ML20116K243

Forwards Schedules of Corrective Actions Submitted by State of Oh & Counties of Ashtabula,Geauga & Lake for Deficiencies Noted in Final Rept for 841128 Offsite Radiological Emergency Preparedness Exercise

ML20116K243
Person / Time
Site:	Perry
Issue date:	05/01/1985
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8505030221
Download: ML20116K243 (17)

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[ ( Federal Emergency Management Agency o Washington, D.C. 20472 O O MAY l 1985 MEMORANDUM FOR: Edward L. Jordan Director, Division of Emergency Preparedness qyh and Engineering Response Office of Inspection and Enforcement g

U.S. Nuclear Re latory Commission 0, ?

FROM: R d W. r m Assistant Associate Director f 4 Office of Natural and Technological Hazards Programs

SUBJECT:

Ohio Schedule of Corrective Actions for Deficiencies Identified During the Perry Nuclear Power Plant (NPP)

Offsite Radiological Energency Preparedness (REP) Exercise Conducted on November 28, 1984 Attached are the schedules of corrective actions submitted by the State of Ohio and the Counties of Ashtabula, Geauga and Lake for the deficiencies noted in the Final Report for the Perry NPP Offsite REP Exercise conducted on November 28, 1984. The exercise report was sent to you on January 31, 1985.

The Federal Emergency Management Agency (FEMA) Headquarters and Region V staff have reviewed the schedules of corrective actions submitted by the State and Counties and found them adequate with the following exceptions. Geauga County's response to the K.3.a/K.3.b deficiency (radiological exposure control for emergency workers) is not acceptable for two reasons. First, FEMA does not accept the Geauga County position that the Ohio Department of Transportation (0 DOT) crew "... stationed at the access control point did not have emergency duties within the EPZ. " The Federal evaluation position is that the ODOT crew did have emergency duties within the EPZ and should have been issued proper dosimetry equipment. Secondly, the County stated in its response that

"...recent discussion with ODSA (Ohio Disaster Services Agency) have indicated that equipment care, usage, distribution and personnel training for 000T personnel is the responsibility of ODSA and will be addressed as such." If this is the case, this would become a Category B deficiency for Ohio, and the State would have to submit a corrective action for the deficiency. Lastly, Ohio has been requested to provide a revised schedule of corrective actions for Ashtabula, Geauga and Lake Counties which specifies the expected completion date for correcting each of the deficiencies.

FEMA Region V has provided this information to the State and requested a revised schedule of corrective actions. As soon as we receive and analyze the response, we will send you the results.

If you have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 646-2861.

Attachments As Stated x

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0505030221 850501 PDR

, 9M ADOCK 05000440

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. MAR 181985. '

. STATE OF OHIO ADJUTANT GENERAL'S DEPARTMENT

) 2825 WEST GRANVRIE ROAD WORTHINGTON,OH10 43005 2712 DISASTER SERVICES AGENCY AGOH-DS March 4,1985 Mr. Wallace Weaver Federal Emergency Management Agency Region V 300 South Wacker Drive

• Chicago, IL 60606

Dear Mr. Weaver:

This correspondence is in reply to your final report of t'he Perry Nuclear Power Plant exercise conducted on November 28, 1984. Included is a brief description of the deficiencies found, the manner in which the deficiencies will be corrected, and the scheduled date for corrective action by the following participants: the State of Ohio, Ashtabula, Geauga and Lake Counties.

If any additional details are needed for your evaluation, please contact Kenneth Cole of my staff at (614) 889-7157.

FOR THE DIRECTOR

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L i RICHARD M. LOCKHART A

Deputy Director LAC:kjs

Attachment:

as stated e

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i, UTILITY: Perry Nuclear Power Plant ,

l* Ohio Summary Listing of Deficiencies and Corrective Actions March s,1985_4 l (State) ,. ,

Ohb - l (Community) , , ,

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8 NUREG Narrative Statenant Corrective Action Scheduled ,

i Item of Deficiency ,

Proposed a Date _ .

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• I 4

A.4 Around the clock staffing capability at the EOF was not demonstrated as outlined in it was never the Intent of the State to have May $1,1985 ('

l more than one functioning representative the State of Ohio Plan, at the EOF. Both the ODOH and ODSA representatives are fully trained to inde-

pendently handle any duty as liaison.

Each serves 2 shifts on and 1 shift off *

(16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> off) so that there j is 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage and periods of (

increased activity can have double staffing *

(8 tuurs per day can be doub'e staffed).

The text on page Il-C-2 and 11-C-10 *

(ll-C-2-b-3 and ll-C-3-c-1-b) address this criteria. The text on page Il-I-5 (ll-1-3-a-5) will be clarified in the i*

next plan revision. 5 E.7 Infornetion contained in the EBS messages All messages released through the EBS will be May 31,1985 was not released at the JPIC. provided to the JPIC for distributMa to the '

j media.

l F.1.b. The five-way telephone link proved unreliable The five-way dedicated the was installed in April 9,1985

] during the ucercise. segments during t'ae wouks and days prior to i the exercise, and was tested it!!!y only a fes / -

times, its failure during the exercise Insved . /

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8 two connectors and remedial action was prompt. .' f ,

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• UTILITY: Perry Nuclear Power Plant Summary Listing of Deficiencies and Corrective Actions (cont'd.) -

NUREG Narrative Statement item of Deficiency Corrective Action Proposed Scheduled

-' _ Date F.1.b.  !

(cont'd.) Since the exercise, the telephone company has spent considerable time " debugging" and testing the line. There were three separate tests of the entire system including one which involved I activating the circuits for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Additional tests were conducted to ensure that the system will maintain its same level of loudness over an extended period. The five-way dedicated system was fully

• 3 . operational at the time the telephone company completed its work in January 1985.

The parties to the line (PNPP, Ohio DSA, and Ashtabula, Ceauga and Lake County DSAs) l I

have agreed to participate in a regular monthly check to ensure the continued operability 1

! and quality of the system. A day and time each month has been establishe:1 and a

] " Periodic Test Instruction" procedure

is being written. The first such test is' scheduled for April 1985.

It is worth noting that the evaluators stated

" backup communications functioned effectively and communications were notg inhibited during the exercise."

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UTILITY: Perry _ Nuclear Power Plant

, Summary Listing of Deficiencies and Corrective Actions (cont'd.)

9 NUREG Narrative Statement Item of Deficiency Scheduled Date 1.8. The OEPA member of the fleid monitoring team The field monitoring team members will be traine was not familiar with his sampling procedures, May 31,1985 in proper sampling pmedures. Field monitoring and. sampling will be an objective of the July exercise T6r the Davis-Besse Nuclear Power 1 Station.

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( ,,r CON OF ASMABCLA Y

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. EMERGENCY MANAGEMENT AGENCY 25 West Jefferson Street Jefferson, Ohio 44047 (216)576 9090,576 9148 er Emergency Management Coordinator March 12, 1985 Mr. Ken Cole Ohio Disaster Services 2825 West Granville Road Worthington, Ohio 43085

Dear Ken,

Attached are the responses to the FEMA exercise held on November 28, 1984.

The deficiency's have all ready been corrected with the changes being made in the plan and standard op~erating procedures as required.

I would like to point out that the Ashtabula County Medical Center is properly equipped for this type of emergency. I feel that the evaluator for FEMA was not listening to the hospital spokesperson. I can assure you that the hospital does have the equipment, and the staff is well trained. I feel that this should j not have been listed as a deficiency.

If you have any questions please contact me.

Sincerely, g d v K. Michael Wheeler, Director Ashtabula County Emergency Management Agency KMW/jf cc County Commissioners Dick Hall Bill Coleman

S Deficiency: Information contained in the EBS messages was not released at g,g, the JPIC.

The information in the EBS messages was presented orally by the Lake County Public Information Officer from the stage at the JPIC. It was not presented to the news media in written form. Procedures for the Public Information Officers 41ocated at the JPIC) and the Public Information Liaison Officers (located in the county EOCs) of Ashtabula, Geauga, and Lake Counties will be changed to facilitate the distribution of each EBS message in written form to news media personnel at the JPIC.

Deficiency: The five-way telephone link proved unreliable during the exercise.

I I* b The five-way dedicated line was installed in segments during the weeks and days prior to the exercise, and was tested fully only a few times. It's failure during the exercise involved two connectors and remedial action was prompt. Since the exercise, the telephone company has spent considerable . time " debugging" and testing the line. There were three separate tests of the entire system to include one which involved activated circuits for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Additionally tests were conducted to ensure that the system will maintain its same level of loudness over an extended period. The five-way dedicated system was fully operational at the time the telephone company completed its work in January 1985.

The parties to the line (PNPP, Ohio DSA, and DSAs of Ashta-bula, Geausa, and Lake Counties) have agreed to participate in a regular monthly check to ensure the continued operability and quality of the system. A day and time each month has been es-tablished and a " Periodic Test Instruction" procedure is being written. The first such test is scheduled for April 1985 g

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. DeficirAncy: Emergincy workers in the field did not have mid and low range dosimeters and record keeping cards.

t g,g,g, The emergency plan will be changed to indicate clearly that each off-site emergency worker who is within the plume exposure pathway emergency planning zone (EPZ), has work assign-ment within the EPZ, or is a member of a decontamination monitor-ing team will be issued one CDV-730 (mid range) dosimeter, one CDV-742 Form." The (high range) dosimeter, one TLD, and a " Dosimetry Report plan will not prescribe a low range dosimeter since published guidance specifies the mid range and high range direct reading dosimeters and a TLD.

... it is recommended that all local emergency workers be equipped with two direct reading gamma dosimeters; one with a range of 0 to 20 R and one with a range of 0 to 200 R. These two dosimeters should provide for continuous coverage from 0.4 to 200 R which is well beyond any anticipated whole-body gamma exposure. They will also provide some redundancy by ,their overlappinC ramges (0.4 to 20 R and 4.0 to 200 R).

To offset the disadvantages of the direct reading dosi-meter, all emergency workers could be provided with a thermoluminescent dosimeter as well as the two direct reading dosimeters. This dosimeter would also measure whole-body gamma radiation dose for the dual purpose

• of (1) providing a redundant measurement of the accrued dose, and (2) providing a measurement of the accrued dose of less than as well as in excess of the range of the direct reading dosimetry (0.4 to 200 R)."

Guidance On Off-site Emergency Radiation Measurement, FDiA Rep 2, September 1980.

Narrative description in the Exercise Report indicates that workers should have "... record cards to record their hourly ex-posure readings." (page 48). Emergency workers are provided with a " Dosimetry Report Form" which asks for "Before" and "After" readings and a " Mission Total". This form constitutes the County's dosimeter recording procedure; apparently it was i

not seen by the exercise evaluator since the field people participating in the exercise were all carrying this form.

There is no published guidance indicating that readings from direct reading dosimeters should be recorded hourly. T3 County considers such a procedure bureaucratic and ill-advised 1_n_ that the worker can at any time sinely read the direct read-ing dosimeters and compare this reading with the "Before" read-1_ng to ascertain the current total dose. The " Dosimetry Report Form" instructions direct the emergency worker to." Read each CDV-742 each half hour."

-* Deficiency: EOC staff did not have an opportunity to actively monitor emergency worker exposure.

Pre-exercise agreement with FDiA was that traffic control points would be activated at the proper time in the scenario and personnel at such points would remain until observed by the exer-cise evaluator. Once the evaluator had concluded the evaluation the traffic control points were to be disteissed. This agreement was in consideration of the policemen's and road crew's time (and cost) in that they would have no activity (they do not actually stop or direct traffic in an exercise) except an occasional message to the EOC. In this instance the evaluator concluded his observations and questioning in short order.

In future exercises traffic control personnel will make at least one communication to the EOC indicating dosimeter readings.

Deficiency: The Saybrook Fire Station is not an adequate facility for use as f a decontamination center. -

The Saybrook Fire Station will be either (1) replaced as a decontamination station or (2) arrangements in or near the station will be made to correct the shower and drain water situation.

[., Deficiency: The hospital emergency room staff did not demonstrate all of the

\ , , - equipment necessary to handle a contaminated injured victim.

FDiA, Ohio DSA, and Ashtabula DSA made arrangements to con-duct exercise activities at the hospital out of syncronization with the overall exercise scenario. This arrangement was made in consideration of historical real' patient load in the emergency department at various times of the day. Ashtabula County DSA and the Ashtabula County Medical Center are aporeciative of effort _s to reduce the likelihood of exercise olay interracine with actual emergencies (or vice versa). Part of these arrangements included s'Imulating the arrival of the ambulance since the; ambulance play l would be demonstrated at the accident location in synchronization

( with the scenario. With the exception of the ambulance the hospi-l tal staff demonstrated proper receipt of the patient. The state-ment on page 58 of the Exercise Report "The staff, through improvisation of unavailable items of equipment ..." - appears .

to be an unwarranted declaration that the hospital is not properly equipped.

l Similarly, the Exercise Report (page 58) indicates that the

... spokesperson was unaware of the availability of a health physicist." The evaluator appears to have not heard, or did not comprehend, that professional staff who are not titled

" health physicist," but indeed have equal or greater training in the medical and radiation fields, were brought to bear on C. the exercise patient.

f Whole Body retention trays (page 58, Exercise Report) are not a I. requirement for a " local" hospital (NUREG-0654; FEMA-Rep-1, Rev. 1, item L.1.) although such equipment seems appropriate for the power plant's designated support hospital (Lake County Memorial Hospital East). Ashtabula County Medical Center staff did demonstrate cleansing of the patient with appropriate catch trays._ A water retention receptical with associated paraphernalia was present in the treatment / decontamination room but it was not demonstrated. In future exercises participants will be instructed to demonstrate fully the eouipment and supplies on hand.

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". County ofifake  !

OFFICE OF (M

DISASTER SERVICES !1GEilC'!

39 FAIRDALE STREET

. PAINESVILLE, OHIO 44077 .-

February 28,1985 L;

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l Mr. Kenneth Cole ]

Ohio Disaster Services Agency ,s 2825 West Granville Road .

Worthington, OH 43085 .5

Dear Ken:

Please find enclosed Lake County Disaster Services Agency's response to the FEMA Exercise Report of January 18, 1985, for the Perry Nuclear Power Plant Joint Exercise held on November 28, 1984. Please forward these responses to

.. FEMA, Region V or include them in your response submittal to FEMA.

Thank you for your assistance in our training and exercise arrangements.

Respectfully, LAKE COUNTY DISASTER SERVICES AGENCY Robert H. Retzler Director RHR:mb I

l Enclosure

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h. '. LAKE COUNTY, OHIO, RESPONSE TO FEMA EXERCISE EVALUATION l v'

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Defic. ency: Information contained in the EBS message was not released at (Item E.7.) the JPIC.

Response: Each EBS message released will be telecopied, in its entirety, from the Lake County EOC to the JPIC. Public Informatican Officers (in the JPIC) and Public Information Liaison Officers (located in County EOC's) will have procedures to ensure proper distribution of the EBS messages.

Deficiency: The five-way telephone link proved unreliable during the (Item F.1.b.) exercise.

Response: The five-way dedicated line failure during the exercise involved two connectors. Since the exercise, the telephone company has spent considerable time " debugging" and testing the line. Since the corrections were incorporated there have been three separate tests of the entire system of which one involved activating circuits for approximately twenty-four (24) hours.

Additionally, tests were conducted to ensure that the system will maintain the same level of volume over an extended period.

The five-way dedicated system was fully operational at the time the telephone company completed its work in January 1985.

The parties to the line (PNPP, Ohio DSA, DSA's of Ashtabula, Geauga and Lake Counties) have established an agreement to participate in a regularly scheduled monthly check to ensure the continued operability and quality of the system. A day and time each month has been established and a " Periodic Test Instruction" procedure is being written. The first such test is scheduled for April 1985.

Deficiency: Lake County was using a perimeter control map different from (Item 3.10.J.) that shown in its 10-08-84 version of the plan.

Response: The perimeter control point map in the plan will be updated to show the current perimeter control points. This map will cooincide with the EOC perimeter control point map used in conjunction with exercises or an actual situation.

All three counties (Ashtabula, Lake and Geauga) will coordinate their perimeter control points and maintain their EOC maps with information supplied by the other involved counties.

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Response to FEMA Exercise Evaluation Page Two l

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Deficiency: The Reception Center Manager did not have sufficient working (Item J.12.) knowledge of the facility's plan for operation.

Response: Additiona! training will be conducted to ensure the Reception Center Manager and other key personnel have a working knowledge of the facility's overall plan for operation and the agencies, departments, and resources utilized to implement the facility's plan.

Deficiency: Emergency workers in the field did not have mid and low range (Item K.3.a., dosimeters and record keeping cards.

K.3.b.) .

Response: The emergency plan will be revised to indicate clearly that each off-site emergency worker who has a work assignment within the EPZ, or is a member of a decontamination monitoring team will be issued one CDV-730 (mid-range) dosimeter, one CDV-742 (high-range) dosimeter, one TLD and a

(:. . " Dosimetry Repan Form." The plan will not prescribe a low range dosimeter since published guidance specifies the mid range and high range direct reading dosimeters and a TLD.

... it is recommended that all local emergency workers be equipped with two direct reading gamma dosimeters; one with a range of 0 to 20 R and one with a range of 0 to 200 R which is well beyond any anticipated whole-body gamma exposure. They will also provide some redundancy by their overlapping ranges l

(0.4 to 20 R and 4.0 to 200 R).

l l To offset the disadvantages of the direct reading dosimeter, all emergency workers could be provided with a thermoluminescent dosimeter as well as the two direct reading dosimeters. This dosimeter would also measure whole-body gamma radiation dose for the dual purposes of (1) providing a redundant.

. measurement of the accrued doses, and (2) providing a measure-I ment of the accrued doses of less than as well as in excess of the range of the direct reading dosimetery (0.4 to 200 R)."

Guidance On Off-Site Emergency Radiation Measurement, FEMA Rep 2, September 1980.

Emergency workers are provided with a "Dosimetery Report Form" which asks for "Before" mission and "Af ter" mission readings and a " Mission Total." This form constitutes the (s' ' County's dosimeter recording procedure and all emergency l workers participating in the exercise carried this form.

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Response to FEMA Exercise Report Page Three

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Response: (Continued)

There is no published guidance indicating that readings from direct reading dosimeters should be written down on record keeping cards hourly. Under the current procedure an emergency worker can, at any time, simply read the direct reading dosimeters and compare this reading with the reading recorded before the mission began to determine the current total dose. The " Dosimetry Report Form" instructions direct the emergency worker to " Read each CDV-742 each half hour."

Therefore, the current procedure satisfies the present guidelines for emergency worker exposure control.

Deficiency: Radiological release data forms were not completely filled out.

(Item O.4.j.)

Response: Procedures and forms for recording information transmitted by

,. telephone will be reviewed and changed, if necessary. Any

(,:',, - changes made will be inserted into training programs for personnel using the procedures and forms for recording information transmitted by telephone.

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A ""o~e <2's> 285 2222. ex' soa DIR ECTOR . February 26, 1985 - DEPUTY DIRECTOR DALE B. WEDGE RONNIE N. EGING Ken Cole Ohio Disaster Services Agency 2825 W. Granville Road Worthington, Ohio 43085

Dear Ken:

Attached are my responses to the FEMA Exercise Report (1/18/85) of the evaluated exercise held on 28 November 1984. You may relay these responses directly to FEMA or consolidate their response with yours and the County responses.

Thank you for your assistance in our training and exercise arrangements.

Sincerely yours,

. l I Dale B. Wedge Director DBW/pl Attachment

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.- SECTION DEFICIENCIES

1. EOC (E.1.)

The notification of " Unusual Event" received via commercial telephone was not verified.

Corrective Response ,

Procedure for the Sheriff's Department and EOC Dispatcher, where appropriate, will be revised to more clearly address notification / verification procedures by means other than the five-way dedicated telephone line. Training will also emphasize the actions needed during such occurances as system failure.

2. Media Relations (E.7.)

Information contained in the EBS message was not released at the JPIC, e.g.,

presentation of protective action recommendations in terms of familiar land-marks or boundaries.

Corrective Response -

The information in the EBS messages was presented orally by the Lake County Public Information Officer from the stage at the JPIC. It was not presented to the news media in written form. Procedures for the Public Information Officers (located at the JPIC) and the Public Information Liaison Officers (located in the county EOCs) of Ashtabula, Geauga, and Lake Counties will

, be changed to facilitate the distribution of each EBS message in written form 7.' to news media personnel at the JPIC.

3. EOC (F.1.b.)

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The five-way telephone link proved unreliable during the exercise.

Corrective Response The five-way dedicated line was installed in segments during the weeks and days prior to the exercise, and was tested fully only a few times. It's fail-ure during the exercise involved two connectors and remedial action was prompt.

Since the exercise, the telephone company has spent considerable time " debug-ging" and testing the line. There were three separate tests of the entire system to include one which involved activated circuits for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Additionally tests were conducted to ensure that the system will maintain its same level of loudness over an extended period. The five-way dedicated system was fully operational at the time the telephone company completed its work in January 1985.

The parties to the line (PNPP, Ohio DSA, and DSAs of Ashtabula, Geauga and Lake Counties) have agreed to participate in a regular monthly check to ensure the continued operability and quality of the system. A day and~ time each month has been established and a " Periodic Test Instruction" procedure is

- being written. The first such test is scheduled for April, 1985.

h

, 4. Radiological Exposure Control (K.3.a.) '

Em'ergency workers in the field did not have mid and low range dosimeters and record keeping cards.

Corrective Response The emergency plan will be changed to indicate clearly that each 6ff-site emergency worker who is within the plume exposure pathway emergency planning zone (EPZ), has work assignment within the EPZ, or is a member of a decontami-nation monitoring team will be issued one CDV-730 (mid range) dosimeter, one CDV-742 (high range) dosimeter, one TLD, and a " Dosimetry Repcrt Form." The plan will not prescribe a low range dosimeter since published guidance speci-fies the mid range and high range direct reading dosimeters and a TLD.

A narrative description in the Exercise Report indicates that workers should have "... record cards to record their hourly exposure readings." (page 48).

Emergency workers are provided with a " Dosimetry Report Form" which asks for "Before" and "After" readings and a " Mission Total". This form constitutes the County's dosimeter recording procedures apparently it was not seen by the exercise evaluator since the field people participating in the exercise were all carrying this form. There is no published guida'nce indicating that readings from direct reading dosimeters should be recorded hourly. The County considers such a procedure bureaucratic and ill-advised in that the worker can at any time simply read the direct reading dosimeters and compare this reading with the "Before" readina to ascertain the current total dose. The

" Dosimetry Report Form" instructions direct the emergency worker to " Read each CDV-742 each half hour."

(k. Guidance On Off-site Emergedney Radiation Measurement, FEMA Rep 2, September 1980.

5. Worker Exposure Control (K.3.a., K.3.b.)

The ODOT crew assigned to the access control point did not have the proper dosimetry equipment, did not know how to obtain it and would not know how to use it. There was no exposure control for their emergency workers.

Corrective Response The ODOT crew that was stationed at the access control point did not have emergency duties within the EPZ. During the preparation for exercise par-ticipation it was felt that it was better to not try and "second guess" or

" overplay" the evaluator. However, recent discussion with ODSA have indicat-ed that equipment care, usage, distribution and personnel training for ODOT personnel is the responsibility of ODSA and will be addressed as such.

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