ML20126K241

Advises That Revised Responses to Schedule for State of Oh Corrective Actions of 841128 Offsite Emergency Preparedness Exercise Adequate

ML20126K241
Person / Time
Site:	Perry
Issue date:	06/12/1985
From:	Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Edelman M CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8506190201
Download: ML20126K241 (2)

Text

_ _ - _ _ _ _ _ _ . _ _ _ _ _ . . _ _ _ _ _ _ - _ _ _ _

. o

'JllN 1 '2 fM Docket No. 50-440 Docket No. 50-441 The Cleveland Electric Illuminating Company ATTN: Mr. Murray R. Edelman Vice President Nuclear Group Post Office Box 5000 Cleveland, OH 44101 Gentlemen:

We have received the enclosed Federal Emergency Management Agency (FEMA) letter dated May 23, 1985, which included the revised schedule of corrective actions submitted by the State of Ohio for the recomendations identified in Ohio and Lake, Ashtabula, and Geauga Counties as a result of the exercise held on November 28, 1984. The exercise report was sent to you on February 22, 1985, and the original State response was sent to you on May 16, 1985, from this office.

The FEMA Headquarters and Region V staff have reviewed the schedule of corrective action submitted and have detennined that the revised responses submitted were adequate.

We fully recognize that the recomendations to be implemented may involve actions by other parties and political institutions which are not under your direct control. Nonetheless, we would expect the subject of offsite preparedness for the area around the Perry Nuclear Power Plant to be addressed by you as well as others.

/

-g 5

)

i l i

f bSCO hk<d WWLGV IUO E5 OSSTOW ]

TDC. p ocx. OSCOOWO PDC r -

8506190201 850612 PDR ADOCK 05000440 F PDR

The Cleveland Electric Illuminating 2 Company 'JUN 1 2 G85 In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosure will be placed in the NRC's Public Document Room.

Sincerely, C. J. Paperiello, Chief Emergency Preparedness and Radiological Protection Branch

Enclosure:

As stated cc w/ enclosure:

J. J. Waldron, Manager, Perry Plant Technical Department M. D. Lyster, Manager, Perry Plant Operations Department L. O. Beck, General Supervising Engineer, Nuclear Licensing and Fuel Management Section~

D. Matthews, EPB, 0IE W. Weaver, FEMA Region V DM8/ Document Control Desk (RIDS)

Resident Inspector, RIII Harold W. Kohn, Ohio EPA Terry J. Lodge, Esq.

James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health l

l l

l RIII II RIII i d(, )

t

! YneT kr P lips Knop / /4( Pa erfello 06/12/85 i

h.

hkh Federal Emergency Management Agencyg,-@*

• %.~.? Washington, D.C. 20472 MAY 2 3 im MEMORANDUM FOR: Edward L. Jordan Director, and Engineering Response Division of Emergency ,

h Preparedne Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission gg y ,

FROM: .

Assistant Associate Director nd Office of Natural and Technological Hazards Programs

SUBJECT:

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

Of fsite Radiological Emergency Preparedness (REP)

Exercise Conducted on November 28, 1984 Attached is the revised schedule of corrective actions for the State of Ohio, and the Counties of Ashtabula, Geauga and Lake for the deficiencies cited in the Final Report for the Perry NPP Offsite REP Exercise conducted on November 28, 1984.

The initial schedule of corrective actions submitted by the State was sent to you on May 1, 1985. Several issues required further action by the State and Counties. The K.3.a/K.3.b deficiency (radiological exposu* e control for emergency workers) has been determined to be a deficiency for the State rather than Geauga County. This clarification and acceptance of renponsibility by the State for the deficiency is reflected in the revised schi dule of correc-tive actions. The revised schedule also includes the expected completion date for correcting each of the deficiencies.

The Federal Emergency mnagement Agency (FEMA) Headquarters and Region V staf f have reviewed the revised schedule of corrective actions submitted by the State and found it to be adequate.

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

Dtxattment As Stated

~

JUN 12 1985

.SEGeeMFT57 850523 PDR ADOCK 05000440 F PDR n

f

@ 'b VI /Y ls

ry STATE OF OHIO ADJUTANT GENERAL'S DEPARTMENT 2825 WEST GftANVELE It0AD WOWTHINGTON.OH10 43085-2712 DISASTER SERVICES AGENCY AGOH-DS April 8,1985 Mr. Wallace Weaver, Chairman Regional Assistance Committee Federal Emergency Management Agency Region V 300 South Wacker Drive Chicago, IL 60606

Dear Mr. Weaver:

Enclosed are the revised corrective actions that will be applied to the November 28, 1984 exercise deficiencies. The deficiency listed under Geauga County that concerns the Ohio Department of Transportation is in reality the responsibility of the Ohio Disaster Services Agency. Therefore, we have addressed that item under the Ohio corrective actions.

I regret not including a letter from the Ashtabula County Medical Center (ACMS), but under the current circumstances, I feel the issue of equipment availability at ACMC will be resolved during the April 9-16, 1985 hearings.

FOR THE DIRECTOR ,

- - s

. i f C ARD M. LOCKHART (Deputy Director KBC:kjs Encls: as stated i

pcN.cooi .. /

UTILITY: Perry Nuclear Power Plant Ohio Summary Listing of Deficienceis and Corrective Actions April 4,1985 (State) (Date)

Ohio (Community)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date A.4 Around the clock staffing capability at the it was never the intent of the State to May 31,1985 EOF was not demonstrated as outlined in have more than one functioning rep-the State of Ohio Plan. resentative at the EOF. Both the ODOH and ODSA representatives are fully trained to independently handle any duty as liaison. Each serves 2 shifts on and I 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 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per day can be double staffed) . The text on page ll-C-2 and ll-C-10 (ll-C-2-b-3 and ll-C-3-c-1-b) address this criteria. The text on page 11-1-5 (ll-1-3-a-5) will be clarified in the next plan revision. Concerning the quantity of work to be performed, it should be noted that the amount of activity observed is due to the accelerated nature of an exercise.

During a real event, all activities would take place over a longer period of time.

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

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date E.7 Information contained in the EBS messages All messages released through the EBS May 31,1985 was not released at the JPIC. will be provided to the JPIC for distri-bution to the media.

F.1.b. The five-way telephone link proved The five-way dedicated line was installed April 9,1985 unreliable during the exercise. in segments during the weeks and days prior to the exercise, and was tested fully only a few times. Its failure during the exercise involved two connectors and remedial action was prompt. Since the exercise, the telephone company has spent con-siderable time " debugging" and testing the line. There were three separate tests of the entire system including one which involved 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 operational at the time the telephone company completed its work in January 1985.

l I

l l

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

NUREG Narrative Statement Corrective Action Scheduled Ittm of Deficier.cy .

Proposed Date F.1.b. The parties to the line (PNPP, Ohio (con t'd . ) DSA, and Ashtabula, Geauga and Lake County DSA's) have agreed to participate in a regular monthly check to ensure i the continued operability and quality of the system. A day and time each month t

has been established and a " Periodic Test Instruction" procedure is being w ritt en. The first such test is scheduled for April 1985.

! s It is worth noting that the evaluators stated " backup communications functioned effectively and communications were not inhibited during the exercise."

1.8. The OEPA member of the field monitoring The field monitoring team members will be April 24,1985 team was not familiar with his sampling trained in proper sampling procedures.

procedures. Field monitoring and sampling will be an objective of the July exercise for the

Davis-Besse Nuclear Power Station.

K . 3.a . The ODOT crew assigned to the access The State of Ohio Disaster Services K . 3.b . control point did not have the proper Agency has a request to the Director of (Geauga dosimetry equipment, did not know how tte the Department of Transportation County) obtain it and would not know how to use it, requesting training dates for the There was no exposure control for ti eir department's personnel. That information emergency workers, will be provided under separate letter when it becomes available.

~

UTILITY

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

NUREG Narrative Statement Corrective Action Scheduled

Item of Deficiency Proposed Date K . 3.a . (NOTE

It is the responsibility of the Ohio K . 3.b. Disaster Services Agency to arrange for training (cont'd. ) of, and issuance of equipment to, the Ohio Department of Transportation. Therefor, the corrective response for this deficiency appears under the State of Ohio. )

}

I.

h

l l

ASHTABULA COUNTY RESPONSE TO FEMA EXERCISE EVALUATION Summary Listing of Deficiencies and Corrective Actions Ohio April 5,1985 (State) (Date) i Ashtabula County (Community)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date E.7 Information contained in the EBS messages The information in the EBS messages September 1985 was not released at the JPIC. was presented orally by the Lake (Procedures)

County Public Information Officer April 1986 from the stage at the JPIC. It was (Demonstration) not presented to the news media in written form. Procedures for the Public Information Officers (located at the JPIC) and the Public Information Liaison Officer located in the Ashtabula County EOC will be changed to facilitate the distribution of each EBS message in written form to news media personnel at the JPIC.

F.1.b. The five-way telephone link proved un- The five-way dedicated line was January 1985 reliable during the exercise. installed in segments during the (Operational) weeks and days prior to the exercise, April 1985 and was tested fully only a few times. (Beginning its failure during the exercise monthly tests)

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 l

ASHTABULA COUNTY RESPONSE TO FEMA EXERCISE EVALUATION Summary Listing of Deficiencies and Corrective Actions (cont'd.)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date F.1.b. hours. Additionalf tests were conducted (cont'd. ) to ensure that the system will maintain its same level of loudness over an extended period. The five-way dedicated system was fully operational j 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 j and Lake Counties) have agreed to i participate in a regular monthly check to ensure the continued operability and quality of the system. A day

, and time each month has been l established and a " Periodic Test Instruction" procedure is being i written. The first such test is scheduled for April 1985.

K . 3.a . Emergency workers in the field did not The emergency plan will be changed September 1985 have mid and low range dosimeters. to indicate clearly that each off-site emergency worker who is within the i plume exposure pathway emergency l planning zone (EPZ), has work assignment within the EPZ, or is a member of a decontamination monitoring team will be issued one J CDV-730 (mid range) dosimeter, 1 one CDV-742 (high range) dosimeter, one TLD, and a " Dosimetry Report Form." The plan will not prescribe a low range dosimeter since published guidance (FEMA REP-2, September 1980) specifies the mid range and high range dirgct reading dosimeters and a TLD.

ASHTABULA COUNTY RESPONSE TO FEMA EXERCISE EVALUATION Summary Listing of Deficiencies and Corrective Actions (cont'd.)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date K . 3.b. EOC staff did not have an opportunity to Pre-exercise agreement with FEMA April 1986 actively monitor emergency worker exposure. was that traffic control points would (Demonstration) be activated at the proper time in the scenario and personnel at such points would remain until observed by the exercise evaluator. Once the evaluator had concluded the evaluation the traffic control points were to be dismissed. This agree-ment 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.

K . 5.b. The Saybrook Fire Station is not an The Saybrook Fire Station will be September 1985 adequate facility for use as a decontamination either (1) replaced as a decontami-center. nation station or (2) arrangements in or near the station will be made to correct the shower and drain water situation.

ASHTABULA COUNTY RESPONSE TO FEMA EXERCISE EVALUATION Summary Listing of Deficiencies and Corrective Actions (cont'd.)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date L.1. The hospital emergency room staff did not The Ashtabula County Medical Center April 1985 demonstrate all of the equipraent necessary staff did demonstrate cleansing of the (Equipment) to handle a contaminated injured victim. patient with appropriate catch trays.

A water retention receptical with associated paraphernalia was present in the treatment / decontamination room but it was not demonstrated.

Additional equipment in the form of whole body trays were purchased for the Ashtabula County Medical Center on April 4,1985. In future exercises participants will be instructed to demonstrate fully the equipment and supplies on hand.

i i

i

County sf Geauga

~

- D p 13281 PAINESVILLE.R AVENN A ROAD o GE AUG A COUNTY sAF ETY CENTER cHARDON OHIO 44024 DISASTER SERVICES AGENCY e"o~c <2ie' 28s 2222. cx' so3

. I A DEPUTY DIAECTCP DIRECTOR RONNIE N EGING D ALE B. WEDGE Apri1 5, 1985 Ken Cole Ohio Disas ter Services Age n cy 2825 West Granville Road Worthington, Ohio 43085

Dear Ken:

Attached are my corrective 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 wi th yours and the County responses.

Thank you for your assistance in our training and exercise arrange-ments.

Sinqerely yours,

{

~

b Dale B. Wedge, Direct r Geauga County Disas te r Services Agency A t t a ch tne n t

UTILITY: Perry Nuclea r Powe r Plant Ohio Summary Listing of Deficiencies and Corrective Actions April 5, 1985 (State)

Ohio (Geauga County) i

! NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date E.1 The notifiction of " Unusual Event" Procedures for the Sheriff's April. 1986 (EOC) received via commercial telephone Department and EOC Dispatch- (Demonstrate) was not verified. er, where appropriate, will be revised to mo re clearly address notification /verifl-cation procedures by means other than the fi ve-way dedi-cated telephone line. T ra i n-Ing will also emphasize the actions needed during such occurences as sys tem failure.

E.7 Information contained in the EBS The information in the EBS Sept. 1985 (Media message was not released at the messages was presented orally (For review)

Relations) JPIC, e.g., p resen ta t i on. o f p ro- by the Lake County Public in-tective action recommenda t ions formation Of fi cer from the A p r i l '. 1986 j in terms of familia r l a n dma rk s stage at the JPlc. It was (Demonstration) or bounda ries. not presented to the news me-i dia in written form. Proce-dures for the Public Infor-mation Of ficer (located at the JPIC) and the Public Informa-tion Liaison Officer (located i in the Geauga County EOC) will

be changed to facilitate the I . distribution of each EBS mes-sage in written form to new media personnel at the JPlc.

UTILITY: Perry Nuclea r Powe r Plant .

~

Ohio Summary Listing of Deficiencies and Corrective Actions April 5, 1985 (State)

Ohio (Geauga County)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency _

Proposed Date F.1.b. The five-way telephone link proved The five-way dedicated line Jan. 1985 unreliable during the exercise. was installed in segments (Operational)

(EOC) during the weeks and days prior to the exercise, and Ap ri l . 1985 was fully tested only a few (tested monthly) times. It's failure during the exe rci s e involved two conn e c to rs and remedial ac-tion was prompt. Since the exercise, the telephone com-pany has spent considerable t ime " debugging" and tes ting the IInc. 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 />. Addi-tionally tests were conducted to ensure that the system will maintain its same level of loudness over an extended per-lod. The five-way dedicated

! system'was fully operational at the time the telephone com-pany completed its work in Jan-ua ry 1985

UTILITY: Perry Nuclear Power Plant Ohio Summary Listing of Deficiencies and Corrective Actions April 5, 1985 (State)

Ohio (Geauga County)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date F.1.b. The parties to the line (continued) (PNPP, Ohio DSA, and DSAs of Ashtabula, Geauga and Lake Counties) have agreed to parti cipate In a re gul a r monthly check to ensure the continued operability and quality of the system. A day and time each month has been es tablished and a "Pe r-iodic Test I n s t r.u c t i on" pro-cedure is being written. The fi rs t such test is s ch e d ul e d for April, 1985 K.3.a. Low and mid range dosimeters The emergency plan will be Sept. 1985 (Radiation were not available for emer- changed to indicate clear-Exposure gency workers in the field. ly that each off-site emer-Control) gency worker who is within the plume exposure pathway emergency planning zone (EPZ),

has work assignment within the EPZ, or is a member of a de-contamination monitoring team will be issued one CDV-730 (mid

. range) dosimeter, one CDV-742 (high ran ge ) dosimeter, one TLD, and a " Dosimetry Report Fo rm." The plan will not pre-

. scribe a low r.a n g e dosimeter

O UTILITY: Perry Nuclea r Powe r Plant Ohio Summary Listing of Deficiencies and Corrective Actions April 5, 1985 (State)

Ohio (Geauga County)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date K.3.a. since published guidance (Continued) (Guidance On Off-Site Emergency Radiation Measurement, FEMA Rep 2, September 1980.) specifies the mid range and high range direct reading dosi-meters and a TLD.

K.3.a. The ODOT crew assigned to the See State corrective actions N/A K.3.b. access control point did not (Wo rke r have the p rope r dos i me t ry Exposure equipment, did not know how Control) to obtain it and would not know how to use it. There wa_s no exposure control for their emergency workers.

Enunty of hhc 0FFICE OF DISASTER SERVICES AGENCY 39 FAIRDALE STREET PAINESVILLE, OHIO 44077 April 5,1985 Mr. Kenneth Cole Ohio Disaster Services Agency 2825 West Granville Road Worthington, O H 43085

Dear Ken:

Please find enclosed Lake County Disaster Services Agency's revised response to the FE M A Exercise Report of January 18, 1985, for the Perry Nuclear Power Plant Joint Exercise held on November 28,1984. Please forward these responses to FE M A, Region V or include the m in your response submittal to FE M A.

Thank you for your assistance in our training and exercise arrange ments.

Respectfully, LAKE COUNTY DISASTER SERVICES AGENCY I A Robert H. Retzl' r Director R H R:mb Enclosure

a 4

~

L&EE COUtrfY, ORIO, RESPONSE TO FBIA EXERCISE EVALUATION Summary Listing of Deficiencies and Corrective Actions Ohio (State)

Lake (Community)

SCHEDULED NUREG CORRECTIVE ACTION PROPOSED DATE ITEM NARRATIVE STATEMENT OF DEFICIENCY E.7. Information contained in the EBS Each EBS message released will be telecopied in its June 15, 1985 message was not released at the entirety, from the Lake County EOC to the JPIC.

JPIC. Public Information 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.

F.1.b. The five-way telephone link proved The five-way dedicated line failure during the exercise Completed unreliable during the exercise. involved two connectors. Since the exercise the tele- January 25, 1985 phone 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. April 15, 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

m lake Commty, (Baio, Besponse to FBIA Esercise Evaluation . Page Two l

BRJREG SCHEDULED ITEM NARRATIVE STATEMENT OF DEFlCIENCY CORRECTIVE ACTION PROPOSED DATE F.1.b. (continued) been established and a " Periodic Test Instruction" procedure is being written. The first such test is scheduled for April, 1995.

J.10.j. Lake County was using a perimeter The perimeter control point map in the plan will June 15, 1985 control map different from that be updated to show the current perimeter control shown in its 10-08-84 version points. This map will coincide with the EOC of the plan. perimeter control points map used in conjunction j with exercises or an actual situation.

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

i

J.12. The Reception Center Manager Additional training will be conducted to ensure the June 15, 1985 1 did not have sufficient working Reception Center Manager and other key personnel have knowledge of the facility's plan a working knowledge of the facility's overall plan j for operation. for operation and the agencies, departments, and

! resources utilized to implement the facility's plan.

K.3.a. Emergency workers in the field did The emergency plan will be revised to indicate clearly June 15, 1985 i K.3.b. not have mid and low range that each off-site emergency worker who has a work ll dosimeters and record keeping cards. assignment within the EPZ, or is a member of a decon-tamination team will be issued one CDV-730 (mid-range)

dosimeter, one CDV-742 (high-range) dosimeter, one TLD and a " Dosimetry Report Form." The plan will not prescribe a low-range dosimeter since published guidance,

! (FEMA Rep-2, September 1980), specified the mid-range

! and high-range direct reading dosimeters and a TLD.

l i

l

, l Page Thrine 2ake County, (Baio Response to FEMA Esercise Evaluation SCHEDULED NUREG DATE MARRATIVE STATEMENT OF DEFICIENCY CORRECTIVE ACTION PROPOSED ITEM K.3.a and K.3.b (continued) Emergency workers are provided with a " Dosimetry Report Form" which asks for "Before" mission and "After" mission readings and a " Mission Total." This form constitutes the County's dosimeter recording procedure and all emergency workers participating in the exercise carried this form. 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 hour, or sooner, if instructed." Therefore, the current procedure satisfies the present guidelines for emergency worker control.

Procedures and forma for recording information June 15, 1985 0.4.j. Radiological release data forms were not completely filled out. transmitted by telephone will be reviewed and changed, if necessary. Any changes made will be inserted into training programa for personnel using the procedures and forma for recording information transmitted by telephone.

)