ML20141G396

Discusses Implementation of Encl FEMA Recommendations Re Offsite Radiological Emergency Preparedness.Fema Disapproval of State Plan Will Result in Initiation of Steps Described by M Phillips at 851210 Meeting

ML20141G396
Person / Time
Site:	Davis Besse
Issue date:	01/06/1986
From:	Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Williams J TOLEDO EDISON CO.
References
NUDOCS 8601100186
Download: ML20141G396 (2)

Text

f 1 JAN O 6 1986 Docket No. 50-346 Toledo Edison Company ATTN: Mr. Joe Williams, Jr.

Vice President Nuclear Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:

We have received the enclosed Federal Emergency Management Agency (FEMA) letter dated December 13, 1985, which included the following: the offsite exercise evaluation report prepared by FEMA Region V; the schedule of proposed corrective actions submitted by the State of Ohio; and letters from FEMA Headquarters to the Governor of Ohio and the Deputy Director of the Ohio Disaster Services Agency regarding the rejection of a proposal to redefine the boundaries of the plume exposure pathway Emergency Planning Zone (EPZ) to exclude portions of Lucus and Ottawa Counties that are presently within this EPZ.

FEMA identified no deficiencies during the exercise; however, two areas requiring corrective actions were identified. FEMA Headquarters and Region V staff have reviewed the schedule of corrective actions submitted by the State and found it to be adequate.

We fully recognize that the recommendations to be implemented may involve acticas 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 Davis-Besse Nuclear Power Station be addressed by you as well as others.

Note that FEMA has requested that the State provide certain offsite radiological emergency preparedness information by February 7, 1986, or certain actions will be taken, including: the return and disapproval of the State's original Radiological Emergency Preparedness (REP) plan submitted per 44 CFR 350; and requesting the publication of a notice in the Federal Register that offsite emergency planning and preparedness around the Davis-Besse site are not adequate to protect the public health and safety and that the plans have, therefore, been returned for appropriate corrective actions. Our concern regarding the timely resolution of the EPZ issue has been demonstrated by the attendance of Mr. M. Phillips of my staff at a December 10, 1985 meeting with you, members of your staff, and State and local governmental officials to discuss FEMA's rejection of the proposed EPZ revision. Should FEMA disapprove the State's REP plan submitted under 44 CFR 350, the NRC will initiate those steps described by Mr. Phillips at the aforementioned meeting.

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Toledo Edison Company 2 06 M

- 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,

" Original cicr.:d !;y-U.D. Shafer#

W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch

Enclosure:

As stated cc w/ enclosure:

L. Storz, Plant Manager DCS/RSB (RIDS)

. Licensing Fee Management Branch Resident Inspector, RIII Harold W. Kohn, Ohio EPA.

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

, . cc w/o enclosure:

, D. Matthews, EPB, OIE i W. Weaver, FEMA, RV l

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- *' z Federal Emergency Management Agency 1 C f Washington, D.C. 20472 DEC l 3198a MEN 0 RANI 1H EDR: Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Of fice of Inspection and Enforconent

, U.S. Nuclear Regulatory Connission FRCM: . r Assistant Associate Director Office of Natural and Technological llazards Programs SUBJECT. Exercise Report of the July 16, 1985, Exercise of the Offsite Radiological Emergency Preparedness Plans for the Davis-Besse Nuclear Power Station ,

Attached are two copies of the Exercise Report of the July 16,1985, joint exercise of the offsite radiological energency preparedness plans for the Davis-Besse Nuclear Power Station. 'Ihis was a joint full participation exercise for the State of Ohio and Ottawa County. The report dated October 4,1985, was prepared by Region V of the Federal Dnergency Managem3nt Agency (FEMA).

'Ihere woru no deficiencies observed during the exercise. 'Ihere were two NUREG criteria (J.11 for the State of Ohio and K 3.b. for Ottawa County) identified as areas requiring corrective actions; however, these exercise inadequacies did not detract fran the overall demonstrated capability to i protect the health and safety of the public. Attached is a schedule of corrective actions submitted by the State of Ohio. FFMA fleadquarters and Region V staff have reviewed the schedule of corrective actions submitted by the State and found it to be adequate.

I While there were no deficiencies identified darin] the July 1985 exercise, It must be noted that two significant areas partially within the 10-mile ,

.l energency plannin] zone (EPZ) did not participate in the exercise--derusalon l Township (Lucas County) and the City of Port Clinton (Ottawa County).

In the case of Lucas County, a REP plan has never been sihmitted to FIMA for review, and neither the County nor Jerusalon Township have partici[nted in any exercises. Ilowever, it should also be notel that exercise objectives have never required their participation.

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T 7 Concerning Ottawa County, the County plan previously included REP planning for that part of Port Clinton within the existing 10-mile EPZ. Objectives for prior exercisos provided for appropriate County and city participation.

However, on April 30, 1985, the Ohio Disaster Services Agency (ODSA) subnitted a proposal to FEMA to redefino the 10-mile EPZ. W is proposal, among other things, eliminates Jorusalen Township and the entire City of Port Clinton from the 10-tailo EP2. 20 July 1985 exerciso objectives were prepared based on ODSA's proposed 10-tallo EPZ. %erefore, no objectivos were included for the City of Port Clinton.

Asstaning there is no agreement on excludity; the City of Port Clinton and Lucas County from the Davis-Bosso 10-milo EP2, exercise objectivos for the city and County will be required in the next biennial exerciso.

Finally, I would like to point out that FEMA has notified Governor Colosto and ODSA that the protxxial to redefine the 10-mile EP2 is not acceptable.

Details are contained in the attached letters from FIM\ to the Governor and 006A dated December 9,1985. %e lotters also reference other requirements ,

which must be met in the near future beforu FENA will continue processing Ohio's plans and preparedness for the Davis-Desso sito under 44 CFR 350.

If you have any questions, pleaso contact Mr. Ibbert S. Wilkerson, Chief, Technological Itazards Division, at 646-2861.

Attachments As Stated

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Davis Basse Nuclear Power St ation Toledo Edison Company Joint Exercisa Facility Locat ion: Locat ed in t he St at e of Ohio. Ott awa Count y. near t he Town of Oak liarbor. Ohio.

Exarcise Dat a: July 16. 1985 Dat e of Report : Oct obar 4.1985 Part icipant s : St at e of Ohio ( full scale). Ot t awa Count y ( full scale).

Sandusky Count y (not for evaluation) and t he Toledo Edison Company ( full scala)

Federal Emergency Managnment Agency Region V Nat ural and Technological llazards Division 300 South Wacker Drive Chicago. 1111cols 60606

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\ 1 TABLE OF CONTENTS TABLE OF CONTENTS page 2 EXECUTIVE

SUMMARY

St at e of Ohio pagn 4 Ot t awa County page 6 Sandusky County paga 10 EXERCISE REPORT Int roduct ion

1. Exnreise Background page 12

2. Participat ing and Non-Part icipat ing St at e and Local Governmnnts page 12

3. List of Evaluat ors page 12

4. Evaluat ion Crit eria pagn 13

5. Exarcisa object Ives page 13

6. Summary of Scenario page 16

7. Stat e and Local Resoureen Planned t o be Used in t he Exercise page 19

8. Exercisa Findings In Paet Exercises page 19

9. Exercisa Object.ives St ill t o be Effectively Achinvad page 20 Narrat ive

1. State of Ohio paga 21

2. Ot t awa Count y page 28

SUMMARY

LISTING OF EXERCISE FINDINGS paga 39 State of Ohio

1. Deficiencies page 40

2. Arnas Requiring Correct (,a Act ions page 41

3. Areas Recommended for Improvement page 42 J

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Ot t awa Count y

1. Deficiencies page 43

2. Arnam Rsquiring Correctiva Act ions paga 44

3. Areas Recommended for Improvement page 45 Sandusky Count y

1. Aream Recommanded for improvement' page 47 3

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EXECUTIVE

SUMMARY

Stara of Ohio The St at a prompt ly act ivat ed t heir Emergency Operat ions Cent er (EOC) in Wort hingt on. Ohio by ut ilizing an up-t o-dat e call list . The St at n prnpositionnd the milk sample t eam, t he mobile communicat ion vehicles and st af f, and part of t he field monitoring t eams. The St at e niect ed I o doubin st af f t heir organizat ions to provide additional t raining as wall as demonst rat n t he capabilit y for cont inuous twenty-four hour operat ion. The Stat e provided timely decisions and coordinat ed their activities with t he ot her emergancy responsa organizations. The EOC facilities are adequal e and have the requitad map displays. A st at us board was utiliznd and emergency classificat ion invals were post ad. Tha St at a demonst rat ed primary means of communicat ing wit h t he Federal Agencies, t he Count y EOC t he ut ilit y and t he mobila St at e unit s deployed t o t he cmargency planning zone (EPZ).

The St ain of Ohio demonst rat ed their abilit y to project the done t o t he public based on fleid dat a of plumn pat hway exposures. Using t his informat ion t hey wnre able to nat imat e t he t ot al populat ion exposura. They warn also abin t o implement appropriat e prot ect iva act ions for ingestion pat hway hazards. Ilownver, since t here was no analysis of ingest ion pat hway mamples. t he St ata did not demonst rat a t hnir ability to project the doen t o the public from ingent inn pat hway exposures.

The st af f from t he Ohio Disast er Sntvices Agancy (ODSA) (who were '

pinposit ioned) . t he Ohio Department of public linalt h and Ot t awa Count y (who arrived in real t ime) were all in position 1o perform thalt ammigned dut ies at t hn Emergency Cont rol Cant ar (ECC) (Emergency Operations Facility (EOF)). Tweaty-four hout staf fing capabilit y som demonst rat ed at t he EOF by double st af fing. The EOF was configuind so t hat t he Disast er Services Agency, t he Department of Public Ilealt h and Count y st af f had access t o st at us boards, ut ilit y brinfings and ut ility personnel. Thorn was a thraa part y line for t alecommunicat ions from t he EOF. , t a t he St at a and Ot t cwa Count y EOCs. Additionally, t he st af f at t he Eur maint ained cont act with their EOCm by commercial telnphone.

Thn Stain staf f at t he EOF ammint 9d t he St at e EOC st af f in underst anding ut ilit y recommendat. ions and plant cond it ions . The St at n EOF st af f also t ammistad the Count y lialmon in explaining prot nct ive act ions t o t he Ot t awa Cmint y EOC. Prot ect ive act ions were based upon plant st at us and field t eam informat ion as well as prot ect ive act ion guidas. Tha absenen of radiological probinmu via the ingnation pathway was properly discummed during vary t horough t echnical discummions about rennt t y.

The ODSA members of t he St ain monit oring t eamm warn st aged at t he Finmont Altport wit h t he Fnvit onment al Prot nct ion Agency (EPA) membare tamponding t o that locat ion in -al t ime from Bowling Ctenn, Ohio. Following a brinfing of t he t eam membat e by the t eam Inadar, t hree t eams, each consist ing of Iwo monit oring parsons, were immund prot netivn clot hing and dispalched from thn alt port t o Iheir assignnd areas t a charact erize t hn radiat ion coqjit ions in the arna. The monit oring (name warn dispatched t o t hef t ammigne1 monit oting area wit hin about one-half hout of atrival at Ihe assembly point.

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. Each team was equipped wit h a sampilng kit cont sining wat er sample preservat ion acid. disposable coveralls, polyuret hane boot u. full face reariratots with charcoal filt ers, and sample submission forms for

- identifying samples and requesting analysis from the Department of llealt h laboratory.

The t eams were also equipped with silver zeolit e cart ridges for collecting radiciodine. The radioiodine radiation was count ed using a RASCA1.

Inst rument with a SPA-2 probe biased on the radiciodine radiat ion energies.

Thus t hey were able t o measure small amount s of radicioding in a radiation field without interference from other radiat ion energies. The team leader j displayed familiarity with his radiation inst rument s when he det ect.ed an erroneous reading on t he RASCAL and was able t o correct the malfunction in the field.

The field assessment t eams were supplied wit h spat ula t ools t o collect dirt f rom t he ground surface for analysis. They had garden clippers'for use in clipping veget at ion. They were also equipped to collect water. All sampling procedures were demonst rat ed. The samples of vegetat. ion. wat er and soil collect ed were maint ained for iransport. t o t he laborat ory in Columbus.

Hilk sampling was accomplished in a timely, professional manner by the Ohio Department of Ilealt h. The necessary equipment and supplies were available and co11act ion t echniques were proper and ef ficient .

The Communicat ions Van (Van 1) performed a vit al f unct ion in maint aining continuous communicalions betwenn t he St at e EOC. Count y EOC. the EOF and Joint Public Infotmat f on Center (JPIC) and all monitoring t eams. The communicalions equipment was excellent and was operat ed by trained and experienced personnel. Field t eam communlcat ions were ef fect ive with no interference or dead spot a not ad.

• Radiological exposures of the fisld t nam members were monit ored using self-reading dosimet era and permanent recording devices and were cont rolled by the Accident Assessment Group at Worthington. The field teams were knowledgeable about maximum allowable doses and where and when to go for decontaminallon of personnel. equipment , etc.

The JPIC st af f was praposit ionad in onder to avoid the nacessity of a helicopter flight faom Columbus. The et af f, when not ifled of the Alert condition at t he plant . proceeded wit h the act ivat ion of t he JPIC f acility.

This is in accordance wit h t he wtit t en plan. A media briefing room was also act ivat ed at Ihe Stat a EOC in Wort hingt on so briafings could be conduct ed from t hat locat ion should it become necessary. Briefing mat arlain would be cootdinat ed between the two sit es.

The abillt y t o maint ain et af fing atound t he clock at the JPIC was demonet rat ed by double ut af fing. There were two Public Infotmation Of ficers (P10m) and four support personnel. Only one of Ihe Plos took part in the madia briefings. In fut ut e exercises a shif t changa should be demonst rat ed and both/all Plos should t ake a direct part in t he media briefings. The JPIC f aellit y cont ains all t he necessary work areas for t he ut 111ty Stat e, and County public informat ion staf f and a large briefing room for the media. It also has the nacassary communications. reproduct ion and ot her suppott equipment. The JPIC has t elephone, dat afax and radio cont act wit h the St at e EOC in Wort hingt on, t elephone and dat af ax cont act wit h t he Ot Iawa Count y EOC and t elephone and radio cont act with t he EOF.

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llowever, t he JPIC f acility is immediat ely adjacent t o the power stat ion and even though the building is a protected facility, access to the facility would be cut off should a release occur. During discunnions with Toledo Edison and Stat a personnel it became ' apparent that they were not. in agreement about what would happen should acceum to t he JPIC facilit y be restricted or whern the alternate JPIC would be locat ed. It is recommended that t he urility and the State aet ablish a common alt ernat e JPIC out side the 10-mile EPZ and t hat the Stat e and Ot t awa Count y amend their plans to incorporat e the reunits of this planning.

There were mome delays in clearing materiale for release. to the media and it appeared t o involve t he County rat her than t he St at e. Similar delays were experienced during t he April 13-14. 1983 exercise. The State's spokesperson had good " stage presence", was prepared ana responded well to questions from the floor.

The Stat e. County and ut ilit y staf f met frequently to discuum, coordinate and consolidate Ihe cont ent of releases. A rumor cont rol funct ion was established at t he St ate EOC and responded t o a number of calls. C111s were received and assigned to the EOC staf f membar most qualified to answer the quent ion. The rumor cont rol telephone number van announced at t he JPIC briefings ano in media releases.

The utility and Stat e t etminat ed t he exercise and de-activat ed their staf f ano facilitinn at 1632 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20976e-4 months <br /> anu 1635 hours0.0189 days <br />0.454 hours <br />0.0027 weeks <br />6.221175e-4 months <br /> tempactively. It is recommended t he ut f1it y and St at a not terminate the exercise until all exercise part icipant s agree the exercise should be t erminated.

Oftawa County The EOC was activat ed following notificat ion and verification of an Alert emergency clammification at 0934. Notificat ion was received from t he ut flit y by 't he Ot t awa Count y Sherif f

• m Communicalions Cent er. The dispatcher alert ad t he EOC et af f by activat ing ' pagers and following a telephone call-out list. The notificat ion synt em has around the clock (24-hour) capabilities.

The EOC was operat ional hy 1045 and st af fing won complet e by 1115 wit h t he except ion of two organisat ions. Fort y-one ut af f posit ions were reptement ad and some at af f alt ernat es part icipat ed for ext ra t raining. Twenty-four hour staf fing was demonst rat ed with the present ation of a rooter, t o eliminate an earlier deficiency. Each st af f member was familiar with their assignment and Intcract ed af f actively wit h of her part icipant m. The County P!O was promptly dispatched to t he JPIC t o coordinat e EOC press informat ion. Real time dispalch of the PIO was recommended during the last exercise.

The Execut Ive Group consist ing of Ihe Ot t awa Count y Disant er Services Agency Direct or, t bree Count'y Commissioners, t he Count y Engineer, t he Of t awa Count y Sherif f and a Carroll Township t runt ne (for t echnical advice) was kept '

informed of the situation, formulat ed decisions and briefed EOC st af f. It was not ed t hat t he init int prot act Ive act ion implement ed by Ot t awa Count y was not consist ant with t he ut ilit y prot ect ive act ion recommendat ion in that Of Iawa Count y evacuat ed boat era f rom t he wat are ten miles around the Davis Beame Nuclear power St ation. Several prot ect lve action orders were issued I by ofIawa County in a relat ive short period of time, which could be confusing. It is incommanded t he Ot t awa Count y procedures be reviewed t o see if the frequency of prot ective action recommendat ions can be reduced.

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1. ,a j . The abilit y t o coordinat'e information and decision making between the Ottawa County EOC, t he State EOC, t he ut.111ty, the JPIC. recept ion /congregat e care, decont amination cent ers, and the evacuation of mobilit y impaired was l

demonst rat ed . There seemed to be some problems with coordinating informat ion with Sandusky County af t er Sandusky Count.y activat ed and st af fed their E0C. The pre-exercise agreement between FEMA and the Stat e of Ohio

! was t hat one congregate care facility would be act ivat ed and st af f ed rat her than the four actually activat.ed and staf fed during the exercise. These agreement s need t o be complete and reliable in order for the Fedetal evaluators t o observe all areas to be demonstrat ed.

The new EOC facility is adequale for support ing ext ended amergency operat Lons. All required graphics and displays were post ed. Map displays identifying evacuat ion rout es and relocat ion and care cent ers correct s an earlier deficiency. Haps ident ifying monitoring isoints remained in Ihe done assessment room. This location did not limit the decision making of Ihe EOC st af f because of the f rtquent briefings. Population distribut ion l information was posted in the EOC to correct a deficiency from an earlier exatclue. Ilowever, demographic informat ion neads t o be verified for accuracy. tiessage handling was ef ficient. and EOC access and macurit y was effective.

The primary communicalions syst em int erlinking ihe ut flity. St at e and Count y was Ihe tbree-way dedicated line. Commercial telephones were the means for cont act wit h t he Emergency Broadcast Syst em (EBS), t he EOF, local schools and hospit als aa.1 the Count y represent at ive in t he JPIC. The RACES radio was used for contact with ot h9r E0C's. Two-way radios were t he primary means for contact ing ambulances, monit oring teams, and for back-up t o t he primary syntem (telephone). 'In addit fon, a duplicat e of the high and low band radio console locat ed in t he Sherif f's Communicat ions Cent er is l available in t he EOC. Nat ional Cuard, Stat e Police and Disaster Services radios were also present.. A hard-copy device was operatlonal and linked t he EOC and JP10. All communicalions synt ame funct loned very well. The versat flit y of Ihe synt ems is commendable.

A dose project ion t eam was available in the EOC and was staf fed by St at e, ut 111t y and County personnel. Finid readings co11 meted by State teams were ut ilized t o develop dose calculat ions by both computer and hand comput at ion techniques. Calculat ions wet t e checked against ut ility dat a and found t o be in ' good agreement . Dome project f ons were providad t o the Count y Execut ive Group and incorporat ad int u declulons regarding ptot active act ions. EPA et andards, went her and plant et at us were considered in their decleions.

Ot tawa Count y of ficials simulat ed t he act ivat ion of Ihe prompt alert and not ificat ion syst am ( strens) and the EBS at 1118 and 1120 respectAvaly Io alert Ihe public of t he mit e ates emergency declared by of ficials at the Davis Besse Nuclear Power St at ion as of 1105. A prot act Ive action decision was announced when t he Covernor made a Declarat ion of Emergency.

Public info mat Lon at af f wit hin t he EOC drafIad mat erial and t ransmit t ad hard copies t a t he Ot t awa Count y public info mat inn ut af f locat ed at the JPIC. These same people coordinat ed public instruct ion for broadcast by EBS and t he Nat iona10ceanic and At mosphet ic Agency (NOAA). Prescript ed messages wete used but it was not ad some prescripted snessages reviewed by the Exacut ive Group were alt erad, which addad t o the t ime needed t o t elease these messages.

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e 1 o Pr'orective actions were deveribed in terms of f amiliar boundaries and landmarks. The initial public protective action was within the 15 minutes required in Federal planning guidance. Addit ional public instruct ions were

. coordinated wit h act ivat ion of t he prompt. alert and notification system and were periodically repeatad on the EBS.

Traf fic control point s were est ablished in the field by a coordinat ed ef fort bet ween County and St ate agencies. Assist once was requested from the Nat ional Cuard t o man these point s. Staf fing by the Nat ional Cuard was simulated. The pre-exercise agreement was for a simulation of all field t raf fic cont rol activities. Consequently, t he field 9f fort a were not evaluated.

Ot tawa County was prepared to evacuat e the mobility impaired. A writt en list with special needs was available and updat ed during the exercise with current hospital informat ion. This list was maintained by County' social service personnel. Transportation would be coordinated by t he Count.y Sherif f's dispatcher and carried out by township fire district s.

Arrangem9nt a had 'been made wit h the National Guard for additlonal medical transport.

The Carroll Township Fire Department provided a demonst rat ion of t heir capabilit y t o handle t he mobilit y impaired during an evacuat ion. Upon initiation of public alert ing by Ottawa County, they would verify that all of the mobilit y impaired individuals had ieceived t he emergency information. Then t hay would assist with t he evacuat ion of those mobilit y impaired who raquest assistance. It was readily apparent that all etaf f were knowledgeable of their procedures for conducting the evacuation, maintaining radiological exposute t control. exposure guidelines and the procedures to be followed in the event t hay became contaminat ed. There was some uncertainty concetning t he maximum exposure allowable in life saving situations. The act (vit les demonstrat ed for t he evacuat ion of mobilit y impaired corracts a previous deficiency.

Suf ficient infott.ation had been compiled by t he EOC et af f on milk animals, wat er' intake points and crops t o manage prot action of the ingestion pat hway . This informat ion appeared t o be current and was baund on actual field surveys. All relevant informat ion was incorporat ed into Count y decision making.

Hobilisat ion and staf fing of t he Recept ion Cent er (Fremont-Ross liigh School) and Congregat e Care Cent er-( At kinson School) was pre-arranged and out of sequence with the exercise play. Ilowever, t he st af f e of bot h centers activat ed and ef fect ively responded in accordance with the pre-arranged schedule. The cent ers were staf fed by volunt eer agencias such as t he American Red Close and the Sandusky Valley Amat aur Radio Club, in addit ion to the responsible Count y agencies. The otganisat ions represent ed in the centers were double staf fed and/or provided rosters of personnel for their respect ive organisat ions /agencias t o damonst rat e around t he clock (24-hour) etaf fing capabilit les.

There at e commenclat t elephones (pay st at ions and privat e lines) within t he

! Recept ion Center and th9 School syst em's regular telephone lines at the Congregat a Care Cent er for communicalions wit h all appropriat a localions and organisations. The ie19 phone synt ems at bot h locat ions were supplement ed by two-way radios (base stat ion and portables) operat ed by t he Sandusky Valley Amat nur Radio Club.

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1 o Radiological monit oring personnel at t he Fremont-Ross liigh School Reception Cent er demonstrated procedures for regist rat ion, radiological monit oring and decontamination of evacuees (through the participation of a volunteer family of 't hree individuals). The same volunteer family. upon the directions of reception center coordinators (and an exercise play), were bussed t o the Congregate' Care Center where they were again registered by the Red Cross.

In both instances multi-copy regist rat ion forms were utilized for the registration of evacuees.

The Fremont-Ross High School is adequate for reception and/or congregate care of evacuees, except for mobilit y impaired individuals. The school is void of ramps, rails'and toilet facilities t o accomodate t he handicapped.

The Atkinson School is void of showering and/or bath facilit ies, in addition to being void of facilit les to accomodate the handicapped.

Exposure cont rol equipment was suf ficient for all County field workers.

Personal dosimet ry was provided in =t kit that included inut ructions, dose limitations, high and medium range dvsimet ers, TI.Ds and recond keeping cards. Chargers and geigher coi at era were available in t he EOC. The EOC rsdiological at af f were familiar with the decont ominalion procedures for fiald personnel should the need arise.

The Port Clinton Fire Department demonstrat ed t he procedures for emergency worker decont aminalion. One emergency worker and his vehicle were regist ered, monit ored and dacont aminat ed. The t eam monit oring the emergency '

worker should be aware of proper procedures for preventing Ihe spread of contaminst ion and exhibit great er care in reading t he scale of t he survey Instrumentu.

Ona problem result ed when t he decont amination t eam failed t o t ake t he dosimet era and TLD from an emergancy worker. Consequent ly, bot h I he TLD and the dosimet tre were discarded int o'Ihe cont aminst ed clot hing barrel. The decontaminat ion team demonst rated ef fect ive procedures for the vehicle and emergency worker decont amination, a high degree of prior t raining and t he procedures for their own exposure cont rol.

The JPIC was act ivat ed during the Alert emetgency classificalion betwenn 0932 and 1105. The Ot tawa County represent atives arrived at 1000 . Double staf fing was used Io demonetrat e ability t o maint ain staf fing around t he clock (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) over an ext ended period of (ime but only one person took part in media briefings. The Ot t awa Count y represent at Ives at the JPIC coordinat ed information with the Stat e and Toledo Edison and their JPIC count erpart m. Ot tawa Count y has t elephone and datafax capability between the JPIC and the Ot tawa Count y EOC and by using Stat e equipment have t elephone, datafax and radio cont act wit h t he St at e EOC. The ability to brief the media at the JPIC in a clear and accurat e manner was demonst rated but there were occasional delays in get t ing Ot t awa Count y final concurrence of Ihe message cont ent and t his result ed in delay for some releases.

Similar delays were experienced during the April 13-14. 1983 exercise.

No media briefings were conduct ad at Ihe Ot t awa Count y EOC but media representat ives did make a request t o come int o t he Ot t awa Count y E00 t o take background vidao f oot age and pict ures for t he evening news. The Ot t awa Count y denial was consist ent with their plan concerning EOC access. It is recommended the medla gather this background mat erlat during iraining sessions conduct ed prior to t he agatelse.

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, Recovery and reent ry were not to be evaluat ed during this exercima.

j llowever. Ottawa Count y did conduct recovery and reent ry act ivit ies and t he following comment s are made t o reflect t hese act ions.

The simulat ed accident: at the Davis Besse Nuclear power Plant was de-escalated at 1602 hours0.0185 days <br />0.445 hours <br />0.00265 weeks <br />6.09561e-4 months <br />. Af t er de-escalation by t he ut ilit y and t he St at e.

Ot tawa Count y organized their recoveti and reent ry committ ee t o discusa and develop recovery and reent ry recommendat. ions for t he Execut ive Group. These discussions were ext ensive and complet e which enabled t he Execut.ive Group to quickly conalder the recovery and reentry recommendat ion and t he Execut ive Group decisions were communicat ed prompt ly t o all County response organizat ions and t he 'EBS syst em by approximat ely 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />. This recovery and reent ry play by Ot t awa County will correct a past exercise deficiency.

Sandusky County The Sandusky County EOC in Fremont was activat ed during t his exercise, although act ivity at this location was not t o be evaluat ed. llowever, t he Direct or of the of fsit e federal evaluation t eam visit ed t he EOC t a discuss their role in support of Ihe Ot t awa Count y emet gency response ef fort. The Sandusky Count y operat ing procedut es indicat e t hat t he EOC should be act ivat ed af t er receipt of t he Sit e Area Emergency not ificat ion. The Ot.tava County USA Dir9ct or and Sherif f are responsible for not ifying their i

count erpart s in Sandusky Count y whenever an amargency classificat ion is l (nit iat ed or changed. This dual not ificat ion serves as the means for verificat ion of the emergency st atus wit hin Sandusky County.

During t he exercise, t he Sandusky County DSA Direct or received t he ifnusual Event. Alett and Sit e Area Emergency not ificat ions f rom Ot t awa Count y while at his office. At the Sit e Area Emergency not ificat ion he info med Ot t awa Count y t hat he was relocat ing t o t he Sandusky County EOC which was to be act ivat ed at that time. The Sandusky Count y DSA Direct or verified each of tlieve not ificot ton calls wit h the Sherif f who had raceived similar not if icat ions f rom t he Ot t awa Count y Sherif f.

The Sandusky Count y DSA Direct or indicat ad t hat he did not receive any furt her not ification or informat ion f rom Ot t awa Count y af t er his relocat ion i t o t he EOC. Ot t awa Count y indicat ed t hat t he Sandusky Count y E00 was notified of t he General Emetgency clammificat ion but did not- record t o whom the not ificat ion was made. The ' Sherif f did receive t he proper not ificat ion of the General Emetgency clamst ficat ion and report ed t his Io t he Sandusky Count y EOC st af f. Since he had not received his not ificat ion call, it would have been prudent for ihe Sandusky County DSA Ditact or t o call at t awa Count y t o verify t he General Emergency classifical fon.

According t o the Sandusky County procedures, t he EOC st af f act ivat es t he recept ion cent er for Ot t awa Count y evacuees somet ime af t er t he Sit e Area Emet gency not ificat ion consist ent with ' plant condit ions and t he pot ent ial for an evacuat ion prot ect ive act ion t ecommendat ion. The Sandusky County DSA Ditect or indicat ed that t he recept ion cent er would be (and wan) act ivat ed

! immediat ely upon receipt of t he Sit e Atea l Emergency not i ficat ion t o allow l aufficient t ime t o prepare for t he influx of Ot t awa Count y evacuees who l could arrive within fif t een minut en of t he implement at ion of an evacuat ion prot act (ve act ion i ecommandal ion.

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- The Sandusky Count y EOC staf f indicated that they had not routinely been receiving any informat ion concerning the emergency (other than the classification not ification cited above) from any direct source. The  ;

information t hey had 'was sporalle and obtained by monitoring Red Cros.  !

communications and limited discussions by EOC staf f with their counterparts in other locations. There was insufficient information available in Sandusky County for t he EOC st af f to be fully aware of the emergency' situat ion and the response being implemented.

For example, t he EOC staf f vere unaware that Red Cross personnel were being dispatched ' t o activate fout (4) congregate care shelters rather than just the prearranged congregate care shelter at Atkinson School. The ODSA should riview t he flow of informat ion t o Sandusky County and 't he operating procedures to det ermine an appropriate means for Sandusky County to receive emergency info mation. One recommendation for a possible solut ion would be for Sandusky County to establish a liason of ficer position in the Ottawa County EOC. This liason officer would then be responsible for providing ,

current emergency information to the Sandusky County EOC and answering any questions which might arise in either EOC. If this recommendation is i implemented the communication Links between the EOC's should be reviewed to t insure t..at adequate primary and backup communications are available to t support this 11 anon of ficer posit ion.

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' e EXERCISE REPORT Int roduc t i on

1. Exercise Background This was the third joint. exercise for the Stat e of Ohio and Ott awa County resulting from a simulated accident at the Davis Besse Nuclear Power Station. The first j oint exeicise was on November 6, 1980 and involved full participation by both the State of Ohio and Ottawa County. The second ' joint exercise for the State and Ot t awa County was on April 13-14.'1983 and involved a partial participation by the St at e of Ohio and full part.icipat ion by t he County. This report addresses t he most recent (July 16, 1985) joint full participation exercise for the Davis Besse Nuclear Power Stat ion.

2. Part icipat ing and Non-part icipating St at e and Local Covarnments The t en (10) mile plume exposure EPZ of the Davis Besse Nuclear Power St at ion impact s primarily on Ot t awa Count y. It also impactu on a small portion of Sandusky County, a portion of Jerusalem Township wit hin Lucas Count y, and a port ion of Lake Erie. The St at e of Ohio has submitt ed a proposal t o FTJiA Region V to redefine t he t en mile EPZ. This proposal eliminat es from the plume exposure EPZ t he City of Port Clint on (Ott awa County). the portion of Sandusky County and t he portion of Jetusalam Township (Lucas County). The Crane Creek St ate Park, Crane Creek Experimental St ation and the Ottawa National Wildif fe Refuge remain in the EPZ. FEMA Region V analysis and recommendat ions concerning the ,

proposal has been f orwarded to FEMA lleadquarters for decision. The FEMA lleadquart ers decielon could have an ef fect on what local governments are required to pat t icipat e in Davis Besse Nuclear Power St at ion exercises.

Local unit s of government t hat participated in the July 16. 1985 full patricipation exercisa included Ott awa Count y ( for evaluat ion) and Sandusky County (not for evaluat ion). Lucas County did not part icipat e.

3. .L i s t of Evaluatote For this exercise there was a t otal of eleven Federal evaluat ors observing of f-sit e exercise activities. On-sit e activities were evaluat ed by a sapat at e t eam from t he Nuclear Regulat oty Commission (NRC). Of t he of f sit e evaluators, five, including the of f sit e Exercise Evaluat ion Team Direct or, were Federal Emergency Handgement Agency (FEMA) R9sion V st af f. The balance of t he t eam was composed of tapresent atives (one each) from t he Depairment of Energy (DOE), the Environment al Prot ection Agency (EPA), the U.S. Depart ment of Agriculture (USDA). the Amattican Red Cross ( ARC) and two cont ract.

avaluat ot e f rom the Atgonne Nat ional Laborat ory ( ANL).

The evaluator assignmant a were as follows:

Of f-site Exercise Evaluallon Team Direct or Wallace Weaver, FEMA 12 l

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. State of Ohio Evaluation Team Robert. Shapiro, Team Leader, FEMA, Stat e EOC Cindy-Bcggs-Mayes, DOE, Stat e EOC Ray Kellogg. FEMA, JPIC James Opelka, ANL, EOF Pet e Tedeschi, EPA, State Field Monit.oring Team and ODSA Communications Van (Van 1)

Robert Coniny. USDA, ODSA Communications Van (Van 1) and ODil Milk Sampling Collection Ottawa County Evaluation Team Dan Bement, Team Leader, FEMA, Count y EOC Sue Ann Curtin, ANL, Count y EOC Woodie Curtis. FEMA Rec?ption/ Congregate Care Centers Walt er O'Keefe. ARC / FEMA Evacuation and Decontamination Ray Kellogg, FEMA, JPIC

4. Evaluation Crit eria The plans that were evaluated by this exercise were developed using the

" Crit eria for Preparat ion and Evaluat ion of Radiological Emergency Response Plans and Preparedness in Support of Nuclear ' Power Plant s" (NUREC-0654 / FEMA REP-1, Revision 1) . Therefore. 't hese criteria and the modules based on t hese crit eria ent it led. " Modular Format for Uniformit y of Radiological Emergency Preparedness Exercise Observations and Evaluat ion." dat ed June '1983, were used for' exercise evaluation.

5. Exarcise Object ives Objectives f or this exercise were select ed f rom among t he FEMA t hirt y-five (35) st andard objecfives listed in Tab "M" of t he " Modular Format for Unifatmity of Radiological Emergency Preparedness Exercise Observat ions and Evaluat ions," dated June 1983. The object ive numbers list ed below correlate to Tab "M".

The Stat e of Ohio select ed t he following nineteen (19) objectives, including t hose appilcable to t he JPIC, to be demonst rated during the exercise.

1. Demonst rate abilit y t o mobilize staf f and activat e facilities prompt ly.

2. Demonst rat e abilit y t o fully st af f facilities and maintain st af fing around t he clock.

3. Demonst rat e abilit y I o make decisions and t o coordinat e emergency ac t ivit ie s.

4. Demonst rat e adequacy of facilities and displays t o support emergency operations.

! 5. Demonst rat e ability t o communicat a with all appropriat e locat ions, l organisat ions, and field personnal.

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l , 7. Demonstrate appropriat e equipment and procedures for determining ambient radiation levels.

8. Demonstrate appropriate equipment and procedures for measurement of

, airborne radioiodine concentrations as low as 10-7 uCi/cc in the l . presence of noble gases.

9. Demonstrate equipment and procedures for collection, transport, and analysis of samples of soll, vegetation, snow,' water, and milk.

l 10. Demonstrate ability t o project dosage t.o the public via plume l exposure, based on plant and field data, and to determine appropriate protective measures based on PAG's, available shelter,

evacuation time estimates, and all ot her appropriat e factors.

11. Demonstrate ability to project dosage to the public via ingestion pat hway exposure based on fiAld dat a and t o determine appropriate protective measures, based on PAG's and.other relevant factors.

l 12. Demonst rat e ability to implement protective act. ions for ingestion l pathway hazards.

i i 13. Demonstrat e abilit y to alert the public within the 10-mile EpZ. and disseminate on initial instructional message, within 15 minutes.

14. Demonstrate abilit y to formulate and distribute appropriate l instruction t o the public, in a t imely f ashion.

i Demonstrat e ability t o continuously monitor and control emergency 20.

worker exposure.

24. Demonst rat e abilit y I o brief the media in a clear, accurat e and l

timely manner.

25. Demonstrat e abilit y t o provide advance coordination of information released.

26. Demonst rat e abilit.y t o establish and operate rumor cont rol in a l coordinat ed fashion.

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32. Demonstrate ability to identify need for. request and obtain Federal assistance.

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34. Demonst rat e abilit y t o est imate tot al populat ion exposure.

Ot t awa Count y select ed the following t went y (20) objectives to be demonst rat ed during the exercise. The County actually selected nineteen (19) object.lves prior t o the exercise. Credit is being given for their recovery and reent ry act ivity.)

1. Demonst rate abilit y t o mobilize si if f and act ivat e facilit ies p rompt ly .

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2. Demonstrate ability to fully staf f facilities and maint ain staf fing around t he clock.

. 3. Demonstrate ability to make decisions and to coordinate emergency '

activities.

4. Demonstrate adequacy of facilit ies and aisplays to support emergency operations.

5. Demonstrate ability to communicate wit h all appropriate locat ions, organizations, and field personnel.

10. Demonstrate ability to project dosage to the public via plume exposure, based on plant and ' field data, and to determine appropriate protective measures based on PAG's, available shelter, evacuation time estimates. and all other appropriate factors.

13. Demonstrate ability to alert the public within the 10-mile EPZ, and disaeminat e an initial inst ructional message, within 15 minutes.

14. Demonst. rate abilit.y to formulat e and dist ribute appropriat e instruction to t he public, in a timely fashion.

15. Demonstrat e the organizat ional pb!1ity and resources necessary t o manage an orderly evacualion . . . or part of t.he plume EPZ.

16. Demonstrate t he organizational ability and resources necessary to deal with impediments to evacuatior, at inclement. weat her or traffic obstructions.

17. Demonst rat e the organizational abilit y and resources necessary to cont rol access to an evacuated area.

18. Demonst rat e t ha organizat ional ability and resources necessary to ef fect on orderly evacuation of mobility-imp,11 red individuals within t he plume EPZ.

20. Demonst. rate abilit y to continuously monitor and cont rol emergency worker exposure.

24. Demonstrate ability to brief t he media in a clear, accurate and timely manner.

25. Demonst rat e ability I o provide advance coordinat. ion o8 information released.

26. Demonstrat e ability t o establish and operat e rumo- t s ' trol in a coordinated fashion.

27. Demonstrat e adequacy of procedures for regist ratanw ehd radiological monit aring of evacuees.

28. Demonst rat . adequacy of facilit les for mass care of evacuees.

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. 29. Demonstrate adequate equipment and procedures for decontamination of emergency workers, equipment and vehicles.

. 35. Demonstrate ability to determine and implement appropriate measures for controlled recovery and reentry. (Even though the recovery and reentry objective'was not to be demonst rated during this exercise, the demonstration by Ottawa County observed by the Federal evaluation team was so complete that credit for this objective is being noted.)

6. Summary of Scenario The Davis Besse Nuclear Power Station radiological emergency preparedness exercise objectives and scenario for the July 16. 1985 joint full participation exercise were ' developed by exercise planners from the Davis Besse Nuclear Power Station and the St ate of Ohio Disaster Services Agency. The exercise planners did not participate in the exercise and protected the scenario from the participants of the exercise 'so they would 'not be aware of the scenario events.

FEMA Region V conducted discussions with the utility and State planners in March 1985 to select the' objectives and determine the scope of the exercise. Review of previous ex5rcise deficiencies were made by FEMA Region V and t he scenario writers in order to ddvelop a scenario that would allow demonstration of past axercise deficiencies as well as allow demonstrat ion of exercise objectives selected by the exercise participants.

During the pre-exercise scenario development. period it was decided to emphasize the alerting, mobilizat. ion and activation of staff and not emphasize or evaluate the recovery and reentry portion of the exercise.

Therefore t.he scenario was developed on t he assumption that Ot tawa County would not be able to eliminat.e the recovery and reentry deficiency (M.I .) identified in the April 1983 exercise. However, the Ottawa County demonst ration of recovery and reentry was so complete it was agreed by the Federal evaluation team to give Ottawa Count y credit for demonstrating corrective actions for this past exercise deficiency It is st ill recommend 4d the next scenario be ddvaloped to (M.I.).

emphasize and have evaluated the recovery and reentry portion of the exercise.

Submission of the scenario was according to deadlines outlined in Nuclear Regulat ory Commission (NRC) and Federal Emergency Management Agency (FEMA) guidelines. Westinghouse Idaho Nuclear Company.

Incorporated reviewed t he of f-site portion of t hd scenario' for FEMA and found it to be adequat e to exercise the objectives selected by Ottawa Count y as well as those select ed by the Stat e of Ohio.

During the evaluation of this exercise the scenario was found to be adequat e to init iate emergency response operations by t.he Stat e of Ohio and Ottawa Count y. The Federal evaluation team was able to evaluate the capability of both t he State of Ohio and Ot tawa County. The scenario did allow for the demonstration and evaluation of the objectives selected by the Stat e of Ohio and Ottawa County for t he July 16, 1985 exercise.

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. The scenario provided additional experience and training for milk sampling personnel. The scenario also provided an excellent demonstration of effective ' communications with the use of " Van 1".

As an initial condition for the exercise, the reactor is simulated to be near the end of core life and with higher than normal reactor coolant activity: dose equivalent Iodine 131 activity is 0.9 uCi/ gram 'which is -

just below the Technical Specification' limit of 1.0 uCi/ gram. This activity is the result of fuel " leakers" which have been getting progressively worse over the past several weeks. In order to minimize the potential for exceeding the Technical Specification limit, chemistry and health physics (C&llP) personnel are sampling the reactor coolant system every four hours.

The initial meteorological conditions include a tornado watch which is in effect for Lucas, Wodd, Sandusky and Ottawa Counties until 1000, July 16, 1985. At 0845 (00/15), a tornado will be seen to touch down onsite. The sighting will be in the southeast corner of the site and the tornado will be heading out toward the lake. There will be some minor damage to the sewage treatment plant but no effect on plant operation. Sighting of the tornado onsite is cause foi- declaration of an Unusual Event by the shift supervisor.

By 0930 (01/00) the reactor coolant system (RCS) leak rate has increased to 70 gpm. Per EI 1300.01, a leak rate of 50 gpm is the emergency action level for an Alert. Given the elevated RCS activity, this leak rdre results in increased containment radiation levels, indicated on RE 4597. The control' room receives " Containment RAD HI SFAS Ch'l/2" alarms (radiation levels 1.5 times higher than normal background levels). By 0945 (01/15), when containment radiation levela reach 1.8 times greater than background, they will receive indication of a safety actuation Level l ' isolation. This actudtion isoldtes the containment 'and starts t he emergency ventilation system (EVS) to maintain a negative pressure in the containment annulus.

Containment radiation levels continue to increase gradually as a result of the RCS leakage until approximately 1045'(02/15) when the following sequence of events occurs:

Immediat ely following an excessive vibration alarm on react or coolant pressure (RCP) 1-1,'the impeller separates from the shaft, causing significant damage to both the impeller and the pump casing. These vibrations weaken the weld on the discharge piping df the pump. (This weld is the source of the increas.ed RCS leakage, and will progressively worsen until 1200 (03/30), when a double-ended rupture of the cold leg piping occurs.) Debris from the impeller and casing will be carried into she react or core, resulting in damage to the cladding, and a release of gap' activity to the RCS. and subsequently, to the containment.

The accident results in a reactor trip, but six rods fail to fully insert due to the debris. The operators will initiate emergency boration to increase the shutdown margin.

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4 As a result of the fuel cladding damage and the increased leak rate f into the containment, thd radiation monitors (RE 4597) indicate I rapidly increasing levels of radioactivity in the containment. By l

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1000 (02/30), containment radiation' levels will exceed 3000 R/HR,

equivaleat to a release of approximately 50% of the gap activity in

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the core. Per EI 1300.01, this level of radiation, togerlier with an SFAS (safety features actuation system) function activation, will prompt the declaration of a Site Area Emergency.

At 1115 (02/45) a C6HP technician assisting with the analysis of a reactor coolant system (RCS) Esmple spills the liquid and becomes contaminated on'his left forearm, leg and hand. Monitoring and decontamination procedures are initiated, per Health Physics (HP) 1602.01 and HP 1604.01. Initial washing of the contaminated area will reduce the levels, but a second washing will be tiecessary to eliminate j the contamination. (This d5 contamination process will only be

! discussed / simulated by participants.)

i A large-break (8.5 f t 2) loss of coolant accident _(LOCA) occurs at 1200 l (03 /30) . The blowdown momentarily uncovers 't he reactor core before it is reflooded by core flood tanks and low pressure injection (LPI), and additional core damage occurs at this time.

p, Monitor RE 4597 (containment radiation monitor) reflects significantly increased radiati5n levels in the cont ainment and, by ~ 1205 (03/35),

! thine levels will be >60,000 R/IIR. With containment pressure elevated as a result of the rupture, this will result in declaration of a General Emergency.

As a result of the system rupture, containment pressure exceeds design j limits (36 psig) and the containment integrity is breached. The station l vent effluent radiation monitor indicates that a minor ~ release of radioactivity to the environment has begun. Due to continued exposure

to a high t emperature and humidity environment, the flow through t his breach increases. At 1230 (04/00) a step increase occurs; a major i release is now in progress, and new dose projections'and protective action recommendations should be initiated. The peak release rates, dose rated and integrated doses are as follows

Release rates 6.06 uCi/sec Xe 133

(-1300/04/30) 1.2 ES uCi/sec 1 131 Maximum child thyroid dose rate (2 miles) 8.9 Rem /hr Maximum int egrated t hyroid doses l

(based on 2 hr. duration)

Unprotected 17.8 Rem Shelt ered 16.02 Rem Evacuation 17.8 Rem i Maximum whole body 52.0 mr/hr dose rate (2 miles) l 18

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. For this postulated release pathway, the iodine doses are more limiting, and provide the basis for all protective actions.

- The release will continue until 1430 (06/00), and will decrease at a rate consistent with depressurization of the containment. Since containment pressure provides the driving head for the release,' as pressure decreases, the release rate will decrease as well. By 1430, the containment is depressurized, and, with fhe reactor in cold shutdown, the release is terminated.

9 The wind, for the duration of the release, is at 2 mph, and is blowing from approximately 72 degrees, and the stability class is "D" (neutral).

Immediately thereafter, the wind speed increases to 10 mph, and by 1500 (06/30) the plume is dissipated, and all radiation levels within the ten mile EPZ are at background. Participants should discuss downgrading the emergency classification, and initiate reentry and recovery discussions. Following these discussions, the exercise will be terminated at 1600 (07/30).

The actual events followed the pre-exercise scenario. The Unusual Event was declared at 0849, the Alert at 0931. the Site Area Emergency at 1105 and the General Emergency at 1207. Recovery and reentry was not an objective selected to be demonstrated during the exercise and therefore was not demonstrated by the State of Ohio. Ottawa County chose to demonstrate recovery and reentry within the EOC and was given credit for the demonstration. The simulated accident at the Davis Besse Nuclear Power Stat ion resulted in both sheltdring and evacuation protective action recommendations. There were three orders to shelter issued at 11'12, 1220 and 1255. Two evacuation orders were issued at 1220 and 1255.

7. State and Local Resources Planned to be Used in the Exercise The State of Ohio planned to staf f and demonstrate the State Emergency' Operations Center (EOC) in Worthington, Ohio; the Joint Press Information Center (JPIC) at the plant site (located near Oak liarbor);

the Emergency Control Center: Emergency Operations Facility (EOF) also located at the plant site; the Stat e Disaster Service Agency's Communications van, and the Field Assessment teams.

Ottawa. County planned to demonstrate its Emergency Operating Center, the Joint Public Information Center, reception /congrdgate care centers and decontaminafion center. The County also chose to demonstrate its capability (simuisted) to activate the prompt alert and notification systems, the emergency broadcast system, access control, and evacuation of a part of the plume EPZ.

8. Exercise Findings in Past Exercises There were no deficiencies noted for the State of Ohio and Ottawa County during the radiological emergency preparedness exercise of April 13-14, 1983. There ware seven areas requiring corrective actions as identified for the State of Ohio and six areas requiring corrective actions as identified for Ottawa' County during the evaluation of the April 13-14, t

1983 joint participation exercise for the Davis Besse Nuclear Power Station.

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Six of the seven areas requiring corrective actions by the State of Ohio were. demonstrated during this exercise'(July 16, 1985) with the remaining one, NUREC 0654 Criteria item M.3 being partially demonstrated. The six areas requiring corrective actions by Ottawa County were fully demonstrated during this exercise.

There.were ten areas recommended for improvement to the State of Ohio and thirteen for Ottawa' County during the April 13-14, 1983 exercise.

The recommendations were in the areas of plans, training and resources.

While " areas recommended for improvement" d,id not require a Schedule of Corrective Actions and were not tracked by FEMA, these recommendations for improvement were reviewed during the July 16, 1985 exercise to determine if appropriate actions had been implemented.

During the exercise the Stnte of Ohio effectively demonstrated nine of the aforementioned ten areas recommended for improvement. Ottawa County effectively demonstrated twelve'of the thirteen areas recommended for improvement.

9. Exercise Objectives Still to be Ef fectively Achieved Because of the weaknesses noted elsewhere in this report, the following exercise objectives were not completely demonstrated. Appropriate action will b4 required to correct the exercise deficiencies and these objectives must be successfdlly demonstrated during the next radiological emergency preparedness exercise for the Davis Besse Nuclear Power Station.

The State of Ohio did not completely demonstrate the following objective:

11. Demonstrate ability to project dosage to the public via ingestion pathway exposure, based on field data.

Ottawa County did not completely demonstrate the following objective:

20. Demonstrate ability to continuously monitor and control emergency worker exposure.

.The following exercise objective has not yet been completely demonstrated by thE State of Ohio in the current exercise cycle:

35. Demonstrate ability to determine and implement appropriate measures for controlled recovery and reentry.

'The following three exercise objectives have not yet been demonstrated by Ottawa County in the current exercise cycle:

19. Demonstrate the organizational ability and resources necessary to effect an orderly evacuation of schools within the plume EPZ.

30. Demonstrate adequacy of ambulance facilities and procedures for handling contamina6ed individuais.

31. Demonstrate adequacy of hospital f acilities and procedures for handling contaminated individuals.

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. ' Narrative

1. State of Ohio Activation and Staffing At 0849 the ODSA was notified of an Unusual Event at the Davis Besse Nucient Power Station. Staf f members were notified by use of up to date telephone call lists to report to the State EOC. During a real emergency, the staff would report to the EOC at the Alert notification but due'to the time compression of the exercise they were asked io report upon declaration of the Unusual Evenf. Staffing of the EOC was completed in approximately one hour and thirty minutes, with most reporting to the EOC within an hour. The two ODSA representatives at the EOF were prepositioned but began to perform their duties at the EOF about the time they would have arrived from Columbus. The representative from the State Public Health Department arrived at the EOF in real time (at approximately 1100). All required personnel were present at the EOF to assist in dose assessment and decision making.

The EOF staff would be notified in Columbus by use of a pager or telephone call-up lists.

.By 0931 the situation at the station had escalated to an Alert due to a reactor coolant leak. At 1050 the State monitoring teams were deployed to the EPZ from their staging areas and began monitoring procedures.

When radiation levels further increased in the containment facility, a Site Area Emergency was declared 'st 1105 and thd State recommended sheltering dairy animals within a two mile radius of the plant. A

" State of Emergency" was declared by the Governor, and at 1115 the State recommended to the County that they shelter their populace in subarea 1.

A General Emergency was declared at 1207 and at 1214 the State recommended to thd County shat they shelter the populace in subareas 1, 2 and 6a. These protective action recommendations were well within the 15 minute response time and corrects a significant deficiency cited during the 1983 exercise. The State demonstrated around the clock (24-hour) staffing capability at the EOC by double staffing and all members displayed ext ensive training and ability to execute their emergency response dut ies. Twenty-four hour staffing ct the EOF was demonstrated by ODSA also through double staffing. However, leadership and responsibility remained with the ODSA Chief of Staff at the EOF throughout the exercise. Twenty-four hour staffing was not directly demonstrated by Public Health but other members of Public Health were at the local EOCs and could presumably have served at the EOF.

Emergency Operations Management The Deputy Director of the Ohio Disaster Services Agency was effectively in charge of the em vgency and ensured that appropriate response procedures were implemenfed. This corrects a deficiency cited during the ' Davis Besse exercise of 1983.

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. Hourly status briefings were conducted and efficient message handling

_ procedures utilized to ensure that. t.he EOC staff was kept current on the status of the emergency. Some minor recommendations were made to the staf f, such as _asking some of the staf f members to speak up so that they could be heard by all when giving their reports. These recommendations were given in a spirit of improving the briefing procedures which were effective.

The State demonstrated their capability to request Federal assistance from the Department of Energy and the Federal Emergency- Management Agency. This was done by the Governor's liaison who requested assistance from these two agencies as outlined in the Federal Radiological Emergency Responsd Plan (FRERP) and the Federal Radiological Monitoring and Assessment Plan (FRMAP).

~ Facilities The State EOC, which is located in the basement of the Ohio Army National Guard Armory in Worthington, Ohio, is a federally certified facility and has sufficient amenities to support the EOC staff for ex5 ended periods of time. This capability has been demonstrated during actual emergency and several previous exercises. The configuration of the workplace at the EOF was set-up so that all the Stdre and County staff had ready access to utility personnel and displays as necessary to understand the emergency situation. The use of headsets minimized the noise level in t.he EOF.

Appropriate maps and charts displaying such information as evacuation routes. relocation centers, radiological donitoring points, access control points, etc. were conspiciousiy displayed in the EOC for use by the emergency staff. This ~ corrects an earlier deficiency reported during the i983 Davis Besse exercise.

Communications i The State EOC as well as the mobile communications units dispatched to the local area near Davis Besse provided thd necessary primary dnd alternste communication systems to implement emergency response procedures involving all response organizations. Thd State demonstrated the ' primary means of communicating with Federal Agencies, the County EOC, the utility and the mobile State units deployed to the EPZ.

At the EOF communications of essential emergency nuclear incident information. status board data, release rates and projected' dose rates were sent to the State and Ottawa County EOCs via dedicate'd three party teiephones. This telephone was manned at the EOF by a utility reprasentative. When necessary, information was sent to the State EOC from the EOF via telefax. Commercial telephone lines were often used between the State EOC and the EOF to discuss plant status and dose assessment procedures. The County liais6n at the EOF was also in touch with the County EOC via commercial telephone.

The Ohio Disaster Services Agency deployed a communications van (Van 1) for the exercise which was locaded in Ott.awa County. The van is well equipped with the following:

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2 HF Band Radios 2 VHF Low Band Radios

'l Mobile Telephone

. 1 VHF Repeater-4 Hand' held radios (portable)

The van was in continuous communication with the EOF, JPIC, Ottawa County EOC, State EOC and the field teams. Personnel operating the equipment were experienced and professional. The communications van is capable of 24-hour oper5tions. Message logs and f5rms were effectively used. Van I can also communicate directly with the Sheriff's Net, National Guard Net and'the St5te Police. Van I was a vital link in the communications system for the exercise. Overall communications were excellent.

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Dose Assessment and Protective Action Recommendations Dose assessment and protective action recommendations were accomplished at the State EOC with assistance'from the State staff at the EOF.

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The State staff at the EOF were constantly in touch with the utility staff concerning underlying reason 5 for the utility' decision making progress.

Both the utility and the State were making protective action decisions, using both the EPA guidelines and plant status evaluation, and field team monitoring data. As soon as the utility made a protective action recommendation, the ODSA Chief of Staff in the EOF was in touch with the State EOC. He answered questions and in one case reminded the State of t.he fifteen minutes time limit for a State decision.

Most dose projections were based on plant release data coming from the utility. One dose projection using field monitoring readings was calculated. This was because only one iodine reading was greater than background levels. The projected doses were promptly calculated using a computer. These values were tihen checked against both'the utilities dose projections and the State's hand-held calculator estimates. All three dose ' projections were in close agreement.

Field monitoring data was plotted on the map and the field teams were directed to go to new locations as required by the Accident Assessment Group ( AAG), through the' State's communications van. 'The plume data which came into the AAG at the State EOC' included windspeed in m/sec and wind direction. No problems were encounter 5d in understanding the wind direction terminology.

Recommended Improvement: The State include the time radiation readings were taken on their field monitoring 86atus board.

Field team data was reported promptly but it was not always promptly entered on the field monitoring status board. Periodic estimates of doses to personnel in the af fected areas were updated regularly. The adequate demonstration of this' objective corrects the State's previous deficiency to periodically estimate' total' population exposure noted at the last Davis Besse exercise.

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Protective action recommendations were made and based on both plume and ingestion paihway hazards. Protective actions included the sheltering of lactating dairy cattle out to two milds, placing them on stored feed,

, and watering them with ground water whenever possible. These actions demonstrated the State's ability to adequately implement protec{ive actions for ingestion pathway hazards. However, the State did'not ddmonstrate their ability to project the dose to the public through the analysis of ingestion pathway samples such as water, milk,' crops etc.

Required Corrective Action: NUREG 0654 criteria J.ll Since there was no analysis of ingestion pathway samples, the State did not demonstrate the ability to project dosage to the public via ingestion pathway exposure.

Recommendation: .During the next joint exercise the State should collect

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and analyze pathway samples and demonstrate the ability to project dosage to the public via ingestion pathway exposure.

The State adequately demonstrated their ability to estimate doses from plume exposure to the public based on appropriate plant and field data.

This corrects the State's previous deficiency to adequately demonstrate their. capability to provide recommended ' protective actions.

The State followed their plan and their SOPS in implementing protective action decisions. Protective action recommendations were updated and reviewed as conditions changed.

The use of potassium iodide (KI)was not recommended for the public or emergency workers during the exercise. The Ohio EPA was the only organization which sanctioned the'use of KI for their workers at the timeoftheexer(ise. ~However, subsequent to the exercise the Ohio Department of Health announced that planning is being developed for the distribution of KI to other' emergency workers and institutionalized persons for use in the event of a nuclear power plant accident involving a radiological release. EPA personndl are screened before hand for their intoldrance to KI. EPA personnel are instructed to take KI tablets before going into the affected sectors or areas. The decision cancerning the use of KI durirg thE exercise was consistent with 'the guidance in the State's plan.

Field Monitoring Mobilization was not observed because the field assessment teams were assembled in Columbus and drove to the Fremont Airport where they were joined by the observer. Three teams, consisting of two monitoring persons-per team, were dispatched to their assigned monitoring stations from the airport. Each team was equipped with the necessary equipment <

and materials to assess the radiation contamination conditions in the zone of interest. The State'demonstraied that it can assemble the required number of field monitoring personnel and move them and their equipment into the zone of interest in a timely manner.

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. The field assessment team observed was familiar with their equipment and its use. They had no problem setting up the equipment for measuring the radioactivity of int erest. Sample collection procedures for environmental samples were in accord with EPA techniques, including the fixing of water samples with nitric acid. The team was familiar with the area assigned to them and found their monitoring points easily.

Calibration information for instruments was included in the team kit .

The instrument cases are sealed with marked tape so that any opening of the case before its use in the field can be detected and the case can be checked for proper contents and the instruments can be checked to make sure they are working properly.

Recommended Improvement: The State followed their rediological survey S0P and took reading at belt height. It is recommended that'these procedures be changed t.o include an instrument survey at ground level for deposit ion 'of radioactivit y.

Communications between the controller and the field monit.oring teams was goci. Communication was maintained throughout the exercise with no interference and no dead spots noted. Transmissions were clear and signals were strong. A backup communication system was not demonstrated.

Each team sampling case cont.ains the necessary equipment for environmental sampling. Also included in the case are protective clothing including poly gloves and poly boots, a full face respirator with charcoal filters, and disposable coveralls. Forms for submitting samples to the Health Department for analysis are also included. The forms are completed at the time the samples are collected. Calibration information for the instruments is also included. Team members were supplied with appropriate personal dosimetry and instructions on the use of t he dosimeters. Team members were knowledgeable in the use of dosimeters.

Field Monitoring (Milk Sampling)

Actual call up and activation of the milk sampling team was not observed as the person was dispatched from the Ottawa County EOC and met the evaluator at the Fremont Airport. However, in an actual emergency there is a mobilization call list which can be activated very quickly by the Ohio Department of Health in the event of a radiological emergency.

They have written procedures, including a mobilization call up listing, and each individual has emergency cards with names of key individuals and phone numbers.

The Department of Health person deployed for milk sampling had all the necessary equipment to accomplish the assignment. Equipment included a dipper, funnel, bucket, plastic containers, labeling pens, boots, plastic gloves, ice chest, measuring cup and chemicals for cleaning utensils and preserving the milk.

The State vehicle used Lor collecting the samples and storing the equipment was small but adequate. The vehicle did not have a two way radio and communications was accomplished by telephone. Overall the equipment for milk sampling was adequate.

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The milk sampling team member demonstrated proper and ef fective procedures for milk sample collection. The person was familiar with the area where the sample was collect ed and used a complete writ ten procedure and followed it exactly. .The entire milk sampling operation tooli one hour which included driving to and from the dairy farm. The sample was taken to thd Ottawa County EOC in accordance with instructions. Overall the technical operations were very good.

The milk sampling team member was familiar with proper exposure control procedures. A kit included TLD, a high range 0-200R CDV-742, a mid range 0-20R CDV-730, written procedures and a radiation exposure control form. KI was not in the kit but'the team member was familiar with its usage from a training session. The team member was knowledgeable of decontamination procedures if necessary. Overall exposure control for milk sampling was adequate.

Public Alerting and Instruction Activation of the siren system and EBS is a local responsibility in Ohio. The State action under this objective id to support the County by confirming, through the EOC the emergency conditions necessitating Eheltering in place and evacuation. The County's implementation of the protective action recommendation to alert the public within the 10 mile EPZ and to disseminate an initial instructional message within fifteen minutes will be addressed in the Ottawa County portion of this report.

Protective Action Evacuation activities such as activation of reception centers, congregate care facilities, relocation of specIa1 needs individuals and access control are'the responsibility of local government. The State through the EOC was responsible to project dosage to the public via ingestion pathway exposure, based on field data as agreed during exercise pre planning between the State and FEMA.

Radiological Exposure Control The State EOC is not within the 10-mile EPZ, but dosimetry was distributed from the EOC. Dosimetry including low. medium and high range self reading dosimeters and TLDs, was available to the field teams which reported to and were controlled by the AAG. The ACC were also equipped with dosimeter chargers and record keeping cards for recording dosimeter readings. Appropriate instructions were given to the field teams on the use of this equipment.

Ohio EPA personnel were supplied with KI and were aware of its proper use. Field monitoring teams were aware of dose levels requiring authorization and were knowledgeable about where and when to go for decontamination of persennel, equipment, etc.

Media Relations Maps to support briefing of the media in the State EOC media briefing i

area were available with 10 and 50 mile " rings" but did not display evacuation routes. No briefings were conducted at this site.

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i f o Rumor control was staffed at the State EOC. Concerned citizens calling were requested to indicate their concern and provide a telephone' number. The appropriate staff members best qualified to respond to this person, called back and provided the information directly. Appropriate logs of the calls'were maintained.

The State of Ohio, Ottawa County and Toledo Edison were represented in the JFIC. The State staff was prepositioned for this exercise. They were double staf fed to show a two shif t capability. The JPIC facility, located on the plant grounds, is well designed for this use. It'has all the necessary and required space and equipment for both the PI0s and the media representatives. The stdff arrived at the JPIC at 1025. The activation approximated normal arrival time from Columbus following activation procedures.

The building has feeding and sleeping facilities for the staff and an adequate protection facte- to allow for extended staf f operations af ter a release. Once a reles&_ has occurred, access to the JPIC will be terminated. Utility representatives at the'JPIC indicated they would continue to prepare and coordinatt releases at the JPIC, although 6riefings would be held 5t a utility facility in Toledo. The State indicated they would establish an alternate Media Center at a Junior High School in Port Clinton. The State plan does not provide for an alternate media center; nor do the State and Toledo Edison have common planning for an alternate JPIC.

Recommended Improvement: The utility, the State and Ottawa County should establish a common alternate JPIC outside the 10-mile EPZ and that the State amend their plan to incorporate the results of this plcnning.

The State public affairs staff at the JPIC has telephones, telefax and radio capability for communication with the State EOC in Worthington.

They have telephone and telefax capability with the Ottawa County EOC.

They have telephone and radio capability with the EOF although the EOF is in the same building. They'also have radio capability with the communications van and field monitoring teams.

There were at least seven briefings held at the JPIC during the course of the exercise. During the briefings plant conditions and the status of State and local emergency response and protective actions were discussed. Hard copy of statements were availa61e including EBS releases. State, County and utility personnel coordinated and consolidated statements prior to their release.' The State and County representatives made good use of maps during presentations. The one person that functioned as spokesperson for the State had good stage presence, was knowledgeable of the matters being discussed and responded well t5 questions from the media.

Recommended Improvement All State spokesperons/public information officers at the JPIC (1st and 2nd shifts, etc.) should be involved in briefing the media.

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... While EBF messages were not prepared at the JPIC they were read at-.

. briefing's and hard copy released to the media. The rumor control telephone numbers wire included in releases prepared at thd JPIC.

Recovery and Reentry Recovery and -reentry aspects were not objectives for this exercise.

ThEre was a pre-exercise 5greement that thdre would be a limitsd

- discussion between the State and the County of recovery and reentry to bring the exercise to a logical point of termination. The State

. terminated thelexercise at 1632 when the utility and State recommended

- recovery and reentry. The State of Ohio deactivated their stdff.and

- facilities even;though Ottawa County requestdd information from the State.

Recommended Improvement: Although recovery and reentry was not to Se evaluated it is recommended that the State and utility do not terminate the exercise until'all exercise participants are at a point where termination of the exercise is agreed.

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2 .' Ottawa County Activation and Staffing The' declaration of' an Unusual . event occurred at 0849 and notificat ion of

.this incident was received by the Ottawa County Sheriff Dispatcher at

-0850. Aotification was made by the utility over the dedicated ' telephone and verification was completed. A form was used to record this information as was recommended during the last exercise. The dispatcher activated pagers belonging to four key EOC operations staff (Sherif f,'

State radiological analyst, Disaster Services Agency Director, and

' County Engineer). In addition, the Carroll Township Police Chief and Ohio DSA were also notified by the Dispatcher.

The EOC was promptly activated following notification of an Alert at 0934. The same notification and verification procedures demonstrated for the Unusual Event were activated again. However, the cell out lists

-were more extensive. Pagers were activated by the Dispatcher for 31 individuals including the four EOC operational staff who were contacted earlier. An additional 28 staf f for the fir

• EOC ' shift were contacted by telephone. The call out notification was begun at 0938 and' completed at 0954..~ Additional dispatch staf f were assigned to this task.

This alert and notification system has 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capabilities. The EOC ,

was' operational by 1045 and by 1115 all staff were in place with the exception of two organizations. By the end of the exercide, all organizations had representation in the EOC except for the Ohio Department of Transportation. The EOC staf f was comprised of 41 positions,.although more individuals participated in this exercise. For some positions,. alternates were present. and they participated in the EOC

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operations for additional training. A shift change was not demonstrated

~ but 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staf fing capabilities were documented by the presentation of a roster. Availability of this roster eliminates a previously reported deficiency. All 'staf f demonstrated professionalism in carrying out their assignments. Each EOC position representative was familiar with

.his assignment and worked effectively with other staff members. The Ottawa County PI0s were dispatched to the JPIC at 0935.

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, Emergency Operations Management The Executive Group was in charge of the Ottawa County Emergency )

Operations Center as designated in the plan. The Execut.ive Group consisting of the Ottawa County Disaster Services Director, three County Commissioners, the County Engineer and'the Ottawa County Sheriff. The Executive Group was supported by a Carroll Township Trustee. The ExeEutive Group kept informed of the situation, formulated decisions, and' briefed the EOC staff throughout the exercise to keep them informed.

The Executive Group was formed prior to the Alert classification declared at 0931 and provided protective action decisions so the County during the Site Area Emergency at 1105, the General Emergency at 1207, and Recovery and Reentry at 1602. Two shelter orders were Issued at 1115 and 1214 and two evacuation orders were issued at 1220 and 1255.

The initial protective action order was not consistent with the utility protective act. ion recommendations in that Otfawa County evacuated a

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portion of Lake Erie that was not part of the utility recommendations.

The frequent protective action orders concerning areas to be sheltered and evacuated could possibly be confusing.

Recommended Improvement: Procedures should be reviewed to determine if the frequency of protective adtion orders issued can be reduced.

The Executive Group in their protective action consideration used knowledge of the area and logically included wi$hin the protective action decisions the Crane Creek State' Park, Crane Creek Experimental Station, the Ottawa National Wildlife Refuge and the Ottawa County Fair which was in progress near Oak Harbor.

The Ottawa County written procedures and checklists were used to alert, mobilize and activate the Ottawa County Emergency Operations Center staff. They were also used to activate and staff the reception center, congregate care centers, decontamination center, the Joint Public Information' Center and the demonstration of mobility impairad. Pre-exercise agreement between FEMA and the State of Ohio was that only one congregate care center would be activated and staffed in Sandusky County. Buf, during the exercise,' four congregate care centers were activated and staffed. Consequently the' evaluation team was not aware of this until after the fact and was not in a position to evaluate these additional congregate care ' facilities.

Recommended Improvement: Pre-exercise coordination between FEMA and the State of Ohio should be complete so ths6 the Federal evaluation team is aware of all areas to be' demonstrated and evaluated (i.e., congregate care facilities).

Coordination between Ottawa County and Sandusky County seemed effective early in the exercise but less effective later in the exercise when the Sandusky County EOC was activated.

Recommended Improvement: Ottawa County message log entries should include names of persons contacted when important messages such as changes in accident classifications, numbers of evacuees, etc. are communicated'fo Sandusky County.

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. Message handling within the Ottaw. County EOC was efficient and copies were distributed as appropriate. Access to the EOC was contro115d and security was effective.

Facilities

-The new EOC is located in the basement of the Ottawa County Courthouse Annex. This facility has adequate lighting, furniture, space, telephones and noise control. A backup generator was avail 5ble for emergency electrical power. Extended use of this facility could be accomodated by access to the Sheriff's jail where beds, showers and kitchen facilities are available.

Graphics utilized during this exercise were well draf ted and well displayed. All required maps were posted including the plume EPZ, evacuation routes, relocation and care centers, siren locations, dairy animal locations and tr5f fic contr51 points. Display of' maps for

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evacuation routes, relocation centers and shelters corrects a deficiency from an earlier exercise. The' map identifying radi61ogical sampling points was posted in'the dose assessment room. A concern about the posting of this map outside the EOC operations area was expressed during an earlier exercise. However, this location seemed appropriate to the kind of decisions that were being made in t he assessment room. Staff-briefings kept the EOC informed on dose assessment information. The map depicting road blocks established by State and County organizations was displayed and available for reference by all EOC participants.

Population distribution information was available in a table that was keyed to areas which were identified on a map. Population distribution information corrects a previously reported deficiency. However, the demograpic information represented in the table' appears to have anomalies. For example, no transients are reported in the sector (subarea 1) that is immediately adjacent to the lakeshore. However, the observer understands that this information was derived from a 1980 data base.

Recommended Improvement Information on population distribution maps posted in the EOC and listed in the county plan should be verified /up dated.

Communications A communications room is available next to the EOC operations area.

This room 'contains a duplicate of the high and low band ra,dios that are located in'the Sheriff's Communications Center. Adjacent to the EOC Communications room are cubicals'for a number of individual portable radio systems. These systems include State Police, National Guard, Ohio Disaster Services and RACES. Commercial telephones are available for all EOC staff,'the Executive Committee, rumor control operations and the radiological assessment area.

The primary communications system interlinking the utility, State and Ottawa County was the three-way dedicated telephone. County cont act with the State, EBS. EOF. JPIC County representatives, local schools and hospitals was by commercial telephone. The RACES radio was used for 30 umme

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, contact wit h other EOC's. Radios were also used for contact with ambuldnces, monitoring teams and for back up to many of the primary systems. All communications systems functioned very well. The o

versat ility of 'the systems was commendable. Hard copy was available between the EOC and JPIC.

Dose Assessment and Protective Action Recommendation A dose projection team was available in the EOC and performed their responsibilifies in a separate office. This team included State, utility and County staff. Field readings collected by State teams were utilized to develop dose calculation with both computer and hand computation techniques. Field readings came in promptly and the plume was plotted. 511 calculations were checked with t.he utility data and

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were found to have good agreement.

Dose projection data was provided to the County administrators and incorporardd into decisions regarding protective actions. EPA st5ndards, weather and plant status were alk fact 5 red into the decision making.

Public Alerting and Instruction Ottawa County public information staff within the County EOC initially contacted the EBS/NOAA at 0957 per the procedures to notify them that a t'est would be conducted at the Davis Besse ' Nuclear Power Station to test the capabiliti4s and preparedness of State, local and utility officials who would be responding to emergencies at the nuclear power facilify.

Ot tawa County public information staf f simulated the activation of the prompt alert and nofification system (sirens) at 1118 dnd the EBS at 1120 to alert the public of the Site Area Emergency declared by officials at the Davis Besse Nuclear Power Station at 1105.

At 1116 the utility recommended sheltering subareas 1 and 6a but State and local Directors of'the Ohio Departments of Health and Agriculture also r5commenddd that all lactating dairy animals within a two-mile radius of the plant be taken of f pasture, sheltered or kept under roof and fed stored feed and ground water. In accordance with off-site standard procedures the Coast Guard was notifit.d t5 evacuate the waters

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of boaters for ten miles. Ottawa County officials also contacted the Ottawa National Wildlife Refuge and the Crane' Creek State Park to evacuate as a precautionary measure. _

The sirens and EBS were activated again at 1134 and 1135 respectively to announce the Governor's Declaration of Emergency at 1116 and the Ottawa County concurrence of that declaration. The Siste of Ohio at 1125 recommended precautionary sheltering of residents in subarea 1 and the County concurred with that recommendation at 1130 and access control at two mi1Es was implemented at 1120.

The sirens and EBS were again activated at 1220 and 1222 respectively to announce to the public the Ottawa County receipt of the General Emergency declared at 1207 by Davis Besse of ficials and to announce the protective action recommendations to shelter subareas 1,2 and 6a and to evacuate subarea 8, the Crane Creek State Park, the Ottawa Wildlife National Refuge and the Ottawa County Fairgrounds.

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. The next activation of the prompt alert and notification system (sirens) and EBS occurred at 1253 and 1255 respectively to alt er the prot ective action recommendation to the public to widen the shelter area to include subareas 3, 4, and 5 and t o evacuat e subareas 1,2, 6a, 8, the Crane Creek State Park, the National Wildlife Refuge and to close t he Ott awa County Fairgrounds.

Public information staff within the Ottawa County EOC drafted material within the EOC and transmitted hard copies to the Ottawa County spokesperson at the JPIC located in the Administration Building at the Davis Besse Nuclear Power St ation. The same staf f draf t ed the messages for the EBS and NOAA. The development of this material was complete and timely once the decisan was made by the Executive Group.

Prescripted messages were used to decrease the time needed to develop messages. It was noted that pre scripted messages were altered by the Execut ive Grcup which added to the' time needed to release messages.

Protective actions were described in terms of familiar boundaries and landmarks. The messages included guidance on sheltering methods, (e.g.,

close windows, put cloth over mouth when'outside, etc.) They also included instruct. ions for transients without shelter and when instructions t o evacuate was formulated they included information and instruction on the evacuation of school children.

The public information staff in the Ottawa County EOC provided instructi5n to the public by distributing these messages to the EBS, over tone alert radios, calls to schools, factories, etc, and t o Ot tawa County public informat ion staf f at the JPIC for use by television, radio and newspaper report ers.

The timing of public inst ruction was coordinated with the public alerting process such that public alerting was followed by an instructionai message within fif teen minutes of the decision by the State cr Ottawa County to take protective action. These protective action decisions announced over the EBS were periodically repeated.

Protective Action Protective actions demonstrated during this exercise included the actual establishment of traffic / access control points, preparation for the evacuation of mobility impaired, 'and management of the ingestion pathway. All demonst rations were performed promptly and were appropriate to the scenario problems.

Traf fic/ access control points were promptly established at 2, 5 and 10 miles and were plott ed on the traf fic and access control map in the EOC. Traffic control points in the field wete manned through a l

coordinated eftort between County and State agencies. The first shift staff involved in these demonstrations were obtained from the State Police. The se:ond shift staff were requested from the National Guard, County Sheriff,' County Engineer and Ohio DOT. The placement and briefing of guard personnel was simulated. A map was available t o identify all road block locations. This was recommended during the last exercise.

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- Resources were available to keep evacuat. ion routes open under a variety of situations. Pre-exercise agreement was for a table top demonstration of access control. The field demonstration of access control therefore was not evaluated. Changes to pre-exercise agreements'need to be communicated in writing to FEMA Region V so a complete evaluation of exercise play can be evaluated.

Recommended Improvement: Pre-exercise coordination between FEMA and the State of Ohio should be complete s5 thati the Federal evaluation team is aware of all areas to be demonstrated and evaluated (i.e., access c ont rol) .

Special Evacuation EOC staff were prepared to evacuate the mobility impaired. A written list of special needs individuals was available and appropriately updated during the exercise with up to the minute hospital information.

This list was organized by Townships and available to the local fire districts where transportation arrangements would be made. The base list was compiled and up-dated biannually by the County social service personnel. Activities demonstrated for evacuation of the mobility impaired corrects a previous deficiency.

The Carroll Township Mobility Impaired Procedures provided for EMS /EMT response to requests for assistance by mobility impaired persons in need of transportation and help. There is a list of persons in the Township, which is updated periodically, that would need assistance. The training enc 5mpasses the entire Volunteer Fire Department. The iraining includes the use of dosimeters, TLDs and CVD 700. In addition the volunteers are regularly updated on the nuclear power station accident response.

There was some uncertainty, by representatives of the Carroll Township Fire Department, concerning the maximum exposure allowable in lifa saving situations. When queried the correct answer was provided by one department representative and a second fire representative explained that he thought the maximum exposure allowable had changed. All emergency workers naed to be kept up to dat.e through training, on emergency worker exposure control.

Recommended Improvement The EMS /EMT personnel involved in mobility impaired assistance should be informed of the current guidelines for the maximum allowable exposure dosage for lifesaving situations.

Relocation Center There were two separat e locations utilized for reception and congregate care in Sandusky County. The Fremont-Ross High School was operated as a Reception Center and the Atkinson School operated as a Congregate Care Center.

Agencies represented at the Reception Center were the Sandusky County Di. aster Service Agency, t he Sandusky County Health Department, the American Red Cross, and Ihe Sandusky Valley Amateur Radio Club. The facility was adequately staffed by the foregoing and represented the requirements of radiological monitoring ieams, nurses, health department staff, a manager and registrars.

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. .The Congregate Care Center at the Atkinson School was operated by the Americaa Red Cross and likewise included registrars, a manager and

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nurses. -The staff at both centers were double staffed and/or provided organizational rosters of oiher personnel that would be utilized for work-shifts in addition to the first twelve hours.-

A family of three individuals and the family's d.,g arrived at the Reception Center. They were registered and monitored by the radiological monitoring team and given information on sheltering for their pet at the County Fairgrounds. The family was monitored for potential contamination and the one individual processed through simulated decontamination procedures.

After being monitored and determined to be free of contamination the evacuees were transported by bus to the Congregate Care Center where they were again registered by the American Red Cross through the use of

.a multi-copy " Shelter Registration Form."

There were two monitoring teams of three individuals each at the Reception Center. They were equipped with geigher couniers (six total) which included probes and listening attachments. They were additionally

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equipped with mid-range dosimeters and chargers for the dosimeters. The team demonstrated whole body scanning on t he volunteer evacuees.

According to the spokesperson for the monitoring team, there is suf ficient equipment and personnel (paid and volunteer) to conduct monitoring of all evacuees within a twelve hour period. Individuals needing decontamination would be segregited from the non-contaminated evacuees at' the school's entry-way monitoring point. They would be rouied to the respective male / female shower rooms, where they would shower for dacontamination. After showering they are re-monitored until found to be free of contamination. Contaminated clothing and other personal belongings will be receipted to the respective evacuees, bagged in plastic bags and containers,' and picked up latei by the utility operators.

Transportation between the Reception Center and the Congregate Care Center will be provided through the use of buses (approximately 45) belonging to the Fremont City School District. The school buses are equipped with two-way radios for communications with ihe bus dispatcher, who is located in the bus storage 'and gaiage building. The garage is next door'to the Fremont-Ross High School Reception Center.

The Reception and Congregate Care Centers are well outside the ten mile EPZ of'the Davis Besse Nuclear Power Station. According to the shelter / congregate care center manager ( ARC representative) the Center will accomodate two'hundied persons for an extended period. It was explained that additional schools throughout the County are pre-designated for congregate care and would become operational as needed.

The Atkinson Scliool Congregate Care Center will be staffed and operated by the American Red Cross. Sleeping and eating accomodations will be handled by pre-arranged agreements between the Red Cross, the County and School Districts. The center's cafeteria, recreation facilities (gymnasium, grounds, etc.), means for storage, parking, etc are adequate.

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. However, neither the Atkinson School nor the Fremont-Ross High School are equipped wit h ramps, hanirails, toilet facilities, etc. to accomodate the handicapped. Further, the Atkinson School is void of facilities for showering and/or bathing ano therefore would not be suit 951e t o support an extended operation as a congregate care facility.

Recommended Improvement: It is recommended that additional planning be done for t he accomodation of handicapped individuals at the reception / congregate care cent.ers and appropriate means for

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showering / bathing and other hygiene needs of all evacuees.

Sufficient information had been compiled by the EOC staff on milk animals, water intake points and" crops to manage protection of the ingestion pathway. This information appeared to be current and based on field sucveys. All relevant information was incorporated into County decision making.

Decontamination and Emergency Worker Exposure Control The Pott Clinton Fire Department demonstrated a thorough knowledge of the operation of a decontamination station and exposure control. The Fire Department training includes an intensive hands on training with all survey meters and their individual use. Although they have had training sessions this was their first exercise and it demonstrated the individuals were thoroughly trained and knowledgeable.

The defined decontamination area preparation was well done. The fact that a person must. pass over the same area going into the shower and as coming out of the shower is planned for by covering the pathway as decontaminat ed individuals exit the showers. An individual being monitored at the Center by the monitoring team was observed to have simulated contaminat ion on one of his hands. He was observed to lower his arm and place the contaminated hand inside the pocket of his trousers and other parte of his body which had been previously monitored.

The actions of the individual being monitored went unnoticed by the monitoring team member who had already monitored t he areas of his body and observed them to be free of cont amination. The monitoring team ( s) need t o observe and take action to prevent the spread of contamination by individuals found to be' contaminated.

Recommended Improvement: The evacune and emergency worker monitoring teams should follow S0P to prevent evacuees and emergency workers from spreading contamination to other parts 'of their clothing and their bodies.

During the monit oring of the lef t arm of an emergency worker a reading of 4.5 mr was obtained at the front side and a reading of .45 mr on the rear side due to changing the meter scale. The person doing the monitoring did not seem aware of changing the scale of the survey met er even though he was questioned about the scale change by his survey team member recording the readings. Survey teams need to be aware of scale changes to ensure recording proper readings.

35 s

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. Recommended Improvement: Care should be taken by the monitoring teams in the use of the monitoring instruments to insure that readings are consistent with the scale setting.

The dosimeters and TLD of emergency workers should be retained by the registrars at the beginning of the monitoring process. During the emergency worker decontamination demonstration, the dosimeters and TLD was not retained for record purposes. The emergency worker was allowed to retain his dosimeters and TLD throughout the monitoring process.

They were discarded with his clothes in the contaminated clothing bin and lost for working purposes. Dosimeters and TLDs of emergency workers need to be taken from the emergency worker at the beginning of'the monitoring process so a record of exposure by the emergency worker is recorded.

Required Corrective Action: NUREG 0654 criteria K.3.b The dosimeters worn by emergency workers should be taken and exposure levels recorded at the time of registration at the decontamination center. Further, the

-TLD (permanent record of exposure) should be taken and retained for reading.

Recommendation: Emergency worker training should emphasize the importance of expo =ure records so that all personnel are aware of the need to maintain dosimeters and TLDs. In addition, decontamination procedures and training should emphasize the need to maintain dose records as represented by dosimeters and TLDs.

Radiological Exposure Control Exposure control equipment was available for all County departments that had responsibility for field activities. This equipment was provided in a package that included instructions for use, dose limitations, medium and high range dosimet ers, TLD's and record keeping cards. Chargers and geigher counters were available in the $0C. National Guard resources l were requested when the situation escalated. All Guard participants would have had proper dosimetry if they were activated.

The EOC radiological staff was familiar with the decontamination

~

procedures for participating field personnel should the need arise.

Media Relations Press briefings conducted by the Ottawa County spokesperson was conducted in the JPIC. No press briefings were conducted at the Ottawa County E0C. Media representatives did make a request to come into the Ottawa County EOC to take background video footage and pictures for the evening news.

l The decision was made not to allow the media into the EOC during the exercise, even for this purpose, which is consistent with the County plan concerning access and security during'an exercise or actual accident.

Recommended Improvement: Permission should be given t o the media to come into the Ottawa County EOC during training sessions and training drills, prior to an exercise, to enable them to obtain necessary video and picture coverages for future news broadcast.

36 -

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- . ~. . - . _ - . - . _ . .- - ._ - . ---_____--_- ._~ _ _ .

i , ,- 4 The ~0ttawa County staf f activated the JPIC in real time, arriving at 1000. The County was double staffed to demonstrate two shift

} capability. Only one person performed the duties of the spokesperson.

Recommended Improvement: All. spokespersons/public information of ficers at the JPIC (1st and 2nd shif ts, etc.) should be involved in briefing the media.

The County has telephone and telefax capability between the EOC and the JPIC, telephone, telefax and radio capability to the State EOC in 5

Worthington, and telephone capability with the EOF, and using State equipment, a radio capability, r There were at least seven briefings held during the course of the exercise. 'During the briefings plant conditions and'the status of State 4 and local emergency response and protective actions were discussed.

Hard copy of statements were available 'to include EBS releases. Even  !

though EBS messages were not prepared at the'JPIC, they were read at briefings and hard-copy released to the media. The rumor control phone numbers were included in releases prepared at the JPIC. State, County 4

and utility personnel coordinated and consolidated statements prior to ,

their release. During this process some rather extended delays were i encountered in getting final concurrence from the Ottawa County Executive Group.

Recommended Improvement: Ottawa County should revise / review their procedures to eliminate any extended delay in obtaining finsi copy news release concurrence by the Ottawa Executive Group.  ;

Recovery and Reentry The simulated accident at the plant was de-escalated at 1602. Recovery and reentry was'not an exercise objective to be evaluated during this exercise. The following comments are made to reflect what recovery and reeniry actions were taken by Ottawa County which demonstrate corrective

~

t action foi an earlier exercise deficiency. -

Pre-exercise discussions between FEMA and the State of Ohio agreed that although ' recovery and reentry was not to be evaluated the exercise would

-terminate after a limited discussion of recovery and reentry activities ,

by the State and Ottawa EOC sfaff. Ottawa ' County, af ter de-escalation '

by the utility and the State, organized their Recovery and Reentry 1- Committee.

This committee conducted a study of the situation and discussed the situafion prior'to making recommendations to the Executive Group for decision. Discussions included arrangements to secure the evacuated area during recovery and reentry operations. Policy and procedures were  ;

developed on allowing entry to the evacuated area for essential services such as what to do with dairy cows and'their milk. Relaxation of protective action recommendations was based on monitor data indicating safe levels of radioactivity. Arrangements were made to provide the public with information on safety precautions, possible health effects of low level exposure, etc.

37 1

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, - Recovery and reentry decisions were communicated promptly to all response. organizations and.the EBS at approximately 1700.when the Executive Group mada decisions concerning recovery and reentry. Ottawa County terminated the exercise once EBS was riotified.

The utility and State of Ohio terminated the exercios and de-activated their staff and facilities at 1632 and 1635 respectly without any

. protective action iecommendations beyond announcing recovery-and reentry could'begin.' Consequently State staff input was not available to Ottawa County.during much of the time Ottawa County discussed and decided

.cacovery and reentry actions.

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SUMMARY

LISTING OF EXERCISE FINDINGS 39 e .

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UTILITY: Davis Besse Nuclear Power Station Summary Listing of Deficiencies Ohio July 16. 1985 (State) (Data)

Ohio (Community)

NUREG Narrative Statement Correct ive Action Scheduled Actual l

Item of Deficiency Proposed' 'Dat e Date There were no demonstrat ed and/or observed inadequacies t hat warrant ed a finding that of fsit e emergency preparedness is not adequat e t o provide reasonable assurance that appropriat e measures can be taken t o prot ect the health and safety of the public living in t he vicinit y of t he Davis Besse Nuclear Power St at ion in t he event of a radiological emergency.

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UTILITY: Davis Besse Nuclear Power St at ion Summary List ing of Areas Requiring Corrective Actions Ohio July 16,1985 (State) (Date)

Ohio

( Communit y)

NUREG Narrative Statement Corrective Action Scheduled Actual g Item of Weakness Proposed 'Date Date J.11 Since there was no analysis of ingestion pat hway samples, the State did not demonstrate the abilit y to project dosage to the public via ingestion pathway exposure.

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W UTILITY: Davis Besse Nuclear Power Station Summary List ing of Areas Recommended for Improvement Ohio July 16, 1985 (State) ~~

(Dat e)

Ohio

( Communit y)

Narrat ive St at ement g of Recommendat ion All State spokespersons/public information officers at the JPIC (1st and 2nd shifts, etc.) should be involved in briefing the media.

The ut ility and the Stat e should est ablish a common alternat e JPIC location, outside the 10 mile EPZ, and the State should thereaf ter amend t heir plan to incorporate the result s of this planning.

The time t hat radiation readings are taken should be included on the field monitoring status board.

The field assessment team followed their radiological survey SOP and t ook readings at belt height. It is recommended that these procedures be changed to include an instrument survey at ground level for deposition of radioactivit y. .

The t ermination of t he exercise should be at a point. where all exercise participant s are in agreement (i.e., the State of Ohio should have cont inued exercise participation 1 o provide Ot t awa Count y with recovery and reent ry protective act ions t o bring t he exercise t o a logical terminat ion point rat her t han f.erminate when recovery and reentry was announced by t he ut ility and the State.)

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UTILITY: Davis Besse Nuclear Power Stat ion Summary Listing of Deficiencies Ohio July 16, 1985 4

'(State) (Date)

Ottawa County

( Communit y)

NUREG Narrative Statement Corrective Action Scheduled 1 Actual-l Item of Deficiency Proposed ~ 'Date Date There were no demonstrated and/or observed inadequacies that warrant ed a finding that offsite emergency preparedness is not adequate t o provide reasonable assurance that appropriate measures can be taken to protect the health and safety of the public living in the vicinity of the Davis Besse Nuclear Power Station in the event of a radiological emergency.

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UTILITY: Davis Besse Nuclear Power Station' Summary Listing of Areas Requiring Corrective Actions -

Ohio July 16, 1985 (State) (Dat e) '

Ott aws Count y

( Community)

NUREG Narrative Statement Corrective Action Scheduled Actual Item of Weakness Proposed Date Date K.3.b The dosimeters worn by emergency workers should be taken and exposure levels recorded at the t ime of registdration at the decontamination center.

Further, the TLD (permanent record of exposure) should be taken and retained for reading. These items were discarded along with cont'aminat ed clothing and thus lost.

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UTILITY: Davis Besse Nuclear Power Station Summary List ing of Areas Recommended for Improvement Ohio July 16. 1985 (State) (Dat e)

Ottawa County

( Communit y )

Narrative Statement of Recommendation l

All spokespersons/public informat ion of ficers at t he JPIC (1st and 2nd shifts, etc.) should be involved in briefing the media.

Informat ion on population dist ribution posted in the EOC and listed in the county plan should be verified / updated.

Ot tawa Count y message log entries should include names of persons contact ed when import ant messages such as changes in accident classification, numbers of evacuees, etc. are communicated t o Sandusky County.

Pre-exercise coordinat ion between FEMA and t he St at e of Ohio should be compiere so that the Federal Evaluation Team is aware of all creas t o be demonst rat ed and evaluated (i.e, congregat e care facilities and access control).

Protective action procedures should be reviewed to det ermine if t he frequency of protective act ion orders issued can be reduced.

, The EMS /EMT personnel involved in mobility impaired assistance should be informed of t he current guidelines for t he maximum allowable exposure dosage for lifesaving sit uations.

I Permission could be given t o. the media t o come into the Ot tawa Count y EOC during training sessions and training drills prior t o an exercise to enable t hem to obtain necessary video and pict ure coverages for fut ure news broadcast.

Ot tawa County should review / revise their procedures to eliminate any extended delays in obt aining final copy news release concurrence by t he Ot t awa County Execut ive Croup.

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UTILITY: Davis BesseL Nuclear PowerI Station -

Summary Listing of Areas Recommended for Improvement Ohio July 16, 1985 (State) (Dat e)

Ott awa County (Community)

Narrat ive Stat ement of Recommendation Addit ional planning needs to be done for the accomodation of the handicapped individuals at the reception and congregate care centers and for appropriate means for showering / bat hing and other hygiene needs of 'all evacuees. -

The evacuee and emergency worker monitoring teams should follow SOP t.o prevent evacuees and emergency workers from spreading . contamination 'to other parts of .their clot hing and their bodies.

Care should be t aken by the mon i t oring t eams in the use of t.he monitoring instruments to insure that readings are consist ent wit h t he scale set t ing.

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-i' l UTILITY: Davi> Besse Nuclear Power Station ,

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_c Sunnaary Listing of Areas Recommended foi,.Teprovement.n -

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-Ohio ~

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. Nurative St atement; . .

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of Recommendation *

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S'andusky County. should consider a, liaison. representative in the Ottawa County EOC. - #'

Sanduskey Count.y should obtain proper verification, of emergency information when dual not[ficat. ion is not received f rom Ot t.awa County in accordance with established ' procedures.

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a-1 STATE 0F CWl0 ADJUTANT GENERAL *S DEPARTMENT a025 WEST ARA 88VILLE ROAD WoRTM886GT08L oleo 4300s 2712 DISASTER SERVICES AC2NCY I

November 5, 1985 AG0H-DS

-Mr. Robert Connor, Acting Regional Director Federal Emergency Management Agency Region V 300 5. Wacker Drive, 24th Floor Chicago, Illinois 60606 Attention: Mr. Wallace J. Weaver, Chairman Regional Assistance Committee l

Dear Mr. Connor:

Enclosed are the State of Ohio's proposed corrective actions in respons- <

to deficiencies noted in the Davis-Besse Exercise Report received in our off .e .

l October 7, 1985. The Exercise Report was based upon the exercise conducted i the Davis-Besse Nuclear Power Station on July 16, 1985.

In all, the report identified one area requiring corrective In Ottawaactions County,at il e five areas recommended for improvement for the State. 5-was one area requiring corrective actions and eleven areas recommended for provement. The enclosed schedule of corrective actions (Attachment The areas recommer ed 1) add esses only those areas identified as requiring such actions. Ottawa Courty's <

I for improvement for the State will be taken under advisement.

response to the recommendations is contained in Attachment 2. .

Questions concerning the proposed corrective actions should Thail be addres: you sd to the. Nuclear Operations Officer, Kenneth Cole, at (614) 889-7157.

for your continuing support and assistance.

FOR 1HE DIRECTOR

( ' /f/ fY ICHARD M. LOC T g

Deputy Director Enclosure 3

,, , , , . . , . , . . . . . . . . , . , . - - . - . . . - - - . - . . _ - - . . . ~ - , . - - . - . _ . ~ , - -

v DAVTS-BESSE NUCLEAR POWER STATION EXERCTSE July 16, 1985 Schedule of Proposed Corrective Actions E OF OHIO.

SCHEDULED DATE G OF COMPLETION PROPOSED CORRECTIVE ACTION NARRATIVE STATEMEfff 0F WEAKNESS Nov. 18, 1986 Since there was no analysis of ingestion The ability to project dosage to the public via ingestion pathway exposure pathway samples, the State did not demon- was listed as an objective in error,

+g strate the ability to project dosage to This ability will be demonstrated dur-the public via ingestion pathway exposure. ing the next full participation exer-cise.

CA COUNTY _

SCilEDilLED DATE EG OF COMPl.ET10N PROPOSED CORRECTIVE ACTION M NARRATIVE STATEMENT OF WEAKNESS The importance of exposure records is April 15, 1985

.b The dosimeters worn by emergency workers should be taken and exposure Icvels re- emphasized in emergency worker training sessions. Training also emphasizes the.

corded at the time of registration at need to maintain dose records as repre-pr ,3.ke the decontamination center. Further, sented by dosimeters and TLD's. The the TLD (permanent record of exposure) assumption that the dosimetry was dis-should be taken and retained for read- carded was not a problem with procedure ing. These items were discarded along but a problem inherent with simulation.

with contaminated clothing and thus lost. The emergency worker was asked by the evaluator what he would do next if he was found to be contaminated. The worker explained that he would place his ,

D clothing in a given container and shower. E The activity of retaining doslectry was }

never demonstrated and thus, lead to the 4 con fusion. Standard operating procedures 3 will be modified to emphasize that .

dosimeters and TLD's are retained by the registrar at the beginning of the moni-toring process.

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Attachment 2 DAY 15-BESSE NUCLEAR POWER STATION July 16, 1985 Exercise OTTAWA COUNTY'S RESPONSE TO RECOMMENDATIONS RECOMMENDATION: Pre-exercise coordination between FEMA and the State of Ohio should be complete so that the Federal Evaluation Team is aware of all areas to be demonstrated and evaluated (i.e., congregate care facilities and access control).

RESPONSE

Pre-exercise coordination between Local, State and FEMA was thorough and complete. The additional congregate care facilities exercised by Sandusky County and the access control points exercised by Ottawa County Agenefes participated in these activities were not intended to be evaluated.Had either county desired credit for performing for training purposes only.

these tasks, they would have indicated so during the objectives meeting.

RECOMMENDATION:

Protective action procedures should be reviewed to detenmine if the frequency of protective action orders issued can be reduced.

RESPONSE

Due to the inherent time restrictions of an exercise, Most scenarios key decisions (relating accelerate the sequence of most events.

to protective actions) made by the County Executive Group occur within a two-hour period. Protective action recommendations must be modified at appropriate times as conditions dictate so as not to compromise the health and safety of county residents.

" Ottawa County should review / revise their procedures to eliminate any RECOMMENDATION:

extended delays in obtaining final copy news release concurrence by the Ottawa County Executive Group.

'Ihe Ottawa County Executive Group demonstrated proper cautionOttawa in

RESPONSE

assuring correct information was contained in news releases.

County and Toledo Edison have modified prescripted messages News releases to allow containing for more expeditious review and release.

current data will continue to be scrutinized to assure precise information is issued.

P01 HTS OF CLARIFICATION

" ...It was noted that the initial protective action implemented by 1

Page 6, Pars.7: Ottawa County was not consistent with the utility protective action recommendation in that Ottawa County evacuated boaters from the waters ten miles around the Davis-Besse Nuclear Power Station..."

The initial protective action implemented by Ottawa County was con-

RESPONSE

sistent with existing plans and procedures of Ottawa County and the ,

State of Ohio. I l

Page 7, Para.3:

" ...The RACES radio was used for contact with other EOC's..." l l

The Amateur Radio Energency Service (ARES) radio was used to commu

RESPONSE

' with other EOC's.

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', .5 *2 Attachment 2

" ...The first shift staff involved in these demonstrations were obtained Page 32, Pars. 7:

from the State Police. The. second shift staff were requested from the National Guard, County Sheriff, County Engineer and Ohio DOT..."

RESPONSE

The first shift staff (access control points) involved personnel from the following departments: Ottawa County Engineer, Ottawa County Sheriff, Ohio Department of Transportation and the Ohio State Highway.

Patrol. The second shift was requested from the Ohio Army National Guard. The placement and briefing of guard personnel was simulated.

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Federal Emergency Management Agency f}/ Washington, D.C. 20472 DEC 9 1985 15e Honorable Richard F. Celeste Governor of Ohio Columbus, Ohio 43215 ,

Dear Governor Celeste:

On February 21, 1981, then Governor Rhodes formally submitted the " Ohio Plan for Response to Radiation Emergencies at Licensed Nuclear Facilities", site-specific to the Davis-Besse Nuclear Power Station (NPS), to the Federal Emergency Management Agency (FENA) Region V for review and evaluation in accordance with FEMA's Rule 44 CFR 350.

A radiological arergency preparedness (REP) plan for Lucas County had not been included in the State's sW mission. Ibring FEMA's review process, it was concluded that a separate Lucas County plan was required. On December 7, 1981, FEMA notified the State of the need for this additional information. However, this information was not provided by the State. Consequently, since planning was incmplete, FEMA notified the Ohio Disaster Services Agency (OmA) on June 29, 1982, that further processing of the State's submission was being placa$ on hold pendirg submittal of a Lucas County REP plan.

Despite efforts by Federal, State, local and Toledo Edison Capany officials over the past several years, a ccunty plan has not been sWmitted to FEMA.

In October 1984, ODSA received frm Toledo Edison a proposal to redefine the 10-mile energency planning zone (EPZ) around the Davis-Besse NPS. In addition to eliminating a portion of Lucas County affected by the 10-mile EPZ, the proposal also eliminated that part of the city of Port Clinton (Ottawa County) within the 10-mile EPZ that had been incitded in the original plannirg effort. 'Ihe ODSA, on April 30, 1985, sW mitted this proposal to FENA Region V and recarmerded that it be approved.

FEMA Headquarters and Regional Staff have reviewed the State's proposal and supporting doctnentation to redefine the 10-mile EPZ and have determined that it is not acceptable. In addition, due to (1) the continued absence of a Lucas County Plan, and (2) the long period of time which has elapsed since the State's original, inemplete sWmission in 1981, I have deter-mined that FENA nust return the State's original sutnission unless certain information is provided to FEMA Region V within 60 days of the date of this letter. Details have been provided to Mr. Richard M. Iockhart, Deputy Director, OEA in my letter dated Decenber 9,1985. A strrmary of the information required with respect to the five (5) geographical areas affected by the 10 mile Davis-Besse EPZ is outlined below:

(1) City of Port Clinton - FEMA cannot support the exclusion of Ibrt Clinton frm the plume exposure EPZ. In fact, our review of the proposal indicates that the doctnentation would supp3rt the inclusion of the entire city within the

If the State is not able to provide the information required within 60 days, we will be required to take action in accordance with FD% regulations. This includes: (1) the return and disapproval of the State's original inoca@lete

. REP plan submission under 44 CFR 350; (2) a written explanation to t he Nuclear Regulatory Comnission regarding FD%'s decisions related to rejecting t?e proposal to redefine the 10-snile EP2 and returning the State's original sub-mission; (3) the pWlication of a notice in the Federal Register that. emergency planning and preparedness around the Davis-Besse site are not adequate to protect the pWlic health and safety and that the plans have, therefore, been returned for appropriate corrective actions.

FD% is willing to contirue working with Ohio in the hope that the sae:essary information can be provided within the 60-day time period. ibile it is likely that additional local plans, an exercise and a pWlic neetirg 54i11 be necessary, we are confident that the State and FD%, working closely together, can succeed in acconplishirg the long sought-after approval under FDM rule 44 CFR 350.

Sincerely, s

s )..,...t t. dy slo Samuel W. Speck Associate Director State and In:al Prograns and Support L

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pitsne exposure pattway. Asstanirg all or part of the city is incitded in the pitzne EPZ, a radiological energency preparedness (REP) plan mst be developed in accordance with FDIA regulations and the joint Nuclear Regulatory Comnission (NRC)/ FEMA guidance NUREU-0654, PTMA-REP-1, Rev. 1. he plan mst be fonnally approved by the appro-priate governnental jurisdictions, e.g., the city, Ottawa County and/or the State, and submitted to FEMA for review.

(2) Ottawa County (exclusive of the city of Port Clinton) - h e Iraposal defines the plume EPZ on the basis of a geopolitical bourdary which is generally acceptable. However, additional infonnation is needed before a final decision can be rade.

(3) Lucas County - he proposal to excitde Jerusalen Township fran the EPZ does not [rovide adequate justification to support

- renoval at this time. Berefore, a REP plan mst be developed in accordance with the guidance Irovided in NUREU-0654. Details concerning the specific information needed have been provided in a letter to 00SA. 'Ihe plan mst be fonnally approved by the appropriate governmental jurisdictions, e,g., Lucas County, Jerusalen 'Ibwnship and the State (or Ottawa County if a con-pensatory plan is developed), and submitted to FEMA for revicw.

In addition, the plan would have to be exercised and a public meetirg held.

(4) Lake Erie - In general, the proposal as stated for Lake Erie w uld be acceptable. However, the U.S. Coast Guard (USG3) needs to be consulted and several apparent inconsistencies need to be addressed.

(5) Sandusky County - Generally, the exclusion of the County fran the 10-mile EPZ is considered acceptable based on the resolution of certain conditions. One, it will be necessary for the State to provide written assurance annually that there is no population at risk (pennanent or transient) within that portion of Sandusky County lyirg within the 10-snile EPZ. We results of census data and/or a field

• investigation would be acceptable sour s to cite in preparirg a justification. Secondly, Sandusky County officials mst review and accept the EPZ proposal. I

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, f, %.%. Federal Emergency Management Agency

. Washington, D.C. 20472 DEC 9 1985 Mr. Richard M. Lockhart Adjutant General's Department Deputy Director Chio Disaster Services Agency 2825 West Granville Road it>rthington, Ohio 43624

Dear Mr. Lockhart:

On February 21, 1981, then Governor Rhodes formally submitted the " Ohio Plan for Response to Radiation Ehergencies at Licensed Nuclear Facilities", site-specific to the Davis-Besse Nuclear Ibwer Station (NPS), to the Federal Emergency Managment Agency (FDR) kegion V for review and evaluation in accordance with c'EMA's Rule 44 CFR 350.

A radiological t:mergency preparedness (REP) plan for Lucas County had not been included in the State's submission. During FIMA's review process, it was concitded that a separate Lucas County plan was required. On Decenber 7,1981, FEMA notified the State of the need for this additional information. However, this information was not provided by the State.

Consequently, since plannirg was incmplete, FEMA notified the Ohio Disaster Services Agency (OIEA) on June 29, 1982, that further processing of the State's stbmission was beirg placed on hold pending stbmittal of a Lucas County REP plan.

Despite efforts by Elederal, State, local and Toledo Edison Cmpany officials over the past several years, a county plan has not been submitted to FEW..

Although a county plan has neither been approved by county officials, nor submitted to FEMA for review, a May 5,1983, letter frm the Toledo-Lucas County Civil Defense Director to the Ohio Adjutant General noted that a REP plan for the county had been empleted.

In October 1984, OIEA received frm 'Ibledo Edison a proposal to redefine the 10-mile plume exposure planning zone (EPZ) around the Davis-Besse NPS.

In addition to eliminating a inrtion of Imcas County affected by the 10-mile EP2, the proposal also eliminated that part of the city of Port Clinton (Ottawa County) within the 10-mile EPZ that had been included in the original planning effort. 'Ihe ODSA, on April 30, 1985, submitted this proposal to FEMA Region V and recmmended that it be apprcwed.

FDE Headquarters and Regional Staf f have reviewed the State's proposal and supporting documentation to redefine the 10-mile EPZ and have determined that it is not acceptable. In addition, due to (1) the continued absence

• of a Lucas County Plan, and (2) the long period of time which has elapsed

J since the State's original, inccnplete submission in 1981; I have deter-mined that FDiA must return the State's original submission unless certain information is provided to FEMA Region V within 60 days of the date of this letter. De information required with respect to the five (5) geographical areas affected by the 10-mile Davis-Besse EPZ is outlined below. A more detailed analysis of the issues by FDIA Region V is attached. In addition, a sumery of the issues has been provided to Governor Celeste.

(1) City of Port Clinton - FDiA cannot support the exclusion of Port Clinton from the plume exposure EPZ. In fact, our review of the proposal indicates that the docmentation would support the inclusion of the entire city within the plune exposure pathway because: (a) it is the largest city in Ottawa Comty, with over half of the city geographically located within the 10-mile radius, and has the largest concentration of permanent residents (approximately 4,800) within the 10-mile EPZ; (b) prevailing wind patterns would transport releases to the southeast, i.e., in the direction of Port Clinton; (c) if an emergency did occur at the plant, it could result in the spontaneous evaajation of a significant runber of residents from the city. However, if the city was exclu$ed frm the EPZ, there presunably would be no reason to plan for such an evacuation or to have arrangements for reception centers to accumudate evacuees frm the city; and, (d) there are six schools within the city with an enrollment of approximately 2,500 stuients, a hospital within the city at 10.2 miles frm the plant, and a nursirg hcne within the city at 10.3 miles frm the power station.

fem Decision I. Se entire geographical area of the City of Port Clinton mst be inclu3ed in the pime exposure pathway to ensure that the pW1ic health and safety of Port Clinton residents can be protected, or an acceptable detailed justification for excludirg all or part of the city must be sWmitted.

II. Assunirg all or part of the city is included in the pime EPZ, a radiological energency preparedness (REP) plan mst be developed in accordance with FEMA regulations and the joint Nuclear Regulatory Cbunission (NRC)/FDtA guidance NUREG-0654, FDiA-REP-1, Rev.1. S e plan m st be formally approved by the appropriate gcnermental jurisdictions, e.g., the city, Ottawa County and/or the State, and sutznitted to FDiA for review. B is could be done by either a city plan or incorporating planning for the city in the Ottawa County plan.

(2) Ottawa County (exclusive of the City of Pbrt Clinton) - The proposal defines the plume EPZ on the basis of a geopolitical boundary which is generally acceptable. However, additional l information is needed before a final decision can be made.

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FEMA Decision I The proposal discusses a geopolitical boundary for Ottawa I County; however, it does nothing nore than outline the proposed boundary. We impact of the boundary on the public health and safety of Ottawa County residents in the area to be excluded needs to be addressed. For exartple, the proposal does not indicate the nature of any developnent in the affected treas.

(3) Lucas County - The groposal as stbmitted to excluje Jerusalen Township from the EPZ does not provide adequate justification to supp:rt removal at this time. he State and Federally owned parks appear to have been adequately accounted for in the planning process. However, there are still some questions retaining with respect to the residents of Reno Beach, Lakeland and Howard Farms Beach in Jerusalen 'Ibwnship.

De proposal does not address the nuter of residents within 10 miles of the site, the nature of any develgrnent, land characteristics, warning capability, public safety and risk.

Were is some discussion of prevailing wind direction, but this is not doctanented. De issue of sirens is addressed but follow-up notification is not. Input frcm the residents was not solicited and it is unclear if the joint January 22, 1985, letter on the troposed EPZ boundary frcm the Jerusalen Township Trustee and the Deputy Director of Toledo-Lucas County Civil Defense to OCEA is legally binding on the county. Wile a Lucas County plan is acknowledged in the proposal, the implications of that plan are not fully addressed.

FEMA Decision A REP plan must be develcped in accordance with the guidance provided in NLREG-0654. ne plan nust be formally approved by the appropriate govermental jurisdictions, e,g., Lucas Cotrity (or Ottawa County if a ccrrpensatory plan is developed),

Jerusalen 'Ibwnship and the State, and submitted to FD4A for review. In addition, the plan would have to be exercised and a ptblic meeting held.

(4 ) Lake Erie - In general, the proposal as stated for Iake Erie would be acceptable. However, the U.S. Coast Guard (15G3) needs to be consulted and several apparent inconsistencies need to be addressed.

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a FEMA Decision I. We USCG has primary responsibility for the safety of boaters on Lake Erie. hey nust, therefore, be provided an cpportunity to review and cxwent on REP plans relating to protection of the public health and safety in areas of their responsibility.

II. W ile the proposal states there are no islands within 10 miles of the site, attachnents stbmitted with the proposal indicate that part of West Sister Island is within 10 miles. Wus, the pennanent (if any) and transient population should be addressed ard the existence of any other islands within the 10-mile radius investigated.

III. W e proposal is not consistent concerning the proposed EPZ boundary in Iake Erie. It refers to a 10-mile arc in one place but also inc" cates a rectilinear boundary in another part of the proposal, his apparent inconsistency needs to be corrected.

(5) Sandusky County - Generally, the exclusion of the County frcm the 10-mile EPZ is considered acceptable based on the resolution of certain conditions.

FEMA Decision I. It will be necessary for the State to provide written assurance annually that there is no population at risk (permanent or transient) within that portion of Sandusky County lying within the 10-mile EPZ. %e results of cen-sus data and/or a field investigation would be acceptable source (s) to cite in preparirg a justification. ,

II. Sardusky (bunty officials nost review and accept the EPZ proposal.

If the State is not able to provide the infontation required within 60 days, we will be required to take action in accordance with FDM regulations. Eis includes (1) the return and disapproval of the State's original, incmplete REP plan sutrnission under 44 CFR 350; (2) a written explanation to the Nuclear Regulatory Commission regarding FD%'s decisions related to rejecting the proposal to redefine the 10-mile EPZ and returning the State's original stbmission; and, (3) the ptblication of a notice in the Federal Register that emergency planning and preparedness around the Davis-Besse site are not adequate to protect the ptblic health and safety and that the plans have, therefore, been returned for appropriate corrective actions. ,

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FD4A is willirg to continue wrkirg with Chio in the hope that the necessary information can be provided within the 60-day time period, m ile it is likely that additional local plans, an exercise and a public meetirg will ,

be necessary, w are confident that the State and FD1A, wrking cicsely together, can succeed in acconplishirg the long sought-after approval under FEMA rule 44 CFR 350.

Sincerely,

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Smuel W. Speck Associate Director 9 tate and Incal Progres and Support Attachment As Stated 6

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