ML20126J523

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Requests That Coordinated Planning Effort Continue W/State & Local Emergency Planning Authorities to Assure Offsite Emergency Preparedness Deficiencies Expeditiously Corrected
ML20126J523
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 06/04/1985
From: Ronald Bellamy
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8506100624
Download: ML20126J523 (2)


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JUM 1 4 1985 Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTN: Mr. S. L. Daltroff Vice President Electric Production 2301 Market Street Philadelphia, PA 19101 Gentlemen:

The Peach Bottom full-participation Offsite Radiological Emergency Preparedness Exercise conducted on October 17, 1984, was evaluated by the Federal Emergency Management Agency.

Two Category A deficiencies, concerning Drumore and Little. Britain Township, Lancaster County, and Fawn Grove Borough / Fawn Township Joint Emergency Operations Center, York County, have been addressed at a remedial exercise Ap(ril 10, 1985.

The corrective actions for the Category B deficiencies State of Maryland and Commonwealth of Pennsylvania) have been scheduled in accordance with the enclosed FEMA evaluation.

We request that you continue to coordinate your planning efforts with the States and local emergency planning authorities to ~ assure offsite emergency preparedness deficiencies are expeditiously corrected.

If you have any questions concerning this matter, please contact Mr. T.

Harpsterat(215)337-5208.

Sincerely, Original Signed BY:

Ronald R. Bellamy, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards cc w/ enc 1:

R. S. Fleischmann, Station Superintendent John S. Kemper Vice President, Engineering and Research A. J. Pietrofitta, General Manager, Power Production Engineering, Atlantic Electric Troy B. Conner, Jr., Esquire Eugene J. Bradley, Esquire, Assistant General Counsel Raymond L. Hovis, Esquire Thomas Magette, Power Plant Siting, Nuclear Evaluations PublicDocumentRoom(PDR)

Local Public Document Room (LPDR) hN@l lNSoo0277.

OFFICIAL RECORD COPY

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i Nuclear Safety Information Center (NSIC)

NRC Resident-Inspector Comonwealth of Pennsylvania

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RegionI. Docket. Room (withconcurrences)

- DRP Section Chief I

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0FFICIAL RECORD COPY l

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t g Federal Emergency Management Agency Washington, D.C. 20472 MM' I

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MEMORANDUM FOR:

Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.

Nuclear egulatory Commission FROM:

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. Kri Assistant Associate Director Natural and Technological Hazards Programs

SUBJECT:

Schedule of Corrective Actions for the Peach Bottom Offsite Radiological Emergency Preparedness Exercise Attached is a copy of the schedule of corrective actions for Category B p.

deficiencies cited at the Peach Bottom full-participation Offsite Radiological Emergency Preparedness Exercise conducted on October 17, 1984.

The corrective actions have been submitted by the State of Maryland and the Commonwealth of Pennsylvania.

The two Category A deficiencies in Pennsylvania, one affecting Drumore and Little Britain Township, Lancaster County; and one affecting the Fawn Grove Borough / Fawn Township Joint Emergency Operations Center, York County, have been addressed at a remedial exercise on April 10, 1985.

As soon as the remedial exercise and the results have been reviewed and analyzed, this information will be forwarded to.you along with a supplemental statement on the adequacy of offsite preparedness.

If you have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 646-2860.

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Npo Federal Emergency Management Agency 4

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.. Region 111.105 South 7th Street Philadelphia, Pennsylvania 19106

Dear Mr. Patten:

This letter is in response to your February 20, 1985 letter transmitting PEMA's response to the October 17, 1984 Peach Bottom exercise report.

Following are our comments on the corrective actions proposed.

Category "A" Deficiencies The, assertion that Lancaster County was never informed that lack of federal observation would result in Category "A" deficiencies is irrelevant.

Federal observation is an inherent element of REP exercises conducted under CFR 350.9.

(Note: The preceding is stated in awareness of that element of

)

PEMA's position paper transmitted.under your January 29, 1985 letter requesting FEMA concurrence on PEMA evaluation of municipalities. Without reference to FEMA's eventual respcnse to that position paper, FEMA is now, and was on October 17, 1984, responsible for evaluation of municipalities participating in exercises.) Therefore, FEMA is unable to accept PEMA's

-assurance that citizens of the municipalities will be protected in the event of a radiological emergency at Peach Bottom. We await information from PEMA on the date and scenario of a remedial exercise.

We a1so await a date and scenario for a Fawn Grove Borough / Fawn Grove

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Township Joint EOC remedial exercise. -The term " tabletop" is used in reference to this exercise. Rather than taking a position on the appropriateness of this term for the York or Lancaster municipalities, we will evaluate scenarios, when submitted, to ascertain whether the Category "B" deficiencies assigned to Fawn Grove Borough / Fawn Grove Township will be addressed and whether the main elements of the Drumore and Little Britain Township plans will be exercised.

Category "B" Deficiencies PEMA's response to deficiency #1 st,ates that no reports of not receiving information within the EOC were received. We direct attention to the third paragraph of page 6 of the exercise report (a typographical error made two sentences out of what should have been one). The PIO office's missing of the declaration of General Emergency appeared to be due, at least in part, to problems with the public address system.

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We find the responses to deficiencies #4 and #5 disappointing. Chester County participated in this exercise in order to allow West Nottingham Township to participate. Accordingly, FEMA would not be in a position to insist on corrective actions for any County deficiencies that might have been observed.

In the interest of preparedness, however, we would assume that the State and the County would be most interested in correcting the problems noted. The information given under " Corrective Action" for these deficiencies gives the' impression that the goal is to satisfy exercise requirements rather than to assurc emergency preparedness.

We assume that the addition of staff members referred to in the response to deficiencies #10, #14, #26, #35 and #36 will be reflected in the respective municipal plans submitted for 350 approval. Similarly, responses to deficiencies #19, #21, #22, #23, #24, #25, #28, #29, #30, #32 and #33 should be reflected in revised plans.

A copy of this letter will be forwarded to FEMA Headquarters along with the corrective actions of Maryland and Pennsylvania.

In the meantime we will await scheduling and scenarios for the necessary remedial, exercises.

S cerely, n,

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e hh(PaulP.Gioru.uv Regional Director I

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y PENNSYLVANIA EMERGENCY MANAGEMENT AGsNCY P.O. BOX 3321 HARRISBURG, PENNSYLVANIA 17105 3321 February 20, 1985 Mr. Paul P. Giordano Director Federal Emergency Management Agency Region III Curtis Building, 7th Floor 6th & Walnut Streets Philadelphia, Pennsylvania 19106

Dear Mr. Giordano:

The response of the Pennsylvania Emergency Management Agency (PEMA) to the evaluation report of the Peach Bottom Atomic Power Station on October 17, 1984 is attached.

k Where remedial exercises are necessary, our plan is to complete all exercises not later than April 1, 1985.

Please contact me if you have any questions concerning our response.

Sincerely, ohn L. Patten Director JLP:tjl (Tel:

717-783-8150)

Attachment 6

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SUMMARY

OF DEFICIENCIES CATECORY A.

The following deficiencies indicate that offsite emergency preparedness was not adequate to provide reasonable assurance that appropriate protective meneuren enn he raken er nrntect the henith and safety o f t he nuh14e_

REFERENCE PROJ'D ACT'L DEFICIENCY / RECOMMENDATION NUREG-0654 CORRECTIVE ACTION DATE DATE PART II Drumore Township & Little Britain Townships (Lancaster) 1.

Because no federal observation was permitted. FEMA J.9 1.ancaster County was never informed, of ficially or otherwise.

Prior to in unable to find that emergency preparedness was that lack of federal observer would result in Category "A" April 1 adequate to provide reasonable assurance that deficiencies. Drumore & Little Britain Townships fully parti-1985 appropriate protective measures can be taken to pro-cipated in the exercise and performed as well. If not better thso tect the health and safety of residents in the event the other 5 municipalities within the 10-mile EFZ. It is of a radiological emergency at Fesch Bottom Atomic strongly recommended that FEMA accept the observations made by Power Station.

PEMA as reasonable assurance that the citizens of the munici-palities will be protected in the event of a radiological emer-gency at Peach Bottom. Rest assured, all municipalities will consent to federal evaluation in future drills.

Fawn Crowe Borough / Fawn Township Joint EOC (York County)

J.9 Additional personnel, training and a change in EOC loc.ation will Prior to improve the overall level of emergency preparedness for this April I.

2.

Fawn Crove Borough / Fawn Crowe Township did not municipality. Additional training sessions will be held with 1985 demonstrate an overall level of emergency preparedness the EOC staff and a tabletop esercise will test and evaluate s

aufficient to provide reasonable assurance that their capability to provide reasonable assurance that appropriate appropriate protective measures can be taken to protect protective measures can be taken to protect the lmalth and the health and safety of Borough and Township residente safety of Borough and Township residents.

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SitiMARY OF DEFICIENCIES i

CATEGORY B.

The following deficiencies, while not indicative of preparedness insufficient to provide the assurance specified in Category A. above, require corrective action. Also included are recommendations where performance was adeauate. but correctable wa=1rna==a= vara noted-REFERENCE PROJ'D ACT'L DEFICIENCY / RECOMMENDATION NUREG-0654 CORRECTIVE ACTION DATE DATE PART II j

Fennsylvania i

1.

Internal commmunications in BOC suffered because of H.3.

Public address mytes announcements are habitually fo11 cued by October October technical problems with the public address sytem, a coordination visit to concerned response team personnel to 1984 1984 ensure receipt of the announcement. No reports of not receiving information were received. PA system is in use daily; vocal testing will be conducted weekly.

3.

PIMA accepted Jose rates from BRP in unintelligthle E.5.

Verification and clarification of messages from BRF will be May 1 I

form (without units and with incorrect exponential C.4.b.

executed in a timely manner. BRP also indicates that more care 1985 format) and relayed them to the counties in such will be taken during future exercises when giving dose rates j

form. The FEMA Operations Chief took note of this to PEMA.

j mistake and attempted to acquire intelligible in-formation from BRF but not until after the misinfor-J nation had been relayed to the counties.

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3.

Periodic updates of plant conditions and meterology H.12.

Personnel will be more aggressive in acquiring gdates of plant May 1 were not made available to BRP on a regular basis, nor conditions and meterology during future esercises.

1985 was BEF sufficiently aggressive in acquiring this information for relay to PEMA.

Chester

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The designated EBS station could not be received at E.5.

Chester County was granted permission to participate in this Full Parti-the County EOC nor is the station operational 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> exercise on a limited basis. Chester County was tested and ripation per day.

evaluated as full participants during the Limerick Exercise, will be 4

July 25. 1984.

demonstra-ted during Peach Botton Ex-ercise.

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October I6, 1986 i

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1 StNMARY OF DEFICIENCIES

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CATECORY B.

The following deficiencies, while not indicative of preparedness insufficient to provide the assurance specified in Category A. above, require corrective action. Also included are recossendations where performance was ' adeauate. but correcrable womarn.... vor. noted.

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REFERENCE PROJ'D.

ACT ' t.

DEFICIENCY / REC 0tMENDATION Nt! REG-0654 CORRECTIVE ACTION DATE DATE PART II-1 5.

No permanent record devices (film badges or T1.D's) are K.3.a.

Same as number 4.

In entstence for emergency workers in Chester County.

Attempts should be made to procure this equipment.

6.

Although the reception and mass care center staf f J.10.h.

Same as number 4.

gave every indication of being prepared to perform i

their emergency functions. they did not so fully j

den.nat e at e.

At tis next exercise a fuller demon-j stration of plan taptementation should be conducted.

We*t Slottinahme Township 1

7.

Some of the phone numbers on the Township's call lists F.I.e.

. Call lists shall be periodically updated to insure that personnel October October were not correct. These lists should be regularly and phone numbers are correct.

1984 1984 checked for accuracy.

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1ancaster County l

8.

Monitoring and decontamination equipment should be K.5.

Plastic " baggies" are on-hand and will be utilised to cover the October October i

protected with a plastic cover where appropriate to decontamination equipment.

1984 1984 1

prevent possible contamination.

9.

A systee/ plan should be developed for disposal of K.5.

Following EPA guidelines, low level contaminated water from October October contaminated water and clothing.

decontamination points will be allowed into sewage systems 1984 1984 and/or teach into the ground. Clothing will be collected in plastic bags and laundered, again allowing low level contami-i nated water to flow freely into sewage systems.

i F.wt Drimere Township l

19. The Township does not have the capability for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> A.I.e.

Additional staff members have been recruited and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> February February operations. Staffing for the exercise was incomplete; operation is now feasible.

1985 1985 i

participants played dual roles.

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StMMARY OF DEFICIENCIES CATEGORY B.

The following deficiencies, while not indicative of preparedness insufficient to provide the assurance specified in Category A. above, require corrective action. Also included are reccammendations where performance was adeauate. but correctable wankn===== w r. noted.

REFERENCE PROJ'D

'ACT'L DEFICIENCY /REColelENDATION NUREG-0654 CORRECTIVE ACTION

'DATE DATE PART II

11. Staff did not demonstrate complete familiarity with A. I.e.

The plan had recently been revised and additional training is in February February many aspects of the plan.' Additional training is O.

process to ensuce familiarity with the plan.

1985 1985 4

3 necessary.

12. The Township did not request resources from the A.4.

Training will correct this deficiency. The Township had pre-February February County EMC for unset needs. The Township EMC stated viously advised of unset needs. Assuming the county was aware.

1985 1985 j

that the County was aware of what the Township's did not identif y again during the esereise. This deficiency will j

reveurce shortages were. Ilanet needs ohnuld be be corrected by more aggressive pursuit of ummet needs during explic it ly made krw>wei to time L.ounty at tlue appru.

future exercises.

j priate time.

Fulton Township i

13. The Township did not esercise staf fing requirements A.I.e.

The emergency management staf f of Fulton Township will undergo September September i

as per its plan. An official not so designated extensive training in an attempt to attain an acceptable 1985 1985 acted as EMC. The designated EMC made no attempt level of readiness. The county will work closely with the l

to prepare the Operations Room for readiness and was Township EMC and elected officials to ensure a satisfactory not available to serve as a key staff member. The level of performance in the. immediate future.

Deputy EMC went to another facility and performed

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the sole function of route alerting.

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14. No 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> meaning capability was demonstrated.

A.I.e.

Same as number 13.

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15. The Township never requested unset needs, especially A.I.e.

Same as n eber 13.

l the need for a RACES radio and operation, from the County.

16.

Additional training and familiarity with the Township 0.

Same as number 13.

plan to include responsibilities and communications j

systems available and use of those systems is needed for the EOC staff.

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SLMMARY OF DEFICIENCIES CATEGORY B.

The following deficiencies, while not indicative of preparedness insufficient to provide the assurance specified in Category A above, require corrective action. Also included.

are recoaumendations where oerformance was adeaumre. but correcrable u. h==

... w.r. notei REFERENCE PROJ'D ACT'L DEFICIENCY / REC 009tENDATION NUREG-0654 CORRECTIVE ACTION DATE DATE PAKf 11 Providence Town =hly

17. The RACES operator could not bandle all messages F.1.b.

Additional training for the entire BDC staff will result in September to the EOC. Procedures and esguipment should be better utilization of not only RACgS. but all forme of 1985 reviewed and modified as needed, commmunication.

18.

The Radiological Of ficer was not knowledgeable about K.

Training is now programmed on a continual basis to keep September responsthilities and did not arrive at the BOC radiological monitoring personnel and teams at peak prnficiency.

1985 l-until 1900 when the evacuation was already underway.

Ile should receive additional training.

e York county

19. The design of the decontamination center at Airville K.5.

New centers have been established nutside the gPZ for emergency February February should be reevalusted and revised as necessary to workers. The new centers have showers and can hr,use ambulances.

1985 1985 prevent possible contamination of center and 30C staff.

20.

Supplemental training should be provided to monitors 0.4.c.

Training has been scheduled to begin early in March,1985.

March.

to ensure full asiderstanding of contamination 1985 prevention procedures.

Delta Boroush/ Delta Township Joint EOC

21. Clarification is needed with regard to the timing E.5. 6.

The municipalities' RERP are being assaded and items such as September of the dispatching of route alert teams. Also it EOC relocation outside the EpZ. route alerting, and instructions 1985 is reconnended that a standard message content for to farmers are being incorporated. The county plan details how use by the route alert teams he developed and in-and when KI will be distributed to the local EDCs. Training corporated into'the plans.

sessions have begun.

32. Procedures for the provision of protective action J.9.

Same as number 21.

September 1985 instructions to farmers. should be reviewed. In coordination with the Tork County RgRP and the municipal plans revised as appropriate.

W4EEWEMEPREIE

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SUMMARY

OF DEFICIENCIES CATEGORY B.

The following deficiencies, while not indicative of preparedness insufficient to provide the assurance specified in Category A. above, require corrective action. Also included are recommendations where performance was adeauate. but correctable wankna==a= uara noted-REFERENCE PROJ'D ACT'L DEFICIENCY / RECOMMENDATION NUREC-0654 CORRECTIVE ACTION DATE DATE t

PART II

23. The EMC should confer with the County in order to H.3.

Same as number 21.

September establish an appropriate location outside of the 10 A.I.e.

1985 mile EPZ for the relocation of evacuated EOC personnel.

24.

Clarification and training is needed with regard to A.2.a.

Same as number 21.

September the procedures for obtaining K1 in the two 1985 municipalities.

Fawn Crove Borough / Fawn Grove Town hip 25.

Future exercises should demonstrate staffing of the A.2.a.

Arrangements have been made to change the EOC from its present Prior to EOC to include active involvement by elected officials location to the fire hall and move the decontamination station April I.

during critical periods of activity and greater f rom the fire hall to a location in Stewartstown, which is out-1985 control and direction of emergency response activities side the EPZ. EOC staffing problems have been addressed and demonstrated by the EMC.

more personnel have been acquired. Additional training is being

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done and a table top exercise is scheduled prior to April 1 1985. In conjunction with the moving of the EOC the internal layout will be configured to facilitate an improvement in communications. Arrangements are being finalized to provide an alternate EOC if evacuation is required. (Located outside the EPZ.)

26. Twenty-four hour staffing of all EOC poultions should A.I.e.

Some as number 25.

Prior to be established, and the RERP updated accordingly.

A.2.a.

April I.

1985

27. Additional training shauld be provided to response 11. 3.

Same as number 25.

Prior to personnel with regard to the provisions of the RERP.

A.I.e.

April 1 especially concerning evacuation and relocation 1985 of EOC activities and use of Kl.

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e SLEMARY OF DEFICIENCIES CATECORY B.

The following deficiencies, while not indicative of preparedness insufficient to provide the assurance specified in Category A. above, require corrective action. Also included are recommendations where perforrnance was adeauate. but correcrable uenknnnnen voro noted.

REFERENCE PROJ'D ACT'L DEFICIENCY / RECOMMENDATION NUREC-0654 CORRECTIVE ACTION DATE DATE PART 11 28.

Tho communications mystems used at the EOC should be F.I.a.

Same as number 25.

Prior to critically reviewed and reorganized. The revised April 1, system should enable timely notification to the EMC 1985 and EOC utaf f regarding changes in plant status and protective action recommendations. Specifically, RATES no-twork operations, and training with regard to the recently provided scanner should be provided.

29. The Borough and Township's rien for the utilization of E.5.

Same as number 25.

Prior to route alerting is unclear; route alerting was conducteil E. 6.

  • April I, at inappsopriate times. Clarification is needed with 1985.

regard to the timing of the dispatching of route alerting teams. Initiating route alerting with the sounding of Maryland's strens is not indicated in the RERP, and could cause coordination dif ficulties with Pennsylvania EBS announcements. Responsbility for completing route alerting in Maryland (as alluded to by the Fire personnel) should be clarified and in-corporated in the RERP, if appropriate.

30.

Route alerting took an excessive amount of time. Route E.5.

Same au number 25.

Prior to alert sectora should be reviewed and restructured as E.6.

April 1 necessary in order to provide for a more timely 1985 completion of toutes.

31. Lists of mobility-impaired individials should be J.10.d.

Same au number 25.

Prior to developed and maintained at the EOC.

Apell 1, 1985

32. The RERP should be revised to reference all mutual A.3.

Same as number 25.

Prior to support agreements.

April 1, 1985 m.....

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SUMMARY

OF DEFICIENCIES CATEGORY B.

The following deficiencies, while not indicative of preparedness insufficient to.

provide the assurance specified in Category A, above, require corrective action. Also included are recommendations where performance was adeauate. but correctable wankn===== ver, noted.

REFERENCE PROJ'D

'ACT'L DEFICIENCY /RECOtttENDATION NUREG-0654 CORRECTIVE ACTION DATE

DATE, PART II
33. The Borough / Township EMC should confer with the County H.3.

Same as number 25.

Prior to in order to establish an appropriate location outside A.I.e.

April I.

- of the 10 mile EFZ for the monitoring and decontami-1985 nation of Delta Borough evacuated emergency workers.

34.

The EMC should investigate the cause for the F.I.d.

Same as nassber 25.

Prior to apparent lack of notification to administer KI, and F.I.e.

April 1 ensure the completion of corrective actions am 1985 necessary.

I Lwer Chanceford Township 35.

Future exercise should demonstrate full staffing A.2.a.

The RERP in being written to reflect additional staffing. The September of the EOC.

EOC staff has been advised of participation requirements.

1985 36.

Twenty-four hour staffing should be established and A.I.e.

Twenty-four hour staffing is being included in the RERP.

September incorporated into the semicipal RERF.

1985

37. Future exercises should exhibit the simulation of H.3.

A new EOC location has been identified outside the EFZ if October j

demonstration of activities associated with the A.I.e.

evacuation is required.

1986 l

relocation of 50C operatione.

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,,etacv mataarmtat PintsvsLLE ed AnVLAND 21200 Aus Csvek DEFlest ASthCT AntA CODE 301 486 4422 February 15, 1985 Mr. Paul P. Giordano Regional Director Federal Emergency Management Agency Region III 105 South 7th Street Philadelphia, Pennsylvania 19106

~ ATTENTION:

Mr. James Asher

Dear Mr. Giordano:

This correspondence represents the State of Maryland's re-sponse to the Federal Emergency Management Agency / Regional Assis-tance Committee evaluation report for the radiological emergency response exercise held in conjunction with the. Peach-Bottom Atomic Power Station on October 17, 1984.

Included in this response is a schedule of proposed corrective actions for the deficiencies / rec-ommendations cited.

Please note that the response has been sum-marized to address several deficiencies and recommendations simul-taneously due to the similarity _of corrective measures.

Our re-sponse is summed in four (4) categories and is keyed to summary of Category "B" deficiencies and recoramendations in original report.

EQUIPMENT (recommendations 14 and 15)

The State of Maryland is requesting that Philadelphia Elec-tric Company'(PECo) install a dedicated radio system to serve as a backup to the direct phone lines between Peach Bottom Atomic Power Station and the Maryland State EOC.

We have also requested of PECo and the Baltimore Gas and Electric Company (BGliE), several telecopiers to establish a reliable system for hard copy transmis-sion of news releases.

The projected date for receipt of the telecopiers is June 1, 1985.

In that installation of a backup radio connunications sys-tem requires extensive evaluation and design, completion can be projected no sooner than October, 1986 provided the utility finds this a feasible request.

i TTY FOR DEAF - 484 4083 4--~.

.- PLAN?/ PROCEDURES *(daficiGncy 48 End rscomm2ndationo 13 and 16)

A new map is being developed which will assist Harford County in identifying geographical areas affected during implementation Also, the State of Maryland is actively of protective actions.

pursuing a standard format for notifications between neighboring states and the-utilities.

Consideration will be given to plan and procedure revision to prompt notification of Pennsylvania prior to siren activation in Maryland.

Projected dates for plan and procedures revisions are no later than October, 1985.

The map should be completed by May 1, 1985.

TRAINING (deficiencies 42,44,45,47, and 48 and recommendation 20)

Tasks' cited in the referenced deficiencies and recommenda-tions will be given emphasis during annual. training.

Cecil County and the State of Maryland do not believe the confusion or incon-sistencies cited in deficiencies 44 and 47 exists in the County i

plan.

Rather, we believe the tasked authorities need some adjust-ment to the new plan.

Training is projected to occur throughout 1985 to address all noted deficiencies.

EXERCISE PARTICIPATION / CONDUCT (deficiencies 38,40,41,42, and 46 and recommendations 17,18, and 19)

The referenced deficiencies and recommendations under this heading are the result of player deviation from participation guidance outlined in the State of Maryland exercise directive.

This directive is distributed prior to each REP exercise.

In the future, the directive will emphasize full participation, to the extent possible, during full scale exercises.

Deficiency #42 has been addressed in this category, as it was determined to be a controller induced problem.

Exercise control instructions, within the exercise directive, will emphasize coor-dination of control messages.

The next full scale Exercise with Peach Bottom Atomic Power Station is scheduled for October 16, 1986, thus the projected date for correction of these deficiencies / recommendations coincides with the exercise date.

Finally, we must challenge the accuracy and validity of de-ficiencies 39,41,43, and 49).

Deficiency $39 indicates a misun-derstanding of.the Maryland plan for public information.

Accord-ing to Section 3.1.6.2 of the Maryland REP, the county public in-formation officers (PIO) will report on the radiological emergency 2

. cituntion and county oparationo (i.e. Gvacuation inotructiono).

Th3 Stato PIO will.raport on coordination of rogourcss and stato efforts in support of county operations.

Deficiency 941 is a surprise to Cecil County, as the area's primary EBS station, WAMD, reported that every EBS station partici-pated.

None-the-less, this deficiency has been addressed under Ex-l ercise Participation / Conduct.

Deficiency #43 contradicts what is stated in deficiency $45, as access control is the responsibility of the State Police and the State Police simulated taking KI prior to authorization.

Proper use of KI is addressed in annual training.

Deficiency #49 might be acceptable as a recommendation, but considering the total number of mobility-impaired people that Harford County has identified, it is excessive to plan to that degree (i.e. particular needs).

This information would be neces-sary when dealing with hundreds of mobility-impaired people, but Harford County has approximately 35 mobility-impaired people to evacuate and more than enough ambulances and handicapped equipped buses to move them.

Although we contest this deficiency, infor-mation on particular needs is being solicited through the new pub-lic information brochures for Harford County.

Should there be any questions or comments regarding our re -

sponse or the contested deficiencies, please contact my Assistant Director for Operations, Mr. Edwin O. Tremper, at (301) 486-4422.

Sincerely, a

$[' O hyw

-EDWARD MURRAY Director EM:CLR:lw Information Addressees:

Mr. Daniel H. Mahan, Jr., Director Cecil County Emergency Management and Civil Defense Agency Dr. Charles B.

Browne, Directcr Harford County Department of Emergency Services Coordination Department of Health and Mental Hygiene Attention:

Mr. Timothy Brooks Mr. David Resh, Jr.

Ms. Beatrice Weitzel State Public Information Officer Attention:

Mr. Daniel McCarthy Pennsylvania Emergency Management Agency Attention:

Mr. John L.

Patten, Director Philadelphia Electric Company Attention:

Ms. Roberta Kankus 3

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suonRoom LANE & REISTERSTOWN ROAD as DeatCfon o u nog necv managgegue PimEsVILLE. M ARYLAND 21200 Amo Civsk SEFthat assesCT ARE A CODE 301 486 4422 February 15, 1985 Mr. Paul P. Giordano Regional Director Federal Emergency Management Agency Region III 105 South 7th Street Philadelphia, Pennsylvania 19106 ATTENTION:

Mr. James Asher

Dear Mr. Giordano:

This correspondence represents the State of Maryland's re-9-

sponse to the Federal Emergency Management Agency / Regional Assis-tance Committee evaluation report for the radiological emergency response exercise held in conjunction with the Peach Bottom Atomic Power Station on October 17, 1984.

Included in this response is a schedule of proposed corrective actions for the deficiencies / rec-ommendations cited.

Please note that the response has been sum-marized to address several deficiencies and recommendations simul-taneously due to the similarity of corrective measures.

Our re-sponse is summed in four (4) categories and is keyed to summary of Category "B" deficiencies and recommendations in original report.

EQUIPMENT (recommendations 14 and 15)

The State of Maryland is requesting that Philadelphia Elec-tric Company (PECo) install a dedicated radio system to serve as a backup to the direct phone lines between Peach Bottom Atomic Power Station and the Maryland State EOC.

We have also requested of PECo and the Baltimore Gas and Electric Company (BG&E), several telecopiers to establish a reliable system for hard copy transmis-sion of news releases.

The projected date for receipt of the telecopiers is June 1, 1985.

In that installation of a backup radio comunications sys-tem requires extensive evaluation and design, completion can be projected no sooner than October, 1986 provided the utility finds this a feasible request.

TTY FoR DEAF - 484 4083

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, PLANS / PROCEDURES (dsficiency 48 cnd recommandations 13 cnd 16)

A new map is being developed which will assist Harford County in identifying geographical areas affected during implementation of protective.actio.ns.

Also, the State of Maryland is actively pursuing a standard format for notifications between neighboring states and the utilities.

Consideration will be given to plan and procedure revision to prompt notification of Pennsylvania prior to siren activation in Maryland.

Projected dates for plan and procedures revisions are no later than October, 1985.

The map should be completed by May 1, 1985.

TRAINING (deficiencies 42,44,45,47, and 48 and recommendation 20)

Tasks cited in the referenced deficiencies and recommenda-tions will be given emphasis during annual training.

Cecil County and the State of Maryland do not believe the confusion or incon-sistencies cited in deficiencies 44 and 47 exists in the County plan.

Rather, we believe the tasked authorities need some adjust-ment to the new plan.

Training is projected to occur throughout 1985 to address all noted deficiencies.

EXERCISE PARTICIPATION / CONDUCT (deficiencies 38,40,41,42, and 46 and recommendations 17,18, and 19)

The referenced deficiencies and recommendations under this heading are the result of player deviation from participation guidance outlined in the State of Maryland exercise directive.

This directive is distributed prior to each REP exercise.

In the future, the directive will emphasize full participation, to the extent possible, during full scale exercises.

as it was Deficiency #42 has been addressed in this category, determined to be a controller induced problem.

Exercise control instructions, within the exercise directive, will emphasize coor-dination of control messages.

The next full scale Exercise with Peach Bottom Atomic Power Station is scheduled for October 16, 1986, thus the projected date for correction of these deficiencies / recommendations coincides with the exercise date.

Finally, we must challenge the accuracy and validity of de-ficiencies 39,41,43, and 49).

Deficiency #39 indicates a misun-I derstanding of the Maryland plan for public information.

Accord-ing to Section 3.1.6.2 of the Maryland REP, the county public in-formation officers (PIO) will report on the radiological emergency 2

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'cituntien end county opsrations (i.e. ovacuation instructions).

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.Th3 Stnto PIO will rcport on coordination of resourcos and state efforts in support of county operations.

Deficiency $41 is a surprise to Cecil County, as the area's primary EBS station, WAMD, reported that every EBS station partici-pated.

None-the-le s s, this deficiency has been addressed under Ex-arcise Participation / Conduct.

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Deficiency 943 contradicts what is stated in deficiency #45, as access control is the responsibility of the State Police and the State Police simulated taking KI prior to authorization.

Proper use'of KI is addressed in annual training.

Deficiency #49 might be acceptable as a recommendation, but considering the total number of mobility-impaired people that Harford County has identified, it is excessive to plan to that degree (i.e. particular needs).

This information would be neces-sary when dealing with hundreds of mobility-impaired people, but Harford County has approximately 35 mobility-impaired people to evacuate and more than enough ambulances and handicapped equipped buses to move them.

Although we contest this deficiency, infor-mation on particular needs is being solicited through the new pub-lic information brochures for Harford County.

Shou,ld there be any questions or comments regarding our re-sponse or the contested deficiencies, please contact my Assistant Director for Operations, Mr. Edwin O. Tremper, at (301) 486-4422.

Sincerely,

. W

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-EDWARD MURRAY Director EM:CLR:lw Information Addressees:

Mr. Daniel H. Mahan, Jr., Director Cecil County Emergency Management and Civil Defense Agency Dr. Charles B. Browne, Director Harford County Department of Emergency Services Coordination Department of Health and Mental Hygiene Attention:

Mr. Timothy Brooks Mr. David Resh, Jr.

Ms. Beatrice Weitzel State Public Information Officer Attention:

Mr. Daniel McCarthy Pennsylvania Emergency Management Agency Attention:

Mr. John L. Patten, Director Philadelphia Electric Company Attention:

Ms. Roberta Kankus

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