ML20136G038

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Forwards 851104 Interim Finding on Offsite Radiological Emergency Preparedness (REP) Plans.Rept Based on FEMA Region V Regional Assistance Committee Review of Preliminary site-specific REP Plan.Plan Currently Inadequate
ML20136G038
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 11/20/1985
From: Krimm R
Federal Emergency Management Agency
To: Jordan E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8511220239
Download: ML20136G038 (17)


Text

1 9hf Federal Emergency Management Agency Washington, D.C. 20472 O

O NOV 201985 MEMORANDUM EUR:

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

-U Nuclear Requ atory Ccmnission Ar 1 FROM:

h r C r*1nSF # '

Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

Interim Finding on Offsite Radiological Emergency Preparedness Plans for the Braidwood Nuclear Power Station Attached is an Interim Finding on offsite radiological emergency preparedness (REP) plans for the Braidwood Nuclear Power Station (NPS) dated November 4, 1985. %e finding was prepared by Region V of the Federal Emergency Management Agency (FEMA). At the time that the finding was prepared, neither an exercise nor public meeting had been held in accordance with 44 CFR 350.

(The initial Braidwood exercise was held on November 6, 1985.)

h erefore, the report is based on the FEMA Region V Regional Assistance Comittee's (RAC) review of the preliminary site-specific REP plan for Braidwood (Volume VII of the Illinois Plan for Radiological Accidents

[IPRA]), dated August 1985.

So RAC evaluated the preliminary Braidwood plan in accordance with the criteria provided in NUREX}-0654.

Based on that evaluation, the preliminary plan was found to be inadequate.

During the review, the RAC identified planning deficiencies which could adversely affect public health and safety. Specifically, deficiencies were identified in connection with the following NUREG-0654 planning standards: Assignment of Responsibility; Emergency Response Support and Resources; Medical and Public Health Support; and, Exercises and Drills.

On October 10, 1985, FEMA Region V provided the Illinois Emergency Services and Disaster Agency with the RAC's u nsensus revim; of the preliminary Braidwood plan.

Prior to the initial Braidwood exercise on November 6, 1985, Illinois provided a schedule of corrective actions to FEMA hegion V.

his information has been provided to the RAC for review and evaluation. Following the RAC's evaluation, an assessment concerning the adequacy of the corrective actions will be made.

We results will be provided to the State. We estimate that the final version of the plan will be submitted to FEMA Region V by late January 1986.

If this schedule is maintained, we would most likely be able to provide a supplemental finding on the plans by late March 1986.

It is our judgnent that a serious planning effort has been put forth to date, and we anticipate the final version of the Braidwood plan (IPRA, Volume VII) will be an adequate plan from which to conduct emergency radiological response.

o f During the next few months, FEMA will provide NRC with an evaluation of preparedness based on the November 6,1985, joint full participation exercise. Although the exercise assessment report has not, of course, been prepared, preliminary analysis of the exercise results indicate there were no deficiencies affecting public health and safety.

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

Attachment As Stated l

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INTERIM FINDING

..I Braiduccd Cuclogr Pow 2r Staticn Off-Site Radiological Emergency Preparedness State of Illinois Will, Crundy, and Kankakee Counties November 4,1985 INTRODUCTIAN A.

Area Description 1.

Facility and Surroundings The Braidwood Nuclear Power Station Units 1 and 2 (Braidwood Station), owned by the Commonwealth Edison Company. Chicago, is located on 4.162 acres which consists mostly of land that once had been a coal strip mine. The Station site is in Reed Township. 589 feet above sea level, 1.5 miles (1.4 km) south of the city of Braidwood; 1.5 miles (1.4 km) northeast of Braceville and 4.5 miles (5.2 km) west of the Kankakee River that flows north-northwest. The site is situated in the southwest corner of Will County in a predominantly rural setting. Grundy County, in which the Dresden Station is located, is less than one mile west of the Braidwood Station. Thirty miles to the east is the Indiana state line.

Although there are four communities with a total 1980 population of 7.641 within five miles of the Station. the land use is primarily agricultural.

The total permanent population within five miles of the Braidwood Station is 12.472. Between five and ten miles from the Station the population is 15,258.

The Station's cooling lake is approximately 2,640 surface acres of water plus 600 acres of islands, surrounded by 28 million cubic yards of dirt that was relocated in order to form the dikes. Water is pumped from the lake by six 3,000-HP - 247,000 gallons per minute water pumps (three per unit) thro gh two 16 foot diameter pipes (one per unit), through the condenser and returned to the lake. Water temperature drops 20 degrees F through its 4 1/2 day journey around the lake before its return to the condenser.

Kankakee River water (three miles away) is used for water makeup due to lake-water evaporation and to control lake-water mineral content.

The containment building is 200 feet above grade, 60 feet below grade, 140 feet in diameter and has a 12-foot thick base with 3-1/2 f oot steel reinforced walls over a 1/4" steel liner. It is equipped with a 230 ton capacity crane. The building is wrapped with steel tendon cables made up from 1701/4" wires and under 1.000.000 pounds of forc'. thereby squeezing the containment building two inches and greatly increasing its strength.

The pressurized water reactor, which is the heart of the nuclear reaction, is 44 feet high.14-1/2 feet in diameter, with walls 8-1/2 inches of manganese-molybdenum steel, lined with stainless steel. Total weight with controls is 452 tons. The reactor is below grade and filled with approximately 41.000 gallons of water. Operating pressure in 2,250 pounds per square inch at 580 degrees F.

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l The Westinghouse generator produces electricity at 25,000 volts and is rated at 1.175 megawatts net. Two 625-HVA transformers per unit convert the 25.000-volt generator output to 345,000 volts. which is then sent to the switchyard and directed to the 345-KV transmission system. This, in turn, is distributed throughout the service territory to almost three-million l

customers.

l Facility water discharged into the Kankakee River is circulating water, sanitary treatment affluent and waste-discharge tank water. State and Federal Environmental Protection Agency (EPA) and Nuclear Regulatory Commission (NRC) rules and regulations list discharge limitations which l

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temperature (5 degrees F higher than water from the river). Studies and calculations have been completed as part of the Environment Report and approved by the EPA and NRC which conclude that no detrimental effect will take place on the Kankakee River resulting from the Braidwood Station operation.

2.

Emergency Planning Zones I

The Emergency Planning Zone (EPZ) for the Braidwood Station consists of a circle with the Braidwood Station as the center point. The EPZ extends ten l

miles outward in all directions from the Braidwood Station for the plume exposure pathway planning zone and fifty miles outward for the ingestion exposure pathway planning zone. In the event of a serious accident at the Braidwood Station, the plume exposure EPZ will be the area in which intensive efforts will be made to notify and protect residents and transient populations from exposure to radiation. For the purpose of providing initial notification and informational messages within 15 minutes, the EPZ is further defined through the use of easily recognizable geographic and political boundaries. Although in many cases these boundary descriptions cxtend the EPZ beyond a 10-mile radius from the plant, all other planning considerations are based upon a 10-mile EPZ. This EPZ includes he following municipalities.

Governments within the 10 Mile Emergency Planning Zone 1980 Miles Direction I

Population From Site From Site Braceville 721 2

Southwest l

Braidwood 3,429 2

North I'

Carbon Hill 406 5

Northwest Coal City 3,028 4

Northwest i

Diamond 1,170 4

Northwest

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East Brooklyn 84 5

South Southwest Essex 463 4

South Southeast Gardner 1,322 5

Southwest l

Godley 373 1

Southwest Mason 828 10 West Reddick 243 10 South South Wilmington 747 5

South Southwest Union Hill 82 10 South Southeast Wilmington 4,424 6

Northeast l

l Total 1980 Population 17,320 l

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s The primary-land use around the Braidwood Station is agricultural, with cash grain crops of corn and soybeans. The closest industries are located in the communities aof Wilmington 'and Coal City. There are four recreational facilities in the EPZ which can each accommodate between 1100 and 1800 people.

Major transportation facilities in the Braidwood Station EPZ are limited to Interstate 55, which passes one and one-half miles west of the Station itself, and four railroads. The railroads are the: Illinois Central Gulf Railroad which is one mile west of the Station; Atchison, Topeka and Santa Fe which is four miles northwest of the Station; the Norfolk and Western Railroad which is four and one-half miles southeast of the Station; and the Elgin, Joliet and Eastern Railway Company which is ten miles northwest of the Braidwood Stat ion.

Governments within the 50 Mile Emergency Planning Zone The 50-mile EPZ includes the Illinois Counties of Cook, DeKalb, DuPage, Ford, Grundy. Iroquois, Kane, Kankakee, Kendall, LaSalle, Livingston, McLean, Will and Woodford. The Indiana Counties are Lake and Newton.

3.

Special Demographic Circumstances for Planning The area topography consists of level prairie. Strip mining has created ridges and knolls of overburden material. The created depressions are filled with sub-surface water from the high water table and surface runoff.

The natural drainage forms small creeks which meander across the land. The cmall creeks flow into rivers. Some creek and river beds are several feet below the surrounding prairie. This region of the Midwest is part of the vast expanse of prairie which extends from Indiana west into Iowa and Nebraska.

The area is a productive agricultural community. Cultivated agricultural crops are primarily soybeans and corn. Fork and beef production constitutes the principal animal husbandry practice. The " family-farm" is the backbone cf commerce in this area. Farm size ranges from a few hundred acres to several hundred acres.

In the small villages near the Station are dry goods and food stores, 3

petroleum depots, seed and fertilizer and agricultural equipment sales, i

banks, small family-owned businesses and a grain elevator. The goods, cervices and exchange of news focuses in these small centers of commerce.

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l Industries in the EPZ include: Bowers Sieman Chemicals Company, Coal city l

(industrial lubricants and chemicals for the wire industry) employs 30 people: DeMert and Dougherty Inc., Coal City (aerosols, etc.) employs 115 people; Brownie Special Products Co., Cardner (bakes pizza crusts and cookies) employs 25 people; Personal Products Co., Wilmington Division of Johnson and Johnson (hygienic products) employs 350 people; and Production Training Center, Braidwood (Commonwealth Edison Company) averages 150 trainees.

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Unique Considerations,

Recreational Area.

Within and just outside the 10-mile EPZ are several recreational sites. The numerous lakes of the strip mining areas provide for fishing, boating, water skiing, hiking. water fowl hunting and picnicking. The Kankakee River flows from the southeast to the north across the northeast quarter of the 10-mile EPZ. Waterfront homes, both summer and winter and fishing camps line both side of the river.

Goose Lake Prairie State Park predominates the northwest quarter of the 10-mile EPZ and the Des Plaines Wildlife Conservation Area occupies the northern portion of the 10-mile EPZ limit. Both offer nature study, hunting, fishing, recreatingal boating and other outdoor activities including overnight camping at the Des Plaines Wildlife Area.

Kankakee State Park, located between State Routes 102 and 113 to the southeast of the Station, provides campsites, hunting, water activities and winter recreation.

Collins Lake to the west of the Station allows fishing only. It is the cooling lake to the Dresden Nuclear Power Station.

Unique Facilities To the northeast of the Station, between the 5-and 10-mile area of the EPZ, is the Joliet Arsenal which covers many thousands of acres. Also, a large grain storage f acility is in the northeast quarter of the 10-mile EPZ.

Transportation Systems Interstate Illinois 55 enters the 10-mile EPZ at the north, passes about one mile west of the Braidwood Station and continues out of the 10-mile EPZ to

.the southwest. State Route 17 enters the southern edge of the 10-mile circle. State Route 47 enters the western edge of the 10-mile EPZ. State Routes 113, 102, 129 and 53 are major State highways which traverse the 10-mile EPZ.

River barge traffic moves along the Kankakee River upstream as far as Wilmington. The River Pool is separated by a spillway and locke at Wilmington. The river flows from the east to the north through the 10-mile EPZ.

Three primary railroads cross the 10-mile EPZ. The Illinois Central Gulf to southwest. The passes within 1/2 mile of the Station and runs northeast Atchison, Topeka and Sante Fe crosses the northwest quarter from northeast to southwest. The Norfolk and Western crosses the east and southeastern quarter from the northeast to the southwest. Several spurs of the main railroads exist in the 10-mile EPZ.

Several interstate pipelines transverse the 10-mile EPZ, primarily in a southwest to northeast direction. They are mainly concentrated in the southeastern quarter of the EPZ.

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p Local Emergency Resources 1There are six principal villages within the 10-mile EPZ: Braidwood, Braceville, Cardner. South Wilmington, Coal City and Wilmington. Their combined populations total 13,230. Many emergency response organizations cre volunteer and/or part-time as are many of the elected officials' positions. Emergency equipment is sufficient to meet the every day emergency needs of the communities but is considered limited to meet a technological emergency such as a significant radiological accident at a nuclear power station. The State resources would supplement the local Offorts to respond to such an occurrence.

B.

Emergency Planning Authority and Organizations i

The Illinois Emergency Services and Disaster Agency Act of 1975 (Ill. Rev.

Stat. Ch. 27, para. 1101 et. seq.) establishes an Emergency Services and Disaster Agency and confers upon it broad authority to plan for a coordinated response by State and local agencies to all disasters, whether from natural or manmade causes. The Act provides that the authority to deploy resources in response to an emergency shall be provided by an executive proclamation of a " State of Disaster Emergency."

The Illinois Nuclear Safety Preparedness Act (111. Rev. Stat., Ch.111 1/2, para. 4301 et. seq.) designates the responsibility for emergency response planning for accidents at fixed nuclear facilities to the Illinois Department of Public Health and provides for a fee to be assessed on licensed nuclear power reactors to fund the Illinois Nuclear Safety Preparedness Program. The Governor of Illinois, by Executive Order Number 3, dated April 1,1980, created the Department of Nuclear Safety (IDNS),

transferring to that department the responsibilities of the Illinois Department of Public Health defined in the Illinois Nuclear Safety Preparedness Program.

C.

History and Status of Planning and Preparedness t

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Plan Development i

The Illinois Plan for Radiological Accidents (IPRA) is contained in Volume I

I, the " State General Plan" (March 1982) and an accompanying book of Standard Operating Procedures (SOPS) as well as seven site specific volumes and SOPS. A reformatted version of IPRA Volume I was provided to the RAC in August of 1985 for consideration along with preliminary IPRA Volumes VII (Braidwood) and VIII (Clinton). The preliminary IPRA Volume VII (Braidwood) has been evaluated by the Region V Regional Assistance Committee (RAC).

2.

Plan Review l

Review comments of the State (Volume 1) and Will, Grundy and Kankakee Counties (Volume VII) IPRA were prepared by FEMA Region V with the counsel l

of the RAC. The consolidated RAC finding of the plan was sent to the Illinois ESDA on October 10, 1985. The State has addressed the deficiencies L

and responded with a schedule of corrective actions on October 30, 1985.

Subsequently, they will incorporate the corrective actions into the plan

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(volumes I and VII) and formally submit the plan in its final form sometime af ter the November 6,1985 full participation joint exercise.

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Public Meeting It is tentatively planned to conduct a public meeting following the

publishing of the exercise report. Therefore, the date for the meeting will be in March or April 1986.

4.

Exercises The initial qualifying exercise is scheduled for November 6, 1985.

It is full participation for all participants; 111inois ESDA, IDNS, Will County, Grundy County, Kankakee County, major municipalities within the three Counties and the applicant, Commonvasith Edison Company.

5.

Intervenor Contentions Contentions have been admitted by the Atomic Safety and Licensing Board which pertain to offsite emergency planning for the Braidwood Nuclear Power Station. In a Special Prehearing Conference, August 23, 1979, Bridget Little Rorem, et al, Contentions 1(a), 1(b) and 1(c) were admitted by the Licensing Board as issues in controversy. The Intervenor contends that an adequate emergency plan for the Braidwood Station should include the following: (a) a program for informing the public within ten miles of the Station of the means for obtaining instructions for evacuation or other protective measures in the event of a radiological emergency originating at the Station and (b) assurance that institutions within ten miles of the Station, such as nursing homes, can be evacuated or adequately protected in the event of a radiological emergency. Contention 1(c) is no longer in controversy and therefore is not addressed herein.

A TEMA Region V expert witness has been designated and appeared before the ASLB on October 29, 1985 to address contention 1(a). Contention 1(a) specifically challenges State and local planning regarding NUREC-0654/ FEMA-REP-1, Revision 1, Planning Standard C, criteria 1 and 2.

Testimony has been developed and submitted. Contention 1(b) is tentatively scheduled for the ASLB hearings on January 20, 1986. The same expert witness will testify for FEMA Region V on Contention 1(b).

At the ASLB hearing of October 29, 1985 Bridget Little Rorem submitted an Offer of Proof before the Board stating that Contention 1(a) concerns public information programs other than at the pre-accident stage. The ASLB agreed to consider the matters on motion (in advance of hearing) to determine whether it is necessary to obtain any additional testimony. Seven issues have been identified and FEMA and NRC will provide written response by December 20, 1985.

D.

Documentary Evidence Available for Examination 1.

Plans and Plan Reviews l

Illinois Plan for Radiological Accidents State General Plan, Volume 1, February 1981 State General Plan, Volume 1, March 1982 (Reformatted 1931 edition)

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State General Plan, Volume 1, (Draf t Reformatted dated June 1985)

State General Plan, SOPS, March 1982 6

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i, Braidwood Plan, volume VII, August 1985 (preliminary)

Braidwood SOPS, August 1985 (preliminary)

Braidwood Public Information Brochure, (Draf t) August 1985, Rev.1 Braidwood Public Information Brochure, October 1985 RAC consensus review of the above plans dated September 17, 1985 and relevant correspondence.

State of Illinois schedule of corective actions to the RAC consensus review dated October 28. 1985 It is necessary to understand that the preliminary Braidwood plans which have been sent to FEMA Region V are not the formal submission as described in 44 CFR Part 350. They are for review purposes only. Further, until the ts: rmatted Volume I is formally submitted and accepted, the 1982 State Geny.1 Plan is the plan of record.

PLAN EVALUATION

SUMMARY

The State General Plan (IPRA Volume I) has been formally reviewed and approved for the site-specific locations of Dresden (FEMA-REP-5-IL-1) and LaSalle ( FEMA-REP-5-IL-2). Those approvals are based upon the IPRA Volume I, dated February 2, 1981, which was reformatted in March 1982. The 1982 edition condensed the volume by printing on both sides of the pages, made monor changes and corrections recommended by the Regional Assistance Committee and placed the Standard Operating Procedures in a separate binder. Based upon the Regional Assistance Committee review of plans and exercise results, FEMA determined the document to be adequate. In addition, under the IPRA Volume 1, March 1982, the Regional Director's Evaluations for Quad Cities (FEMA-REP-5-IL-3) and Zion (FEMA-REP-5-IL-4) were submit ted October 25, 1983. approved March 2, 1984 and published in the Federal Register March 9, 1984. The Regional Director's Evaluation for Byron (FEMA-REP-5-IL-5) was submitted June 18, 1984, approved September 13, 1984 and published in the Federal Register September 19, 1984.

A new edition of the State General Plan (IPRA Volume I) was submitted along with the preliminary Braidwood (IPRA Volume VII) Plans and SOPS. The new version has eliminated extraneous material and has been condensed to a more useable document. It will undergo formal RAC review to determine if it significantly alters any of the early RAC findings for IFRA Volume I.

For the purpose of this review, the Regional Assistance Committee has provided a consensus finding of the preliminary Braidwood (IPRA Volume VII)

Plans and SOPS and the State General Plan (IPRA Volume I).

The review participants included Federal Emergency Management Agency, U.S. Department of Energy, Food and Drug Administration, Public Health Services, U.S.

Nuclear Regulatory Commission, U.S. Environmental Protection Agency, U.S.

Department of Transportation, and the U.S. Department of Agriculture.

The following is a summarization of Braidwood (IPRA Volume VII) and, as relevant, the State General Plan (IPRA Volume 1) and follows the format of

" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654 / FEMA-REP-1, Revision 1.

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A.

Assigneent of Responsibility (Organization Control)

The offsite radiological emergency plan for the Braidwood Nuclear Power Station assigns responsibility to State and local governments for emergency response efforts in the emergency planning zones.

The local County governments of Will, Grundy and Kankakee have an cperational role which is explained in its concept and its relationship to the total effort. A block diagram illustrates the interrelationship of County agencies and departments.

In the case of each of the three Counties, there is an individual by title who is in charge of the emergency response. In each County, provision is cade for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day emergency response in addition to a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> communication watch through the Sheriff's radio dispatch.

In the Braidwood Plan and for each of the three Counties, functions and responsibilities for major emergency response elements and key individuals by title are provided in matrix form. A narrative of each major emergency cervice is provided with good explanation of response involvement.

The specific codes and statutes are referenced and are reflected in the State General Plan (IPRA Volume 1).

Missing from the plan are the necessary letters of agreement between government agencias and support organizations with emergency response roles in the EPZ.

The Counties operate from a central location in each County where the key cgencies and departments gather when activated for the emergency response.

The facility in each case is the Emergency Operations Center. They are capable of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operations over a protracted period. An individual, by title, is designated who is responsible for assuring continuity of resources.

B.

Onsite Emergency Organizations Onsite emergency organization is a licensee responsbility and is to be evaluated by the NRC.

C.

Emergency Response Support and Resources The necessary non-government resources to support the Federal response are l

discussed in the State Plan but need further development in providing more l

,information; apacifically, a listing of resources to support the Federal l

response.

Missing from the plan are the necessary letters of agreement which form the basis of other facilities and organizations which can be relied upon to provide assistance in an emergency.

D.

Emergency Classification System Each of the three Counties has adopted the emergency classification and emergency action level scheme which is consistent with the State and the applicant.

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Contained in the plans are procedure. that provide for emergency actions which are consistent with emergency actions recommended by the applicant.

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Notification Methods and Procedures j

l The County plan establishes the procedures which describe mutually agreeable bases for notification of response organizations which are consistent with the emergency classification and action level scheme. The procedures include the verification of messages using the Nuclear Accident Reporting System (NARS) form.

Procedures are established for alerting, notifying and mobilizing emergency response personnel in the County.

A system is in place in planning for disseminating to the public appropriate information in initial and follow up messages which are received from the applicant. The planning includes the procedures for notifying the area emergency broadcast radio stations (WJOL/WLLI) for public announcements to advise the public on actions to take in the event of an emergency.

s The County plan addresses the administrative and physical means and the time required for notifying and providing prompt instructions to the public. The RAC requested of Illinois ESDA an explanation of the notification system with specific reference to the reliability of the backup measures to assure that the necessary instructions are properly and accurately given to the public.

Written public information scripts are a part of the plan and contain important protective action recommendations.

F.

Emergency Communications In planning, provisions are made for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day notification to activate the local emergency response network and the communication links to emergency response groups. Planning has been formulated for communications with contiguous State and local governments within the Emergency Planning Zones. The notification of other State and the Federal family is the responsibility of the Illinois ESDA and is in the State General Plan (IPRA Volume I).

Communications between the Nuclear Power Station, the Emergency Operations Facility, State and local emergency operations centers and radiological monitoring teams and the communications for alerting and activating emergency personnel are provided for through the NARS, other dedicated telephone lines, radio and commercial telephone.

Coordinated communications links for fixed and mobile medical support i

facilities do exist and are so stated in the plan.

Provision is made for testing the entire emergency communications system on a periodic basis.

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G.

Public Education and Information A public information brochure is to be distributed periodically to the public. The brochure disseminates information to the public regarding how they will be notified and what the public actions should be in the event of an emergency at the Braidwood Nuclear Power Station. Absent from the draft brochure was guidance on what to do with pets and livestock.

Pursuant to the deficiency in planning for the draft Braidwood Public Information Brochure being identified by the RAC, the Illinois Emergency Services and Disaster Agency took immediate action to make the correction felt this promptness was necessitated by and notify FEMA Region V.

It was the ASLB Hearing, October 29, 1985. The October version of the Public Information Brochure has been reviewed and adequately corrects this planning deficiency.

Comments and guidance have been given the State on specific information for inclusion. Also suggested was the need for other means for notifying the public, including transients.

The plan designates the points of contact and physical locations for use by the news media during an emergency. Locations are listed for the three Counties. Also listed are locations for the municipalities in the 10-mile EPZ and the State News Media Center.

The plan designates an individual, by tit?e, in each location who is the spokesperson for the release of all public snnouncements.

Provision is made in the plan for the exchange of information among the designated spokespersons in the Counties and municipalities.

Rumor control is at the lowest level of government practical. Specifically, the plan needs to explain how rumor control is implemented at the local level. However, the State makes provision to handle rumors over a State network. The phone numbers are made public at the time of public press briefings and announcements.

The State and applicant have provisions in planning for the conduct of press and briefings annually to acquaint the news media with the emergency pland points of contact for release of public information during an emergency.

Usually the annual briefings are held prior to the annual exercise.

H.

Emergency Facility and Equipment Emergency Operations Centers are established in each of the three Counties and in the main municipalities and the State. Emergency operations and functions are carried out from these locations.

Provisions are made for the activation and staffing of the Emergency Operations Centers.

Offsite radiological monitoring is the responsibility of the IDNS. The assignment and function is in the State Plan and SOPS.

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The criteria for inspection, inventory and operationally checking emergency instruments is satisfactorily addressed. However, there is the matter af

- inspection and maintenance of equipment, primarily radios, which are vf used routinely.

The identification of emergency kits by general category is included in the I

State Plan SOPS.

A central point is established for the receipt and analysis of all field monitoring data and the coordination of sample media.

1.

Accident Assessment The capability and resources for field monitoring within the plume exposure l

EPZ are a part of the State General Plan (IPRA Volume 1).

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l The State Plan provides for methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of radiological hazards. It includes activation, notification means, field team composition, transportation, communications, monitoring equipment and estimated deployment times.

The State has the capability to detect and measure radioiodine concentrations in the air. Also established are the means for relating the various measured parameters and gross radioactivity seasurements. Provision is made for estimating integrated dose from the projected and actual dose rates and for comparison with protective action guides. Details are described in the procedures.

Arrangements are made to locate and track airborne radioactive plumes using Federal and/or State resources.

J.

Protective Response Provided for in the State planning, relative to the Braidwood site, is an established capability for implementing protective action guides and other f

criteria.

l Contained in the Braidwood plan are maps which depict the standard sectors.

Contained in each sector is the population distribution. Refinements to the maps would enhance the presentation of the information.

The transient and resident populations are to be notified by the Prompt Alert and Notification System. The plan cites the use of the emergency

-broadcast station, tone alert acnitors, radio systems for schools, businesses and institutions and by the outdoor sirens which have voice capability in addition to the wail siren.

Planning provides for the confined, in home bed-ridden and mobility

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impaired. Lists are held by local officials which locates those who need special arrangements. The Public Information Brochure takes the handicapped population into account.

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d The issue and recommendation for the intake of potassium iodide is a decision of the State Department of Health Administrator. Directives are drawn up and in the State General Plan (IPRA VolumeI) which clearly states the policy of the State on potassium iodide use.

The Braidwood plan and SOPS contain the procedures for relocating the population. Sheltering is planned and all reception / care centers are well outside the 10-mile EPZ.

Traffic capacities are not in the plan, but an extensive discussion is contained in the Braidwood Evacuation Time Estimate Study which is referenced in the correlation document. Although the brief review found the study to be adequate, two observations were offered State Planners.

Control of access to evacuated areas and organization responsibility for such control is provided in 7-SOP-7, Traf fic and Access Control Guide. The accuracy of instructions for each point should be checked.

The responsibility for dealing with impediments is assigned to the County's Highway Superintendent.

Time estimates for evacuation of various sectors and distances are provided for in the plan / time motion study under various conditions.

The choice of recommended protective actions is the responsibility of the IDNS and is contained in the State Plan SOPa. The IDNS has proven adequate planning and capability in the methods and recommendations for protecting the public from consumption of contaminated food-stuffs.

The Red Cross Chapters have the responsibility for registering and the IDNS is responsible for monitoring the evacuees. Procedures for monitoring can be found in the State Plan SOPS.

K.

Radiological Exposure Control It is the responsibility of the IDNS to make provision for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capability to determine radiation doses received by emergency personnel and it is provided for in State planning.

The plans cover the distribution of dosimetry, reading frequencies and the maintaining of records and the control point for record data deposit.

Planning establishes a decision chain for exposure of emergency workers to radiation in excess of EPA Public Protective Action Guides.

IDNS has established and published action levels for decontamination. They provide monitoring support and technical assistance to local officials for the decontamination of equipment and personnel.

L.

Medical and Public Health Support The Braidwood plan and the State plan addre>> the arrangements for local and backup hospitals and medical services. It would enhance planning if a discussion was included in local planning in addition to the listing provided. Letters of understanding with the hospitals and medical services are required to complete the planning process.

12

The plan lists the location of hospitals, type of facility, capacity and special radiological capabilities for providing medical support for contaminated injured individuais.

The plan does not make clear the local arrangement for transporting contaminated and/or injured individuals.

M.

Recovery and Reentry Planning and Post-Accident Operations The SOPS to the Braidwood plan adequately address the procedures for recovery and reentry into the evacuated area. However, missing from the plan is a general descriptive narrative on the subject.

The State plan specifies :

means for informing the response organizations that a recovery operation is to be initiated; changes in the organizational structure ; and, also specifies the means for periodically estimating total population exposure.

N.

Exercises and Drills The State is the responsible organization for conducting drills and exercises under guidance set forth by NRC and FEMA and is so stated in the plan. Exercises are to provide for mobilizing resources and personnel at the State and local levels and the exercise is to follow objectives and a scenario which is common to the applicant. Exercises are to be critiqued by the State and evaluated by FEMA and the RAC. There is provision is for the variance of exercise times, seasons and conditions.

Communications drills and tests are periodically conducted as a matter of routine in daily business. There is no provision within the plan for medical emergency drills. The IDNS conducts radiological monitoring and health physics drills for their own department personnel and for emergency responders and officials in the local units of government.

Exercise planning and the conduct of exercises is in accordance with Federal guidance. Following Federally observed exercises, the evaluation is critiqued in a joint State-local-utility public meeting as the Federal criteria specifies.

ksaresultoftheevaluation,areportisprovided the State. The State has provisions for acting on recommendations for corrective actions resulting from exercising.

O.

Radiological Emergency Response Training The State General Plan (IPRA Volume I) provides for the conduct of training to any group or jurisdiction on an annual basis and training is available upon request at any time.

The Braidwood Plan (IPRA Volume VII) and the State General Plan (IPRA Volume I) establish a training program for instructing and qualifying personnel who will implement radiological emergency respon=e.

The training includes and is not limited to annual retraining.

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2 O

P.

Responsibility for the Planning Effort: Development. Periodic Review and Distribution of Emergency Plans The plans, in their training program, makes provision for the training of those individuals who develop general and site-specific plans. Individuals by title are designated with responsibility for the development and updating of emergency plans and coordination of the plans with other response organizations. The updating of local plans is the responsibility of the County emergency director.

The annual certification procedure is stated in the State General Plan (IPRA Volume 1).

The approval process of changes in the plan and the fcrwarding of the changes are not adequately addressed in the local plan nor referenced to the State plan but,it is accounted for in the State plan.

And The State plan contains a listing of supporting plans and their source.

the plan has a correlation document (appendix) listing the procedures required to implement the plan. The plan also contains a table of The correlation document cross-references the planning items to contents.

j the criteria.

Special consideration is given to the State of Illinois for this criteria element in that the State currently has five operating nuclear power stations within its boundaries and ultimately there will be seven.

It poses an unusual and demanding hardship on the State to update telephone numbers quarterly. As discussed with the Illinois ESDA in past evaluations it is agreed an annual update is necessary to the Federal holders of the plan.

Ilowever, it is understood and agreed to that at the State and local levels, all telephone listings will be kept current as they change.

l CONCLUSION f

The foregoing is the status based on RAC consensus review of the preliminary offsite planning for the Braidwood Nuclear Power Station. It is the I

conclusion of FEMA Region V that the preliminary Braidwood Plan (IPRA Volume VII) is currently inadequate. The Illinois ESDA must correct the noted deficiencies in the detailed RAC consensus review. The State of Illinois 3

has submitted a schedule of corrective actions which is currently undergoing RAC review.

i The planning deficiencies could adversely affact public health and safety I

and must be corrected in order to provide reasonable assurance that the plan f

can be implemented. Also, important support documents are missing which are

[

vital to the plan as a functional document. Specifically, planning deficiencies exist in the areas of Assignment of Responsibility, Emergency g

Response Support and Resources, Medical and Public Health Support and Exercises and Drills. These deficiencies and several recommendations from the RAC to enhance or clarify planning will be addressed by the schedule of corrective actions.

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H vever, it is FEMA Region V's judgment that serious planning effort has forth to date and it is anticipated the final version of the b:cn put Braidwood Plan (IPRA Volume VII) will be an adequate plan from which to ccnduct emergency radiological response. Further, the State and local gsvernments will demonstrate implementation of their planning (preliminary Brcidwood Plan and schedule of corrective actions) during the November 6, 1985 full participation exercise. Evaluation of this exercise as well as cnslysis of the schedule of corrective actions will allow a reassessment of few months.

the adequacy of offsite planning over the next 15 I

i

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