ML20149G781

Requests That Encl RW Krimm Transmitting FEMA Rept of 870812 Full Participation Exercise at Facility Be Forwarded to Licensee

ML20149G781
Person / Time
Site:	San Onofre
Issue date:	02/12/1988
From:	Matthews D Office of Nuclear Reactor Regulation
To:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML13333A684	List: ML13333A683 ML20149G781
References
NUDOCS 8802180408
Download: ML20149G781 (2)

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UNITED STATES RECEIVED NUCLEAR REGULATORY COMMISSION URC o

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February 12, 1988 F.D FE919 P 12: 11 2 MEMORANDUM FOR: Ross A. Scarano, Director Division of Radiation Safety and Safeguards Region V FROM:

David B. Matthews, Chief Emergency Preparedness Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation

SUBJECT:

FEMA REPORT ON THE AUGUST 12, 1987 SAN ON0FRE EXERCISE The enclosed memorandum from Richard W. Krimm, dated January 29, 1988 transmits the FEMA Region IX report of the August 12, 1987 full participation exercise at Diablo Canyon. We request that you forward the enclosed memorandum and attached report to the licensee.

cd David B. Matthews, Chief Emergency Preparedness Branch Division of Radiation _ Protection and Emergency Preparedness Office of-Nuclear Reactor Regulation FEMA Memo dtd. 1/29/88 4

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MEMORANDUM FOR: Frank J. Congel Director Division of Radiation Protection and Emergency Preparedness Of fice of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission FROM:

Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

Exercise Report for the August 12, 1987, Exercise of Offsite Radiological Emergency Preparedness (REP) Plans for the San Onof re Nuclear Generating Station Attached is a copy of the Exercise Report for the August 12, 1987, full participation joint exercise of the of fsite REP plans for the San Onof re Nuclear Generating Station. The State of California and Orange and San Diego Counties, all located in the 10 mile plume emergency planning zone (EPZ), participated in the exercise.

The exercise report was prepared by the Region IX staff of the Federal Emergency Management Agency (FEMA).

There were no deficiencies identified during this exercise. A schedule of corrective actions is included in the exercise report which addresses the areas requiring corrective actions.

The Region will assure completion by the State of the necessary corrective actions.

Based upon the results of this exercise, there continues to be reasonable assurance that appropriate protective measures can be implemented by the of f site jurisdictions around the San Onof re Nuclear Generating Station to protect the health and safety of the public in the event of a radiological eme rge ncy.

l If you should have any questions, please contact me at 646-2871.

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EXERCISE EVALUATION: REPORT OFFSITE RADIOLOGICAL EMERGENCY PLANS AND' PREPAREDNESS

. SAN ONOFRE NUCLEAR GENERATING' STATION EXERCISE i

EXERCISE PARTICIPATION IDENTIFICATION Facility San Onofre Nuclear Generating Station License'e Southern California Edison Comp 3ny Location Camp Pendleton Marine Corps. Base (Nearest. City: San Clemente)

San Diego County State of California Date of Exercise Report October 9, 1987 Date of Exercise August 12, 1987

. Participants Southern California Edison ~ Company c

State of California Grange County s.

San Diego County City of San Clemente

City of San Jua.' Capistrano Camp Pendleton Marine Corps

California-Highway Patrol

California Parks and Recreation

Amateur Radio Emergency Services American Red Cross Non-Participants None 4,

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EXERCISE EVALUATION REPORT OFFSITE RADIOLOGICAL EMERGENCY PLANS AND PREPAREONESS S4N~ONOFRE~ NUCLEAR GENERATING STATION EXERCISE r

TABLE OF CONTENTS tDescription

.Page Exercise Participation Identification 1

Table of Contents 2

Exercise Summary 3

Exercise Detail:

4 Amate.ur Radio Emergency Services 6-American Red Cross 6

California Highway Patrol.

6 Camp Pendleton Marine Corps 6

City of San Clemente

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City of San Juan Capistrano 8

' Emergency News Center 9

Emergency Operations Facility 10 Offsite Dose Assessment Center to Orange County 12 Radiological Field Monitoring Teams 13 San Diego County 14 State Parks and Recreation 15 Exercise Findings Matrix 17 ATTACHMENTS A.

Evaluator Roster 23 8.

Exercise Objectives 24 C.

Scenario Summary 27 D.

Time.Line Sequence of Events 33 E.

1955 Biennial Exercise Fincings Matrix 34 F.

Status of 35 FEMA Cojectives/?R-1 37 G.

Past Major Milestones 40 i !

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EXERCISE EVALUATICN REFCRT OFFSITE RADIOLCGICAL EMERGENCY PLANS AND PREPARECNESS SAN ONOFRE NUCLEAR GENERATING STATION EXERCISE EXERCISE

SUMMARY

Representatives of the Federal Emergency Management Agency (FEMA) and Regional Assistance Committee, (RAC),

Region IX, evaluated the offsite jurisdiction participation in the radiological emergency plans and preparedness exercise conducted at the San Onofre Nuclear Generating Station on August 12, 1987.

The or, site participation in the exercise was observed by the United States Nuclear Regulatory Commission, Region V,

(NRC-RV) representatives.

The onsite evaluation findings will be reported separately by the NRC-RV.

The objectives established by the offsite jurisdictions were demonstrated and/or simulated.

All but three of the objectives were successfully demonstra,ted.

The list of objectives are a part of this report (see Attachment B).

Objectives 3, 5 and 6 were not satisfactorily demonstrated by all of the offsite jurisdictions.

The evaluators observed, as a whole, that the offsite jurisdiction emergency response operations reflected that definite attention and individual effort was being given to radiological emergency preparedness measures. However, the primary purpose for conducting an exercise is to identify areas of weakness for continuous upgrade to the total system. Exercise evaluators determined areas requiring corrective action to be :

1) completion of plan updates; 2) improved procedures for alert and notification publit information/ instruction via the Emergency Broadcast System; and 3) protection for erergency workers implementing radiological emergency response operations.

Details of the evaluator observations are more specific in the Exercise Detail and Exercise Findings Matrix of the report.

The areas recommended for corrective action, outstanding from the 1995 exercise (i.e., Emergency News Center and Public Information Officer news releases; planning updates; and Emergency Broadcast System (EBS) radio station timely dissemination of public information/ instruction),

were observed and evaluated.

All areas were reported as being greatly improved and/or corrected.

The plan update recommendation will remain as a corrective action finding pending final completion.

The potential for public confusion as a result of conflicting onsite and offsite jurisdiction protective action recommendations via news release or media briefings has been eliminated.

The Emergency Broadcast System radio station KE2Y demonstrated both awaruness of its responsibility and capability to receive and release public information/ instruction.

Details related to these areas of emergency resconse are presented later in this report.

EXERCISE EVALUATION REPCRT 0FFSITE RADIOLOGICAL EMERGENCY PLANS AND PREPAREDNESS SAN ONOFRE NUCLEAR GENERATING-STATION EXERCISE

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EXERCISE DETAIL An outline of.the historical radiological emergency plans and preparedness activities accomplished by the offsite jurisdictions in and around the San Onofre Nuclear Generating Station is provided in this report at Attachment G.

.The offsite jurisdictions within the plume exposure pathway emergency planning zone; i.e.,

City of San Clemente, City of San Juan Capistrano,

-County of Orange, County of San Diego, Camp Pendleton Marine Corps Base, and California Department of Parks and Recreation) entered into an Interjurisdictional Agreement with the utility (Southern California Edison

' Company) during 1982.

The Interjurisdictional Planning Committee meets on a monthly basis to determine common objectives and decide issues related to an effective and coordinated energency response capability and preparedness measures,needed for effecting such a response to a radiological emergency at the San Onofre Nuclear Generating Station..All of the offsite jurisdictions participated in the exercise.

The State of' California Office cf Emergency Services (CA-0ES) Operations-Center and Dose Assessment Center participation in the exercise but their participation was not evaluated.

A full-scale exercise at another nuclear power plant site within California will be conducted soon and the CA-GES will be evaluated at that time.

The site-specific State participation.

(Department of Parks and Recreation and certain liaison activities at various emergency response operations facilities, etc.) was evaluated.

Within the State ofeCalifornia, by State Law, local' jurisdictions have the primary responsibility for emergency response to any disaster within their incorporated boundaries.

There is a statewide Master Mutual Aid Agreement.

The State supports local government efforts, when requested, and coordinates a requirement for further assistance from the Federal Government.

The State has primary responsibility for the ingestion pathway zone emergency response activities at all nuclear power plant sites within the State.

The exercise scenario was developed by staff of the Southern California Edison Company.

The exercise objectives and scenario were submitted well within the required milestones established.

They were reviewed and approved b,'-

the Federal Emergency Management Agency Region IX, (FEMA-RIX) and the U.S. Nuclear Regulatory Commission, Region V (NRC-RV).

The exercise objectives are reflected in Attachment B to this report.

The scenario summary is Attachment C to this report.

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, EXERCISE DETA!L-(continued)

A time-line chart of declared events and receipt of notification at the various response. operations. facilities is shown at Attachment D.

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- The list of exercise evalua'ter assignments is located at Attachment A.

.The. evaluator. assignments, location of evaluation sites, backqcound materials, objectives of the exercise, scenario summary, and other' pertinent information wes provided to all assigned evaluators by mail on July 22, 1967.

The exercise evaluation criteria and process was presented to ano coordinated ~ with all offsite exercise participants to provide aa understanding of the process and responsibility.

On August 11, 1997 the evaluators were briefed by the RIX Project Officer for. the Radiolog: cal Emergency Preparedness program and then provided with an orientation by 1

offsite jurisdiction representatives on their plans and operations. Many f

evaluators accompanied offstte jurisciction representatives to thetc emergency operations centers for familiart:ation with the facility and the players (e.g.,

decision-makers, direction and control group, communications systems, etc.).

The exercLse was evaluated on the basts of a jurisdictional capability to.

I implement current radiological emergency response plans ans in accord with:

1) 44 Code of Federal Regulations, Part 350, Review and Approval of State and Local Radiological Emergency Plans and Preparedness;. Final Rule, September 28, 1983;

2) NUREG-0654, FEMA-REP-1, Rev.

1, Criterta for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Novemoer 1990;

3) the Federal Emergency Management Agency / Nuclear Regulatory Commission Memorancum l

of Understanding, April 1985; ano 4) establi:hed Federal Emergency i

Management Agency policy, criteria, and guidance.

l The Federal Emergency Management Agency / Nuclear Regulatory Commission

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Memorandum of Understanding establishes categories of exercise findtngs ast

1) deficiencies; 2) areas requiring corrective actions; and 3) areas i

recommended for improvement.

Deficiencies are generally addressed in accord with Guidance Memorandum EX-1, Remedial Exercises, dated July 15, 1983.

Areas requiring corrective actions are cited in the Exercise Findings Matrix of this report.

Areas recommended for improvement are noted in the i

jurisdictional text that fellows (by individual jurisdiction, agency or facility title).

The 1985 biennial exercise areas requiring corrective action, pending at the time of this. exercise, were caserved and evaluated.

A copy of the Exercise Finding Matrix from the 1985 olennial exercise recort is included in this l

document at Attachment E.

Evaluation findings f rom ooservations during this exercise are noted directly on the matrix form.

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.e EXERCISE DETAll (continued)'

Guidance Memorandum PR-1.

Policy on NUREG-0654/ FEMA-REF-1 and *4 C~R 350 Periodic Requirements, establishes a six year period for acc:colishnent of major Radiological Emergency Preparedness (REP) program elements ey state and local offsite jurisdictions.

The first joint exercise at thts site was conducted on May 31, 1981.

Thus, the six year cycle.for. this site erdsd on May 31.

1997.

Attachment F sets forth the status of the offsite jurisdiction compliance with these requirements.

t The following comments, by individually assigned evaluators, offer areas I

recommended for improvement and/or noted as being of very nigh quality.

I Amateur Radio Emergency Services.

The activities of this grcuo were not evaluated, but evaluators did observe the volunteer participatton in the exercise.

It was apparent that the system was activatec and woulo De an invaluable asset for radiological emergency response operations.

The volunteers of the Amateur Raoto Emergency Services are commended for their dedicatea work.

American Red Cross.

Clearly demonstrated a capaoility to implement i

procedures for providing mass care.

health services.

family services, communications and respond to disaster welfare inquirtes.

Roles and responsibilities were well understood by the staff.

Decision-making was timely and. coordinated.

The liatson assignments were effectivel) utilited and individuals assigned were efficient.

Overall commencations for a job well done.

California Highway Patrol.

Limited participation due to the sccoe of the exercisu (e.g., no actual demonstration of traf fic control, etc.).

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activities were effective and effictent.

Simulated response acttvittes

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indicated a high-level of awareness with regard to assigned areas of responsibility. Overall performance was commendable.

Camp Pendleton Marine Corps Base.

Emergency response operations at this location are in accord with military plans.

Because of the proximity of the nuclear power plant site to the Base, evacuation is generally effected during the Alert emergency level.

Evaluation at this site is confined to

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those emergency operations that interface with state and local offsite juelsdictions.

The Base communications with offstte jurisdtettons is yta the "yellow" telephone net.

Liaisons are assigned to the Emergency i

Operations Facility and Emergency News Center.

Teams are assigned to activities of Radiclogical Field M:nitoring.

See below at Radiologtcal Field Monitoring Teams for more informacion.

fhe evaluator observed that exercise particication concentrated on training newiv assicned iroividuals

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...'a EXERCISE DETAll (centinued) whs had.not previously been involved with this type of activity.

The plan was dated 1979. Various emergency response operatiens effecteo were not-in accord with the plan (e'.g.', designated communications, emergency cperations

conter floor. plan designations, etc.).

During the 1955 biennial er.ercise, a

major. finding related to the need for regular updating of radic!cgical emergency response plans.

See Attachment E.

It is suggestec that the existing plan be updated to be in consonance with offsite jurisdiction emergency response plans and trainirq be provided to key emergency acrAers for effective. implementation of the plan.

The evaluator noted the performance at this location to be very active and valuable in terms of training and useful for refinement of procedures.

City of San Clemente.

City Officials who are assigned decision-making responsibility for emergency response operations were not able to participate in the exercise due to a priority hearing on official city business.

The next in command, the City's Fire Chief, was required to att as both the City Manager and the City Council.

His perf:reance was competent, reflected familiarity with the areas of assigned resocnsibility, and effective in decision-making activities, The Emergency Operations Center facility has undergene modificatten since the last official exercise and is new considered to be mucn acre effectivo.

i The activation and staffing of thit facility was well demonstrated.

Excellent conferencing and decision-taking was observeo, including an awareness of the 15-minute time limit Jetween a final decisian for a puulic protective action and notification of the public.

Goed team work was j

demonstrated by most emergency operations center personnel, with staff showing good knCwledge of their specific duties and making centributions f

toward decisions for actions required for various upgrades in plant status and for protective acticns.

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Communications systems available at the Emergency Operations Center are l

i excellent and functioned well during the exercise.

The "yellow" telephone l

net speaker pnene capability allowed key Emergency Operations Center staff L

to know what was going on and to contribute to the decision-making process,

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as required.

The siren system, route alerting, school notification procedures, etc.,

are all well established to alert the public and schools in a timely and orderly manner.

The Emergency Operations Facility Liaison for San Cleeente was effective in j

inferming the Emergency Caerations Center of activities and as an ef fect tve j

backup check on information being reported via the "yellow" telephone net.

San Clemente is well ecuipoed to handle evacuation and access centrol.

Plans ano agreements have been established to obtain assistanca from the California Highway Patrol, State Parks, etc., as recuireo.

The Emergency i

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EXERCISE DETAIL-(continued)-

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Operations Center is-well equipped and plans are well estaolished to hanole evacuation of special. evacuees, as well.

(Note:

Another exercise evaluator assigned to observe fiel'd operations reported that inquiry of private schools within the emergency planning zone resulted in a lack of knowled;c with regard to evacuation procedures and that they had not received cooles of the public information brochure.

This will be clarified in the final report.)

Two radiological field monitoring teams were discatched that reocrted

.directly'to the Offsite Dose Assessment Center.

See the 'Offsite Dose Assessment Center and Radiological Field Monitoring Team comments reported below.

Some confusion existed relative to the distributton of docimeters wherein the City was of the opinion that personal film badges were sufficient.

The Exercise Findings Matrix portion of this raport contains an area requiring corrective action that further explains this area.

During th.g 1985 biennial exa--ise, a major finding related to the need for regular updating cf radiological emergency response plans.

See Attachment E.

The City of San Clemente was reported to have had signtficant difficulty in recalling emergency response personnel due to inaccurate telennone numbers.

The current plan is dated 1983 with no known update or changes.

Evaluators were informed tnat the City had updated the plan during 1987, but no copies of the changes were provided or submitted to FEMA.

It ts j

recommended that the City of San Clemente develcp a system for regular updates to the plan in accord with NUREG-0654 It is further recommenced that the standaro operating procedares and interjuctsdictional proceouros te reviewed and updated to reflect the requsred coordination a mo r.g the j

jurisdictions.

The overall finding of the evaluator observing Emergency Operations Center activities for the City of San Clemente reported it as being "exemplary performance."

City of San Juan Capistrano.

The City of San Juan Capistrano just completed revision of their radiological emergency response plan.

The City contracts with the County of Orange for police, fire, transportation, etc.

Therefore, the major emergency response operations for this locattom include decision-making,-directing County resources, liaison activities within the Emergency Operations Facility and Emergency ?!ews Center, ccmmunications, etc.

These duties were observed as being carried out in an orderly manner and staff were very familiar with their roles and the olan.

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Even thougn the City just completed a plan revision, the

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', EXERCISE DETAIL (continuec) interjurisdictional procecures need to be reviewed and updated to reflect the coordination among the jurisdictions.

During the 1985 biennial exercise, a major finding related to the need for regular updating of radiological emergency respo'nse plans.

See Attachment E.

The City of Ean Juan Capistrano should consider development of a regular system for annual update of the plan, as well' as the update of standard cperating procecures and/or interjurisdictional procedures.

Emergency News Center.

The Emergency News Center, its staff ano tne operations within that facility received the highest number of commendations submitted by any assigned evaluator.

The commendations related to organi:ation, procedures, personnel at ti tude, securi ty, media accreditation.

sound system, timeliness of briefings, role playing of simulator staff.

communications, drill identification, etc.

The Emergency News Center was recently transferred from the El Toro District Office of the Soutnorn California Edison Company to the newly cons truc ted Saddleback District Sarvice Center at Irvine.

This was the first exercise of the joint information system emergency response apcrations within that facility.

The procedures were also revised and incorporated several new processes.

For example, instead of merely posting a copy of the news releases and emergency broaddast station messages, coptes were provided to each media representative by a media liaison person.

The posting of plant conottions was excellent in both the media center and the puolic information officer work area.

All of the objectives established for the Emergency News Center were met.

No deficiencies or corrective action findings were submitted.

The credibility of the Emergency News Center (medta briefings ano information flow) was enhanced by the appearance of a Sbuthern California Edison Company Vice : resident, Kennetn P.

Baskin.

Mr.

Easkin is tne Emergency Coordtnatar for the Emergency Operations Facility and flew to tne Emergency News Center from the Emergency Operations Facility via helicopter to support this facility.

For future consideration, the evaluator of fered the following suggestions to enhance information being provided to the mediat 1.

While the new system for distribution of news releases and emergency broadcast system eessages is sufficient, it is reccmmended that they be posted within the facility for easy reference by all using the facility and that a sta*us board be maintained for easy reference.

2.

Explanation of a classification char.ge should be 9

t EXERCISE DETAIL (continued) provided to the media in a more expedient cancer (tne General Emergency'was posted at 10:45 A.M.,

but the explanation was not provided until 10:54 A.M.).

More detailed infcreation as to the scunding of the sirens to advise the public to tune to the emergency broadcast station, information to disabled persons, and general information relative to the p.stcetive actions being implemented should be provided for the energency news conter/ redia.

4 The meeta packets could include general information about the local area (motels, restaurants, maps, etc.).

5.

The graphics and the name identification signs at the speaker table could be ennanced by erlarging (in tne event the facility becomes over-crowood).

6.

Typewriters for use by mocia and public information officers would be useful.

Emergency Operations Facility.

Evaluation of tne offsite related activities in this facility revealra no significant problem areas requiring corrective actions.

As demonstrated in previous exercises, the offsite representatives in the Emergency Cperations Facility were knowledgeable about their assigned duties and carried out tnotr resoonstb111 ties efficiently end e#fectively.

Appropriate coordination was matata: red by the liaisons between the Southern California Edison Cceaanv management grou:.

their rescectiva emergency operations conters, and other Czergency Operations Facility activities, aucn as the Offsite DoseeAssessment Center.

Observed ac tions taken by the Emergency Operation = Facility Liaison group contributed to the successful acccmplishment of the Onsite Objective No. 6 and Joint Objective No.

1.

I Offsite cose Assessment Center.

The objectives established for demonstration Dy the Offsite Dose Assessment Center (CDAC) included Offsite Objectives 1. 3, 4, 6 and 8 and Joint Objectives 1

and E.

All tne objectives were satisfactorily demonstrated at the CCAC.

The physical space actually avallao;e for 00AC activities within the Emergency Operations Facility is extremely cramped.

It is beltaves that the limited space would be detrimental to crolongec occu ancv and :n:rease the stress level during an actual emergency.

In the case of :htn.

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EXEP.CISE GETAIL (continued)

V particular kxercise, the confined space provided the' primary CDAC pla/ers with A.awerenes'1 of: the developing situation.

The Emergency Operationc Facility !f0F)' Public Address System provided a further awareness ofJthe overal's situation ano activities, even when they could -rot physically be

.present for the briefings.

The use and maintenance of emergency status signs and status boards was' excellent.

The technical interfaces observed as areas involved with the CDAC included:

1) access;

2) EOF briefing function; 3) accident assessment and utility plant status. liaison; 4) dose assessment and state quality control: 5:

radiation monitoring control; 6) protective ac tion recommendations t and 71 ingestion pathway and recovery considerations.

The overall ODAC operation, management and accomplishment of assigned or necessary functions was very good.

Constant communications between tne ODAC

.and different areas of influence were ascertained as:

1) -plant status representatives at the Technical Support Center (TSC); 2) Offsite decision-

. makers; 3) State Operations Center / Dose Assessment Center (telephone contact only); and 4) Offsate Radiological Field Monitoring Teams (RFNT) (exceot for that of Camp Pendleton).

The ODAC management recogni:ed and obtaineo radiological inforea7 ton for the ECF amotent environment.

They are to be commended fcr this action.

The ECF is an onstte facility located very close to the nuclear power plant site.

During the alert and notification arrival period at the ECF (8:15 A.M.

to 9:45 A.M.),

radiation was present because of a scenario release.

this inforeation (170mR/hr at 8:15 A.M. to 65mA/hr at 9:00 A.d.)

was availaole from a fixed monitor (a PIC) located at tne EOF.

Thus, tnis information snould have been available at the TSC.

The evaluators believe notification should have been provided. through the main gate for persons arriving and other actions should also have been considered.

In addition, personnel entered the EOF after traversing a possible ' contaminated area and no personnel monitoring was performeo.

Consideration to the need for determining the extent of exposure in that area prior to sending liaisons to the EOF should be addressed in the ' alert and notification plans of the offsite jurisdictions.

ODAC control of radiological field monitoring teams is provided by radio from the EOF. The communicators are from the San Clemente Fire Department.

Team control was judged to be excellent.

ODAC Managers-'need to consider using field tcans in a traversing pattern, monttoring en route at various points, to define the plume boundaries. Use of fixed monitoring points only may not provide the desired information.

Al.o, there is a constant need to rememoer to pass information ba:k-to the field teams relative to events ano concit tons at their Iccations.

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,EkERC15E DETAIL (continue )

Orange County.

The County had several key smergency managsment staff changes recently so this exercise was extremely impcetant t0 the County as a training event.

The staff was mobilizec prc ptly and the Emergency 0:arations Center was declared operational within thirty minutes of the Alset notification, witn all of the agencies listed in the plan representec.

The utility representative in the Emergency Operations Facility recommenced a protective action to the offsite jurisdictions at the General Emergarcv level.

The Offsite Dose Assessment Center (CDAC) concurred in tne recommendation which was based on plant statur. and the octantial for a najcr release.

The offstte jurisdiction decision-makers, an:

the Emergency Operations Facility representative, discussed the protective actions and arrived at a ccordinated decision on the protective action.

The Direction and Control group continually reviewed the radiological data being provided to them by the Offsite Dose Assessment Center (CDAC) to evaluate the need for directing emergency personnel te ingest cctassium iodide (NL).

Arrangements v.ere made w:th the Sher:ff to trans:crt the KI from stockpiles to the key workers in the field. If it was necced.

The scenario did no* d' rive or recuire N1 be used by the key emergeccy workers, but the decision-making process was demonstrat?d.

Frequent, comorehensive briefings were conductec in accord with an announced schedule. Status boards were posted in a timely nenner.

A pacer trail was promptly developed and distributed.

Excellent team castioline in executir; assignments and maintaining a low level of a ise for maatmum versai communications during the briefirgs, etc. was obcorvec.

The Red Cross representatives put tnetr staffs on alert sc:ar ta tneir need and were acle to activate roccation and care actions peceptly anen neecec.

Grange County has frequently demonstrated more than acequate equipment and staffing in the area of communications.

The "yellow" telephone net was observed as teing highly improved c'perationally.

There appeared to be a need for more training in communications systems at the emergency operations center.

The Chief of GSA Communications was on vacation during this important event.

While the previous findings concerning the Energency Broadcast System station (KE2Y) have caen carrected, there is still a need for core work in this area.

See the Exercise P;ndings Matrix cf this report for more information. On the positi.'e side, it shculd be noted that this is the first exercise in which KE2y has agreed to particicate and it as at a tree when the majority of the rac:a statten staff were accent.

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• EXERCISE. DETAIL (cont'inued)

.When the County decided that a State Emergency Declaration was needea to assure that the evacuated population could be properly handled, one of the EOC staff began to draft a proposed declaration.

This drafting process required a considersble amount of time.

There are several optiens o~en to.

the County for improving this system. ' There can be "stock messages" mado a part of the plan, or that. responsibility could be oirected to the State Liaison person assigned to the ECC from the State Regional Office, cr a consistently planned activity that merely included the request be.made of the state and the state would be responsible for preparation of the declaration.

During the 1955 biennial exercise, a major finding related to the need for regular updating of radiological emergency response plans.

See Attacheent E.

'While Orange County did provide exercise evaluators with an updated plan the day before the exercise, there appears to be a need tc review the interjurisdictional procedures to refine the coordination aspects among the jurisdictions.

It is also recommended that the plan incorporase L regular system for annual update and tracking of annual updates.

The exercise participants at the Orange County Emergency-Operations Center met the Offsite Exercise Objectives 1, 2, 7 and 8.

Objectives 4, 6 and Joint Objectives 2 and 3 were not applicable at this locati6n.

Objectives 3 and 5 were not satisfactorily met and are addressed in the Exercise Findings Matrix of this report.

Participation at the Offsite Dose Assessment Center is noted above and Radiological Field Monitoring Team activities are reported below.

Radiological Field Monitoring Teams.

There were Radiological Field Monitoring Teams (RFMT) from four jurisdictions participating ir. the exercise San Clemente.

Orange County, San Diego County, and Camp Pendleton (USMC).

In general, all of the teams provided a good demonstration;'but there was an evident need for continued training to further the understanding of radiation and the use of instruments and dosimeters.

The San Clemente RFMT alert and notification and reporting was timely and effective.

Both teams provided a good demonstration of their ability to make measurements and understand the procedures.

The Orange County team "turn back" and other "caution" measurements need to be reviewed.

The evaluators do not believe that the present system for training'(one-day a year) is workable.

ODAC is going to be depending on field team'information and the field teams will be exiting the area.

In addition, the use of only 200mR pocket dosimeters and low range radiation detection instruments does not satisfy the intent of NUREG-0654 l l

l l

1 i

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4}f'*.*'EXERC8SEDETAIL(continuedL San Diego County's notification call was made~ to the Training Center.

The

' Training Center then notified the dispatcher at Station No. 3.

During off hours,-the Training Center effects a recorded message.

This needs to be l

checked and changed,' if necessary..

San Diego County and ODAC Managers need to determine how to use their RFMT, botn during an exercise and actual emergency.

The plan location of this team is at Pulgas Road (the lower Camp Pendleton Gate).

However, for exercise play they have usually moved up to the U.S. Customs Inspection ~

Station. Since a. radio "dead" spot has been discovered at the inspection station, the team moves up closer to the plant itself, along the shculder of I-5.

Parking along the shoulder of I-5 is not considered in the best interest of emergency worker safety.

It is suqqested that one possible alternative would be to place the team at Basilone Road and have them go ir the direction of Camp Pendleton for assessing their capability to nonitor.

Planning for actual response operations may need to direct the tean to hold back to the Pulgas Road location until it can be determined what the traffic situation is on I-5.

If I-5 is blocked or closeo, the team could then move with a police escort.

San "Diego County.

This County, like Orange County, has undergone some relatively new personnel changes at the emergency services management level.

In addition, due to bomb threats at the County Administrative Guilding, both County Officials (decision-making group) and law enforcement staff were required to be at that location.

The County Director of Office of Disaster Preparedness was required. to act on behalf of the County decision-making group and assign personnel to act on behalf of law enforcement personnel.

These individuals did demonstrate a capability to carry out the assigned responsibilities in accord with the plan.

The County Emergency Operations Center activities were essentially effective and iet appeared likely they would be efficient during a real circumstance of this type.

The Emergency Operations Certer was announced as fully activated at 9:45 A.M.

Periodic briefings were held.

Appropriate actions were coordinated to support the total offsite jur isdic t ion emergency response activities.

The facility doas nave sufficient space, telephones, lighting and equipment.

The physical arrangement of the Emergency Operations Center establishes a glassed-in area designated for Direction and Control, but it was not being effectively utilized.

This had a significant impact on the other activities taking place in the general response operations arena.

It is recommended that space allocations within the Emergency Operations Center be established as planned to permit closer coordination of the entire emergency response personnel.

The communications at this facility are excellent.

Hardware proble?s with the "yellow" telepnene net ocserved durino a pre /lous exercise. vere completely corrected and the system functioned well.

There was goed interface between the Situation Intelligence Officer and the Radiological Officer with Emergency Operations Facility liatsons..

...'#i sv f,.

')-'.

• EXERCISE-DETAll (continued)

There_was a' coordinated effort displayed in the dissemination of er.ergarcy broadcast system radio _ station messages. However, there was a prob'em area identified..More detal1 can be found in the Exercise Findings Matrix.

During the 1985 biennial exercise, a major finding related to. he reed for regular updating of radiological emergency response plans.

See Attachmen:

E._

The County presented update pages. of their 1996 revised plan to evaluators during this exercise.

It is recommenced that the County establish a regular system for_ plan update and tracking the' updates provided.

It is further recommended that the County participate in the refinement of interjurisdictional -procedures to reflect more information i

relative to the coordination among the jurisdictions.

Participation at the Offsite Dose Assessment Center is noted above and J

Radiological Monitoring Team activities are addressed below.

State _ Parks and Recreation.

Evacuation of parks, beaches, campsites, etc.

i is effected at the Alert classification level.

During this exercise, this-activity was simulated to minimize disruption to the public and staff perfgeming day-to-day duties.

Personnel who had not previously participated 'in radiological emergency plans and preparedness exercises were assigned for training purposes.

All personnel _ carried out their assigned responsibility professionally. Each of the exercise participants took their roles seriously and fully implemented procedures. Notifications were received in a timely manner.

Internal communications systems have been modified for improved. coordination of evacuation activities.

There were no unusual problems identified.

The agency carried out their assigned mission in a most effecti"e manner.

During the 1955 biennial exercise, a major finding related to the need for regular updating of radiologic-1 emergency response plans for all memoers of the Interjunisdictional Planning Committee.

The official plan for the Department of Parks and Recreation, Camp Pendleton Coast Area, on file at the FEMA Region IX is dated December, 1980.

However, the State Parks has, developed simplified procedur<s that are updated annually and the Region IX RAC approved this action.

A copy of the :most recent update should be provided officially to FEMA Region !Y for review and approval of the Region IX RAC.

See Attachment E.

EXERCISE EVALUATOR GENERAL OBSERVATIONS In addition to the areas recoxnended for improvement above, esercise evaluators offered the following observations for consideration by the offsite jurisdictions.

1 I

,e EXERCISE DETAIL (continued)

There was evidence of scenario and controller difficulties c: tad dy Me offsite exercise evaluators.

At the ODAC, infernation was cocuestcc e-several occasions by CCAC personnel but the OLAC Controller was cet present.

This forced t'he evaluators into a position of eitner havta; provide the information or to search for the Centroller.

S : o 13.-

difficulties were experienced by evaluators observing the Radiologicai Field Monitoring Teams.

Controllers are extremely iepertant to a successful demonstration of scenario established cbjectives.

They shoul be carefully selected and trained. Some of the odjectives established for offsite demonstration were simulated.

In fu ture devel:pment of ob jec t t.es, those areas intended to be simulated should be stated as such fe.g.,

simulated demonstration of traf fic control, etc.).

Offstte jurtsdictices should consider more in depth involvement during scenario develcoment to create their own messages in order to task a broader range of emergency response operations staff.

Exercise evaluators addressed the current evacuation procedures of the offsite jurisdictions and quentioned the advisaD111ty of evacuation by jurisdictional boundaries.

Discussions with offstte jurisdiction staff disc losed that the subject pas under study and there had been past difficulties with coordinatirq the timely ano orderly evacuation of San Clemente and San Juan Capistrario.

It is suggested that future discussions and studies include conside"ation to a "phased" evacuation based on exposure (e.g., areas closest to the site with a time delay for the next section of the area to be evacuated based on plume travel and projected exposure, etc.).

Evacuating entire cities at the same time will create major traf fic control problems that could resul t in greater exposure.

{,

a EXERCISE EVALUATION REPCRT OFFSITE RADIOLOGICAL EMERGENCY PLANS AND PREPARECNE55 SAN ONOFRE NUCLEAR GENERATING STATION EXERCISE EXERCISE FINDINGS MATRIX As mentioned earlier in this report, the exercise findings and processing of the exercise evaluation report will be in accord with Guidance Menorandum EX-1, Remedial Exercise, and the Federal Energency Management Agency / United States Nuclear Regulatory Commission Mer.orandum of Understanding.

The Exercise Findings Matrix will cite findings determined as areas requiring corrective actions.

Within 30 days of the exercise, the report is provided to the exercise participants and considered to be a "draft" report.

The responsible jurisdictions are requested to respond within 30 days, completing the corrective action portion of the Exercise Findings Matrix.

The final Exerc,ise Evaluation Report is required to be transmitted to the United States Nuclear Regulatory Commission within 90 days of the exercise.

Within 15 days of receipt of the report, the United aStates Nuclear Regulatory Commission w!!! notify the Federal Emergency Management Agency in writing of action taken with the licensee relative to the initiatives with State and local governments to correct inadequacies identliled in the exercise.

The Federal Emergency Management Agency, Region IX, with the support and assistance of the Regional Assistance Committee, will continue to provide technical assistance to the State and local offsite jurisdictions and will monitor progress toward optimum preparedness for protection of public health and safoty in and around the San Onofre Nuclear Generating Station. 1

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OFFSITE RADICLOGICAL EtiERCE!!CY PLAT 45 AtlD PREPAREDrJESS SAtt O!J0FRE fJUCLEAR GEllERATit:G STAT 10t1 EXERCISE EXERCISE FitJDit1GS itATRIX F i t1D it1G PROPOSED CORRECTIVE ACTI0tJ/DATE FOR COMP'LET10t; The first Orange County EBS message for siraulated release by the EBS The offsite jurisdictions "decision-makers" radio station to the public contained internally inconsistent infor-mation which would have cau,ed confusion in the public perception.

promptly discussed the data in a coordinated i

The coordinated decision made by the offiste jurisdiction decision-forum via the yellow telephone system.

Dis-makers was for announcement of the site Area emergency with no pro-cussions included a query regarding the opic recommendation.

tective actions required.

In fact the message released contained both an instruction to the public to take shelter and that no pro-A protective action decision was made at tective actions were necessary. There was no system demonstrated to 10:57 A.t!. to evacuate specific areas.

The assure that the Orange County decision maker (Operational Area Coordi-simultaneous broadcast and sounding of tha nator) uas auare of, or approved, the context of the message released.

The offsite jurisdictions (Orange County, San Diego County, San Juan sirens was set for 11:10 A.n. with instruction Capistrano, San Clemente, State Parks and Camp Pendleton) all con-to repeat the message four (4). t ams at 15 minute increments.

The drill included the curred on the pen and ink changes to the pre-scripted EBS message and simulated dispatch to the Ess station which none of these individuals caught the inconsistency. Also, the message tud been placed on alert..

The simulation at was distributed to several desks within the Orange County EOC and none 11:00 A.M., included the reading of the messag of these exercise participants, some of whom were part of the decision-and instructions.

making process, caught the inconsistency.

At San Diego County there was a coordinated effort displayed in the The pmcess also included complete coordinatio; l f

dissemination of EBS messages. However, there was a problem area f the m ssage content between the Orange i

identified.

The first EBS message at the Site Area emergency level ami San Diego County PIOS and the concurrence ' i issued by San D; ego County was not in concert with the Orange County signatum of the essage fig the orange Countej EBS message. The Site Area emergency EBS pre-scripted message agreed deezs2on-maker prior to its release.

l upon by the offsite jurisdictions was to have read: "There is a poten-tial health hazard to the public if the release continues, but there F flowing the drill, which terminated at is no need for protective action at this time."

As noted, this ms 21:23 A N, the essages wem mmi>ared for the conflict in the released message including a protective action of c nsistency.

The same form was found to he "sheltering" above in the Orange County message.

The San Diego "d J"d Cho i"f"N'C io" ""3 W"SiSCC"C-County message did not include the phrase "...but there is no need copies of the mssaw forun am! rosters of t/c for protective actions at this time."

Therefore, the sheltering drili participant s are attached.

aspect was consistent, but not as coordinated with Orange County.

Thus, Orange and San Diego were releasing conflicting information In mnclusion, the objectives of the corred ir to the public.

"Cl2 " kdN I"Il9 "'" -

In addition, the Site Area emergeacy message Two for San Diego A t tJCh*D E S County was noted as being written at 10:00 a.m. with a requested message release time of 10:00 a.m.

Their General emergency message Two was noted as being taken at 10:19 a.m. when the declaration of General Emergency occurred at 10:29 a.m.

(The Site Area emergency message Two for Orange County was t ime-marked at 9 54 a.m. and the l

...m..

. v..

..a un e OFF511t RADIOLOGICAL EMERGENCY PLANS AND PREPAREDNESS

' SAN ONOFRE NUCLEAR GEiERATING STATION EXERC3SE EXERCISE FINDINGS MATRIX t

FINDING PROPOSED CORRECTIVE ACTION /DATE FOR COMhLET General Energency message Two was tine marked at 10:36 a.m.). While I

the message was being coordinated by Orange County with other juris-dictions, the San Diego County Administrative Officer was taking 8

the information Joun in longhand on a notepad rather than making entries directly to the EBS pre-scripted message form.

These EBS pre-scripted message forms are a part of the plan.

The procedures intended to enhance the dissemination of correct and consistent are information to the public from both counties.

Thus, the EBS message forms should be readily available to whomever is responsible for participating in the coordination activities related to public in-format ion EBS cessages.

Both EBS messages contained the instruction directed to the popu-lat ion ido reside within "10-Miles" of the plant site.

The state-is contrary to the planning concept adopted by the State and ntnt Local offsite jurisdictions for this site.

The s tater.ent "10-Mi les" has no significant meaning to the public.

The EBS nessages should the saae designations used in the public inforruation brochure.

use F Based in part on the foregoing the exercise evaluator assigned to the Orange County C0C reported to the Regional Assistance Committee (RAC) Chairman that in his opinion the way Orange County officials handled the EBS rnessage con-stituted a "deficiency."

The RAC Chairman referred the natter to the RAC.

The RAC unanimously decided that the finding should be categorized as an "Area Requiring Corrective Action" and was applicable to San Diego County as well as Orange County.

The RAC requested that the exercise Project Officer obtain agreement from the of fsite jurisdicticos to take immediate corrective action and to be prepared to demonstrate the ability to quickly and efficiently process EBS messages at the next annual full activation of the siren system on Septen.ber 16, 1987. This was done and the demonstration will take place on September 26, 1987. The results will be included in the final edition of this report.

In accord with the classification as an area requiring corrective action, the offsite jurisdictions will be required to correct this Ic.a area prior to the next regularly scheduled biennial exercise during )

Corrective ac-tions will address the following areas of concern:

Interjurisdict ional procedure #5 (Alert and We_cr 3.3 requires a.

update and nndification to specifically identify p risdictional coordination and responsibility (Interjurisdictional Procedure !6

646..ce.t t.,a.u,o s on hti on 0FFSITE RADIOLOGICAL EftERCE!1CY PLAilS Af2D PREPARED: JESS SAtt Ofl0FRE IJUCLEAR GEfJERATitiG STAT 10f! EXERCISE i

EXERCISE FitJDitiGS MATRIX FitJDitlG PROPOSED CORRECTIVE ACT10rl/DATE FOR COMPLETIO:

can serve as an excellent example for accomplishment of this requirement).

2 (1) The Emergency Broadcast System (EBS) radio station will be alerted prior to siren activation and timed to follow the siren sounding by at least two minutes to permit the public to tune to EBS radio stations consistent wit h data provided in the public informc.t ion brochure; (2) The EBS pre-scripted messages will be redesigned to permi t more expedient coordinat ion and processing (e.g.,

extensive editing requirements or deletion of paragraphs intended at another Icvel of protective action will be coitted);

(3) The new pre-scripted messages will include a system for decision-maker authorization prior to release; and (4) Protective actions decided upon (e.g., shelter and/or evacuation) uill be stated in terms of boundaries identi-i I

fied in the public information brochure distributed to the public (all references to the 5-or 10-Mile emergency planning zone should be deleted).

b.

A hard-copy transmittal capability is required to coordinate both EBS messages and news releases at all emergency response facilities involved with public information releases.

Training workshops for all assigned to areas of responsibility for c.

effective public information activities related to alert and noti-fication will be accomplished after completion of the above listed activities, but prior to the next full-scale biennial exercise.

Since this exercise closed the period for accomplishment of objectives es-tablished by FEMA, in accord with Guidance Nemorandum, PR-1, Policy on NUREG-0654/ FEMA-REP-l and 44 EFR 350 Periodic Requirenents, this exercise finding will rer.ain an open item until the next regularly scheduled biennial exercise during 1989.

flUREG REFERE!JCE:

E.5 and 7.

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OFFSITE RADIOLOGICAL EHERGENCY PLANS AND PREPAREDNESS SAN ON0FRE I:UCLEAR GENERATING STATION EXERCISE EXERCISE FINDINGS MATRIX FINDING PROPOSED CORRECTIVE ACTION /DATE FOR COMPLET10;.

2.

Radiological Exposure Control.

The City of San Clemente failed to issue any emergency personnel with dosimetry. The Director for Emergency Services the City Emergency Operations Center (E0C) was of the opinion that at 8

personal film badges were sufficient to fulfill this requirement. A number of ECC staff need to be issued self-reading recording devices to ensure that personnel are not receiving excess exposures.

Provisions should also be put into the plan for any EOC personnel who may temporarily leave the E0C to first be issued dosimeters (unless the dosimeters are pre positioned in vehicles being used). Also, a number of non-cmergency EOC personnel occupy the building within which the EOC is located (e.g., police and fire person-nel).

Thus, the plan should be modified to include dosimetry use by these people.

'JUREG

REFERENCE:

K.3.a. and b.2.

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. ATTACHMENT 7.2

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"CENERAL EMERGENCY MESSACE TWO" Evocuation Required

~

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EBS Release No.

.I Date 9-/4 f 7 Time 6.c.d II. 9 3 Nome

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$WyYC. hic t.:t ]

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Title C A G.

Request Message Release Time d64)

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< In2/o.m.

Additional Information to be provided av ft4 e24 t/d n.m. /o.m.

Repeat message every (in what time increments) /5/NMa/c'z ond (how mcny times should it be repeated) 8Mlf* /

Message Contents to be released:

1.

Your of tention, please. This is on Emergency Broadcast Message from the

~

(jurisdiction (s))

1. (" S/>(,

WC,,

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2.

This is N@,Etwi-wr a drill. I repeat, thrs,s NOT v.est or o drill.

3.

Stond by for information of importence.

4 on (dcte) c? /6 -J 7, at (time). 7a.

M: /I e6/e.m.

o CENERAL EMdRCENCY was dectored by the menagement of the Scn 0$ dire Nuctecr Generating Stction, located four miles south of the City of Scn Clemente, in the County of Scn Diego.

S.

This CENERAr. EMERCENCY involves

/o4h

- Q ase of radioactive materials to the environment wW(a' pcuti ld cause) o p/s Smede ublic heelth har rd.f/g/aal,frzewergug cT da um 44 W/#

A

. uj u'.nj ho r.9.p.8<

. ( Addi tional inf ormation). '

_.,/A-Md 6.

Utility personnel are working to return the generating station to a safe condition cs soon as possible.

7.

Emergency sirens around the genercting station have been sounded to alert the public to turn on their radios or televisions for information.

8.

Residents of Camp Pendleton should follow emergency instructions issued by Morine Corps officicts.

9.

Th9 foliqying state becches and pcrks have been closed jtn MlMtt Y

.At w (te mt.e t(t.

Visitors to the becenes cod pcrks cre asked to follow instructions from pcrk rangers and lifcquords.

EMD.12d IPS.19 7.2 10/S4

...,. m. : w o c.

. r 4..;r..... 7..,..

o Genercl Emergency Messcge Two continued 10.

Public sofety of ficiols cre requesting thct persons in the followin,: crecs !

recert to their designated Reception end Cere Center es listed in'their emerce cv iniormation pcmphFet. (This scme information moy otso be found in the Orcnge County - South public telephone directory.)

' ' En.s k. (T.',c.x:b W

• Q. Cteman. - hst[cmcre. Oni 7rne'

,tesidentx4 v' v-of Sca. Clement.e shou

.' eve-th esi nclid., dept!.o_n,,pn.d,,Ccij.C. ater.)M

• e erWa.ir-inrr-WM 9

.M 9

(c.:f

.f W (If you are in the Cities of Son Clemente, Son Jucn Copistreno Dcno Point, please leave the creo. Report to the designated Reception and Core Center identified in your emergency informcticn

~

~

pomphlet.)

All exit routes will be clearly mcrked cnd controlled b 11.

Evocuote even if your spouse is at work or your children cre at school. CO N wait er ottempt to relocate with them. Students in school will be evccucted to Reception end Core Centers designated for their schools. They will be reun their fcmilies of a later time.

12.

If you hcve a recreational vehicle or ccr, plecse use it to drive to the Rece Core Center.

13.

If you con provide trcnsportation for o neighbor, plecse do so.

14 If you have no transportation, walk to the nearest Assembly Point indicate end Ccre Center. emergency information pamphlet. You will then be transported t I S.

If you cre o resident of Son Clemente, Sen Juan Capistrano, Capistreno Dona Point, go directly to the Reception end Core Center designated fo 16.

should go to the Reception and Care Center desig information pcmphlet that was provided to the business.

l

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. Cznsrol Emergsney M2ssaga Two continued

- 17.

Before leaving, please DO fhe following:

a. ' Ensure that all members of the hovschold cre cdequet.:iy dr.:ssed f er cuidect cetivity oppropriate to the seosen.

b.7 ClBsy (ll'GA,nd'os/s[ond dec;ies.

'~

c. Turn of f all air conditioners, exhaust fons cnd clothes dryers.

d. Turn of f all lights and electrical oppliances.

e. Turn of f the main water volve to the house.

f. Shelter pets and leave o three-day supply of food cnd water,

g. Bring bedding for each member of the family, such es sleeping begs or blcnkets ond pillows.

h. Bring a three-day supply of toilet articles cnd underclothing.

i. Bring prescribed medicines cnd baby formula foo6, as needed,

j. Bring a small cmount of cash and your checkbook.

k. Close and lock all exterior doors; security for the evacucted area will t:e proviced.

. 18.

At the Reception end Core Center, you will be ke; t informed of the emergency status and unen t,o return home.

I ?.

No actions need to be taken by citizens in other crecs of Orcnge County or Son Diego County.

20.

This is MCT ; * : 3 = a drill. I repeat, this is NOT+;eWr o drill.

21.

To repeat... (repeat items 4 through 19).

22.

Stay tuned to this station for further of ficial information.

EMD.12d

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IP (15 ATTACHMENT 7.2 "GENERAL EMERGENCY MESSACE TWO"

. Evacuation Required

$~.]'

Date.

')!/t, l5 ?

EBS Release No.

Time

/0 ' i:$.

Ncme Scd $ te Ti tie ],,,, E-1 oht Request Message Relecsc Time _ lllNb c.m.h:.&

Additional Infermation to be provided et-n m. J l d, l e.

ew

-~

Repeat message every (in what time increments)

/5'u,,m,.-je.s cnd (how mcny times should it be repeated)

'/.,/-' a, e e, Nessage Centents to be relecsed:

1.

Your ottention, piecse. This isjn Emergency Broedecst Messcge from the (jurisdiction (s)) Orw NM b'T),-m d.os.4 n L C.l, fe d

$m < su G

,k.

2.

This isem.... ;+ o drill. I repeat, this is-o drill.

Y 3.

Stend by for information of importcnce.

4.

On (dcte)

'/.!/ h 57

, at (time)

/c.' @f'

/G) /e.m.

o GENEP.AL EtAEHCENCY wcs declered by the mcnagement ct the Son ort 6f re Nuclecr Generating Station, loccred four miles south of the City of San Clemente, in the County of Son Diego.

5.

This CENERAL EMERGENCY involves on cetuhhd,: e4 release of radiocefive matericls to the environmen jgg,nygdrM o public heol'h hazcrd n e ful w Sm,.e.u c.,

. ryc M e uJ 4. rulific. kJ&

(Additional information).

m.:e i u A 5' m., %,., e u,,s.L.,- % ll.

/

/

6.

Utility persennel cre working to return the generating station to a sofe condition e.s soon cs possible.

j 7.

Emergency sirens cround the generating station have been sounded to ciert the public to turn on their radios or televisions for informatien.

8.

Residents of Camp Pendleton should follow emergency instructions issued by t.'.crine Corps officicis, 9.

The following state be ches nd parks have been closed J,a D,u,(,,

es.,9 Cle wh 91Nrs to tne decenes cno pcrks cre asked to follow instructions trem p e e. <

l and lif eguards.

.,.o-..*J 1.' e pe **.= \\

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5 IPS.l7 7.2 l

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i

' Genercl Emergency Messcge Two continued 10.

Public safety officials cre requesting that persons in the following crees feeve end i

report to their designated f3eception cnd Ccre Center cs listed in their emercenev information pamphlet. (This some information mcy clso be found in the freni of rne y"

Orcnge County - South public telephone directory.)

~ E w.,!c. 'T L.x M M NO*ty-chGen Cte myn ehs([cymere dniv':gr l

,ccr.idents-ob. C 'v.of Sc:LCl eme nt.c.s hou br iee ve-th evilaw.m y5rr-to4he aesigncied3dep,t,,ic,n,en,d,,Cgifdater.M

...._.....s_

j is 1

b y.-; (if you cre in the Cities of Scn Clemente, San Jucn Cepistreno N Ocno Point, piecse leave the creo. Report to the designated,cnd Reception end Care Center identified in your emergency informcticn pamphlet.)

l Follow the evacuation routes indicated in the emergency infermoti*on comphlet m!

All exit routres will be electly merked cnd control. led by emergency perwnnel.

{

t 1.

Evcevate even if your spouse is at work or your children cre of school. DO NOT wait or attempt to relocate with them. Students in school will be evccucted to Reception end Core Centers designated for their schools. They will be reunited witn their fcmilies at a later time.

(

12.

If you have a recreational vehicle or ccr, please use it to drive to the Reception end Ccre Center.

i 13.

If you con provide trcnsportation for c neighbor, plecse do so.

l 14 If you have no transportation, walk to the necrest Assembly Point indicated in the l

emergency information pamphlet. You will then be ircnsported to your Receptien i

cnd Care Center.

I S.

If you cre o resident of San Clemente, Scn Jucn Ccpistre no, Copistreno Decch, or Ocna Point, go directly to the Reception end Core Center designcted for your home, i

16.

Employers, employees, cnd customers who cre not residents of the creos cnnou should go to the Reception end Ccre Center designated in the emergency r

information pcmphlet that wcs provided to the business.

t i

t g MO.12d

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I IPS-20-7.2 a

' 4.f;c m & & %c $ $ 9 ? ?.;.1!5 0 7 W i

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F

' Gen:rol Emergency Messege Two continued-17.

Before leaving, please DO the following:

a. ' Ensure that cil members of the household cre cdequately dressed fer cutdear activity oppropriate to the secson.

bT ClBse 311 Tvind' ws 'cnd dre;ies, o

c. Turn of f all air conditioners, exhaust fcns cnd clothes dryers.

d. Turn of f all lights cnd electrical cpplicnces.

Turn of f the mcin water volve to the house.

e.

f. Shelter pets cnd ' eave a three-day supply of food end wcter,

g. Bring bedding for ecch member of the fcmily, such cs slecoing begs or blcnkers and pillows,

h. Bring a three-day supply of toilet crticles cnd underclothing.

i. Bring prescribed medicines cnd baby formula food, cs needed.

j. Bring a smcil cmount of ecsh and your checkbook.

Close cod lock cll exterier doors; security for the evacucted crea. vill te k.

proviced.

. 18.

At the Reception end Cere Center, you will be kept informed of the emergency status cnd when tp return home.

l ?.

No cetions need to be tcken by citizens in other crecs of Orcnge County or San Diego County.

20.

This is NC'. * ;' - o drill. I repeat, this is ON:a er o drill.

21.

To repeat... (repeat items 4 through 19).

22.

Sicy tuned to this station for further of ficici information.

- n..

EMD. I 2d

!PS-21 -7.2

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Exercise Participants Dennis Smith State of California Christine Boyd Orange County Peter Lawrence Denise Reed 11elen Lotus Tom Amabile San Diego County Richard flamilton Willard Lewis Steve Danon

~'

San Juan Capistrano Cynthia Ferguson Jack Stutbs San Clenente Jack Wallace SONGS Phil Dooley Exercise Evaluators Orange County EOC Joseph D. Domingue San D'iego County EOC llarold Aldrich SONCS EOF Terry Knight e.

e se

' 4.

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l 4.,.. 444uant 94(;cc.f,N.Q'.W Pg l

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EXERCISE EVALUATICN REFCRT i

OFFSITE RADICLC3ICAL EMERGENCY PLANS AN9 F0EFAr4EC?.ESE SAN ONCFRE NUCLEAR GENERATIN3 STATICN EXE:CIEE EXERCISE EVALUATCR ASS!GNMENTS

)

i Nicholas B. Nikas, Chief Natural & Technological Hazards [>ivision Facility / Function Evaluator (s)

Emergency Operations Centers:

Camp Pendleton Ken Miles, RAC (FDA)

Orange County Joseph H.Keller, INEL

-- Joseph D. Donirguez, FEMA San Clemente William Vinikour, Argonne San Diego County

--- John Rooinson, FEMA

-- Su: anne Mooney, FEMA Sen Juan Capistrano Lester Conley, Argonne State Parks

--- J i m E e g a ns k y, FEMA Emergency News Center

-- Verne Paulo, FEMA Communications / Emergency Eroadcast System Terry Knight, FEMA

-Darrell Eakle, FEMA Reception and Care

-- Ji m Eegans ky, FEMA

~ ~ ~ ~,_

Transportation /Evacuatton Ed Henry, DOT (FEMA)

Emergency Operations Facility Dean Kunihiro, RAC (NRC)

Susan Elkins, FEMA Offsite Dose Assessment Center Dave Duncan, RAC (EPA)

Dale Stevenson, RAC (FDA)

Radiological Monitoring Tea?s

---Manley Wu, FEMA Phil Hill, RAC (DCE)

Brad Salmonson, INEL Sob Lyon, EPA, Las Vegas Bob Nicol, FCA Attacnsent A

s.

m i

SAN ONOFRE-NUCLEAR GENERATING STATION 1987 ANNUAL EliERGENCY PLAN EXERCISE OBJECTIVES A.

ONSITE OBJECTIVES 1.

Demonstrate.the ability of on-shif t and recalled personnel to recognize accident conditions, and to declare the appropriate emergency classification within 15 minutes of recognition.

2.

Demonstrate the ability to recall required SCE Emergency Response Personnel in accordance with Emergency Plan Implementing Procedures (EPIPs) and the -

Corporate Emergency Support Organization (ES0)

Procedures.

3.

Demonstrate notification procedures and communication capabilities to provide accurate event and follow-up notifications to offsite agencies within.specified time limits.

4.

Demonstrate the ability of on-shif t and recalled Emergency Response Personnel to conduct adequate turnovers and transfer of responsibilities in accordance with EPIPs and ESO Procedures.

5.

Demonstrate the ability to staff and operate required onsite (TSC, OSC, EOF) and offsite (ENC., HSC emergency response facilities with the required personn)el within the time limits specified by EPIPs and ESO Procedures.

6.

Demonstrate the ability to transmit information between Emergency Response Facilities as it relates to the process of recommending protective actions for the general public tr accordance with EPIPs and ESO Procedures.

7.

Demonstrate the ability to transmit information between Emergency Response Facilities as it relates to the process of emergency classification in accordance with EPIPs and ESO Procedures.

8.

Demonstrate the ability to provide accurate reports of medical team status to Emergency Response Facilities as soon as practical following secondary survey of patient (s), consistent with attending to patient (s) and other required duties.

-24 ATTACHMENT B.

p 4 L A. ONSITE OBJECTIVES (continued) 9.

Demonstrate the adequacy of SCE radiation monitoring team depl'oyment to provide continuous radiological assessment by accurate communication of field data into protective action decision-making. monitorin 10.

Demonstrate the ability to sample and analyze in-plant liquids, in accordance with station post-accident sampling-procedures.

11.

Demonstrate the ability to determine and implement appropriate measures for controlled recovery and reentry in accordance with the SONGS Emergency Plan.

B.

OFFSITE OBJECTIVES 1.

Demonstrate the adequacy of notification procedures and communication capabilities to notify and mobilize emergency response personnel in accordance with the offsite jurisdictions' eme'rgency response plans.

2.

Demonstrate the capability to fully activate and staff the Emergency Operations Centers (EOCs) to meet exercise objectives.

3.

Demonstrate the ability to assess recommendations and disseminate.information to the appropriate organizations, i ncluding recommendations concerning public protective action'.

4.

Demonstrate the ability to deploy field radiation monitoring teams, take. measurements, and communicate with the Offsite Dose Asse)sment Center (0DAC).

5.

Demonstrate th'e ability to develop and issue Emergency t

Broadcast System (EBS)~ messages and coordinate release of EBS messages with the activation of the Alert and Notification System.

6.

Demonstrate the ability t'o coordinate the dispatch of emergency workers including exposure control, 7,

Demonstrate the abil'ity to activate Reception and Care Centers in a timely manner, as needed, i

8.

Demonstrate the decision-making process with respect to supplying emergency workers with potassium iodide (K!).

h

3,. -....

C.'

JOINT OBJECTIVES 1.

Demonstrate the adequacy of the decision making process

-between the ),'0F and offsite EOCs in coordinating _

protective actions towards the general public.-

2.

Demonstrate th'e ability to perform offsite dose assessment projections necessary to provide advance warning to local, state, and federal agencies. and to the general public.

3.

Demonstrate the ability to activate and operate the Emergency News Center (ENC) and coordinate-the.

dissemination of timely and accurate information to the news media.by means of press releases and news briefings.

4 a

e l

,. = -

Salt O!iOFRE liUCLEAR GE!iERATI!iG STATIO!!

1987 AliNUAL EMERGE!!CY PLAll EXERCISE i

SUMMARY

IJIITI AL, Co?IDITIO?fS The exercise begins with Unit 1 oporating at 93% power.

'immediately following a refueling outage.

Plant conditions are nornal, except for a 72-hour LCOAR on tho south charging pump, which is out of service for replacement of the inboard pump seal.

The purp has been out for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and is expected back in service within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Spent fuel is being shuffled to prepare for fuel inspection.

Fuci from the last cycle (removed from the coro about five weeks onr lier) is being moved to the inspection area by maintenanco personnel, with an operator and HP technician in attendance.

Personnel are pre-staged on the turbino deck for tho spent fuel shuffling, and at the south charging punp.

They are'given cue cards describing the simulated conditions, just prior to the start of the exercise.

Control Room personnel are briefed and allowed to use the Control Room data display computer, prior to the start of the exercise.to become familiar with its use, just The ambulance and duty fire truck are also pre-staged inside the Protected Area.

This shortens the response tino of Emergency Service of ficers (ESos) to about The response time for an actual emergency, when Security processing would be suspended for ESos.

A Security officer is stationed with the ambulance, so the vehicle can be released as soon as the ESos arrive.

Unit 2 is operating at 921. power, continuing a power coastdown until the end of the current cycle.

Unit 3 is operating at full power.

SPENT FUEL HANDLI?tG ACCIDE*IT AffD CO!JTAMI!!ATED I!! JUDY At 08:01, a spent fuel assembly is damaged when the spent fuel bridge crane is moved laterally before the assembly has been lifted clear of the storage rack.

Damage is apparent to the pins along one side of the asseably.

Caseous radioisotopes released from the damaged assembly, primarily Kr-85 and Xc-133, rise through the spent fuel pool and are exhausted to the atmosphero via the plant vent stack.

In l

addition to the gas release, particulate contamination is released into the spent fuel pool.

The indication on vent stack monitor R-1254 and the local ARMS channel, R-1236, increase to their alarm setpoints within a few minutes of the accident.

,p.

ATTACHMNT C.

l l

l

SUMMARY

{ continued) i When the accident occurs, personnel in the Spent Fuel Building note the gases escaping from the damaged assembly, and the HP technician observes increased radiation with a hand-held detector.

To limit personnel exposure, the HP technician should direct personnel to evacuate the building.

The operator observing the fuel shuffle should inform the control room of the accident via radio.

When personnel start to evacuate the Spent Fuel Building, the crane operator falls and strikes his head on the crane structure.

He is dazed and bleeding from a head wound.

Personnel leaving the building should assist the injured worker in evacuating, and call for emergency medical assistance.

When ESos are ready to transport the injured worker, the head wound is found to be contaminated.

The worker should be transported, and the Mesa Medical Facility should be notified to handle the contaminated injury.

The injured worker is decontaminated and treated at the Mesa Medical Facility.

The total amount of activity released from the damaged fuel assembly is about 3.3E3 Curies of Xe-133, and 4.0E2 Curies of Kr-85.

The resulting offsite dose is quite small, but the accident meets the criteria of Alert event code A2-5 (spent fuel handling accident with subsequent radiation monitor alarm),

and requires declaration of an Alert.

When the control room becomes aware of the accident, the Shift Superintendent should declare the emergency and initiate emergency notifications.

Declaration of an Alert requires recall of station and corporate emergency response personnel.

Onsite sirens are activated to alert personnel in high-noise areas.

I Because the Alert involves a release of radioactivity, evacuation of the state beach must be recommended during notification of local authorities.

Upon activation of station emergency response facilities, an l

inspection team should be sent to the Spent Fuel Building, to identify containment and cleanup requirements.

If a team is not sent by 08:45, a contingency cue card directs that a team be dispatched to inspect the damaged spent fuel assembly.

When a team is able to find that damage is limited to about 20 pins, inspect the damaged fuel assembly and the release of fission gases is decreasing.

RCS LEAK At 09:15, an RCS Icak occurs, at about 75 gpm.

The leak is 28-

f

,e

SUMMARY

(continued) evidenced by increased charging flow, nomentarily decreased pressurizer level, increasing sphere radiation and sump level, and increased makeup to the VCT.

To avoid automatic transfer of charging pump suction from the VCT to the RWST, it is necessary to increase the primary water makeup rate to the VCT from 60 gym to about 100 gpm.

When the leak rate is determined, it should be identified as an Alert, por event code B2-1.

Emergency notifications to offsite agencies should-indicate the changed plant conditions.

Reactor shutdown is initiated at 09:20, at about 2-1/2% per minute.

Letdown is isolated to help maintain pressuricor icvel while shutting down.

Other plant parameters indicate as expected, given the RCS leak and rapid plant shutdown.

TEEDWX'TER PUMP FAILURE At 09:45, when reactor power is about 30%, the cast main feodwater pum control room,p lube oil low pressure alarm is received in the and lube oil and bearing temperatures are seen to be incroasing rapidly.

The pump is manually tripped.

Subsequent inspection of the pump will reveal that an oil line has ruptured.

Pump bearings are damaged and the pump is inoperable.

Plant shutdown is continued at the same rate, and steam generator levels are maintained by the remaining foodwater pump.

LOSS OF COOLANT ACCIDENT AND FAILURE OF S AFETY INJECTION As the unit is taken off line at 10:00, the RCS leak increasec to about 700 gpm.

This causes rapid RCS pressure and level reduction, and automatic initiation of safety injection.

Containment pressure, temperature, humidity, sump level and radiation begin increasing.

The rupture is located on the charging line connection to the loop A cold 1,eg.

The west feedwater pump safety injection discharge valve KV-8513 fails to open due to an actuator malfunction.

Because the east feedwater pump is out of service, there is a loss of safety injection.

In addition, the north charging purp fails to restart after the Safety Injection Signal, due to a breaker malfunction.

This results in a total loss of makeup to the RCS.

The LOCA meets the criteria for Site Area Emergency, by event code B3-1.

Upon declaration non-emergency response person,nelthe protected area is evacuated of (simulated).

Personnel in the N-Trailers, outside of the Protected Area, assemble in accordance with announcements, to demonstrate assembly of station personnel.

When notified of reclassification to site Area Emergency, Camp Pendleton San Onofre housing is also evacuated (simulated).

.gg.

e l

SUMMARY

(continued)

~

When the safety injection failure is noticed, personnel should be dispatched to the west feedwater pump to open the valve.

When the charging pump f ailure is observed, a team should also be dispatched to repair the breaker.

Cue cards are provided to teams upon arrival at the valve and breaker locations describing the conditions.

Because of the less of coolant and make up capability, voiding occurs in the core, and about it of the fuel is damaged.

As fuel damage occurs, fission products are discharged into containment with the spilled coolant.

Containment pressure and radiation continue to increase, and. pressure reaches about 5 psig by 10:30.

At 10:35, the repair team succeeds in opening HV-851B, allowing restoration of safety injection flow.

Because RCS pressure has decreased to about 760 psig, the feedwater pump delivers about 10,000 gpm safety injection flow, filling the pressurizer in about 2 minutes.

The RCS is then repressurized to about 1200 psig, and SI flow is reduced to equal break flow.

At 11:00, the south charging pump repairs are completed and the pump is started.

This allows initiation of cold leg injection.

However, the leak is greater than the capacity of one charging pump, and safety injection cannot be terminated.

At 11:15, the north charging pump is restarted. Because RCS inventory can be maintained by cold leg injection with both charging pumps running, safety injection is stopped.

RCS temperature is then reduced at 75'P/ hour, by initiating steam flow, to establish 50*F subcooling required for continued RCS depressurization.

Reactor coolant pump restart is avoided, because of inadequate pressure differential between the RCS and the main steam system.

At 11:35, RHR is placed in service.

Because reactor decay heat exceeds RRR capacity, steam generator steaming is continued.

Pressuri:er level is controlled at 70%, and dooldown continuss at 75'F/ hour.

Level then increases as the pressurizer bubble is collapsed.

At 12:48, steam generator steaming is secured, and cooldown is continued with RHR at about 25'F/ hour.

The operating coolant pump is then secured, allowing RCS depressuri:ation and decreased leak rata.

TANK TRUCK ACCIDENT At 10:45, a gasoline tank truck overturns in the northbound lants of Interstate 5, about one mile south of Camino de Estrella, in San Clemente.

Because the truck is leaking gasoline, California Highway Patrol ( CH P) closes the freeway in both directions.

30.

(T

,e

-ee y*....

t h

SUMMARY

(continued) t Eor. personnel receive word of the highway obstruction from CHP

(

representatives via telephone (simulated by cue card).

Uleckago l

of the highway must be evaluated for impact on evacuation plans.

The truck is removed and traffic restored at about 12:15.

l LOSS OF CONTAINMENT I

At 11:00, when containment pressure reaches about 4 psig, the purge exhaust valve,.POV-10,' opens.

The downstream manual

-isolation valve, CVS-313, is.open, with local indication showing closed.

The open valves allow a release of containment activity i

to atmosphera via the plant vent stack.

Plant vent stack moniter i

alarms ~are ititiated, and containment pressure begins decreasing.

Attempts to close POV-10 from the control room are unsuccessful.

f The re, lease results in dose rates of about 484 mR/ hour at the' Exclusion Area Boundary, decreasing to about 47 mR/ hour at Basilons Road.

Th's loss of containment, in conjunction with a LOCA and fuel datage, meets the criteria for General Emergency, by event code B4-1.

Upon declaration, sheltering for downwind areas that j

s cannot he evacuated before plume arrival, and evacuation of the remainder of a 5-mile radius and 10-mile downwind sectors, should be recommended for the general public, in accordance with the i

Emergency Coordinator's procedure.

Subsequent protective action t

recommendations may be made based upon concerns of offsite

agencies, site evacuation of non-emergency response personnel should be conducted, in the direction away from the plume

pathway, t

When'the opening of POV-10 is recognized, a repair team should be sent to close either valve.

Inspection of POV-10 shows that it was opened by a signal from a pressure switch activated by high containment pressure, apparently installed by a saboteur.

In addition, the handwheel has been disabled, and the closing side of the piston operator has been damaged to prevent closure by air i

The stem of CVS-313 has been disabled, with the valve i

pressure.

open and the position indicator showing closed.

Indications of sabotage should be reported to the Emergency Response Facilities, and Security personnel should initiate an investigation.

Re-categori:ation of the emergency may be considered to event code F4-1, a General Emergency based on l

security problems.

f i

At 12:30, the repair team succeeds in closing one of the valves, L

t terminating the release.

Emergency response personnel should consider reclassifying the event, and revise protective action recommendations for the general public, t

3p t

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

f o

SUMMARY

(continued)

RECOVERY PLANNING At 12:45, the Emergency Coordinator and Station Energoney Director are given cuo cards to initiato recovery planning.

Planning should be conducted with team leaders in the TSC and EOF.

, PERSONNEL INJURY At 13:05, a member of the San Clemento Field Monitoring Team falls down a steep slope and breaks his ankle.

The worker was walking near Cristianitos Road.

EXERCISE TERMINATIO?!

At 14:00, the exercise may be terminated.

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EXERCISE EVALUATION REPORT OFFSITE RADIOLOGICAL EMERGENCY PLANS AND FREPAREONEEE SAN ONCFRE NUCLEAR GENERATING STATION EXERCISE

.--t----

TIME LINE SEGUENCE OF EVENTS GENERAL ALERT SITE AREA EMERGENCY EOF DECLARED 8:06 A.M.

9:01 A.M.

10:19 A.M.

".'EN', ~ ~

8:19 A.M.

9:23 A.M.

10:22 A.M.

C Camp Pendleton 8:18 A.M.

9:10 A.M.

10:20 A.M.

0.ange County,

8:23 A.M.

9:15 A.M.

10:26 A.M.

San Clemente 8:18 A.M.

9:12 A.M.

10:29 A.M.

San DJego County 8:23 A.M.

9:10 A.M.

10:29 A.M.

San Juan Capistrano 8:20 A.M.

9:17 A.M.

10:36 A.M.

State Parks 9:15 A.M.

(Evacuated at Site Area)

EBS Station Stancey 9:20 A.N.

Activated 10:55 A.M.

Message Released:

10:57 A.M.

(Offsite Protective Act:en Decision 10:42 A.M.)

~33-

c-EXLRCISE EVALUAI101 REPORT OffSITE RADIOLOGICAL EHERCEllCY PLNIS Niu PREPARE 0tlESS EXER

. x SA!! 0!10fRE 1 UCLEAR GET ERATIllG STATI0ft EXERCISE FIllDIllGS HATRIX

~

EVALUATOR FIIDil:G

~

fiUREG'REF.

The sequence of events during the exercise pre-PROPOSED CORRECTIVE ACTIO!!/DATE FO 1.

G.3.a. and sented an unusual situation that requries futther The P'ublic Information Officer and the G.4.a. & b examination and attention.

A plant status news re-lease and nedia briefing included a statement by the Assessment Center subconinittees will be requested utility spctesperson that they had declared a genera to evaluate and review the plans and procedures and l

caergency and protective action reconinendations had submit their reconinendations and findings to the A unanimous de-Interjurisdictional Planning Consnittee.

been provided to local governments.

cision was reached by the of fsite jurisdictions not plans are scheduled to be ready for formal submittal Updated to inrpien.cnt protective actions, based on technical in mid-1986.

The Interjurisdictional Planning Com-advice from the Offsite Dose Assessment Center.

mittee will nect with the federal Emergency Manage-The alert and notification system was not activated.

nent Agency staff regarding this item.

Each of the local governuents participating in the exercise did recognize the need for providing pronpt It should be noted that the annual siren test wa public infonnation and instruction to clarify the successfully completed Septernber 11, 1985.

situation.

Various forms of public infonnation vere initiated from the emergency operations centers of individual offsite jurisdictions. Preparatory ac-5, tivities were undertaken to develop a coordinated e

offsite emergency public information news release, announcing that protective actions were not deemed h

a s ua rra n t ed a t tha t t ime. Ilouever, during the pre-paratory activities, the e,.2 tse de-escalated and then tennina ted. Unile no deficiency related to regulatory requirenent or plans and procedures im-piementation was observed, any likelihood of actions O

that would result in public confusion requires Q

correction.

?>

The plans and procedures for emergency response ope-rations a t the Emergency flews Center need to be re-vicued and amended, as required, to address the need for a more "joint" approach to public infonnation re-i quirements in the event of an apparent conflict be-O tueen utility announcements on plant status and off-9 site jurisdiction public instruction relating to

[

--appropriate protective action requirernents.

~

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JtMISDICTIO!1 NJD/0R TACILITY: ItJTERJURISDICTIO!JAL PLAritilf1G C0tUITTEE 1

s EXLICISE EVALUATIO:3ItEPORT OffSITE RADIOLOGICAL EMERGEt:CY PLA!!S N!D PREPARE 0

.t w

Stdl O!!0TRE flUCLEAR GEllERAT!f!G STATI0rl EXERCISE FIf1DIf1GS 14 ATRIX i

EVALUATOR Fil:D!!!G

!!UREG 'REF.

~

Pre-exercise activities included the revicu of PROPOSED CORRECTIVE ACTI0fi/DATE FOR CO 2.

of fsite plans and procedures represented as being P.4.

The bffsite jurisdictions' radiological energency current (most, if not all, were dated 1983).

P.10.

response plans will be updated bp April 1986.

the evaluator orientation and during the exerciseDuring it was noted that several plans and procedures were updated documents to the p' lans presented as current.

The federal Emergency flanagement Agency, Region IX, has no record of receiving any 1984 plan update sub-missions for any of the jurisdictions in and around the San Onofre I:uclear Generating Station (except OCTOBER 9, 1987 f rom the utility).-

flUREG-0GS4 requires annual revicu and update, if required, of all plans and procedures, THE CURRENT LEVEL OF EFFORT Ifl TH Telephone rosters are to be updated en at least a ouarterly basis in accord eith IIUREG-0654.

BY THE OFFSITE JURISDICT10t4S AT TH Some re-source support telephone nur:bers were noted by ENSURE TilAT THE RECOMMEtiDATIONS evaluators as being out-of-date.

VISI0rt, AS APPLICABLE; 2) INTEHJURISDICTIONAL P Plan maintenance 3

activities should include a procedure for systematic

'CEDURES REFLECT THE ENTIRE SPEC 8

telephone updates (e.g. standard operating procedures AMONG THE VARIOUS JURISD!CTIONS; AND 3) A that identify the need for employees and agencies to AttilUAL UPDATE (OR A LETTER ATTES!!!

furnish that information upon change, etc.).

AND TRACKING OF CHANCES, kfl If re-vieu of such docuxnts result in a determination that no update is necessary, that infornation should be TO THE f1 EXT REOULARLY SCitCDULED reported to the Feder.1 Emergency It3nagement Agency, liegion IX, through the California Office of Emergency SEE TifE EXERCISE FINDl!JGS FOR EACl!

Services, as appropriate.

DETERitit:

Tile CURREtiT PLAN.E Tile LEVEL OF ACCO l

JURISDICTIOil AilD/0R FACILITY:

IrlTERJURISDICTIQUAL PIMullrJG C0:

IIITTEE 1

~~

EXERCISE EVALUATI0Il REPORT OFFSITE RADIOLOGICAL EHERGENCY PLAUS AND PREPAREDfiESS EXERCISE r

~"

SAfi OriOFRE t;UCLEAR GEt1ERATIllG STATI0tl EXERCISE FIllDIt!GS HATRIX

~

EVALUATOR CINDIrlG T1UREG REF.

PROPOSED CORRECTIVE ACTIOil/DATE FOR COMPLETI0 3.

The primary station for the Emergency Broadcast E. S.

The Interjurisdictional Planning Comittee, the System, LEZY. was recently sold and is ngw under new management. tJew management has not received orienta-Federal Emergency Mariagenent Agency, Region IX, tion or training in ef fecting public information in and the Orange County uill work in concert to the event of a radiological emergency at the San orient and train KEZY station managenent and staff.

Onof re Nuclear Generating Station. Prior exercises Anticipated date for completion is September 1986.

have not included scenario direction for actual trans mission of messages to the emergency broadcast system-station to demonstrate their ability to disseminate public infortra tion. This exercise did not escalate to irnplementation of protective actions that required full activation of the alert and notification system.

The Interjurisdictional Planning Comittee should establish orientation and training for the Emergency P.roadcast System Station KEZY management and staf f n

and include the testing of that system during tha

\\/

i next regularly scheduled exercise.

(t10TE: The T

Federal Emergency !!anagement Agency, Region IX, staff uill be working closely with the local jurisdictions L in this regard and directly with the Station KEZY relative to orientation and training on the overall g

aspects of primary Energency Broadcast Station re-sponsibilities.)

C9 JURISDICTION AND/0R FACILITY:

INTERJURISDICTI0ilAL PLANUING COMillTTEE

/

49

.+

' EXERCISE EVALUATICN REPCRT i

CFFS!TE RADICLOGICAL EMERGENCY PLANS AND FCEDAPECNEES SAN ONCFFE NUCLEAR GENERATING STAT!CN EXERCISE STATUS CF 35 FEMA OBJECTIVES /PR-1 The offsite jurisdictions in and around the San Onofre Nuclear Gerarating Station have successfully demonstrated each of the 35 FEMA objectises that are applicable.

Attachment G shows the number of exercises and other major program activities the offsite jurisdictions at tnis site have been involvec with.

Objectives 1,2,3,4,5,6,7,8,9,10,13,14,15,17,18,19,20,21.22,24,25,26,27,29, 30,31 have generally been a part of each full-scale exercise.

Clarification of certain sub-elements of these objectives and objectives not listed, is provided as followst Objective 2.

Each of the offsite jurisdictions at this site has demonstrated the ability to fully staff all facilities.

Not all have demonstrated a capatility for maintaining staff around the clock during exercise play.

However, since each of the jurisdictions have been required to mainteln 24-hour staffing in response to an actual natural disaster, the RAC feel that the objective has teen successfully demonstrated, o

Objectives 11 and 12.

Ingestion Pathway objectives will be demons. rated by the State of California during 1987 at another nuclear power plant site within the State.

Objective 16.

Region IX RAC does not feel that the offsite jurisdictions within the State of California should have to demonstrate emergency response operations during inclement weather inasmuch as it would have little affect on evacuation at these locations.

The offsite jurisdictions at this site have demonstrated the organi:ational ability and resources required to manage an orderly evacuation with a significant lepedicente during one biennial full-scale exercise an actual hazardous materials spill occurred within Orange County and during tne limited exercise in 1986 the scenario provided a hazardous materials spill that cbstructed the major i

evacuation route

(!-5).

On both occastone, the offsite jurisdictions demonstrated a sattsfactory ability to implement alternate routes for l

continuous evacuation of the public.

Objective 23.

This objective has not teen demonstrated as a separate item.

l However, evacuation at this location would not present a difficult problem l

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STATUS OF 35 OBJECTIVES /PR-1 in that the evacuation of onsite personnel is via Highway 1-5 eoving in a southerly direction whereas the majority of thn population (within the Cities of San Cl

• ente and San Juan Capistrano) would be soving nortnerly.

The San Onofre Nut' Mr Generating Station is adjacent to 1-5 with easy access.

Evacuation of residents at Camp Pendleton Marine Corps Base oculd be using another roadway in a southerly direction.

Therefore, while it has not been addressed as a separate item, it has been considered curing the evacuation procedures performed to demonstrate that cacaellity.

Objective 29.

The offsite jurisdictions have demonstrated the capability for decontamination of emergency workers.

Establishing a physical demonstration of decontamination procedures for equiprent and vehicles is considered too costly for exercise purposes.

This activity has been simulated to the satisfaction of the RAC.

Objective 32.

Within the State of California, local offsite jurisdictions would identify the need for,

request, and obtain sta*te support for emergency response operations.

It would be a State resoonsibility to determine the need for federal assistance.

This will be demenstrated by the State during an exercise at another nuclear power plant site during 1997.

Objective 33.

The County of Orange has demonstrated a capability to relocate to and operate the alternate Emergency Operations Center.

The RAC has determined that there is no purpose to be served by having such a demonstration at the other locations of Emergency Operations Centers.

The San Diego County Emergency Operations Center is located 60-70 mt4es from the plant site. Camp Pendleton would evacuate at an early protective action level and are located out of the 10-Mile Emergency Planning Zone.

Both the City of San Clemente and San Juan Capistrano would relocate their Emergency Operations Centers t'o the Orange County facility which is also well out of the IP-mile Eme ;ency Planning Zone, the Emergency Operations Facility is located close to the plant site, but has a NRC approved "hardened" facility even though they have identified an alternate site for the Emergency Operations Facility.

State Parks evacuates at the Alert level and does relocate to an alternate site (which they do during each exercise).

The RAC feel that this objective has been met.

Objective 34 and 35.

Both of these objectives have been discussed during biennial exercises.

However, no specific quadance has been provided for estabitshing demonstration requirements.

The RAC feel that total population esposure has been estimated by the offsite jurisdictions satisfactorily.

Further, that the State will more appropriately address j

recovery and reentry during the Ingestion Pathway Zone emercise scheouled i

for October 1987.

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Sic ' i n L' U f, '

9 STATUS OF 35 OBJECTIVES /PR-1 The-findings resulting from each full-scale and/or li..ites exercise have ~

I generally been corrected prior to the next regularly scheduled exercise.

The State-of California has made it a matter of record that. they will not provide FEMA. with'an Annual Letter of Certification as required by Guidance Memorandum PR-1.

Based on the above information and the findings contained

.in this exercise report,

.the RAC has determined that the.offsite jurisdictions at this site have complied with GM PR-1, except for item 6 of l

.Section C.(which pertains-to the area requiring corrective action in this exercise evaluation report).

P l

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[EXERCISEEVALUATIONREPCRT-

~

OFFSITE RADIOLOGICAL.EMEPGENCY. PLANS AND PREPAREDNESS SAN ONOFRE NUCLEAR GENERATING STATION EXERCISE PAST PREPAREDNESS MILESTONES

. ~,

PLANNING Draft Plans submit'ted 1980 Annual updates 1981-85 Submitted for 350 processing 1985 Updates 1986 EXERCISES Full-Scale offsite participation.

- 05/31/81 04/15/82 03/23/83 Off year exemption - no offsite evaluation

- 02/29/84

_ Full-Scale offsite participation

- 08/07/85 Off year - Limited offsite exercise / ENC

- 09/10/86 PUBLIC MEETING Official public meeting conducted

- 05/18/81 ALERT AND NOTIFICATION Official demonstration and survey evaluated

- 09/28/63 FEMA official approval

- 01/31/84 PUBLIC.INFORMATION Initial brochure dissemination

- 1982 Updated and distributed

- 1983-86 Technical assistance meeting

- 1985 MEDICAL Training and drills annually

- 1981-85 Training and drills biannually

- 1985-87 Medical dri?,1 evaluaton (MS-1)

- 1987 TRAINING Essential training in accc-d with NUREG-0654 Standard O. conducted annually and reported.

3,

o a

December 1, 1987 ERRATA TO REPORT - EXERCISE EVAltJAi!ON OF THE OFFSITE ENERGENCY PLANS AND PREPAREDNESS AT THE SAN ONOFRE NUCLEAR GENERATING STATION ON AUGUST 12, 1987 -- EXERCISE REPCRT DATE: OCTOBLR 9, 1987.

Page 8, Paragraph One:

"(Note:

Another exercire evaluator assigned to obr,erve field operations reported that inquiry of private schools within the emergency planning zone resulted in a lack of knowledge with regard to evacuation procedures and that they nad not received cootas of the public inforeation brcenure.

This will be clarified in the final report.)"

The text should be changed to read:

"An evaluator assigned to observe the field operations visited the Rainbow Montessori and La Cristiaita schools.

The administrative staff of these schools stated that they had not received copies of the public informa t t or, brochures and were not familiar with offsite jurisdiction plans for evacuating these facilities.

In order to clarify this information, we inspected the utility distribution list for the public inf ormation brochure.

Every user of utility power within the 10-mile emergency planning zone receives a copy of the public information brochure.

The schools are on that list.

During the siren system annual test (September 16, 1987),

approximately 1,000 teacher work packets and 23,000 student work sheets were prepared and distributed to schools throughout the 10-mile emergency planning zone to explain the meaning of the sirens and how it affected the schools and students.

The packatr, also contained questionnaires for evaluation of the siren system effectiveness.

Region IX satisfied that the schools are receiving public information that is available."

Page i7' Exercise Findings Matrix:

. p n,*.

A letter from the InterJurisdictional Planning Committee (IPC) dated October 19, 1907 and forwarded to Region IX hy the State (letter dated November 5,

1987),

addressed certain exercise findings of the report.

The letter requested the offsite jurtsdiction comments be made a part of the evaluation report.

That correspondence, as well as the Region IX response, is l

attached to this errata and made a part of the report.

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Q,0-mgk. Federal Emergency Management Age f7 1'

Region IX

_ Building 105 j

Presidio of San Francisco, California 94129 r

Mr. William M. Medagovirh.

') rec tar Governor's Office ci Emorgency. Dir nces State of Cal 1f ornia E8'JO Meadowview itcad Sacra.nento, Cali fornia WO3!- l w99 Desar Mr.'Meatcovich:

This responde, to your letter nt flavember S, 19H7 forwardtno tor nor

revE6w, thn r.ctnmen ts prepared by the. I ntor jur isd i r t i an.11 Planning Committee (JPC) on the Exercise Evaluation i3enor t n t t ho San linn t rri Nuclear Generatinq Station exercise conoucted on Auou, t

'P,

907.

We siecerely apareciate the time aed effort expended by the IPC in its car erit t review of the report and welcome the opportiant*.y to andress tha concerns exprecsed by th9 iPC in its (Jctober 19, 14tf7 lutter.

i First int w explain that the repnrting

or na t

<. proscrthen b quidance developed jointly by FEMA and the fifff:.

The narrattvn text of the report is intenueo re :ncluoe comment an ite.ms utnor than th9r,o identified as nepoinq corrective

.nc t i ons.

!!ur experteece is that a broader discussion et evaluator observatinns.ind impre%1ons helpt, officials at FEMA and NRC Headquarters to better assess exercise results and reach fatr ano irrparttal findings.

To help achieve accurate.

fair and irrpartial r eporting, Reginn IX is-careful to assign evaluators who are well cualified in the technical aspects of emergency response operations.

In addition, each individual's findings are reviewed and discussed by o ther qualifiert evaluators and members of the Reginnal Assistance Committee (RAC).

This helps ensure that our conclusions and recommendations are technically correc t, and any cross references to State or local plans are appropriate.

Evaluators are instructed before every exercise not to make assumptions, fhey are acked to rnview the applic..ble plans.

famtItarite themselves wtth the exercise scenario

.ind objectivos.

conronnate with exprrise t.o n t ra t t er e,.

.ind then observo part tr.ipant performance in line with overctce on ertives and what plans itulicatr sanoid no oonn.

mMo c.t"ps

.in n tt o orncedur es null i ned.'.t'ove wero f0)idwed in the three specifit areas addtessed in the IPf:

letter.

fho i s%es,

nesertleiess, wre re-examireil

.ind the intluainq athl: t ic na l co;nments are of fere 1.

- a.

s_-

E' [. '

William H. Medignvich page 2.

- 1.

Providing. arequa tr' tbstmetry to emerrinrc

-m yocr4 5:

very important,. as in a recuerf cf duinetr y reau t rup anti the capability of the emergenty worl'ers to reac ird analv m te data.

The-11rar:qe Cinni y ecsponse uJan states that-radioloqttal fiel:1 muniinr t ra teams.4111 be provioed wi t h is types of dosimeters, nott r easj inq ki-200 cd and OM ti

'ma as well as ILDs.

CurrnW ly. *be ovorali suqqeutert dost etc range is 0-200 H.

Ti' '

uvaluator cbserved t m. :.

radioloq1 cal field monttorinq team mester s weru tac i ni; O POJ

• l pocket oosimeters and low ranqo r adiatian tietec tion ecuipwnt that do not satisiv tho intent of NUHiiG -Oh34 ihe 0-3 9 dosimeters aro not considered appropriate for the needs of a radioloq1rai ftold r"On t t'ir i nq t eam. We helleve the Cour ty *t s ta t erren t

• ha t thre te am e.r>cbers hao 0-20W,1 mH range rf ns i ew ' v available in.baseu en a failure to distinquish betw m n equiptrent used for menttorin<l c lutne vs.

emergrancy workor

,,pwposure.

The evaluator, in kettpton with hin assignment, reported h ts obserwt ion, and made a rotonmendation regar d;rq pr o ttsc t i on for errergent:y workerri assigned to field monitoring acttvttien, 2.

We aqret> with ttm statement in the IPC letter that the Dirrction ar.d Control area of the San Dieoo County ECC was not utiliteil au desr:r thed in the plan.

The evaluators also rrported that many of thnne not tral ly assigned to the Directson and Control group were rot available for this exerrise.

Hcwever, the report did not ntate or intend to imply that the Director of Emerqency Services disrupted the general cperatiens of emergency response <, tart.

The report stated that the Direction and Control area was no t fully staffed and this had an impact on other ECC -activities.

The point is that exercise participants deviated frcm the plan in thetr response operatians and ihe evaluaLor made an appropriate no tation. We recommer:d that i f the County plans to use the EDC facility this way in actual emeroency response operations, it r.hould be so staterf in the plan.

3.

.The following observations regarding evacuation procedures are made in the hope that their consideration will servefto enhance tho timely and efficient movement nf people from areas at risk.

Ftrqt, it is genarally agreed that certain aspects of an evacuation of the SONGS I:P7 are rnmplex and require trectal attention, the dC Int ter s tates. s t.r rf x amn l e,

that studios show that too entire l i' '. an be Pvacuated in app rri x i ta t rr 1 y tour 4 "e l ano-ha1t hours to t,vn hours, but the plann <, t a t o thit certain conr1stinns coull itnuede movnment anc! r ortoi r o on to ion hours to evcicitate the EP2.

Iha 1-xerciso Ev.t lua t a rrt 'icpor t intended merolv to direct attentino to thn appatont norri tur f ur thet-study ant ref enement n f er t St inq rroc nMr ris.

Vr1rd;ntliy,

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Suqts's t

n a

e William M. Medigovich Page 3 you consider the proredores out!tred in A'pt:nni-4 rif NfSWG-0654 in finalizing your plans. We t h i s:k you wiii f irm the,r useful, especially in planninq for i pn.inen movn unt of the populations that naqht he its :eo;:ar d).

The report's findinos on pubitc inforcation warn intenced t, -at e a specific point and to also suqqent.i ret t onent th it mient helu thr dissemination of inf ormat ion.

The trportant point to oo

• ace is that although the procedures described in the 'pr oposert r ur re..t t oe: oiaw of the Exercise l'indtrqs Matrix attached en the IP:

lette-can he expected to cause roordination arrong the jur tsdic tions, tt does emL guarantee the correctnrir s, consistency, or accuracy of the i nf or tN t ;on contained in the messages.

In the case at hand. coordination amory he jurtsdicttono took place and, in the case of Orantle County the eensage was reviewed by several officials, apparently approved for rninase anit still i nc l udr'd conflicting information that would have reitataly co ntit5ed the public and added to the level of

anxiety, fhe recommentfat ion that the decision maker sign the resuaa? form was m40e assuming that the signing / approving official would reaa the memaqe carefully, and hopefully catch inconsistencies or inaccurapies.

Obviou;ly, if -the message included technical i nf or ma t t ori thah the decision-maker was not ouali fied to evaluate, he/she wnuld he expected to seek expert advice fron qualified staff.

The tietnq of the broadcast of the IIBG message as described in the matrix ts still somewhat vague. We would itke to recommend that your written instructions regarding how the EDS will be used sp'eci f ir al l y state that the strens will be sounded first to alert the public that important information is to be broadcast over the EDS and then be followed, after a brief delay, by the station airing the desired This makes sense and is supported by NUREG-06564, Appendix 3, message.

Page 3-3 that states:

"A system which expects the recipient to turn on a radio receiver without being alerted by an acoustic alerting signal or some other manner is not acceptable."

In summary, it should be noted that "recommendations for improvement" are made with the full understanding that the State and local offsite jurisdictions may disagree.

These areas are considered to have little impact on public health and safety. The recommendations are meant to be helpful and are made on the basis of an observed activi ty that appeared not to.be in the best interests of the total emergency response operation, safety of emergency workers, or in Itne with the r.ost current acceptable practices.

In that regard we belteve that the exerciso evaluation reordt accurately reflects what w as observert dortnq the exercise and that the recommendations are scund.

Wr? hope the information provided will help clarity how we apply the regulations and other prescribed program procedures in the development of exercise evaluation reports.

We icok forward to working closely with the State and local offsite Jurisdictions to continue to irorove

r__

i,.

.Q.

g William;ii. Mediqovich

~Page 4 ouf ability to safeguard.the health anti natoty nf ' thnlpeait ic resid t' a r

near fixed nuclear power plants.

We havo_ crepared.in errata to the exercise evaluation' repor t to forward 'the ef t si te ju teritc t ion cosentq to our Headquarters and the NRC.

A copy of the errata i'. enc l os;ett.

StocerM v..,

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Robhrt L. vickers Regional Director Enclosure Erra,ta cc:

Camp Penoleton Martne Corps City of San Clemente City of San Juan Capistrano Orange County San Diego Ccunty Southern California Edison Ccmpany State Parks ano Hecreation - San Clemente

'U.S. Nuclear Heyulatory Commi".sion, Hegion V

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Regional Assistan.:e Committee, Region IX t

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AT INFO GOVERNOR'S OFFICE

-Q oaD DRD GEORGE DEUKMEJfAN OF EMERGENCY SERVICES GOVEMOR EA 2800 MEA 00WVEW ROAD

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E SACRAMENTO, CA 95832 PIO DAP

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November 5, 1987

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V IG ANRC DUE:

ixo:

Mr. Robert L.

Vickers Regional Director

- DATE:

pm, y m,,

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'""O' FEMA Region IX

~

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Building 105 Presidio of San Francisco San Fr,ancisco, CA 94129

Dear Mr. Vickers:

AUGUST "SONGS" EXERCISE EVALUATION REPORT Enclosed for review by your Region are comments prepared by the Interjurisdictional Planning Committee regarding the August "SONGS" Exercise Evaluation Report.

The committee's comments were forwarded to me, for forwarding to you, in keeping with established policy and procedure.

Sincerely, W

GOVICH irector Enclosure

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in:erjuriacic:iona aanning comminee County of Cronce. Ca.ny ct son C ego C4 S h CemerM e Ch cf W..cn Ceccomo Conferr.c S cte 6s e erec Sic es B.'orre Cercs. bee o CJom o Ecson October 19,1987

• 4 Mr. William M. Medigovich, Director Office of Emergency Services State of California 2800 Meadowview Road Sacramento, CA 95832-1499 Re:

August Exercise Evaluation Report s

Dear Mr. Medigovich:

The Inter]urisdictional Planning Committee (IPC) responsible for off-site emerg response planning for the San Onofre Nuclear Generating Station (SONGS) has reviewe the draft Exercise Evaluation Report for the August 12,1987 Exercise. As you know Committee is composed of the seven Involved jurisdictions within the 10-mile E Planning Zone including: the City of San Clemente, Camp Pendleton Marine Co California State Parks and Beaches, City of San Juan Capistrano, Orange County Diego County and the Southern California Edison Company. Additionally, the Arne Red Cross and the Ca!!fornia Highway Patrol are also active participants. We appre the opportunity provided us to comment on the evaluation report as the IPC fe sense of responsibility to assure adequate response capabilities for any SONGS re!ated emergency.

Exercise Summary and Detall At the onset, it should be noted that this coordinating body of local Jurisdic.!cas are th agencies responsible for the off-site emergency planning at San Onofre. In the State of California it is the local municipallties that are responsible for all local emergencie to the State Office of Emergency Services on SeptemberThe eva 11, 1987, did not receive copies until Septemberreview period with an October 16 1987.

confer and prepare a coordi'nated response, by the October 9th deadline.This lef t insu inclusion in the record,therefore is submited after the finalized FEMA report, howev items other than those Identifled as needing corrective actions.in re information was found to be very subjective reflecting the personal opinions of theTh Individual evaluators and not based on requirement parameters.

Much of the editorialization was not reflective of actual operations and seemed to be misunderstandings of off-site plans and procedures.

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C.

Mr. Medigovich, Director

. Office of Emergecy Services October 19,1987 Page 2 For the most part, the IPC and our individual agencies have chosen not to discuss the the many assumptions presented in this report because they have little bearing on the overall adequacy of capabilities tested in this exercise. There are several issues, however, which cannot be over looked as they are in conflict with established inter-agency operations and overall response philosophies.

1) The discussion on Page 13 o' n Radiological Field Monitoring Teams does not accurat reflect what transpired in the field during this exercise. All field monitoring teams had in their possession and were issued the required dosemitry and carried all the instrumentation which covers the 0-2000 mR range. This we believe is not just low range radiation detection instruments and does satisfy the intent of NUREG-0634 2)

The San Diego County EOC evaluation Page 14, does not reflect what actually occurred. The Direction and Control area of the EOC was not used during this exercise.

The primary reason for this is that few of the individuals who would normally sit in Direction and Control were present the exercise due to circumstances beyond at control. Dan Eberle, the Director of the Of!!ce of Disaster Preparedness, played the role of the major decisions makers. While he was located in the operations room, his station was physically separated from the operations group.

His presence was in no way disruptive to the operational functions. San Diego County was and is comfortable with that arrangement during this exerc"-

3) The comments on Page 15 t' q

hased" evacuation are not only erroneous but reflective of a lack of understa.

, m IPC plans. There is a phased evacuation set forth in our plans. The Californis state Parks and USMC at Camp Pendleton at the A!ert Level, conduct precautionary evacuation of beaches and recreational areas near the plant site.

At the Site Area Emergency level the Californla State Parks close additional recreation areas and the USMC conducts a precautionary evacuation of the EPZ. At the Site Area Emergency level there is an evacuated (only emergency workers remain) 2.3 mile area around the plant.

If an evacuation is ef fected of the remsining 7.7 mile area of the EPZ, our evacuation studies indicate the.t the EPZ can be evacuated in 1

approximately 4 /2to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> with our existing road network. These studies are based on a simultaneous evacuation of the entire EPZ not the reduced EPZ resulting from the phase evacuation.

Exercise Findings Matrix The IPC finds much of the commentary included within the Exercise Findings Matrix to be a misinterpretation of the operations demonstrated in the Exercise. Consequently, we have tried to give complete explanations of established procedures so that the actions evaluated are reviewed in their appropriate perspectives.

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Mr. Medigovich, Director i

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October 19,1987 Page 3 l

The IPC has spent much time, effort and money on developing coordinated emergency response procedures. For the most part there is complete agreement on att the elements of the basic plan and we have accepted those nuances that are special to each agencies implementations. This has proven to work well for us. Perhaps this should be the manner in which exercise evaluations are made.

That is, keeping in mind the site specific operations and procedures and the adequacy there in demonstrated and by not applyin 4

generic review or evaluation procedure and forcing compliance.

Over the years, the IPC has learned much from our FEMA evaluators.

We are not overlooking the contributions which have been made to process.

We are all aware that the strengthening of the development accomplish what has been established to date.

it has taken a concerted effort to San Onofre has presented some unique problems which have required unique solutions. Because of the enormous cooperation and coordination taken, these solutions have the support of the communities, the jurisdictional governments and have been supported by numerous and lengthy studies with the scrutiny of the surrounding public. It only seems equitable then that the evaluations of these efforts reflect the same kind of sensitivity to the situation and consider the workability of the plans on a case-by-case basis.

The IPC has in the past utilized the recommendations of our exercise evaluators and incorporated them into our plans and planning efforts.

However, as the years progress and new evaluators come forward, we are finding recommendations contradictory to previous years which initiate, the initial change to the plans.

Because our plans are dynamic this can be expected periodically.

As a group we have tried to maintain a level of flexibility to deal with new issues and the myriad of concerns each jurisdiction holds. It is this flexibility and cooperation that is necessary if this planning, exercise and evaluation process is to be positive and of significant benefit to the entire emergency response planning effort.

Very truly yours,

.fpW Cynthia S. Ferguson, Chairperson '

Interjurisdictional Planning Committee Attachments hf a

CSF:kis Federal Emergency Management Agency cc:

Mr. Robert L. Vickers, Regional Director 9

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63 tat. :st t.mtuassuN MtruMI-

.' y Off. SITE RA010 LOGICAL EMERGENCY PLANS AND PR 4.

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' SAN ONOFRE NUCLEAR GENERATING STATION EXER P.

N SS ISE s.

EXERCISE FINDINGS tiATRIX

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FINDING l.

Public Information.

fre Nuclear Generating Station have particip t d iThe of fsite jurisdictions in and around the S PROPOSED CORRECTIVE ' ACTION /D cod one limited exercise since 1981.

an Ono-n four full-scale exercil The current Orange County Plan for EB5 ae i

finding of weakness related Each exercise resulted in a significa message transmittal establishes-that es the Public Information System and/or Emergen reading of the EBS message ;is done.directly -

Dews Cgnter activities.

nt the..

C by the offsite jurisdictions's 'sequentwe action recommendations were implemented from the county over the' phone cy successfully correct the problem area identifiedto each exercise that appeared to to the' station.

It is recorded at the station on-I tion aspects of the alert and notification s Still, the public informa cassette and then the cassette is played over System) continue to encounter problem areas orgystem (i.e., Emergency Broadcast the air as instructed (i.e., # of times and ment and implementation, and training' for its anizationally, exact time to be. aired) San Diego Coimty's the evaluators assigned to observe activiti effective use.

in plan develo Plan is basically the same.

p.

For example, tion /public information reported the followies related to alert and notifica.

This procedure allcws for a coordinated message. to be approv.-

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by all jurisdictions prior to the activ ng:.

i While the previous finding concer.

of the siren system and prior to the activat i...

ation.

radio station KEZy has been corrected, more trainining Emergency Broadcast o f t he EBS.

System (E85)

Once the message is approved it communications personnel should be done The communications operatorng of the Orange County is then read and scheduled for release at the Orange County Emergency Operations Cent at time that the the sirens are sounded.

confused at times on how to funnel E85 messages to the radio stationer (EOC) appeared slightly consonance with standard guidance criteria and -

This is in j

However, the messages did reach the station and the ale t the ANI.

We do not believe it to be in activated on time.

conflict with FEMA recommendations either.

message back from the radio station prior to bro dThe EOC needs to confirm the contents of th r

system was

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very cooperative and enthusiastic about a ;;asting.- KEZY was

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EOC communications placed the E85 statior ?a standb the program. Orange County The Orange County plan calls for the EBS message to b y at 9:20 a.m.

from the radio station just prior to the sirens biing e transmitted i

This procedure is in reverse of standard guidance activated, The operator at Control One r

and criteria.

trained in siren activation procedures and demon t(Orange County Communications) was well cedures satisfactorily.,

s rated these pro-The Communications Operator assigned the task of t j

i EBS message to the radio station was not aware that ransmitting the i J on the message form ("request message release time") wathe time entered

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the time that the radio station was to broadcast s intended as

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instead, this individual held the first EOS aessagthe EDS message.

This action would have unnecessarily delayed the subsnated time before beginni i

ation.

of the E85 message to the public.

equent broadcast O

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r. A s.nt. s St. t.VnLun!IUN HLPUNI

.t OFFSITE RA080LoclCAl. EMERGENCY PLANS AND PREPAR SAN ONOFRE NUCLEAR GENERATING STATION EXERCISE "v

EXERCISE FINDINGS MATRIX y

FINDING The first Orange County E85 message for simulated relea PROPOSED CORRECTIVE ACTION /D mation which would have caused confusion in the publicradio station to the pu se by the EBS ent infor-I i

The coordinated decision meds by the offiste Jurisdiction d perception.

i mal 6ers was for announcementi'efrthe Site Area emergency with ecision-tective actions required.,'In fact the message released no pro-both an instruction to the public to take shelter and that contained tective actions were necessary.

nr. pro-t he Orance County desisio' ! maker Werat ?onal AThere was no sytt.cm #mnnstrated to-assure that While there was' information advising both n

nator) was aw.ye ut oi rea (pordi-

'the offsite jurisdictions (Orange County" atoproved., the contear r<f in'e mepane rcicasc6 sheltering and evacuation actions the. decision

, San Diego County, San Juan maker in Orange County uas present and approvei-Capistrano, San Clemente, State Parks and Camp Pendleton) all con-tLe context of tite nessage released.

I curred on none of these individuals caughtthe pen a^nd ink changes to the pre-scripted EM messa Documentation of this was made and provided ge and to the evaluator on the spot.

The confusion-the inconsistency.

was distributed to severz.1 desks within the Orange County EOCAlso, the message was not with the procedure or ability of these exercisu participants, some of whom were part of the d and none demonstrated but with the evaluator,s under-making process, caught the inconsistency.

ecision-standing of who was the OAC.

At San Diego County there was a coordinated effort displ dissemination of EBS messages.

ayed in the However, there was a problem area identified.

The first EBS message at issued by San Diego County was not the Site Area emergency level

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in concert with the Orange County EBS message.

The Site Area emergency EBS pre-scripted message agreed upon by the offsite jurisdictions was to have read:

i1 tial health hazard to the public if the release continues"There is a poten-i is n6 need for protective action at this time "

, but there the conflict As noted, this was "sheltering" above in the Orange County messagein the released message including a pr 1

of i

County message did not The' San.Diego 1

for protect ive act ions'atinclude the phrase "...but there is no need this time."

Therefore, the sheltering 1

aspect was consistent, Thus, Orange and San Diego were releasing conflicting informatibut not as coordinated w j

to the public.

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la addition, County was noted as being written atthe Site Area emergency message Two for San Diego 1

, message release time of 10:00 a.m.

10:00 a.m. with a requested j

Two was noted as being taken at Their General. emergency message 10:19 a.m. when the dec:aration of 3

General Emergency occurred at 10:29 a.m.

(The Site Area emergency

. j message Two for Orar.ge County was t ime marked at 9:54 a.m. and the -

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_m.o.. a. twntunasuu norun 0FFSITE RADIOLOGICAL EMERGENCY PLANS AND PREPAREDNESS p

SAN ONOFRE NUCLEAR GENERATING STATION EXERCISE

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EXERCISE FINDINGS MATRIX 4.

- y FINDING Cencral Emergency message Two.was time-marked at PR'OPOSED CORRECTIVE ACTION the message was being coordinated by Orange County with oth36 a.m.). While 10:

dictions, the San Diego County Administrative Officer was taki er juris-j the information down in longhand on a notepad rsther than ng cngries directly to the Et$jpre-scripted message form.

making pre-scripted message forms 'are a part of the plan.

These E85 are intended to enhance the~ dissemination of correct and consistent The procedures informat ion to the public from both counties forms should be readily available to whomever is responsible fThus, the EBS message participating in the coordination activitie3 related to public in-or formation EBS messages.

Both EBS messages contained the instruction directed to the pop lation who reside within "10-Miles" of the plant u-site.

The state-Local offsite jurisdictions for this site.is contrary to the planning concept adopted by the Sta ment and has no significant meaning to the public.

The statement "IO-Miles" use the same designations used in the public information broch rThe EBS messages shoe >?d Bas 2d in part on the foregoing the exercise evaluator assigned t u e.

County EOC reported to the Regional Assistance Ccanit tee o the Orange A subsequent EBS Exercise was conducted in his opinion the way Orange County officials handled th (RAC) Chairman that September 16, 1987, which corrected any of tituted a "deficiency."

e E85 message con,

the discrepancies identified in thlS fi"di"3-s The RAC unanimously decided thatThe RAC Cha.irman referred the mat ter to the RAC.

"Area Requiring Correct ive Action" and was applicable to Sethe finding should be categorized as an Ias well as Orange County.

Officer obtain agreement The RAC requested that n Diego County the exercise Project ccrrcctive action and to be prepared to demonstrate the ability to quicklfrom the of fsite ju and efficiently process EBS messages at the next annual full activati y

the siren system on September 16, 1987.

on of This was done and the demonstration cill take place on September 16, 1987.

final edition of this report.

The results will be included in the

'n tcccrd with the classification as an area requiring corrective action

,ffsite jurisdictions will be required to correct

, the he next regularly scheduled biennial exercise during 1989this problem area prior to ions will address the following areas of concern:

Corrective ac-Interjurisdictional pro'cedure #$ (Alert and Warning) requir a.

update and modification to specifically identify jurisdictioes The Ipc will review IP s5 and make modificatt""'

coordination arid responsibility (Interjurisdictional Procedure f6 nal as deemed appropriate prior to the next exerc h.c a.

tauntist tuntunatuN HLPUKl 0FFSITE'RADl0 LOGICAL EMERGENCY PLANS AND PREP

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i4 [ f SAN ONOFRE NUCLEAR GENERATING STATION EXERCISE

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7 EXERCISE FINDINGS MATRIX

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FINDING

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can serve as an excellent example for accomplishment of this PROPOSED CORRECTIVE ACTION requirement).

l (1)

The Emergency Broadcast System (EBS) radio station will be alertedjggior to siren activation and timed to follow the sirestssounding by at least two minutes to permit with data provided in the public information brochure;the public"to tune to (2) The E85 pre-scripted messages will be redesigned to permit more expedient coordination and processing (e g extensive editing requirements or deletion of paragraphs intended at another level of protective action will b omitted);

e (3) The new pre-scripted messages will for decision-maker authorization prior to release; andinclude a system (4) Protect ive actions decided upon (e.g., shelter and/

evacuation) will be stated in terms of boundaries identi-

's or fied in the public information brochure distributed to the public (all references to the 5-or 10-Mile emer s

planning zone should be deleted).

gency 8

b.

A hard-copy transmittal capability is required to coordi EBS messages and news releases at all emergency response f The IPC will evaluate whether there is an nate both involved with public information releases..

acilities internal requirement for hard copy Training workshops for all assigned to areas of responsibili capabilities and make recommendations c.

effective public uithin the next year.

fication will be accomplished after completion of the aboveinformation activities rela Training workshops will be planned and ty for l-listed implemented to incorporate any changes /

activities, but prior to the next full-scale biennial exercise, modifications made relative to aiert and S

ince this exercise closed the period for accomplishment of obj notification procedures.

tblished by FEMA, t

in accord with Guidance Memorandum.

ectives es-

' [' f N

UREG-0654/ FEMA-REP-l and 44 CFR 350 Periodic Reouirem ntPR-8, Policy on inding will remain an open item until the next e

s, this exercise x2rcise during 1989.

e regularly scheduled biennial

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NUREG

REFERENCE:

E.S and 7.

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tuni. sat tuntonssun ntrons 0FF. SITE RADIOLOGICAL EHERGENCY PLANS AND PREPAREONE SAN ONOFRE NUCLEAR GENCRATING STATION EXERCISE

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F EXEntCISE FINDINGS NATRIX

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FINDING

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l 12!an. Rzdiological Exposure Control.

y emergency personnel with dosimetry..The City of San Clemente failed to issuePROPOSED CORRECTIVE ACTION /DATE f

the City Emergency Operations Center (EOC) wasThe Director for Emergency Services et j.

The city of San Clemente will include in.

of EOC, staff nced to be issued selpersonal film badges were sufficient to fulfill thiof the opinion that their plans the provision of issuing s requirement. A number self-reading recording devices to all personnel are not receiving excess"greading recording devices to ensure that emergency personnel as noted in the l isto the plan for any EOC personnel who may temporarily leave thProvisions should also be put Radiological Exposure control Finding.

exposures.

' first be issued dosimeters (unless the dosimet e EOC to chicles being used).

ers are pre positioned in he building within which the EOC is located (e gAlso, a number of non emergency EOC personnel occ

.ci).

Thus, the plan should be. modified to include dosim t., pot ice and fire persony up

copie, e ry use by these l

UREG

REFERENCE:

K.3.a. and b.2.

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EXLRCISE EVALUATIOff REPORT 0FFSITE RADIOLOGICAL EHERCEllCY PLANS A

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SAH ON0fRE fluCLEAR GENERATING STATION XERCISE

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EXERCISE FIhDINGS NATRIX EVALUATOR fillDillG 2.

NUREG"REf offsite plans and procedures represented as beingPre-exercise acti

__i PROPOSED CORRECTIVE ACTION /

2 P.4.

current (most, The offsite jurisdictions' radiological em if not all,'were dated 1983).

P.10.

the evaluator orientatioMarwi during the e xercise, g response plans will be updated by April.1986 _

Durin it was anted that several plans and proced ergency

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updated documents to the p' lans presented as c j

ures uere I

The federal Emergency Management Agency

. Region IX, k

urrent.

missions for any of the jurisdictions in andhas no ' record of receiving any a e sub-frota the utility).the San Onofre fluclear Generating Station (

around and update, if requ; ired, of all plans and procedIIUREG-06S4 requires annual revicu OCTOBER 9, 198J except Telephone rosters are to be updated on at least ures.

ouarterly basis,in accord with !!UREG-0654.

BY THE OFFSITE JURIS a

tsource support telephone numbers ucre not d b Some re-LANNING evaluators as being out-of-date.

ENSURE THAT THE RECOMMENDATI e

y APPEARS TO Plan ciaintenance cctivities should include a procedure for systenatic VISION, AS APPLICABLE; 2) INTERJURISDICT EW AND RE-T' telephone updates (e.g. standard operating p CEDURES REFLECT THE ENTIRE S IONAL PRO-that furnish that inforootion upon change, etc ) identify the need for coployees an AMONG THE VARIOUS JURISDICTIONS; AND rocedurt.s RDINATION ANNUAL UPDATE (OR A LETTER ATT A SYSTEM FOR view of such documents HAS BEEN REVIEWE0 AND FOUND NOT If re.

T THE PLAN no update is necessary,resul~t in'a determieation that AND TRACKING OF CHANGES. WILL BE A UIRE AN UPDATE) that Region IX, through the California Office of Ereported to the federal Eme TO THE NEXT REGULARLY SCHEDULE ency.

EXERCISE.

Services, as appropriate.

DETERMINE THE LEVEL O mergency i

DICTION TO THE CURRENT PLAN, ND STATUS OF Updates for each jurisdiction's plans were made i

however, not in concert corrective action.

with the previously proposed,

ontinue to up-date our plansAll off-1.ite jurisdictions will c

alter each exercise and drill. Plans will, at minimum, be up-d.ited I.!O days following the annual exercise.

A letter attesting to that review will be prepared for each plan.

JURISDICflon AND/0R FAClllTY:

g, litter,1URIS0!CT10nAL PI A!!n!UG C0ftIITTEE

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