ML20206T257

From kanterella
Jump to navigation Jump to search
Forwards Corrective Action Schedule for 1984 Exercise of Offsite Radiological Emergency Plans Transmitted by FEMA on 860519.Support of Corrective Actions Should Be Continued
ML20206T257
Person / Time
Site: Rancho Seco
Issue date: 07/03/1986
From: Fish R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Julie Ward
SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8607080061
Download: ML20206T257 (1)
v • d • e


Text

y

~

JUL 031986 Docket No. 50-312 Sacramento Municipal Utility District P. O. Box 15830 Sacramento CA 95813 Attention: Mr. John Ward Assistant General Manager, Nuclear Gentlemen:

Enclosed is a copy of the corrective action schedule for the 1984 exercise of the offsite radiological plans for Rancho Seco Nuclear Generating Station that was transmitted to us by the Federal Emergency Management Agency on May 19, 1986 We request that you continue your effort in support of the corrective actions to assure they are implemented.

Sincerely, Otigin3! signM by R. F. Fish, k.

Ray Fish, Chief Emergency Preparedness Section

Enclosure:

as stated cc: w/ enclosure R. Meyers, SMUD cc: w/o enclosure D. Matthews,-~ Chief, EPB R. Fish, RV -

S. Elkins, FEMA, RIX bec w/ enclosure:

RSB/ Document Control Desk (RlDS)

Project inspector Resident Inspector G. Cook B. Faulkenberry J. Martin Region V 8607080061 860703 PDR ADOCK 05000312 F PDR f$)/.

1;O, .

I. _i

~

7l'/?b n U '

i,6 .

DESIGl!ATED ORIGINAL

,tj 1..

Dertified By,$h/ N g h W f b M .

Federal Emergency Management Agency s* e Washington, D.C. 20472 MA)' I 9 L986 MDtORANDU4 EDR: F13 ward L. Jordan Director, Division of Dnergency Preparedness and Engineering Response Of fice of Inspection and Enforcenent U.S. Nuclear Regularpry Commission FIO4: -

. n

. Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

Corrective Action Schedule for the Septanber 12, 1984 Exercise of the Offsite Radiological Dnergency Prepared-ness Plans for the Rancho Seco Nuclear Generatiry Station i

Attached is a copy of the corrective action schedule for the 1984 joint exercise of the of fsite radiological energency 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 Fbnagement Agency (FD4A) Region LX, was furnished to you earlier.

There has been significant and continuing progress to improve the offsite radiological emergency response capability; therefore FD4A considers that offsite radiological emergency preoaredness is now adequate to provide reasonable assurance that appropriate measures can be taken of fsite to protect the health and safety of the public liviry in the vicinity of the site in the event of a raliological energency.

If dou have any questions, please contact Mr. Robert S. (Vilkerson, Chief, Technological Hazards Division, at 646-2860.

Attachment As Statel MG9ispa6S'

m 2 51985 i' sts ah-. -

d -

p,n ,m j$ ' 9 ~ J Federal Emergency Region IX Management Building 105 Agency Presidio of San Francisco, California 94129 MEMORANDUM FOR: ASSOCIATE DIRECTOR STATE AND LOCAL PROGRAMS AND SUPPORT 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 of fsite 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. Asris stated _in.the text of the corrective action 3 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~st'at'e'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.

FEMA' Region IX has determined there has>been significant and continuing.

~

progress.to improve the offsite emergency' response capability"and that th'ere is' reasonable assurance that appropriate protective measures can be taken to adequately protect public health and safety in the event of a radiological emergency at the Rancho Seco Nuclear Generating Station.

Attachment e

a '

5.0 EXERCISE FINDINGS MATRIX ** ' -

JURISDICTION Sacramento Municipal Utility .Disti CATEGORY B PAGE 1 FINDING NUREC-0654 CORRECTIVE ACTION DATES REFERENCE

1. Proj /Actu:-

While the emergency classification notification This findino should be addressed by San was dispatched by the EOF in a timely manner, in- N/A Joaquin County since it was an observation sufficient information updates were received at the at their E0C.

county EOCs. 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-ently compiling a description sutmittal of their eni..-a 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 activit.)

will provide an opportunity to closely examine cur-rent systems improvement requirements.

2. Many requests to the Technical Support Center 5 Technical Support Center staff will be in- 7/85 for key data required by the UDAC were not responded formed, during training, of their responsi- N to in a timely manner or, at times, not at all. This bility to respond to UDAC. "

hampered or delayed the assessment process by the UDAC sta f f. I.2 E3 8

3. Although the status board on dose projections state " projection" there seems to be ongoing con- The status boards will be revised to reflect

" actual" versus " projected" data.

fusion at the EOF brief'ings concerning projected data vs. actual data, and/or projected data based on 7/85

{

o vD,

" actual" release data vs. projections based on ,

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

p;.

J,

, fusion can be minimized if the terra " measured" is I j us d when data is obtained from field monitoring i l and/or other monitoring systems (e.g., " measured 5 idose rates" to differentiate from projected dose

,j

~~.' .

5.0 EXERCISE FINDINGS MATRIX '~ - ' ' '

JURISDICTION Sacramento Municipal Utility-Distt CATECORY B PACE 2 FINDING NUREC-0654 CORRECTIVE ACTION DATES REFERENCE Proj/Actua i rates / doses based on technical specifications or -

actual release data). Typically, projected dose rates / doses based on technical specifications are conservative and thus lead to conservatism in pro-tective action recoinnendations. Projections based on measured data provide more realistic conditions '

to enable more precision in the determination of protective action recommendations. I.10 O

e e

4 i

l . , .

S';s)

~

I + ,

n '.

g

t b SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830. Sacrarr. ento. California 95813; (916) 4s2-3211 RJR 84-518 November 30, 1984 JACK KEARNS ASSISTANT DIRECTOR PLANS AND PREPAREDilESS.

STATE OF CALIFORNIA 0FFICE OF EHERGENCY 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 findirigs in Section 5.0, Exercise findings Matrix. '

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

(7 '

7

(

NN e c R. J. Rcdtiguez Executive Directorg uclear Attachment

,, , r ,,, .

- .1

i

' --..s. -

-- ^

5.0 ,.

-~'.

. EXERCISE FINDINGS MATRIX .

~ -

JURISDICTION Sacramento Municipal Utilit w .,

- - CATECORY B PACE 1 FINDING NUREC-0654 CORRECTIVE ACTION DATES '

[ __

R,EFERENCE Proj /Ac'ty

l. While the emergency classification notification 1. This finding should be addressed by San N/.\

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.

l 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 EOCs should.be provided. E.4 -

G.4.b.

MOTE: 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 .

l for Nuclear. Power Plants, FEMA-43" to qualify the ,

systcm against'ths criteria of NUREG-06542 FEMA-REP-1, Rev.1, and establish a schedule for an alNt and notification system demonstration. This activity will-provide.an opportunity to closely examine cur-rant systems improvement requirements.

2. Many' requests to the Technical Support Center -
2. Technical Suppor.t Center staff will be 7/85 fer 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 responsibility to respond to UDAC.

hampared or delayed the assessment process-by the .

i U0AC staff. I.2

3. Although the status board on dose projections 3. The status boards will be: revised . to 7/85 l state " projection" there seems'to be ongoing con- reflect " actual" versus " projected" data, i fusion at the EOF briefings concerning projected i

data vs. actual; data *and/or projected data based on

" actual" release data vs. prqjections based-on - -

'* measured". data obtained from monitors. This coa- .

l: fusion can be minimized if the ters " measured" is used when data is obtained frcin field monitoring and/or other monitoring systems (e.g., " measured dose rates" to differentiate- from projected dose

. - _ _ _ , . , _ _ ,, _____m.. .,s__..,y. . . m .,_-_,,% __y. __ , _ . , _ . _ _ __y__ ,. , _, v. ._ - < , _ _ _ , _ _ _ _

L "* * .

5.0 '

EXERCISE TINDINGS MATRIX "

JURISDICTION Sacramento Municipal Utili CATECORY E - PACE 2

-F l'I;:DIMC NUREC-0654 CORRECTIVE ACTION DATES REFERENCE Prol /Ac ts:.

rates / dos::s 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 ion measured data provide more realistic conditions '

to enable more precision in the determination of

, protective action reconnendations. 1.10 9

e

((

1 e

9 e

e a

      • 8** efer ew ** ee e ammt e * = em e + s . we e .e. em s., ,
e. We ebahn e* 68

~ ,.

5.0 EXERCISE FINDINGS HATRIX '*

JURISDICTION Amador County - -

CATECORY B PACE I FINDING NUREG-0654 CORRECTIVE ACTION DATES REFERENCE

1. 'The planned alert and notification system for Proi/Actm th2 County fa'iled to meet the criteria of NUREG-0654 The County of Amador rejects this finding as during the exercise. While there was an established 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 classification level within the next higher classifi-cation level as further assurance that those activ-ities have been accomplished or that they are still E.2 required. H.4

2. The county announced activation of the EBS, but it was not clearly. demonstrated that the appropriate The FEMA evaluator failed to observe " simulated "

notification to the EBS was followed, or that the process. See details in attachment.

message.was consistent with the protective action E.5 '

decision. E.7 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- (_, .,j REP-1, Rev.1, and establish a schedule for an alert y.p" and notification system demonstration. This activ- .

~

ie

,ity.will provide an opportunity to closely examine ,f ., -

j current systems. improvement requirements. T. ,

l

a. ..

5.0 EXERCISE FINDINGS' MATRIX ,

i JURISDICTION ~ Amador County . . .

f CATECORY B' PAGE 2

.. FINDI NG NUREG-0654 CORRECTIVE ACTION DATES REFERENCE Proj/Actu.

3. : .There was little to no coordination of media, -

rumor control; EBS,' or protective action implemen- Tri-County discussions and implementation of tation with the' utility, state, or other counties decided upon actions will correct.

demonstrated during the exercise. 9/85 G.4.b.

4. . Evaluation of the transportation activities re-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 '

connunica tions. The California Highway Patrol .

covered all manned roadblocks and took control of directing Cal-Trans and Amador Public Works to the s assigned check point. Cal-Trans had no signs and only one barricade per point. Cal-Trans had prob-lems 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-i 4

bility that appears to be double work.- The Ione i Police Dispatcher receives information on the groups that' require assistance for evacuation--one being the school- district for which the Field Connand Post

  • at-lone also is assigned responsibility. In addi-tien, the Jackson Logistics Officer has responsibil-ity for contacting the school ~ district to fulfill i the requirement for buses. A more. comprehensive co-y("

~

j i ordinated plan for transportation / evacuation should

be developed by the agencies responsible for'imple-p ; mentation of the plan. J.2

'Ai  :

i

} ,' >

s. =

W 't 4

1

.r--,

L i'

5.0 . .

EXERCISE FINDINGS MATRIX ** ,

~

JURISDICTION Amador County -

CATEGORY B PAGE 3 FINDING .

NUREC-0654 CORRECTIVE ACTION DATES  :

REFERENCE Proj /Actua i ,

5. The Amador County Field Command Post dispatched  ;;

police, energdney medical services,' and a radio- Equipment and training will correct. See de-logical monitoring team to the scene of an accident tails in attachment. 9/85 1 with an injured, potentially contaminated victim. ,

All personnel had appropriate dosimeters. The.po-  !

1 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 the 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.

4 llowever, 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 4

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. '

, wara noted by exercise observers. One such item was ths. lack of consideration being given to the cities

within the county that are involved in emergency '

response. activities by virtue of. geography, but with-i out benefit of planned assignment. As mentioned in I.!

the Exercise Summary portion of. this report, local .

  • 5 government (city and county) have, by law, the pri-

'bmary responsibility for emergency response opera- -

tions, with State support. Evacuation implementa- q'

.; tion and/or public information mechanisms create'a m.

l requirement for city service agencies (i.e., law -

i j enforcement, fire, public works, etc.) to respond i .-

{

~ ..

5.0

~

EXERCISE FINDINGS MATRIX JURISDICTION Amador County 4 .

CATECORY , B PAGE 4 FINDING NUREC-0654 CORRECTIVE ACTION DATES REFERENCE Proj /Ac t u..

to. radiological emergenci response activities in- A.2.a. -

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

citics are neither tasked by the plan nor a part of F.1 the communications system. F.6 4

o V:

r\..

~f e,.

, t'

. o+..

a ..,

.- "' s i

6

.s CF'.*CE C F ,

giW 9 F 9, -

Te _ EMERGENCY SERVICES _ _

4 .

103 COURT STREET = JACKSON, CALIF. 95342

  • PHCNE (200) 223-1383 or 223 3230 Ext. 384 ,

n January 4,1983 Orrin E. Orr, Chief Radiological Emergency Preparedness State Office of Emergency Services 2S00 Meadowview Road Sacramento, CA 93832

Dear Orrin:

The attached is Amador Ceunty'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'" pre'viously agreed upon, and theref ore reported inaccurate?Iniormation.
2. The exercise utilized too compressed a .

timeframe for adequate demonstration of response capabilities. The county recommends that all future exercises be tivo-day 3xercisd

3. There is a"needjfor 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 policy 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,

% . . 11 )

-r- .

Sean M. Crowdert Coordinator .

c: FEMA ..

Attachment b

1 The following information is provided in response to FEMA's 1934 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. Observa.tions 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 shculd 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 :omehow 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 Amader also believes the subject of back-up communications for j the ENC should be pur:;ued.

1 1

~.. ..

.t

-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 big 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 adequate 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 Couaty 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.

No. 3 - Action has been taken to correct this problem.

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

l No. S '- The county concurs.

No. 6 - The county concurs and is taking steps to implement such ection.

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

No. 3 - The county concurs.

No. 9 - The county concurs.

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

3 .

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

N o. 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 i

county-specific RACES can be fully utilized as back-up communicators.

T - e

-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-i ' 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-d The fact that the TSC preempted communications on the two-digit ring-down line did impact EOC operatiens. 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 engoing 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.

i

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

(,

  • i 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 response 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 frorn SMUD and State OES to assure g 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 shows 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 cr.!y city within the 10-mile EPZ which plays an integral role in emergency response.' Therefore,

,,the County of Amador rejects the finding. ..__. __ , _

, . .,s

b -

5.0-EXERCISE FINDINGS MATRIX *- ,

t JURISDICTION Sacramento. County. ,

CATECORY R PACE 1

- FINDING NUREC-0654 CORRECTIVE ACTION REFERENCE ~

DATES '

1. The planned alert and notification system for Proj /Ac tie::

the County failed to meet the criteria of NUREG-0654 during the exercise. While there was an established Sacramento disagrees with the finding. See 4

procedure for alerting, notifying, and mobilizing detail in attachment.

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 i

at the Site Area' classification level (who were put on standby at the Alert level) were not contacted .

i 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-
  • Ii fication level as further assurance that'those ac-tivities have been accomplished or that they are E.2 still required.

11 . 4 5

2. 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-tor simulated transmitting EBS directly to the

. radio station from the EOF. This.is not in accord c uith the County Plan which states that.the E0C-is .-..

g responsible for implementing all protective actions. .

the Sacramento County E0C is the EBS entry point. -

lq -

.iot the EOF. The .only means of communication be- o

' tween the'EOC'and the radio station studio is-com- ,l-

.i.on dial telephone. This circuit would be over-- i.

4 loaded during an emergency. A ring-down circuit' .

4

. .u a radio link should be considered. The EBS

~. .

5.0 EXERCISE FINDINGS MATRIX . "

' - - .i I

JURISDICTION Sacramento County- , .

CATEGORY B PAGE 2 FINDING '

NUREG-0654 CORRECTIVE ACTION REFERENCE DATES-l Proj /Actua l radio station KFBK did'not have copies of the pre-l scripted EBS messages available to its operating #

personnel. Also, the book of instructions were not

i. available. ~The radio station appeared to be re-luctant 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 EBS system in Sacramento is not considered sufficiently functional to be E.5

implemented during an ' incident at the: Rancho Seco E.7-

.'iluclear Generating Station.

, G.4.b.

NOTE: ,The utility, state and counties are cur-

' rently canpiling aidescription 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 f or Nuclear Power Plants, FEMA-43" to qualify the

' tystem against the criteria of NUREG;0654, FEMA-IIEP-1, Rev. 1, and establish aischedule for an alert

.'ind notification system ' demonstration. : This activ-ity will provide an opportunity to closely examine

current systems improvement requirements.
1. ; Ability to identify and check individualswho.may
nave been contaminated during.an evacuation was not i .atisfactorily demonstrated. According to the- Sacramento County disagrees.with evaluation ,.

-' aperating procedures manual for Sacramento County finding, but will stress de-contamination (",[y Liraffic control points in contaminated areas should procedures in future training ~ activities, s5 r c L>

ruve areas for decontamination and ~ storage' of con- #

taminated vehicles. . All- traffic should be detained l' .

C;;.

mtil checked by a radiation ' field monitoring team. ti

/er County Health, they'do not have adequate staff

j to perform this function nor dolthey have the neces- .

.ary equipment.

If called upon in a real. situation

, , ,. ,. ,, . . . =.-. _

5.0 ,

EXERCISE FIUDINGS MATRIX '

JURISDICTION Sacramento County ,

CATEGORY B PAGE 3 FINDING NUREG-0654 CORRECTIVE ACTION REFERENCE DATES Proj/Actuai to have monitoring teams at all traffic control points, they would not be able to provide service

,uith existing staff. The coordinator in the K.5.a.

! rield Conunand Post did not know where theidecon- K.S.b.

' t.imina tion point was.

! 4. Radiological Field Monitoring Team kits did not - -

include charcoal cartridges, anti-contamination Sacramento County disagrees with the evalua-suits, respirators or KI tablets (which were kept tion finding. See details attached.

'at the Wilton Fire Station Field Command Post at -

lease eight miles from the points the team was H.11 responsible for monitoring). J.10

.S. The County standard operating procedures pro-tective action guide states the team should not Sacramento County disagrees with the evalua-stay in a radiation field over 200 mr/hr. The team tion finding. See details attached.

was in a field with over 500 mr/hr at 12:52 P.M.

The Field Command Post requested another air sample shich kept the team in'the field until 1:04 P.M. K.4 6 The Team Leader for the Radiological Field Monitoring Team Il stated that he and the other Sacramento County disagrees with the evalua-county monitors have had little experience with tion finding'. See details attached.

.ictual monitoring conditions. The monitoring teams

.hould be assigned at least a week per year to field i:onditions training using the appropriate equipment. 0.4.c.

/, Due to the scope of the exercise and evacuation being a part of the scenario for Amador County in i-this exercise, there were peripheral activities that Sacramento County disagrees with the evalua- E

. tere noted by exercise observers. One such item was tion finding. See details attached.

?

ihe lack of consideration being given to the cities '

s althin the county that are involved in emergency a response activities by virtue of geography, but

.tilhout benefit of planned assignment. As mention-- ,

d in the Exercise Summary portion of this report. '

local government (city and county) have, by law,

9" 97 COUNTY OF SACRAMENTO 8

DEPARTf.1ENT OF GENERAL SERVICES

\o g* JERRY M. SAULTER, DIRECTOR U D tayoS Carole Hopwood Emergency Operations Coordinator Emergency Operations Services (916) 366-2707 January 7, 1985 Orrin Orr, Chief Radiological Emergency Preparedness California Office of Emergency Services P. O. Box 9577 Sacramento, CA. 95823

Dear Orrin,

Attached is the County of Sacramento's response to the FEMA evaluation findings for the September 12, 1984 exercise.

As you suggested during our telephone conversation on Friday,- it is appropriate 'to schedule a meeting between FEMA, OES, and the involved ji;risdictions to discuss the responses.

I look forward to hearing from you regarding the future meeting date. ,

i Sincerely, b .

Carole Hopwood Emergency Operations Coordinator JAN 8 1985 3284 RAMOS CIRCLE n SACRAMENTO, CALIFORNIA 95827 = TELEPHONE (916) 366 2111

. s A

  • Exercise Detail page 3 - Sacramento County FE!!A Comments:

~ -Excrcise Evaluator comments directed to the exercise scenario implementation were as follows:

1. Radiological Field Monitoring Teams noted that certain radiologial readings data contained in.the scenario radiological inforcation (rcading for open/ closed RO-2) were reversed. The readings for the RM-7 for dose and contact were impossible.
2. The Radiological Field Monitoring Team Evaluators who served as controllers felt the controller manual data was presented in a confused nanner.
3. Tbc extent of play for the Radiological Field Monitoring Teams should be expanded to include more sampic points, air samples, decentcatination, and capabilitics for sustained operations.

Scenario devcicpment for future RSNGS plans and preparedness exercises should be expanded for more offsite jurisdiction resource. commitment (porhaps to the f cxtent of requiring more support from outside sources) and specifically address evacuation procedures.

County Response:

. The County of Sacramento Concurs with the FEMA Evaluator's Comments regarding items 1 & 2 above. The County further agrecs that the extent of play for the Radiological Monitoring Ficld Sampling teams should be expanded as should the UDAC activities.

The Emergency operations Division will recommend expansion of these two . areas to the County scenario development team member during the next large scale exercise preparation.

1 e

  • I I

'l

. 1

+

2 Exercisc Dctail - page 10 - Sacramento County FD'A Corcent 's a

Sacramento County Emercency Operations Center (ECC) The EOC*fer Sacramento County is a new facility that takes advantage of the space in a way that is conducive to a gcod operations environment. The noise factor is controlled because the individual service chiefs have separate officec. A public address systen is utilized to provide plant status, when appropriate, so that they are free to carry cut their assigned duties. Eriefings are held in the room where the status bcards are posted. These briofings are conducted en a regular basis. Status boards are not always up-to-date and maps were not oosted.

There should be consideration given to improved status board maintenance and larger maps.

County Response: ,

The County of Sacramento disagrees with the statement, " Status beards are not j always up-to-date and nans were not posted. There should be consideration given to inproved status board maintenance and larger naps.". These boards j scrve as the primary information source for EOC staff. The use of maps for most of the EOC staff is not a requirement, nor is it necessary. For those such as the Transportation Officer and public works personnel who do need maps, individual sets are located in their respective officos and serve those personnel well. Therefore it is not our intention to change the nothod of posting maps in the EOC at this time.

4-e i

i e

i t

- _. , , .. n. .- - . , . . . , - . . , ,.

. .s I

l Exercise Detail page 10 continued - Sacramento County

- TEMA' Comment:

The media facility had little or no activity. Activation was timely and staffing was provided. Rumor control appeared to be handled satisfactorily County Respensc:

'The County concurs with this comment. The media facility located at the EOC could probably be expected to have little activity if the Emergency news Center (ENC) functions as it is intended to.

FEMA Comments:

At the time the Emergency Operations Coordinator for Sacramento County went to the EOF at the General Emergency, some confusion 'took place in regard to the transfer of decision-making authority. This area should be investigated for impreved procedures.

C'ounty Response:

Che County of Sacramento disagrees . with this statement. Prior to the Emergency Operations Coordinator leaving for the EOF, a briefing for all service chiefs was begun in the briefing room, almost simultaneously the Coordinator was advised the emergency had escalated to a General Emergency classification. The Coordinator announced to the Service Chiefs that she must leave immediately due to the General Emergency and that Ron Hines would assume the duties of the Emergency operations Officer in the EOC. Mr. Hines has functioned as the Emergency Operations Officer in the-past, and there was a smooth transition in the transfer of authority. - We discussed this iesce with Mr. Hines, the service Chiefs and other EOC staff and all said they were confident that the transfer. of authority was smooth. The confusion may have occurred with the EOC FEMA Evaluator if he was not in the briefing room during the time of these announcements.

O l

I e

. s Excrcirc Detail - page 11 - Sacramento County FEMA Finding:

The mobilization of the Radiological Field Monitoring Team appeared satisfactory. There were a few problems. The monitor's telephone listing was out-of-date (3/1/82). The team was familiar with their equipment and the routes. A particular vehicle is not assigned for the team. For the exercise they had been provided a County van that had only a half tank of gas. During a real event it could be difficult to find a service station or have the time to make provisions for fuel. Consideration should be given to providing an all weather vehicle for this. function. Overall, the team ' members interacted well and used good judgn.cnt. They demonstrated the prcper techniques and were aware they should check their dosimeters at recular intervals and when to leave the rilune area. They were in constant radio contact with the FCP.

County Response:

The telephone mobilization listing was updated as of 1-20-84. An out of date list was inadvertently inserted into one RADMON kit and that list was removed.

Sacramento County Environmental Health has 2 vans assigned. Both vans are assigned to Radiological work as well as Haz Mat, Water, Sewage and many other Environmental Health programs. These vehicles are alwavs used for Radiological Ecsponse. If more vehicles are needed they come from the pool.

Vehicles are parked within a block of the gas pumps. It-is the drivers responsibility to determine if there is enoagh fuel available for the ' days activities. If these vehicles are used for extended response (i.e. days) the

County has the capability (through the TRANS SERVICE CHIEF) to respond with a tanker of fuel. Just exercising with a full tank does not prove that we could provide an extended response. We think FEMA's findings did not take into consideration the County's ability to respond for extended periods, nor for providing service and maintenance in the field.

. . t Exercine Findines Matrix - Sacramento County - page 1

- FD;A Finding:

The planned alert and notification system for the County failed to meet the criteria of ::U2EG-0654 'during the exercise. While there was an established procedure for alerting, notifying, and mobilizing emergency response personnel, the escalation of the classification level from Alert directly to General Exercency resulted in a breakdown of the planned system. Key personnel who would have been mobilized at the Site Area classification level

-(who wcre put on standby at the Alert IcVel) were not contacted at the time the General En.crgency was declared. The plan, standard operating procedure, and or checklist should repeat the actions to be take at the lover classification level within the next higher classification level as further assurance that those activities have been accomplished or that they are still required.

  • County Response:

Sacramento County disagrees that the notiff.catien system failed to meet the criteria of EUREG-0654 during the exercise. The escalation fhr the classification level from Alert to General Emergency went smooth and according to the plan. In reviewing our Personnel Activation List, it is clear that these contacts were made promptly (see attached Activation lists).!

The Standard Operating Procedures and checklists do repeat the actions to be

- taken, and did so during the exercise, at the lower classification within the next higher classification level.

4 e

1 2 .

  1. e i

, w -

,e , - - , + -, .n,-,

l e .' .

.y

  • PART IV - OPl.RAllNG DATA M.Wuat - S ACR.W9 i0 CtNi f EXHISli 2.2-1 'PER50*iNEESTCTWA'It0N*L-MT-Notification of personnel will be handled by the County Cc.rnunicittons Center untti the E0C is operational. Notify one individual in each position in accordance with the response indicated under the type incident.

l The following terminolo9y will be used for initial nottittation of the listed l personnel: l l

Select the appropriate phrase in ( ).

'THIS IS THE SACRAMENTO (County Conrunications Center or E.ere;ency Operations Center) ThERE HAS BEEN AN INCICENT AT THE RANC.40 5EC0 SUCLEAR POWER PLANT. THE INCIDENT IS CLAS5IFIED AS (Unusual Event. \lert. Site Emergency, or General Emergency)."

"YOU ARE REQUESTED T0:* 1

a. "(REPORT IMME0lATELY TO THE (EOC at 3234 Ramos Circ _le Ro.id or EOF at 15324 - 61st Street). A001T10NAL INFORMAT10H AND INSTRUCT LON 'allt 3E PROVIDED AT THE FACILITY.)"

or

b. "(PLEASE RENAIN GN STANDBY UNill FURTHER ADVISED)."

Date/ Time In\ttated _

_. 0 % / M %Fb By _L.Yns.nn. A hottsf/eh

.)oArytc bee %)

i I i l POSITION / l HORK PH. l RADIO l RESPONSE I CONTACT I HOME PH. I.2AGER l Time Contacted ICOMMENTS (notify only one l l'" lIA l 13 4l$ l contact per position) l l Igg i l' 4 IV l l -

1 15 I I f ly I I i 1171o i Alj I i

l i. l~ lt 1 I It 1 1- 1 I I I I

~

1 l l 1 l l I A. Emer. Ons. Cocrdinator I I IStty lE0C IEOF IEOF I .

l 366-2707 l 279 l l@ql IANl Carole Hopwood i 400-1868 I P- l

  • E6538

, 1 366-2107 l ygy l l l l -!

John Anderson i. 1-667-9546*l l I I I i l 366-2116 l l l l l l

. Ron Hines l 969-3006 l 1 1 I I i 1 w2n i l i l i l i eur-esto i asi l I l I  !

l ADDITIONAL ItsTRUCilots: 11 necessary, adviso listed n=rsonnel of escalation.

m.

h#50 4 g, . 9

, + - . -

.. l l

PARI IV - OPERATING DATA MANUAL - SACRAMENIO CCut:TY ExHIBil 2.2-1 PERS0tlNEL ACllVAll0N LIST (Cont.)

I I I i

WORK PH. I RADIO I RESPONSE I P051110N/ 1 I HOME PH. I PAGER'l Time Contacted 1 COMMENTS CONTACT I I I e I yi 15 A ls t I I

I I

I i

i

( l19 I<rIl41$'*l

'4 e lg l I* l ^ li!

l l

l l lj16 f l h l IN I I I I I I I I ly i I I I I i I I 1 1 I I I I l

i i IStbyl EOFI EOFI B. Emer. Ops. O'. rector 1 l 440-5878 l 905 l i /# ll Ql U dl

! 969-6372 l I ,,

@BrianRichter 440-5883 i i l i i I 1  !

442-9252 l I I I I i i

@ H1111am Freerran l 440-5886 l l l 1 I l 967-625a l l I  ! I 1

@ Gary Cassady I m-2m I i i i i I en i w-tsco _t251 1 ( i i i (D M h l W i l i I I i i l~

I  ! I-ECCI EOC,{ EOCI C. Sheriff I P7sl I i l i i Watch Corxnander 1 550 Hotline i 1 880' ImnI 440-5092 I l 1 I l l l

428-011781  ! I I l Robbie Waters i 1 l 440-5094 i i I l l l 929-6146 l l I I I i Dee Reynolds I 1 .

I i i l i i i 440-5308 i I' I l 1 l Braxton Bonner 1 I I I I i i I-I L $ I i 1 I I I l- 1 I

- 1 l -

! l_ _ l EOCl ECCL EOCl

0. E00 Dor Officer _ pent I 365-an o i I 5 i .

I 969-300 Ll_260 9 M ail. it.nI

' Ifon Hines '

l 1 366-2114 l .8 l l [

i Gary Mahan ~7 2f- 413% I -.SS^ 07" 8 I _4_ I 3 l 366-2107 i i i l I i l -

312 1300 t i l i f i Bill Tubbs

- I m no 1 i l I i I l h6.peu t i- wf4S% i 259 I I e I i _

l e un)gsted Hin.bor  ;

I .

- j

. - -i.  :. .. . .. .. . .

l '

- \ \

..- f

, . . , ,.. - . ,. g ...,S--

~ . . .

paris.IV - OPERAllNG DA1 A MANUAL SACRAMf.NTO COUNTY Exhiblt h2-1 PERSONNEL ACTIVATION LIST (Cent.)

I I I I

l WOR!! PH. I RA010 i RESPONSE l FOS 1110H/

C0!!iACT L N0'EA PH. I PAGER I Time Contacted ICCMMENTS I I lu. p gjg 13 4 [g i l i lyyIo le a11 1 I I Is ,1 6 IT eil 1 I

4 8d 1 1 1

IS r l 5% .1!

1 I l'a i i I i l 'l 1 1 di l i i 1 i 1 31 I I I I i l i E. Public dnfo. Officer 1 I I i ECCI EOCl EOCl I ' 440-5883 l l iW/3l F953l William Freerv.n 1 442-9252 I I tc > rA t /c A I l 440-1764 l l l l l l 446-5559*l i I I l l Crato Smith I l 366-2191 l l l l l l Emil DeJan l 966-3923*l i i I l l I I I I I I I I I I I i I i tVa kehne cev4 [ l l [ecFl l l F. -. I I I I . 'l EOFI EOFI i 366-2095 I l icfWI les3l Ken Knight I 929 4056 1 1 I I k RI I 366-2109 1 191 l 1 l 1 i i 363-0595 l I I I  ! 1 Bob xntaht l 366-2131 I l i i l i i 451-2519 1 I I I I Frank Jores 1 i

I . I i i i i I I I I I 1 I i l i i l i i l i I I I 1 8 i i l~ l i. I I I t 15thyl E0C1 ECCL S. tidalth Officer I

-) 366-2181 1 219 39?-7925 I l-I lVr5 l (W.5 N I

I I

l Pa's1 Here 1

~ '

.$ 360-2191 6 i l l l AN -l ~

  • Emit DoJatt  ! 965-39?3 tr i /133109J11 9T)f l 366-2111 l l l l l l Walter schauer . I 66.2 402G I I t i I f I l i l 1 1 I I

L 4 1 1 1 I

1 I I l I i 1 1 5 1 I I I I l .. '

~ c.d.*.LNisledIN2ber . .

i Exed: S13-IA

~

' 2.? ? , hqo ?,

. ~ . . , _ ._ _

PARI IV - OPERAllNG DAT A MANUAt. - SACRAME!!TO COUNTY Exhibit 2.2-1 PERSONNEL ACTIVATIO:: LIST (Cont.)

I I I I RESPONSE I l WORK PH. I RADIO I ICOMMENTS POSITION / I PAGER l Time Contacted l HOME PH.

CONTACT I I ItA gi is A I id gi 4. I I

- 1 la g I i{s l ( l I

I 1

I lu8 r17 1I 4Ilu di fl i I i 1' l I .Ii i l $i I I I i i I I

i i i i i I I i IStbyl EOCl ECCI f I 1 H. Fire Service Chief I I I i Icg.gl I .

I Wm fi -

1 l Sac. Fire Dept. I SFO Hotline i l l 449 5266 I I. ] l l  ! I I I I 442-2356 l 1 William Powell '

l 'l 1 i 1 KEN N L- l 441 S&Sh ,

i I i 1 1 1 %/- 7304 + 1 I I I I 1 I 1 I I I I I I I i

! l' - I l i l

' I i i l I i 1 1

l 1 l I i I l I I istbyl EOCl EOCl

.I l I. General Services 440-6462 l -l l l 1 l' ] 1 ppa? I 1/W2l I 383-7531 1 l Mike Silvey I l l l l

l 366-2111 l 907 I I i i _

l Jerry Saulter 1 957-1880 l 259 ! l 366-2111 l l l l l l

' i 1 l I I I 1 677 4611 1 Ilike Ocberd . I i  ! i l l' I

- 1 I I O I i 1 I i 1

I I l 1-1 I 1 IStb11 E0tl ECCt

2. Pubite thrks i ) 8 l 0

[

I 440-6581 8 9661005 t I lFAR) IMd! __

  • Dee Netenate - l l l (E r4

. : , ' * [' ' ' 440-5966 428 0589 lI L I J lD5'll oc - b ih C

'.. l. i

- . 31n Ras 440-6501 l 8 l l l'

' " l I I t I  ! _

I 363-0195 I i Doue Fraletof> .

l l l l l I I  ! l .P  ! _

I I I I t t 1 0.

  • I. I I I 'I I 1

I .

.. - l

. . ',- ! A.  : .~ .

q

- a .:4.--- . . . . .

4 r.. ,

. _, D9 a') D$CO'll M U-Oh .

SACRAMENTO C0tftiTY PAR 1 IV - OPERAllNG DAT A mal 4UAL l

Exhthtt 2.2-1 PERSONNEL ACitvAT10ft LIST (Cont.)

I I i I

WORK PH. I RADIC l RESPONSE I POSIT 10N/ l 1 HOME PH. I PAGER.) T1rne Contacted ICOMMENTS CONTACT I I Its a l [5 A ld l I I l( y I l' A l.13 .I I la o l- 1 e Fi l I

I I li f i k i[ d ij i i 16 1. I I i i Ig i i l i i 3 1

I I I I I I I I i 1 i l i I IStbyl EOCl EOC!

I I K. Red Cross  !

452-6541 l l l

)

Barbara Surns I 922 1852 l I lIB/AI l/C##lI 452-6541 I i l l l l

Nancy Vickers i 456-1451 l I lIF/// I I i 452-6541 l l l l l 1

James McColm 1 362-7732 1 1 l49591 I i ~

452-6541 l l l l 1

~

l 1 I i I 929-8733 1 l l 1 _,

Randy May I I I I i l I

I I i i l I i

i i i i i I I IStbyl EOCl EOCl i I I L. Wolfare i i i I I I I i s.' -3 I I I I I 1 T n 1 440-1100 I i i [ l l i  ! I f OPenneClark i 1-758-0421 i 1

  • l $  ! i !cD! !wx!

[]A r4 $0SS-e m w-  ! a:X'41_ l l

!!l i i i l

i l

Adhintstrattve (1f ficer i I _t IS(:h'r! ECCL _EOCl ,

R. -

1 440-5886 8 .. f. 6 $ l 1 l- 967 6342 I _t E 4  ! 'I _

Gary casrady.

  • .' 440-5633 8 8 l l $,I

-  : ,-r

l. 1 1

/- ,

I 961-70 % *l 1 -5 8 _

'!J  ?. ? George 11111er l Sur 1&v<

l l l l b. l

  • P93 hic'%M2 l 440-M i i fl3>  ?

' . Ia fin rv fatva J!

I I i i I . Ibssiw 1

r i_ l_ _i i i  % nom I I I s I l . Im an .

r
. .

i I. Idoc

~ '

i I ,

.t R

; . , . . . ' .i .

5%v5 tat.eaunr:.:..(ll. .. .

q

4.;.,1, .

..-~..~~

S ACRA.".ENTO COUN1Y

(~

' P AR1 IV - OPERA 11NG DAT A MANUAt. s.

Exhibit 2.2-1 PERSONNEL ACT1 VAT 10N LIST (cont.) ,

~

RESIONs3 RADIO' 00&IX

_ FJRK FH. TIFE CONTACTII PAGER POSITION / HOME PR.

CONTACT ,

I g

1 as -

as .

E* 54 1o 24 .

j -

EOF EOF

, IDF

- c/cey 4e UDAC Eanager 4 53 ,u N. 36o-ziot , Mpg w ",.% .m 1-677-96h6  !

prgoF John G. Anderson 366-2108 l__

l _

Art Seipel 736-9383* _ _l f

I h27-h3oo ,

I j  !

Orrin Orr , .

I ---

EOF EOF EOF -

O.

?.ad. Monitoring Co=unict; tor '

366-2000 og3, M32

~

332-9288 Bill Driver 366-2000 _

j h81-h132 Rrnetto Doerflein f

  1. -2000 ,

Jim Campbeu 381 8932 i

~

J

. I 4

. __. -- I _ _- . -

Y e

  • 1 .

-L ,

e e @

PART IV - OPERAllNG DATA MANUAL - SACRAMENTO COUNTY Exhibit 1.1-1 EOC SUPPORT-STAFF-AC44 VAT 10N<b1SL (Cont.)

POSITION / WORK PH. RADIO TIME CONTACT H0ttE PH. PAGER CONTACT ARRIVE ASSIGNMENT

a. Communications Of ficer (1) 366-2706 896 7t? '

Ron Allison 422-2654 (99P/5F COC 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 Ghilarducci 421-4836 W WMCAD/E 440-5722 487 S W Cy / #F O9 Robert Ladner 988-4643* o 9;-c, / /c> i tr 440-5722 - 489 Robert Carboni 445-5739
c. Msq. Cntr. Supervisor (1) 366-2111 Patt Adach) 966-0904 366-2914 Joanne-Bewev - 391-5982 366-2914 4C) C Lynette Doerflein 481-4132 cyQ isP

~

d. Purchasing Agent (1) -

366-2034 W nhoy /EN Andrew Reshke 421-8180 CF72 G / fc> f E5 ,

\

366-2030 /

  • Jack Hehl -

383-3420 366-2035 Ray iharaldson 489-8282

  • Unlisted Number

. i ,

l 1.1-1, Page 2 ~

Issued: 7-13-34

PART IV - Ol'ERATING DATP, MANUAL. - SACRAMENTO COUNTY l

(

Exhibit 1.1-1 EOC SUPPORT STAFF ACTIVA 110% LIST (Cont.)

WORK PH. RADIO TIME POSil10N/

110ME PH. PAGER CONTACT ARRIVE ASSIGNMENT i CONTACT

! e. EOC Clerk (2) ,

i

! Roberta Johnson 366-2111 366-2707 CN l

Mary Ann Bennett 967-2038 W/G, l

366-2111

,Patt Adach) 966-0904 -

366-2111 .

Kim 11alker 988 4223

f. Situation Intelligence Officer (1) 366-2111 Spencer Bole 488-8824 366-2111 goc .

988-9434 09,3/

. Louise Lockhart Don Yee 922-3885

9. Radio Operator (2) -

366-2914 Bill Driver 332-9288 366-2914 .

Jim Camobell 381-8932

' 366-2914 (E O C Cory Jac.eson 366-3312 097.3

  • linlisted Number s

1.1-1, Pt.9e 3 issued: 8-13-84

i . .-

PART IV - OPERATING DATA MANUAL - SACRAMENTO COUNTY Exhibit 1.1-1 EOC SUPPORT STAFF ACTIVATION LIST (Cont.)

POSITION / WORK PH. RADIO TIME CONTACT HOME PH. PAGER CONTACT ARRIVE ASSIGNMENT l

~h. Message Center Operators (1) 366-2707 N * *# / EOC Hary Ann Bennett 967-2038 092 R / fofo

~ '

366-2116 Nancy Lane 685-4640* -

366-2111 '

Kim Walker 988 4223

1. RACES Coordinator (1) 452-5056 ST/k'b "W / /E O C Keith Crandall 381-51 57 093 9 / /o;p /

Robert Cloud 961-8407

  • 366-2107 ,

Gary Wann 972-0232 i *

  • Unlisted Number -

e e e e

( .

  • .-l'.-A NL;Ilt FMim M,.f n gttGl.;rit; y A Gle.,ts.a.ti:[JGK.4,t:; .,

1)ispatche r L4j fg a 7-ry fyngfpj,g!)ateggg

. T iin ,. -~

(

  • At tions U inea u.i t ,n t e I r',ve* nt Alert l /. re a Ge

- Par

1. Log information on FORM A or FORM B of the OSQf O /O "NOTIFIC ATION FOR M. " o7
2. Dispatch Fire, Ambulance. Law, etc. if offsite N/

3upport is requested by Rancho Seco f) / h 71 / 8 i

d (Galt Fire 209-745-3022 or Blue Net 1 44 A9 0" W * *

  • f Contact Senior Dispatcher for additional CCTR 3.

3taffing (392-4893). OS (/S 09/O ic(

c.c i

4. Complete the " PERSONNEL ACTIVATION LIST." 08t/(, 09.33 lic N/A Clos e Evac. 'l
5. If Rancho Seco Pa rk Closure or Evacuation is ]

indicated or directed, contact Control 22 (2072)

CvM -

(if ope rational) or: Goldwyn schroeder 988-6272 g$ I Cary Knut11s 486-711'1 [

Thom Oliver 685-6342 pc939 p @nor 1N.>

Advise them of the emergency classification and rs tuM -@

O W C) request Rancho Seco Park Closure or Evacuation.

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

/

following of the potential that they may be handling J contaminated oatients: r

a. Oult tire inue riot 1-4489 or 209-745-3022
b. Elk Grove Fire Control Firo hotline
c. !.!D!B Sac / Hill hotline Suttor Gonoral Hospital 454-2223
d. 4S3-3020 3

'dethodist Hospital c.

laorican River Hospital 486-3211 [

f. 3 A

v Notify the Health Officer of any emergency medical- ! N/A I 7.

responso associated with the Rancho Seco Emergency '

. j ,

(D1h3 at ECC).

When directed by the EmergencyCoordinator N/A

8. EBS ,

i orcDosignated Official, call the EBS station, 'l 924-3222 (KF3K). Advice them that an EBS broadcast may be required as the result of an j incident at the Rancho Seco Power Flant and that o they will be called if an EBS broadcast.la reqGred, k (EBS folder at Console c ) '

I i r Whedirected, initiato Siren Activationprocedurce.N/A.

l ll - e i

  • . y (ib:t'r.uctions'at Console .c ) '

k, 4, __

i

l.= ',* - R ANClio .'h;CO EX.f MitGKNC Y ACTI'sN.'; -_f . Ci.MC R f .IST -

3.,.,

ilate s fi g g y 1)lnpatche ry,m.,-re Mercia .

, Time ~---

Actions s} o m.s...a Sve nt Alert 3,tc A rita Ge ne r.1

10. Additional Notifications:
a. If directed, complete "OTHER AGENCY _

N/A g - lO N. -

NOTIFICATION LIST." Advise the EOC Ops.

Officer at 2707/2114 when list complete,

b. If directed, complete "EOC SUPPORT STAFF N/A ACTIVATION LIST." Advise the EOC Ops. og p 9 lO kc Officer at 2707/2114 when list is complete.
11. Initiate an " EMERGENCY OPERATIONS ACTION

.iND MESS AGE LOG _" and update. i, l

l l

i

! i

)

r 1 L

1 L 1 I  !!

i l 1 ' l

,,' l

, l I

, } ,

g -

1 l

.k -:-.  :: - p. il, .'

)

I f

I

' l l g I;, p e

Y -

+

J.

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

During the exercise the Sacramento County Energency 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 message 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 ECC is the EBS 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 copics of the prescripted EBS messages available to its operation personnel.

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

The sacramento Emergency Broadcast Station (EBS) system needs censiderable training and coordination between the counties and the radio station KFBK. At the present time, the EBS 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:

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, KFEK.

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 St$ tion did comply with this request. 'EOC staff confirmed that the message was broadcast at the appropriate time.

Exercise Findinos Matrix - Sacramento County - page 1-2 continued The 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 concerncd parties, including FEMA, are ongoing .

The County agrees that further training and coordination between the county and the radio stations is necessary. Toward that goal there have b'een several rectings between County staff and the radio stations. fella is providing money

' to KFBK to supply a 2-way radio link between the County and KFSK as an alternato n.cthod to land line communications.

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

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

9 e

S O

j e l

i d ,

i

Q -

e Exercise Findincs Matrix - Sacramento County - page 2-3 FEMA Finding:

Ability to identify and check individuals who may have been centaminated during an evacuation was not satisfactorily demonstrated. According to the operating procedures manual for Sacramento County traffic control . points in centaminated areas should have . areas for decontamination and stcrage of contaminated 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 function 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. The coordinator in the Field Command Post did not knew where the decentamination 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 vehi.cles 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 'o they have the nor d i 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 sherif f's Department representative, and he does know that the decontamination points are the traffic access control points and vhere they are located.

T

+

e 9

,, , -, .,- .o..- .

a .

,1 .

Exercise Findinc Matrix - Sacramento County -

page 3

. ' FEMA Finding:

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

County Response:

Field Monitoring Team Kits are not required by, NUREG 0654, to carry this equipment. . Radiolcgical Monitoring teams are removed from the field at 100

pr/hr. If I-131 is released (as per UDAC), field teams will be removed to Field Cencand 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 var 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 sample.

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.

e O

g e - n vu~

> +

8, . .

3 . *

.e .

Exercise Findinc . Matrix - Sacramento County -

page 3 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 cenditions. The monitoring teams should be assigned at least a week per year to field conditions training using the appropricte eouipments.

County Response: -

This is a subjective statement not documented by field observation, nadiological 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 Countv in this exercise, there were peripheral activities that 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 response activities by virtue of geography, but without benefit of planned assignment. 1.s 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 respcnd to radiological emergency response activities indirectly affecting 1 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. HUREG C654 page 11 " Planning Basis" delineates 10 mile radius for EPZ. Ingestion 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; i

l l

5.0 b EXERCISE FINDINGS MATRIX * -  ?

JURISDICTION San Joaquin County ,

CATEGORY B PACE 1 FINDING NUREC-0654 CORRECTIVE ACTION DATES REFERENCE Proj /Actu:i t

1. The planned alert and notification. system for th3 County failed to meet the criteria of NUREG-0654 San Joaqutn County disagrees wtth 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 Em:rgency resulted in a breakdown of the planned -

system. Key personnel who would have been mobilized i 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 nextLhigher classi-

~

fication level as further assurance that those ac-

. tivities have been accomplished or that they are E.2 Istill required. H.4

.N0TE: .The utility, state and counties are cur-

! rently compiling a description submittal of their

.i entire alert and notification system in accord with

!,the requirements contained in the " Standard Guide for_ the - Evaluation of Alert and Notification .

i Systems for Nuclear. Power. Plants,' FEMA-43" to quali-f fy the system against the criteria of NUREG-0654-

. f 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 current. systems improvement requirements. ,

, , p.

- 2. There was little to no coordination of media,. -

rumor control, EBS,:or protective actions imple- San Joaquin. County dtsagrees with the evalua- ..',5 .

i tion ftndings Tri-County discusstons and

.wantation with the-utility,-state, or other counties ,!

itemonstrated during the. exercise. G.4.b implementation of dectded upon actions will 5 correct, 9/85 ,

4

5.0 .b -

  • .a.'.
  • EXERCISE FINDINGS MATRIX *. , ,~ .

JURISDICTION San Joaquin County -

CATECORY B PACE 2 FINDINC NUREC-0654 CORRECTIVE ACTION REFERENCE DATES

13. Proj/ Actual.

Due to the scope of the exercise and evacuation theing a part of the scenario for Amador County-in San Joaquin County disagrees with evaluation

'this exercise, there were peripheral act.ivities that finding, See details in attachment.

were noted by exercise observers. One .tch item was the lack of consideration being given to the cities

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

~

lwithout 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

. op: rations, .with State support. Evacuation imple-

.nent.ation and/orf public information mechanisms

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

' to respond to radiological emergency. respon,se ac.) A.2.a.

t tivities indirectly affecting their jurisdiction. A.2.b.

(et the cities'are neither tasked by the plan nor F.1.

' a part of the connunications. system. This applies F.6 to all county plans that impact on city government.

f.,

+

..I .

s .

l

..]' . , )

?! .

kg COUNTY OF SAN JOAQUIN 7fi\ bf Jhh OFFICE OF EMERGENCY SERVICES nowato n. natow,u co*"a^toa

.i. noo 4oi. cou n.ou.c

.nu ng -,,,,~~n-a sToCKTON, C ALIFORNIA 95202 iQY TELEP*eonse209)944 2999 February 5, 1985 M . Orrin E. Orr, Chief Radiological &crgency Preparedness .

Office of Emergency Services Post Office Dox 9577 Sacra:nento, Califomia 95323

Dear Orrin,

We would like the following co ments incorporhted into the reply to the Federal Dergency etinagesent Agency Critique of the 1984 Rancho Seco lhercise. 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 en the matrix coments, I have also

~ includcd some cmments on the narrative portion. ,

E)GRCISE FINDINGS MATRIX - SAN JOAQUIN COUNIY FINDING 1 - We deny the implication that key people were not notified.

All required personnel were notified, however, there were recre problems than there should have been. We intend to revise the procedures 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 B ergency Broadcast System and Protective Action ccordination, the situation was satisfactory after same initial problems.

FINDING 3 - According to plan procedures, all city police departments are notified by the Sheriff's Department at the Alert Leval. Knowledge of local goverment processes would reveal that a key function of the Chairnan of the Board of Supervisors is to coordinate with other poli-  ;

tical leaders and jurisdictions of the County.

J

, . - p

o ....I'*.

. t. . . .

Mr. Orrin E. Orr February 5, 1985 Page 'I%o FD4A CRITIQUE OF 'IEE 1984 IWNCHO SWO EXERCISE OIMFR CGNENTS 4.0 EXERCISE DETAIL - NARRATIVE

1. EOF - Page 7 - Next to Last Paragraph

/ Protective Action recmmendations and instructions issued by San Joaquin County were sent to the Sacramento Municipal e Utility District Public Information facsimile operator as planned. Our feeling is that the Sacramento Municipal Utility District needs to revise the Bergency News Center ard Public Information Officer procedures at their end. They have not provided persons to serve as PIO clerks at the EC and the system of having PIO messages arrive at the E F instead of the ENC is bound to lead to confusion.

2. San Joaquin County EC - Page 11 of D:ercise Detail
We did receive timely information frcm our liaison at the ,

EOF and frcxn the Control Room and Technical Support Center.

All information on ECF status boards and frcm 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 ceuments 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 submitted 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 Bergency Managernent Agency officials, have any questions, please feel free to'calle .

in rely, ,

) \.V #

Ronald E. Baldwin, Coordinator

- Bnergency Sdrvices REB /hld c: Carol Hopcod, Sacramento County Sean Crov.tler, Anndor County ,

e Rob Meyers, SMUD

N ,' ,

.t .

STATE OF CAufoRNIA GEORGE DEUKMEJtAN , Governor OFFICE OF EMERGENCY SERVICES POST OFFICE box 9577 SACRAMENTO, CAllfoRNIA 95823 (916) 427-4990 427-4013 February 19, 1985 Sue Elkins FEMA Region IX Bldg. 105 1 Presidio of San Francisco, CA 94129

Dear Sue:

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,

% ,M ANN C. VASQUEZ, Chief Radiological Emergency Preparedness 4

Enes.

e .

A7.  :'

A j:o . . ,. . . i.: a

.. I ...6 . ... .,  :.,

. - + * '16 (* it '; *

, .. . ,o. -

- - - - - + - - "~* '-" ' -

,-' y, STATE OF CAtlFORNIA GEORGE DEUKMEJIAN , Governor OFFICE OF EMERGENCY SERVICES POST OFFICE SOX 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. recent 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.

4 Sincergly, .

/.I l

-f $7//&( . J 1/I LIAM M. MEDIC ICH j Director

/& ' $V a:8C cha , 64 T/t Al. c?. '

.m.

Retrieved from "https://kanterella.com/w/index.php?title=ML20206T257&oldid=3053549"