ML20128D660

Forwards Revised Schedule of Corrective Actions for State of Oh & Counties of Ashtabula,Geauga & Lake for Deficiencies Cited in Final Rept of 841128 Offsite Radiological Emergency Exercise

ML20128D660
Person / Time
Site:	Perry
Issue date:	05/23/1985
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8505290157
Download: ML20128D660 (19)

Text

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Federal Emergency Management Agency g, at**

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'e Washington, D.C. 20472 O O MAY 2 3 Woo MEMORANDUM FOR: Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcenent U.S. Nuclear Regulatory Commission FROM: '. "-

Assistant Associate Director 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 exposure control for emergency workers) has been determined to be a deficiency for the State rather than Geauga County. This clarification and acceptance of responsibility by the State for the deficiency is redected in the revised schedule of correc-tive actions. The revised schedule also includes the expected completion date for correcting each of the deficiencies.

The Federal Emergency Management Agency (FEMA) Headquarters and Region V staff 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.

h nt As Stated 8505290157 850523 PDR ADOCK 05000440 F PDR

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STATE OF OHIO ADJUTANT GENEftAL'S DEPAftTMENT 2sas west onAsmuE ROAD WORTHWeGTON, OHIO 43005 2712 DISASTER SERVICES AGENCY AGOH-DS April 8,1985 l 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

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C ARD M. LOCKHART LDeputy Director KBCikjs Encis: as stated I

APR 121985

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

(State) (Date) 1 Ohio i

(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 Il-C-2 and ll-C-10

} (ll-C-2-b-3 and ll-C-3-c-1-b) address j this criteria. The text on page l 11-1-5 (ll-1-3-a-5) will be clarified in the next plan revision. Concerning

'I the quantity of work to be performed, it should be noted that the amount of activity observed is due to the l accelerated nature of an exercise.

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

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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-I bution to the media.

1 i 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 l during the exercise involved two

! connectors and remedial action was i prompt. Since the exercise, the l' 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 i 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 i level of loudness over an extended i period. The five-way dedicated system was fully operational at the time the telephone company 1 completed its work in January 1985.

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

NUREG Narrative Statement Corrective Action Scheduled item of Deficier.cy Proposed Date F.1.b. The parties to the line (PNPP, Ohio (cont'd. ) DSA, and Ashtabula, Geauga and Lake County DSA's) 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 writt 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 to 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 their department's personnel. That information emergency workers. will be provided under separate letter when it becomes available, o

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 (con t'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. )

ASHTABULA COUNTY RESPONSE TO FEMA EXERCISE EVALUATION Summary Listing of Deficiencies and Corrective Actions ,

Ohio April 5,1985 (State) (Date)

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

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 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.

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 plume exposure pathway emergency planning zone (EPZ), has 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 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 diryt reading dosimeters and a TLD.

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i I ASHTABULA COUNTY RESPONSE TO FEMA EXERCISE EVALUATION l

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

l l NUREC Narrative Statement Corrective Action Scheduled Item of Deficiency Proposed Date j 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 i the scenario and personnel at such j points would remain until observed i by the exercise evaluator. Once

] the evaluator had concluded the evaluation the traffic control points j were to be dismissed. This agree-ment was in consideration of the i

policemen's and road crew's time

! (and cost) in that they would i have no activity (they do not I actually stop or direct traffic in .

l an exercise) except an occasional message to the EOC. In this instance the evaluator concluded his observations and questioning in short order.

4 in future exercises traffic control

! personnel will make at least one

, communication to the EOC indicating dosimeter readings. .,

1 1 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 i in or near the station will be made I to correct the shower and drain water situation.

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

NUREG Narrative Statement Corrective Action Scheduled i item of Deficiency Proposed Date l L.1. The hospital emergency room staff did not The Ashtabula County Medical Center April 1985 l demonstrate all of the equipment 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 i of whole body trays were purchased j for the Ashtabula County Medical l Center on April 4,1985. . In future exercises participants will be instructed to demonstrate fully the equipment and supplies on hand.

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-- 13281 PAINESVILLE-RAVENN A ROAD o GE AUG A COUNTY sAF ETY CENTER cHARDON OHIO 44024 DISASTER SERVICES AGENCY

""o~t <2's > 285-2222. c x T. So3 l A DEPUTY DIAECTC9 DIRECTOR ROWE N EGU40 D ALE B. WEDGE Apri1 5, 1985 Ken Cole Ohio Disas te r Se rvices Agency 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 with yours and the County responses.

Thank you for your assistance in our t raining and exe rcise arrange-ments.

Sinqerely yours,

[

Dale B. Wedge, Di rect r Geauga County Disas ter Services Agency A t t a ch rne n t 1

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

Ohio i

(Geauga County)

NUREG Marrative Statement Corrective Action Scheduled item of Deficiency Proposed Date I

E.1 The notifiction of " Unusual Event" Procedures for the She ri f f's April. 1986 (E0C) received via commercial telephone Department and EOC Dispatch- (Demonstrate) was not verified, er, where appropriate, will i

be revised to more clearly l

address no t i f i ca t i on/ve r i f i-cation procedures by means other than the five-way dedi-cated telephone line. T ra i n-4 Ing will also emphasize the j

actions needed during such

' occurences as system failure.

1 l E.7 I n fo rma t i on contained in the EBS The information In the EBS Sept. 1985 I (Media message was not released at the messages was presented orally (For review) ,

JPIC, e.g., presentation.of pro- by the Lake County Public in-i Relations) tactive action recommen da t ions f orma tion O f fi ce r from the A p r i l '. 1986

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l In terms of familiar la n dma rks stage at the JPlc. It was (Demonstration) i or boundarles. not presented to the news me-

' dia in written fo rm. Proce-l dures for the Public Infor-l mation Officer (located at the

] JPIC) and the Public Informa-

' tion Liaison Officer (located I in the Geauga County EOC) will be changed to facilitate the j . distribution of each E85 mes-sage in written form to new l media personnel at the JPlc.

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UTILITY: Perry Nuclea r Power Plant

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Ohio S umma ry Listing of Deficiencies and Corrective Actions April 5. 1985 (State) ,

Chlo j (Gesuga County) i 4

NUREG Narrative Statement Corrective Action Scheduled Item of Deficiency Proposed Date l

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) l (EOC) during the weeks and days prior to the exercise, and Ap ri l . 1985 l (tested monthly) was fully tested only a few times. It's f a i l u re during the exe rci s e involved two connectors and remedial ac-

' tion was prompt. Since the i

exercise, the telephone com-i pany has spent considerable time " debugging" and testing

]j the line. There were three i

separate tests of the entire l .

system to include one which i 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 l loudness over an extended per-I j lod. The five-way dedicated system *was fully operational at the time the telephone com-

! pany completed its work in Jan-uary 1985 I

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

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(Geauga County)

NUREG Narrative Statement Corrective Action Scheduled item of Deficiency Proposed Date F.1.b. T'ie p a r t i e s to the line (continued) (PNPP, Ohio DSA, and DSAs of Ashtabula, Geauga and Lake Counties) have agreed to participate 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 established and a "Pe r-Iodic Test I n s t r.u ct i on" pro-cedure is being written. The fi rs t such test is scheduled for April, 1985 K.3.a. Low and mid range dosimeters The eme rge n cy plan will be Sept. 1985 were not available fo r e me r- changed to indicate clear-(Radiation gency workers in the field. ly that each off-site emer-Exposure 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-con tami na t ion mon i to ri ng team will be issued one COV-730 (mid

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

. scribe a low r,a n ge dos i me t e r s

UT!LITY: Perry Nuclea r Powe r P lant 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 wculd not know how to use it. There wa.s no exposure control for their eme rgen cy wo rke rs . _

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EnuntyofEahr OFFICE 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 FEM 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 FEH A, Region V or include them in your response submittal to FE M A.

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

Respectfully, LAKE COUNTY DISASTER SERVICES AGENCY I ,

Robert H. Ret:1' r Director RHRtab Enclosure

LAEE CANff, IM10, MSNESE 10 FBth EEERCisE EvalaAT105 S m ry Listing of Deficiencies and Corrective Actions (Baio (State)

Lake (P-ity)

ImpBEG SCHEDULED MARRATIVE STATEM MT OF DEFICIENCY CORRECTIVE ACTION PROPOSED DATE ITDI Eo7. Information contained in the ERS Each ERS message released will be telecopied in its June 15, 1985 message was not released at the entirety, from the Lake County EOC to the JFIC.

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 ERS massages.

Folob. 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 caaAeted to ensure that the system will maintain the same level of volume over an entended 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 DS&, 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

lake Commty, insie, Beepense to FWas Esercise Bealuaties Page Two 3R: REG SCHEDULED 17538 MARRATIVE STATEMENT OF DEFICIENCY CORRECTIVE ACTION PROPOSED DATE F.1.b. (contimmed) been established and a " Periodic Test Instruction" procedure is being written. The first such test is scheduled for April, 1985.

J. I). j . Lake County was using a perimeter he 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. his map will coincide with the EOC of the plan. perimeter control points map used in conjunction with exercises or an actual situation.

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.

J.12. h e Receptica Center Manager Additional training will be conducted to ensure the June 15, 1985 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 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 he emergency plan will be revised to indicate clearly June 15, 1985 E.3.b. mot have mid and low range that each of f-site emergency worker who has a work 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. .

Page Mrime Emha Canary, h W to M Easrcias Spelmation i

SCHEDULED

. EDSEC DATE l ITag naamar1VE STATEIENT OF DEFICIERICY COSEECTIVE ACTION F30 POSED t

i E.3.a and K.3.h (contimmed) Emergency workers are provided with a " Dosimetry Report i Form" which asks for "Before" mission and "After" i

mission readings and a " Mission Total." his form cometitutes.the County's dosimeter recording procedure

! and all emergency workers participating in the exercise

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i carried this form. Mere is no publishad guidance '

indicating that readings from direct reading dosimeters should be written down on record keeping cards hourly.

l Under the current procedure an emergency worker can, at

! any time, simply read the direct reading dosimeters and compare this reading with the read N recorded before jl the mission began to determine the current total dose.

Me " Dosimetry Report Form" instructions direct the j

' emergency worker to " Read each CDV-742 each hour, or sooner, if instructed." herefore, the current procedure satisfies the present guidelines for 4

amargency worker control.

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)f June 15, 1985 C.4.j. Radiological release data forms Procedures and forms for recording information i j tramanitted by telephone will be reviewed and changed,

were not completely filled out.

' if necessary. Amy changes made will be inserted into training programs for perscanal using the procedures and forms for recording information transmitted by

]1 telephone.

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