter, Attachment 6) . When provided to FEMA they will be reviewed to insure compliance with NUREG-0654/ FEMA REP-1.

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n 10 CONTENTION Ut Reception centers do not have the means or facilities for handling contami-nated property.

RESPONSE

The County RERPs provide for decontaminating vehicles at the reception centers (Lake RERP, p.129As Ashtabula RERP, p. J-S; Geauga RERP, p. J-5).

The County SOPS provide the procedures to be followed in decontaminating vehicles at the reception centers.

The County SOPS provided for confiscation of contaminated clothing and issuance of substitute clothing. The contaminated clothing will be bagged for later disposal by PNPP. Contamination levels and the decontamination ef fort will be recorded in the applicable section of a Personnel Decontamina-tion Record Form.

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,c CONTENTION Z:

The plans do not provide decontamination protection for bus drivers during eme rgencies.

RESPONSE

Planning Standard K of NUREG-0654/ FEMA REP-1, requires plans to provide that a "means for controlling radiological exposure, in an emergency, are established for emergency worksrs." Criteria K.S.b. states that "(e]ach organization, as appropriate, shall establish the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, and for waste disposal."

The Ohio Department of Health has established radiation exposure limi ts for emergency workers, including bus drivers. These drivers will provide dosimeters, which are reliable radiation detection devices. Dr. John H.

Acke rman, M.D. , Director of the Ohio Department of Public Health, has indicated that no emergency worker will be assigned to an activity involving an airborne release involving particulates or radioactivity deposited on exposed surf aces unless the worker has been provided suitable respiratory equipment.

The County RERPs have incorporated Dr. Ackerman's directive into there plans (Lake RERP, Attachment K-3 Ashtabula RERP, Appendix 3 2; Geauga RERP, Appendix 34, p. 34-1).

Should the bus drivers need decontamination, the State Plan describes the means for decontamination. Ohio DSA is the lead agency with Ohio Depart-ment of Health (ODH) and Ohio Environmental Protection Agency (OEPA) provid-ing support and technical assistance (State Plan,Section II, Part K).

The details of how decontamination will be carried is contained in the OSDA Decontamination Standard Operating Procedure (SOP)(p. II-K-05). Figure

12 II-K-2 in the , State Plan lists the monitoring and decontamination stations for all nuclear facilities in the State. Lake County is listed but the plan indi-cates that the decontamination facilities is "to be announced".

The County RERPs (Section J) all indicate provision for monitoring equipment at reception centers to identif y contaminated property. The Lake RERP, contrary to the Sta te Plan, indicates that decontamination will take place at the Auburn Career Center in Paineville, Ohio (Lake RERP at pp.

141-141A). Otherwise, it is consistent with the State Plan. In Geauga County decontamination of emergency workers is at the Hambden Fire Station.

FEMA found this facility inadequate for decontamination of emergency workers in the November 28, 1984 exercise and reccanmended that the County find an alternative facility. Wounds are to be decontaminated at the Hambden Fire Station or one of the hospitals listed in Section L of the plan. Contaminated property is to be picked-up by PNPP for disposal. The FEMA Interim Report 4

( FENA Exhibi t 1 ) found the procedures adequate to handle contaminated property. g

13 CONTENTION BB:

Offsite emergency plans are inadequate due to the planning deficiencies set for th in the Federal Emergency Management Agency Interim Report of Agency Interim Report of March 1, 1984.

RESPONSE

The February 6,1984 transmittal letter of FEAM Interim Report (FEMA Exhibit 1) -from FEMA Region V to FWA Headquarters considered the Regional Assistance Committee review of the Lake, Ashtabula and Geauga County Plans and stated:

Given the above, FEMA, Region V concluded that the remaining deficiencies, considered as whole, are such that, in spite of them, there is reasonable assurance that appropriate protection measures can be taken in the event of a radiological emergency at Perry Nuclear Power Plant. This conclusion is based solely on the basis of a plan review. Further evaluation of State and local governments ability to implement these plans will be made as a result of the November 28, 1984 full participation exercise.

Following the submission of the Interim Report to FEMA Headquarters, the Perry full participation exercise was conducted as scheduled. The results of l

this exercise indicated no category A deficiencies (" Deficiencies Af fecting I

l Public Health and Safety") for any of the State or county res ponse organizations.

(Exercise Report, Perry Nuclear Power Plant, November 28, 1984, FEMA Exhibit 2, i

l at p. 72).

Sunflower Alliance raised two specific issues in its statement of material facts: (1) that the Exercise Report indicated that the Staff at the Ashtabula County Medical Center "had to improvise the means to attempt to decontaminate f the patient" and, (2) FEMA " considered deficient the adequacy of field monitoring l radiation levels". Sunflower's Statement of Material Facts (Contention BB) .

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i 14 FEMA found that certain items were unavailable to the staf f (whole body pans, rinse water retention vessels and hose connectors for decontamination water).

This lack of material was the deficiency. The ability of the hospital staff to improvise was a positive point. It showed the hospital staf f's knowledge of proper decontamination procedures and their ability to make-do in the

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/ absence of required equipment (Exercise Report, Perry Nuclear Power Plant, November 28,1984, p. 58, FD(A Exhibit ).

As stated in response to Contention M, the deficiency in the field monitoring team was not one which af fects the public health and safety. The state has indicated that it will take appropriate corrective action (Corrective Action Letter, Attachment 6).

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14 In regard to the first point, the Intervenor's misconstrue FEMA's ccament.

As stated in response to Contention P, during the November 28, 1984, exercise, FEMA found that certain items were unavailable to the staf f (whole body pans, rinse water retention vessels and hose connectors for decontamination water).

This lack of material was the deficiency. The ability of the hospital staf f to improvise was a positive point. It showed the hospital staf f's knowledge of proper decontamination procedures and their ability to make-do in the absence of required equipment (Exercise Report, Perry Nuclear Power Plant, November 28, 1984, p. 58, FEMA Exhibit 2) .

As stated in response to Contention M, the deficiency in the field monitoring team was not one which af fects the public health and safety. The State has indicated that it will take appropriate corrective action (Corrective Action letter, Attachment 6) .

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ROBERT 0. SHAPIRO FEDEFAL EMERGENCY MANAGEMENT AGENCY, REGION Y ,

STATEMENT OF PROFESSIONAL QUALIFICATIONS I am employed as an Emergency Management Specialist in the Technological Hazards Branch, Natural and Technological Hazards Division of the Federal Emergency Management Agency (FEMA), Region V. I have been in this position since 1981. I have responsibility for the review and evaluation of State and county radiological emergency plans. I have been the FEMA Team Leader for Ohio, Indiana and Michigan radiological energency planning. I have reviewed many State and county plans and represented FEMA during Region Assistance Comittee reviews. I have been either Exercise Director. Team Leader, or evaluator of more than 35 off-site nuclear power plant exercises. I have developed six Regional Director's Evaluations for six different nuclear power plants of which five have received approval. I have received a Special Achievement Award and a Certificate of Outstanding Perforinance.

I am also the FEMA Region V Hazardcus Materials Officer. The responsibilities for this program are to review, evaluate and provide I guidance for Hazardous Material incident / accident planning.

! From ilanuary 1981 to September 1981 I was an Emergency Management Specialist with FEMA Region VI Plans and Preparedness Division. In this function I was responsible for the overall planning efforts of the State and local government for nuclear power plant accidents.

i From May 1980 to January 1981 I was a Emergency Management Specialist with FEMA Region V Plans and Preparedness Division. I was f

I responsible for the Maintenance and Improvement Grant Contract (Title II l

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2-Program) of four states in Region V. I was the principle plan developer of the FEPA Region V Regional Operations Plan, which is the basic plan ,

used by FEPA for emergency response during peace or war contingencies.

I was the Mobilization-Designees-Armed Forces Reserves (POPDES) program marager for FEMA Region V and in this function was responsible for the assignrent and training of reserve officers and unlisted performance, reserve duty at the Pegion.

Frer Varch 1978 to Fay 1980 I was employed by United Steel and Wire Company as a Quality Control Supervisor.

From August 1977 to December 1977 I was Assistant Manager at a Pondercsa Steak House.

Fror October 1976 to August 1977 I was employed by the State of Michigan as a production supervisor.

From September 1965 until May 1976 I was an officer on active duty with the United States Air Force. I was responsible for every phase of services activity in support of military operations.

I attended Shippensburg State College, Otterbein College and I

received a Pachelor of Science Degree from the latter in 1965. I have f

completed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> tcwards a Masters Degree in Guidance and Counseling (Ball State University) and many professional management courses and Disaster Preparedness courses while working for the Federal Government.

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I am a Major in the United States Air Force Ready Reserve. I am assigned to HQ AFRES, 10th AF as Disaster Preparedness Officer assigned to Wurtsmith AFB, Michigan. I develop and coordinate disaster preparedness response plans associated with military response to peace and war time contingencies. 7 orovide guidance and training to the

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. Cisaster Preparedness Division Personnel. My responsibilities and training are directed towards response to all disaster situations (war related, natural disaster, civil disturbances, terrorist threats, nuclear and conventional weapons accidents, etc.).

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PO 80x 97 e PERRY. oMIO 44081 e TELEPMoNE (216) 259 3737 e AooRESS.to CENTER ROAo

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PERRY NUCLEAR POWER PLANT March 4, loS4 This letter sent to: Mr. Albert E. Stewart, Director, LCDSA Mr. Michael Wheeler, Director, ACDSA Mr. Dale Wedge, Director, GCDSA Mr. Kenneth Cole, Nuclear Preparedness Officer, State of Ohio Sheriff James Todd, Ph.D. , Geauga County Sheriff Edwin Cunningham, Lake County Sheriff William Johnston, Ashtabula County Evacuation Tine Study for Perry Nuclear Power Plant -

Enclosed is the March 1984 draft of the Evacuation Time Study for the Perry Nuclear Power Plant. This document will be used by emergency response personnel charged with decision making on protective actions in the event of an emergency. It must be reviewed for comment by state and county officials.

It is important that the Evacuation Time Study be in accordance with local planning efforts. Therefore, I have marked certain sections of the study that you should check for accuracy.

March 19 is the target date for review comments. It is very impor-tant that you prepare your written remarks by that date.

We know you have a busy schedule, but realize the importance of your input before a final draft can be precared.

If you have any questions, please feel free to give me a call.

Thank you for your help.

Very truly yours,

'. .L' s .: e, * - 1 a ,_ ;

Janet Dugan Emergency Planninr, l

JD:bal I cc: D. Hulbert R. Trudeau C. Haslett D. Hall i

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• DISASTER SERVICES AGENCY 39 FAIRDALE STREET EE'.7

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PAINESVILLE, OHIO 44077 Phone (216) 352 5281 AlsERT t. $TtwART Director tat. 361 March 26,1984 The Cleveland Electric !!!uminating Company P. O. Box 97 Perry, OH 44081 Attention: Mrs. Jan Dugan

Dear Mrs. Dugan:

Having reviewed the Evacuation Time Study for the Perry Nuclear Power Plant as 1 proposed by HMM Associates. {

l offer the following comments:

Section i l

1.2 The Perry Nuclear Power Plant, hereafter to be referred to as PNPP is located l the Village of North Perry, a political subdivision within Lake County, Ohio. The J I

plant site is located along the southern shores of Lake Erie. A site vicinity map for the plant is included as Figure 1.1. j l

The Plume Expcsure Pathway Emergency Planning Zone hereafter referred to as I the EPZ is the geographic area surrounding...

Figure 1.2 Suggestslohd outer boundry line to show EPZ.

Section 2 2.3 Third paragraph,suggest - it is assumed that the permanent population sector willevacuate from their places of residence and that all households having more than one vehicle will use only one vehicle.

Fourth paragraph suggests - additional explanation is needed by reviewer, does the plan assume this position or does it specifically warrant it?

2.5 While NETVAC has been used in previous hearings with success. Has it's findings been proven in actual situations?

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Section 3 3.4 Table 3.1 Are their twenty-three (23) households in the City of Mentor, within the EPZ?

3.8 First paragraph - Should not County be changed'to Counties?

3.11 is Figure 3.3 through 3.5 consistant with Warning Maps being developed and other criteria?

3.14 Table 3.2 As a matter of comment only, where are these Medical / Jail Facilities? Sub-area (E) Headlands State Park, has on certain Holidays in the past, saw as many as 60,000 to 80,000 transients.

Sectica 4 Table 4.1 Reviewer feels it is wise to remove Lakeland Community College from Primary Reception Center. The JPIC is located here, other Lake County locations can absorb the load. .

4.19 Figure 4.3 Check width of Roadway?

l Section 5 l

! 5.2 Initial Notification The land portion of the EPZ surrounding the Perry Nuclear Power Plant will have an Outdoor Siren Notification System, with Public Address capabilities that surpass requirements and recommendations yet remaining consistant with NUREG-0654/ FEMA-REP-1 Appendix 3 guidelines. This system will be used by County officials to Alert and Disperse Emergency Information to the population, i.e., Evacuate, Shelter in place, Turn-on their radios and television sets for additional information, all clear. Pursuant to NUREG-0654 guidance, notification messages will commence on the designated television and EBS l stations prior to the activation of the Siren /Public Address System.

Within fifteen (15) minutes the population, within the EPZ of the plant, will have

! been given an informational or instructional message regarding the emergency.

5.2 Second paragraph - I sure would hope so.

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! 5.3 Very conservative estimates.

5.4 Permanent Population, second paragraph - Suggests removal of (and local) l emergency preparedness officials.

l Transient Population. Suggest removal of (and local) emergency preparedness

! officials. Discussions with County emergency preparedness officials.

5.5 Suggests removal of (and local) emegency preparedness Officials. Discussion with County emergency preparedness officials.

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l 5.8 The Priority Treatment ERP denotes traffic support at all intersections.

Section 6  %

6.20 Suggest word change - Remove manual and add Physical Traffic.

Section 7 7.1 While I do not agree with this approach, let it stand if it has been successful in other hearings. -

Al-6 What are we talking about, Madison Village, Madison Township, North Madison?

A2-2 Again, reference is made to North Madison, there is no legal siatus for this assumption, it is Madison Township.

Sincerely, g p

LAKE DISASTER SERVICES AGENCY

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f tewart

[ Director / Coordinator mb 6

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County er Geaugag%w; ggg_.- 13781 PAINESVILLE R AVENN A ROAD e GE AUG A COUNTY SAFE TV CENT E cH ARDON. ohio 44C;4 S r.

DISASTER SERVICES AGENCY s-PHONE I2161285 22:2. EXT. 603 g l k OIRECTOC DEPUTY OIRECTOR DALE 8. WEDGE RONNIE N EGING Jan Dugan 10 Center Road R225 Perry, mio 44081

• is Ref: hnts on Time Evacuation Study p,G'tr' ,

Dear Jan:

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Page 4-1: In all areas shere it state [that this is based on discussions with County and local law enforcement and / emergency preparedness officials, I would like to state that se only had one meeting with BN. At that rmeting se only discussed what routes sould nust t axely be used for an evacuation and problems with meather. 'Ihis produced an addition of Old 44 (North Street - Ravenna Road). No other infonration was discussed with these consultants.

Page 4-4: Ch southbound exits I do not understarsi 534 south to Route 166 west to Geauga County Reception Centers. It sould sean that once on Route 166, they would go to Route 528 and then south to the Middlefield Reception Centers. 'Ihe Gardon Reception Centers are prirmrily used for evacuees fran Lake County.

Page 5-1: I do not find any portion of the plan that defines the various meather conditions. During our meeting with Bfd, we indicated the problems in l

'Ihmpson with severe winter seather. We would like to have a better under-standing of what they are basing their estinntes on. We can see a change in the estimates of time.

Since working on the plan se have found special grouns in 'Ihmpson that should be addressed. We have fourri two (2) cartpsi t es , a group hczne and a day-care center for which we have written SOPS.

I find no other problens in Sections 4, 5, 6 and 7.

l Sincerely yours, N

Dale B. Wedge Director DCM/pl ADSAAA/B/5

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S%.M.

hwe 4 00lM OF ASMABGA EMERGENCY MANAGEMENT AGENCY 25 West Jefferson Street Jefferson. Ohio 44047 (216)576-9090,576 9148 Emerg.ncy wen.g.m.n Coordinator January 23, 1985 '

l Jan Dugan Emergency Planning Unit TV 1

Perry Nuclear Power Plant l PO Box 97 Perry, Ohio 44081

Dear Jan,

This letter is to inform you that af ter reviewing the Evacuation Time Study for the Perry Nuclear Power Plant with the Sheriff's Department it meets with our approval.

Sincerely, ,

f d?r;&%

K. Michael Wheeler, Coordinator Ashtabula County Emergency Management Agency KMW/jf l

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STATE OF OHIO -

l ADJUTANT GENERAL'S DEPARTEENT M 'T ,,

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DISASTER SERVICES AGENCY AGOH-DS-NOO January 29, 1985 l

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Ms. Jan Dugan Cleveland Electric illuminating Co.

Perry Nuclear Power Plant l P.O. Box 97 l Perry, OH 44081 i

Dear Ms. Dugan:

My staff has reviewed the " Evacuation Time Estimates for Areas Near the Per y Nuclear Power Plant" (March 1984), prepared for CEI by HMM Associates.

The study is sound and should become an individual resource document.

The concerns we did identify do not affect the overall integrity of the study.

However, we would appreciate your comments or further explanation on the following items:

- Page 2-2, Paragraph 1, Line 5: What are the site-specific characteristics of the PNPP EPZ?

- Page 2-3, Paragraph 6: What is the source of the assumption that snowstorms would reduce roadway capacity by 30 percent during winter conditions ? This figure seems low, particularly for the " snowbelt" counties.

Thank you for your time in resolving our questions. If our concerns need further clarification, please do not hesitate to contact me or the response supervisor, Larry Grove, at (614) 889-7157.

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Sincerely, / , /

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l LA KENNETH B. COLE Nuclear Operations Officer O

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.g DISASTER SERVICES AGENCY ,

March 18,1985 AGOM-DS Mr. Wallace Weaver Federal Emergency Managernent Agency Region V 300 South Wecker Drive Chicago, IL 60406 Deer Mr. Weaver:

Enclosed are the responses to the November 20, '964 Regional Assistance Committee review of the Ashtabula, Ceauga and Lake coc ities Radiological Emergency Response Plans. As noted in the responses, all corrective actions will be addressed in the next revision to the plans. These revisions are scheduled for distribution July 31, 1985.

We appologize for the form of the cor-ect!.e :. m, and for the date of transmittal, if any additional details are needed for your e 4!ustion, please contact Kenneth cole of my staff at (s14) est-7157.

FOR THE DIRECTOR f ./ .

f < .; A RICHARD Y LOCKHART Deputy Dirx:c-LAC:kjs Encls: as stated

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a 4/6 Enfmtg of Eahe CFFKI 0F DISASTER SERIICES AGENCY M FAIRDAtt $7R117 PAINI5VILLE, OHIO 44077 -

March 7,1983 Mr. Kenneth Cole Ohio Disaster Services Agency 2825 West Granville Road Worthington, OH 43083 Dear Men Enclosed please find the Response tc. the RAC Consensus Review of the 1.ake County, Ohlo, Radiological Emergency Response Plan. Please forward these response responses submittal to FEMA.to PEMA, Regio. Y . ;a:Lude them in your Thank you for your assistance in these mat:ers.

Respectfully, l.AKE COUNTY D1$ ASTER SERVICE 5 AGENCY

/

j .6 Robert H. Retzler #

Director *

'RHRamb Enclosure

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3//a i RESPONSE TO THE RAC CONSENSU5 REVIEW i 0F THE LAKE COUNTY, CHIO, RADIOLOGICAL EMERGENCY RESPONSE PLAN Criteria

! tem loadecuacy Response 1 A.I.b. Letters of agreement will be obtained from school districts providing school buses for evacuation purposes.

A.3. Letters of agreements for " private" organisations, such as Red Cross, Schools, etc., and a signed acceptance of responsibility letter ior all other plan participants will be obtained. The acceptance of responsibility letter will be

separate from the receipt of plan letter.

l D.4 Paragraphs 3-01 and 3-03 indicate that the County Commisaloners will take into account " advice from the staff assembled at the EO C," "

. . . meteorological conditions, transportati:, conditions" etc. This should satisfy NUREG-0634 criteria D.6 G. I . The first ed!tlon of the " Emergency Information Handbook" will be include: in Revision 4 of the plan.

! G.4.b. Page 93 wl!! he rewritten to show that there wi!! be a Public Information Officer (PIO) and a PIO Llaison. Brief descriptions of their functions and speelfic locations from which they will operate wi!! be included in the next plan revision.

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! G.4.c. This inadequacy wl:! be addressed as part of the criterla item G.I. inadequacy cor:ection.

H.7. Attachment H 8 refers t: Emerlency Worker Desimetry I

and will be retitled to reflect this. Attachment 12, Equipment for Lake County Field Monitor Team wi!! ne revised to show the capability to take air samples and gron Gamma readings 09:y. This will be the support provided to 5 tate Field Monitoring Teams.

H.10. Pale ICO A, which corrects the inadequacy, was not included in the last plan revision (Rev. 3). It will be included in Revisioa. 4 of the emergency plan.

H.11. Attachment H-9, Emergency Kits, will be revised to include the contents of the Personnel Decontamination Kit, Equipment /Yehicle Decontamination Kit, Personnel Dosimetry Kit and the Radiological Monitoring Kit.

k l Criteela item

]Qgdggggsy, Response i H.12. Lake County Radlological Manitoring Teams will' be manned by Lake County Health District personnel. These teams will be supervised by the Lake County Health

District representative at the EOC where all field data will be reported. Field Monitoring Teams are Intended to have alr sampling and gross gamma count capability only.

The Emergency Response Plan will be revised to reflect these capabilities in Revision 4 of the plan.

1.7 The proposed Stationary Alert Monitoring System design will be completed and a brief description of the system's capability will be included in Revision 4 of the Emergency Response Plan. The Radiolog! cal Monitoring Kit contents i

will be listed in Attachment H.9, Emergency Kits of the Emergency Response Plan (Revision 4).

1.4. The purpose of the Lake County Field Monitoring Team, per paragraphs I.01, !.02, and 1-04 (pp.112 - 113), Is to provide support to the Ohio Department of Health with regard to " airborne and g :und level gamma radiation" readiryis, if necessary. The teams will also be provided with t% capability for a;r sampling (see response to l criteria item H-12 inadequ:y). Appropriate training will i

be conducted and documented for Lake County Health District Fleid Monitoring personnel. Malntenance of the l Stationary Alert Monitoring System and field monitoring l

Instruments will be out:.r.ed in Revision 4 of the Emergency Response Plan.

3.10.a. A legible evacuation routa map will be inserted into Revision 4 of the Emergency Response Plan.

3.10.g. See response to criteria ite- A.!.5. inadequacy.

3.12. Sufficient detail describing the means for regletering and monitoring evacuees will be :ncluded in Revision 4 of the Emergency Response Plan. SOP's have been submitted to the FEMA RAC for revlew regarding th!s inadequacy.

K.4 The Emergency Response Plan will be revised to show that under no circumstances shall an emergency worker be allowed to excesc "hfesaving doses" out!!ned in Attachment K-3, Maximum Permissable Radiation l Exposure to Emergency Worxers. Further changes will be dependent upon the outcome of current discussions l between CD5A and Ohlo De;:artment of Health.

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Crlterla item Inadecuacy Resnonse K.J.a. There is not an Appendix 33 in the Lake County plan, however, there is Attachment K-4, Guidelines for Maximum Acceptable Levels of . Santamination. The sources for these guidelines are the Ohio Disaster Services Agency, as derived from the U. S. Department of Energy Response Plan and the Federal Emergency Management Agency (FEMA REP 2).

K.3.b. Sufficient detail descr;bing the meana for radiolog! cal decontamination of emergency personnel, supplies, etc.

w!!! be included in Revision 4 of the Emergency Response Plan. SOP's have been submitted to the FEMA RAC for review regarding this inadequacy.

L.l. Letters of agreement with Lake ' County Memorle! ".ast and West acknowledging their capabilities and awaro ens of their responsibl!!tles will be obtained and referenced in Revision 4 of the Emerge .cy Response Plan (see response to criteria item A 3).

L.4. See response to criteria ite . A.3. Inadequacy.

O.4.b.. Q.4.d. D$A -Director will ensu e the radlolog! Cal emergency response training prograrr is conducted in a manner that will qualify appropriate personnel to implement the radlological emregency response plan.

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c, .g a l Gaunty of Eake j OFFICI 0F .... .

! DISASTER SERVICES AGENCY '

l M FAIRDAll STREET PAINE $ VILLI, OHIO 44077 f,

i l March 12,1985 2

1 4

! Mr. Kenneth Cole i Ohio Dlaaster Services Agency

2825 West Granville Road i Worthington, OH 43085 i

i Dear Kent j Enclosed is an Appendix to the Response to the RAC Consensus Review of the j Lake County, Ohio, Radiological Ernergency Response Plan. The response to this criterla ltern inadequacy was inadvertantly omittad.

! Please forward this appendix alon6 with your :=ponse submittal to FEMA, Region V.

(  ! apologize for any inconvenience this rnay have caused you.

I Respectfully, 1.AKE COUNTY DISASTER SERVICES AGENCY Robert H. Retzler Director RHRimb Enclosure l

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APPENDIX To TW RESPONSE TO THE RAC CONSENSUS REVET OF THE LAKE COUNTY, CHIO, RADIOLOGICAL EMERGENCY RESPONSE PLAN Criteria Item

]Dadsguagg _

Resoonna C.4. Page 170 was apparently omitted from the RAC copy of the plan. This page, or its equivalent, will be included in revision 4 of the plan. I.etters of agreement will be handled as per criteria items A.1.b. and A.3. Inadequacy corrections.

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i 1 ofIL CON OF ASHTABLO EMERSENCY MANAGEMENT ASBNCY 35 West JeMaroon Street Jefferson. Ohio 44047 (tie) m.mo. s7s.em me Wheeler saweener idenessment Coennow March 12, 1985 Mr. Ken Cole Ohio Disaster Services 2825 West Granville Road Worthington, Ohio 43085

Dear Ken,

Attached are the responses to the "irade:uacies" listed the FEMA RAC Review for the Ashtabula County Redie'.epial Emergency Response Plan, as of November- 20, 1984.

There were seventeen comments eva hated as inadequate. The responses are based on (1) what changes will occur to the next revision of the response plan, (2) discussion and clarifications with Mr. Bob Shapiro and the S tate DSA, (3) cor.er:s f rom other key sources.

The Ashtabula County Radiological berger:y Response Plan is a living document. Improvement in the plan anc procedures will develope as training is completed, additional equipment is acquired, guidelines change and resources baceme available.

If you have any questions please cor.:eet e.

Sincerely,

. ,. a.

g rp%Ab W K. Michael Wheeler, Director Ashtabula County Emergency Management Agency KMW/jf cc County Commissioners Dick Hall Bill Coleman

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RESPONSE TO RAC CONSENSUS REVIEW ITEM RESPONSE TO INADEQUATE COMMENT General Criteria items Alb, A3, J10d, J10g, 11, L4, 04h, P7 were noted ad deficiencies, some in part due to a lack of Letters

of Agreement. Discussion with ODSA and FEMA have outlined that these letters only need to be obtained from " private"

organisations such as Red Cross, Schools, etc., and that a

signed responsibility /seceptance letter was acceptable from i all other plan participants. Letters of Agreement will be j obtained from all needed organizations before plant start-up.

Alb A block diagram (as appendix 10) is included in the plan, j

indicating control, coordination and interrelationships of 1

response agencies and organizatices. Response functions of each agency are included in the plan in Appendix 6. Concept of operations for each agency / agency interface is discussed in detail in ccoresponding 50P s. However, more detail will added to the plan describing overall Ashtabula County emergency response concept of operations. Letters of agreement with response organizations will be obtained as noted in " General" response above.

A3 Letters will be obtained as noted ab:ve.

E5 Appendix 18 is referenced as the PN?? Emergency Information Handbook. The handbook will be prov fed as part of the plan and will include the following television, AM radio and rM radio frequencies and call letters.

Television AM Radio FM ?.sdio TV3 WKYC 1100 WWWI 95.5 WGCL TV5 WEWS 1220 WGAR 97.1 WREO TVB WJKW 970 WFUN TV25 WVIZ 1360 WWCW 1330 VELW 1460 WQLS 1560 WBKC G1 The Information Handb::k vill be included as part PNPP of the Emergency plan (a?pendix 15).

The PS?? Emergency Information Handbooi includes the fei:owing information:

1. Educational information en radia: ion such as sources of radiation, examples of natural radiation levels (x-rays, color T.V. etc.), dangerous'radistion levels. There is also e section on nuclear energy which describes how a nuclear power plant o with safety in mind. perates and how a plant is built (1)

le gli, 2.

, Contact for additional rumor control information,(includina hotline phone number 1-800-228-6974), a toll free which can handle two incoming calls at one time.

3. Protective measures including evacuation routes, i

' relocation centers, emergency TV and radio stations to tune to, shelter instructions, evacuation instructions, respiratory protection, etc. The director of the Department of Health, State of Ohio will not currently provida potassium lodide for emergency workers or residents, therefore use of radio protective drugs are l not mentioned in the PNPP Emergency Information Handbook.

4. A special needs information card is included in the handbook. When filled out and sent to ACEMA the card will identify what special transportation needs the elderly and handicapped will need. Ambulance and bus support will be available to prov:de transportation for those individuals that do not own vehicles or those individuals that require special transportation.

C2 Appropriate telavision and radio stations are included in the PHPP Emergency Information Handbook. See response to E5.

M11 Several pieces / types of communicatiora equipment are available in the EOC/E0C communicatiers Center. They are included in the plan on page f-1 to f 3 and are not part of any equipment kits.

1. 5 way phone system (Emergency Rspense Network)

2. 3 way phone system (Inter County Network)

3. Public Information Network 4

Regular Telephone (6 telephons .*ines with 17 extensions)

5. Radio, communications with a n fire, police, ambulance, disaster services. Radio communications are hospitala[ablewithothercountyIOC;s, also avai reception centers, Red Cross (via amateur radio operators), etc.

6. Pagers, key EOC staff personeel are given pagers

7. Tone-Alert Radios - are used for ::ttfication of some risk organisations and schools.

J10c Lists of hearing impaired persens will be kept by responsible fire departments and in the EOC (Geneva, Geneva on the 1.ske, Harp use / notification.ersfield When Chiefs) andofwill notified ar be readi'.y available exergency conditionfor each fire department will dispatch firefighters to warn the hearing impaired. The PNPP Emergency Information Handbook will be included as part of the plan as Appendix #13.

(2)

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J10d several nursing homes and one day care center are identified in procedures. Per section J.4.1 " Handicapped individuals living 6t home who need transportation and others who need transportation but are unable to go to a predesignated pick-up location will be provided trans direction of a local fire department." portation under A "special needsthe information card" will be included with each PNPP Emergency Information Handbook. This card requetts persons desiring special transportation needs to write or call the Ashtabula County EMA about.their needs. The ACE'.4A will also request the names of mobility impared persons from various organizations in A6htabula County. Local "Welcome Wagon" organizations will also be asked to notify the ACEMA of any persons requiring special transportation.

J10g The following inventory of buses by school district are i

available for evacuation use:

TRANSPORTATION REGULARS SPARES TYPE RESCURCE LOCATION EQUIPMENT BUSES 29 8 (36) 66-PASS ASHTABULA AREA

( 1) 34-PASS CITY SCHOOLS BUSES 17 6 (17) 48. PASS HAPPY HEARTS

( 6) 54-PASS SCHOOL BUSES 3 0 ( 2) 32-7455 ASHTABULA COUNTY

( 1) 54.?:35 JOINT VOCATIONAL SCHOOL BUSES 25 5 (30) 60-PASS BUCKEYE LOCAL SCHOOLS BUSES 21 4 22) 65-PA55 CONSEAUT AREA

2) 35.?A55 CITY SCHOOLS

1) 12-PA55 BUSES 27 7 (34) 66-PASS GENEVA AREA

• CITY SCHOOLS BUSES 14 A (18) E5-PA55 GRAND VALLEY LOCAL SCHOOLS BUSES 23 7 (23) 65-?A55 JEFFERSON AREA

( 5) 47-PA55 LOCAL SCHOOLS

( 2) 71-PA55 BUSES 16 3 18 65-PA5S PYMATUNING VALLEY 1 24-PA55 SCHOOL DISTRICT

• • TOTAL ** 175 44

• inside 10 mile EPZ

_ -------- -. _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (3)_ _ _ _ _ _ _ ___ ____

ik glL 1

these buses are available from the above school districts.

Letters of agreement will be obtained from each school district providing buses. The-number of buses available, 4 type of bus, and bus resource location will be readily l

available in the event of an emergency for all Eoc staf f i

(including the Transportation Of ficer, Reception Center l Officer, informationHealth Department, Liaison EOC and County Coordinator,)Public Commissioners .

I J12 Evacuees will be monitored and decontaminated, if necessary, Personnel from local fire departments are assigned to each reception center for these purposes. Actual steps to follow i

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while monitoring / decontaminating personnel, vehicles and equipment are included in $0P-A04, Decontamination.

Currently, TEMA is in possession of the latest 50P's that were received for ASLB preparation. Contemination action levels are included in Appendix 33. Registering for evacuees shall occur in accordance with standardised American Red Cross procedures. Per SOP-A16, ARC personnel will register the arrival of evacuees at a reception center and record their departure from the center. An ARC Disaster Shelter Registration form will be used. Registration information will be used as the basis for continuing assessment of feeding and lodging reguirements, as well as the primary source of information for reunification of families.

K4,K5a Both were noted as deficiencies because the county plan has followed guidance set forth by ODSA and the Ohio Department of Health (0DH), the Department of Energy and the U.S. EPA. '

RACC commenta that "these items need to be resolved" and that the " State plan is rated inadequate" have been taken into consideration. Ashtabula County must rely on the outcome of the current discussions between the ODSA and ODH before acceptable changes to the plan can be made.

K5b Currently, FEMA is in possession of the latest 50P's that were received for ASLB preparatica. 50P-A04 does describe techniques for radiological deconta-ination of emergency personnel, general population and vehicles; ir.strumentation, suppliesi vounds; personnel decontaeination records, etc.

L1 A latter of agreement with Ashtabula County Medical Center (ACMC) will be obtained. Contaminated / injured individuals will be handled in accordance with the ACMC Disaster Plan.

Lt. Contaminated injured persons will be transported to ACMC by fire department vehicles and ambulance service vehicles. A letter of agreement will be obtained f rom Ashtabula County (4)

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i l Medical Center. Local Fire Departments providing ambulances for transport of contaminated injured persons will sign a responsibility / acceptance letter.

0&h Per Appendix 34, both the Northwest Ambulance District and l

the ACMC will receive specialised training provided by utility consultants on the proper handling of contaminated / injured individuaAs. ACMC will also be trained i

on the evaluation of individuals ~ exposed to radiation and l radioactive materials, and treatment procedures for these l individuals. " Operators of transport vehicles" are also therefore i

trained they will be trained in handling of contaminated / injured as emergency medical support personnel, persons. Letters of agreement will be obtained from ACMC.

Fire Departments providing ambulances for transport of contaminated injured persons will sign a responsibility acceptance letter. The ACDSA Directer will ensure that all j emergency respondenta receive proper training.

P7 The concept of operations for the Emergency Operations Canter (IOC) is included in 50P-A03, EOC Operations which' describes i

when/how the IOC is activated, E00 facility equipment, KOC staffing and E0C operation. Emergency responsibilities of the County C nmissioners and D5A Director including protective a. tion decision making and recovery / reentry activities are discussed in SOP-AC'., Direction and Cont:fol.

Appendices 1,8,9,18 and 30 will be completed by plant start-up.

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County of Geauga D

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g gp 13281 P A'NESVILLI A AVENNA ROAD e GE AgC A COL,N** $481'Y REN'E4 Cham 3CN. 0 d:C 44034 i

$ l DISASTER SERVICES AGENCY i

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OleICTC# cess TvcingCToo Oakta WEoGI February 26, 1985 soNNit N to N3 i

Kan Cole Chio Disaster services Agency 2035 w. Granville Road worthington, Ohio 4300$

Dear Ken Attached are ny consner.ts based on the FEMA RACC review of the Geauga County Radiolctical Emergency Response Plan, as of 20 November ,984.

': tere were seventeen (17) noted deficiencies of which +=veral concerned airtilar issues. My consents are based on: what changes will ::: r in Change 3, discusa sions and clarifications with Bob Shapiro and yourself sed co:v.ents fror. the utility's consultant.

Thank you for your tire and effort and should you have say pestions, please esil.

Sincerely yours, b/

Dale 3. Wedge Director DSW/p1 Attachment

4 It <ll COMMS)tTS 70 RACC RIV1EW h 1. Criteria items (Alb, A3, C4, J104, clog, L1, L4) all were noted as defi-

! eiencies because of a lack of Letters of Agreerent. (App. 7). Discussion with OD9A and FEMA have outlined that these letters only need to be obtained i

from " private" organtaations such as Red Cross, Schools, etc., and that a ?igned responsibility /asseptance letter was acceptable from all other 6 .n participants. It was stated that the Geauga caerunity Hopsital (App.

1, Tab 1) need only include a summary 1.etter stating its agreements wita

! in support heepitals. It enould also be noted that the remainder of the Appendix 7 agencies Taba 2-9 are currently completed and are pending Change

' auksistal.

2. Criteria itene (ES, 01) were both deficiencies ratir.g the non-inclusion of t'.ie Public Infermation Brochure and the non-listed ESS frequencies and stations. Change 3 will include the first edition of the public informa-tion handbook as well as a revision of the plan (3-4) to incorporate their updating.

. 3. Criteria items (J12 K5b) were noted as defie:encies necause some procedures that were addressed, were referring the reader to revise the appropriate SOPS which were not included in this RACC Review. Currently FEMA is in possession of the latest SOPS that were received in order for ASLB prepara.

tien. Change 3 will encompass r. ore detail in the plan, that will satisfy the reviewer, in terms of data needed, but will not replace the SOP.

4. Criteria items (K4, Kla) both were noted as def t:.ancies because the county plan has followed guidance set forth by CD8A and e.a chio Department of Health (ODH), the Department of Energy and the U i rPA. RACC cessents that "these itema need to be resolved" and that :. 4 the " State plan is rated inadequate" have been taken into considerstm. Geauga County must rely on the outcoes of the current discussiens eetween the CDSA and CDH before acceptable changes to the plan can be :: ate.

l 5. Criteria item ;04h) was noted as a do!iciency be:aase the plan did not 1 specifically identify the OSA Direct:r as he:ng reapensible for g county esergency worker training. Recognizing the fact t..st train.ng program impler.entation may be provided by cther entities: .t11 tty, CD8A, consul-tant, the 04A director will insure that required tra ning is attended to.

Change 3 will refleet this correction.

6. Criteria item (77) was noted as a deficien:y cecase prevaeus RACC comrrents were not indicated in the revised edstion of t; e Gesaga County RZRP (Change 2). Change 3 will indicate that RACC eces. ta ha. been and will continue to be included in the annual ' update of the ecunty %an.

1

! 7. Criteria ite= (G34) was rated because the p* an d;d not list the physical l

address cf the Ceunty Public inferr.ation Off cer :71C) who perforr.s h.s duties at the JP:C. Change 3 Wi!.1 eerrett this eversight, 1

- n, at/4

8. Criteria item (J10a) was rated as a deficioney because (Change 2) did not refleet previous AACC eeaments stating that "the several roads which do not have a perimeter control point have at least en unmanned barricade readalock". The AACC commente received prior to the issuance of Change 2, were received by this county on January 19, 1984. AACC stated at that time, "In addition, we suggest that several of the smaller roads such as Sidley Road, Dewey Road, and Clay Street, which do not have a perimeter control pcint have at least an unmanned readblock with the appropriate ,

i sign called for in the Manual on Uniform Traffic Centrol Devices (noted) ."

Closer RACC review will note that Change 2 has " smaller roads" designated

' that these have a perimeter control peint ';hange 2, Appendix 27, 28)and have assigned provsously unaddressed roads as receiving unmanned barricades /

roadblocks. Seauga County has taken RACC ccmr.ents into consideration and has espanded upon them to the greater benefit of the public.

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, - CERTIFICATE OF SERVICE I, Brian P. Cassidy, hereby certify that copies of (1) Appearance of Brian P. Cassidy; (2) Testimony of Robert O. Shapiro; and, (3) the Federal Emergency Management Agency's Exhibit 3, Regional Assistance Committee Consensus Review, November 20, 1984, were serve by mailing, Express Mail, on this 25th day of March, 1985 to the individual named below.

James P. Gleason Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, Ma ryland 20901 Jerry R. Kline Atomic Safety and Licensing Board ye U.S. Nuclear Regulatory Commission 9 ll t, Washington, D.C. 20555 l}7, Glenn O. Brigh t kh- s Atomic Safety and Licensing Board {' _

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• U.S. Nuclear Regulatory Commission m ..

Washington, D.C. 20555 ->

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'd Docketing and Service Section Of fice of the Secretary U.S Nuclear Regulatory Comrdssion Washington, D.C. 20555 Colleen P. Woodhead, Esquire Of fice of the Executive Legal Direc tor U.S. Nuclear Regula tory Commission Washington, D.C. 20555 Jay Silberg, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Sue Hiatt 8275 Mentor Avenue

• Mentor, Ohio 44060 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Terry J Lodge, Esquire 618 N. Michigan Street Suite 105 Toledo, Ohio 43624 r

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[ January 31, 1965 i

4 Nr. Richard M. Lockhart i Deputy Director Ohio Disaster Services Agency

2825 West Cranville Road j Worthington, Ohis 43085 .

1 Attention: Mr. Kenneth Cole

Dear Mr. Lockhart ,

! Enclosed are the consensus findings of the Regional Assistance Committee

' as a result of their November 20, 1984 review of the Ashtabula, Geauga and Lake Counties Radiological Emergency Response plana.

The attachments lists each applicable criteria iten identified by NUREC 0654/FD'A Rep-1, Revision 1.

. The RAC Consensus indicates additional effort is required on some criteria items, as reflected in the Attachments.

A schedule of corrective actions is required. The schedule of corrective actions should address each NUREG-0654/FD'A Rep-1, l

l Revision 1 criteria item that has a deficiency noted, include a com.ent describing the corrective action proposed and an estimated date when the action will be completed. We suggest use of a format shitar to that used regarding deficiencies noted during exercises.

j g, ,, .p g . .- . - - . . - - = - u - ., -.,e ive actions by I March 11, 1985.

Sincerely ,

l ec: Reader File Wallace J. Vesvar, Chairman 90 Ill 59 E 9 Docket File Regional Assistance Committee t

l RD's Office Bob Turner Bob Shapiro Attachments Phyllis Rainier R5-TII-25-DB-6-9446-ah-1-31-S S DB _ W Den Bement 4

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. r Regional Assistance Committee Consensus Review of the Revised Ashtabula County, Ohio Radiological Emergency Response Plan as of November 20, 1984 Criteria Item Rating Comment Ala Adequate The plan identifies the State, local, Federal and private sector organizations (including the utility) that are intended to be a part of the overall response organization for EPZs (Appendix #6) and the responsibility matrix-(Appendix #7).

Alb Inadequate The plan includes a broad and general explanation of the concept of operations for the County with only a brief description of .

the response functions for participating agencies. There are references to non-existent letters of agreements in Appendix #8 where Agencies are supposed to explain.

(Pages B-1, Paragraph B, 2 and A-2).

Alc Adequate The plan includes an illustration of the interrelationships of the overall response organization in a block diagram. (Appendix

#10). " Control Coordination and l Interrelationships of Response Agencies and l Organizations.

l Ald Adequate Rated during previous RAC review meeting conducted April 19, 1983.

Ale Adequate Rated during previous RAC review meeting conducted April 19, 1983.

A2a Adequate The plan specifies the function and responsibilities for major elements and key individuals by title of emergency response in a table of primary and support responsibilities using the AE ency as one axis and the function as the other. (Appendix #7).

A2b Adequate Rated during previous RAC review seeting conducted April 19, 1983.

A3 Inadequate The plan references Appendix #8 for letters of agreement referring to the concept of operation. However, Appendix #8 is only a l

subj ect page (titled " Letter of Agreement")

behind which the letters should be located as i referenced. The letters are not included in the plan.

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A4 Adequate Revision is adequate. This capability is reflected in paragraph B-3.

cla thru E2 Adequate Rated during previous RAC review meeting conducted April 19, 1983.

E5 Inadequate The plan still does not contain the suggested inclusion of listing the EBS stations by frequency or call letters. Appendix #18 is referenced for the information. However, the information is not in the referenced Appendix

1. 18.

E6 Adequate Rated during previous RAC review meeting conducted April 19, 1983.

E7 Adeuate Sample messages included in the plan that are to be disseminated to the public should provide instruction for respiratory protection such as handerchief over mouth, .

etc. for those people who leave their buildings.

Fla & F1b Adequate Rated during previous RAC review meeting conducted April 19, 1983.

Flc Adequate The plan includes a diagram of EOC communication links (Appendix #20) one of which indicates the State is responsible for the communications link to Federal response Agencies. There should be a written statement of this requirement in the plan.

Fld thru F3 Adequate Rated adequate during prievicus RAC review meeting conducted April 19, 1983.

G1 Inadequate The plan has not addressed the recommendation for inclusion of samples of the annually distributed public infsreati:n caterials.

The plan update references Appendix F18 for the caterials. However, Appendix #18 is only a title page, " Perry Nuclear Power Plant Emergency Inforcation Handbook." No Perry Nuclear Power Plant Emergency Information Handbook was in the plan or available for review by the RAC.

l G2 Inadequate The plan has not addressed the requirenent to include the lis:ing of the Eis frequency as recoceranded by the FAC.

G3a Adequate The plan states the Joint Public Information Cer.ter is located at the Lakeland Community College , Kirkland , Ohio. (Page G-2, Paragraph G3).

2

o I

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G4a Adequate Rated adequate during previous RAC review meeting conducted April 19, 1983.

C4b Adequate The plan states upon Activation of the Joint Public Information Center, the Ashtabula County Public Information Officer will go to the Joint Public Information for the coordiantion of Public information and news releases with representatives from Lake and Geauga Counties, the State of Ohio, and Perry Nuclear Power Plant (Page G-2, Paragraph G.3).

G4e Adequate The rumor control telephone number to be used by the general public should be included in the plan.

O-G5 Adequate The plar quotes this Nureg Criteria item on the coordinated annual news media briefings, (Page G-3, Paragraph G.5).

H3 thru H7 Adequate Rated adequate during previous RAC meeting conducted April 19,1983.

B10 Adequate The plan contains all Nureg criteria requirements on the inspection, inventory, and operational check of emergency equipment / instruments; the time period for each check, reserve supplies, repair, calibration, and those individuals / agencies that are responsible for same. (Page H-3).

H11 Inadequate Lists are found in Appendix #22 but no mention is made of com=unications equipment.

H12 Adequate The plan states that coordination of the sample media of State monitoring teans in Ashtabula County is discussed in the Ohio State Nuclear Power Plant Emergency Response Plan (Page H-3, Paragraph H.4).

17 thru J9 Adequate Rated during previous FAO revie. meeting conducted April 19, 1983.

J10a Adequate The plan includes the map showing the preselected radiologiesi sampling and monitoring peints and designated road blocks on the map depicting evacuation areas as suggested by the RAC review in addition to the other required ca;s.

J10b Adequate Rated during previous RAC review meeting conducted April 19, 1983.

3

-- - - - -, , , , , - - - . . - - - , . - . , - - - - - - - , . --. - - , . , , , - -~

i J10e Inadequate The plan states that arrangements will be made to notify any t. earing impaired. These arrangements need to be completed and become a part of the written plan. The plan references Appendix fl8 (Perry Nuclear Power Plant Emergency Inf ormation handbook) which is not included in the plan.

J10d Inadequate The plan refers to the non existing Appendix

1. 18 information for the major parts of this criteria item. The Perry Nuclear Power Plant Emergency Inf ormation Handbook and/or further information on this criteria ites needs to be included in the Ashtabula County plan.

Appendix #9 for the procurement of school buses for transporting evacuees is only a letter suggesting local school districts be contacted for this need.

J10e Adequate The referenced letter of Agreement or the '

basis f or decisions should be revised since Federal guidance on KI was published 6/29/82 (Federal Register Volume 47, Number 125).

J10f Adequate Same Comment as J10e above. '

J10g Inadequate lhe plan states that school buses will be used as the means for relocation of evacuees. A letter from the office, Superintendent of Public Instructions (Appendix #9) is included to verify the a.ailability of buses for this purpose in response to the RA0 review. However, there is no indication of the numbers of buses that will be made available for evacuation of evacuees, nor frez where except (" schools outside the 1C ri'.e EPZ).

J10h Adequate Rated during previous FAC review seeting conducted April 19, 19e3.

Adequate Evacuation route capacities should be J101 estimated in c:nsultation with the Ohio Department of Trar.sportation rather than using the National Average figure. k'e should be using the best :apacity esticates available to ensare realistic evaluation times.

J1Gj thru J11 Adequate Rated during previaas EAC review meeting conducted April 19, 1963.

J12 Inadequate The means for registering and monitoring evacuees are included in SOP's. The SOP's were not included in the plan, thus not available for review by the RAC.

4

K3a Adequate The plan addresses the RAC review recommendation that the issuance of TLD devices and their capability to determine dose on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis be included in the plan, in addition to the other parts of this criteris item (page K-1, paragraph K.2, page K-2).

K3b Adequate Dosimeters will be read hourly or more frequently if necessary. Records are maintained in the EOC.

K4 Inadequate The Ashtabula County Plan states the Ohio Department of Health will determine if a worker can e~.ceed the limits. The State plan says no one will exceed this limit. This item needs to be resolved.

K5a Inadequate The plan (Apoendix 33) uses the same levels as the State plan; the State plan is rated ,

inadequate.

K5b Inadequate The sc ans for radiological decontamination Missing of emergency personnel, wounds instrumentation, supplies , etc. , are included in SOP's. The SOP's were not available for the RAC to raview. The RAC requests copies of these SOP's so a review can be completed.

L1 Inadequate Plan refers .o Letter of Agreement with Ashtabula County indicating preparedness to deal with contaminated individuals-letter not available for review.

L3 Adequate State Responsibility.

L4 !nadequate Plan indicates that c:n:amina:ed individuals will be transpor:ed in fire department vehicles-refers to le::er of agreement that was not availble f or RAC review.

M1 Adequate Rated during ;revious RAC review mee:ing conducted April 19, 1983.

M3 Adequate S: ate Responsibility.

I M4 Adequate State Resp;nsibillity.

Nla Adequate Rated during previous RAC review neeting

! conducted April 19, 1983.

Nlb Adequate The plan n w quotes the STREG criteria for mobilization of staff and resources, exercise scheduling, etc.

5

v N23 Ad;qusto Th3 plcn incorporatas tha NURIG critorio itco n ccatcnt fer th2 csmmunicaticcs drill thich the County is responsible for insuring (ie PNPP, other Counties response organizations and the State). They also include the aspect of understanding the content of messages (page N-2, Paragraph N.3).

N2e Adequate The plan states that a medical emergency drill involving a simulated contaminated individual and which makes provision for participation by support organizations in Ashtabula County such as hospitals and ambulance services will be conducted annually (page N-3, Paragraph 1).

N2d Adequate Rated during previous RAC review meeting conducted April 19, 1983.

N2e1 Adequate State Responsibility.

N3a Adequate The plan quotes the Nureg criteria item for .

the basic objectives of each drill and exercise (page N-3, paragraph n.4)

N3b Adequate The plan quotes the Nureg criteria ites for the dates, time period, places and participting organization. (Page N-3, paragraph 4).

N3c Adequate The plan quotes the Nureg criteria item for the simulated events (page N-3, Paragraph N.4).

N3d Adequate The plan quotes the Nureg criteria item for a time schedule of real ad simuated initiating events.

N3e Adeuate The plan quotes the Nureg criteria item for a narrative su::ary which describes the conduct of the drill er exercise.

N3f Adequate The plan quotes the Nureg criteria item for arrangements for exercise observers (page N-3, Paragraph N.4).

N4 Adequate Rated during previous RAC review seeting conducted April 19, 1953.

N5 Adequate The plan establishes means for evaluating observer and participant com=ents on are as needing imprevement, including e:ergency plan procedural changes; for assigning ,

responsibility for implementing corrective actions and establishes canagement control to ensure corrective actions are

- implesented. (Page N-4, para. N-6) -

6

t 01 thru 04g Adequate Rated during previous RAC review meeting conducted April 19, 1983.

04h Inadequate The plan states "the operators of transport vehicles will be trained in the handling of contaminated injured individuals." There is no mention of who will provide the training, nor explanation of training for other emergency medical support personnel. The reference to Appendix #8 would perhaps explain the plan for training in the letters of agreements. However there is nothing in the referenced Appendix #8 (page L-1, Paragraph L.4).

04j Adequate Rated during previous RAC review meeting conducted April 19, 1983.

05 Adequate The plan sti:es that "all emergency workers will be trained initially, after employment .

' or assignment, and at least annually thereafter." (page 0-2, paragraph 0.4).

P1 thru P3 Adequate Rated during previous RAC review meeting conduc.ted April 19, 1983.

P4 Adequate There are no provisions for the annual certification of the plan that indicates its current nature as suggested in the last RAC review. The certification page is a blank, unsigned foreat only.

P5 & P6 Adequate Rated during previous RAC review meeting conducted April. 19, 1953..

f P7 Inadequate (See .;ureg criteria item A.I.b.). The plan i

contains an appendix listing procedures l

required to imple:ent the plan. McVever, the concept of operations and/or SOPS for the l

! response organizations are not included in the plan. The brief statements in the plan regarding the response organizations does not include enough detailed information to l

l explain a concept of operation and/or SCPs.

I Also Appendixes are incomple.te (#9) and/or

! are cissing (#1,8,18, 30) from the plan.

PS Adequate Rated during previ:us FAC review meeting conducted April 19, 1963.

l P10 Adequate The plan states " Telephone numbers and l

frequencies listed in the SOPS will be l verified to be correct and updated as l

necessary at least quarterly.

7

R:gional Assictcnca Ctmaittco Csnsensus R;vice

• cf th3 Revised Geauga County,0hio Radiological Emergency Response Plan as of November 20, 1984 Criteria Comment Iten Rating Ala Adequate The plan identifies the State, local, Federal and private sector organizations (including the utility) that are intended to be part of the overall response organization f or emergency planning zones. (page B-2-B-5 and Appendix #4).

Alb Inadequate The plan includes a broad and general explanation of concept of operations for the county with only a brief description of the response functions for participating -

agencies. There are references to non-existent letters of agreements (Appendix #8) where agencies are supposed to explain their respective concept of operations.

Alc Adequate The plan includes an illustration of response organteations and their interrelationships in a block diagram, including State and Federal organizations as recommended by the previous RAC review. (Appendix 6, page 6-1).

Ald Adequate The plan states that the Geauga County Commissioners have decision making control over the entire emergency response effort and decide on the responses to be ordered for the public. (page B-1, paragraph B-2 and Appendixf4).

Ale Adequate The plan provides for 24-hour per day emergency response, including 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day i

manning of commanications links (pages B-8, paragraph B-7;E-1, paragraph E-2; F-2, paragraph F.3, and H-1, paragraph H-2).

1 A2a Adequate The plan specifies the functions and responsibilities for major elements and key individuals by title of emergency response.

The description of these functions are in narrative form and a table which shows primary and support responsibilities using the agencies as one axis, and the function as the other. The plan has included the items as recem er.ded by the previous RAC review.

(Appendixes #4 and 6).

1

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A2b Ad qucto R tcd during th2 prsvicus RAC rovicw me3 ting

. conducted April 19, 1983.

A3 Inadequate The plans' cross reference refers to appendix

1. 8:.but there are no letters of agreement developed between local agencies and other support organizations having an emergency response role within the EPZs.

A4 Adequate The plans' revision is adequate. It states that "the County Commissioners shall be in overall charge of the emergency response by Geauga County. They will be assisted by the DSA Director. The DSA Director serves in the dual capacity of DSA Director and Chief of Staff. In the role of Chief of Staff, he manages operation of the EOC and coordinates the total emergency response effort. He is responsible for coordination of the emergency actions of individual agencies, and for the coordinated use of available resources."

Cla Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

C4b Adequate Rated durigg the previous RAC review meeting conducted April 19, 1983.

Cic Adequate Rated durit:g the previous RAC review meeting conducted 1.pril 19, 1983.

C2a -Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

C3 Adequate Rated during the previous RAC review caeting conducted April 19, 1963.

C4 Inadequate The plan contains only one letter of agreeeent (Geauga C:=munity E spital) for private organizational support to the respense effort although it lists eight (8) other organizations in Appendix #7. Letters of Agreement are needed for the A=erican Red Cross, Ambulance Services, and other support organizations.

D3 Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

2

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D4 Adequato The plca sectes th:t caerg: cy cetic;s to be

- tckco io th] c:unty will be mad] b;Ord c2 recommendations made by PNPP, the Ohio DSA, and the County EOC oporations group (page D-2, paragraph D-3). I: also contain procedures that provide for emergency actions to be taken which are consistent with the emergency actions recommended by the utility that takes into account local offsite conditions that exist at the time of the emergency (Appendix #9 and page D-1).

E.1 and E.2 Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

E.5 Inadequate The plan does not address the recommendation of the RAC review that the EBS stations be listed by frequency numbers or call letters.

The plan references Appendixes 15 and 16 for this informatian however, it is not included in those Appendixes nor any other Appendix in the plan. .

E.6 Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

E.7 Adequate The plan includes written messages intended for the public that are consistent with the licensee's classification scheme. It states

" Warning messages that include a recommendation for evacuation of the public in that portion of the 10 mile EPZ which is in Geauga County (i.e., Thompson Township) will proceed south on State Route 528 to Cardinal High School in Middlefield...as the primary reception center.. ..(page E-4, paragraph E-6). Note: The PNPP Emergency Information Handbook which is referenced as being in Appe: dix #15 is not included in the plan.

Fla and Flb Adequate Rated during the previs;s RAC review meeting conducted April 19, .963.

Flc Adequate The plan states that " regular telephone, or telephone and radio through the State EOC or the E07" will be the means fpr communications with Federal agencies. (; age F-3, paragraph F.4).

Fld, thru F3 Adequate All were rated during the previous RAC review meeting conducted April 19, 1983.

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G1 Inad:quato Th3 carrativa discuss:s tho type ti public irformatien matcrials to be nada cv;ilcbla and the method of information dissemination, the PNPP Emergency Information handbook is not available.

C2 Adequate The plan includes public information for permanent and transient persons within the 10 mile EPZ. It addresses the recommendation of the last RAC review, "to expand the locations where information will be provided to transients."

G3a Inadequate The plan states that the PIO is the designated point of contact for the news media during an emergency. However, the physical location is not designated. (page G-3, paragraph G-4).

Adequate Rated during the previous RAC review meeting G4a conducted April 19, 1983.

G4b Adequate The plan states "the PIO will go to the JPIC, where he will exchange information and coordinaca public information and news ,

releases, with representatives from Lake and Ashtabula Counties, the State, and PNPP."

(page G-2, paragraph G-4)

G4c Adequate The plan states that " rumor control will be exercised by use of a separate hotline telephon in the EOC. The county administrator will be responsible for assuring that people who operate this telephone are knowledgeable of the status of the emergency and are capable of answering questions relative to the emergency..."(page G-3, paragraph G-5).

G5 Adequate The plan includes information on a coordinated program to acquaint news media with the emergency plans, information concerning radiation, and points of contact for release of public infor=ation in an emergency. (; age G-4).

H3, H4, & B7 Adequate All were rated during the previous RAC review meeting conducted April 19, 1983.

H10 Adequate The plans frequency of inspection, inventory, operational checks and calibration of emergency equipment /instru ents meet Noreg 0654 criteria. (; age H-2 and 3).

4

• 4 H11 Adequato Th3 plcn centains a list cf coerg0nty kits in

• • Appe: dix #20.

H12 Adequate It is realized that the State does the sampling (paragraph H-5). However, the State needs to coordinate a local central point for samples with the County.

17 thru Ill Adequate State and/or County responsibilities were f rated for the County during the previous RAC review meeting conducted April 19, 1983.

J9 Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

J10s Inadequate The plan has not fully addressed the RAC review recommendation that "the several roads which do not have a perimeter control point

/ have at least an unmanned barricade / roadblock."

J10b Adequate Rated during the previous RAC review meeting ,

conducted April 19, 1983.

J10e Adequate The plan states that "the primary means of alerting the public will be through a siren /public address systes, any segments of the public which cannot be alerted by the siren /public address system will be alerted by telephone and/or mobile public address units. the Thompson fire Department maintains a current record of people with hearing disabilities and will be responsible for alerting this segnent of the County's population (page E-3).

J10d Inadequate The plan refers te a *e:ter from the Chief, Pupil Transportation (Appendix #24) which sugges: that the County f:rzalize planning for use of public school huses, with local school districts , since < ach school district own the buses. There are no letters of agreenen:s be:veen the County and the school districts for the use :f the buses, as referenced in the plan. (page J-4, paragraph a and the referenced ;;pendit #7).

J1Ce and J10f Adequate The referenced letter of agreement or the basis for decisions should be revised since Federal guidance en K* vas published 6/29/82 (F.R. Volume 47, Nesber 125).

5

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J10g Ictdaqusto Th2 pics states that "most af the ov:cuctirg population will travel in their Cwn vehicics.

People without vehicles will remain in their homes, where they will be picked up by school buses operating under the direction of the Thompson Fire Department." Bowever, since there are no agreements indicating that buses will be made available for the transportation of the populace the foregoing planning is incomplete.

J10h thru J11 Adequate All were rated during the previous RAC review

! meeting conducted April 19, 1983.

J12 Inadequate The plan indicates that the means for i registering and monitoring of evacuees,are included in SOPS which are not included in the plan.

K3a Adequate The plan states that Cleveland Electric will process TLDs as frequently as necessary (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day if required). "(page K-1, ,

paragraph '-2). It further states that both direct reading dosimeters and TLDs will be issued to emergency workers.

K3b Adequate The plans' revision states that dosimeters are sead every hour. Paragraph K-3 states

! that exposares will be kept for an indefinite period of time.

K4 Inadequate The plan states that the Ohio Department of Health will determine if a worker can exceed the limits. The State plan says no one vill exceed this limit. This ites needs to be resolved.

K5a Inadequate The county plan uses :he same action levels

as the s: ate plan for determining :he need for decon:amintion. The Sta:e plan is rated inadequate.

K5b Inadequate The means f or radiological decontamination of l

emergency personnel vsunds, supplies, etc.

l are included in omi::ed SOP's rather than the RE RP. Some decon:stination procedures are included with the Geauga Com= unity Hospital Letter of Agreement (; age K-6).

l l

i

,. . ( .

L1 In:d qu;to The plcn etctcs that Geauga Community

Bospitc1 cill previda medicci tresteert ca a local hospital per letter of agreement.

Backup hospitals (university, etc.) are listed however the plan does not include letters of agreement from the backup hospitals or any indication of the hospitals awareness and capabilities for responsibilities.

L3 Adequate Rated during the previous RAC review seeting conducted April 19, 1983.

L4 Inadequate The plan does not include letters of agreement with ambulances, fire departments, etc.. for the transporting of victims of radiological accidents to medical support facilities.

M1 Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

M3 and M4 Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

N1a Adequate Rated during the previous RAC review meeting ecoducted April 19, 1983.

N1b Adequate The plan includes all the elements of the criteria item as recom: ended by the previous RAC review (page N-1, paragraph N-2).

N2a Adequf,te The plan includes the elementa of the Nureg criteria, including the recosaendation of tha previous RAC review "to insure that emergency workers understand the content of messages that will be transmitted and h:w they should respond to the messages." (page N-2, paragraph N-3a).

N2c thru N2d Adequate All were rated during the preveus RAC review meeting conducted April 19, 1953.

N3a thru N3f Adequate Scer.arios will be developed according to requirements in Nureg-0654 N4 Adequate Rated during the previeus RAC review neeting conducted April 19, 1983.

i 7 l

l

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N5 Adequato Th3 plan states that the County DSA Dir0ctcr

"- will sch;dule o critiqua tamediately af ter conclusion of an exercise. The critique participants will evaluate general performance and the ability of individuas, organizations, and equipment to respond as required. The County DSA Director is responsible for development and provision of copies of a written summary of the critique to all participating agencies, the State DSA and CEl. He is responsible for the review and implementation of any necessary improvements and/or corrections. The County Commissioners will have the final responsibility for ensuring that improvements and/or corrections are completed in a timely manner.

01 and Olb Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

04a thru 04g Adequate Rated during the previous RAC review meeting ,

conducted April 19, 1983.

04h Inadequate Training is offered to all emergency workers. Responsibility for training requirements are not addressed.

04j Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

05 Adequate The plan states that " initial training will be scheduled expeditiously for all newly assigned emergency workers. Retraining and refresher training will be scheduled at least annually thereafter.

P1,2, and 3 Adequate All were rated during the previous RAC review meeting conducted April 19, 1983.

P4 Adequate The plan provides for the updating of the plan and agree:ents as needed; the review and certifying it to be current on an annual basis , with the update to take into account the changes identified by drills and exercises (pages P-! and P-2, paragraph P-3).

P5,6, and 8 Adequate All were rated during the previous RAC review meeting conducted April 19, .983.

P7 Inadequate The plan does not address the recommendation of the previous F.AC review.

P10 Adequate The plan states that " telephone numbers, radio frequencies and names listed in the SOPS will be reviewed and updated at least quarterly." (page P-2, paragraph P-3).

8

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R;gion31 Assistcnca Committce C:nssnsus R vicv of the

.-

• Revised Lake County, Ohio Radiological Emergency Response Plan November 20, 1984 Criteria Rating Comment 1tes Ala Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

Alb Inadequate A letter included in the State of Ohio plan from the Chief, Pupil Transportation dated May 27, 1983 indicates school buses may be used for evacuation purposes and states prior arrangements should be made with the appropriate schools. No letters of agreements concerning such prior arrangements could be found in the Lake County plan.

Alc thru Ald Adequate Rated during the previous RAC review meeting conducted April 19, 1983.

Ale Adequate The plan adequately addresses criteria iten Ale.

A2a Adequate The plan adequately addresses this criteria item but the plan should consistently use acroynns, e.g. LDSA used interchangeably with DSA which could be conf used with Ohio DSA.

A2b Adequate Rated during previous RAC review meeting conducted April 19, 1983.

Inadequate This criteria item is rated inadequate A3 because the County relies on the State to comply with this criteria item. The State of Ohio plan is rated " inadequate" for this criteria iten.

A4 Adequate Revision is adequate, this capability is reflected on page 25.

Cla thru c3 Adequate Rated during previous RAC review meeting conducted April 19, 1983.

C4 Inadequate Page 170 has been removed and so the plan sequence of ; ages goes from 169 to 171. Page instruction is needed to explain the missing page. This planning criteria item is further rated inadequate because the letters of agreement are missing.

. I

9 D3 Adequate R;ted during pr;vicus RAC revicv mesting  ;

- ccnductcd April 19, 1983.

D4 Inadequate Paragraph I-01 indicates the utility will pass recommended protective action recommendations to the County Commissioners through the Ohio Department of Health. The Lake County plan does not indicate basic consideration such as varied offsite conditions which the commissioners should consider in accepting or rejecting the utility protective action recommendation.

El thru E5 Adequate Rated during previous RAC review meeting conducted April 19, 1983.

E6 Adequate Paragraph E-07 (Page 61) adequately addresses the 15 minute criteria requirement.

E7 Adequate Sample messages included in the plan that are to be disseminated to the public should provide instruction for ad hoc respiratory ,

protection such as hankerchief over the south, etc. for those people who leave buildings.

sense.

Fla thru Flc Adequate Rated during previcus RAC review meeting conducted April 19, 1983.

Fld Adequate Communications equipment is shown on Page 87.

Fle Adequate Rated during previous RAC review meeting conducted April 19, 1983.

F2 Adequate Attachment F-1, (Page 87) responds to this criteria.

F3 Adequate Rated during previous RAC review meeting conducted April 13, 1983.

G1 Inadequate The " packet" of public information has not been transmitted for review. Therefore, this criteria 1:eu is rated inadequate until a sa:isfactory review is completed by the RAC.

G2 Adequate Rated du:ing previous RAC review meeting cor. ducted April 19, 1983.

G3a Adequate The Lake Coun:y Public Information Of ficer will coord'..s:e all press briefings at the Joint Public Infermation Center loca:ed at Lakeland Cos=;.ity College on page 99.

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)

i G4a Ad:quato R tCd durirg previous RAC r0vice me3 ting

- conducted April 19, 1983. l l

G4b Inade'quate The schedule of corrections indicates page 93 of the plan would be modified to indicate a continuous dialogue between the public information officer of the State and County agencies as well as the utility would be conducted. This modification has not been completed. It is still not clear in the plan if the County PIO will be physically located in the Media Center or whether the County PIO will be at the Lake County Emergency Operations Room with a dedicated line to coordinate news releases.

G4e Inadequate The Public Information package and sample of the telephone insert has not been provided to FEMA /RAC for review. This criteria ites will remain inadequate until a satisfactory review is completed.

G5 Adequate This information is explained on page 93-A of the Lake County plan.

H3 Adequate H-01, Page 95 of the Lake County plan indicates the location of the Lake County Emergency Operation Center at 8000 Garfield Road , Kirkland , Ohio.

H4 Adequte Rated during previous RAC review meeting conducted April 19, 1963.

H7 Inadequate The Lake Coun:y plan s:ates the County field monitoring teams will support the States capability to do a field assessment.

However,*.ake County does not have the capability to measure radio-iodine to 10-7 uci/cc in the presence of noble gases. See Attachmen: H-8 (Page 110) and Attachment 1-2 (page !!6) of the Lake Coun:y plan f or the lists of monitoring equipment.

HIO Inadequate Page 100 was not modified according to the schedule of corree:ive actions to indicate corrective actions to indicate a six (6) month exchange cycle for instruments.

(FEMA's) copy of :he Lake County plan does not contain page ;00A, if this is the page where the modificatien was to appear).

Ell Inadequate Emergency Kits do not mention protective

!. clothing, respira:Ory pro:ection equipment or other supplies ou: side of monitoring equipment and communication equipment. See commen: under H7.

3

B12 Intdequa.o Mounty Beam (mwog up taagnrungs rcpset findings to th2 Lako C unty Emerg:ecy Op3rcticas Cestor a:d further trcccaittcd to

• tho Stato EOC. Couxty tocas cre taiquo to Lake County in Ohio. Radiological Monitoring appears to be uncoordinated in Lake County.

Kits are located at local fire and police stations. The RAC questions the County's ability to provide complete accident as se s s ment . See consent under criteria iten H.7.

17 Inadequate Stationary Alert Monitoring system consists of 16 monitoring stations located on public buildings. It is still being designed. Data will be telemetered to a central control and display position at the Lake County EOC.

This is considered inadequate as the system is still under design. Two man Lake County field monitoring teams is equipped according to County SOPS. The RAC needs to review these SOPS.

18 Inadequate Lake County is developing an independent '

assessment capability which is duplicative and has limited ef fectiveness. The Lake County field monitoring team equipment is not adequate for rapid assessment of the radiological hazards. The expertise of the team has not been adequately documented.

Maintenance of the Stationary Alert System and field instruments is not addressed. No SOPS are available for review by the RAC.

19 thru Ill These planning criteria items pertain only to the State of Ohio.

J9 Adequate Lake County officials have accepted state guidance and criteria for protective response action.

J10a Inadegaate Although the evacuation cap appears on page l 132 it is not completely legable making it difficult to use.

J10b Adequate Attachment J-1-A is a population distribution projection by 221/2 sectors while Attachment J-1, EPZ " subarea" map is zoned according to geographic sections rather than 22 1/2 sectors and is the actual area to be evacuated. Since the two projections do not l

correlate with one another it may be prudent to incorporate the population figures l

projected on the 22 1/2 sectar projection l

onto the Sub Area.

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J103 Adequate Paragraph E-07 (Pag 2 61) cf th] Lake County

.. pl:n indicctes tha sirens till be sould:d ct the " General Emergency" Accident Classification. If the need arises, it say be sounded at the " site area emergency" accident classification after coordination with the County Commissioners has been completed.

J10d Adequate Paragraph J-06 (page 122) addresses transportation arrangements planned for the mobility impaired.

J10e Adequate fhe referenced Letter of Agreement or the basis for decisions should be revised since Federal guidance on K1 was published 6/29/82 (F.R. Volume 47, Number 125).

J10g Inadequate Paragraph J-06 (page 121) indicates that buses will be used to evacuate the States position according to a May 27, 1983 letter from the Chief, pupil transportation indicating it is permissable to use school buses for evacuation purposes after agreements had been made with the affected school systees. Since the plan does not off er evidence agreements have been made ,

this criteria item is rated inadequate.

J10h Adequate Rated during previous RAC review meeting conducted April 19, 1983.

J101 Adequate Rated during previous RAC review meeting conducted April 19, 1983.

J10J thru J11 Adequate Rated during previous RAC review meeting conducted April 19, 1983.

J12 Inadequate The means for registering and monitoring evacuees are in:;uded in SOPS. These SCPs need to be revie.ed by the RAC.

K3a Adequate Paragraph K03.2 (; age 140) plans f:r hourly j readings of d:simeters ith a tabulation of these readings on a radiation exposure form found in K2 (; age 144).

K3b Adequate See Comment K3a above.

K4 Inadequate The '.ake Coun

y plan states the Ohio l Departzent of health will determine if a worker can ex:eed the limits. The State plan l

also says no one will exceed this limit.

This item ceefs to be resolved.

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K53 Innd:quato Th] Like County plan (Appendix 35) es s the

• s:me 10vels as tha State plea; the etcta plc3 is rated inadequate.

K5b Inadequate The means for radiological decontamination of emergency personnel, supplies, etc. are included in SOPS rather than RERP. The State of Ohio did not submit the SOPS to the RAC for Review.

L1 Inadequate Persons requiring diagnostic services for exposure vill be transported to Lake County Memorial Hospital. (East or West). Both hospitals have the capability for evaluation or uptake. Letters of agreement acknowledging capability and awareness of responsibility are not available.

L3 This criteria item is the responsibility of the State.

L4 Inadequate Paragraph LO3.7 (page 149) indicates

• transportation of contaminated personnel has been arranged. No letters of agreement with these organizations could be located in the plan.

M1 Adequate The State advises the County. The State is rated adequate for this planning criteria item. See paragraph M.01 and M.02. (page 151) of the take County plan.

M3 and M4 These two planning criteria items are the responsibility of the State of Ohio.

Nla Adequate Paragraph N-01 (Page 154) adequately addresses this criteria item.

N!b Adequate Paragraph N-01 (Page 154) adequately addresses this criter.ia item.

N2a Adequate Plan discusses co==;nication drills with State and local governments. Perry Nuclear Power Plant and State and Lake County EOC and field assessnent teams.

N2e Adequate Rated during previous P,AO review meeting conducted April 19, 1983.

N2d Adequate Revision is adequate. See page 155.

N2el This criteria itet in the responsibility of the State of Ohio.

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N33 Ad qu te Paragraph N-03.1 thru N-03.6 cd:quatoly

.: address this criteria ites.

t N3b Adequ' ate Rated during previous RAC review seeting conducted April 19, 1983.

N3c Adequate Paragraph N-03.3 (Page 156) adequately addresses this criteria.

N3d Adequate Paragraph N-03.3 and N-03.5 adequately addresses this criteria item.

N3e Adequate Paragraph N-03.3 and N-03.5 adequately addresses this criteria ites.

N3f Adequate Rated during previous RAC review meeti.ng conducted April 19, 1983.

N4 Adequate Paragraph N-04 (page 156) adequately addresses this criteria ites.

N5 Adequate Paragraph N-05 (page 156-156A) adequately ,

addressess this criteria ites.

01 thru 04a Adequate Rated during previous RAC review meeting conducted April 19, 1983.

04b thru 04d Inadequate Good training requirements listed.

Attachment 0-2 (page 162) provide a list of training courses for emergency workers.

However, the progran does not seem to be ensured by any one individual.

04f thru 04j Adequate Rated during previous RAC review seeting conducted April 19, 1983.

Adequate Revision is adequate, Fages 157 and 158 05 discusses initial and annual training.

Adequate Rated during previous RAC review meeting P1 thru P6 conducted April 19, 1983.

P7 Adequate Appendix 4 (pages 176-17?A) adequately addresses this criteria ite .

Adequate Rated during previous RAC review meeting P8 and P10 cunducted April 19, 1983.

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