ML20207H354

Forwards FEMA Radiological Emergency Preparedness Exercise Rept of 880805 Exercise.Deficiencies Noted

ML20207H354
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/17/1988
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
References
NUDOCS 8808250329
Download: ML20207H354 (2)

Text

o; AUG17ll3 In Reply Refer To:

Docket:

50-267 Public ' evice Company of Colorado ATTH:

Robert 0; Williams, Jr.

Vic.e President, Nuclear Operations 2420 W. 26th Avenue, Suite 15e Denver, Colorado 80211 Gentlemen:

Attached is a copy of the Federal Emergency Management Agency's (FEMA) exercise evaluation report of the August 5, 1988, emergency preparedness exercise.

The report indicates that FEMA observed two deficiencies requiring remedial drills.

If you have ary further questions, please contact Mr. Nemen M. Tere at (817) 860-8129.

Sincerely, Cn;;&l Q: led By.-

A.C. BEACH L. J. Callan, Director Division of Reactor Projects

Attachment:

As stated cc w/o attachment:

Dr. M.L. Olson, Regional Director FEMA Region VIII Denver Federal Center Bldg. 710 Box 25267 Denver, Colorado 80225-0267 cc w/ attachment:

Fort St. Vrain Nuclear Station Manager, Nut:1 ear Production Division 16805 WCR 19 Platteville, Colorado 80651 0:hN RIV PS C:

C:RPB C:DRP/B AI 88-244 NMTe cd RJ tt BM ray TWesterman LJCallan 8/i /88 8/ 6 /88 8

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o Public Service Company of Colorado Fort St. Vrain Nuclear Station P. Tomlinson, Manager, Quality Assurance Division (same address).

Colorado Radiation Control Program Director Colorado-Public-Utt ities Commission bec to DMB (A045) i bec distrib. by RIV w/ report-Resident Inspector Inspector K. Heitner, NRR Project Manager SEPS:RPBFjle RIV File./

bec w/o report:

R. D. Martin R. L. Bangart R. E. Hall B. Murray R. J. Everett SEPS:RPB File Project Engineer DRP/B DRP MIS System C. A. Hackney l

W. D. Travers, NRR l

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CONTENTS FOREWARD...............................................................

v A B B R E VI ATIO N S..........................................................

vi INTRO D U CTIO N AND AUTHO RITY.......................................... vill 1 E X E R C I S E O V E R VI E W...................................................

1 1.1 Ba c kgro u n d.........................................................

1 1.2 Exercise, Medical Drill, and,Remcdial Drills Summary....................

2

1. 3 F e d e r al E v al u a t o rs..................................................

4 1.3.1 Full-Scale Exercise - August 5,1987............................

4 1.3.2 Ingestion Pathway and Laboratory Remedial Drill-N o v e m be r 4, 19 8 7.............................................

5 1.3.3 Public Alerting and Notification Remedial Drill-December 11,1987............................................

5 1.3.4 Medical Drill - September 3 0, 19 8 7.............................

5 1.4 Ex e rcis e O b j e c t iv e s.................................................

6 1.4.1 Full-Scale Exercise -- August 5,19 8 7............................

6 1.4.2 Ingestion Pathway and Laboratory Remedial Drill--

No v e m b e r 4, 19 8 7.............................................

8 1.4.3 Public Alerting and Notification Remedial Drill--

December 11,1987............................................

8 1.4.4 Plume Monitoring Teams - Remedial Drill.......................

9 1.4.5 Medical Drill - September 3 0, 19 8 7.............................

9 1.5 Exercise and Remedial Drill Scenario Timelines and Narrative S u m m ar i e s.........................................................

9 1.5.1 Full-Scale Exercise - August 5,1987.........................

10 1.5.2 Ingestion Pathway and Laboratory Remedial Drill --

No v e m be r 4, 19 8 7............................................. 12 1.5.3 Public Alerting and Notification Remedial Drill-December 11,1987............................................ 14 1.5.4 Medical Drill - September 3 0, 19 8 7............................. 18

1. 6 E v al u a t i o n C r i t e r i a.................................................. 20 2 E X E R C IS E E VA LU ATIO N................................................ 22 2.1 S t a t e O p e r a t i o ns.................................................... 22 2.1.1 StateEOC...................................................

22 2.1.1.1 Full Scale Exercise - August 5,1987.................... 22 2.1.1.2 Public Alerting and Notification - Remedial Drill Results, December 11,1987............................ 29 2.1.2 MediaCenter.................................................

30 2.1.3 Forw ard Co m m and Pos t........................................ 34 2.1.4 Plu m e Monitoring Tea ms....................................... 38

- Full Scale Ex ercise -- August 5,19 8 7.......................... 38

- Plum e Re m edial Drill Status.................................. 43 2.1.5 I ng e s t i o n P he.s e............................................... 43 2.1.5.1 Full-Scale Exercise -- August 5,1987.................... 43

- Ingestion Field Monitoring Teams...................... 43

- Ingestion Sample Labora*.ory.......................... 47 iii

. - ~

. - _ ~. -

o

'a CONTENTS (Cont'd)

I 2.1.5.2 Ingestion Pathway Field Monitoring and Laboratory Remedial Drill Results - November 4,1987.............. 48

- Ingestion Field Monitoring Teams...................... 49

- Ingestion Sample Laboratory.......................... 50 2.2 Weld County Ope rations.............................................. 51

.l 2.2.1 W eld Coun ty EO C............................................. 51 2.2.2 Fort Lupton Middle School Reception / Mass Care.................. 54 2.2.3 Fort Lupton Fire Department Decontsmination Center............. 56 2.3 Medical Drill - September 3 0, 19 8 7..................................., 5 7

)

2.3.1 Weld County Am bulance Service................................ 57 2.3.2 St. Luk e s Hospi t al............................................. 58-3 TRACKING SCHEDULE FOR STATE / LOCAL ACTIONS TO CORRECT DErlCIENCIES AND AREAS REQUIRING CORRECTIVE ACTION............. 61 l

4 EVA LU ATIO N OF O BJ ECTIVES........................................... 87 j

4.1 Summary of FEM A Objectives Remaining to be Met......................

87 4.2 FEM A Objectives Tracking - Fort St. Vrain............................ 87 a

l TABLES

_ i I

1 Remedial Actions for the Fort St. Vrain Nuclear Generating Station Ex ercise and R e m e dial Drills............................................ 62 2 Summary of Objectives Remaining to be Met at the Fort St. Vrain Nuclear G enerating Station...............................................

87 j;

3 FEM A Objectives Tracking Chart - Fort St. Vrain........................... 88 i

e iv

E FOREWARD The design of this report has evolved over several years and has taken into account Federal Emergency Management Agency guidance as well as suggestions from those who have been evaluated at Radiological Emergency Preparedness exercises.

The report organization consists of the Exercise Overview, Exercise Evaluation, Issues Tracking and Objective Evaluations Sections.

The Exercise Overview Section provides a brief synopsis of past exercise (s) and presents an executive summary of the current exercise. Federal evaluators are also included in these section along with the exercise objectives and the exercise scenarlo(s).

The Exercise Evaluation section provides detailed narrative summaries of State and Local offsite emergency response operations. Narrative summaries are organized according to assigned exercise objectives. Following each narrative st,mmary, issues are presented in three categories - Deficiencies, Areas Requiring Corrective Action, and Areas Recommended for improvement.

The issues identified in the exercise evaluation section are tabulated and included in the Issues Tracking section. The issues tracking table includes opportunity for State and local response, dates for issue resolution, and FEMA evaluation to the proposed State and local respon.e. This table provides a mechanism for tracking exercise inues to completion.

The Objective Evaluation section includes a summary of FEMA objectives to be met within the context of the six-year cycle and also provides a comprehensive tracking of the status of FEMA objective for all exercises conducted to date.

V

8 ABBREVIATIONS A&N

- Alert and Notification ANL

- Argonne National Laboratory ARD

- American Red Cross CDH

- Colorado Department of Health CPR

- Center for Planning and Research DODES

- Colorado Division of Disaster Emergency Services I

DOE

- Department of Energy DOH

- Colorado Department of Health DOT

- Department of Transportation EBS

- Emergency Broadcast System i

ECL

- Emergency Classification Level EMS

- Emergency Medical Services EOC

- Emergency Operations Center EOF

- Emergency Operations Facility EPA

- Environmental Protection Agency i

EPZ

- Emergency Planning Zone

(

ERF

- Emergency Response Facility EAB

- Exclusion Area Boundary FDA

- Food and Drug Administration j

FSV

- Fort St. Vrain FOSAVEX - Fort St. Vrain Exercise FCP

- Forward Command Post FEMA

- Federal Emergency Management Agency GE

- General Emergency HHS

- Health and Human Services HP

- Health Physicist

)

INEL

- Idaho Nuclear Engineering Laboratory JIC

- Joint Information Center El

- Potassium lodide LOCA

- Loss-of-Coolant Accident mR/h

- Millirems per hour NOAA

- National Oceanic and Atmospheric Administration NOUE

- Notification of Unusual Event NRC

- Nuclear Regulatory Commission NWS

- National Weather Service vi

4 PAG

- Protective Action Gulde PAR

- Protective Action Recommendation PAS

- Protective Action Section P!O

- Public Information Officer PSC

- Public Service Company (of Colorado)

RAC

- Regional Assistance Committee RADEF

- Radiological Defense RCS

- Reactor Coolant System RDO

- Radiological Defense Officer s

REP

- Radiological Emergency Preparedness SAE

- Site Area Emergency SOP

- Standard Operating Procedure USDA

- United States Department of Agriculture e

0 vii

INTRODUCTION AND AUTHORITY On December 7,

1979, the President directed the Federal Emergency Management Agency (FEMA) to assume lead-role responsibility for all off-site nucler power facility planning and response.

F. **A's immediate basic responsibilities in Fixed Nuclear Facility Radiological Emergency Response Planning include

~

Taking the lead in off-site emergency response planning an,d in the review and evaluation of state and local government emergency plans, ensuring that the plans meet the Federal criterla set forth in o

NUREG-0654, FEMA REP-1, Rev.1 (November 1980).

Determining whether the state and local emergency response plans can be implemented on the basis of observation and evaluation of an exercise conducted by the appropriate emergency response jurisdictions.

Coordinating the activities of volunteer organizations and other involved Federal agencies.

- U.S. Department of Commerce (DOC)

- U.S. Nuclear Regulatory Commission (NRC)

- U.S. Environmental Protection Agency (EPA) l

- U.S. Department of Energy (DOE)

- U.S. Department of Health and Human Services (HHS)

- U.S. Department of Transportation (DOT)

- U.S. Department of Agriculture (USDA)

- U.S. Food and Drug Administration (FDA)

- U.S. Department of the Interior (DO!)

Representatives of these agencies listed above serve as members of the Regional Assistance Committee (RAC), whleh is chaired by FEMA.

viii

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1 EU'RCISE OVERVIEW 1.1 BACEGROUND A radiological emergency preparedness exercise was conducted on August 5,1987 for the Fort St. Vrain Nuclear Generating Station. The exercise was evaluated by FEMA. The August 5 exercise completed the six-year cycle for exercising the 35 FEMA objectives.

A pre-exercise session was held on August 3,1987 to provide an overview of the Colorado Radiological Emergency Response Plan concept of operations. This briefing was provided by representatives of the State of Colorado and Public Service Company of Colorado. Federal evaluator meetings were also held prior to the exercise on August 4, 1987 to review exercise objectives, the exercise scenario and coordinate logistical arrangements. The plume and Ingestion phases of the exercise were conducted between C100-1600 on August S.

Following the exercise on August 6,1987, a FEMA federal evaluators' meeting was held to prepare a preliminary evaluation of the exercise. These preliminary findings were presented to the exercise players in the afternoon at Fort St.

Vr31L Visitors Center at the plant site. A public critique was also held at 5:00 p.m. at the same location.

Based on the results of the August 5 exercise, two deficiencies were identified.

Three remedial drills were proposed to correct the deficiancies. The first remedial was conducted on November 4,1987 and included redemonstration of the state Ingestion field monitoring teams and the state ingestion sample lab procedures. A remedial drill to i

redemonstrate the ability to alert the public within the 5-mile EPZ within 15 minutes was held on December 11, 1987. A remedial drill to redemonstrate procedures for the plume monitoring has not been scheduled pending availab!!!ty of state field team communications equipment. The results of this remedial drill will be documented in an addendum to this report.

Section 2 of this document provides narratives, deficiencies, areas requiring corrective action, and areas recommended for improvement for each of the jurisdictions and field activities tested in the exercise. Section 3 provides a summary listing of Deficiencies that would lead to a negative finding and Areas Requiring Corrective Action, including those needing priority attention. ihls summary is in tabular format and provides space for state and local jurisdiction responses and schedule for corrective actions.

Section 4 compiles in tabular format, all FEMA Objectives met or yet to be achieved, developed from NUREG-0654, as well as a summary table of those FEMA objectives whleh have not been satisfactorily met or tested to date over the course of all Fort St. Vrain exercises evaluated by FEMA.

The findings presented in the report were reviewed by the RAC Chairman of FEMA Region VI, who served as the Interim RAC Chairman of FEMA Region VI!! for this exercise and the remedial drills. FEMA suggests that state and local jurisdictions take remedial actions in response to each of the problems Indicated in the report and that the

2 state submit a schedule for addressing those problems. The Regional Director of FEMA Region Vill is responsible for certifying to the FEMA Associate Director of State and i

Local Programs and Support, Washington, D.C., that such deficiencies and areas requiting corrective action have been corrected and that such corrections have been incorporated into state and local plans, as appropriate.

1.2 EXERCISE, MEDICAL DRILL, AND REMEDIAL DRILLS

SUMMARY

The following is a summary of the August 5,1987 exercise, the medical drill held on September 30,1987 and the two remedial drills held November 4 and December 11,1987.

The summaries provide highlights of actions appropriately implemented, objectives met or not met, Identified Deficiencies, and Areas Requiring l

Corrective Action (ARCAs). Each Deficiency und ARCA is identified using an alpha numeric code.

Example (87-D1):

87= year, D= Deficiency, 1= sequential number.

Deficiencies and ARCAs are referenced in parenthesis and are further described in Section 2 and Tables 1,2, and 3.

State of Colorado Operations Of the fourteen objectives assigned to the State EOC, all were met except Objectives 13 and 14 regarding public alerting and notification (67-D1). These objectives and the associated defic!ency were corrected at the December 11,1987 remedial drill.

The state is to be highly commended for establishing effective procedures for public alerting and notification as evidenced by the successful remedial drill. At the full-scale August 5 exercise, there was an exceptional demonstration of emergency operations management, effective resp'onse to an actual communication system breakdown and a good discussion of recovery and reentry issues. Additional effort is needed to assure emergency classification levels are properly relayed (87-A1), revise the state procedures (87-A2), and to fully demonstrate that ingestion pathway actions can be implemented (87-A 3).

The Medla Center and Rumor Control functions encompassed eight exercise 4

objectives. These were all met at the August 5 exercise. Effective cooperation and coordination of information existed among the Public Information Offices. However, I

I some important improvements are needed to continually assure that information is timaly and consistent with emergency response actions, particularly protective action recommendations (87-A5). Also, additional space and telephones will likely be needed in an actual emergency (87-A4). As was evidenced from the December 11, 1987 remedial drill, the emphasis has shifted to empha:! zing the preparation of

bile alerting and notification Information rather than the development of press releases (87-A6).

At the Forward Command Post, seventeen objectives were evaluated. Staff notification, mobilization and management was outstanding, and major improvements have been made in the facility. Objective 5 was not met based on the non-functional communications with the field monitoring teams (47-D2). FEMA has been assured that appropriate training and equipment will be provided to meet this objective and to

{

completely correct the deficiency by March 1988. Direct two-way communication were

3 also not kvallable between the traffic control point field personnel and the FCP via the DODES Mobile Comvan (87-A8). Finally, the EPA PAGs for the ingestion pathway were outdated (87-A7)

Because of the number and importance of issues identified with respect to state plume and ingestion field teams and the ingestion sample laboratory, a deficiency was identifled at the August 5 exercise. The deficiency relates primarily to plume field team communications, with additional issues related -to procedures, training and equipment (87-D2).J A remedial drill was held on November 4,1987 to redemonstrate ingestion field monitoring and sample laboratory activities. New procedures were developed, responders were trained and the results indicated correction of the deficiency related to the ingestion field teams and the ingestion sample laboratory. Furthermore, the remedial drill demonstrations also corrected the required corrective action regarding predeployment briefings (87-A12).

The state is to be commended for expeditiously scheduling and correcting the deficiency as it related to the ingestion field monitoring and sample laboratory activities.

The deficiency (87-D2) as it relates to the plume monitoring teams is still outstanding. In addition to the issues related to the deficiencies, required corrective actions are also outstanding for the plume teams with regard to delays in plume team deployment (87-A9), improvements in demonstration of procedures for taking direct radiation readings (87-A10) and the need for additional training in the use of field calculation forms (87-A11).

Iocal Government Operations At the Weld County EOC, ten objectives were evaluated and all were met.

Particularly effective was the response by the Emergency Management Coordinator, particularly since the county plan and procedures need to be updated (87-A13) and the EOC was temporarily located in a less than optimal location (87-A14). As observed at the State EOC, the Notification of Unusual Event also was not received at Weld Co (87-A 15).

All objectives were met regarding the Fort Lupton Middle School Reception / Mass Care facility and the Fire Department Decontamination Center. All staff and volunteers are to be commended for an effective demonstration. At the Reception / Mass Care facility, the procedures need to be reviewed regarding distinguishing contaminated from noncontam8nated individuals (87-A16) and to assure efficient movement of evacuees (87-A17). At the decontamination center, decontamination screening criteria also need to be reviewed (87-A18).

Medical Drill - Private Support Operations Objectives 5,30 and 31 were met as part of the regularly scheduled medical drill on September 30, 1987.

The Weld County Ambulance Service provided off-shift personnel who responded professionally to the drill scenario. A utility health physicist also traveled in the ambulance to the hospital. Overall excellent contamination control r

techniques were implemented. The "patient" was cared foe properly even though she was "tagged" as being "injured, with no contamination" by' the health physicist.

Onsite readings indicated that the "patient" was "contaminated." One additional item related to communications with the St. Lukes hospital procedures should be revised to ensure that essential patient status information is conveyed and updated to the hospital so appropriate personnel and equipment are available upon arrival (87-A19). At St. Lukes Hospital, the emergency room staff demonstrated appropriate equipment and techniques for decontaminating the "patient" and appropriate hot line procedures were demonstrated.

1.3 FEDERAL EVALUATORS Eighteen Federal evaluators participated in the August 5,1987 exercise. Three evaluators participated in the November 4,1987 remedial drill and two evaluators participated in the December 11, 1987 remedial drill. Three evaluators also participattd in the September 30,1987 medical drill. For each of these events, the evaluators, their agencies and their evaluation assignments are listed.

1.3.1 Full-Scale Exercise - August 5,1987 Evaluator Agency Location Gary Jones FEMA Exercise Coordinator, Interim RAC Chairperson Gary Kaszynski ANL State EOC, Camp George West Bob Dillard FDA State EOC, Camp George West Philip Nyberg EPA State EOC, Camp George West Walter Payne FDA State EOC, Camp George West Cheryl Malina USDA State EOC, Camp George West Gary Sanborn NRC Media Center, State EOC Marvin Davis FEMA Media Center, State EOC Dana Cessna FEMA Media Center, State EOC Rumor Control, State Health Department Gary Jones FEMA Forward Command Post Frank Wilson ANL Forward Command Post

Evaluator Agency Location Lee Peyton FEMA Forward Command Post Bill Stouder DOT Forwr.rd Command Post, Traffic Control Point Marco Beteta FEMA Forward Command Post, Fort Lupton Middle School Reception Center / Mass Care Brad Salmonson INEL State Plume Field Monitoring Team #1, Fort Lupton Fire Dept. Monitoring / Decontamination Johra Martin DOE State Plume Field Monitoring Team #2, Fort Lupton Fire Dept. Monitoring / Decontamination i

Joe Keller INEL State Ingestion Field Monitoring Team #1, Ingestion Sample Lab Caroline Herzenberg ANL State Ingestion Field Monitoring Team #2, Fort Lupton Middle School Reception / Mass Care Ed Hakala CPR Weld County EOC 1.3.2 Ingestion Pathway and Laboratory Remedial Drill-November 4,1987 Joe Keller INEL Ingestion Monitoring Team, Ingestion Sample Lab Brad Salmonson INEL Ingestion Monitoring Team Gary Kaszynski ANL Observer G'ary Jones FEMA Observer /Overall Drill Coordinator 1.3.3 Public Alerting and Notification Remedial Drill-December 11,1987 Gary Jones FEMA State EOC, Overall Coordination Gary Kaszynski ANL State EOC 1.3.4 Medical Drill - September 30,1987 Gary Kaszynski ANL Weld County Ambulance Service Robert Hite FEMA FSV Site, St. Lukes Hospital Bill Gasper ANL St. Lukes liospital

l 6

'I t

1.4 EXERCISE OBJECTIVES 1.4.1 Full-Scale Exercise - August 5 1987 3

The following FEMA objectives were evaluated at the August 5,1987 full participation exercise for state and local response. The numbers associated with the 7

object!ves correspond to the FEMA objectives.

1.

Demonstrate ability to mobilize staff and activate facilities promptly.

2.

Demonstrate ability to fully staff facilities and maintain staffing around the clock.

3.

Demonstrate ability to make decisions and to coordinate emergency activities.

4.

Demonstrate adequacy of facilities and displays to support emergency operations.

5.

Demonstrate ability to communicate with all appropriate locations, organizations, and field personnel.

6.

Demonstrate ability to mobilize and deploy field monitoring teams in a timely fashion.

7.

Demonstrate appropriate equipment and procedures for determining ambient radiation levels.

8.

Demonstrate appropriate equipment and procedures for measurement of airborne radiolodine concentrations as low as 10~7 uCl/cc in the presence of noble gases.

l 9.

Demonstrate appropriate equipment and procedures for collection, transport and analysis of samples of soil, vegetation, water, and milk.

10. Demonstrate ability to project dosage to the public via plume I

exposure, based on plant and field data, and to determine l

protective

measures, based on

PAGs, available shelter, evacuation time estimates, and all other appropriate factors.

l

11. Demonstrate ability to project dosage to the public via ingestion pathway exposure, based on field data, and to determine appropt late protective measures, based on PAGs and other relevart factors.

i

12. Demonstrate ability to implement protective actions for ingestion pathway hazards.

13. Demonstrate ability to alert. t'he public within the 5-mile EPZ, and disseminate an initial Instructional message, within 15 minutes. (Notes offsite FSV plans and procedures are approved for a 5-mile EPZ).

14. Demonstrate ability to formulate and distribute appropriate instructions to the public in a timely fashion.

15. Demonstrate the organizational ability and resources necessary to manage an orderly evacuation of all or part of the plume EPZ.

t

16. Demonstrate the organizational ability and resources necessary to deal with impediments to evacuation, such as inclement weather or traffic obstructions.

17. Demonstrate the organizational ability and resources necessary to control access to an evacuated area.

18. Demonstrate the organizational ab!!!ty and resources necessary to effect an orderly evacuation of mobility-impaired Individuals within the plume EPZ.

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

21. Demonstrate the ability to mak'e the decision, based on predetermined criteria, whether to issue K! to emergency workers and/or the general population.

22. Demonstrate the ability to supply and administer KI, once the deelslon has been made to do so.

23. Demonstrate ability to effect an orderly evacuation of onsite personnel.

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

25. Demonstrate ability to provide advance coordination of information relee. sed.

26. Demonstrate ability to establish and operate rumor control in a coordinated fashion.

i

8

27. Demonstrate adequacy of -procedures for registration and radiological monitoring of evacuees.

28. Demonstrate adequacy of facilities for mass care of evacuees.

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

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

l

34. Demonstrate ability to estimate total population exposure.

l f

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

I 1.4.2 Ingestion Pathway and Laboratory Remedial Drill-November 4,1987 Based on results from the August 5 exercise, the following objectives were redemonstrated as part of a remedial drill for the ingestion field monitoring teams and the ingestion sample lab. The numbers associated with the objectives correspond to the FEMA objectives.

6.

Demonstrate ability to mobilize and deploy field monitoring teams in a timely manner, j

9.

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

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

1.4.3 Public Alerting and Notification Remedial Drill - December 11,1987 Based on results from the August 5 exercise, the following objectives were redemonstrated as part of a remedial drill on public alerting and notification. The

~

numbers associated with the objectives correspond to the FEMA objectives.

13. Demonstrate ability to alert the public within the 5-mile EPZ, and disseminate an initial instructional message, within 15 minutes.

14. Demonstrate ability to formulate and distribute appropriate instructions to the public in a timely fashion.

9 1.4k Plume Monitoring Teams - Remedial Drill Because of scheduling requirements, this report does not include results of a remedial drill to desionstrate the following objectives that were considered deficient at the August 5, IV.,7 exercise. An addendum to this report will be published followlag redemonstratir., of the following objectives. The numbers associated with the objectives refer to the /EMA objectivo.

5.

Demonstrate ability to communicate with all appropriate locations, organizations, and field personnel.

8.

Demonstrate appropriate equipment and procedures for measure-ment of airborne radiolodine concentrations as low as 10'I uCl/cc in the presence of noble gases (plume team #2 only).

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

1.4.5 Medical Drill - September 30,1987 Three objectives were evaluated as part of the regularly scheduled Medical Drill. The results of this drill are included as part of this report and are included in Section 2. The numbers associated with the objectives refer to the FEMA objectives.

5.

Demonstrate ability to communicate with all appropriate locations, organizations, and field personnel.

30. Demonstrate the adequacy of EMS transportation personnel and procedures for handling contaminated Individuals, including proper decontamination of vehicle (s) and equipment.

31. Demonstrate adequacy of hospital facilities, and procidures for handling contaminated individuals.

1.5 EXERCISE AND REMEDIAL DRILL SCENARIO TIMELINES AND NARRATIVE SUMM ARIES For the exercise and remedial Ollis, approximate scenario timelines were developed to assist the evaluators in documenting significant events. In some instances actual exercise play may have deviated slightly from the Intended scenario timelines.

Thus, the times and events presented in this section may not be entirely consistent with evaluator observations presented in Section 2.

..).

10 1.5.1 Full-8eale Exercise - August 5,1987 The exercise was based upon events leading to core damage and later release of the activity.

i The initial conditions weres j'

1.

Reactor power,100%

~..

2.

Four circulators in operation 3.

342 MW electrical 4.

Both bollers are out of service for a common line repair 5.

Cooling water systems are normal 6.

Hellum purification systems are normal 7.

Electrical distribution system is normal l

At 0600 the reactor operator adjusted the core orifice valves to redistribute flow, one region decreased in temperature slowly.

The reactor operator's actions 3

continued until it was noticed that the thermocouple reading at the outlet of the low j

region decreased to almost average core inlet temperature.

Radiation monitor 9301 Indicated an increasing coolant activity. The operator returned the orifice valves to their original positions suspecting that the low temperature Indication was due to a falling thermocouple. Coolant activity continued to increase until it was greater than 15% above the initial reading. The operator informed the Shif t Foreman. The time was approximately 0700.

L The coolant activity level caused a declaration of a Notification of Unusual Event (NOUE) to be declared.

i Management requested that a coolant sample be obtained for analysis by the 4

incoming chemists.

The on-shif t health physics person was directed to obtain the sample. The H.P. entered the building at approximately 0730 to do this.

}

At 0800 a cold reheat line ruptured at the inlet to the Loop 2 circulator bypass l

1 solation causing a "High Reactor Building Temperature" initiation of SLRDIS (Steam Line Rupture Detection / Isolation System) with the resultant loss of forced coolant (LOFC) and loss of secondat'y cooling capability. This resulted in an "ALERT" declared.

(At this point in the scenario, the H.P. taking the coolant sample became injured.)

l The electric feed pump was damaged by the high discharge pressure and the l

turbine driven feed pumps had no steam due to the boiler outage and were unavailable.

The main condenser rupture disks were broken when vacuum was lost and the condensate i

l

i 11

+

system required greater than six hours to become available for heat removal. It was decided to reestablish cooling via fire water.

y The reactor building atmosphere in the area of the cold reheat line break was approximately 300'F for a significant time with the average building temperature slightly greater than 150'F unt!! approximately 1400.

At approximately 0945 cooling and forced circulation was recovered using the "A" circulator, driven by boosted firewater and cooling via the Loop 1 ESS section of the steam generator. The reestablishment of flow resulted in greatly incre,ssed primary coolant activity caused by fission products released during the LOFC.

At 1000 the reactor building activity rose with Indication thtt there is primary to r/

secondary leakage in the failed reheat section.

A Site Area Emergency (SAE) was declared. The release of activity from the building was monitored through the normal reactor building stack monitor, but Indications were that the filters were not working, flow was 100% of normal with no change in pressure across the filters. These conditions Indicate the filters were being bypassed and therefore ineffective.

The conditions continued for two hours to allow monitoring teams to be observed. At approximately 1200, the Loop 2 reheat section failed depressuring the RCS through the break in about 20 minutes. The resultant release caused a declaration of "GENERAL EMERGENCY."

At approximately 1400, the operator attempted to close the circulator bypass and was successful. The leak was isolated.

A review of plant conditions indicated that the plant was no longer presenting a threat to the public and a recommendation that "deescalation be considered" was made.

Prior to 1600, the exercise was complete. Between 1440 and 1600, the steps and conditions for deescalation were based on plant conditions.

The following is a timellne synopsis of the exercise scenarlo.

Event Time Distribute initial conditions packages 0600 Complete discussion of plant conditions and all 0700 observers on station Declare NOUE based on 25% increase in primary coolant activity.

Cold reheat line rupture, loop 2.

0800 Loop 2 circulator bypass and isolation fall open.

Totalloss of feed and condensate systems.

Health Physicist that was taking the primary coolant sample is injured and contaminated. Declare Alert.

12 Event Time SLRDIS (Steam Line Rupture Detection / Isolation System) 0945 recovery complete on firewater.

i f

Primary coolant activity levels increase.

Declare Site Area Emergency.

I f

Coolant leakage becomes evident in the failed reheat 1000 section (small leak).

' Gross failure of tubes in the fa!!ed reheater, 1200 RCS depressurizes in 20 minutes. Declare General I

Emergency

,.l Radiation levels at the Exclusion Area Boundary (EAB) 1330 l

and plant conditions no longer justify the General Emergency Classification on site.

l f

Loop 2 circulator bypass is closed, accomplishing 1440 l

system isolation.

l Radiation levels at the EAB and plant conditions no 1500 longer justify a Site Area Emergency Classification on site, Exercise is terminated 1600 1.5.2 Ingestion Pathway and Laboratory Remedial Drill-November 4,1987 For the ingestion field teams and laboratory sample remedial drill, essentially the same scenario used in the August 5 exercise was used for the remedial drill. Some of the key events associated with the remedial drill follow.

initial Plant Conditions l

The information provided herein represent the simulated plant conditions under which the Ingestion Pathway and laboratory remedial del 11 was accomplished on November 4,1987.

j e Reactor Power Level - 100%

NOUE declared 0 0300, November 3,1987 based on 25% increase in primary coolant activity.

SAE 4 0100. Radiation release begins (low level activity).

13 GENERAL EMERGENCY C 0800 - massive release to reactor building. Unfiltered release to environment.

- Max release rate

- 21 Cl/See Noble Gas

.11 Cl/See lodine

- Wlod Speed Variable 1-5 mph

- Max Dose Rate 12 rem /hr W.B. O EAB 9.2 rem /hr Thyroid C EAB Release terminated 01200

- Dose rates O EAB - Whole body = 1.8 mr/hr.

Thyroid = 38 mr/hr Particulate and 1-131 data is "real time" data.

Peak-radioactivity concentrations for pasture values are real time equivalent. Milk uCl/ liter values can be assumed to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the release was terminated.

Sequence of Events The following is a summary of the approximate sequence of events for the Ingestion field team and laboratory remedial drill.

E minus 6 days (Oct. 29, 1987): Provide players with Plant Status Information and Plume Exposure Pathway Data that prepares them for Ingestion Pathway Fle!d Activity.

E minus 00:30 mins (Nov. 4,1987): Players arrive at Fort Lupton and prepare for team briefing.

E minus 00:10 mins (Nov. 4,1987): Team Chief receives Instruction message regarding conduct of the Remedial Drill.

E Hour - 12:00 (NOON), Nov. 4,1987: Remedial Dr!!! begins E + 2:30 hours (1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br />), Nov. 4.1987: (Time approximate) Field Teams return to FCP. "Hot Line" Procedures are demonst;ated.

E + 3:00 hours (1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />), Nov. 4,1987: Shut-down FCP Operation and depart for Department of Health Laboratory, Denver.

E + 4:00 hours (1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />), Nov. 4,1987: Laboratory Remedial Drill begins.

14 E + 4:30 hours (1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />), Nov. 4, 1987:

Laboratory drill concludes -- Exit briefing begins.

E + 5:00 hours (1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />), Nov. 4,1987:

Remedial Drill and related activities conclude.

1.5.3 Public Alerting and Notification Remedial Drt11 - December 11,1987 The public alerting and notification drill was conducted as a tabletop procedure overview and subsequent demonstration of Objectives 13 and 14. The following Initial Plant Conditions and events timeline summarize the remedial drill.

l l

Initial Plan Conditions (Prior to 0130 hours0.0015 days <br />0.0361 hours <br />2.149471e-4 weeks <br />4.9465e-5 months <br />, Dec. 11, 1987):

Reactor Power was at 75% and had been operating at this level for e

the past three (3) months.

l I

Next scheduled outage - March 1988.

e Four Circulators in operation.

Both boilers out-of-service for common line repair.

All other systems NORM AL.

l l

i, 1

l 1

l l

15

SUMMARY

OF EVENTS -- December 11,1987 Event Time A reactor operator was adjusting the Orlfice valves to redistribute flow.

0130 Hours While this is a normal operation, he noticed that coolant activity had increased to a level of 30% GREATER than the initial readings.

The Shift Supervisor declared a NOTIFICATION OF UNUSUAL EVENT 0145 Hours (PLANT "CONDITION BLUE") and initiated the required notification sequence:

• Technical Advisor 0145 hrs Plant Management 0147 hrs Weld County 0148 hrs DOH-Rad. Duty Officer 0158 hrs NRC OPS Center 0205 hrs PSC Media Rep 0215 hrs I

Weld County Communications Center Dispatcher received a Plant 0148 Hours Condition "B LU E" report from FSV.

After completing the NOTIFICATION FORM and verifying authenticity the Dispatcher initiated the following notification sequence.

j l

Telephone 279-8855 and relayed Information to CSP-Denver Comm Center Dispatcher. Requested that the information be relayed to the DODES Duty Officer. 0155 hrs Advised Comm Center Dispatch Supervisor. 0158 hrs CSP - Denver Comm center Dispatch received notification of a Plant 0155 Hours Condition "BLUE" from Weld County Communications Center and were asked to relay the information to the DODES Duty Officer.

The Dispatcher initiated the following notification sequence:

Advised the Duty Officer. 0158 hrs Contacted the DODES Duty Officer, and passed information. 0215 hrs l

i 4

16 Event Time The DODES Duty Officer received information regarding a Plant 0215 Hours Condition "BLUE" at the FSV Plant and initlated the following:

Contacted the DODES Director at his home and discussed the MOUE.

The Director suggested that the DODES Duty office do the following:

- Contact DOH, Rad. Control and ensure their awareness.

- Contact the Plant Shift Supervisor and request any explanation of current or far-reaching consequence.

- Keep the DODES Director Informed.

NO OTHER calls were necessary at that time.

The DODES Duty Officer reached DOH, Rad. Control Duty Officer. He 0235 Hours had been advised by the plant supervisor.

The DODES Duty Officer reached the FSV Shift Supervisor. The reason 0256 Hours

• l for declaring a NOUE was based on NRC requirements. No other advice, explanation or assurances were given at that time.

DODES Staff, as required, were assembled and briefed on the early AM 0815 Hours Plant Condition BLUE notification.

The Chief of Operations was Instructed to begin a LOG and post appropriate status boards. Further, the following Staff members were Instructed to be available in case of an escalation.

SEOC Director Chief / OPS e

Chief /Comm

• PIO Ass't./ OPS

+

i As:'t./Com m The DODES Duty Officer was directed to prepare his FCP Staff, as required (Simulated).

At the FSV Plant, a Cold Reheat Line ruptured causing a "High Reactor 1100 Hours Building Temparature" Condition.

Automatic System initiation begon.

1 Plant conditions dictated the activation cf the Emergency Response Organization.

l

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-17 I

Event Time The Shift Supervisor declared an ALERT (Plant "Condition GREEN") and 1115 Hours' initiates appropriate notification sequences.

Technical Advisor 1115 hrs Plant Management 1116 hrs Weld County 1117 hrs Colorado Health 1120 hrs NRC OPS Center 1125 hrs NRC Resident 1127 hrs

(,

PSC Media Rep 1127 hrs Weld County Communications Center received a Plant Condition 1117 Hours "GREEN" notification from FSV. After verification, the following actions s,

were taken:

Activated NAWAS and requested that the "GREEN" tape be played.

1130 hrs Contacted KOA - requested "GREEN TAPE" be played.1137 hrs Followed remainder of notification procedures and directed manning of FCP and Weld County Support facilities.1150 hrs (1)

CSP, Denver Comm Center notified DODES via 279-8855, of the 1135 Hours Plant Condition "GREEN."

(2)

DODES Director activates the RERP and staffs the SEOC.

Dispatches team to FCP.1141 hrs All PSCC, State and Weld County Response Centers were reported staffed 1230 Hours and declared OPERATIONAL.

The following conditions existed:

1.

The NRC dispatched its response team ~ ETA was approx!nately 1500 Mountain, 12/11/87.

2.

The Plant recovered from the loss of FORCED CIRCULATION, however, Primary Coolant activity had increased significantly.

3.

The Reactor Building atmosphere in the vicinity of the Cold Reheat Line was approximately 300*F.

4.

No significant off-site radiological release occurred.

5.

Weather conditions were stable and the wind speed was a steady 3-miles per hour.

6.

Wind direction was blowing from 315' to 135*.

7.

Weather Conditions were forecasted to be stable for 36 Hours.

18 e'

1.5.4 Medical Drill - 3eptember 30,1987 The exercise was based upon an injury that could actually occur during th'e performance of routine duties by Health Physics Technicians.

The initial conditions were:

1 1.

The compactor building and equipment were accessible and operable.

2.

A Health Physics Techn! clan was assigned to process radioactive waste by the Health Physics Supervisor at 0530 that day.

3.

From previous radioactive waste processing, there were several drums of compacted radioactive wastes that were moved from'the compactor building to storage by the Health Physics Maintenance Mechanic.

These drums did provide for a small amount of radiation exposure to the Health Physics Technician.

At approximately 0805, following completion of transferring the drums of compacted radioactive wastes to storage, the Health Physics Maintenance Mechanic entered the compactor building "to confer with the Health Physics Technician who was in the process of compacting radioactive wastes.

At approximately 0810, the Health Physics Technician was in the process of lowering the ram of the compactor into a drum and noticed that a broom handle was protruding over the lip of the 55-gallon drum. She reached into the compactor to remove this object just as the ram came in contact with the object which then disle.dged with sufficient force causing an open fracture of her lef t forearm.

The victim then cried out and fell backwards out of the controlled area resulting in minor bruises on her head.

At this time, the victim's anti-contamination clothing had some contamination on i

the outside. Additionally, where the anti-C's were torn in the area of the injury, there was some skin contamination in an around the area of the wound which was transferred to the skin from the outside of her anti-C's.

The Health Physics Maintenance Mechanic observed the accident and rushed to the aid of the victim. In the course of doing so, contamination was transferred from the victim to the mechanic's hands and clothing.

At approximately 081.5, the accident was reported to the Shif t Supervisor. The Shift Supervisor directed immediate response by fire brigade personnel and requested that an ambulance be sent to the site.

.!mmediate first aid was administered by station personnel including an emergency medical techntelan from security.

1

19 By approximately 0900, the ambulance arrived on-site and cleared through security. After transfer of the victim, the ambulance proceeded to St. Luke's Hospital in Denver.

Health Physics decontaminated one person (the mechanic) on-site after depseture of the ambulance and that concluded this portion of the exercise.

Anticipated arrival of the ambulance at the hospital was 1000. The victim was then turned over to hospital staff for treatment. No later than 15 minutes after its arrival, the ambulance and crew were released to return to normal duties.

Decontamination of the ambulance and crew was not performed but only discussed as time permitted.

The hospital staff then treated the victim using a designated emergency room ud facilities.

Both the victim and attending personnel ware decontaminated as accessary.

/,' approximately 1100, the exercise was terminated and was fo!! owed by an immediate critique with hospital staff.

The following is a timeline sequence of the Medical drill scenario Event Time 1.

Health Physics Tech assigned to process radioactive 0530 wastes.

2.

HP Tech commences assigned duties.

0600 3.

HP Maintet snee Mechanic moves drums of compacted 0805 radioactive wastes to storage.

4.

HP Tech is injured. Mechanic becomes contaminated.

0810 1

5.

Shif t Supervisor notified of injury and requests that 0815 an ambulance be sent to FSV.

6.

Emergency response crew arrives at scene. Commences 0820 i

administering first aid.

7.

Contamination of victim detected by HP Tech.

0825 8.

The ambulance arrives at the security gate.

0845 9.

Af ter victim is admitted through 5ecurity and arrives 0950 at the scene.

l J

20 Time Event 10.

After victim is transferred to the arrbulance, ambulance 0905 departs site for hospital.

]

11.

The contaminated mechanic is escorted to the Health 0910 l

Physics office for decontamination.

12.

Decontamination of mechanic is complete.

0940

~

13.

Ambulance 5,rrives at hospital.

1000 14.

Victim is transferred to hospital staff for treatment.

1010 15.

HP Tech surveys ambulance and crew for the hospital RS.

1010 16.

Ambulance and crew released for return to normal duties.

1015 17.

After completlun of administering medical treatment, 1100 surveying of personnel, and decontamination, terminate the exercise.

1.6 EVALUATION CRITERIA The exercise evaluatior.s that follow in Sec. 2 of this report are based on applicable planning standards and evaluation criteria set forth in Sec. II of NUREG 0654-FEMA-1, Revision ' (November 1980). A FEMA federal evaluation team evaluated the exercise utilizing the modular format to evaluate the assigned exercise objectives.

Following the narrative for each jurisdiction or off-site response activity, Deti-cienchs, Areas Requiring Corrective Actions and Areas Recommended for Improvemer.t are prssented with accompanying recommendations. Any identified Deficiencies would cause a finding that the cif-site preparedness is not adequate to provide reasonable assurance that appropriate protective measures can and will be taken to protect the hecith and safety of the public living in the vicinity of the site in the event of a radio-logical emergency. At least one Deficiency in this category would necessitate a negative j

finding.

This report includes the results of the full-scale exercise, tne remedial drills associated with the ingestion pathway field and lab sample analyses, redemonstration of the public alerting and notification procedures and fM regularly scheduled mt. cal drill. This report does not include result.1 for remedL etivities associated with the plume monitoring teams. The findings from this remedial will be included as part of an addendum to this report.

Areas Requiring Corrective Actions include those activities where demonstrated performance during the exercise was evaluated and considered faulty; corrective actions are considered necessary, but other factors indicate that reasonable assurance c >uld be

31 given' that in the event of a radiological emergency, appropriate measures can and will be taken tv protect the health and safety of the public. This category should be relatively easy to correct in comparison to those classified as Deficiencies.

Areas Recommended for Improvement are also listed as appropriate for each jurisdiction or off-site activity These recomntendations are suggestions to improve on an already satisfactory operation. These are based on evaluator uperience and may or may not be implemented.

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33 2 EXERCBE EVALUAMON On the basis of general criteria set forth in NUREG 0654/ FEMA-REP 1, Rev.1 (November 1980), and exercise objectives and observations, an evaluation has been performed of the August 5,1987 exercise, the September 30, 1987 medical drill and the remedial drills held on November 4,1987 and December 11, 1987. These evaluations, including Deficiencies, Areas Requiring Corrective Action and Areas Recommended for Improvement are presented herein. FEMA Region Vill will maintain close liaison with the state and local governments in determining the required corrective actions (including timeframes for accomplishing the corrections) in accordance with established criteria and guidelines.

2.1 STATE OPERATIONS 2.1.1 State EOC 2.1.1.1 Full Scale Exercise - August 5,1987 The State Emergency Operations Center (SEOC) is located in the basement of t

the Colorado State Patrol Training Academy at Camp George West in Golden, Colorado.

The SEOC is dedicated to emergency response activities and is adequate t,.upport emergency operations related to the Fort St. Vrain Nuclear Generating Station.

The SEOC consists of an operations room, dose assessment area, director's j

office, P!O work area, message center, and kitchen. The operations room has sufficient i

space to conduct emergency activities. Excellent displays and amenities are available, including a posting of "Agency Represent, tion Personnel" signed in to the SEOC, status boards, an operations-offlece desk with.. o telephones (one direct to the Forward Command Post) and an internal P.A. system, a tape recorder and a wireless headset l

communications system. A podium and P.A. microphone are used for briefings, and an overhead projector and a message board with duplicating capability are available.

Portable TVs with a VCR are also available. Equipment for processing internal messages includes a computer with printer, fax machine, and typewriter. The facility also has available a backup diesel power generator that is tested weekly. Overall, the SEOC facility and amenities are excellent to support emergency operations, and therefore Objective 4 was met.

Based on receipt of the Alert ECL at 0819 and subsequent verification at 0822, the staff notification fanout commenced. The Alert ECL was received from the plant, but no call was received at the SEOC from Weld County; however, based on a call back to the plant, the SEOC was informed that Weld County had been notified of the alert.

There was no indication that the SEOC received the NOUE. It is recommended that procedures be reviewed to determine why the NOUE was not received at the SEOC. All notification fanouts were comp'eted by 0851, for a total of 29 minutes for staff

23 notification.

Based on availability of key staff to perform essential emergency functions, the 3EOC was declared operational at 0925. The SEOC was considered fully staffed at 1100 with all approp-late agency representatives available.

Prior to the' exercise, it was agreed that 24-hour staffing of the SEOC would be discussed. According to the operations officer, the agency representatives would work 12-hour shif ts and could leave only if a replacement was available. It was also indicated that during slow periods the staff would be released to local hotels / motels for rest. Based on these observations, Objectives 1 and 2 were met.

Emergency operations management and decision making were exceptional.

Excellent coordination was observed between the DODES director, the operations officer, and also with the DODES representative at the Forward Command Post (FCP).

Briefings were held throughout the day. They were timely, informative and kept all staff updated on the status of emergency response activities. The staff prepared for potential response actions by anticipating resource needs to implement possible PARS.

It is suggested that wind direction be posted on the EPZ map to eliminate confusion as to which direction wind was coming "from" ~and going "to."

Effective procedures were in place to ensure access to the SEOC. It is also clearly evident that the State Plan needs to be reviewed, raised, and updated to reflect the level of operation's management demonstrated.

Based on thesa observations, Objective 3, demonstration of decision making ability to coordinate emergency operations, was met.

The SEOC staff, particularly the communications officer, is to be commended for dealing with an actual communica' ion system breakdown. All telephones except those on a direct line to the outside were inoperable. Incoming messages received at the message center were logged in and sent to the assessment center (which was used for internal message control), where they were reviewed, copied, and sent by runner to the party of concern. Messages were also logged into a computer in the assessment center.

Later in the exercise, incoming messages received at the message cente were first taken to the operations ofUcer's desk, and then to the assessment center by runner.

Incoming communications received via telephone at the operations officer's desk were recorded on a message form and then sent to the assessment center.

Outgoing communications were reviewed oy the operations officer, copied, and sent to the message center for logging and transmittal. A copy was also sent to the assessment center for logging into the computer.

Because of the dual logging of messages at the message center and assessment center, untimely movement of messages may have occurred. Early in the exercise, PSC personnel were experiencing delays in receiving messages'. The cause related to the message center / assessment center logging system and then distribution by runner. Once the assessment center logging procedure was eliminated, messages were received directly from the message center. It is suggested that the logging procedure be reviewed to reduce time for internal message transfer. Based on these observations, Objectiva 5 was met for SEOC com;aunications.

Objective 10, relating to plume dose projections and determination of protective measures based on PAGs and other relevant factors, was met based on the following observations:

24 The Colorado Department of Health (CDH), in its capacity as lead health emergency response agency,. moved quickly to staff both the SEOC at Camp George West, in Golden, and the FCP, in Fort Lupton.

Most of the CDH dose assessment resources were assigned to the FCP, leaving a single health physicist available at the.

SEOC. While the RERP calls for dose assessment capability at the SEOC, FCP, and CDH offices, no independent assessment work was done at tne SEOC during this exercise.

Because of the co-location concept, all dose projections were done at the FCP by CDH in consultation with the utility.

Radioactivity release data and dose assessment calculations by the utility were provided to the SEOC from the FCP using a "Radiological Status" form on a roughly 15-minute update basis after the "ALERT" status was declared, but no field data or CDH d,se assessment calculations were received at the SEOC. Post-exercise checks revealed tnat CDH did indeed calculate doses at the FCP based on radioactivity release data provided by the utility, but none of that was transmitted to the SEOC. Communication problems prevented field data from reach 6g the FCP from the field monitoring teams, and thus no field data reached the SEOC either. Agreement between CDH and the utility on dose calculations was reported to be generally good, which is not surprising, since they used essentially identical computer models previously agreed upon. Similar computing y

capability was available at the SEOC but wts not utilized.

The "Radiological Status" updetes generally provMed the SEOC with information on the release and dose assessment pro}cetions, although there should be some field verification. The information was received by facsimile transmission over a dedicated telephone line and was temporarily sent by voice telephone when part of the telephone system failed unexpectedly. More data, however, would be required by the SEOC if that location was expected to compute the projected doses independently. Furthermore, the DODES director aggressively pursued additional dose assessment dsta by telephone from the FCP before concurring in any major emergency management deciskns.

Two areas of the "Radiological Status" form deserve some attention. First, the "RELEASE CLASSIFICATION" field should be revised to reflect the actual incident classification at the time of update, e.g., NOUE, ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY.

This was inconsistent during the exercise. Seccad, more thought should be given to the "PROJECTED DOSE" field and the "EXPECTED DURATION OF RELEASE" from which it is calculated. FEMA understands that the "projected dose" is intended to be the best estimate of the dose from the immediate sittation and is used to trigger the appropriate protective action recommendation via the PAGs. The "projected dose," however, is merely the centerline dose rate projection, calculated from the expected release rate, multiplied by the "estimated duration of release,' which seems to be little more than a hunch with a default value of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Since this is obviously a critical parameter, FEMA recommends that its use and derivation be reviewed to be certain that decisions will be made on the best possible information and that appropriate personnel be apprised of the significance and limitations of those terms.

A variety of factors caused difficulties in executing the ingestion pathway portion of the exercise (Objectives 11 and 12). The end result was that the action necassary to control the ingestion exposure pathway was discussed only, because the field

l 25 data necessary for determining these actions was not available until af ter some of the critical personnel at the SEOC had been released. Howeve', in spite of the exercise scenario difficulties, it was determined that objectives 11 and 12 were met, primarily based on tabletop discussions at the SEOC.

While the players were still available during the exercise, the Department of Agriculture representative was able to obtain current information on the location of dairy farms, feed lots, and crops, and the number of sheep and cattle in the affected zones. The Department of Agriculture representative was assisted by the Weld County Agriculture Extension Agent.

The Department of Agriculture representative also coordinated ingestion pathway activities with the Colorado Department of Health.

Furthermore, there was some extensive discussion at the SEOC among CDH, the Department of Agriculture, and DODES regarding the actions that could or should be taken to control the transportation and use of foodstuffs which might have been contaminated as a result of the "incidant". These discussions revealed a comprehensive understanding by all parties concerning the appropriate control measures. The use of traffic control points, the embargo of produce or livestock or dairy products from the most contaminated areas, and the diversion of milk for appropriate retention periods were all discussed in general terms but not reviewed in terms of actual ingestion field sampling data as none was available.

As part of the tabletop discussion, officials from the FCP provided to the DODES Director an assessment of ingestion pathway issues and decisions made at the FCP with' regard to the ingestion field data.

Based on decisions made at the FCP, it was determined that cattle within one mile of the plant would be taken off pasture and put on stored feed and imported water.

These actions would be coordir.ated with the Department of Agriculture, and any embargo actions coordinated and enforced by the Departments of Health and Agriculture and the state law enforcement agencies. It was also indicated that milk within one mile of the plant would be diverted to cheese i

processing (see FCP Section) and that dairies producing milk between 1 an' 15 miles of the plant would be instructed to use milk at their own discretion. This information indicated an appreciation at the SEOC for the resources required for these efforts, but 1

specific, scenario-related actions based on ingestion field data were not directly addressed it is suggested that at the next ingestion exercise, the scenario be developed to allow adequate time for full deployment of field personnel to demonstrate ingestion response actions at the SEOC.

Following receipt and concurrence of a protective action recommendation for sheltering in sectors ABCDEFJKL at 1005, the DODES Director requested preparation and dissemination of a public alerting and notification mess %e. The primary public A&N method is by NOAA.' The EBS and siren systemfar6 secondary. At 1051, conveyance of the message was completed to EBS radio KOA and the NOAA weather radio.

For exercise purposes, the scripted message was exchanged by the controller for a message to be actually broadcast; this exchange took approximately two minutes. Thus the total time from decision-making to EBS and NOAA transmittal took 44 minutes; the FEM A standard for this procedure is 15 minutes.

At 1114 another public aler.ing and notification message was requested by the DODES Director based on a decision made at 1112 to recommend a precautionary

36 evacuation of children and pregnant women in Sectors ABCDEFJKL This public A&N message was submitted to the controller at 1137. There was no intention to exchange this message for one appropriate. for transmission to the public alerting notificatio'n stations.

Nevertheless, it took 25 minutes to develop and obtain approval for this message. It is likely that additional time would have been needed to convey the message to the publ!c A&N stations.

In addition to the dela'y in developing the public A&N message recommending evacuation of ch!!dren and pregnant women, the content of the message was inconsistent with the news release regarding the areas to be evacuated expressed as familiar landmarks.

Subsequent public A&N messages were not developed independently of news releases. News releases 87-04 (12:45 p.m.), 87-05 (1:45 p.m.), 87-06 (2:15 p.m.), 87-07 (3:15 p.m.), and 87-08 (4:45 p.m.) were intended to be used verbatim for public A&N messages. The purpose and audiences of new releases and public A&N messages are distinctly different, and the practice of basing public A&N messages on the content of press releases should be discontinued.

J s w- ~,

FEMA understands that the primary public A&N methods $ by NOAA and that

't secondary methods include EBS tri& hired and public address activation in Platteville. It is suggested that when the secondary system is activated, it be consistent in content and coordinated with the primary public A&N system. Coordination therefore, is suggested between the SEOC, Weld County officials at the FCP, and communication center personnel responsible for activating the siren in the Weld County Communication Center.

Based on these observations, Objectives 13 and 14 were not met, and remedial actions are required to meet the objectives.

The SEOC staff played a secondary role in managing orderly evacuation of the plume EPZ. Most of these activities were handled at the FCP by Weld County agency representatives and the str.te police. Based on observations at the SEOC, Objective 15 was met.

l The ability to identify the need for, and request and cbtain, federal assistance (Objective 32) was met. Various requests were made throughout the exercise for federal resources to supplement existing state resources. At the SEOC, requests for federal assistance were not always channeled through the governor or his authorized representative (in this instance, the DODES Director) as stated in the plan.

As discussed previously under Objective 10, calculations for projected plume dose contained the "integrated dose," the sum of doses at a particular distance along the plume trajectory made by the releases up to that moment of update. When added to the population data for the individual sectors traversed by the plume. It is possible to

.i compute the total population exposure based on the plant release data. While is,is highly desirable to confirm these calculations with actual field data, the dose estimation ability was clearly demonstrated during this exercise, and thus Objective 34 was met.

l

27 While the actual recovery / reentry phase of the exercise was constrained by time and availability of personnel, there was a very good discussion at the SEOC regarding the appropriate measures to be taken and how they would be implemented in practice. Good cooperation between Weld County authorities and state response personnel was evident throughout, and it was obvious that traffic control could be established and maintained.

The precautionary evacuation recommended by CDH was carried out through the proper channels, and the necessary information was generally provided to those affected. Lack of communication with the field teams prevented the verification of projected exposure rates, but otherwise the operation proceeded smoothly. There was adequate appreciation at the SEOC for the controls required for safe recovery and reentry, and thus Objective 35 was met.

A total of 14 objectives were evaluated at the State EOC, Objectives 1, 2, 3, 4, 5,10,11,12,15, 32, 34 and 35 were met. Objectives 13 and 14 were not met based on the deficiency identified and thus remedial actions are necessary.

DEITICIENCY 87-D1

Description:

Once the decision had been made to implement PARS and draft public A&N messages, it took approximately 44 minutes in one instance and at least 25 minutes in another to develop the message and transmit the message to the public A&N stations. FEMA reautres that this process take no longer than 15 minutes. The content of one message was inconsistent with the corresponding news releases recommending evacuation of children and pregnant women. Later in the exercise, news releases were used for public A&N messages. Finally, it we' not clear as to the procedure for assuring that the NOAA pub' a alerting and notification messages are consistent in content sad coordinated with the secondary, and particularly, the tertiary Platteville

stren, activation and public address announcements. (NL 4EG-0654 II, A.2.a E.6, Appendix 3)

Recommendation:

Review and, if necessary, modify SEOC procedures to ensure that once a decision has been made to issue a public A&N message, the message is developed and sent to appropriate entities within 15 minutes. Assign e Specific individual or individuals who have been trained in, and are responsible for, drafting public A&N messages. The procedure should ensure that the content of the primary public A&N messages 's consistent with the backup systems as well as timely.

Consider de.elopment of prescripted public A&N messages that are speelfic to sector (s) or zone (s) affected by protective action recommendations.

For example, for each sector or zone affected by PARS, consider developing an index to identify boundaries described by common landmarks. Ensure that the primary focus of public A&N messages is to inform the public of basic protective measures and not use press release

28 format and information for general public distribution. The purpose and audiences for these two types of messages are distinctly different.

AREAS REQUIRING CORRECTIVE ACTIONS 87-Al

Description:

The Notification of Unusual Event was not received at the SEOC (NUREG-0654, II, E.1).

Recommendation: Determine the reason for this problem, and provida training to appropriate individuals to ensure that emergency classifications are relayed properly to the State EOC.

87-A2

Description:

The Colorado RERP plan and procedures (when available) are outdated and do not reflect the concept of operations demonstrated during the exercise. For example, the SEOC dose assessment role has be'en redefined, public alerting and notification procedures as defined in the plan were not carried out and demonstrated, and internal message logging procedures were not consistent with the plan. These are just a few of the obvious inconsistencies between the response demonstrated and the plan (NUREG-0654, II, P.4, P.5).

Recommendation:

Review and revise tt i State RERP as necessary to reflect the current status of emergency response demonstrated during the exercise.

87-A5

Description:

Because of dismissal of some key emergency response personnel, actual demonstration of specific agency response actions for the ingestion portion of the exercise could not be evaluated at the SEOC (NUREG-0654, !!, J.11).

Recommendation: During the next exercise of the ingestion pathway, ensure that actual demonstration of Ingestion response actions occur at the SEOC by all appropriate agency representatives.

~

AREAS RECOMMENDED FOR IMPROVEMENT

==

Description:==

Initially in the exercise, there was confusion as to the wind direction and potentially affected planning zones.

Recommendation:

Utilize sppropriate maps to display wind direction information and potentially affected planning zones.

==

Description:==

Internal message traffic was delayed at times because of duplicate logging procedures.

Recommendation:

Review and modify internal message traffic procedures to. ensure efficient internal message transfer.

w

.-,.n

<ms.-

--~-,,_,

29

==

Description:==

The "Radiological Status" form did not raflect the actual emergency classification level at the time of update.

Recommendation: Consider revision to procedure and/or form to reflect current emergency classification level at the time of update.

==

Description:==

Requests for Federal assistance originated from j

sources other than through the DODES Director (governor's designee) as stated in the plan.

Recommendation:

Revise procedure or plan to reflect intended means for requesting federal assistance.

2.1.1.2 Public Alerting and Notification - Remedial Drill Results, December 11,1987 A remedial drill was held on December 11, 1987 to redemonstrate Objectives 13 and 14 that were found to be defielent at the August 5 exercise.

.The remedial drill consisted of a tabletop overview of the new procedures that were developed by the state. Subsequently, the drill consisted of implementing the new procedures to assure that once a decision was made to implement a protective action recommendation, a message could be generated and disseminated to the public in 15 minutes.

Based on the following observations, the two objectives were met and the deficiency relating to public alerting and notification was corrected.

Major improvements have been made in the system to provide public warning and dissemination of both initial and subsequent instructional messages to the public. Staff assignment of responsibility has been clearly defined and effective procedures are available for fulfilling this function. The procedures a e enhanced by development of color-coded tapes that correspond to the Alert, SAE and GE emergency classification levels. In addition, prescripted tapes are available to convey protective actions to the public via a new grid system of eight geographic areas surroundit.g the plant.

As part of the remedial drill, implementation of the procedures produced instances.where the public was notified and warned in 5 minutes or less. The FEMA i

standard for this procedure is 15 minutes.

Furthermore, it was clear that the procedures refocus staff activities to developing and disseminating public notification and warning information first, then Implementing public information procedures for the news media.

Finally, the procedures as implemented ensured that the content of the primary s

public A&N method (AMN is consistent with the back-up systems as well as timely.

Overall, the public A&N remedial drill was a complete success, the staff responsible for developing the procedures are to be highly commended, and FEMA

~

30 concludes that Objectives 13 and 14 are met and Deficiency 87-D1 identified at the August 5,1987 exercise is corrected.

DEFICIENCIES None.

AREAS REQUIRING CORRECTIVE ACTION None.

AREAS RECOMMENDED FOR IMPROVEMENT None.

2.1.0 Media Center The Media Center is located in and is part of the State Emergency Operations Center at Camp George West.

According to the state plan, public information representatives from the following organizations should be present:

the Governor's office, the Division of Disaster Eme gency Services, the Department of Health and the Public Service Company of Colorado. Together, these representatives make up a Public Information Coordination Team which issues joint press releases regarding emergencies at the Fort St. Vrain plant.

Public information representatives reported promptly to the Media Center following the decision to implement the state radiological emergency plan. A full staff was present and, through the presentation of a roster and other discussions, was able to demonstrate a capability to staff the center on a continuous basis. FEMA Objectives 1 and 2 were met.

The ability to make decisions and coordinate emergency activities was demonstrated but there were lapses in the latter that illustrated a need for tighter controls over the release of information and a need for the assignment of clear responsibilities to accomplish this. For example, in the case of advisories to pregnant women and children, the press release and the public A&N message had different descriptions of the geographic area in which the advisory was applicable. In a later public A&N message, wording describing the worst-cese effects of a planned release of radioactivity remained in the message despite it having been stricken from a press release on the same subject. This also serves as an illustration of the difficulties likely to be encountered when those responsible for issuing public instructions via NOAA and EBS rely on press releases for the content of those messages, FEMA Objective 3 was met.

Facilities and displays were generally adequate. However, there is a need for additional telephones in the PIO work area. Five organizations were represented in this

31 exercise (including NRC); even more would be represented in an actual emergency; thus i

the need for additional telephones. FEMA Objective 4 was met.

PIOS working in the media center were, except for a period when the telephone j

system was down, able to communicate with all other locations. The same, however, was not true for those trying to communicate with the PIOS. The phone number at the top of each press release was that of the state EOC switchboard. However, the operator was instructed not to transfer calls from reporters to the PIO work area in the EOC. There were no instructions to the operator to tell reporters anything useful, such as the fact that periodic briefings were being conducted at the EOC. There is no point to directing media calls to a location at which reporters will have na access to information. FEMA Objective 5 was met.

Generally, the public information function was well staffed and operated in a manner that would insure accurate and current information reaching the public. Overall, Objective 24, was met. However, the P!O team appeared to give undue attention to the media's deadlines when considering the timing of press releases and briefings and not enough attention to the coordination of this information with that being disseminated

]

over the NOAA and EBS systems. As previously mentioned, there were inconsistencies at times. On another occasion, reporters were provided information about protective action recommendations that had not yet gone out over these emergency broadcast networks.

While in most cases, information was provided to the media promptly (and perhaps even too promptly), there was one situation (the announcement that a general emergency had been declared) that was slow in being announced to the press. The briefings appeared to be contingent on the completion of press releases that didn't warrant the delay because j

they didn't provide complete summaries of thq current situation anyway, only some highlights.

Furthermore, the briefings, while providing some realism, fell short of a realistic test of each agency's ability to respond to media inquiries. With a couple of exceptions, most of the "reporters" asking questions at the briefings showed little of the firmness characteristic of working media. Also, news briefings should be announced over the PA system in the EOC so that everyone working in the EOC is awcre that a briefing is taking place.

Finally, it would be useful to be able to monitor (sound only) the news briefings from other locations, such as the P!O work area in the EOC and the Forward Command Post. It is important that key officials are aware of how information for which they are responsible is being presented to the media. In the case of PIOS in the work area, they could alert others to the kinds of information that there is a need to gather.

By virtue of the system in place (the preparation of a single press release), there was effective cooperation among PIOS and good coordination of information in advance of conducting briefings 'e issuing press releases. However, the preparation of a single, coordinated press release does not necessarily result in a product that explains in enough detail the activities of the separate organizations responding to the emergency. FEM A Objective 25 was met.

33 The State Rumor Control Operation (Public Inquiry Center) was located in the third floor office of the Health and Environmental Protection Branch of the Colorado State Health Department. The rumor control facility consisted of a large room with a desk, a designated dedicated phone, chairs, a travel map of Colorado and a hard copy receiving device. The ability to mobilize a staff and activate the facilities promptly were adequately demonstrated. One person was on hand to handle the rumor control duties. Under real world conditions, the operation would be staffed by 3-4 persons augmented by a clerical staff of six persons operating from an adjoining office furnished with a bank of dedicated phones, a TV monitor and an AM/FM radio. As designated in the State Emergency Plan, a liaison representative of the Public Service Company of Colorado was present to help translate technical information into layman's terms.

The ability to make decisions was adequately demonstrated as was the ability to coordinate emergency activities. The rumor control operative had a keen knowledge of the proper response methodology to deal with all inquiries. A total of about 4-5 calls requesting rumor control responses were received and adequately handled by the rumor control person.

Although the single rumor control phone was supposed to be dedicated, other calls regarding State Health Department business were received throughout the exercise.

The ability to communicate with all appropriate locations, organizations and field personnel was adequately demonstrated with the exception of the State EOC which experienced phone problems off and on during the exercise.

Overall, the ability to establish and operate rumor control in a coordinated fashion was adequately demonstrated.

FEM A exercise Objectives 1, 2, 3, 4, 5 and 26 assigned to Rumor Control were met.

FEMA exercise Objectives 1, 2, 3, 4, 5, 24 and 25 assigned to the Media Center at the State EOC were met. It is important to note that based on results of the public A&N remedial drill conducted on December 11, 1987 that the concept of operations for l

public alerting and warning and public information has been refocused to emphasize public alerting and warning first, then, to public information. This will likely provide the basis for correcting appropriate ARCAs described below at the next biennial exercise.

DEFICIENCIES None.

AREAS REQUIRING CORRECTIVE ACTION 87-A4

Description:

Although five different organizations were represented in PIO work area in the state EOC, there were only two telephones. In an actual radiological emergency even more

33 l

~

organizations would require work space and comrnunications equipment. (NUREG-0654, !!, G.3.a)

Recommendation:

The telephone needs of the principal organizations should be assessed and an adequate number of l

telephones provided. In future planning assessments, attention should be paid to the space and equipment needs of the principal organizations without losing sight of the advantages of having all PIOS work in close proximity.

87-A5 De cription: There were inconsistencies between press releases and public A&N announcements. In addition, on one occasion the press was provided information on a protective action 2'

recommendation before it was disseminated over the official emergency broadcast networks. (NUREG-0654, !!, G)

Recommendation: Plans and procedures should be assessed to determine whether there is a need for tighter controls over the release of Information and better coordination between those responsible for issuing information to the news media and those responsible for issuing information to the affected public.

87-A6

Description:

Problems were created by the decision to base public A&N messages on the content of press releases. For one thing, those responsible for press releases are not operating under the same time constraints as those responsible for i

emergency instructions to the public. In one case, a draf t press s

release was disseminated over the emergency networks and included wording that was disputed and struck from the final version of the press release. In general, the process should j

work in reverse. The emphasis should be on getting emergency Instructions to the public out over the public A&N networks; the press releases should include that information but only after it has been disseminated via official channels to the affected areas. Press releases, because they may address a variety of subjects, some in detail, normally do not lend themselves to being used as emergency messages to the public. (NUREG-0654, II, E.5)

Recommendation: The practice of basing public A&N messages on the content of press releases should be discontinued.

i AREAS RECOMMENDED FOR IMPROVEMENT

==

Description:==

Procedures for handling incoming calls from reporters e

were inadequate. Calls to the switchboard at the state EOC, which was the number listed at the top of press releases, were answered by an operator whose only instruction was not to refer calls to the EOC work areas.

34 Recommendation:

Plans and procedures should address just how calls from reporters to the EOC and Media Center are to be handled. If calls go to a switchboard and reporters are not to be referred to a PIO, then the switchboard operator should be given precise instructions on what reporters are to be told.

4

==

Description:==

The designated dedicated phone was used to receive calls not related to rumor control business.

Recommendation:

Redevelop proper procedure for using a i

dedicated phone / phones for rumor control activities.

2.1.3 Forward Command Post State personnel designated to man the FCP received an activation notice, via their paging system, from the State EOC, at 8:29 a.m. By 9:40 a.m. all state, local and utility personnel were in place at the FPC and the Facility was declared operational.

Representatives of the Colorado Division of Disaster Emergency Services - and the Colorado Department of Health, together with representatives of Weld County and the Utility manned the facility.

The FCP personnel were knowledgable of their responsibilities and, throughout the exercise, displayed a level of cooperative action that was outstanding. As soon as it became evident that the scenario would require FCP activity extending beyond the capability of a single manning shif t, action was initiated, by all agencies represented, to insure multi-shift coverage. Each agency developed a written list of relief personnel and provided the list to the FCP director. Based on these observations, Objectives 1 and 2 were met.

1 A co-location concept is utilized at the Forward Command Post (FCP). The key agency officials from DODES, Colorado Dept. of Health, Weld County Sheriff's Office, PSC, and the NRC demonstrated excellent cooperation in determining actions to be implemented. The interface and discussions that took place were truly exceptional. The Director of the FCP was definitely in charge and did a fine job in coordinating with all

]

agency representatives at the FCP. There were numerous briefings given, throughout the exercise, which were very informative for all participants. Once a recommendation for a protective action was agreed upon at the FCP, it was immediately discussed by phone with the SEOC for concurrence. Good use of displays and maps was demonstrated while the decisions making process took place. All personnel were well trained and knew their jobs. Throughout the exercise many problems were presented to the decision makers at the FCP and on each occasion the decisions were mutually agreed upon and implemented i

in a timely and coordinated manner. Overall, excellent management and operational concepts were demonstrated effectively and efficiently by the key personnel colocated at the FCP. Thus, based on these observations, Objective 3 was met.

Objective 4,

demonstrate adequacy of facilities and displays to support emergency operations, was met. Major improvements have been made at the FCP since the 1985 exercise, and these improvements have increased the efficiency of emergency response. The facility is well-designed and well-equipped. Telephones, a PA system, a television monitor, status boards (including an electronic copying unit) enhanced the j

emergency operation.

.------.-.)

35

~

~

Primary communications at the FCP was by land-line telephone. Fourty-two telephones are in place in the FCP which provide connections to all fixed locations and organizations participating in emergency operations at Ft. St. Vrain. There was a short.

Interruption of telephone communications to tM State EOC when the system serving the j

Camp George West area went down. Otherwise, all systems worked well throughout the exercise. Back-up communications from and h the FCP is via radio provided by a state communications van that is parked just outsida the FCP facility. Message exchange between the van and the FCP is by runner. Communications to the state field monitoring teams, from the state communications van, failed completely during the exercise. Even the dispatching of a relay vehicle failed to resolve t..e communication problem. Overall, Objective 5 was not met based on the communications, problem; the plume field monitoring section provides a detailed account of field team communications and the associated deficiency.

Radiological status information was received every 15 minutes by the Colorado Department Health from the utility. Information included plant status, meteorological data and appropriate information needed for determining protective actions. Based on the utility data, the state calculated plume data and compared it with plant data.

Protective actions were then determined based on discussions between CDH, NRC and utility personnel. Following concurrence with the State EOC on protective actions, these actions were then implemented. Based on these observations and the excellent dialogue between the state, utility and NRC personnel, Objective 10 was met.

Based on radiochemical analysis, decisions were made to prevent marketing of milk up to 1 mile of the plant; it was determined that the milk would be diverted to other

~

uses. Dairy cattle were also put on stored feed up to 15 miles. Also it was recommended that pastureage not be used out to 20 miles, until cleared based on radiochemical analysis. Overall, this objective (11) was met, however, the plan needs to be updated to include the latest EPA PAGs. This would include the recommendation that all milk above preventative guidelines be condemned, rather than diverted to other uses.

Laboratory analysis data was used to make protective action recommendations for the ingestion pathway exercise. Objective 12, demonstrate the ability to implement protective actions for ingestion pathway hazards, was met.

Late in the exercise, a decision was made to evacuate all pregnant women and children and the Weld County Sheriff's Representative adequately coordinated his responsibilities with his Weld County EOC and State Police, and proved that appropriate resources were available to handle the evacuation. Excellent anticipation of problems was demonstrated by the Weld County representatives.

For example, before an evacuation decision was made, the County Sheriff had reviewed his map and checked for available vehicles and other resources that would be needed to carry out the evacuation. The Sheriff's Representative also properly handled a problem dealing with impediments to evacuation based on a traffic obstruction. Also demonstrated was the ability to evacuate mobility-impaired individuals. An up-to-date file is located at the Weld County EOC and a vehicle was dispatched to one of the mobility-impaired addresses for demonstration. Based on these observations, Objectives 15,16, and 18 were met at the Forward Command Post.

1 36 l

The Weld County Sheriff's Department and the Colorado State Highway Patrol displayed adequate control over traffic and access control points during the exercise. All traffic control points were established within 20 minutes of notification. Excellent interface and coordination existed between the Weld County Sheriff's Department, the Colorado State Highway Patrol, the Forward Command Post and field personnel with respect to implementing protective measures such as establishing traffic control points and evacuation of mobility-impaired. The DODES Mobile Commvan did not have Weld County Sheriff's Department radio frequency available. This prevented directed two-way

^

radio communications between Weld County Sheriff's Office field personnel and the FCP via the commvan.

Another problem identified was that the. Weld County Sheriff's Department personnel, who demonstrated traffic control, were not familiar with KI, KI procedures or its use. Overall, Objective 17, to demonstrate the ab'lity and resources necessary to control access to an evacuated area, was met.

The Forward Command Post serves a secondary role In monitoring emergency worker exposure control. One responsibility is to remind field teams to read their direct-read dosimeters (DRDs). In the field, the team members read their DRDs at appropriate time intervals and one plume team provided a dosimeter reading to the FCP. Because of the communication problems between the FCP and the field monitoring teams, the FCP was not able to remind the field teams to take readings. Nevertheless, the field team members acted appropriately and Objective 20 was met for the FCP.

The Colorado Department of Health utilized both plant status and dose 131 projection data to determine 1 levels out to 20 miles. Based on these calculations, it was determined that the issuance of El was not necessary, thus Objective 21 was met.

Because of this decision, K! was not issued. However K! was available and was within expiration dates. It was determined that had a decision been made to issue KI, the field teams could not have been contacted and directed to take it because of the communications problem. Nevertheless, Objective 22 was not applicable based on the decision not to issue KI.

There was a decision at 0906 to evacuate all ncn-essential PSC plant personnel and the Weld County Sheriff's representative effectively demonstrated the knowledge and the organizational ability to provide sufficient resources to handle the situation.

During this initial evacuation of plant workers, the Sheriff's Deputy also remembered that there were migrant workers around the plant and he took proper actions for also evacuating those individuals. Based on these observations, Objective 23 was met.

The utility supplied the state with 15-minute updates on plant status. The state made estimates on probable population exposure from their projections. State data was compared with plant data and the more conservative numbers were used to determine whole body, child thyrold, time to reach PAGs and dose rates, among other parameters.

This system appeared to work very well to make estimates of population exposures.

Objective 34 was met.

Lab results were used to demonstrate the state's ability to determine and implement appropriate protective measures in the ingestion pathway. Decisions were made pertaining to dairy herds, pasturage food stocks, and cattle, etc. for the duration of the exercise. National Guard and local law enforcement were used to secure the area to

37 l,

1 l'

' prev'ent any movement of food stock out of the area. Objective 35, to demonstrate the t

ability to determine and implement measures for controlled recovery and reentry, was met.

In summary FEMA Objectives 1, 2, 3, 4, 10, 11, 12, 15, 16, 17, 18, 20, 21, 23, 34 and 35 were met. Objective 5 was not met.

DEFICIENCIES None.

AREAS REQUIRING CORRECTIVE ACTION 87-A7

Description:

The Ingestion PAGs in current use are out of date. The decision to use milk for cheese rather than condemn it could result in potential public health problems. (NU REG-l 0654, !!, J.11)

Recommendation: It is recommended that CDH update their plan to include current EPA PAGs for the ingestion pathway.

87-A8

Description:

The ' State DODES Mobile Commvan had equipment problems and did not have Weld County Sheriff Department radio frequencies on hand. Thir prevented direct two-way radio communications between Weld County Sheriff's field personnel and the FCP via DODES commvan (NUREG-0654, !!, F).

Recommendation: The communications equipment should be expeditiously repaired and Weld County Sheriff Department radio frequencies should be available in the commvan at all times.

AREAS RECOMMENDED FOR IMPROVEMENT

==

Description:==

Emergency field personnel from the Weld Co. Sheriff's e

Det.artment were not familiar with K!, K! procedures or its usage.

Recommendation: It is suggested that K! and instructions on its use be included in subsequent training programs for emergency field personnel in Weld County.

I 1

38 1

2.1.4 Plume Field Monitoring Teams Full-Scale Faercisc - August 5,1987 Two plume field monitoring teams were activated for the exercise.

Five objectives were evaluated with regard to plume field monitoring activities. Discussions of each objective relates to both plume teams, with specific activities and issues related l

to individual teams discussed as appropriate.

Following receipt of the Alert ECL, CDH directed activation of the field monitoring teams. The 24-hour State Highway Patrol headquarters dispatcher contacts CDH staff through an answering service. A pager system is also used, with various l

individuals sharing weekly responsibility for wearing a pager. The field monitoring team members were mot,.lized from their normal work stations at the CDH in Denver.

,i The decision to mobilize the field monitoring team was made at 0826 hours0.00956 days <br />0.229 hours <br />0.00137 weeks <br />3.14293e-4 months <br />, and the first field monitoring team members arrived at the FCP in Fort Lupton at 1010, which seems timely considering the travel time and the time it takes to load monitoring equipment into vehicles.

Upon arrival at the FCP, the team members unloaded all of the field monitoring equipment brought from the CDH and began organizing the equipment by teams.

Additional equipment, radiation survey instruments, and air sampling equipment were obtained from a locked storage cabinet at the FCP.

Once all the field monitoring equipment vias organized by teams, which took additional time and delayed the overall deployment, the team members began the instrument source checks, battery checks, and operability checks of the air sampling equipment. During the course of organizing and checking the equipment, the team members were briefed on the plant status and meteorological conditions. Prior to deployment from the FCP, the field team received Instructions regarding the administrative exposure limit (3 rem) that was in effect during the emergency response, and they received an excellent set of instructions as to where to begin their radiation surveys. They were instructed to traverse the plume, locating the plume boundaries and plume centerline. Each team was given two traverse locations during the predeployment briefing. Two to three briefings were provided throughout the predeployment timeframe, resulting in about a one-hour period between team arrival and subsequent departure. Overall Objective 6 was met for both plume teams.

Plume team 1 deployed from the FCP at 1135 and arrived at the traffic control point (TCP) at 1150. An approximate 30-minute delay was encountered at the TCP when j

the TCP officer impounded the plume team 2. (Controller intervention finally succeeded in releasing team 2 to go on with its monitoring mission in the field.) At 1224, team 1 arrived at its first assigned monitoring location and began a plume monitoring traverse northward along County Road 31. By 1258, team 1 had completed the initial traverse of the plume; this included returning to the plume centerline to collect an air sample and moving back outside the plume to count the air sample. Since the field team did not have radio communications (see Objective 5 summary), the team leader decided that they should go to the nearest public phone, town of Gilchrist, to call in their monitoring data to the FCP and to request further field monitoring instructions. This initial phone call

39 1

was placed at 1324, and team I was instructed to wait at the phone for further instructions.

Over 1} hours elapsed (1506) before team I received instructions to conduct a plume traverse south on County Road 251 and return to the emergency worker decontamination center via the TCP. (Note: During this time interval, team 1 called the FCP a couple of times requesting instructions; they received at least one call from the FCP prior to the 1506 call to deploy on the final plume traverse.)

Objective 6, the ability to mobilize and deploy field monitoring teams in a timely fashion was met; however there was some delay in the initial deployment from the FCP and further delays in deployment from field monitoring locations to new monitoring assignments. The delays in the field were primarily attributed to field team coordination i

from the FCP. This type of time delay should be corrected, since it does not permit proper utilization of the field monitoring resources. Pre-packed emergency response kits containing most of the instrumentation and air sampling equipment could speed up the Initial deployment process from the FCP. A key oversight in the predeployment briefings was a lack of discussion on communicatiors equipment and its use; for example, antenna to be used with the hand-held radio units were not taken into the field.

Objective 5,

the ability to communicate with all appropriate locations, organizations, and field personnel, was not met by the plume monitoring teams because of the failure of the primary communications system, the portable radio, j

Plume monitoring team number 1 should be commended on its resourcefulness in locating a public pay telephone after completing their first monitoring assignment and using the telephone to communicate their field monitoring data to the forward command post (FCP). Plume monitoring team 1 also made contact with the FCP via the sheriff's department traffic control point (TCP) radio. This radio link was not direct to the FCP, since it had to b2 relayed through the sheriff's department communication center.

Plume team 1 utilized the TCP communications system twice; the first time was to notify the FCP of the apparent radio communications failure between the field teams and the FCP, and the second use of the TCP communications was to relay the second set of field measurement data to the FCP. (This was at the close of the exercise when team I was returning through the TCP enroute to the. emergency worker decontamination center.)

Field monitoring team 2 did not attempt to communicate monitoring results by telephone until 1430, at which time the tesm was returning to the FCP. This attempt to convey monitoring results by telephone occurred three hours into the exercise and after plume monitoring had concl%d.

Objective 7

w. '

$et for both plume field monitoring teams.

Team 1 demonstrated appropriato quipment and procedures for determining ambient radiation levels.

The team members were knowledgeable about the operation of radiation monitoring instrumentation, and they understood the need to take both open and closed window measurements at each measurement height. The team members seemed to be familiar with the area, or at least they did not have any difficulty using a map to locate the assigned plume monitoring route. Team 2 demonstrated adequate procedures for measuring direct radiation, except the lack of open/ closed window readings at ground level to determine deposition.

40 Plume team 1 met Objective 8 but plume team 2 did not.

Plume team 1 demonstrated the appropriate use of air sampling equipment and procedures for taking the air samples (i.e., the air sample was collected at plume centerline using a silver zeolite cartridge, and the air sample was taken outside of plume for counting).

The major issue appears to be training related to tne use of the field calculation forms. The forms used during this exercise were, according to the team members, provided by the utility, and the team members were uncertain about the conversion factor used for converting counts per minute (cpm) to uCl/ce. They were not sure that the conversion factor was applicable to the counting instrument they were using, and initially they used different conversion factors. (The difference in the conversion factor was a difference in the value of the exponential power -- this can lead to orders of magnitude difference in the calculational results.)

Upon comparing their initial calculated value with the controller's data and noting the large difference, they decided it would be appropriate to use the conversion factor printed on the form. Therefore, it would appear that more training should be given to the team members on the use of the field calculation form. This training should include a derivation of the conversion factor so that there is no question that the conversion factor applies to the counting instruments used in the field.

Two minor items related to sampling techniques were noted: (1) the air sampling pump and filter head should be set up prior to entering the plume for collection of the air sample. During the exercise, the filters were placed in the filter head af ter the team reached the centerline sampling location -- this adds a little unnecessary exposure time to the emergency worker, and it could lead to cross-contamination o' clean items in the equipment supply kit if the kit is opened in the plume to obtain the air filters, and (2) after leaving the plume, the silver zeolite cartridges should be purged with clean air to remove any residual noble gases which remain in the void spaces within the cartridge.

This will improve the quality of the gross field measurement data.

Finally, one other item related to air sample counting should be checked. The instrument used by team 1 for counting the particulate filter and the silver zeolite filter was an end window G.M. detector. It is well documented that a pancake-type G.M.

detector, with a detector diameter very close to that of the filters, has good counting geometry and provides adequate sensitivity to measure radiolodine at a concentration of 10~7 uCi/ce. It is questionable whether the end-window-type G.M. detector has adequate counting geometry to provide the desired sensitivity.

Plume field team 2 exhibited good anticontamination controlin that they bagged and/or contained air sample cartridges and filters prior to entering the plume. The general procedures utilized in taking air samples were good; however, during the field analysis of the silver zeolite cartridge, the cartridge was reversed in the counting ring (upside down), which would result in low readings. In addition, the calculations were performed by an individual with marginal knowledge of the analytical procedures. This

~

was evident from his failure to properly calculate both particulate and radiolodine air sample results.

The improperly-counted silver zeolite cartridge and incorrectly-calculated results compromised the team's ability to accurately report air monitoring results. Based on these observations, plume team 2 did not meet Objective 8.

41 Both plume field monitoring teams did not meet Objective 20, to demonstrate the ability to continuously monitor and control emergency worker exposure.

Field monitoring team kits (both team I and 2) contained the appropriate protective clothing and respirators, and at the close of the exercise, one team member gave an excellent demonstration of donning the protective c:othing. Both members of plume team I had permanent record dosimetry badges; however, the assistant for team 2 did not have a permanent record dosimetry badge.

Furthermore, because of the field team communications problems, personnel dosimeter readings could not be conveyed to the FCP.

Prior to deployment from the FCP, all team members were issued one direct reading dosimeter with a range of 1500 mR. This dosimeter range (1500 mR) is not appropriate for use with the 3 rem administrative exposure limit, especially since the field teams did not have a dosimeter charger with them in the field. If a single direct reading dosimeter is to be used by each team member, it should, as a minimum, have a range of 0 to 5 R. Furthermore, the direct reading dosimeter worn by team 2 members were reading 50 and 150 mR, respectively, 20 minutes after deployment. Since team 2 had not entered a radiation area at this point, it was evident that the dosimeters werc not functioning properly. These dosimeters were not replaced with properly operating ones prior to their entry into the plume. One other item noted relates to emergency worker exposure control: the field monitoring teams did not have a K1 supply in their field team kits. Although KI was available at the FCP, without radio communications it is unlikely that the KI could have been distributed to the field teams if the need had arisen.

In summary, FEMA Objectives 6 and 7 were met for both plume field monitoring teams.

Objective 8 was met for plume team #1 but not met for plume team #2.

Objectives 5 and 20 were not met by either team.

DEFICIENCY 87-D2 An overall deficiency was identified based upon the number and importance of areas requiring corrective action identified with

[

the plume field monitoring teams, the ingestion fle!d monitoring teams and the ingestion sample lab. The following descriptions and recommendations support the deficiency as it relates to the plume field monitoring team demonstrations.

==

Description:==

The primary communication system between the field monitoring teams and the FCP did not function.

This resulted in excessive delays in repositioning plume field teams to new monitoring and sampling points and resulted in ineffective use of the plume teams once they entered the field (NUREG-0654, II, F.1.d).

Recommendation: Supply operable and effective equipment to communicate between the FCP and field monitoring teams. This will ensure proper direction and control of field monitoring teams to minimize radiation exposure while

conducting field monitoring and sampling activities. Field team communicators need to be trained on proper use of the communications equipment and proper radio protocol.

==

Description:==

Both plume teams failed to demonstrate acceptable emergency worker exposure control. The single I

1500 mR direct reading dos! meter was not appropriate for the 3 rem administrative exposure limit. A member from field team 2 was not wee. ring a permanent record dosimeter, and both members of field team 2 were deployed into the plume with possibly.

malfunctioning direct-reading dosimeters. All field team members were deployed without K1 in their possession (NUREG-0654, II, J.10.e, K.3.a).

Recommendation: A review of emergency worker exposure control is needed, especially with regard to availability of perma' tent record dosimeters, chargers, and effactive use and availability of suitable direct-read dosimeters for the 3 R administrative exposure limit. A review of the procedure for the issuance of El to emergency workers is also needed.

==

Description:==

Significant errors were made by team 2 in the analysis of air sample results. The silver zeolite cartridge was loaded upside down, and calculations made were not in accordance with the procedures (NUREG-0654, !!, I.8,1.9).

Recommendation: Specific training for the analysis of a!r particulate and radiolodine samples should be administered to potential field team members.

AREAS REQUIRIIiG CORRECTIVE ACTIONS 87-A9

==

Description:==

Both plume field teams experienced time delays in initial deployment from the FCP (NUREG-0654, II,1.8).

Recommendation: Prepack field team equipment into kits and consolidate briefings to hasten deployment of the plume monitoring teams.

87-A10

Description:

Direct radiation readings taken by team 2 did not incorporate ground level open and closed window readings to evaluate ground deposition (NUREG-0654, II, I.8).

Recommendation: Procedures should include direct radiation readings to assure that ground level measurements are taken i

to allow evaluation of ground deposition.

1 87-A11

Description:

Plume team 1 was not sure if the conversion factor provided on the air sample calculation sheets was correct for the instruments that were being used. Initially, they used a conversion factor which had a different value in

43 the exponent.

This could lead to orders of magnitude differences in the calculated results (NUREG-0654,11,1.2, I.5).

Recommendation: Provide more training to the field teams with regard to the proper use of the field calculation forms.

Include the derivation of the conversion factor in the training and perhaps include the derivation as a footnote on the calculation sheets.

s AREAS RECOMMENDED FOR IMPROVEMENT

==

Description:==

The air sampling pump for team I was assembled in e

the plume. This can increase unnecessary exposure to workers and possibly can contaminate other resources in equipment !rits.

Recommendation: Assemble filter sampling head beforn going into the plume to collect a sample,

==

Description:==

Air samples obtained by team 1 were not purged with a

cleu: air before counting. This can bias gross sample counts.

Recommendatiom Leave air sampler assembled until the sample counting location is reached. Turn the airpump on for a few seconds to puqe the noble gas from the air cartridge with clear. air from the counting location.

Plume Remedial Del 11 Status At the time of report preparation, the remedial drill to redemonstrate objectives 5, 8 (Team #2) and 20 with regard to the plume monitoring tennis had not been completed. Results from this remedial drill will be documented in an addendum to this report.

2.1.5 Ingestion Phase 2.1.5.1 Full Scale Exercise - August 5,1987 Ingestion Field Monitoring Teams The ingestion field monitoring teams were responsible for demonstrating four exercise objectives.

The scenario called for the ingestion teams to demonstrate activities out of sequence during the exercise. In order to distinguish the two ingestion teams from the plume monitoring teams, the ingestion teams were designated teams 3 and 4.

4

44 The ingestion field monitoring teams were mobilized promptly after notification of the Alert ECL. The team members were mobilized from the Downtown Denver CDH building; one member, the milk sanitarian, reported directly to the FCP. Prior to departing from the FCP into the field, each team was assigned a 45' sector as described in a procedure document prepared for the exercise. Each team was instructed to obtain samples of milk, soll, forage, crops, and standing water (if available).

There was no briefing provided on the assigned sampling priority t. be given to regions within the designated sampling sector, and the teams were not briefed on the p-ojected plume deposition footprint, even though at the time of deployment a projection and limited plume data was available. The ingestion teams heard earlier briefings for the plume teams but were not provided with a specific briefing for the Ingestion pathway prior to their departure from the FCP. Nonetheless, Objective 6, demonstration of the ability to mobilize and deploy field monitor!ng teams in a timely fashion, was met.

Ingestion team 3 easily located the dairy farms cited in the procedures document. This document had the location of dairies within 10 milec of the plant and limited crop information. There was no evidence that dairy and crop information was available for the entire 30-mile IPZ. The milk sanitarian was very familiar with proper sampling procedures and made excellent notes of feeding practices of the dairy herd. A minor equipment problem was noted in that the normal sanitary milk sample is a 6-ounce sample, while the radiological sample is 128-ounces. The only means avalleble for obtaining the sample was by dipping with a small dipper. The collection of a soll sample and the forage sample by team 3 was not done in accordance with the procedures outlined in the exercise procedure document.

One team member was a lant-minute replacement and needed training in taking soll and forage samples. Since a soll sampling template was not ased, the area sampled was not recorded. Similarly, the area covered by the forage sample was not recorded. Finally, team 3 made no attempt to maintain contamination control or to avoid contamination of unused sample containers by the collected samplas. Based on these observations for ingestion field team 3, Objective 9 was not met.

Ingestion field monitoring team 4 also did not meet Objective 9. Milk sampling by the milk sanitarian was demonstrated professionally at a dairy. Sample collection of four feed samples and a vegetation sample also occurred at the same dairy.

The vegetation sampling method used was not in accordance with the exercise procedure document provided to the team.

Soll sampling equipment was available, but actual demonstration of soil sample collection was not provided. No water sampling equipment or supplies were available, and thus no water samples were taken. Some discussion took place of potential crop, vegetation, water, and soll sampling at other locations in the assigned sampling area, but no further sampling took place. The samples taken near the dairy were not within the plume deposition area. The team did not ge into the ingestion zone beyond 10 miles from the plant. Finally, there was almost a complete lack of contamination control in the demonstrated sampling procedure. During sampling and transport of the samples to the FCP, no visible effort was made to prevent cross-contamination of samples, contamination of the outside of sample containers, and contamination of personnel, equipment, and the vehicle's Interior.

l t

45

^

For ingestion team 3, Objective 20 was not m et.

No radiation detection instrumentation was taken into the field, and neither team member had experience or training in the use of such instrumentation. Both team members wore 1.5 R direct-read dosimeters, and one team member had a 200 R direct-read dosimeter. Neither team member had a permanent record dosimeter. One team member went into the field with i

his 1.5 R direct-read dosimeter reading greater than 80 percent of the dosimeter range.

Objective 20 was also not met for ingestion field monitoring team 4. The team members' dosimetry equipment was not in accordance with the plan. The milk sanitarian had two identical,0-1.5 R direct-read dosimeters and did not have a permanent record dosimeter. The health physicist had a TLD and four direct-reading dosimeters (two 0-200 mR, one 0-1.5 R, and one 0-20 R). The team had a dosimeter charger and knew how to read their dosimeters but did not know the maximum dosage allowed without authorization. The team members knew where to go for emergency worker monitoring 1

and decontamination. The team had three survey meters (one CDV-700, one CDV-715,

}

and one CDV-720); the team demonstrated the use of the CDV-700.

In sum mary, Objective 6 was met for both ingestion monitoring teams.

Objectives 9 and 20 were not met for either teams.

DEFICIENCY,

/

\\

87 j -D2 An overall deficiency was identified based upon the number and importance of areas requiring corrective action identified with

,/the plume field monitoring teams, the ingestion field f

/ monitoring teams and the ingestion sample lab. The following

\\ ~f descriptions and recommendations support the deficiency as it relates to the ingestion field monitoring team demonstrations.

==

Description:==

The exercise document used by the field teams had the locations of dairies within 10 miles of the plant and limited crop information. There was no evidence that dairy and crop information was available for the whole 30-mile ingestion EPZ (NUREG-0654, !!, J.11).

l Recommendation:

Develop and document necessary information on land use and crop distributions for the entire j

30-mile ingestion EPZ.

A 1

==

Description:==

One field teams was deployed without any radiation detection instrumentation, and neither of the team members were knowledgeable in the use of such instrumentation (NUREG-0654, l.8 H.7).

Recommendation:

Develop an equipment checklist for ingestion field teams for use prior to deployment into the field to insure that all equipment is available. Train all response personnel in proper use of radiation detection instrumentation.

4'6

==

Description:==

Soll and forage samples were not conducted in accordance with the procedt.res outilned in the exercise procedures document provided to the fletd team members.

Water sampling equipment was not available, and both teams did not demonstrate collection of water samples (NUREG-0654, II, J.!!, N.2.d, 0.4.c).

Recommendation: Redemonstration of ingestion sampling procedures is needed, including proper equipment and techniques for collection of vegetation, soll, and water samples in the region affected by plume deposition based on an accident scenario. Training is suggested on the use of appropria'te procedures for sample collection.

==

Description:==

Neither ingestion field monitoring team practiced effective contamination control in the sample collection procedure (NUREG-0654, J.11).

Recommendation: Review and demonstrate procedures to prevent cross-contamination of samples, co'ntamination of outsides of sample containers, and contamination of personnel, equipment, and the vehicle interiors.

==

Description:==

All team members did not wear dosimetry equipment specified in the plan (NUREG-0654, II, K, K.3.a).

Recommendation:

Proper exposure control protective equipment is needed for the ingestion monitoring teams.

Sultable dosimeters and TLDs should be supplied to teams ir.

conformity with the state plan, and teams should be informed of maximum dose allowed without authorization and procedures to fellow in the event of excess dose.

AREA REQUIRING CORRECTIVE ACTION 87-A12

Description:

The teams were deployed without an adequate briefing on the location of potential plume deposition "footprint." No priority was given to regions within the 45' sector assigned, and furthermore, no sampling was conducted within the plume deposition area (NUREG-0654, !!, I.8).

Recommendation: Develop an approach on the way risk from the ingestion pathway is to be approached. Document the approach in the plan. Train all responders in the approach adopted, assuring that teams be briefed about the priority cf sampling points so that the most significant sampling is not omitted.

47 AREA RECOMMENDED FOR IMPROVEMENT j

==

Description:==

Milk sampling required the use of a small dipper to take a 128-ounce sample.

Recommendation: Supply a larger dipper and funnel so that the sample can be taken with greater ease and speed.

Ingestion Sample Laboratory The field samples were transported from the FCP to the CDH laboratory in the lith Avenue CDH building in downtown Denver. The samples were admitted to the lab in the original sample containers direct from the field. There was no attempt to "double bag" the samples or to perform a radiation reading to insure that samples too hot to properly handle were admitted. (A screening of the samples collected by team 3 was performed at the FCP; however, the results of these measurements were not put on either the sample containers or the paperwork which accompaaled the sample to the Inb.)

~

The lab had adequate analysis instrumentation, which include: a computer-based Ge (LI) detector and gamma analysis system, liquid scintillation, gross alpha-beta counter, and appropriate sample preparation equipment. There was no evidence of any preplanned sample dose rates, which would preclude entry to the lab; however, personnel did state that "hot" samples would not be admitted. In 'idition, there was no evidence that any preplanning had been done to establish countin;.imes for emergency samples.

Lab personnel stated that the normal counting times would be used.

The nuclide list used in the automated gamma analysis included a few short-lived nuclides; however, in an emergency situation, many short-lived nuclides would be expected, and the nuclide list should be modified to include more short-lived nuclides.

Based on thece observation:;, the laboratory analysis port!on of ob8ective 9 for soll, vegetation, water, and milk was not met.

DEFICIENCY

.m

[87-D2 i An overall defielency was identified bped upon the nuiM and i

importance of areas requiring corrective action identified with j

the plume field monitoring teams, the ingestion field

(

bj monitoring teams and the ingestion sample lab. The following

'a" descriptions and recommendations support the deficiency as it relates to the Ingestion sample laboratory demonstrations.

==

Description:==

The radiological laboratory evalusted is set up to do routine analyses of samples.

For the potentisily radiologically contaminated ingestion field samples, no attempt was made to double-bag samples or screen samples to ensure samples too "ho t" were not admitted.

Furthermore, no preplanned dose rates were established

48 which would preclude entry of samples into the lab. Also, counting times had not been established for emergency samples (NU3EG-0654, !!, H.12, J.11, 0.4.c).

• Recommendation:

Ingestion samples received at the s

radialogical lab need to be properly bagged, screened, and tagged to identify and properly handle ' tot" samples.

Preplanning is needed to establish a proto w for precluding entry of "hot" samples into the lab. Counting times need tc be established for emergency samples, rather than using normal counting time.s as stated by the lab personnel.

AREAS REQUIRING CORRECTIVE ACTION None, Reference 87.I12.

AREA ERCOMMENDED FOR IMPROVEMENT

==

Description:==

The nuc!!de list used for gamma analysis in the lab did e

not contain many short-lived nuclides.

Recommendation:

Review the nuclide list with a view toward including more short-lived nuclides that would be present in emergency samples.

2.1.5.2 Ingestion Pathway Field Monitoring and Laboratory Remedial Drill Results - November 4,1987 Based on results of the August 5,1987 exercise, Objectivs 6, 9, and 20 were redemonstrated utilizing 2 Ingestion field tar ms.

All objectives were met with no defielencies or areas requiring corrective action. The following presen.3 a narrative view of the remedial drill followed by specific coinmen'., of the areas requiring corrective action identified at the August 5,1987 e..ercise.

The field ter.ms were pre-mobilized to the forward command post at Fort Lupton.

Prior to deployment to assigned sampling locations, a complete t id comprehensive briefing was given by the Field Monitoring Team Chief. The briefing covered the plant status, results of the plume phase measurements, communications (radios were assumed to be 1:ioperative), exposure limits and reporting requirements, and sampling assignments. The sampling assignments were developed to obtain samples both from within the projected plume footprint and from areas near the proje.eted footprint to establish unaffected (background) areas. The teams checked their equipment, loaded their vein!cles and deployed, in a reasonable time, to their assigned sampling locations.

Team 3 personnel were very knowledgable about the locality and were able to locate their assigned sampling locations quickly. The other team, Team 4, failed to locate their first assigned dairy and instead arrived at one of the dalries assigned to Team 3. This missed location caused no problem since when Team 3 arrived, the sampling assignments were reordered.

Team 4 was able to locate two sssigned surface water sampling locations. Team 3 demonstrated the use of the backup communications (commercial

49 ohone) and coamunicated the change in assignment to the FCP.

Based on these abservations, Objective 6 was met.

Both teams accurately followed the new sampling procedures with regard to vegetation, water and soll. Both teams also demonstrated good contamination control procedures designed to minimize the possible cross contamination of samples and equipment. All team members had three direct reading dosimeters (DRD) and one team member on each team had a permanent record dosimeter. A spare set of DRDs was also deployed with each team. Frequent DRD readings were made and were recorded on the dosimetry recording form. The teams had been instructed during the predeployment briefing on dose limits and reporting requirements. At the conclusion of the sampling sequence Team 3 reported to the TCP (setup at the FCP for this exercise) where additional contamination control procedures were adequately demonstrated. External radiation readings were made on all samples and an additional clean bag was placed over the field sample bag prior to sending the samples to the 1sboratory for anhiv-is.

Objective 20, to demonstrate tne ability to monitor and control emergency wc.

exposure was met.

In accord with the new procedures, samples above a predetermined radiation level were segregated and not sent to the State Laboratory. The allowable samples were transported to the State Department of Ikalth Laboratory wher( all samples were received in the hot laboratory.

All samples were remonitored for smearable contamination radiation levels and prepared (simulated) for counting. Care was taken to minimize sample cross contamination. Objective 9 was met based on these observations.

Ingestion Field Monitoring Teams The following is the status of previous issues related to Deficiency 87-D2 Identifled at the August 5 exercise as presented in Section 2.1.5.1.

All of the issues associated with Deficiency 87-D2 related to ingestion field -

1. j monitoring and the sample laboratory were corrected at the November 4,1987 remedial d-ill. The follow!ng is a narrative summary of actions taken to correct the deficiency as well as the ARCA previously identified at the August 5 exercise.

Th briefing prior to deployment and the assignment of sampling locations demonstrued that a plen to establish the location of high levels of activity and to establish areas where no contamination problems er!sted, had been developed. This ARCA (87-A12) was identified at the August 5,1987 exercise, demonstrations at the remedial drill corrected this issue.

1 The FCP obtained from the State EOC (actually from Dept. of Agriculture) maps and written descriptions of dairy operations in the sectors impacted out to 30 miles.

These maps and descriptions were FAXED to the FCP by the State EOC so that if samples were required from this larger area, the field teams would have been able to locate the sampling sites.

50 Both teams took radiation detection levices into the field and follo~wed their new procedures with regard to radiation measurements at each sampling location.

Both teams followed the new procedures and collected soll, vegetation, and water in accord with the new procedures.

Both teams followed acceptable contamination control procedures. Care was used to assure that sampling equipment would not cross contaminate samples.

The samples themselves were double bagged to minimize contamination problems.

All team members had three direct-read dostmeters of various ranges. One team member on each team had a permanent record dosimeter.

A larger dipper and funnel was included in the sampling equipment. (This item related to an area recommended for improvement identified at the August 5,1987 exercise.)

Ingestion Sample Laboratory The new procedures establish a radiation limit above which samples would be excluded from the laboratory. All samples were rebagged at the TCP (FCP) prior to be transported to the laboratory. All samples were screened for both radiation level and smearable contamination. Still remaining to be established is the minimum counting time for each sample type to assure that the emergency information needed is obtalt.ed and that sample throughput can be maximized.

I DEFICIENCY None.

AREAS REQUIRING CORRECTIVE ACTION None.

AREAS RECOMMENDED FOR IMPROVEMENT

==

Description:==

One team member on each team did not have a e

permanent record dosimeter. Depending on the plan this may not be necessary, however, during the predeployment briel'ng, the teams were told that they would report doses of 200 mr and that I rem was acceptable with approval.

Recommendation:

All personnel must have a permanent record dos! meter.

51

==

Description:==

The maps issued to the field teams, while of a good i

scale, had many extraneous markings which made delt use more difficult.

Recommendation:

Reexamine the maps and delete extraneous markings that appeared to be section lines which are not roads and planning area boundaries.

Descriptiom The vehicles used will in many cases be used for multiple sampling runs. While the teams used good contamination control techniques, it will be virtually impossible to keep the vehicles from becoming contaminated.

Recommendation:

Suggest that the area where samples will be j

stored be covered with plastic or other easily removed material so that there will be less chance of cross contamination between sampling runs. Care should be taken that the area under foot of the personnel not be covered with material (plastic) which could become slippery if wet.

==

Description:==

All of the important information concerning feeding protocol, milking schedules, milk collection frequency, and milk volumes in the sampled tank was not obtained.

Recommendation: Suggest a review of the milk sample record form or label with a view toward listing all of the needed information so that the label or form becomes a check list.

2.2 WELD COUNTY OPERATIONS

)

2.2.1 Weld County EOC The Weld County EOC is located in the Sheriff's squad room which also was used by people whose offices opened into the EOC. At 1500, a complete shif t change of deputies was held, complete with personnel inspection. This activity interfered with emergency operations. As a minimum, a dedicated EOC area is necessary, or at least an area not used day to day by other activities. The EOC met minimum standards for f urniture, space, lighting and telephones. The facility can support extended operations and backup power is tested weekly.

The required maps were avellable, though not posted. The incident emergency level was posted and changed as required. A status board was available, bt:t not used: a "status log" was available for review, and it was kept surrent. Apart from the problem resulting from the day to day use of the EOC area by other Sheriff's personnel, the adequacy of the facil!ty was demonstrated and thus Objective 4 was met.

Activation and staffing of the Weld County EOC commenced with a verified ALERT notification from the utility at 0826. The EOC was activated immediately with staffing, as authorized in the exe.cise guidance, and complete at 0846. Written, current call lists were used to notify emergency personnel. Calls were made by 24-hour duty

~

4 53 personnel. Twenty-four hour staffing was demonstrated through use of a roster. The Sheriff's representative was dispatched to the FCP at 0828, and he maintained communicatlons within the EOC throughout the exercise. Based on these observations, Objectives 1 and 2 were met.

The Weld County EOC was effectively managed by the County Emergency Management CArdinator, as designated in the plan. The staffing of the EOC, namely the Coordinator, was minimal as planned; however, she was In contact with the FCP, other county agencies, and knew locations of their county board members. She was aware of the need for briefings periodically. A copy of the Weld Co. REP pisn was available. This plan was published in 1980, can be considered obsolete, and requires rewriting to incorporate the operational concepts used by Weld Co. In its EOC and relationships with the Forward Command Post. Most noteworthy of the observations were the professional knowledge and dynamic management displayed by the County Emergency Management Coordinator. Because of this performance, Objective 3 was met.

The Weld Co. Sheriff's communications center provided the required support to enable the emergency managers to communicate with all appropriate locations, organizations, and field personnel. All primary systems were availabl 2 and were used as the exercise required.

NAWAS was monitored for the early advisory from DODES.

Emergency operation 2 will be enhariced if a hard-copy communications system !s set up between the FCP and the County EOC; as the Weld Co. representative at the FCP had to transmit messages from outside the FCP in order to assure receipt at the Weld Co.

EOC. Overall, Objective 5 was met.

The Weld Co. EOC played a limited role in public alerting and notification. This is primarily a responsibility assigned to State EOC personnel. As was experienced by other exercise entitles, there were difficulties in receiving some messages, i.e., the NOUE was never sent to the county and, times and responsibilities for accomplishing actions were not clear. It should be noted that the public address, nodule of tl'e siren system did not function during the exercise; there was no intention to activate the siren itself. Overall this Objective (13) was met for Weld County.

Within the EOC's scope of responsibility, evacuation techniques were adequately dmonstrated. Use of Sheriff's patrols were especially effective throughout the exercise in carrying out the evacuation of certain population (pregnant women, children) in a portion of the EPZ, though no impediments developed to impact the evacuation, the EOC was prepared to respond and resolve these matters. Effective access control was carried out by the Roads and Bridges Dept. (simulat-d use of barricades) and traffic control points by the Sheriff's field force.

Especially noteworthy was the technique for determining, locating, and evacuating mobility-impaired citizens. Objectives 15, 16, 17 and 18 were met.

In summary, all objectives were met at the Weld County EOC.

l

53 DEFICIENCIES None.

l AREAS REQUIRING CORRECTIVE ACTION 87-A13

Description:

The existing Weld County Radiological Eraergency Plan is obsolete, having been prepared in 1980, with no changes since. (NUREG-0654, II, P.4, P.5)

Recommendation: The plan must be revised to incorporate organizational and operational concepts developed since j

1980.

87-A14

Description:

The Weld County EOC is temporary, located in dual usage space in the Sheriff's squad room.

Day to day business disrupts emergency operations, and there would be inadequate telephones if the EOC were staffed beyond the minimum authorized for this exercise. (NUREG-0654, II, H)

Recommendation:

The county should estab!!sh an EOC j

location dedicated to emergency management if possible, with i

adequate telephones, and preferably in the same building as the communications center.

1 87-A15

Description:

The Weld County EOC did not receive the Notification of Unusual Event. (NUREG 0654, !!, E.1)

Recommendation:

The utility, state and county should establish written plans and procedures to require that the county receives this emergency classification level.

AREAS RECOMMENDED FOR IMPROVEMEl'T

==

Description:==

It was not evident that a system is in place in the Weld Co. communication center for recording and logging messages.

Recommendation: Establish a logging system if one is not in place.

1

==

Description:==

Messages from the Weld County Sheriff's Department stationed at the FCP were not received at the Weld County EOC unitss the messages were transmitted from outside the FCP.

Recommendation: An outside antenna for the Weld Co. representa-the at the FCP will enhance communications capability.

==

Description:==

The traffic control point (TCP) monitoring kits e

contained dead batteries.

Recommendatten:

Ensure that fresh batteries are available for inclusion into the TCP monitoring kits.

l 1

1

,---,w

54 2.2.2 Fort Lupton Middle School Reception / Mass Care A reception / mass care facility was activated and set up at the Fort Lupton Middle School. The physical layout and space available at the Fort Lupton School is sufficient to support the anticipated response activities. The main school operations are housed in a large air-conditioned brick building. A cafeteria with a capacity to serve over 600 individuals is available for use by the reception / mass care personnel. A large gymnasium can be used for sleeping quarters and as temporary housing for the evacuees. Toilet facilities, including showers are located near the gym. Other rooms in the school can be used for isolation areas, family interview rooms, etc. The nurses' rooms will be utilized for first aid and medical care; arrangements for additional medical assistance have been made with the Fort Lupton Hospital. Based on the adequacy of the facility, Objective 4 was met.

Activation and mobilization of the facility's emergency response personnel were demonstrated using planned notification procedures. The Greely Red Cross received a te'ephone call from the Sheriff's department notifying them to activate the reception / mass care faellity and mobilize staff. The Red Cross representatives placed telephone calls and used a beeper system to alert the school principal and emergency personnel. The reception / mass care facility staff were at the school within 40 minutes.

Organizations represented included:

the Red Cross; school personnel who performed admiristrative, janitorial and support duties; fire department and health department staff who were responsible for the decontamination operation. The ability to support the emergency response activities for an extended time was simulated. Verbal responses were received from the various agencies represented concerning their respective department's ability to support operations on an extended basis.

All organization personnel indicated that they could maintain response functioni for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, but that after that time they would have to rely on support from pre-arranged mutual aid agreements. Based on these observations, Objectives 1 and 2 were met.

The personnel who responded for the exercise play were familiar with their duties and performed sufficiently. They demonstrated the ability to mobilize and set up staff operations, make timely and appropriate decisions, establish communications with required locations (via land line only), and coordinate mass feeding with loaal businesses and school food service. Objectives 3 and 5 were met.

Procedures for registration and radiological monitoring of evacuees were demonstrated at the Fort

• Lupton Middle School.

Overall, these activities were performed well however, some issues were identified.

Several evacuees were processed through the reception / mass care center during the exercise. Upon entering the facility, evacuees were instructed to first go to the Lupton Fire Department where they would receive their initial radiological monitoring and if necessary, decontamination. They would then be asked to return to the center for subsequent monitoring and reception. The fire department is re:ponsible for performi:,

decontamination of personnel and vehicles for the general public with present plans l

providing for the;e activities to occur at the fire department; some distance away from the reception / mass care center. If the fire department is also to provide personnel to conduct initial monitoring at the fire house then this process (as currently established) is a

d

55 extremely cumbersome and ineffielent.

It is recommended that fire department personnel set up their operations at the reception / mass care center grounds and share monitoring activities with the center staff. This would streamline the process, reduce redundancy, and mitigate the potential for further spread of contamination from evacuees and their vehicles. Then, following initial monitoring at the entrance of the reception / mass care center, the evacuees and vehicles could be routed to general parking or the decontamination area, as appropriate.

One Individual demonstrated redlological monitoring at the reception / mass care center.

Monitoring was done very carefully using a CDV-700 survey meter, but the radiation level (1.5 mR/ hour) used for distinguishing whether an Individual was contaminated or not was too high.

Registration of evacuees wr.s performed at the entrance door to the center.

Registration was conducted in a very professional manner insuring that a comprehensive accounting system for'evecuees was complete and legible. Evacuees were checked at the

~:

registration desk for clearance from the fire department monitors.

FEM A objectives (Nos. 1, 2, 3, 4, 5, 27 and 28) assigned to the reception / mass care center were met.

4 DEFICIENCIES None.

AREAS REQUIRING CORRECTIVE ACTION 87-A16

Description:

A radiation level of 1.5 mR/ hour was used as the criteria for distinguishing contaminated from uncontaminated l

Individuals. (NUREG-0654, !!, K.5.a)

Recommendation:

Consideration be given to selecting and designating a lower threshold value (nearer background radiation level) so that all contaminated individuals could be l

Identified and decontaminated.

87-A17

Description:

Evacuees arriving at the reception center were i

directed to leave (without monitoring) and go instead to the fire station for initial monitoring and fecontamination l

followed by subsequent return to the reception center where they could then be monitored again and registered. (NUREG-0654, !!, J.12)

Recommendation:

The procedures for monitoring and decontamination of emergency workers and evacuees should be thought through more carefully, so that staff, facilities and equipment can be utilized more efficiently, and to insure that J

the movement of evacuees is limited. Consideration should be

)

given to co-locating the reception / mass care center and the deenntamination operation, l

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r AREA RECOMMENDED FOR IMPROVEMENT

==

Description:==

Communicathn systems at the reception / mass care l

l center are limited to commercialland line telephones.

Recommendation:

Provisions should be made for a backup communication system (s) which would enhance emergency operations.

2.2.3 Fort Lupton Fire Department Decontamination Center A decontamination center for evacuees, emergency personnel and vehicles was activated at the Fort Lupton Fire Station.

Decontamination procedures were demonstrated for people only, by the members of the Fort Lupton Fire Department.

Set up of the facility and mobilization of the emergency sthff were not evaluated during the exercise. A procedure was available at the fire station which described this process. Hot lines were estab!!shed and four monitoring stations, using CDV 700 meters, were situated on the hot line. A large shower area approximately 20 feet by 20 feet was csed to wash down contaminated personnel with water supplied by a garden hose. A first cid station was assembled in an adjacent area. Protective clothing was available for use by the fire department personnel.

Proudures used for hand!!ng contaminated people at the center were good. The radiological criterla used to determine if an Individual or vehicle was contaminated was too high.

A level of 1.5 mR/ hour or higher is recommended for decontamir.ation.

Although this is in accordance with the state plan, it is in sharp contrast to the i

i 1000 dpm/1000 ml removable contamination and 0.4 mR/ hour total contam: nation criteria also given in the plan. This screening level permits the potential for significant spread of contamination both within this facility and offsite on personnel and equipment. The decontamination center plan speelfled that the facility had a capacity of 110 people per hour; there were no written values on vehicle espacities per hour.

Radioactive waste, contaminated clothing and materials are disposed of in designated barrels. Waste water from the shower operation is discharged directly into the existing r

sewer system, Most of the emergency personnel at the decontamination center were issued proper dosimetry equipment, Objective 20, was therefore met.

Three FEMA objectives (4, 20 and 29) were demonstrated and met by the Decontamination Center operations. One objective (#E) was not tested, DEFICIENCIES None.

57 AREAS REQUIRING CORRECTIVC ACTION 87-A18

Description:

The 1.5 mR/hr decontamination criteria utilized at the Fort Lupton Fire Station appears to be in sharp contrast with the 1000 'dpm/1000 ml(removable contamination) and the 0.4 mR/hr 0 2 cm (total contamination) also given in the state plan. The 1.5 mR/hr criterla would result in potential for widespread contamination trackout. (NUREG-0654,11, E.5.a)

Recommendation: The screening and decontamination criterla should be amended downward to enhance contamination control. The 1000 dpm/1000 mi and 0.4 mR/hr criterla appear to be more appropriate and should be reflected in the procedures.

AREA RECOMMENDED FOR IMPROVEMENT

==

Description:==

The water used for decontamination of personnel came directly from a garden hose and was cold.

Recommendation: Consideration should be given to providing warm

{

or tepid water for decontamination of personnel. This would help in ensuring a more effective and comfortable operation.

2.3 MEDICAL DRILL - SEPTEMBER 30,1987 The Fort St. Vrain medical emergency exercise was conducted as a separate drill on September 30, 1987. Objectives 5, 30 and 31 were tested during this drill. The drill required onsite response by utility operations, health physics and security staff. Offsite response was demonstrated by off-shift personnel from the Weld County Ambulance Service ard staff from St. Lukes Hospitalin Denver.

I 2.3.1 Weld County Ambulance Service j

The onsite resident NRC inspector evaluated the response to the scenario that

{

resulted in contaminated and injured-contaminated workets. A request for an ambulance for the simulated injured-contaminated worker at 0816 resulted in arrival of a Weld County Ambulance at approximately 0830.

The ambulance left the plant at approximately 0844. While enroute to St. Lukes Hospital, the ambulance crew contacted the hospital at 0848 through the Weld County Communication Center in Greely. The hospital was not: fled of the situation at 0855.

No further attempt was made by the ambulance crew to contact the hospital to eenvey ETA or provide additional patient Information. When the ambulance arrived at the emergency room entrance, the receiving hospital staff personnel were briefed on the patient's condition at approximately 0948. Following the briefing and patient transfer the ambulance crew departed. During the drill debriefing session, the hospital staff had

58 Indicated that better and more frequent communication wes needed between the ambulance crew and the hospital with regard to ETA and patient status, it was Indicated that the letter of agreement with the Weld County ambulance service specifies the type of patient information the hospital staff requires to properly prepare for injured-contaminated patients. Apart from this shortfall, it was determined that Objective 5 was met for the medical drill.

Prior to the transfer of the injured-contaminated worker from the accident site to the ambulance, the worker was surveyed, found to be contaminated, and essentially isolated from contaminating surrounding areas, including the ambulance. A utility health physicist rode in the ambulance and acted as a player / controller. In consultation with the ambulance paramedics, excellent contamination control procedures were either demonstrated or described. One confusing and potentially problematic situation arose in the ambulance when the utility health physicist "tagged" the patient at being "injured, with no contamination" also referenced as a "Category 1" patient condition. This was clearly inconsistent with actual contamination readings found on the patient's wound at the accident site. The ambulance crew and the health physicist nevertheless treated the patient as if she was contaminated. It was evident at the post-drill review that a review is needed of the present system of tagging patients. Overall, Objective 30 was met by 7

the Weld County ambulance service.

DEFICIENCIES None.

AREA REQUIRING CORRECTIVE ACTION 87-A19 Descriptions it was evident that the St. Lukes Hospital staff should have been kept better informed on patient status and ETA throughout the trip from the plant to the hospite.l.

(NUREG-0654, F.2)

Recommendation: Raview procedures to ensure that while in transit, patient status information and ETA are conveyed to the hospital staff to ensure that appropriate resources are available to treat incoming injured-contaminated patients.

AREAS RECOMMENDED FOR IMPROVEMENT l

None.

2.3.2 St. Lukes Hospital l

The emergency room staff and facility at the St. Lukes Hospital were utilized to provide medical treatmer.t for an injured contaminated individual. Notification that a patient was being transported to the hospital was received at 0855. The notification call l

l l

59

)

came, via commercial telephone from St. Anthonys Hospital, in Denver. Upon request from Weld County, St. Anthonys made the call to St. Lukes to notify them and relay l

Information that had been received from the accident scene at Fort Saint Vrain. The emergency room was informed that the patient was a female, age 29, with a raGologically contaminated injury to her arm. An estimated time of arrival of 0925 was i

given to the hosphal.

c Upon notification, mobilization procedures were initiated as the emergency room 4

staff prepared to receive the contaminated injured.

Numerous hospital staff, from various departments, were involved in set up and preparation of the emergency room fec ;lties. A hot area was established and secured from the rest of the emergency room. Appropriate emergency room staff dressed in protective clothing, complete with face masks, double gloves and bootles.

Security guards were positioned to prevent unauthorized entry. It took the hospital staff approximately 20 minutes to set up the emergency room snd make all preparations to receive the patient.

I Communications were not established with the in-bound ambulance, while in transit to the hospital. Due to the nature of the injuries sustained by the patient and the minor amounts of contamination it was not Imperative that her conditions and vital signs 1

be communicated to the hospital. However, the emergency room staff should have been kept informed on updated arrival times. In addition, the operation of this important communication link should have been tested to verify its efficiency.

j d

The ambulance arrived at the hospital at 0947 and immediately discharged the

)

patient. There was some confusion with the transferring of the patient from the gurney l

used to transport her in the ambulance to the hospital gurney. The emergency room staff had prepared a gurney with plastic covering for the patient to be moved to upon arrival

~

at the hospital. This transfer was to occur outside the emergency room in the receiving Due to the nature of the injuries, with consideration given to the degree of area.

contamination on the patient, the health physicists at the hospital decided that a transfer i

outside the emergency room was not necessary. Therefore the patient was brought into the hospital on the gurney from the ambulance. When the ambulance was released and i

ready to leave the hospital, the patient had to be transferred to the emergency room gurney. This process was a bit cumbersome and difficult within the confines of the treatment room. Hospital procedures provide for transfer to occur upon arrival of the ambulance, outside the emergency room, with the health physicists having the option to alter the process. Consideration should be given to requiring immediate transfer of the i

patient to the hospital gurney.

Emergency room staff demonstrated appropriate equipment and techniques for

~

decontamination of an injured, contaminated patient. Proper precautionary metsures 3

were taken to monitor and prevent the spread of contamination including: dry and liquid wastes were contained and properly disposed; plastle tarps were laid out; air vents were sealed; a portable X-ray machine was used and isolated from potential contamination; plastle gloves were changed as necessary; dosimeters were issued to staff; and the equipment, supplies and personnel were monitored. A health physicist from the utility accompanied the injured individual to the hospital from the aceldent site.

He was j

4 available at the emergency room to assist the hospital staff.

i i

L t

J

60 Medical procedures demonstrated were appropriate to the situation and injury.

Two staff doctors attended the patient and prepared her for further treatment in the operating room (operating room procedures not included in drill).

Following the release of the patient from the emergency room for transport to the operating room (simulated), the doctors and emergency room staff were mon!tored and disrobed using approved procedures on the established hot line.

DEFICIENCIES None.

AREAS REQUIRING CORRECTIVE ACTION None.

AREAS RECOMMENDED FOR IMPROVEMENT

==

Description:==

The system used to notify St. Lukes that an injured contaminated patient was being transported was not a direct link.

The call originated at the utility, then to Weld County, to St.

Anthonys Hospital and finally to St. Lukes.

Recommendation: The established direct link to St. Lukes Hospital should be used.

J e

e h

6

61 l

3 TRACKING SCHEDULE FOR STATE / LOCAL ACTIONS TO CORRECT DEFICIENCIES AND AREAS REQUIRING CORRECTIVE ACTION Section 2 of this exercise report has provided a listing of deficiencies and/or areas requiring corrective action with recommendations noted by Federal evaluators during the exercise and drills conducted as appropriate. The evaluations were based on the applicable planning standards and evaluation criteria set forth in Section !! of the NUREG-0654, FEMA-1, Rev.1 (November 1980) and pre-approved exercise objectives.

The FEMA Region VIII Regional Director is responsible for certifying to the FEMA Associate Directne, State and Local Programs and support, Washington, D.C., that any deficiencies and areas requiring corrective action noted in the exercise will be correctert and such corrections will also be incorporated into the emergency response plans as appropriate.

FEMA Region Vill may request that the State of Colorado and local jurisdictions participating in the Fort St. Vrain exercise and remedial drills submit measures that they will take or intend to take to correct those problems found by the Federal evaluators. If corrective actions are necessary, FEMA Region VI!! will request that a detailed plan, including dates for scheduling and implementing corrective actions, be provided if such actions cannot be instituted immediately.

Table 1 provides by jurisdiction a consolidated summary of all Deficiencies and Areas Requiring Corrective Action. The table is designed so that spece has been allowed to add (1) the proposed corrective actions that have been recommended and (2) the projected and actual date of completion.

j

TABIE I Remedlel Acticas for the 1987 Fort St. Vrain Escrelse and Itemedle! Drlins Page 1 of 26 FEMA Deficiencies and/or Areas Requiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action - with FEMA /RAC Objective NURFC-0654 State (S) and Local (L) Proposed Completion Local Corrective Actions and Completion Secrmsendations for Correction No(s)

Reference Corrective Actions Date Determination of Adequacy Date STITE ROC Deficiency 87-91 mesc ri pt ies:

Once the 13, 14 A.2.a.

Revise procedures and ass g:a 12/11/8F Deficiency corrected 12/11/87 decision had been made to E.6 staff responsibilities to assure implement PARS and draft Appendia public alerting and notification public A&M messages, it took 3

occurs within 15 minutes.

approminately 44 minutes in one instance and at least 25 minutes in another to develop the message and transmit the message to the public A&M stations. FEMA requires that this process take na longer

han 15 minutes. The content of one message was incon-sistent with ti.e correspond-ing news releases recosusend-ing evacuation of children and pregnant e<xn.

Later in the esercise, news releases were used fer public A&M messages.

Finally, it was not clear as to the procedure for assuring that the NOAA public alerting and notifica-tion messages are consistent in content and coordinated with the secondary, and particularly, the tertiary Platteville siren, activation and public address announce-meats.

)

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TAltlE I (Cent %0 Page 2 of 26 FEMA Deficiencies and/cr Areas Sequiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action -- with FEMA /RAC Objective NUREC-0654 State (S) and Local (L) Proposed Completion Local Corrective Actions and Completion Receasendations for Correction No(s)

Reference Corrective Actions Date Determination of Adequacy Date STATE ESC (Cent'd)

Deficieecy (Cast'd)

Secomandat ien t Review and.

if necessary, modify SEOC procedures to ensure that once a decision has been made to issue a

public A&M

message, the message is developed and sent to appro-priate entities within 15 minutes.

Assign specific a

individual er individuals who have been t rained in, and are responsible

for, drafting public A&M messages.

The procedure should ensure that the content of the primary public A&M messages is consistent with the backup systems as well as timely.

Consider development of pre sc ri pt ed puelic A&d messages that are specific to sector (s) or zone (s) af fected by protective action recom-sendations. Far esemple, for each sector or zone affected by FARs. consider developing an indes to identify boundaries described by common landmarks.

Ensure that the primary focus of public A&M messages is to inform the public of basic protective measures and not i

. 2 m

TAMIE I (Cont *4 Page 3 of 26 FEMA Deficiencies and/or Areas Requiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action - with FEMA /RAC Objective NUREC-06S4 State (S) and Local (L) Proposed Completion Local Corrective Actions and Completion Recommendations for Correction No(s)

Referes.ce Corrective Actions Date Determination of Adequacy Date SY1TE EOC (Cast *4)

Defiesency (Cast'd) use press release format and information for general public distribution.

The purpose and audiences for these two types of messages are distinctly different.

Areas Requiring Corrective Action 87-Al Descriptions The Natifica-1 E.1 SEOC was not operational at 12/87 tion of unusual Event was not MOUE.

PSC did call State using received at the SEOC.

the State Emergency Number.

CSP Rece - ndatioet Determine Denver r-Center did receive 7

the reason for this problem, the call.

As of Dec 87 all and provide training to notifications go directly to Weld appropriate individuals to Co.

ensure that emergency classifications are relayed property to the State EOC.

87-c2 Descripties:

The Colorade 3

F.4. P.5 The Colorado RERP will be revised 03/89 RERP plan and procedures as required. FSCC has offered to

(, hen available) are outdated assist the State and Weld County and do not reflect the with the revision by hiring a conc ept of operations contractor to work with the State demonstrated during the and Weld Cownty, at PSCC capense.

esercise.

For e s empl e, the SEOC dose assessment role has a

been redefined, public starting and notiiication procedures as defined in the plan were not carried out and demonstrated, and internal e

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'MlllE 1 (8'on1W Fage 5 of 26 FEMA Deficiencies and/or Areae Requiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action - with FEMA /RAC Objective NUREC-0654 State (S) and local (L) Proposed Completion local Corrective Actions and Completion kecommendations for Correction No(s)

Reference Corrective Actions Date Determinaties of Adequacy Date 8EDIA CENTER Deficiencies None.

Arese Requiring Corrective Acties 87-A4 Descriptient Although five 4

C.3.a A

meeting to asses,s FIO 12/88 communications needs is scheduled different organisations were represented im FIC work area for April 1988.

Required in the state EOC, there were procurement actions, if needed, uilt be initiated.

riens and only two telephones.

In an actual radielegical emergency procedures will be revised, if even more organisatices would necessary.

require work space and casununicaticas equipment.

Becemmendetise The telephone needs of the principal organizations should be essessed and an adequate number of telephones provided. In future planning assessmente, attention should be paid to the space and equipment needs ei the principal ergenizations without losing sight of the advantages of having all Plos work in close presioity.

87-G5 Descriptient There were 25 C

Revise procedures and assign 12/11/87 inconsistencies between press staff responsibility to provide releases sad public A&M better control over the release announcements.

In additien, of information and to improve en one occasion the press was SEOC staff coordination.

provided information on a e

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TABIE I (Cont *4 Page 7 et 26 FEMA Deficiencies and/or Areas Requiring Esercise Proposed FEMA Evaluaties of State sad Actual Cmrective Action - with FEMA /RAC Objective NUREC-0654 State (5) and Local (L) Propresed Completion local Corrective Actions and Completion Rec - ndations for Correction No(s)

Reference Corrective Actions Date Determination of Adettuacy Date MEDIA CENTER (Cont'd)

Areme Reaguiring Corrective Acties (Cent *d) final version of the press release.

In general, the process should werk in reverse. The emphasis should be on getting emergency instructions to the public out ever the public A&M networhal the press releases should include that inf0rma-tien but only after it has been disseminated wie official channels to the affected areas.

Press releases, because they may address a

variety of

subjects, some in detail, normally de not lead them-selves to being used as emergency messages to the public.

acce h tient The practice of basing public A&M messages on the content of prios re-leases should be discon-tineed.

FUBefeaD CDeceAmp POST Deticiencies None.

o O

e A

a 4

TAttlK i (Coat's0 Page 8 a,f 26 FEMA Deficiencies and/or Areas Sequiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action - with FEMA /RAC Objective NUREC-0614 State (5) and Local (L) Proposed Completion 14 cal Corrective Actions and Completion Recomumendations far Correction No(s)

Reference Corrective Actions Date Detereinstion of Adequecy Date rotuaas r===mn post (Cent'd)

Arese Requiring Corrective Acties SI-Al Drecriptient The Ingestien J.l!

Review current EPA FACs and 03/89 PACS in current use are out update appropriate

plans, of date.

The decision to use procedures and checklists.

milk F pr cheese rather than condew it could result in potential p blic health problems.

Recommendatient It is receaumended that CD6a update their plan to include current EPA PACS for the ingestion pa t hies y.

SF-A8 Descriptient The State DODEs 5

F Required ceammunications e<avi pment 03/88 Mobile Comuevan had equipment will be repaired / replaced, as problems and did not have required.

Two way radio com-Weld Cemety Sheriff Depart-munications between traffic ment radio frequencies on control point field personael and hand.

This prevented direct the FCP will be available, two-way radio c - =ications between Weld County sheriif *e fictd persecnel and the FCP wie DODES comunwan.

acceanendetiem1 The communications equipment should be empeditiously repaired and Weld County Sheriff De pa rt ment radio frequencies should be avaalabte in comuevan at all tsees.

- - - - - - - - - -~

3 I

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TAB 12 I (Coat *4 Fase 11 of 23 FEMA Defi-ciencies and/or A.eae Requiring Esercise Proposed FEMA Evaluation of State and Actual Correctsee Action - with FI,MA/RAC Objective sfuaEC-06%

State (5) and Local (L) Iroposed Completion local Corrective Actione mad Completion Recommendations for Correction Iso (s)

Reference Corrective Actions Date Determination of AJequacy Date e

FIDet FIE12 sukul19 misc TEAles (Cent'd)

Beficiency (Cent'd)

pewded, esgweis s ly witse regaaJ to availability of permanent record dosi-

metete, chargers, and effectsve use and availability of suitable dsrect read desineters for the 3 8 administrative e s po sure limit.

A review af the procedcre for the issuance of Ki to emergency workers is also 8

U needed.

Descriptient Significant errors were made by team 2 in the analysis of air sample results.

The silver seelite cartridge was leaded upside down, and calculations made were not in accordance with the procedures.

Recenseadatises Speci fic training for the analysis of air particulate and radioiadise samples should be administered to potential field team members.

4 0

4 g

D

-q

TAB 121 (CentW Page 12 of 25 FDeA Deficiencies and/or Arese sequiring Esercise Proposed FDeA Evaluation of State and Actual Corrective Action with FDeA/RAC Objective NUREC-0654 State (S) and Local (L) Freposed Completion Local Corrective Actions and Completion acceammendations for Correction He(s)

Reference Cerrective Actions Dste Determination of Adequacy Date l

l rtasar rissa neestivaleC Tuases (Cest'd )

Areme Seguiring Corrective Actions 87-A9 Seacriptions Both plasme 6

1.8 Redemometrate initial deployment 03/88 field tease esperiencee time of plume field teams from Ene delare in initial deployment FCP.

irem ahe FCF.

Beca h tiset Prepack lield team equipment inte bits and censolidate brief-ings to hesten deployment of t he plume monitoring teams.

87-c10 Descriptions Direct radia-F

!.8 Ret emons t rat e procedures for 03/88 tien readings takee by team evaluating ground deposition.

w 2 did set incorporate ground level open ad closed window readings to evaluate ground deposition.

Seceamendatient Procedures shoulJ include direct radia-tien readings to assure that ground level measuremente are tahem to allow evalue-tien of ground deposition.

CF-cIl Desc ri pt iees Plevne team 1 8

I.S.

Procedures will be revised and 0)/88 was not sure if the conver-I.9 plume team members trained with e6es facter provided on the regard to the proper use of the air sample calculation field calculation, forms.

sheets was correct for the instrumente that were being used.

Initsally, they used

TAltl.E I (Cent *d)

Fase 13 of 25 FEMA Deficiencies and/or Areas Requiring Esercise Propesco FDIA Evaluaties of State and Actual Corrective Action ~ with TDIA/RAC Object ive NURECH454 State (S) and Imcal (L) Proposed Completion local Corrective Actione and Ceepleties Recommendations for Carrection Ne(s)

Reference Corrective Actions Date Determination of Adequacy Date FLIAIE FIEIA NDEBIMBlWC TEasIS (Cast'd)

Areas Seguiring Corrective Acties (Caet'd) a conversies facter wenich had a different value in the esponent.

This could lead to orders of magnitude dif-forences la the calculated results.

Bec " -alens ProviJe more training to the field tease wit h regard ce the proper e.se of the field calculatise fe ws.

Include 2

the derisation of the conwcrosen fatter in the tr.aia N and perhape seclud.

1he istivst*om tJ e Teotnota s 7,

e..,.,-...

3 3,Bru.*.T14mf Ff CD P3SIPJEPWM I

osfielswey t

a 1 * -02 as everall de iciency ag 9,20 I.'d, Precedc es will be revised and 11/4/4F All of the iss

's associated 11/4/87 identaffed Lsed pen the J.ll.

anaestica trae membeer tr ained to with Deficiency sF-N (-elated neaAes sai invertence of E.F.

meet Ow kc.sives 9 **1 20 to the ingestice.

Vi+ld 1 areas requi-ing cerrective N.2.4 W,

emitwt g to e wwe corrected ett sez.

sdeetitied witA the K.).a.

W objectises met.

plume tield aceitering tease, 0.4.c I

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TAHl.L 1 (Cont'd)

Page 15 of 25 FEMA Deficiencies and/or Areas Requiring Esercise Proposed FEMA Evaluation of State and Actual Ctrrectit-Action - wi'.h FEMA /RAC Objective NUREC-0654 State (S) and Locat (L) Proposed Completion Local Correctiva Actions and Completion Recomuncedations for Correction No(s)

Reference Corrective Actions Date Determination of Adequacy Date INCESTIOel FIEIA HDatt f0EINC TEANS (Cont'd)

Deficiency (Cont'd)

. in the use of such instru-mentation.

Mec - ndation:

Develop an equipment checklist for ingestion field teams for use prior to deployment is.c o the field to insure that all equipment is available.

Train all response per*,conel in

~

proper use of radiation detection instrumentation.

M

==

Description:==

Soil and forage samples wrc not i_onducted in accordarice witt.

the procedures outlined in the exercise procedures document pro-vided to the field teac members.

Water samplang equipment was not avail-able, and both teams did not demonstrate collectica 3

of water samples.

1 Mecommendetion Redemon-stration of ingestion sampling procedures is

needed, ku luding proper equipment and t echniq.se s for collection of vegeta-

tion, soit, and water i

1 9

4 4

e 4

g

} '

L s~

m

=

s d

s TABLE 1 (Cont'd)

E Page 16 ef 25 FEMA Deficiencies and/or Area., Requiring Esercise Proposed FEMA Evaluatica of States and Actual Corrective Action * - with FEMA /RAC Objective NUREC-0654 State (5) and I,ocal (L) Proposed Completion 1,0 cal Corrective Actions and Completion Recommendations for Correction No(s)

Reference Corrective Actions Data Determination of Adequacy Date INCESTION.?IB A MoutTOEIMC TEAT:3 (Cont'd)

Det ciency (Cont'd) samples in the resto-affected by plume deposi-tion based on an accident scenario.

' raining is suggested on the use of appropriate procedures for sample collection.

Desc ript ion t Neither ingestion field monitoring team practiced effective contamination control in the sample collection U

procedure.

Recommendations Review and demonstrate prw edures to pre ee.it cross-contamination of samples, contamination of outsides of sample containers, and contamina*. ion af person-

nei, equipment, ar ~

%e vehicle interi Descrirtion:

team I

members did not dosi-metry eq.sipment 1.

ified in the plan.

Recommendat ion:

Proper esposure control protec-l tive equipment is needed a

. TABLE i (Cont'd)

Page 17 of 25 FEMA Deficiencies and/or Areas Requiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action -- with FEMA /RAC Objectave NUREC-0654 State (S) and Local (L) Proposed completion Local Correceive Actions and Completion Rocosamendations for Correction No(s)

Refereice Corrective Actions Date Determination of Adequacy

Date, INCESTIces FIELD MONITOEING TEANs (Cont'd)

Deficiency (Cont *d) for the ingestion monitor-ing teams.

Suitable dosimeters and TLDs should be supplied to teses in conformity with the state plan, and teses should be intormed of maaimum dose allowed without authoriza-tion and procedures to follow in the event of i

excess dose.

5 Aresa Requiring Correctivr. Action 8FC12 Descriptions The teams were 6

I.8 Procedures will be revised and 11/4/87 SF-Al2 corrected at remedial 11/4/87 4

deployed without an adequate plume team members trained with drill.

briefing on the location of regard to plume deposition and potential plume deposition proper team approach.

"footprint." No priority was given to regions within the 1

45*

sector

assigned, and 4

furthermore, no sampling was

]

conducted within the plume deposition area.

i Becommendation:

Fevelop as approach on the way risk from the ingestion pathway is to be appree'_hed.

Document the approa.th

'.a toe plan.

Train att ersranders in the spproac!.

adopted, assuring tret teams be briefed about e

1 e

t 4

'=

e 5

'b

0 2

TABLE I (Cont'd)

Page IS,of 25' FEMA Deficiencie and/or Areas Requiring Exercise Proposed FEMA Evaluation of State and Actual Corrective Action - with FEMA /RAC Objective NUllEC-0654 State (S) and Local (L) Proposed Completion Local Corrective Actions and Completion Recomumendations for Correction No(s)

Reference Corrective Actions Date Determination of Adeqmcy Date INCESTION FIELD MONITORING TEANS (Cont'd)

Areas Requiring Corrective Action (Cont *d) the priority of sampling points so that the most significant sampling is not omitted.

INCESTION SAMPlJC IAFORATORY Deficiencf 87.12 An overeil deficiency was 9

H.12, Procedures will be revised and 11/4/8?

The issue associated with 11/4/87 3

identified based upon the J.II, laboratory parsonnel trained to Deficiency 87-D2 related to nwnbe r and importance of 0.4.c meet Objective 9.

areas requiring corrective the Ingestion Sample Labora-action identified with the Lory has been corrected and plume field monitoring teams, the objective met.

the ingestion field monitor-ing teams and the ingestion sample lab.

The following descriptions and recomumenda-tions support the deficiency as it relates to the inges-tion sample laboratory demonstrations.

Descriptient The a

radiological laboratory evaluated is set up to do routine analyses of samples.

For the poten-tially radiologically f

contaminated ingestion l

t I

TABLE 1 (Cont'd)

Page 19 of 2%

1 FEMA Deficiencies and/or A-eas Requiring Esercise Proposed FEMA Evaluation of State ana Actuiu Carrective Action ~ with FEMA /RAC Objective IsuREC-0654 State (S) and 1.ocal (L) Proposed Completion 1.ocal Corrective Actions and' Completion Recommendations for Correction No(s)

Reference Corrective Actions Date Determination of Adequacy Data IIICEST10el SAMP12 e aanma1ORY (Cont'd)

Deficiency (Coet'd) field samples, no attempt was made to double-bag samples or screen samples to ensure samples too "hot" were not admitted.

Furthermore, no preplanned dose rates were estab-lished which would pre-clude entry of samples into the lab.

Also, counting timec had not been established for emergency samples.

Recommendatioot Ingestion samples received at the radiological lab need to be properly

begged, g

screened, and tagged to l

identify and property handle "hot" samples.

Preplanning is needed to establish a protocol for precluding entry of "hot" samples into the lab.

Counting times need to be established for emergency samples, ratlwr than using normal counting times as stated by the lab Mrsonnel.

3 0

e

_o e

1

.m

]

.e TABt.E 1 (ContW Page 20 o,f 25 FT.MA Deficiencies and/or Areas Requiring Exercise Proposed -

FEMA Evaluat '.an of State and Actual Carrectave Action with FEMA /RAC Objective NUREG-0654 State (S) and local (L) Proposed Completior.

Local Corrective Actions and Completion Recosseendations for Correction No(s)

Reference Corrective Actions Date Determination of Adequacy Date luCESTION SAMPLg Isan8A10RY (Coet'd)

Areas Requiring Corrective Action Mone, Reference 87-D2 WEID QMarTY ROC Deficiencies None.

Arw.s Requiring Corecctive Action

'87-A13

Description:

The existing 3

P.4. P.5 The Weld County RE3P (an annen of 03/89 Weld County Radiological the State RERP) will be revised Emergency Plan is obsolete, as required during the revision having been prepared in nf the State RERP (Refs 87-A2).

1980, with no changes since.

tecommendation The plan must be revised to incor-porate organisational and operational concepts developed since 1980.

8 7-t.14 Descriptioet The Weld 4

H Weld County will continue to 03/89 Coonty EOC is temporary, study the suggestion of an EOC located in dual usage space dedicated to emergency in the Sheriff's squad management.

The emergency room.

Day to day business management coordinator position, disrupts emergency opera-vacant since Nov. 1987, has been tions, and there would be recently filled.

The extensive inadequate telephones if the review of this and other EOC were staffed beyond the associated concerns is a priority uithin Weld County.

l

~_

TABl21 (Coct*d)

Page 21 of 25 FEMA Deficiencies and/or Areas Requiring Esercise Proposed FEMA Evaluation of State and Actual Carrective Action - with FEMA /RAC " Objective NUREC-0654 State (5) and Local (L) Proposed Completion Local Corrective Actions and Completion l

Recosamendations for Correction No(s)

Reference Corrective Actions Date Determination of Adequacy Date l

l WEl.D COUNTY Eoc (Cont'd)

(rsea Re v i2ing Corrective Actice (Cont'd) t minimum authorized for this exercise.

Rec - adation The county should establish an EOC tocation dedicated to emergency management if

possible, with adequate telephones, and preferably in the same building as the communications center.

87-A15 Description The Weld 1

E.1 Weld County was not required to 12/87 g

County EOC did not receive be notified of the NOUE.

Current the Notification of Unusual procedures (RERP Cha.nge #2) now Event.

require all notifications, Recommendation The including NOUE, be passed to Weld utility, state and coenty County by the PSC.

should establish written plans and procedures to require that the county receives this emergency classification level.

FORT IEFTON MIDDt2 SCHOOL RECEPTION / MASS CAME I Deticiencies Mons.

e e

t

+_

e=

a e

g

i ',

ni t

TAB 121 (Cont'd)

Page 22 of 25 e

FEMA Deficiencies and/or Areas Requiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action -- with FEMA /RAC Objective NCREC-0654 State (S) and 1.ocal (L) Proposed Completion Local Corrective Actions and Completion Recoaumendations for Correction No(s)

Reference Corrective Actions Date Determination of Adequacy Date FORT l.UPTON MIDCLE hCM00L RgCEPflos/ Mass CAas (Cont'd)

Areas Requiring Corrective Action 87-A16

Description:

A radiation 27 K.S.a The Colorado Department of lieanth 03/89 level of 1.5 ma/ hour was uilt review current threshold used as the criteria for levels

and, wiie re appropriate, distinguishing contaminated revise them.

from uncontaminated individuals.

acc - ndation:

Considera-tion be given to selecting and designating a

lower threshold value (nearer background radiation level) so that all contaminated on individuals could be identi-fied and decontaminated.

87-AIF Descrigtion:

Evacuees 28 J.12 The entire concept of monitoring 03/89 arriving at the reception and decontamination of emergency center were directed to uorkers and evacuees will be leave (without monitoring) reviewed in-depth during the and go instead to the fire revision o the State / County f

station for initaal monitor-RERPs.

Tt.e s e recoassendat ion s,

ing and decontamination alwag with

others, will be followed by subsequent considered.

return to the reception center dere they could then be monit ored again and registered.

Receaseendet ion:

The procedures for monitoring and decontamination of emergency workers and evacuees should be thought

TABLE I (Cont'd)

Page 23 of 25 FEMA Deficiencies and/or Areas Requiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action - with FEMA /RAC Objective NUREC-0654 State (S) and Local (L) Proposed Completion Local Corrective Actione and Completion Reconnendations for Correction No(s)

Reference Corrective Actions Date Determination of Adequacy Date FORT LUPTUel MIDDLE SCHOOL RECEPTIORP/ MASS CARE (Cont'd) frsas Requiring Corrective Action (Comt'd) through more carefully, so that staff, facilities and equipment can be utilized efficiently, and to more insure that the movement of evacuees is limited.

Consideration should be 4

given to co-locating the reception / mass care center and the decontamination operation.

I FORT LUP10ef FIRE DEPARTMENT DEccefTAMIMATIost CENTER D1f it.:iencies 4

None.

frsas Requiring Corrective Action 87-A18 Description The 1.5 mR/hr 29 K.5.s The Colorado nepartment of IIealth 03/89 decontamination criteria uill review "screening" and utilized at the Fort Lupton "decontamination" criteria used Fire Station appears to be for contamination control and in sharp contrast with the recommend appropriate changes.

1000 Jpa/1000 ml (removable g Plans, procedures, and training, contamination) and the 0.4 uill reflect new or revised d/hr @ 2 cm (total contami-standards.

ution) also given in the i

4 e

o 1

b 4

TABLE 1 (Cont'd)

Page 24 of 25 FFMA Deficiencies an#for Areas Requiring Esercise Proposed FEMA Evaluation of State and Actual Corrective Action with FEMA /RAC Objective NUREC-0654 State (S) and Local (L) Proposed Completion Local Corrective Actions and Completion Recommendations for Correction No(s)

Reference Cortective Actione Date Determir.ation of Adequacy Date 1

FORT IEFTeel FIRE DEPARTMEart DECoelTAffluATION CEntrEE (Cont'd)

Areas Requiring Corrective Action (Cont'd) state plan.

The 1.5 mR/hr criteria would result in potent.at for widespread contamination trackout.

Recommendation:

The screening and decontamina-tion criteria should be amended downward to enhance contamination control.

The 1000 den /1000 ml and 0.4 mR/hr criteria appear to be 3

more appropriate and should be reflected in the procedures.

WELD CDLAfTY AMSULAafCE SERVICE Deficiencies None.

A.rsas 2cquiring Corrective Action 87-A19 Descriptient It was evident 5

F.2 Current procedures will be 03/89 that the St. Lukes Hospital reviewed and revised where staff should have been kept necessary to ensure that better informed on patient receiving hospitals are kept status and ETA throughout better informed and updated as to che trip f raer Lbe plant to patient status and ETA.

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e 87 4 EVALUATION OF OBJECTIVES 4.1

SUMMARY

OF FEFA OBJECTIVES REMAINING TO BE MET Table 2 provides listing of those FEMA Objectives which, according to the Region VI!! Interim RAC Chairman, have not been satisfactorily met or tested and which should be incorporated into the exercise objectives on or by the sixth year of the 6-year l

period in which all the objectives raust be tested. As noted previously in this exercise report, this August 5,1987 exercise represented the end of the six year cycle for the Fort Saint Vrain Nuclear Generating Station.

TABLE 2 Summary of PEMA Objectives Remaining to be Met at the Fort St. Vrain Nuclear Generating Station Jurisdiction (s) and FEMA Objective Remaining Issues, Date 5.

Demonstrate ability to communicate State Plume Field Monitoring, with all appropriate locations, FCP, Deficiency 87-D2, 8/5/87 organizations and field personnel 8.

Demonstrate appropriate equipment State Plume Field Monitoring, and procedures for measurement of Deficiency 87-D2, 8/5/87 airborne radi i aslowas10~9odineconcentrations uCi/cc in the presence of noble gases 20.

Demonstrate ability to continuously State ?lume Field Monitoring, monitor and control emergency worker Deficiency 87-D2, 8/5/87 exposure 4.2 FEMA OBJECTIVES TRACEING - FORT SAINT VRAIN NUCLEAR GENERATING STATION Table 3 provides a comprehensive tracking system of FEMA Objectives, NUREG-0654 Reference Elements, Exercise Objectives, Jurisdictional Responsibility, Exercise Dates, Identifled Deficiencies and Required Corrective Actions, and the Date Specific FEMA Objectives Were Met by State and Local agencies.

This tracking system represents the progress and status of this data through the 6-year exercise cycle in which all FEMA Objectives must be tested.

- - - -~

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TAllLE 3 FEM A Eserclae Objectives Tracklag Chart - Fort St. Vrala Page 1 of 5 Objective Jurisdictional Deficiency or Area at this Responsibility Date of Requieing Carrective Date Objective Met NUREC-0654 Exercise Exercise /

Action (By tracking FEMA Objective Number and Description Reference (Yes/No)

State Local Drill Number and Date)

State Local (s) 1.

Demonstrate ability to mobilize E.1, E.2 (S&L)

Yes I

I 8/5/87 87-Al, State EOC 8/5/87 8/5/87 staff and activate facilities 87-A15. Weld County prompt 1y (!).

2.

Demonstrate ability to fully staf f A.2.e, A.4 (S&L)

Yes I

X 8/5/87 None 8/5/87 8/5/87 facilities and maintaia staffing around the clock (2).

3.

Demonstrate ability to make A.I.d, A.l.e, Yes X

X 8/5/87 87-A2, State EOC 8/5/87 8/5/87 decisions ano to coordinate A.2.a (S&L) 87-A13, Weld County emergency activities (1).

4.

Demonstrate adequacy of facili-J.10.a. J.10.b.

Yes X

X 8/5/87

'87-A4, Media Center 8/5/87 8/5/87 ties, equipment, maps and dispisys C.3.a. H.2, H.)

87-A14. Weld County to support emergency operations (S&L)

(1).

E

{

5.

Demonstrate ability to cosusunicate F1., F2. (S&L)

Yes 1

X 8/5/87 87-D2, Plume Monitoring Pending 8/5/87 uith all appropriate locations, 9/30/87 87-A8, FCP organizations and field personnel 87-A19, Weld County (1).

Ambulance Service O.

Demonstrate ability to mobilize 1.8 (S)

Yes I

8/5/87 87-A-9, Plume Monitoring 8/5/87 and deploy field monitoring teams 11/4/87 Teams in a timely fashion (1).

Corrected !!/4/87 87-A12, I.1gestion Team, 7.

Demonst rat e appropriate equipment 1.8, 1.11 (S)

Yes I

8/5/87 87-A10, Plume Team 2 8/5/87 and procedures for determining ambient radiation levels (1).

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TAl4LE 3 (Cont'd)

Page 2 of 6 l

Objective Jurisdictional Deficiency or Area at this Responsibility Date of Requiring Corrective Date Objective Nat huREC-0654 Emercise Esercise/

Action (By tracking FEMA Objective Number and Description Reference (Yes/No)

State Local Drill Number and Date)

State Loc.s1(s) 8.

Demonstrate appropriate equipment I.9 (S)

Yes X

8/5/87 87-D2, Plume Monitoring Pending and procedures for measurement of 87-nll, Plume Team #1 airborne radioiodipe concentra-tions as low as 10-uCi/cc in the presence of noble gases (!).

9.

Demonstrate appropriate equipment 1.8 (S)

Yes X

8/5/87 87-D2, Ingestion Teams, 11/4/87 and procedures for collection, 11/4/87 Sample Lab, transport and analysis of samples of soit, vegetation, snow, water sad milk (1).

10.

Demonstrate ability to project I.10 (S),

Yes X

8/5/87

one S/5/87 dosage to the public via plume J.10 (S&L) esposure, based on plant and field data; and to determine appropriate protective meaneres based on PACS, available shelter, evacuation time estimates and a other factors (1).

11.

Demonstrate ability to project J.9 (S&L),

Yes X

a/5/87 87-A7, FCP 8/5/87 dosage to the public via ingestion

'J.11 (S) pathway exposure, based on field data; and to determine appropriate protective measures based on FACs and other relevant factors (3).

12.

Demonstrate ability to implement J.9 (S&L),

Yes X

8/5/87 87-A3, State EOC 8/5/87 protective actions for ingestion J.!! (S) pathway hasards (3).

1).

Demonstrate ability to alert the E.6 (S&L)

Yes X

X 8/5/87 87-01, State EOC 12/11/87 8/5/87 public within the 10-mile EPZ and 12/11/87 dieseminats an initial instruc-tional message within 15 minutes (1).

I 1

2

TABl.Z 3 (Coal'd)

Page 3 of 5 Objective Jurisdictional Deficiency or Area at this Responsibility Date of Requiring Corrective Date Objective Net NUREC-0654 Esercise Esercise/

Action (8y tracking FEMA Objective Number and Description Reference (Yes/No)

State Local Drill N.usber and Date) state Local (s) 14.

Demonstrete the ability to E.5, E.7 (S&L)

Yes X

8/5/87 87-DI, State EOC 12/11/87 12/11/87 formulate and distribute appro-priate instructions to the public in a timely fashion (1).

15. Demonstrate organizationel ability J.9, J.10.a.

Yes X

I 8/5/87 None 8/5/87 8/5/87 and resources necessary to manage J.10.g (L) an orderly evacuation of all or part of the plume EPZ (3).

4 16.

Demonstrate organizational ability J.10.k (L)

Yes X

I 8/5/87 Mone 8/5/87 8/5/87 I

and resources necessary to deal with impediments to evacuation, such as inclement weather or traffic obstructions (3).

4

17. Demonstrate organizational ability J.10.) (L)

Yes I

X 8/5/87 Mone

$/5/87 8/5/87

.o and resources necessary to control access to an evacuated area (.3).

1

18. Demsostrate organizational ability J.10.d (L)

Yes 1

X 8/5/87 None 8/5/8' 8/5/87 i

and resources necessary to effect en orderly evacuation of mobility-impaired individuals within the plume EPZ (3).

19.

Demonstrate organizational abit'ity J.9, J.10.g (L)

No X

X Prior Mone Prior'to Prior to and resources necessary to effect to 1987 1987 en orderly evacuation of schools

.1987 within the plume EPZ (3).

)

20.

Demonst rate ability to continuously K.3.a. K.3.b Yes X

X 8/5/87 87-D2, Plume er.d

!!/4/87, 8/5/87 4

monitor and. control emergency (S&L)

!!/4/87 Ingestion Monitoring'

'Ingestios g

team worker esposure (1).

onlyt plume team-l pending 4

2 i

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4 TAllLE 3 (Cont'd)

Page 4 of j Objective Jurisdictional Deficiency or Area at this Responsibility Date of Requiring Corrective Date Objective Met NUREC-0654 Exercise Exercise /

Action (By tracking FEMA Objective Number and Description Reference (Yes/No)

State Local Drill Number and Date)

State Local (s) 21.

Demonstrate the ability to make the J.10.f (S&L)

Yes x

8/5/87 Jone 8/5/87 decision, based on predetermined criteria, whether to issue K1 to emergency worbers and/or the general public (1).

22 Demonstrate st s ability to supply J.10.e (S&L)

Yes x

8/5/87 None Not re-and admicaster KI, once the quired decision hi s N:en made to do ao based on (3).

decision regarding Objective 21 23.

Demonstrate the ability to support J.2 (L)

Yes X

8/5/87 Ncae 8/5/87 an orderly evacuation of on-site personnel (3) and (4).

24.

Demonstrate the ability to brief C.3.e, C.4.a Yes X

8/!/87 87-A6, Media Center 8/5/87 the media in a clear, accurate and (S&L) timely manner (3).

25.

Demonstrate ability to provide C.4.b (S&L)

Yes x

8/5/57 87-A5, Media Center 8/5/87 advance coordination of information released (3).

smonstrate ability to establish C.4.c (S&L)

Yes X

8/5/87 None 8/5/87 26.

e and operate ruser control in a coordinated fashion (3).

27.

Demonstrate adequacy of procedures J.12 (S&L)

Yes I

8/5/87 87-A16, Fort Lupton 8/5/67 for registration and radiological Reception / Mass Care monitoring of evacuees (1).

28.

Demonstrate adequacy of facilities J.10.h (L)

Yes X

8/5/87 87-AIF, Fort F.upton 8/5/87 for mass care of evacuees (1).

Reception / Mass Care L.

?

l TABLE 3 (Cont'd)

Page 5 of 5 Objective Jurisdictional Deficiency or Area at this Responsibility Date of Requiring Corrective

_Date Ob ective Met j

NUREC-0654 Exercise Esercise/

Action (By tracking FEMA Objective Number and Description Reference (Yes/No)

State Local' Drill Number and Date)

State Local ( s,)

29.

Demonstrate adequate equipment and K.5.a. K.5.b (L)

Yes X

8/5/87 87-A18. Fort Lupton Fire 8/5/87 procedures for decontamination of Station Monitoring /

emergency workers, equipment and Decontamination sehicles (1).

30.

Demonstrate adequacy of EMS trans-L.4 (L and/or No X

9/30/87 None 9/3C/8?

portation, personnel and procedures utility support) for handling contaminated indi-i viduals.

including proper decon-tamination of the vehicle and equipment (1).

31.

Demonstrate adequacy of hospital L.1 (L and/or No X

9/30/87 None 9/30/87 facilities and procedures for utility support) handling contaminated persons (1).

33.

Demonstrate ability to identify C.I.a. C.I.b (S)

Yes X

8/5/87 None 8/5/87 0

need

for, request and obtain Federal assistance (1).

33.

FEMA Objective 33 no longer evaluated.

38.

Demonstrete ability to estimate H.4 Yes X

8/5/87 None 8/5/87 total population esposure.

35.

Demonstrate ability to determine M.1 (54L)

Yes X

8/5/87 None 8/5/87 and implement appropriate measures for controtted reentry and recovery (3).

(1) Objective i.hich must be demonstrated at each full pasticipation e ercise.

(2) Same as (1) escept 24-hour staffing is required only once in each six year esercise cycle.

(3) Objective wt.ich must be denunstrated in each six year esercise cycle.

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