ML20198J956

Forwards Corrective Action Schedule for 840912 Exercise of Offsite Radiological Emergency Preparedness Plans for Facility.Offsite Radiological Emergency Preparedness Now Adequate

ML20198J956
Person / Time
Site:	Rancho Seco
Issue date:	05/19/1986
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8606030263
Download: ML20198J956 (47)

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Federal Emergency Management Agency i

Washington, D.C. 20472 O

O MAY I 91986

- MEMORANDlM FOR: Edward L. Jordan Director, Division of Einergency Preparedness and Engineering Response office of Inspe'ction and Enforcement U.S. Nuclear Regulatiory Commission FRN:

n Assistant Associate Director Office of Natural and Technological Hazards Programs SUBJECr:

Corrective Action Schedule for the September 12, 1984 Exercise of the Offsite Radiological Emergency Prepared-ness Plans for the Rancho Seco Nuclear Generating Station Attached is a copy of the corrective action schedule for the 1984 joint exercise of the offsite radiological emergency preparedness plans for the Rancho Seco Nuclear Generating Station. This was a full participation exercise for the State of California and Sacramento, Amador and San Joaquin Counties. The report, dated September 20, 1984, prepared by the Federal Emergency Management Agency (FEMA) Region IX, was furnished to you earlier.

There has been significant and continuing progress to improve the offsite radiological emergency response capability; therefore FEMA considers that offsite radiological emergency preparedness is now adequate to provide reasonable assurance that apprcpriate measures can be taken of fsite to protect the health and safety of the public livirn in the vicinity of the site in the event of a radiological emergency.

If you have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 646-2860.

Attachment As Stated 8606030263 860519 PDR ADOCK 05000312 F

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Region IX Building 105 Presidio of San Francisco, California 94129 MEMORANDUM FOR: ASSOCIATE DIRECTOR STATE AND LOCAL PROGRAMS AND SUPPORT r

FROM:

Regional Director

SUBJECT:

Corrective Action Schedule for the 1984 Exercise of the Offsite Radiological Emergency Preparedness Plans for the Rancho Seco Nuclear Generating Station Attached is the corrective action schedule for the Rancho Seco Nuclear Generating Station 1984 Plans and Preparedness Exercise of September 12, 1984. Comments submitted by the utility, state, and local offsite juris-dictions are also attached.

At a meeting on March 14, 1985, representatives of the utility (SMUD),

the counties (Amador, Sacramento, and San Joaquin), the state (CA-0ES),

and FEMA Region IX, discussed the exercise report and the corrective action schedule. As is stated in the text of the corrective action schedule and the comments of the counties, additional activities for improvement to the alert and notification system (particularly the Emer-gency Broadcast System (EBS)) procedures are required. Regional staff will continue to work closely with the state and county offsite juris-dictions toward achievement of that goal.

It should be noted that an alert and notification system demonstration is currently scheduled for September 1985.

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FEMA Region IX has determined there has been significant and continuing l

progress to improve the offsite emergency response capability and that there is reasonable assurance that appropriate protective measures can be taken to adequately protect public health and safety in the event of l

a radiological emergency at the Rancho Seco Nuclear Generating Station, i

Attachment e

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EXERCISE FINDINGS MATRIX-

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JURISDICTION Sacramento Municipal Utility;Disti CATECORY

,B PACE 1 FINDINC NUREC-0654 CORRECTIVE ACTION REFERENCE DATES 1.

While the emergency classification notification Proj /Actua i

was dispatched by the EOF in a timely manner, in-This finding should be addressed by San N/A sufficient information updates were received at the Joaquin County since it was an observation at their EOC.

county EOCs.

Exercise Evaluators observing activi-ties in San Joaquin County determined that-increased information briefings (via the dedicated line) from the E0F to the county E0Cs should be provided.

E.4 G.4.b.

NOTE: The utility, state and counties are cur-rently compiling a description submittal of their entire alert and notification system in accord with the requirements contained in the " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants, FEMA-43" to qualify the system against the criteria of NUREG-0654-FEMA-REP-1, Rev.1, and establish a schedule for an alert and notification system demonstration. This activity will provide an opportunity to closely examine cur-rent systems improvement requirements.

2.

Many requests to the Technical Support Center for key data required by the UDAC were not responded Technical Support Center staff will be in-7/85 formed, during training, of their responsi-to in a timely manner or, at times, not at all. This M

hampered or delayed the assessment process by the bility to respond to UDAC.

UDAC staff.

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3.

Although the status board on dose projections state " projection" there seems to be ongoing con-The status boards will be revised to reflect fusion at the EOF brief~ings concerning projected

" actual" versus " projected" data.

7/85 data vs. actual data, and/or projected data based on y;f

" actual" release data vs. projections based on bm

" measured" data obtained from monitors. This con-y;.

fusion can be minimized if the tenn " measured" is used when data is obtained from field monitoring and/or other monitoring systems (e.g., " measured "i

dose rates" to differentiate from projected dose

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EXERCISE FINDINGS MATRIX JURISDICTION Sacramento Municipal Utili)y Disti CATECORY 0 PAGE 2 FINDING NUREG-0654 CORRECTIVE ACTION REFERENCE DATES rates / doses based on technical specifications or actual release data). Typically, projected dose Proj/Actua rates / doses based on technical specifications are conservative and thus lead to conservatism in neo-tective action recommendations. Projections based on measured data provide more realistic conditions to enable more precision in the detennination of protective action reconnendations.

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SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830, Sacramento, Califomia 95813; (916) 452-3211 RJR 84-518 November 30, 1984 JACK KEARNS ASSISTANT DIRECTOR PLANS AND PREPAREDflESS.

STATE OF CALIFORNIA 0FFICE OF EMERGENCY SERVICES POST-OFFICE BOX 9577 SACRAMENTO CA 95823 1984 RANCHO SECO EXERCISE REPORT Attached please find the District's response to the 1984 Rancho Seco Emergency Preparedness Exercise Report dated September 20, 1984.

The response contains the corrective actions the District will take to resolve the findings in Section 5.0, Exercise findings Matrix.

If you have any questions, please contact Roy LeNeave of my staff at (916) 451-2023.

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EXERCISE FINDINGS NATRIX.

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JURISDICTION Sacramento Municipal Utilit

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PACE 1 FINDING NUREC-0654 CORRECTIVE ACTION DATES REFERENCE Proj/Actu

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While the emergency classification notification

1. This finding should be addressed by San N/A was dispatche,d by the EOF in a timely manner, in-Joaquin County since it was an observation sufficient information updates were received at the-at their EoC.

county E0Cs.

Exercise Evaluators observing activi-ties in San Joaquin County determined that increased information briefings (via the dedicated line) from the EOF to the county E0Cs should be provided.

E.4 G.4.b.

NOTE: The utility, state and counties are cur-rently compiling a description submittal of their-entire alert and notification system in accord with the rcquirements contained in the " Standard Guide for the Evaluation of Alert-and Notification Systems for Nuclear Power Plants, FEMA-43" to qualify the system against 'the criteria of NUREG-0654~-FEMA-REP-1,Rev.1,andestablishascheduleforanalOt and notification system demonstration. This activit) will provide an opportunity to closely examine cur-rent systems improvement requirements.

2.

Many requests to the Technical Support Center

2. Technical Suppor.t Center staff will be

,7/85 for key data required by the UDAC were not responded informed, during training, of their to in a timely manner or, at times, not at all. This hampered or delayed the assessment process by the responsibility to respond to UDAC.

UDAC staff.

I.2 3.

Although the status board on dose projections

3. The status boards will be revised'to 7/85 state " projection" there seems to be ongoing con-reflect " actual" versus " projected" data.

fusion at the EOF briefings concerning projected data vs. actual data,'and/or projected data based on

" actual" release data vs. projections based-on

" measured" data obtained from monitors. This con-

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fusion can be minimized if the term " measured" is used when data is obtained frca field monitoring and/or other monitoring systems (e.g., " measured dose rates" to dif ferentiate from projected dose

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JURISDICTION Sacramento Municipal Utilit CATEGORY h PACE' 2 I

l'IIDINC NUREG-0654 CORRECTIVE ACTION DATES REFERENCE Proi/Actm rates /dosas based on technical specifications or dClual release data). Typically, projected dose rates / doses based on technical specifications are conservative and thus lead to conservatism in pro-tective action recommendations.

Projections based on measured data provide more realistic conditions to enable more precision in the determination of

, protective action recommendati'ons.

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~o JURISDICTION Amador County CATECORY B

PAGE I FIMDING NUREC-0654 CORRECTIVE ACTION REFERENCE DATES 1.

The planned alert and notification system for Proi/Ac tu:.

the County failed to meet the criteria of NUREG-0654 during the exercise. While there was an established The County of Amador rejects this finding as incorrect.

See details in attachment.

procedure for alerting, notifying, and mobilizing emergency response personnel, the escalation of the classification level from Alert directly to General Emergency resulted in a breakdown of the planned system.

Key personnel who would have been mobilized at the Site Area classification level (who were put on standby at the Alert level) were not contacted at the time the General Emergency was declared. The plan, standard operating procedure, and or checklist should repeat the actions to be taken at the lower j

i classification level within the next higher classifi-cation level as further assurance that those activ-l ities have been accomplished or that they are still E.2 1

required.

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The county announced activation of the EBS, but i

1 it was not clearly demonstrated that the appropriate I

notification to the EBS was followed, or that the The FEMA evaluator failed to observe " simulated process. See details in attachment.

iossage was consistent with the protective action E.5 decision.

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NOTE: The utility, state and counties are cur-rently compiling a description submittal of their i

entire alert and notification system in accord with i-the requirements contained in the " Standard Guide h

for the Evaluation of Alert and Notification Systems i

for Nuclear Power Plantt, FEMA-43" to qualify the 5

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REP-1, Rev.1, and establish a schedule for an alert 70 1

landnotificationsystemdemonstration. This activ-e-

1 l ity will provide an opportunity to closely examine d.,-"

j current systems improvement requirements.

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h 5.0 EXERCISE FINDINGS HATRIX JURISDICTION Amador County t

CATECORY B

PAGE 2 FINDING NUREG-0654 CORRECTIVE ACTION REFERENCE DATES 3.

There was little to no coordination of media, Proj /Actu.

rumor control; EBS, or protective action implemen-Tri-County discussions and implementation of tation with the utility, state, or other counties demonstrated during the exercise.

decided upon actions will correct.

9/85 G.4.b.

4.

Evaluation of the transportation activities re-

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lating to evacuation procedures noted problem areas The County of Amador rejects the finding. See relating to primary responsibility, errors in desig-details in attachment.

nated roadblock identifications, and overlapping cannunica tions.

The California Highway Patrol covered all manned roadblocks and took control of directing Cal-Trans and Anador Public Works to the assigned check point. Cal-Trans had no signs and only one barricade per point. Cal-Trans had prob-lens with two roadblocks assigned in the plan, on liighway 12, that should have been assigned to be covered by the Lodi Cal-Trans organization. A typographical error reflects Raodblock No. 27 and No. 28. The California Highway Patrol is not listed in the plan for evacuation. This needs to be cor-rected.

Logistics for buses has assigned responsi-bility that appears to be double work. The Ione Police Dispatcher receives information on the groups that require assistance for evacuation--one being the school district for which the Field Comnand Post at lone also is assigned responsibility.

In addi-tien, the Jackson Logistics Officer has responsibil-ity for contacting the school district to fulfill the requirement for bus,es. A more comprehensive co-i ordinated plan for transportation / evacuation should

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5.0 EXERCISE FINDINGS MATRIX JURISDICTION Amador County CATECORY B

PACE 3 FINu11 C NUREC-0654 CORRECTIVE ACTION DATES REFERENCE Proi/Actua

5. The Amador County Field Command Post dispatched police, emergdncy medical services, and a radio-Equipment and training will correct. See de-Icgical monitoring team to the scene of an accident tails in attachment.

9/85 with an injured, potentially contaminated victim.

All personnel had appropriate dosimeters. The po-lice, emergency medical services and radiological field monitoring team all performed their assigned tasks in a professional manner. The radiological field monitoring team surveyed the vehicle, the area and the victim and found no contamination (per the scenario).

However, a problem was identified in that tha emergency medical services rescue vehicle carriec radiological monitoring equipment which was well out of calibration and the staff were not fully trained in the proper use of the equipment.

In this par-ticular demonstration, no adverse effects were ob-served due to the dispatch of a properly equipped and trained radiological field monitoring team.

Ilouever, in a real event the radiological field monitoring team may not be available and had contam-ination been present, problems could have resulted.

L.1 6.

Due to the scope of the exercise and evacuation being a part of the scenario for Amador County in The County of Amador rejects the finding. See this exercise, there were peripheral activities that details in attachment.

were noted by exercise observers. One such item was the lack of consideration being given to the cities within the county that are involved in emergency

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response activities by virtue of geography, but with-km

'out benefit of planned assignment. As mentioned in

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the Exercise Summary portion of this report, local E

government (city and county) have, by law the pr

{X i mary responsibility for emergency response, opera i-

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'tions, with State support. Evacuation implementa-7, l

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5.0 EXERCISE FINDINGS MATRIX

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JURISDICTION Amador County- - - - - - g CATECORY B

PACE 4 FINDING NUREC-0654 CORRECTIVE ACTION DATES REFERENCE Proj/Actua to radiological emergency response activities in-A.2.a.

directly affecting their jurisdiction. Yet the A.2.b.

cities are neither tasked by the plan nor a part of F.1 the coonnunications system.

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January 4,1985 Orrin E. Orr, Chief Radiological Emergency Preparedness State Office of Emergency Services 2800 Meadowview Road Sacramento, CA 95832

Dear Orrin:

The attached is Amador County's response to the 1984 Rancho Seco' Exercise. In your transmittal to FEMA, I would appreciate your mentioning the following specific items:

1. FEMA evaluators failed to discuss findings with county at the debriefing as previously agreed upon, and theref ore reported inaccurate information.

2.

The exercise utilized too compressed a timeframe for adequate demonstration of response capabilities. The county recommends that all future exercises be two-day exercises.

3.

There is a need for a public address-type system to each county EOC so that each EOC can actually hear the EOF briefings being given. This should help eliminate " slow" or

" inaccurate" information flow.

This response is being sent.to the State OES for compilation into its final report format; however, in keeping with previous po!!cy of the board of supervisors, a complete and unabridged copy of this transmittal must be appended to the official response sent to FEMA. In addition, the Rancho Seco Plan, Part V, requires a complete copy of this transmittal to be sent directly to FEMA and for FEMA to assure its attachment to the original critique document.

Thank you, BLU Sean M. Crowder Coordinator

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l The following information is provided in response to FEMA's 1984 critique of the 1984 Rancho Seco Exercise. Although it appears that the County of Amador need only respond to the Category B matrices presented in Section 5.0, there are certain incorrect or inaccurate statements or suppositions that appear throughout the body of the critique document. Therefore, this response will be a page-by-page response.

Section 4.0 EXERCISE DETAIL

-Page Two, Paragraph 1 - Exercise Scenario-The County of Amador believes it to be inappropriate to conduct an exercise and not " grade" it. To say the exercise is merely "a report of exercise observations" is deceptive and misleading to the public due to two factors:

1.

The public is not overly familiar with the detailed workings of the plan and cannot readily interpret an observation. They can, however, readily perceive the significance of a

" letter grade or score" and directly relate that grade to their own personal sense of security or well-being; and 2.

Observations are not always accurate as evidenced by previous FEMA evaluations, (including this 1984 critique), therefore, an inaccurate observation reported to the public can reflect an erroneous state of preparedness--either for good or for bad.

-Page Three, Paragraphs 5 and 6 - Exercise Scenario-The County of Amador concurs that the extent of play for rad monitoring teams should be expanded and believes a two-day exercise is appropriate for all future exercises.

-Page Three, Paragraph 8 - Past Findings-This paragraph implies that the evacuation portion of the exercise was cancelled as a result of jumping the scenario from an Alert to a General Emergency classification. This statement is erroneous and misleading.

-Page Three, Paragraph Last - Outstanding Objectives-The implication in this paragraph is that Amador County was comehow at fault for this " time lag". In actuality, the problem was both an information flow problem from the EOF as well as a scenario problem. The decision to cancel the evacuation was not made by the County of Amador.

-Page Four,' Paragraph Two-This statement is not necessarily true. The County of Amador reserves its right to determine its level of participation in any future exercise.

-Page Four, Paragraph Four-This paragraph requires both explanation and justification before the County of Amador can respond.

-Page Five, Paragraph One-The County of Amador also believes the subject of back-up communications for the ENC should be pursued.

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-Page Six, Paragraph Two-The County of Amador does not concur with this suggestion and therefore does-not intend to implement or support its implementation.

-Page Seven, Paragraph Three-The confusion ~ alluded to in this paragraph could be eliminated by implementing No. 3 cited in the cover letter.

-Page Seven, Paragraph Seven-The County of Amador concurs with the intent of this paragraph.

-Page Seven, Paragraph Eight-The County of Amador does not concur with the last sentence of this paragraph.

-Page Seven, Paragraph Next-to-Last-The County of Amador does not believe this function to be a public information function, but rather an emergency broadcast function.

-Page Seven, Paragraph Last-The County of Amador does not believe the flow of information from the EOF conferences to the EOC decision-maker was at all satisfactory. There were blg gaps of time. and adequate' information flow. See No. 3 cited in the cover letter for additional information.

-Page Eight, Paragraph Three-Sentence two is Inaccurate in that the scenario called for discussion only and no

" response operations" with regard to ingestion pathway.

-Page Eight, Paragraph Six-This paragraph is inaccurate.

-Page Eight, Paragraph Last-The County of Amador does not believe its existing EOC facilities to be adequ' ate for an actual response to a nuclear accident. "Small and cramped" does not begin to describe the poor response conditions that would exist should a prolonged nuclear response be necessary..

-Page Nine, Paragraph One-No. 1 - The County of Amador concurs and believes SMUD should purchase and provide such duplicating equipment for use within or near the EOC.

No. 2. Press releases were posted in the EOC.

N o.' 3 - Action has been taken to correct this problem.

No. 4 - The County of Amador will ut!!!ze such a map when SMUD or the State OES provides the map and the capability to post accurate plume information on it.

No. 5 - The county concurs.

No. 6 - The county concurs and is taking steps to implement such cet!on.

No. 7 - The county believes this capability currently exists.,

No.8 - The county concurs.

No. 9 - The county concurs.

No. 10- The county will review this subject during its review of the public information function.

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No.11-The county concurs, but doubts if sufficient staff can-be obtained to achieve the level of clerical need.

No.12. The county does not concur.

-Page Nine, Paragraph Next-to-Last-The County of Amador concurs that there is a need for SMUD to install a RACES antenna at the EOF, and that a " drop" for each county should be provided so that county-specific RACES can be fully utilized as back-up communicators.

-Page Nine, Paragraph Last-The County of Amador retains its right to determine its level of participation in any future exercise.

-Page Ten, Paragraph One-Sentence Four is without substantiation; therefore the County of Amador has no basis-in-fact for a response.

-Page Ten, Paragraph Two-Sentence Two has appeared in many critiques and evaluations. The County of Amador will accept two or three "all-weather vehicles" for our rad teams should SMUD provide them.

-Page Twelve, Paragraph Two-The fact that the TSC preempted communications on the two-digit ring-down line d_id impact EOC operations. If the counties have timely access to the phone system, then tri-county coordination could be more timely and adequate. The County of Amador believes the TSC should be provided with supplemental communications capability between itself and the EOF so that coordinated county responses and coordination activities will not be hampered when " locked-out" by the TSC.

-Page Twelve, Paragraph Last-The County of Amador does not concur with the conclusion as stated in the last sentence.

Other equally valid conclusions could be drawn from the statements presented.

Section 5.0 - EXERCISE FINDINGS MATRIX

-SMUD Page 1, Finding #3-See Amador County cover letter No. 3 for comments.

-Amador County Page 1, Finding #1-The County of Amador rejects this finding as incorrect.

The plan clearly delineates the procedures to be utilized and provides the necessary supporting material to assure prompt notification of key personnel regardless of the level of emergency.

The county does recognize the necessity to provide training on an cngoing basis to assure that employees are informed and knowledgeable of the proper N & A procedures.

-Amador County Page 1, Finding #2-The person responsible for monitoring the broadcasting of all EBS messages correctly logged the broadcast and " simulated" content of each message which had been sent over the EBS system. The FEMA evaluator failed to observe this process. All EBS confirmations were reported to the Coordinator.

-Amador County Page 2, Finding #3-The county concurs there was very little coordination of media functions.

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Rumor control is county-specific and does not require " coordination" unless a question concerning another jurisdiction is raised. No basis-in-fact is provided within the critique, therefore, the county rejects this portion of the finding.

The county concurs that the coordination for EBS needs improvement and will be meeting with the other two counties and State OES to address this issue in early 1985.

The county believes that a total review of coordinating the implementation of protective actions is warranted and will participate in tri-county discussions of the issue.

-Amador County Page 2, Finding #4-All emergency response personnel performed their respense duties according to plan procedures as assigned to them and as presented on the matrix shown in Part I of the plan; therefore, the County of Amador rejects the finding.

-Amador County Page 3, Finding #5-The proper equipment has been requested from SMUD and State OES to assure i that there will be no future occurrences of this kind. Continued training should also be I provided to ambulance personnel in the use of this equipment.

-Amador County Page 3, Finding #6-Part I of the Amador County Plan clearly shov/s the respective areas of responsibility for all cities within Amador County, (Part I, Page 36).. Part IV,1.1-5 clearly presents the mechanism tying the cities to the emergency response communication system. SOPS are written for the City of lone since it is the or.!y city within the 10-mile EPZ which plays an integral role in emergency nesponse.' Therefore,

,,the County of Amador rejects the finding.

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5.0 EXERCISE FINDINGS MATRIX

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JURISDICTION Sacramento County CATECORY R

PACE 1 FINDING NUREC-0654 CORRECTIVE ACTION REFERENCE DATES 1.

The planned alert and notification system for Proj /Actua the County failed to meet the criteria of NUREG-0654 during the exercise. While there was an established Sacramento disagrees with the finding. See procedure for alerting, notifying, and mobilizing detail in attachment.

emergency response personnel, the escalation of the classification level fran Alert directly to General Emergency resulted in a breakdown of the planned system. Key personnel who would have been mobilized lattheSiteAreaclassification level (who were put

! on standby at the Alert level) were not contacted at the time the General Emergency was declared. The plan, standard operating procedure, and or checklist should repeat the actions to be taken at the lower

classification level within the next higher classi-

fication level as further assurance that those ac-

<tivities have been accomplished or that they are E.2 still required.

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During the exercise the Sacramento County Emer-gency Operations Coordinator failed to transmit the Tri-County discussions and implementation of first actual EBS protective action message to the decided upon actions will correct.

9/85 radio station KFBK. The only information that the radio station received was one message at 10:15 A.M.

instructing them to transmit a standard EBS test message. Later EBS messages were simulated from the f.0F, but were never actually sent to the radio station. Also, the Emergency Operations Coordina-simulated transmitting EBS directly to the tor radio station from the EOF. This is not in accord uith the County Plan which states that the EOC is s

responsible for implementing all protective actions.

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the Sacramento County E0C is the EBS entry point, out the EOF. The only means of communication be-

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s PART IV - OPERAllNG DAT A MANUAL - SACRAMUtTO COUNTY PERSONNEL ACTIVAlloti LIST (Cont.)

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POSITION /

WORK PH.

RADIO TIME CONTACT H0ttE PH.

PAGER CONTACT ARRIVE ASSIGNMENT a.

Communications Officer (1) 366-2706 896 6

Ron Allison 422-2654 09/5~ f OC 366-2706 897 Lawrence Vandre 428-2131 366-2706 898 Gary Massone 366-2706 899 Kent Eldr_idge 786-7007 b.

Security Of ficer (1) 440-5722 485 Lee Gh11arducci 421-4836 er WAic+3/t 440-5722 487 S M eCy

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IT OC Robert Ladner 988-4643*

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/ci f 440-5722

.489 Robert Carboni 445-5739 c.

Msq. Cntr. Supervisor (1) 366-2111 Patt Adachi 966-0904 366-2914 391-5982 Joanc.e L ay 366-2914

@OC Lynette Doerflein 481-4132 oCP / 7 d.

Purchasing Agent (1)

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/EN Andrew Reshke 421-8180

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/ fotB 366-2030

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383-3420 Jack Mehl 366-2035 Ray Tharaldson 489-8282 r

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1.1-1, Page 2 Issued: ?-13-84

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.4-PART IV - OPERATING DATA MANUAL - SACRAMENTO C00MTY Exhibit 1.1-1 EOC SUPPORT staff ACTIVATION LIST (Cont.)

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RADIO TIME ~

CONTACT liOME PH.

PAGER CONTACT ARRIVE ASSIGNMENT e.

EOC Clerk (2)

Roberta Johnson 366-2111 366-2707 UN Mary Ann Bennett 967-2038 C#7/(,

366-2111 Patt Adach) 966-0904 366-2111 Kim llalker 988 4223 f.

Situation Intelligence Officer (1) 366-2111 Spencer Bole 488-8824 366-2111 goc Loutse lockhart 988-9434 093/

922-3885 Don Yee c.

Radio Operator (2)

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366-2914 GLC)<Z Cory Jameson 366-3312 0973

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PART IV - OPERATING DATA MANUAL - SACRAMENTO C,0UNTY Exhibit 1.1-1 EOC SUPPORT STAFF ACTIVATION LIST (Cont.)

POSITION /

WORK PH.

RADIO TIME CONTACT

-HOME PH.

PAGER CONTACT ARRIVE ASSIGNMENT h.

Message Center Operators (1) 366-2707

/

EOC Mary Ann Bennett 967-2038

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/ Jes/o 366-2116

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Nancy Lane 685-4640*

366-2111 Kim Walker 988 4223 1.

RACES Coor'dinator (1) 452-5056 STMb uy

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KOC Keith Crandall 381-5157 c3953 9

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Robert Cloud 961-8407

• 366-2107 Gary Wann 972-0232 l

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Log information on FORM A or FORM B of the ON 5' O /O "NOTIFIC ATION FOR M. "

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Dispatch Fire, Ambulance, Law, etc. if offsite support is requested by Rancho Seco f) / N f)/ /)

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(Galt Fire 209-745-3022 or Blue Net 1 44R4 0" W

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Contact Senior Dispatcher for additional CCTR staffing (392-489 3).

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Complete the " PERSONNEL ACTIVATION LIST."

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5.

If Rancho Seco Park Closure or Evacuation is N/A Clos e Evac.

indicated or directed, contact Control 22 (2072) g CuPC. *

(if ope rational) or: Goldwyn Schroeder 988-6272 Gary Knut11a 486-711'1 f5 Thom Oliver 685-6342 pcg.3 @

c939 00rfRt.)

r>c u Ac. * (D Advise them of the emergency classification and ON request Rancho Seco Park Closure or Evacuation.

/

If requested by the Health Officer, notify the N/A l

following of the potential that they may be handling contaminated patients: 1-4489 or 209-745-3022 s,

unit rire utue not (Tontrol Firo hotline b.

Elk Grove Fire Sac / Hill hotline o.

t! DIS 454-2223 d.

Sutter General Hospital 4S3-3020 c.

1!ethodist Hospital 486-3211 l

f.

American River Hospital t

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Notify the Health Officer of any emergency medical l' I

response associated with the Rancho Seco Emergency j

(31h3 at ECC).

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EBS. When directed by the Emergency CoordimMor N/A or.Doalgnated Official, call the EDS station,

[

924-3222 (KF3K). Advice them that an EBS l

broadcast may be required as the result of an incident at the Rancho Seco Power Plant and that they witi be catted if an EBS broadcast.is reqGred.

,l (EBS folder at Console c )

3 Whna directed, initiato Siren Activationprocedurce. $

N/A.

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10. Additional otificationst

c. If direetz 1, con s a,14ER AGENCY _

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lok NOTIFIC c r!OB' yIST." Advise the EOC Ops.

Officer at ;. ' '4114 when list complete.

b If directed, complete "EOC SUPPORT STAFF N/A ACTIVATION LIST." Advise the EOC Ops.

ogp9 I

Officer at 2707/2114 when list is complete.

11. Initiate an " EMERGENCY OPERATIONS ACTION AND MESSAGE LOG" and update.

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Exercise Findines Matrix - Sacramento County - page 1-2 continued FEMA' Finding:

During the exercise the Sacramento County Emergency Operations Coordinator failed to transmit the first actual EBS protective' action message to the radio station KFBK.

The only information that the radio station received was one nessage at 10:15 A.M. Instructing,them to transmit a standard EBS test message.

Later EES messages were simulated from the ECF, but were never actually sent to the radio station.

Also, the Emergency Operations Coordinator simulated transmitting EBS directly to the radio station from the EOF.

This is not in accord with the County Plan which states that the EOC is responsible for implementing all protective actions. The Sacramento County EOC is the EDS entry point, not the EOF.

The only means of communication between the EOC and the radio station studio is common dial telephone. This circuit would be overloaded during.an emergency. A ring-down circuit or a radio link should be considered. The EBS radio station KFBK did not have copies of the prescripted EBS messages available to its operation personnel.

Also, the book of instructions were not available. The radio station appeared to bo reluctant to participate in the exercise.

The Sacramento Emergency Broadcast Station (EBS) system needs considerable training and coordination between the counties and the radio station KFBK. At the present time, the EDS system in Sacramento is not considered sufficiently functional to be implemented during an incident at the Rancho Seco Nuclear Generating Station.

County Response:

The county of Sacramento agreed to the following exercise objectives (see under 2.0 objectives and guidelines) with regard to the EBS:

e l

SACRAMENTO EBS notification to coincide with EBS station testing.

No actual EBS broadcast of messages.

- Simulated use of sirens.

- Remaining according to Plan.

Sacramento County never agreed to actually pass a test message to the CPCS 1

-station, KFBK.

The County did agree to ask the station to transmit their weekly test message

.to_ coincide with the simulated $ sounding of the sirens.

The Radio Statfon did comply with this request.

EOC staff confirmed that the

[

message was broadcast at the appropriate time.

I

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page 1-2 continued Sacramento County Exercino Findinos Matrix Tho Emergency Operations coordinator put the CPCS 1 station on alert status when the County EOC was partially activiated at the second stage " alert classification". The initial message was simulated to the station, which broadcast their weekly test message at the County's request.

Later messages were simulated from the EOF which is in conflict with the EBS as written plan. The plan will be rewritten to show the entry point for cither the EOC or EOF, that decision has not been made yet, as meetings with cll concerned partics, including FEMA, are ongoing.

the county The County agrees that further training and coordination between and the radio stations is necessary. Toward that goal there have been several Ecotings between County staff and the radio stations.

FEMA is providing money 2-way radio link between the County and KFBK as an to KFBK to supply a alternate n.cthod to land line communications.

The county is working with KFBK; KRAK and KGNR to establish written procedures conduct ongoing training to ensure that the EBS system in Sacramento and to may be quickly implemented in the event of an incident at the Rancho Seco Nbclear Generating Station.

FEMA personnel with technical expertise in communications are also participating in these meetings.

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' page 2-3 Exercisc Findings Matrix Sacramento _ County 2

3 FEMA' Finding:

~

. Ability to identify and check individuals who may have been ecntaminated during ;an evacuation was not satisfactorily demonstrated. According to the

-operating procedures manual for sacramento County traffic control points in c

contaminated areas should have areas for decontamination and storage of contaninated vehicles. 'All traffic should be detained until checked by a radiation field monitoring team. Per County Health, they,do not have adequate

.' staff to perform this functibn nor do they have the necessary equipment.

If called upon in a real situation to have monitoring teams at all traffic control points, they would not be able to provide service with_ existing staff.

Tho coordinator 'in the Field Command Post did not know where the decontamination point was.

County Response:

Training has been changed 'to stress de-contamination procedures.

The Evacuaticn occured prior to any release. There was no need to decontaminate a'ny vehicles or personnel. County Health does have decontamination equipment contrary to the FEMA Evaluation,. The statement "Per County Health, they do not have adequate staff to perform this function nor do they _ have the necessary equipment.",

was taken out of context and is not true. County

= Health Administration made no such statement, in fact, Traffic Control points could be manned for decontamination by Health Department personnel and if needed, additional personnel would be provided by the Fire Districts.

There is no such position as " Coordinator" in the Field Command Post.

There is a Field Command Post Commander, a sheriff's Department representative, and he does know that the decontamination points are the traffic access control points and where they are located.

a 7

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Sacramento County Exercine Findine Matrix page 3

• FEMA Finding:

Radiological Field Monitoring Team kits did not include chdreoal cartridges, anti-contamination suits, respirators or KI tablets (which were kept at the Wilton. Fire Statien Field Command Post at least eight miles from the points the team was responsible for monitoring)

County Responses Field Mcnitoring Team Kits are not required by, NUREG 0654, to carry this equipment.. Radiolegical Monitoring teams are removed from the field at 100 mr/hr.

If I-131 is released.(as por UDAC), field teams will be removed to F.ield Censand Post and-await further instructions.

FEMA Findings:

The County standard operating procedures protective action guide states the team should not stay in a radiation field over 200 mr/hr. The team was in a field with over 500 mr/hr at 12:52 P.M.

The field Command Post requested another air sample which kept the team in the field until 1:04 P.M.

. County Response:

The RSOERP states that the field survey team shall withdraw immediately and contact the Radiological. Monitoring Supervisor if the dose rates exceed 100 mr/hr not 200 mr/hr as stated in the FEMA findings. The Plan also states a worker whose dose approaches 500 mr should be re-assigned outside the 10-mile Emergency Planning Zone, if possible. The total dose received by the team in the 500 mr/hr field was about 100 mr, well within the exposure limitations.

The UDAC was aware of the 500 mr/hr field and the associated risks involved.

The UDAC team concluded that the risk was minimal compared to the need for the air samplo.

See part III; Section 5.3.1 page 1 Caution Statement.

Any field survey team that encounters dose rates of 100 mr/hr or nore shall withdraw immediately and contact the Radiological Monitoring Supervisor.

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Exercise Findino Matrix page 3 Sacramento County e

FE!;A Finding:

The Team Leader for the Radiological Field Monitoring Team If stated that he and the other county monitors have had little experience with actual nonitoring conditions. The monitoring teams should be assigned at least a week por year to field conditions training using the appropriate equipments.

County Response:

This is a subjective statement not documented by field observation.

Radiological Monitor training does include actual monitoring conditions includine radioactive sources.

FEMA Finding:

Cue to the scope of the exercise and evacuation being a part of the scenario for Amador Cpunty in this exercise, there were peripheral activities that were noted by erercise observers. One such item was the lack of consideration being given to the cities within the county that are involved in emergency response activitics by virtue 6f geography, but without benefit of planned assignment. As mentioned in the Exercise Summary portion of this report, local government (city and county) have, by law, the primary responsibility for emergency response operations, with State support.

Evacuation implementation and/or public information mechanisms create a requirement for city service agencies (i.e., law enforcement, fire, public works, etc.) to roepend to radiological emergency response activities indirectly affecting their jurisdiction. Yet the cities are neither. tasked by the plan nor a part of the communications system. This applies to all county plans that impact on city government.

County Response:

This finding is not applicable to Sacran. ento County.

There are no cities within the EPZ for Sacramento County, NUREG C654 page 11

" Planning Basis" delineates 10 mile radius for EPZ.

Inge.5 tion Pathway of 50-miles is the State responsibility with the assistance of Sacramento County's Health Ddpartment which has jurisdiction in all cities within Sacramento County.

D

h 5.0 EXERCISE FINDINGS MATRIX JURISDICTION San Joaquin County -

CATECORY B

PAGE 1 FINDING NUREG-0654 CORRECTIVE ACTION -

DATES REFERENCE Pro i /Actuti I '

l.

The planned alert and notification system for the County failed to meet the criteria of NUREG-0654 San Joaquin County disagrees with the evalua-during the exercise. While there was an established tion finding, but will consider revision to procedure for alerting, notifying and mobilizing Procedures and training conduct.

9/85 emergency responsg personnel, the escalation of the classification level from Alert directly to General Emergency resulted in a breakdown of the planned system. Key personnel who would have been mobilized at the Site Area classification level (who were put on standby at the Alert level) were not contacted at the time the General Emergency was declared. The plan, standard operating procedure, and or checklist should repeat the actions to be taken at the lower classification level within the next higher classi-fication level as further assurance that those ac-tivities have been accomplished or that they are E.2 still required.

H.4 NOTE: The utility, state and counties are cur-

. rently compiling a description submittal of their

)

! entire alert and notification system in accord with l

lthe requirements contained in the " Standard Guide for the Evaluation of Alert and Notification

}

l Systems for Nuclear Power Plants, FEMA-43" to quali-i fy the system against the criteria of NUREG-0654-l FEMA-REP-1, Rev.1, and establish a schedule. for an l alert and notification system demonstration. This

activity will provide an opportunity to closely 4

examine current systems improvement requirements.

if-

~

2.

There was little to no coordination of media, rt.

rumor control, EBS, or protective actions imple-San Joaquin County disagrees wtth the evalua-A mentation with the utility, state,'or other counties tton ftndings Trt-County discusstons and

,t.

demonstrated during the exercise.

G.4.b implementation of decided upon actions will 5,

correct, 9/85

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5.0 EXERCISE FINDINGS MATRIX

• l L

JURISDICTION San Joaquin County CATECORY B PAGE 2 FINDI!1C NUREG-0654 CORRECTIVE ACTION i

REFERENCE DATES 3.

Due to the scope of the exercise and evacuation Proj/ Actual lbeing a part of the scenario for Amador County in

.this exercise, there were peripheral activities that San Joaquin County disagrees with evaluation finding, see details in attachment.

were noted by exercise observers.

One such item was Lhe lack of consideration being given to the cities l

'uithin the county that are involved in emergency l response activities by virtue of geography,.but

!without benefit of planned assignment.

As mention-

ed in the Exercise Summary portion of this report, local government (city and county) have, by law

' the primary responsibility for emergency respons,e operations, with State support. Evacuation imple-

, ment.ation and/or public information mechanisms

' create a requirement for city' service agencies (i.e., law enforcement, fire, public works

'to respond to radiological emergency respon,se ac.)

etc Livities indirectly affecting their jurisdiction.-

A.2.a.

A.2.b.

(et the cities are neither tasked by the plan nor F.1 a part of the communications system. This applies F.6 to all county plans that impact on city government.

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a COUNTY OF SAN JOAQUIN OFFICE OF Et.;ERGENCY SERVICES nouas.o z. matowiu er C'**D'"'70" Roou 40s, countwouse 222 EAST WEBER AVENUE hy

,e SToCKToN. CALIFoRNI A 95202 Ts6erwona e aosi e44 2et:

February 5, 1985 e

~ Mr. Orrin E. Crr, Chief Radiological Dnergency Preparedness Office of Dnergency Services Post Office Box 9577 Sacramnto, California 95823

Dear Orrin,

We would like the following ccrments incorporated into the reply to the Federal Energency Managemnt Agency Critigee of the 1984 Rancho Seco Fxercise. Overall, we felt it was a valid exercise that demon-strated our ability to respond adequately to any emergency at the plant. While this reply centers on the matrix ccnments, I have also

' included sane conments on the narrative portion.

DERCISE FINDINGS MATRIX - SAN JOAQUIN COUNI'Y

- FINDING 1 - We deny the implication that key people were not notified.

All required personnel were notified, however, there were mre problems than there should have been. We intend to revise the precedures and conduct training during 1985 to improve notificaticn activities.

FINDING 2 - While there were problems with coordination, the charac-terization of the situation as "little to no" coordination is an inaccurate overstatement. Particularly, in the area of Dnergency Broadcast System and Protective Action coordination, the situation was satisfactory after scrne initial problems.

FINDING 3 - According to plan procedures, all city police departe nts are notified by the Sheriff's Departent at the Alert Ieval. Knowledge of local governmnt processes would reveal that a key function of the Chairman of the Board of Supervisors is to coordinate with other poli-i i

.t cal leaders and jur sdictions of the County.

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Mr. Orrin E. Orr February 5, 1985 Page 'No FEMA CRITIQUE OF 'IHE 1984 RANCHO SB00 EXERCISE,

01HFR CG+1ENTS 4.0 EXERCISE DETAIL - NARRATIVE 1.

EDF - Page 7 - Next to Iast Paragraph Protective Action rec h tions and instructions issued by San Joaquin County were sent to the Sacramento Municipal Utility District Public Information facsimile operator as planned. Our feeling is that the Sacramento Municipal Utility District needs to revise the Energency News Center and Public Information Officer procedures at their end. They have not provided persons to serve as PIO clerks at the ENC and the system of having PIO messages arrive at the EDF instead of the ENC is bound to lead to confusion.

2.

San'Joaquin County EOC - Page 11 of Exercise Detail We did receive timely information frm our liaison at the

~

EOF and frm the Control Rom and Technical Support Center.

All information on EOF status boards and frm briefings was passed on to us. Required coordination of protective actions and EBS messages was not accomplished as well as it should have been. The information coordination system does need to be reviewed.

Other criticisms in regard to forms and radiological monitor procedures will be addressed in this year's training program.

While these are all the coments we have in regard to the critique, San Joaquin County will conduct a thorough review of all procedures to seek ways to improve our response.

In addition, as subrnitted to you earlier, the County will conduct a thorough training program in 1985 to ensure our ability to respond effectively to any emergency at Rancho Seco.

If you, or the Federal Drergency Management Agency officials, have any questions, please feel free to call-in rely, d

UV Ronald E. Baldwin, Coordinator Dnergency Sdrvices REB /hld c: Carol Hopwed, Sacramento County Sean Crowder, Amador County Rob Meyers, SMUD

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STAft OF CALIFORNIA GEORGE DEUKMEJ1AN, Covernor OFFICE OF EMERGENCY SERVICES POST OFilCE SOX 9377 SACRAMENTO. CALIFORNIA F5023 (916) 427-4990 427-4013 February 19, 1985 1

Sue Elkins FEMA Region IX Bldg. 105 Presidio of San Francisco, CA 94129 Dear Sues.

Enclosed are the SMUD and San Joaquin, Sacramento and Amador county comments on the 1984 FEMA exercise findings.

We will be discussing these at the Rancho Seco Planning Team meeting March 6 in Sacramento. Orrin will let you know the place and time.

Please call Orrin if you have questions.

Sincerely.

N g#

4 ANN C. VASQUEZ, Chief Radiological Emergency Preparedness Fncs.

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q STATE OF CAUFORNIA GEORGE DEUKMEJ1AN. Governor OFFICE OF EMERGENCY SERVICES POST OFFICE 80X 9577 SACRAMENTO, CAUFORNIA 95823 (916) 427-4990 November 30, 1984 Robert L. Vickers, Regional Director Federal Emergency Management Agency Region IX Bldg. 105 Presidio of San Francisco, CA 94129

Dear Mr. Vickers:

The 1984 Rancho Seco Emergency Preparedness Exercise Report was forwarded to Sacramento, San Joaquin and Amador counties November 5.

A coordination meeting was held November 9, attended by Susan Elkins and Terry Knight of your staff. However. recen; discussions with the jurisdictions indicate they will be unable to develop their corrective action schedules until mid January.

As soon as these schedules have been received by this office and coordinated, a formal corrective action schedule will be submitted to FEMA.

o Sincerfly,

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VI LIAM M. MEDIC ICH Director

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