ML20210E018

Forwards FEMA & Final Exercise Evaluations on 850820 Offsite Emergency Preparedness Exercise.Evaluation Lists Several Areas Requiring Corrective Actions & Improvement.No Deficiencies Affecting Public Health Noted

ML20210E018
Person / Time
Site:	Palisades
Issue date:	03/21/1986
From:	Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8603270162
Download: ML20210E018 (2)

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MAR 211986 l

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l Docket No. 50-255 Consumers Power Company ATTN: Dr. F. W. Buckman Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:

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We have received the enclosed Federal Emergency Management Agency (FEMA) letter dated February 21, 1986,.and associated final exercise evaluations on the offsite emergency preparedness exercise conducted on August 20, 1985.

This was a full-i participation exercise for Van Buren and Allegan Counties and a. partial participation exercise for the State of Michigan and Berrien County. This final exercise evaluation lists several areas requiring corrective actions and areas recommended for improvement regarding the offsite emergency response plans for the area around the Palisades Nuclear Power Station.

Based on the performance of the offsite agencies during the exercise, FEMA did i

not identify any deficiencies affecting public health and safety in the event of an accident at the Palisades Nuclear Power Station. As a result, the approval under FEMA Rule 44 CFR 350 will remain in effect.

i We fully recognize that the recommendations to be implemented may involve actions by other parties and political institutions which are not under your direct control.

Nonetheless, we would expect the subject of offsite preparedness for the area l

around the Palisades Nuclear Power Station to be addressed by you as well as others.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosure will be placed in the NRC's Public Document Room.

Sincerely, l

g@ signed by 10. Shhfed

'l W. D. Shafer, Chief Emergency Preparedness and Radialogical Protection Branch

Enclosure:

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FEB 21 1986 MEMORANDUM FOR: Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S clea Regul t y Cmmission FFOM:

'idm Assistant Associate Director Office of Natural and Technological liazards Prtgrams

SUBJECT:

Exercise Report of the August 20, 1985,. Exercise of the Offsite Radiological Emergency Preparedness Plans for. the Palisades Nuclear Power Station Attached are two copies of the Exercise Report of the August 20,1985, joint exercise of the offsite radiological emergency preparedness plans for the Palisades Nuclear Power Station. This exercise was partial participation for the State of Michigan and Berrien County and full participation for Van Buren and Allegan Counties. The report dated November 29, 1985, was prepared I

by Region V of the Federal Emergency Management Agency (FEMA).

There were no deficiencies observed during the exercise. There were inadequacies identified requiring corrective actions; however, they did not detract from the overall derronstrated capability to protect the health and safety of the public. The State is preparing a schedule of corrective actions. As soon as they are received, we will send you a copy. Ilowever, since there were no identified inpediments to protecting the public during the exercise, the approval under FEMA Rule 44 CFR 350 will renuin in effect.

If you have any questions, please contact Mr. Pobert S. Wilkerson, Chief, Technological !!azards Division, at 646-2861.

Attachments as Stated i

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Palisades Nuclear Power Plant Consumers Power Company Joint Exercise Facility Location:

Located in the State of Michigan, Northwestern Van Buren County on the shore of Lake Michigan.

Exercise Date:

August 20, 1985 Date of Report:

November 29, 1985

Participants:

State of Michigan (partial); Van Buren County (full);

Allegan County (full); Berrien County (partial) and the Consumers Power Conpany.

Federal Drergency Management Agency Region V Natural and Technological Hazards Division Technological Hazards Branch 300 South Wacker Drive Chicago, Illinois 60606 1

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TABLE OF CONTENTS TABLE OF CONTENTS page 2 EXECUTIVE

SUMMARY

page 3 State of Michigan page 3 Allegan County page 4 Berrien County page 5 Van Buren County page 5 EXERCISE REPORT page 10 Introduction page 10 1.

Exercise Background

'Page 10 2.

Participating and Non-Participating State and Local Governments page 10 3.

List of Evaluators page 10 4.

Evaluation Criteria page 11 5.

Exercise Objectives page 11 6.

Sumary of Scenario page 15 7.

State and Local Resources Planned To Be Used in the Exercise page 17-8.

Exercise Findings in Past. Exercises page 17 9.

Exercise Objectives Still To Be Effectively Achieved page 18 Narrative page 20 1.

State of Michigan page 20 2.

Allegan County page 23 3.

Berrien County page 31 4.

Van Buren County page 33

SUMMARY

LISTING.OF EXERCISE FINDINGS page 40 State of Michigan page 41 1.

Deficiencies Affecting Public Health and Safety

'page 41 2.

Required Corrective Actions page 42 3.

Recomendations For Inprovement page 43 Allegan County page 44 1.

Deficiencies Affecting Public Health and Safety page 44 2.

Required Corrective Actions page 45 3.

Recomendations For Inprovement page 47 Berrien County page 48 1.

Deficiencies Affecting Public Health and Safety.

page 48 2.

Required Corrective Actions page 49 3.

Recomendations For Inprovement page 50 Van Buren County page 51 1.

Deficiencies Affecting Public Health and Safety page 51 2.

Required Corrective Actions page 52 3.

Recomendations For Inprovement page 53 i

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FEE.03 '86 09:11 FEMA REGION V CHICAGO 1 P.02 EXECUTIVE SUM ARY State cf Michigan We Stitte EOC in Lansing has been evaluated during fifteen (15) previous radiological exercises. Since this was-a partial participation exercise for the State, the EOC staff consisted of representatives from the State Departrent of Public Health and the Emergency Management Division, Departrent of State Police. The EOC staff was prepositioned for this exercios. We most recent evaluation of alerting and mobilization of the State 1:0C staff occurred during the January 25, 1984 exercise involving the Donald C. Cook Nuclear Power Station.

I At 0826, the Palisades Nuclear Dower Plant advised the Michigan State Police that the Plant was experiencing an " UNUSUAL EVENT". The EOC staff was subsequently notified at 0905 of an " ALERT" condition. The " SITE AREA INERGECY" notification came at 0937 and the " GENERAL EMERGENCY" at 1008.

Emergen:y response procedures were irplemented through periodic staff briefings, discussions and references to the various status boards, maps and charts. All displays were maintained with the current exercise information.

We EOC facility has long term operational capability. We comnunications with Ic :al emergency operations centers (EOCs), the Technical Support Center (TSC), Dnergency Operations Facility (EDF) and Joint Public Information Center (JPIC) were by " hotline" with the Law Enforcement Information Net (LEIN) and State Police radio as backup.

The internal comnunications, displap and equipment were arranged to provide maxinum accessibility for the staEf.

Primary and backup comunications systems are available with all local IXs, contiguous States, the licensee and FEMA. Hardcopy information capability was demonstrated throughout the exercise between State and local govern:Mntal facilities, the utility and the JPIC. Protective action recomne idations were based on scenario conditions throughout the exercise.

We seesario did not provide a need for Berrien County to alert the public since t:1e County was not affected by the plume and no shelter or evacuation orders were issued.

However, Berrien County issued an EBS message informing the put.ic that Berrien County was not affected and instructed the public to monitor their radios for further informstlen.

FINA and the State agreed before ;he exercise that schools would be open (simulated) co that the countie9 could demonstrate their organizational ability to effect an orderly evacuat..on of schools within the plume EPZ. But during the exercise State EOC sta?f advised the counties tnat schools were closed. State exercise controliers should ensure staff understand pre-exercise agreements.

An alternate for the Director, Emergency Services Division, was in comund l

of the State EOC and directed the emergency response procedures. The State plan wan used as a reference during the exercise. Frequent formal and informat briefings were held to keep the EOC staff informed of exercise developments and actions.

Federal assistance waa required and requested from the Department of Energy (DOE). We State ensured that the appropriate Federal agencies were informe:1 of the situation and the State provided status updates in case their arsistance became necessary. %e Director of Emergency Management is authorised to request Federal assistance should the need arise.

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We JPIC has a@le space, necessary equipment and required maps and displays. The JPIC staff demonstrated the ability to comunicate with all appropriate locations and organizations using primary channels. Sufficient telephones for the public information officers (PIOS) and reporters were available. The JPIC staff was pronptly notified by the State EOC staff of information it needed.

The State demonstrated the ability to brief the media in a clear, accurate and timely manner. There were frequent and co@ rehensive briefings that were supplemented by extensive use of maps and diagrams.

We State demonstrated the ability to provide advance coordination of i

information released from the JPIC. All news releases and briefings were effectively discussed and cleared by all JPIC team members and their respective parent organizations before being released.

Allecan County Allegan County demnstrated the ability to notify their emergency response staff and activate their EOC. The county's demonstration in this area corrected a deficiency cited by FEMA d3 ring the 1983 exercise. The county EOC is sufficient to support the EOC staff during extended operations.

During the exercise the EOC staff demonstrated the ability to respond to an energency at the Palisades Nuclear Power Station. The staff made proper utilization of the primary conmunications systems as well as maps and charts for directing the emergency response activities. The presence and use of these maps and charts by the DOC staff corrects a 1983 exercise deficiency.

The County provided the public with protective instructions within the time constraints described in NUREG 0654. However, evaluators felt the timo factor to coordinate and release this information could be inproved. County officials described the resources and the manner they would utilize them to deal with i@edimnts to the evacuation process.

The County described the manner in which they would manage an effective evacuation of'chools that might be affected. There are no known. mobility s

inpaired individuals residing within the Allegan County EPZ. The County explained in detail how potassium iodine (KI) would be issued.

An Allegan County representative was prepositioned at the JPIC and coordinated news releases in a timly manner. According to the county, a teacher would be available at the JPIC to provide Spanish translations but no one filled that position at the JPIC during the exercise. The County also elected to demnstrate the ability to operate a rumor control position at the JPIC but did not provide staffing for this position during the exercise.

The County indicated they would demonstrate their capability to operate a decontamination and reception center during the exercise. This 1

demonstration was limited to agency representatives activating and staffing the centers and responding to questions asked by the evaluator. The Department of Social Services representative at the reception / congregate care center seemed unaware of their responsibility for the management of the facility. Reception / congregate care staff demonstrated some weakness in the operations of the reception / congregate care center.

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'Ihe Fenville Fire Department dispatched a tank truck to the Decontamination Center. The Fire Department representatives indicated they had not received any training in their decontamination duties and indicated they would welcone this training. The Federal evaluation also concludes Allegan County did not demonstrate adequate training and knowledge of procedures to decontaminate emergency worker equipment and vehicles.

The second shift EOC Radiological Officer explained the plan for distribution of dosimeter kits to emergency workers. Written instructions should be added to the dosimeter kits explaining the use of the dosimeter, the TLD's and the interval that readings should be entered on the record card and called into the EOC. To enable a conplete evaluation of decontamination and reception / congregate care, the county must be prepared to demonstrate their capabilities in these areas during the next exercise.

Berrien County Berrien County was in a partial participation mode during the Palisades Nuclear Power Plant exercise because of their January 25, 1984 full scale participation in the exercise of the Donald C. Cook Nuclear Power Plant.

'Ihe County EOC facility is adequate, in terms of amenities,.to support staffing needs routinely and for extended operations.

The County Deputy Director of Emergency Preparedness was the person effectively in charge of the emergency response for the County, as reflected in the County plan. The EOC staff are well trained and effectively implemented the emergency procedures specified in the County plan. The EOC staff demonstrated ability to make decisions and to coordinate emergency activities and ability to comunicate with all appropriate locations and organizations, using primary channels. The County also demonstrated ability to disseminate an instructional message. However, because the plume did not affect Berrien County and no sheltering and evacuation was necessary, the public information message was sinply to notify County residents that they were not affected but to remain tuned to the emergency broadcast station for further developments. This was also included in media briefings and press releases.

There was also effective coordination between the County EOC and the County representative at the JPIC. The County PIO at the JPIC participated in the preparation of press releases, media briefings and coordination of information released at the JPIC. The representative was knowledgeable of the County plan and his responsibilities at the JPIC.

f Van Buren County The EOC staff in Van Buren County denonstrated ability to mobilize staff and activate facilities through the activation of the County EOC, a reception and congregate care center at the Gobles High School, and a decontamination center at the Bangor Fire Department. However, the two (2) County Public Information Officers assigned to the JPIC were prepositioned at the JPIC which was contrary to preplanned exercise play as agreed between FEMA and

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the State of Michigan.

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We Van Buren County EDC was activated shortly af ter the County Sheriff's Dispatcher was contacted and advised of an " UNUSUAL EVENT" at the utility by the shift engineer on duty. The_ telephone call, via dedicated lines from the utility to the Sheriff's Dispatcher, was verified by a hardcopy nessage via the LEIN from the Michigan State Police Post at South Haven.

The Sheriff's Dispatcher telephoned and advised the County Dnergency Preparedness Coordinator of the reported " UNUSUAL EVENT" at the utility.

%e County Emergency Preparedness Coordinator proceeded to the County EOC, after reportedly mobilizing the County PIO for the EOC and the Radiological Officer. He also contacted and advised key EOC staff of the situation ~and requested the key staff to remain on alert.

The Sheriff's Dispatcher received a subsequent notification of an " ALERT" condition at the utility, via the dedicated telephone line between the County Sheriff's Dispatch Center and the utility. Again, the call from the utility was followed by a hardcopy message via the LEIN, also advising of the " ALERT" condition at the Palisades Nuclear Power Plant.

The Sheriff's dispatcher relayed the report to the County Emergency' Preparedness Coordinator in the EOC, via te'; phone and a hardcopy by a The mobilization of the remainder of the EOC staff was effected by runner.

the Emergency Preparedness Coordinator from the EOC. %e County successfully demonstrated the verification of messages received and procedures for mbilization of County staff during this exercise. This corrects the deficiencies in the May 25, 1983 exercise concerning Mobilization of Staff and Verification of Messages.

Van Buren County's staffing of the JPIC was partial because there was no english/spanish speaking interpreter as reflected in the County plan and there was no demnstration of a shif t change of personnel for the rumor control position. Therefore the mbilization and fully staffing of 4

personnel at the JPIC is an area requiring corrective action by Van Buren County.

The County Emergency Preparedness Coordinator (as Chief of Staff) was the person in charge at the County EOC as designated in the County plan. The EOC staff was involved in decision-making with major decisions being made by the executive group. There were periodic briefings to update the staff and receive updates from the organizations represented in the EOC. The County Sheriff's Department provided security for the EOC through the use of a roster identifying individuals with~ authorized entry, the use of personal identification and a sign in and out roster.

The County EOC operations room is small but functional for the number of organizations represented in the EOC.

It is equipped with sufficient furniture, telephones, adequate lighting and other amenities to serve as an EOC. The County EDC is located approximately twenty-three (23) miles from the Palisades Nuclear Power Plant and therefore can support extended operations. All required maps were posted or available in the EOC.

The map showing population distribution by increments out to ten (10) miles, that was missing during the last exercise, was available and used during the August 20, 1985 exercise. The map now displayed in the EOC shows the population distribution by sectors from one (1) through ten (10) miles.

@is map has also been included in the County plan (page B-21).

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We EOC staff denonstrated the provision for comnunications with the State EOC by use of a dedicated centrex telephone line, with the Law Enforcement Informatien Net (LEIN) as the secondary /back-up means of comnunications.

Weir comunications with all lxal EOCs is primarily via LEIN, with comnercial telephones as a back-up system'. The utility has a four (4) party telephone line from the utility to the three (3) siren activation points in

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the County (the County Sheriff's Depart 2nent, the Covert Fire Department and the South Haven Police Department). The dedicated line is backed up by radio comunications and commercial telephones at all four (4) locations.

Se use of comnercial telephone (primary) and police radio (back-up) connects the County with the Emergency Operations Facility. The County's contact with FEMA is through the State but can be acconplished via cormercial telephone. The EBS station is contacted by comnercial telephone The (primary) with radio as a secondary /back-up means for comnunications.

media center can presently be contacted only by use of comnercial telephone from the County EOC.

There are tone alert radios in all schools within the ten (10) mile EPZ as The support hospitals are primary means for alerting and connunications.

contacted through the Hospital Emergency Ambulance Response Net (HEARN) with comnercial telephones as back-up. All ambulances in the County can be There is no contacted by radio from the County Sheriff's Dispatch Center.

The hard copy capability between the nedia center and the County EOC.

County demonstrated ability to comnunicate with all appropriate locations, organizations and field personnel which corrects the required area of inprovement (significant deficiency) cited during the last exercise.

The EOC staff demonstrated their ability to alert the public within the 10 mile EPZ and disseminate an initial instructional message within 15 minutes. Alerting actions focused on a simulated activation of the fixed siren / broadcast system and release of EBS messages. Supplemental route alerting was demonstrated as an alternative i'n the event of siren failure.

FEMA Region V had requested prior to the exercise that the scenario writers fail a part of the siren system to enable Van Buren County to demonstrate supplenental route alerting.

During this exercise all three (3) of these alerting systems (sirens, EBS, and supplemental route alerting) were utilized to notify the public of shelter and evacuation reconnendations. Activation of these systems corrects'a deficiency from the last exercise. However, the shelter message (first EBS message) was released to the EBS station prior to the sounding of The second evacuation message sirens rather than after sounding the sirens.

It (third EBS message) was slow in being transmitted to the JPIC and EBS.

is the opinion of the Federal evaluation team that the Public Information l

Staff in the EOC should receive additional training on public alerting procedures and sequencing.

Per exercise agreement between FEMA Region V and the State of Michigan Van Buren County was not required to deploy emergency workers into the field to actually set up and man access control points. This will be done during the next full participation joint exercise now scheduled for August 19, 1986.

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h e BDC staff coordinated the efforts of law enforcement jurisdictions to control access to the evacuated area. Traffic and access control points were established and promptly relocated to reflect the on-going emergency situation. This demonstration was well coordinated and effective.

Information on evacuation numbers were tracked and conpiled by the Red Cross. The above information was coordinated into traffic management decisions.

We EOC staff reported that state and county resources are adequate to deal with impediments to evacuation. These resource capabilities were simulated in the DOC by reacting to messages rather than actually deploying equipment into the field. It should be pointed out to the readers of this report that due to the climate conditions in Southwest Michigan, Van Buren County each year is usually required to keep highways open due to heavy snow or storm damage caused by high winds.

The EOC staff denonstrated their capabilities to evacuate mobility-inpaired individuals within the affected EPZ.

Procedures were in place and lists of mobility impaired and their special needs are available from the Departnents of Health and Social Services. Transportation arrangements were simulated for the relocation of the individuals on these lists. Ambulances and other vehicles are provided by the Fire Department. This effort was well coordinated and corrects a deficiency from the previous exercise.

Information from the State EOC did not provide an opportunity for the County to denonstrate the orderly evacuation of county schools. When the County ingaired with the State EOC about school evacuations they were told that schools were closed and not in session. Therefore, the County did not attenpt to demonstrate the organizational ability necessary to effect an orderly evacuation of schools within the plume EPZ. Pre-exercise planning between the State of Michigan and FEMA was to assume schools were in session and the evacuation of schools would be simulated from the County emergency operations centers.

The County EOC staff demonstrated their ability to continuously monitor and control energency worker exposure in the field and to supply KI to their field staff, once the decision had been made by the State. Radiological exposure control kits including calibrated dosimeters, TLD's, KI and record keeping cards were distributed from the Health Department distribution center in Hartford. Field workers were provided with written instructions on the use of this equipment. Health departnent and EOC radiological staff were aware of decontamination procedures and dose limitations.

The organizational ability and resources necessary to manage an orderly evacuation of all or part of the plume EPZ was denonstrated. The denonstration consisted of a bus and four automobiles, with a number of volunteers, that were moved out of the EPZ to the County decontamination center at the Bangor Fire Department, where they were monitored and decontamination was demonstrated on the vehicles. The convoy then traveled to the reception and congregate care center at the Gobles High School. Here they were monitored for potential contamination, registered and housed.

Exceptionally good performance was shown in a demonstration of mergency nedical care and transport of a volunteer evacuee, using both an ambulance and a helicopter at the congregate care center.

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'Ihe two County PIOS were well trained and anply demonstrated their coordination role between.the County and the JPIC. They actively participated in media briefings, the formulation of instructions to the public and the advance coordination of information released at the JPIC.

The County person staffing the rumor contro'. position was also well trained and demonstrated ability to operate rumor cantrol in a coordinated fashion at the JPIC.

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EXERCISE REPORT Introduction 1.

Exercise Background This was the fourth joint exercise for the Michigan Division of Dnergency d

Management and the Counties of Van Buren, Allegan and Berrien resulting from a simulated accident at the Palisades Nuclear Power Plant. The first joint exercise was on December 9, 1980 and involved full scale participation by the State of Michigan, and the Counties of Van Buren, Allegan and Berrien.

We second joint exercise was on February 23, 1982 and involved partial participation by the State of Michigan, and full scale participation by Van Buren, Allegan and Berrien Counties. The third joint exercise was on May.

25, 1983 and involved partial participation by the State of Michigan and Berrien County and full participation by Van Buren and Allegan Counties.

This report addresses the ucst recent joint exercise for the Palisades Nuclear Power Plant which was conducted on August 20, 1985.

2.

Participating and Non-Participating State and Local Governments We 10-mile inhalation emrgency planning zone (EPZ) of the Palisades Nuclear Power Plant inpacts on parts of Allegan, Berrien and Van Buren Cc'inties, as well as Lake Michigan, with the major portion of the zone falling within Van Buren County. The 1980 permanent population within the 10-mile EPZ is estimated at 28,664. The influx of sumer vacationers increases the population considerably.

The 50-mile ingestion pathway zone enconpasses all or parts of nine (9) counties within the State of Michigan and three (3) counties within the State of Indiana. The remaining portion of the 50-mile ingestion pathway zone is located over Lake Michigan. In addition to Van Buren, Allegan and Berrien Counties, other Michigan Counties within the 50-mile EPZ include Barry, Cass, Kalamazoo, Kent, Ottawa and St. Joseph. The Indiana Counties are Elkhart, LaPorte and St. Joseph. The 1980 permnent population within the 50-mile ingestion EPZ is estimated at 903,998. The foregoing Michigan and Indiana Counties beyond the 10-mile EPZ did not denonstrate the procedures for inplementation of ingestion EPZ protective actions as this activity was beyond the scope of this exercise. This exercise was conducted during normal working hours.

3.

List of Evaluators for this exercise there was a total of eleven (11) federal evaluators observing off-site exercise activities. On-site exercise activities were evaluated by a seperate team from the Nuclear Regulatory Commission. The off-site evaluation team included seven (7) evaluators from FD% Region V and four (4) contract evaluators from Argonne National Laboratory ~ (ANL).

The evaluator assignments were as follows:

Off-Site Exercise Evaluation Team Director Dan Bement, FDM 10

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State of Michigan Evaluation Team Rick Anthony, Team Leader, FEMA Patricia Buckley, FEMA Edward Tanzman, ANL Van Buren County Evaluation Team Woodie Curtis, Team Leader, FEMA Sue Ann Curtis, ANL Caroline Herzenberg, ANL Edward Tanzman, ANL Allegan County Evaluation Team Robert Shapiro, Team Leader, FD4A Phil Kier, ANL Walter O'Keefe, FEMA / ARC Edward Tanzman, ANL Berrien County Evaluation Team Wiley Howell, Team Leader, FEMA Edward Tanzman, ANL 4.

Evaluation Criteria The plans being evaluated by this exercise were developed using the

" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0654/ FEMA REP-1, Revision 1).

Therefore, these criteria and the exercrit based on these criteria, " Modular Format for Uniformity of Radiological Emergency Preparedness Exercise Observations and Evaluation", dated June 1983, were used for exercise evaluation.

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Exercise Objectives Objectives for this exercise were selected from among the thirty-five (35) standard objectives listed in Tab "M" of the " Modular Format For Uniformity of Radiological Emergency Preparedness Exercise Observations and Evaluation" dated June.1983. The objective numbers listed below correlate to Tab "M".

The State of Michigan selected the following seven (7) objectives, including those applicable to the Joint Public Information Center (JPIC), to be demonstrated during the exercise.

3.

Demonstrate ability to make decisions and to coordinate emergency activities.

4.

De::enstrate adequacy of facilities and displays to support energency operations.

5.

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

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13. Demonstrate ability to alert the public within the 10-mile EPZ, and disseminate an initial instructional message, within 15 minutes.

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

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

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25. Demonstrate ability to provide advance coordination of information released.

Van Buren County selected the following twenty (20) exercise objectives, including those applicable to the JPIC, to be denonstrated during the exerciso.

1.

Demonstrate ability to mobilize staff and. activate facilities prortptly.

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 comunicate with all appropriate locations, organizations and field personnel.

13. Demonstrate ability to' alert the public within the 10-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.

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

16. Denonstrate the organizational ability and resources necessary to deal with inpediments to evacuation, as inclement weather or traffic obstructions.

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

18. Denonstrate the organizational ability and resources necessary to effect an orderly evacuation of mobility-inpaired individuals within the plume EPZ.

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

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

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

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

25. Denonstrate ability to provide advance coordination of information released.

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

27. Denenstrate adequacy of procedures for registration and radiological monitoring of evacuees.

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

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

Allegan County selected the following twenty (20) exercise objectives, including those applicable to the JPIC, to be demonstrated during the exercise.

1.

Demonstrate ability to mobilize staff and activate facilities pronptly.

2.

Demonstrate ability to fully staff facilities and maintain staffing

.around the clock.

3.

Denonstrate ability to make decisions and to coordinate emergency activities.

4.

Demonstrate adequacy of facilities and displays to support _ emergency operations.

5.

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

13. Demonstrate ability to alert the public within the 10-mile EPZ, and disseminate an initial instructional message, within 15 minutes.

14. Denonstrate 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.

16. Denonstrate the_ organizational ability and resources necessary to deal with inpediments to evacuation, as inclement weather or traffic l

obstructions.

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

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18. Demonstrate the organizational ability and resources necessary to effect an orderly evacuation of mobility-inpaired individuals within the plume EPZ.

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

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

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

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

25. Demonstrate ability to provide advance coordination of information released.

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

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 decontamination of energency workers, equipment and vehicles.

Berrien County selected the following seven (7) exercise objectives, including those applicable to the JPIC, to be demor4strated during the exercise.

3.

Demonstrate ability to make decisions and to coordinate emergency activities.

4.

Denonstrate adequacy of facilities and displays to support emergency operations.

5.

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

13. Demonstrate ability to alert the public within the 10-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.

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

i

25. Demonstrate ability to provide advance coordination of information released.

14

6.

Sumary of Scenario The Palisades Nuclear Power Plant radiological emergency preparedness scenario, developed by writers from the utility and the State, took into consideration deficiencies identified in past exercises in order to develop a scenario that would allow demonstration of past exercise deficiencies as well as allow demonstration of exercise objectives selected by the State of Michigan, Van Buren, Allegan and Berrien Counties.

Representatives from the Palisades Nuclear Power Plant, the State of Michigan, Van Buren, Allegan and Berrien Counties and FEMA Region V met on May 8,1985 at the Palisades Nuclear Power Plant to select the exercise objectives and to discuss the scope of the exercise. Subnission of the scenario to FEMA Region V was according to deadlines outlined in Nuclear Regulatory Comission (NRC) and Federal Emergency Management Agency (FEMA) guidance. Westinghouse Idaho Nuclear Conpany Incorporated reviewed the off-site portion of the scenario for FEMA and found the scenario adequate to exercise the objectives selected.

The plant is operating at 98% power and has been operating the equivalent of 200 full power days. The primary coolant system activity has been at 1.1 uCi since 0810 saturday (limited condition of operation reached at 0810 today). The latest primary sample showing 1.1 uci/g taken at 0830 on Monday. Primary coolant system leakage is 0.3 gpm unidentified, 0.2 gpm identified and 0.01 gpm primary to secondary. One of the three charging punps is inoperable due to normal preventive maintenance.

"B" charging pump is in service and "C" is the backup. The high-pressure safety injection pump is inoperable due to a broken oil filter.

At 0810, an " UNUSUAL EVENT" is declared as a result of exceeding 1 uCi/g Iodine-131 deficiency in equipment qualification DEQ for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Plant shutdown continues.

At 0815, a maintenance repairman, while loading gas bottles, knocks over several cylinders of propane with a forklift truck. The valve is severed on one of the cylinders. The cylinder is propelled through the metal wall of the Feedwater Purity Building, striking the sulfuric acid tank. A hole is punched in the tank about half way up. The sulfuric acid runs to the floor from the hole. The acid reacts with the water on the floor, causing sulfuric acid fumes. Toxic sulfuric acid fumes fill the Feedwater Purity Building as a result of the leaking sulfuric acid reacting with the water in the containment area around the acid tank.

At 0820, the repairman calls the Control Room to report the accident and the Auxiliary Operator notifies the Control Room of a toxic gas release (Alert).

At 0830, the Control Room notifies Chemistry of the toxic gas release. At 0835, the acid tank has drained down to point of break.

(Leak is secured.)

Between 0835 and 0930, Chemistry neutralizes the spill, the Auxiliary Operator establishes ventilation and cleanup begins.

At 0930, Charging Punp P-55B trips due to a pressure controller rupture (broke off at connection). This caused the punp to trip on low oil The backup charging punp starts but trips imnediately due to a pressure.

seized punp mtor caused by low seal cooling flow.

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15

At 0940, the Auxiliary operator notifies the Control Room that the Feedwater Purity Building is now habitable; toxic sulfuric acid fumes have dispersed (possible de-escalation).

At 0950, the high pressure safety injection (HPSI) fails due to a damaged Y-Phase overcurrent. relay damage. 'Ihe damage resulted when a maintenance man inadvertently btmped the breaker with some tools while on his way to fix the charging ptmps. Now there are no high pressure safety injection punps or charging punps.

At 1000, the cap on the main steam isolation valve on Steam Generator B opened up (modelled as a 1.0 ft2 break). At the same time, (5) steam generator tubes ruptured. Primary coolant and steam generator fluid are released to the environment via the door to the roof of the Auxiliary Building (the door is about seven feet away and five feet above the damaged main steam isolation valve. Steam and radionuclide also gather in all floors of the Conponent Cooling Water Room (The Main Steam isolation valves are on the second floor; the door to the roof is on the third floor of this room). In the opinion of the scenario writers, a " GENERAL EMERGENCY" condition exists due to the loss of two of three fission product barriers, with potential for the loss of the third. The potential loss of the third is indicated (in the scenario writers' view) by the plant high radiation alarms.

In fairness to the plant, they may believe that the high radiation is coming from the activity in the primary coolant with an iodine / noble gas spike, and not from additional failed fuel rods. Therefore, breach of the third barrier is not inminent and the event is a Site Area Dnergency. The Consumers Power Conpany evaluators and NRC evaluators will determine if the reasoning not to classify the vent as a General Emergency is adequate. An additional consideration is that there is ar. Dnergency Action Ievel of Site Area Dnergency, which is defined as a steam line break and greater than 50 gpm primary to secondary leak rate and indication of fuel damage, all of which occur here.

At 1000 and 15 seconds, there is a reactor trip on high reactor power followed quickly by low pressurizer pressure and low steam generator pressure trip signals. All but five (5) control rods insert so that.the reactor remains critical.

At 1902, the primary pressure has bottomed out above the low-pressure safety injection punp head. At this point, there is no safety injection as bottom high pressure safety injection punps and all three charging punps are out and the primary system pressure is too high for low pressure safety injection flow or safety injection tank flow. The pressurizer is enpty and steam is coming out of the break. Since power generation is now greater than combination of energy being released out of the. break and the energy transferred to the steam generators, the primary pressures begin to rise.

At 1020, the primary system pressure has peaked at 2400 psi and the pressurizer has refilled due to expansion of the primary coolant.

At 1030, the reactor goes suberitical due to the primary system heatup (negative moderator coefficient of reactivity) and now the energy transferred out the break and to the steam generators is greater than decay heat. The primary coolant begins to cool off, and the pressure and tenperatures begin to fall.

16

At 1100, the core is unavered and fuel is overheating and failing. The high pressure safety injection pump is fixed but, by itself, can only stabilize level (flow in = flow out).

The plant can be cooled in one of three ways. One is to wait for the second high pressure safety injection punp to be fixed (should Le fixed about 1200) and reflood. A second way is to open the bypass around the main steam isolation valve and cool using the good steam generator and turbine bypass valve (or atmospheric dump valves), and a third is to open the power operated relief valves and depressurize down a pressure at which the low pressure safety injection punps can provide injection flow. The scenario writers did not think that the power operated relief valves would be used (based on the advice of our simulator instructor) or that the atmospheric dunp valves would be used. Therefore, the scenario was written based on the plant staff waiting for the second high pressure safety injection pump to be fixed.

If the plant staff elects to use the turbine bypass valve, the cooldown is so slow that the scenario, as we have drawn it, will not change nuch. The controllers are prepared, however, to allow the plant staff to cool in any of the three ways described above.

At 1200, the other high pressure safety injection punps is fixed and plant cooldown can conmence. The core is covered quickly after the secon-1 high pressure safety injection is put into service.

Between 1330 and 1400, the drill ceases with the core cooled and covered, and the release stopped (although the path still exists).

7.

State and Local Resources Planned To Be Used in the Exercise During this exercise the State of Michigan planned to use the State EOC in Lansing and the JPIC at the Lake Michigan Community College, Benton Harbor, Michigan. The State of Michigan also planned to use.the necessary comunications systems to conduct emergency operations.

Van Buren, Allegan and Berrien Counties planned to demonstrate their EDC facilities, energency response staff and comunications systems capabilities. The three (3) counties planned to have spokespersons at the JPIC to demonstrate their ability to coordinate public information and rumor control.

i In addition, Van Buren and Allegan Counties each planned to demonstrate one j

(1) reception / congregate care and decontamination center.

i 8.

Exercise Findings In Past Exercises There were two (2) significant deficiencies (required corrective actions) and three (3) minor deficiencies (areas reconmended for inprovement) identified for the State of Michigan during the evaluation of the May 25, 1983 joint participation exercise for the Palisades Nuclear Power Station.

Corrective actions for the two significant deficiencies and the three minor deficiencies for the State of Michigan have been demonstrated as a result of the August 20, 1985 exercise of the Palisades Nuclear Power Station.

17

'Ihere were eight significant deficiencies (required corrective actions) and

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eight minor deficiencies (areas recomended for inprovement) identified for Van Buren County during the evaluation of the May 25, 1983. exercise for the Palisades Nuclear Power Station. Corrective actions for six of the eight significant deficiencies and five of the eight minor deficiencies for Van Buren County have been demonstrated as a result of the August 20, 1985 exercise of the Palisades Nuclear Power Station.

There were eight significant deficiencies (required corrective actions) and five minor deficiencies (areas reconmended for inprovement) identified for Allegan County during the evaluation of the May 25, 1983 joint participation exercise for the Palisades Nuclear Power Station.

Corrective actions for seven of the eight significant deficiencies and the three of the five minor deficiencies for Allegan County have been demonstrated as a result of the August 20, 1985 exercise of the Palisades Nuclear Power Station.

There were no significant nor minor deficiencies identified for Berrien County during the evaluation of the May 25, 1983 joint participation exercise for the Palisades Nuclear Power Station.

I 9.

Exercise Objectives Still To Be Effectively Achieved Because of the areas requiring corrective actions noted in this report, the following exercise objectives were not conpletely demonstrated. Appropriate action will be regaired to correct the inconpleted exercise objectives.

These objectives nust be successfully demonstrated during the next biennial radiological emergency preparedness exercise for the Palisades Nuclear Power Station.

State of Michigan All exercise objectives for the State of Michigan were effectively achieved.

Allegan County Allegan County did not conpletely dem3nstrate the following six (6) exercise objectives.

1.

Demonstrate ability to mobilize staff and activate facilities pronptly:

The Allegan County PIO was prepositioned at the JPIC contrary'to pre-planned exercise play as determined by the State of Michigan and FEMA.

Nor was an english/spanish speaking translator at the JPIC as defined in the County plan.

2.

Demonstrate ability to fully staff facilities and maintain staffing around the clock: There was no double staffing of the County PIO at the' JPIC or other means demonstrated to show the County's ability to maintain staffing around the clock.

20. Demonstrate ability to continuously ')nitor and control emergency worker exposure: Dosimeter kits for amergency workers did not include

~

written instructions on the use of dosimeters, TLD's or the interval for recording readings on the record cards.

'18

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26. Demonstrate ability to establish and operate rumor control in a coordinated fashion: There was no activation of County personnel for the rumor control position.

27. Demonstrate adequacy of procedures for registration and radiological monitoring of evacuees: The Department of. Social Services representatives at the reception / congregate care center seemed unaware of their responsibility to be in charge of the facility.

29. Demonstrate adequate equipment and procedures for decontamination of energency workers, equipment and vehicles: Allegan County did not denonstrate adequate training and knowledge of procedures to decontaminate equipment and vehicles that belong to the emergency workers.

Bertien County Berrien County did not demonstrate the following objective.

13. Demonstrate ability to alert the public within the 10-mile EPZ, and disseminate an initial instructional message, within 15 minutes: The scenario did not provide a need for Berrien County to Alert the Public through dissemination of an instructional message because the county was not affected by the plume. Therefore, it was not necessary for Van Buren County to activate the Berrien County portion of the outdoor warning system (sirens).

Van Buren County Van Buren County did not conpletely demonstrate the following three (3) exercise objectives:

1.

Demonstrate ability to mobilize staff and activate facilities promptly: The two Van Buren County Public Information Officers and the person assigned to rumor control at the JPIC were prepositioned. Also there was no english/spanish speaking interpreter at the JPIC from Van Buren County as outlined in the plan.

2.

Demonstrate ability to fully staff facilities and maintain staffing around the clock: Van'Buren County did not denonstrate a capability to man rumor control at the JPIC on a continuous- (24-hour) basis.

19. Demonstrate the organizational ability and resources necessary to effect an orderly evacuation of schools within the 10-mile EPZ.

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Narrative 1.

State of Michigan-i Activation and Staffing The August 20, 1985 Palisades Nuclear Power Plant exercise was the fourth such exercise in which the State of Michigan participated for this site.

The State of Michigan's participation in this exercise was limited in that

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the State of Michigan activated and staffed the State emergency operations center in Lansing and the JPIC sufficiently to support the emergency response demonstrated fully by Van Buren and Allegan Counties and the partial participation by Berrien County. Staff alerting, mobilization and activation of these two facilities have been evaluated and successfully demonstrated during previous exercises. Therefore during the August 20, 1985 Palisades exercise, State staff were prepositioned.

For the purpose of this exercise there were sufficient EOC organizational representatives present to support the Counties that participated in the exercise. There is a direct conmunication link (dedicated telephone) with the utility which is monitored continuously by the Operations Division, Michigan Department of State Police.

Emergency Operations Management Emergency operations management was conducted in a manner to support emergency operations inplemented by Van Buren, Allegan and Berrien Counties. An alternate to the State Director, Emergency Management Division was the individual effectively in charge. The EOC staff was involved in decision making and periodic briefings were held to update the EOC staff on the situation. Message logs were kept and distributed as appropriate resulting in efficient message handling.

The EOC staff was notified at 0826 of an " UNUSUAL EVENT" at the Palisades Plant that occurred at 0810.

It was notified at 0905 of the " ALERT" declaration that occurred at 0847 and notified at 0937 of the " SITE AREA R4ERGENCY" declaration that occurred at 0927. 'Ihe State was notified of the general energency at 1008. The State of Michigan issued the " GENERAL D4ERGENCY" protective action order at 1010 for in place sheltering in all sectors out to two miles and sectors, B, C, and D out to five miles. The State Parks within the 10-mile EPZ were ordered closed. Additionally, waterways in sectors R and A were closed to lake traffic out to ten miles and railroads were notified.to stop traffic out to ten _ miles.

The protective action to evacuate all sectors 0-2 miles and sectors B,C, and D out to five miles occurred at 1105. The evacuation protective action was upgraded at 1129 to evacuate all sectors out to five miles and sectors B, C, and D out to ten miles. The State ensured that the appropriate Federal Agencies were contacted and informed of the situation and kept abreast as the operation progressed.

Facilities The State Dnergency Operations Center has been evaluated during numerous past exercises and has been found to be sufficient for the conduct of emergency operations. This was not an objective and as such not evaluated during this exercise.

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o Comunications Comunications between the State EOC, the JPIC, the Palisades Nuclear Power Plant and Van Buren, Allegan and Berrien Counties were effective and efficient. Telephone was the principal means of exchanging information.

Hardcopy capability exists between the State EOC and the JPIC. Alternate means of comunications such as the Law Enforcement Information Network (LEIN), datafax and radio were also demonstrated during the exercise. The Dnergency Management Division, Michigan Department of State Police comunications system is reflected below.

Organization Primary Systems Back-up Systems State EDC Telephone LEIN, Teletype, Radio and Datafax County EDC's Telephone LEIN Contiguous States Telephone Teletype and Radio Utility Telephone Radio and Datafax EOF Telephone Datafax JPIC Telephone Datafax EBS Telephone Radio FDG Telephone Teletype, Datafax and Radio-Dose Assessment and Protective Action Recomendation Radiological assessment is not evaluated during partial State participation exercises. These objectives are carried out only in terms of supporting local goverment exercise play, primarily through simulation at the State emergency operations center. Actions taken by the State of Michigan were based on the exercise scenario and the protective action recomendations of the utility. Although not an exercise objective, the State recomended the issuance of potassium iodide (KI) to emergency workers in support of this objective by the Counties.

Public Alerting and Instructions Since this was a partial participation exercise for the State of Michigan, the limited EOC staff reviewed the protective action recomendations from the Palisades Nuclear Power Station before forwarding protective action recomendations to Van Buren, Allegan and Berrien Counties. Activation of the siren system and the Emergency Broadcast System (EBS) is a local responsibility in Michigan. State action under this objective was to support the counties by confirming, through simulation at the EDC, the

" GENERAL EMERGENCY" and inplementing the Governor's order to evacuate or shelter in place.

The Counties inplementation of the protective action recommendation to alert the public within the 10-mile EPZ and to disseminate an initial instructional message within fifteen minutes is addressed in the Van Buren, Allegan and Berrien Counties portion of this report. However, the scenario (as written by the State and utility) did not provide a need for Berrien County to alert the public and disseminate an instructional message because Berrien County was not affected by the pltrne.

21 (REV) ve w-e

Required Corrective Action: NUREG criteria item N.l.a

'Ihe scenario did not provide a need for Berrien County to alert the public through dissemination of an instructional message because the County was not affected by the plume. Therefore it did not become necessary for Van Buren County to activate sirens in Berrien County.

Reconmendation: The State and utility scenario writers should ensure future scenarios will drive objectives to be demonstrated by the counties.

Protective Action Evacuation activities such as activation of reception centers, congregate care facilities, relocation of special needs individuals and access control are the responsibility of local governments with assistance from the State.

It is noted that the State EOC staff did not inplement pre-exercise agreement between FEMA Region V and the State concerning schools. The pre-exercise agreement was schools would be in session and the counties would demonstrate their organizational ability to effect an orderly evacuation of the schools. The Counties were informed at the inplementation of the evacuation order, schools were not in session.

Reconmended Improvements: State exercise controllers need to ensure the State staff understand pre-exercise agreements in order for the Counties to demonstrate their selected objectives.

Ingestion pathway protective action was not an objective for the State of Michigan during this exercise.

Radiological Exposure Control Radiological Exposure Control was not an exercise objective for the State of Michigan and therefore was not evaluated.

Media Relations There were no media briefings conducted in the State EOC. Media activities in the State of Michigan are conducted at the JPIC. The JPIC for the Palisades Nuclear Power Plant is located in the theater building on the campus of Lake Michigan Ccxmunity College.

It is well outside the 10-mile Emergency Planning Zone.

i A State representative served as the noderator during the briefings at the JPIC. The staffing of the JPIC included Public Information Officers and staff from the State of Michigan, Van Buren, Allegan and Berrien Counties and the Palisades Nuclear Power Plant. Frequent briefing of the media were conducted under the leadership of the Sta_te moderator / director and included PIO representatives of the counties and the utility. A video cassette of each briefing and about the Palisades Nuclear Power Plant was available to the media. A collection of maps and reactor diagrams, as well as a status board, aided in the presentations. Technical jargon was explained by a utility representative.

The State and County PIOS coordinated their information before each briefing. The rumor control telephone was manned, the number was posted in the JPIC and was repeatedly announced to the media. The connunications l

system in the JPIC adequately supported the response activity. An open conmercial telephone line linked the JPIC to the State EOC.

22 1

i e

i A datafax machine for hardcopy transmissions was also available between the JPIC'and the State EOC. The media had access to a bank of eleven telephones in a separate room away from the briefing room. Se JPIC was notified pronptly by the' State EOC of changes in emergency classification status and protective actions. Each change in the plant status and protective actions was the subject of a JPIC briefing and a news release was distributed to the media.

Recovery and Reentry.

The exercise scenario was designed to demonstrate. local alert, notification and mobilization. Recovery and reentry play was purposely designed to be j

very limited and was not an exercise objective to be evaluated. The limited i

recovery and reentry play in the scenario was designed to bring the off-site conditions back to normal conditions to logically terminate the exercise.

Recovery and reentry was an exercise objective for evaluation during the May l

25, 1983 partial participation exercise and is a part of that exercise report for the State of Michigan.

I 1

2.

Allegan County I

Activation and Staffing i

he Allegan County Sheriff's Dispatcher received notification at I

approximately 0826 of an " UNUSUAL EVDTf" condition at the Palisades Nuclear j

Power Plant that occurred at 0810. %e notification was verified by a LEIN hardcopy message from the Michigan State Police at South Haven. The dispatcher notified the County Sheriff and the County Dnergency Management Coordinator (both on duty and co-located in the same building as the j

dispatcher).

f The County Emergency Management Coordinator proceeded to the EOC located in the basement of the adjacent County Courthouse building to setup the EOC and await further updates on the utility conditions. %e utility declared an j

" ALERT" at approximately 0847. Allegan County received notification at.

approximately 0905 which necessitated activation of the EOC. The EOC was fully staffed at 0930. Alerting and mobilizing the EOC corrects a i

deficiency from the 1983 exercise.

The Allegan County EOC staff demonstrated the ability to maintain twenty four (24) hour around the clock staffing through the use of a shift change, double staffing and personnel rosters.

Bnergency Operations Management The Chairman of the Allegan County Board of Comissioners was the individual effectively in charge of %e operation. Frequent briefings were held to update staff on the situttion. Staff were involved in the briefings, j

decision making and other aspects of the operation pertaining to their i

respective responsibilities. Timely entries were made on the status board and message distribution within the EOC facilitated the operational capabilities. %ere was a delay in the receipt of hard copy messages from the sheriff's comunications center to the County EOC. Wis delay was

{

caused because messages were hand carried from the sheriff's department, 4

which is located in a building adjacent to the EOC.

1 23

e Recomended Improvement:

It is recomended that the present hand carrying system of delivering messages between the sheriff's office and the EOC be revised to a more efficient system.

Facilities The emergency operations center, located in the basement of the Allegan County Courthouse, has sufficient amenities to support the emergency response staff for an extended operation. The EOC start was kept abreast of the situation through the use of an illuminated sign display of emergency action level classifications and an overhead projector for the display of information on significant events.

The required maps were displayed in the EOC. The maps depicted evacuation routes, access control points, preselected radiological sanpling and monitoring points, relocation centers in host areas and shelter areas and population distribution around the nuclear facility by sectors. Th s corrects a deficiency from the 1983 exercise.

Comunications Allegan County demnstrated ability to comunicate with all appropriate locations and field personnel by use of comercial telephone as the primary means for comunications. The primary means are supplemented by two-way radio and the LEIN to the State and other counties. Conferencing is available on lines within the EOC.

RACES and/or citizen band radio groups were used to supplemnt comercial telephone comunications in the reception / congregate care and decontamination centers. There is no hard copy capability between the EOC and the JPIC.

Recomended Improvement: Hard copy capability is recomended between the EOC and the JPIC.

Dose Assessment and Protective Action Recomendations Dose assessment and protective action recomendations for shelter and evacuation were provided to the Counties by the Michigan Department of Public Health, Radiological Health Services Division. It was recomended by the State Radiological Health that emergency workers in the field start taking Potassium Iodide (KI) daily. The state instruction to stop taking KI oas also announced by Allegan County.

Public Alerting and Instructions Allegan County issued its first EBS message'to WKZO radio / television station at 0933. The message stated that the Chairperson of the Board of Comissioners of Allegan County had been notified of an accident at the Palisades Nuclear Power Plant and the accident had been classified as an unusual event. The message also stated there had been no release of radioactive material and therefore no need for protective actions. Due to the large spanish speaking migrant population in the area the' County arranged to have all EBS messages repeated in spanish.

24

At 0945 Allegan County received a hardcopy LEIN message that stated: "At 0920 the Governor had declared a state of disaster existed due to an " ALERT" classification level at the Palisades Nuclear Power Plant." Allegan County received a hard copy (LEIN) of the Governor's Declaration at 1907.

Allegan County was notified at 0826 of an " UNUSUAL EVENT" that. occurred at the Palisades Nuclear Power Plant at 0810. The County was notified at 0905 of the " ALERT" declaration that occurred at 0847 and notified at 0939 of the

" SITE AREA DiERGENCY" declaration that occurred at 0927. The " SITE ARTEA DiERGENCY" was due to a sulphuric acid spill and the loss of the safety injection pumps.

The County was notified of the " GENERAL DiERGENCY" at 1014. The " GENERAL DiERGENCY" declaraation was due to the release of iodine and noble gases.

Allegan County also received the State's " GENERAL DiERGENCY" protective action order at 1014 for in place sheltering in all sectors out to two miles and sectors B,C and D out to five miles. The State Parks within the 10-mile EPZ were ordered closed. Additionally, waterways in sectors R and A were closed to lake traffic out to ten miles. Railroads were notified to stop rail traffic within the 10-mile EPZ. Road boundaries were used to describe.

the affected area in messages to the public.

Van Buren County activated the pronpt alert and notification system (outdoor sirens) in both Allegan and Van Buren Counties at 1020. Allegan County activated the EBS at 1022 and thus disseminated an initial instructional message within 15 minutes.

At 1038 and 1941 respectively, the PIO at the Allegan County EOC informed D3S and the Allegan County PIO at the JPIC that the Michigan Department.of Health issued an advisory that all milk animals should be placed on stored feed in sectors, B, C and D out to forty (40) miles and all other sectors to five (5) miles. Representatives of the Michigan Department of Agriculture conducted a continuing surveillance of those dairy farms affected to ensure purity of the milk supply. Those farmers in the affected area unable to put their cows on stored feed were advised to call 616-673-5411 and were cautioned to avoid drinking the milk until measurements were made. Farmers and gardeners in the affected area were advised they should also avoid eating or selling fresh garden produce grown in the area.

The Governor issues his protective action reconmendation to evacuate all sectors out to two (2) miles and sectors B, C and D out to five (5) miles at 1105. The sirens were sounded at 1106 and the County activated the EBS at 1107. The State, at 1129, expanded the evacuation protective action reconmendations to have sectors B, C and D evacuated out to ten (10) milesand all other sectors to five (5) miles. Allegan County announced this over WKZO radio (EBS) at 1129, one (1) minute after being informed by the State. The message described the areas to be evacuated, gave the routes to reach the congregate care center, and provided a telephone number to call for more information.

The 1245 Allegan County EBS instructional message concerning emergency j

workers taking KI deviated from the initial instructions received from the State Radiological Health Division. Allegan County said institutionalized persons should also take potassium iodide.

25 i

Recomended Improvement:

It is reconmended that the County consult with the State Radiological Health Division before adding other categories of people to health department protective instructions.

Protective Action Evacuation and access control activities were sinulated in the Allegan County EOC. The simulated activation of personnel of the County Sheriff's Department had begun at the " ALERT" notification. By 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> additional patrols were deployed and by 1135 sneriff's deputies were reportedly manning all acces.= control points.

The evacuation routes activated had sufficient capacity to handle the estimated numbers of evacuees. The sheriff's marine unit used four motor boats to evacuate boaters outside the designated evacuation area on Lake Michigan. The provision of signs and barricades and removal of inpediments to evacuation are responsibilities of the Road Comission and were simulated in the EOC.

There is reportedly sufficient resources in terms of personnel and equipment to remove impediments to evacuations. Additional workers of the County Sheriff's Department were activated (simulated) to assist Van Buren County in the evacuation of nobility-inpaired persons living within the EPZ. Van Buren County, as the primary local response government, is responsible for insuring transportation of residents without transportation and/or mobility inpaired residents in Allegan County.

There are no schools within the 10-mile EPZ in Allegan County. However, there is a small school with thirty (30) pupils just outside the 10-mile

'EPZ.

The school was reported to be out of session by a staff member in the State EOC. The pre-crercise agreement between FDiA and the State was that schools would be considered in session for exercise play purposes. However, the County WC school rep:esentative explained that in case of an incident at the utility, the schocl would be notified by conputer terminals or by telephone of any sheltet or evacuation order.

Because of heavy snows in winter and threats of tornadoes, closing of schools in the county are routine with standard operating procedures which are also applicable to radiological emergencies. Parents of students attending the school are given information on evacuation of i.he school, where the students will be relocated in case of an evacuation, etc. The procedures for the evacuation include the notification of bus drivers for student transportation. The Federal evaluation team gives Allegan County credit for demonstrating the organizational ability necessary to effect an orderly evacuation of schools within the plume EPZ.

A reception / congregate care center was opened at the Fenville High School.

It was agreed between FEMA Region V and the State of Michigan prior to the exercise, that alerting and mobilization of the staff for the reception / congregate care center would not be an objective to be evaluated.

It was further agreed the demonstration at the reception / congregate care center would be out of sync with the exercise scerurio.

26 1

'Ibe school principal was not aware his school was going to be used as a m

reception / congregate care center until the reception / congregate care staff arrived at the school..The principal imediately checked with the school Superintendent's Office and verified the building should be made available as a reception / congregate care center and made arrang m ents with the school staff to set up the school as a reception / congregate care center. This comunications breakdown within Allegan County allowed for a demonstration of an unannounced notification of the Fenville High School and allowed the administrative and custodial staff to demonstrate their capability to turn their school into a reception / congregate care center on a timely basis.

The organizations represented at the reception / congregate care center included the Department of Health, Department of Social Services, Red Cross, School, Ambulance Services, Fenville Fire Department and the Fenville Police Department. Three (3) of the above departments were represented by two (2)

It persons and the other departments were represented by one (1) person.

was indicated a full operating staff is available for continuous 24-hour operations. It was agreed prior to the exercise that double staffing or a shift change would not be required during this exercise for the reception / congregate care center staff.

l The Allegan County plan indicates the Department of Social Services has the primary responsibility for the management and operations of the reception / congregate care center and the decontamination center. However the Social Services representative at the reception / congregate care center seemed unaware of this responsibility.

The State of Michigan reported they conducted an Allegan County EOC staff training program on Tuesday, July 30, 1985. Additional field training reportedly was offered by the state for reception / congregate care and decontamination. The State of Michigan discussed this with Allegan County but the field training program was never conducted. The Federal evaluator determined, through his questions, that additional staff training on the operations of the reception / congregate care center is needed.

Required Corrective Action: NUREG 0654 criteria J.10.h, J.12, K.5.a and K.5.b The Department of Social Services representatives at the reception / congregate care center seemed unaware of their responsibility to be in charge of the facility. Reception / congregate care center staff demnstrated some weakness in the operation of the reception / congregate care center.

Recomendations: Additional training is needed for the Department of Social Services and the other agencies involved in the operation of the reception / congregate care center.

During pre-exercise discussions with the State of Michigan and Allegan County, FEMA Region V requested the demonstration at the reception / congregate care center actually involve the processing of individuals through the center.

It was suggested this could be done through a group of people evacuating frcrn the 10-mile EPZ.. During the pre-exercise meeting the State of Michigan representative informed the Federal evaluation team he was not certain if there would be an evacuation of people. o the t

reception center for processing. The demonstration during the exercise at the reception / congregate care center consisted of staffing and setting up the facility and answering questions asked by the Federal evaluator.

27 ~

Reconnended Area of Inprovement: 'Ihe pre-exercise agreement between FEMA Region V, the State of Michigan and Allegan County concerning how the capability at the reception / congregate care center was to be demonstrated was not followed. ' A more conplete and extensive demonstration involving the actual processing of individuals through the reception / congregate care center should be conducted during the next exercise.

Representatives of the Departnents of Social Services and Health explained the procedures for registration and radiological monitoring of evacuees.

The Health Department representative was equipped with two geigher counters with probe attachments (CDV 700 and 715) and decontamination / monitoring forms. The Social Services representative had shelter registration forms and explained the use of these forms to the Federal evaluator. The representatives of both agencies demonstrated prior training in tl.eir respective areas..The procedures and equipment for decontamination of evacuees and emergency workers was also explained.

If found to be contaminated, individuals would be sent to the showers for decontamination.

Personal clothing and other possessions found to be contaminated would be put in plastic bags. The Department of Social Services would be requested to provide replacement clothing.

If the individual was found to be " clean" they were sent to the middle school, 1/2 block to the north of the high school. This congregate care center can accomodate approximately 1900 evacuees. Other congregate care centers, as defined in the County Plan, would become operational as needed.

'Ibe Fenville High School reception / congregate care center is well outside the ten mile EPZ of the Palisades Nuclear Power Plant. The school is adequate for use as a reception / congregate care center with sufficient amenities to support the center. The feeding of evacuees will be acconplished by use of food stuff already available in the school and through local purchase by prior agreements between the American Red Cross, the school system and Allegan County.

It is also equipped to handle evacuees in wheel chairs, on crutches, etc.

Conmercial telephone was the primary means of conmunication at the reception / congregate care center.with local police and Red Cross radio as back-up. There was radio capability between the center, the ambulance and the hospital. A nursing station was available and staffed. There was quick access to hospital care by virtue of the ambulance services available at the center.

The decontamination center for emergency workers, equipment and vehicles was also located at the Fenville High School. The Fenville High School is an adequate facility for a decontamination center. The Center can handle a large number of people and a grass area next to the high school is available for vehicle decontamination. The decontamination center was activated and staffed. But the demonstration at the decontamination center consisted of the Federal evaluator asking the decontamination staff questions. During the question and answer session.the Health Department representative was found to be knowledgable regarding her assignment. She did indicate she would welcome a refresher course.

28

'Ihe Fenville Fire Department dispatched a tank truck to the decontamination center. The Fire Department representatives indicated they had not received any training in their decontamination duties and indicated they would welcome this training. Answers to questions asked by the Federal evaluator also indicated the Fenville Fire Department staff at the decontamination center did not understand their duties and responsibilities.

According to pre-exercise discussions with the State of Michigan and Allegan County, the Federal evaluation team expected a nore conplete demonstration of capability at the decontamination center.

Required Corrective Actions: NUREG 0654, criteria K.5.a and K.5.b Allegan County did not demonstrate adequate training and knowledge of procedures to decontaminate equipment and vehicles that belonged to the emergency workers.

Recomendation: The State should provide training for Allegan County decontamination center staff. During the next exercise Allegan County should conduct a full and conplete demonstration involving the radiological monitoring and decontaminatien of emergency workers,. vehicles and equipment.

Radiological Exposure Control Per FmA Region V agreement with the State of Michigan the scenario limited the demonstration of Allegan County's ability to monitor and control emergency worker exposure to activities within the EOC. Dosimetry for personnel of the County Sheriff's Department is distributed from the County EOC. Emergency worker dosimetry for County Road Comission and Fire and Rescue personnel is issued by the respective departments from locations outside the 10-mile EPZ of the Palisades Nuclear Power Plant.

There were approximately fifty low range (0-200mr) dosimeters and thirty film badges available at the County EDC. All individuals in the EOC were issued a film badge, dosimeters and a record card, although the EOC is well outside the 10-mile EPZ of the utility. This was done to demonstrate to the Federal evaluation team how this equipment would be distiributed to emergency workers from the Sheriff's Departe nt.

No written instructions on the use of the dosimeters and record keeping cards were provided in the dosimter kits. Nor were oral instructions given to emergency workers when they were issued the dosimeter kits.

Required Corrective Action: NUREG 0654, Criteria K.3.a and K.3.b.

Dosimeter kits for emergency workers did not include written instructions on the use of dosimeters, TLDs, or the interval readings should be entered on the record card and radioed back to the EOC.

Recomendation: Written instructions should be added to the dosimeter kits explaining the use of the dosineters, TLDs and the emergency worker record card. These instructions should also include what interval readings are to be entered on the record card. The next exercise should provide for a more conplete and extensive demonstration of the County's ability to continuously monitor and control emergency worker exposure control. Allegan County will be required to deploy emergency workers during the next joint exercise to better enable the county to denonstrate their ability to monitor and control emergency worker exposure.

29 1

'Ihe availtble supply of dosimeters were adequata for the number of individuals within the EOC. The dosimeters distributed within the EOC

~,

during the exercise would be those to be distributed to emergency workrro from the Sheriff's Department if access control had been selected as an objective to be demonstrated.

'Ihe second shift Radiological Officer explained the plan for distribution of dosimeters for emergency workers of the Sheriff's Department. He further reported that the deputies of.the County Sheriff's Department have received training in radiological exposure control.

Media Relations In accordance with the Allegan County plan there were no news media briefings at the Allegan County EOC. All news media representatives arriving at the County EOC would be directed to the JPIC at the Lake Michigan Comunity College, Benton Harbor, Michigan.

The Allegan County PIO at the JPIC was well trained and effectively demonstrated his coordination responsibilities between the County EOC and the JPIC. He was well versed on the County plan and participated in frequent and conprehensive briefings of the media. The PIO demonstrated, through participation with State, utility and other local PIO staff, ability to formulate and distribute appropriate instructions to the public, in a timely fashion; ability to brief the media in a clear, accurate and timely manner and ability to provide advance coordination of information released at the JPIC.- However, the Allegan County PIO was prepositioned at the JPIC contrary to pre planned exercise play determined by the State of Michigan and FEMA.

There was no activation of County personnel for the rumor control position nor an english/spanish speaking translator for the JPIC as defined in the County plan.

Required Corrective Action: NUREG 0654 criteria item E.2 Allegan County did not demonstrate the ability to alert, notify and mobilize staff for the Joint Press information center.

Recomendation: Allegan County demonstrate during the next exercise the ability to alert, notify and mobilize its staff at the Joint Press Information Center.

Required Corrective Action: NUREG 0654 criteria item G.4.c Allegan County did not demonstrate the ability to establish and. operate runor control in a coordinated fashion.

Reconmendation: During the next exercise, Allegan County should staff the County rumor control position and denonstrate the ability to establish and j

operate rumor control in a coordinated fashion.

There was no double staffing of the County PIO position nor other means demonstrated to show the County's ability to maintain staffing around the clock (twenty-four hour) staffing at the JPIC.

30 4

__m m -

Required Corrective Action: NUREG 0654, criteria items A.2.c cnd A.4 Allegm County did not demonstrate the cbility to fully etcff cnd maintnin ctaffing cround the clock st the Joint Public Information center cs ctsted in exercise objective fl.

Reconnendation: Allegan County during the next exercise demonstrate the ability to fully staff and maintain staffing around the clock (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) at the JPIC.

kccovery and Reentry Recovery and reentry was not an objective of the exercise and therefore was not evaluated.

3.

Berrien County Activation and Staffing Per FEMA and NRC agreement, Berrien County participates fully during the Donald C. Cook exercise and participates only partially during the Palisades Nuclear Power Plant exercise. Activation and staffing was not an exercise objective in Berrien County. The County is inpacted more by the Donald C.

Cook Nuclear Power Plant than the Palisades facility. Berrien County effectively demonstrated activation and staffing of County facilities during the January 25, 1984 exercise of the Donald C. Cook Nuclear Power Plant.

Emergency Operations Management The Deputy Coordinator of the Office of Emergency Preparedness was the individual effectively in charge of emergency operations as designated in the County plan. The County EOC was notified of the Alert conditions at the utility at 0906, the Site Area Emergency at 0947 and the General Emergency at 1019. There were no protective action orders issued for the County, however, plans were reviewed and options discussed by the EDC staff in the event of a radical windshift that would require inplementing protective actions.

Formal briefings were not conducted but the staff were periodically briefed by representatives of agencies in the EOC to insure the staff was kept current on the situation. The staff was involved in decison making. Copies of the plan and checklists were available for reference with some staff having excerpts of. the plan, pertaining to their respective responsibilities.

Messages were logged but because of the minimal EOC staffing it was not necessary to make copies of messages for distributitn. A copy machine was available in the EOC for multiple copy distribution.

Facilities The Berrien County EOC is located in the basement level of the County Sheriff's Departnent. The EOC has sufficient' lighting, space, telephones, furniture and other amenities to support extended operations. All required maps except a specific map showing the population distribution by sector were displayed in the EOC. The map depicting the population distribution is included in the County plan but a wall map of the areas surrounding the Palisades Nuclear Power Plant was modified to display the population distribution.

31

Recomended Inprovement: ' It is recomended that a permanent wall map depicting the population dictribution by sector cround the Palirades Nuclo r Power P1rnt be obt ined tnd used during futura ex rcises involving the Palisades Nuclear Power Plant.

Comunications Staff of the Berrien County EOC demonstrated ability to comunicate with all appropriate locations and organizations utilizing primary channels. The LEIN is the County EOC's primary means of comunications with the State and local EOC's.

Connercial telephone is the primary means of comunications with the utility, JPIC, EBS, support hospitals, schools, etc. Two way radio from a number of sources (i.e., the hospital emergency ambulance response net, the citizens band, RACES, REACT, etc.) is the back up means of comunications with the foregoing and reception / congregate care and decontamination centers. There is no hard copy capability between the JPIC and the County EOC.

Recomended Inprovement: Hard copy capability is recomended between the EOC and the JPIC.

Dose Assessment and Protective Action Recomendations Dose assessment and protective action recomendations are provided to the Counties by the Michigan Department of Public Health, Radiological Health Services Division.

The exercise play did not necessitate the need to alert and provide instructions to the public in Berrien County, except to notify them that they were not in the affected areas. The EOC staff demonstrated procedures to be followed in the event it became necessary to alert the public and provide instructions.

Public Alerting and Instructions The State of Michigan at 1019 concurred with the utility declaration of General Emergency that was declared at 1008. Van Buren County is responsible for activation of the siren system for Berrien and Allegan Counties in conjunction with the incident at the Palisades Nuclear Power Station. An EBS message was draf ted in the County EOC and sinulated activation of the EBS was demonstrated but not in coordination with telephone notification of activation of the siren system by Van Buren County at 1025. No part of Berrien County was affected by the plume. Therefore, Van Buren County did not activate the Berrien County portion of the siren system. Consequently, there was no need to alert the public by way of dissimenating and instructional message within'15 minutes.

The County's EBS message advised Berrien County residents they were not in the affected area and they should remain tuned to the EBS for further developments.

Protective Action Protective action was not an exercise objective for Berrien County and therefore was not demonstrated.

32

Padiological Exposure Control Radiological exposure control was not an exercise objective for Berrien County and therefore was not demonstrated.

Media Relations

'Ihere were no media briefings conducted at the Berrien County EOC although a space was set aside for that purpose. The Berrien County PIO at the JPIC was knowledgable and effectively performed his coordination role between the Berrien County EOC and the JPIC. The County PIO actively participated in media briefings, the exchange of information and coordination of the release

~

of information with JPIC staff of the State of Michigan, the utility and Allegan and Berrien Counties.

The County PIO, through participation with other JPIC staff, demonstrated ability to brief the media in a clear, accurate and timely manner; ability to provide advance coordination of information released and ability to formulate and distribute appropriate instructions to the public in a timely manner.

Recovery and Reentry Recovery and reentry activities were not an exercise objective and therefore were not denonstrated.

3.

Van Buren County Activation and Staffing Staff alerting and mobilization procedures were demonstrated at 0826 when the shift engineer on duty at the utility notified Van Buren County over the dedicated telephone line of the Unusual Event condition at the Palisades Nuclear Power Station. The dedicated telephone between Van Buren County and the Palisades Nuclear Power Station is nonitored 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day by personnel of the County Sheriff's comunications center.

The' Van Buren County Sheriff's Dispatcher, upon notification of the " UNUSUAL EVENT", imediately telephoned the County Emergency Preparedness Coordinator and informed him of the reported unusual event at the utility. Recently updated telephone call lists were used by the Van Buren County Sheriff's Dispatcher and the County Emergency Preparedness Coordinator to alert and mobilize the EOC staff. The County Emergency Preparedness Coordinator proceeded to the County EOC, after reportedly mobilizing the County PIO for the EOC and the Radiological Officer. He also contacted and advised key EOC staff of the situation and requested that they stand by for further information.

The Sheriff's Dispatcher received a subsequent notification of an " ALERT" condition at the utility at 0905 via the dedicated telephone line between the County Sheriff's Comunications Center and the utility. Again, the call from the utility was verified by a hardcopy message via the LEIN. The Sheriff's Dispatcher relayed the report to the County Emergency Preparedness Coordinator in the EOC, via telephone and a hardcopy by a runner. The mobilization of the remainder of the EOC staff was effected by the Energency Preparedness Coordinator from the EOC.

33

W e County successfully demonstrated the verification of messages received

/

and procedures for nobilization of County staff during this exercise. This corrects the deficiencies in the May 25, 1983 exercise concerning mobilization of staff and verification of messages.

The EOC was fully staffed at 0945 with all positions as identified in the plan. The County EOC staff denenstrated the ability to maintain staffing around the clock through the use of a shift change of personnel, double staffing and personnel rosters. County EOC personnel also displayed adequate training and knowledge of their respective duties and responsibilities.

Emergency Operations Management The County Emergency Preparedness Coordinator was in charge and effectively coordinated Van Buren County's emergency response activities. There were periodic briefings to update the staff on the situation. The staff was involved in decision making, with major decisions being made by the executive group and/or'the Emergency Preparedness Coordinator. Copies of the County plan were available for reference, with sone staff members having excerpts of written procedures and checklists pertaining to their respective responsibilities.

Message logs were kept. Messages were written on a four (4) copy message form which made for easy and efficient nessage handling and distribution. A photocopier machine and clerical staff were available for making additional copies of messages as necessary. The County was notified of the Site Area Emergency conditions at 0937 and the General Emergency at 1010.

We protective action order to take shelter was given' at 1010 and to evacuate at 1105 and 1129. The activation of reception and congregate care centers was out of sync with the exercise scenario as preplanned between Van Buren County and the State of Michigan. However, there was sinulation in the EOC with and reports of the activation of reception and congregate care centers at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />. Access to the Van Buren County EOC was controlled by personnel from the County Sheriff's office. The County demnstrated ability to make decisions and to coordinate energency activities.

Facilities The Van Buren County EOC is functional even though it is small and has limited space. The EOC has sufficient lighting, furniture, telephones and other amenities to serve as an EOC. The EOC is approximately twenty-three (23) miles from the Palisades Nuclear Power Station and therefore could support extended operations affecting the 10-mile EPZs The emergency classification levels were posted on placards which were placed above two (2) county maps, located on the wall at the front of the roixtc and could

~

easily be observed by the EDC staff.

There was a status board in the EOC. The status board was used to display significant events by use of an overhead projector. However the information displayed was hard to see, because of the small projection and the overhead projector was consistently cut off after the information was displayed only briefly. Also, information was conpletely discarded from the display as new updates were received and filled the display area.

34

i.--

Recomended Igrovement: Placing the overhead projector further from the i

status board will project a larger image for easy reading. Calling the staffs attention to the projected information will insure the staff is aware i

of new information on the board before the projector is turned off.

l All required maps were displayed in the EOC. Se population distribution map displayed in the EOC and in the County' plan shows the population distribution t'/ sectors from one through ten miles. This map display corrects a minor deficiency of the May 25, 1983 exercise.

L

}

Comunications Se comunications system demonstrated at the Van Buren County EOC functioned well during the exercise. The County demonstrated primary and j

back-up comunications with the-State of Michigan by use of a dedicated "Centrex" telephone line and the Law Enforcement Information Net (LEIN).

y i

Comunications with local EOCs is primarily by LEIN with.comercial telephone as the back-up system. Se utility has a four (4) party dedicated telephone line from the utility (with conferencing ability) to the three (3) siren activation locations in the County.

We dedicated telephone line is backed by radio and regular comercial telephones at all four (4) locations. The County's comunications with FEMA is routinely through the State of-Michigan but can be accoglished by comercial telephone. The EBS station is contacted by comercial telephone with two way radio as' secondary back up. Se JPIC can presently be contacted only by comercial telephone from the County EOC.

i There are tone alert radios in all County schools within the 10-mile EPZ of j

the Palisades Nuclear Power Plant. The support hospitals are contacted by j

telephone and/or radio from the County Sheriff's Dispatch Center. There is no hard copy capability between the JPIC and the County EOC.

i Recomended Inprovement: Hard copy capability is reu.. d ed between the EDC and the JPIC.

The County demonstrated ability to comunicate with all appropriate locations, organizations and field personael. We acconplishment of this objective corrects the required area of inprovement (significant deficiency) i cited during the May 25, 1983 exercise.

i j

Dose Assessment and Protective Action Recomendation Dose assessment and protective action recomendations for shelter _and evacuation were provided to the counties by the Michigan Department of Public Health, Radiological Health Services Division. It was recomended by the State that emergency workers in the field start taking Potassim Iodide i

(KI) daily. %e State instruction to stop taking KI was also announced by Van Buren County.

Public. Alerting and Instruction Van Buren County is responsible for the.inpjmentation of the pronpt alert

.I and notification system, drafting of EBS medages, subsequent-transmission of messages to the EBS station and activation of the tone alert radio system.

t 35 i

l

During the exercise the plEnt notified the State of the General Emergency ct 1008. The State made its casessment cnd at 1910 notified the County vis telephone, followed by h;rdcopy veriification st 1919, of its reconmendation to shelter in place 0-2 miles all sectors; 0-5 miles in sectors B, C and D.

The waterways in sectors A and R, were closed out to ten (10) miles. Air and rail were also closed out to to ten (10) miles. Sirens were activated at 1020. A simulated siren failure occurred for three (3) siren' units in the system to enable the County to demonstrate supplemental route alertire.

The EDS station was activated at 1017, prior to the siren activation at 1020. This procedure is out of sequence in that the activation of the EBS should occur after the sirens are sounded. The Federal evaluation team does not consider this a problem in that the initial EBS message would be repeated and consequently announced to the public after the sounding of the sirens. The fifteen (15) minute requiremnt in NUREG 0654/ FEMA Rep-1, Revision 1 was m t.

Portions of the messages transmitted to EBS and the JPIC were prescripted. Public information messages were adapted to reflect the emergency conditions that existed and to identify designated evacuation routes. The adapted messages were not always written out to document information given to EBS.

The sequence of the second EBS notification (first evacuation) was in correct sequence and again acconplished within fifteen (15) minutes. The third EBS notification for the expanded evacuation was received by the County at 1129 and simulated activation of the sirens was at 1130. The EBS and JPIC message identifying evacuation routes was transmitted by the County PIO to EBS and the JPIC at 1150.

The Federal evaluation team has concluded some additional training would be helpful for the PIO in the Van Buren County EOC. This is based on the actions observed during the three public alerting situations described above.

Recomnended Improvement: NUREG-0654 criteria 0.4.j The first shift Public Information Officer (PIO) in the Van Buren County EOC needs additional training in the proper sequence of activating the EBS, the use of prescripted messages and writing out all messages given to the EBS to document the infornation.

Protection Action Traffic and access control points were established and pronptly relocated to reflect the on-going emergency situation. This simulated demonstration included fifteen (15) law enforcement jurisdictions, two hundred and seventeen (217) individuals and ninety-one (91) vehicles. The demonstration was well coordinated and included personnel and equipment to deal with

~

inpediments to evacuation, traffic obstructions and access / egress via waterways.

Information was available at the EOC in written form concerning the location of the mobility inpaired and any associated special transportation requirements needed. Van Buren County is the primary local response governm nt and is also responsible for insuring transportation for people without transportation and the mobility inpaired in Allegan and Berrien Counties per each of the County plans.

36

Contrcry to the planned objectives the County did not demonstrats the 1

org;nizational (bility cnd resources necessary to effect cn orderly cv;cuation of echools within the plume EPZ. The County, on instructions from the State EOC, indicated that adace school was not.in session no evacuation was necessary.

Prior to the exercise it was agreed between FD4A Region V and the State that school would be in se asion (simulated).

Required Corrective Action: NUREG-0654 criteria items J.9 and J.10 9 %e County did not denonstrate organizational ability and resources necessary to effect an orderly evacuation of schools. This omission was contrary to pre-exercise planning between the State and FDiA.

Reconmendation: During the next joint exercise Van Buren County should demonstrate the organizational ability and resources necessary to effect an orderly evacuation of schools. Pre-exercise agreements need to be demonstrated.

It was agreed between FEMA Region V and the State of Michigan prior to the exercise that alerting and mobilization of the staff at the reception / congregate care and decontamination centers would not be an i

objective to be evaluated during the exercise. Sufficient staff at these facilities were prepositioned. Evidence was provided that the Social Service official is aware of the procedures'to activate relocation centers.

The reception / congregate care center was at the Gobles High School. The staff was well trained and capable of performing their respective functions in the operation of the reception / congregate care center. Two bilingual.

individuals were included in the staffing of the center to intrepret for non-english speaking spanish evacuees. There were also individuals from the County mental health clinic to assist with evacuees experiencing situational stress, etc.

Radiological monitoring, registration and congregate care was demonstrated.

A convoy of volunteer evacuees from the South Haven area arrived at the center in a school bus and four automobiles. We convoy had departed from a vehicle monitoring and decontamination center at the Bangor Fire Department prior to their arrival at the reception / congregate care center. Bangor Fire Department personnel had monitored the bus and four vehicles for potential radiological contamination and sinulated decontaminatin prior to releasing the convoy to proceed to the reception / congregate care center.

The congregate care of evacuees would be acconplished through prior written agreements between the County, Red Cross and the school system. Emergency food, beds and bedding and other emergency needs would be provided evacuees through the Red Cross by local purchasing.in the host sheltering areas.

We County Health Department monitoring teams conducted radiological monitoring upon arrival of the evacuees. Individuals sinulated to be contaminated were routed to a locker room with showering facilities wiere an additional monitoring team remonitored them after taking simulated showers.

l he uncontaminated evacuees were registered into the reception center fed and later returned to their houses. An American. Red Cross registration form, with multi-carbon copies, was filled out for each registrant.

37 l

Comunications at the reception / congregate care and decontamination center

/

was by telephone and two way radios. A nursing station was staffed in the reception / congregate care center. There was a demonstration of emergency medical care of a volunteer evacuee. The demonstration involved the evacuee, the arrival of an ambulance and a helicopter, which demonstrated the care and transport of the evacuee by both vehicles.

Radiological Exposure Control Radiological exposure control kits (containing TLDs, calibrated low and high range. dosimeters, KI, record-keeping cards and instructions) are issued to all emergency field workers from the County Health Department at Hartford, Michigan. Workers were instructed to call in their dosimetry readings to the health department at hourly intervals. During the~ exercise, it was recommended by State Radiological Health that emergency workers in the field start taking potassium iodide (KI) daily. The instruction to discontinue taking KI was also announced. The County demonstrated by simulation at the EOC the ability to supply and administer KI once the decision had, been made to do so. The supply of equipment is reportedly adequate for emergency field workers with any additional needs to be supplied by the utility in conjunction with the State. The County Radiological Officer, Health Department representative and County Emergency Services Coordinator are aware of decontamination procedures and emergency worker dose limitations.

Media Relations The two (2) Van Buren County PIOS and the person assigned to rumor control at the JPIC were prepositioned at the JPIC contrary to pre-exercise planning between the State of Michigan and FEMA. Also, there was no english/spanish speaking interpretator at the JPIC from the County as outlined in the County plan.

Required Corrective Action: NUREG-0654 criteria item E.2: 'Ihe County prepositioned their JPIC staff rather than alert, mobilize and deploy in real time. Also there was no english/spanish speaking interpretor at the JPIC from Van Buren County as outlined in the plan.

Recommendation: Pre-exercise agreements need to be demonstrated during the joint exercise. During the next exercise Van Buren County should activate, mobilize and deploy their JPIC staff according to real time rather than preposition them. Also deployed County JPIC staff should reflect the f

staffing shown in the plan.

A representative from Van Buren County manned the rumor control lines at the JPIC. However there was no shift change of the rumor control position manned by Van Buren County. The County plans are not consistent on how rumor control at the JPIC is manned. The Allegan County plan states rtunor control lines will be manned by the utility and local government as available.~ The Van Buren County plan states rumor control will be handled j

by the "public information officer" designee.

Required Corrective Action: NUREG-0654 criteria item A.4 Van Buren County did not demonstrate twenty-four (24) hour capability to man the rtunor control position at the JPIC.

38

Recmmendation: The next joint exercise Van Buren County should demonstrate twenty-four (24) capability to man rumor control by having a shift change, double staffing or showing the federal evaluator a roster reflecting replacement staff. The County plans should be written so they are consistent on how rumor control at the JPIC is manned.

The County PIOS actively participated in oral briefings of the media.They exchanged information and coordinated releases with the JPIC staff of the State, Allegan and Berrien Counties and the utility. The County PIOS and rumor control staff displayed adequate training and knowledge of the County plan and their respective responsibilities at the JPIC.-

Clerical help for message handling, duplicating and other support activities were provided to Van Buren County and other participating jurisdictions at the JPIC by the utility. Comnercial telephones and two-way radio relay was used by County staff to connunicate with the County EOC.

Recovery and Reentry Recovery and reentry activities were not an exercise objective to be evaluated. However, the County EOC staff discussed their awareness of recovery and reentry planning procedures. The EOC Chief of Staff identified several potential logistical problems and requested the responsible EOC departmental representatives to consider manpower and equipment needs.

l 39

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SUMMARY

LISTING OF EXERCISE FINDINGS 1

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l ITTILITY: Palisades Nuclear Power Station Stmmary Listing of Areas Requiring Corrective Actions August 20, 1985 Michigan (Date)

(State)

Michigan (Comnunity)

NUREG Narrative Statement Corrective Action Scheduled

' Actual Item of Weakness Proposed Date Date N.1.a.

'Ihe scenario did not provide a need for Berrien County to alert the public and disseminate an instructional message because the County was not affected by the plume. Therefore it did not becxee necessary for Van Buren County (siren activation location) to activate sirens in Berrien l

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1 42 (REV)

['

s UTILITY: Palisades Nuclear Power Station Summary Listing of Reconinended Inprovements Michigan August 20, 1985 (State)

(Date)

Michigan (Comnunity) 1.

State exercise controllers need to ensure the State staff understand pre-exercise agreements in order for the Counties to demonstrate their selected objectives.

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l l

43

+ -

L ITPILITY: Palisades Nuclear Power Station Sumnary Listing of Deficiencies Michigan August 20, 1985 (State)

(Date)

Allegan County (Comnunity)

NUREG

. Narrative Statement Corrective ' Action.

Scheduled Actual Item of Deficiency Proposed Date Date None 1

44

F

'<q UTILITY: Palisades Nuclear Power Station Sumary Listing of Areas Requiring Corrective Actions Michigan August 20, 1985 (State)

(Date)

Allegan County (Comunity) 1

{

NUREG Narrative Statement Corrective Action

' Scheduled Actual Item of Weakness Proposed Date Date l

J.12 The Department of Social Services l

Representatives at the reception congregate care center seemed unaware l

of their responsibility to be in charge of the facility. The center's staff demonstrated weakness, in the operation of the reception congregate care center.

l K.5.a The County's monitoring and l

K.5.b decontamination team did not l

demonstrate adequate training and knowledge of procedures to decontaminate equipment and vehicles.

K.3.a Dosimeter kits for emergency workers K.3.b did not include written instructions on the use of dosimeters and TLD, nor the interval readings should be entered on the record cards and radioed / telephoned back to the EOC.

E.2.

'Ihe County did not demonstrate ability to alert, notify and mobilize staff.

for the Joint Press Information Center.

45 i

I

UTILITY: Palisades !!uclear Power Station Sunmary Listing of Areas Requiring Corrective Action Michigan Atsust 20, 1985 (State)

(Date)

Allegan County (Conmunity)

NUREG Narrative Statement Corrective Action Scheduled Actual Item of Weakness Proposed Date Date G.4.c

'lhe County did not demonstrate ability to establish and operate rumor control in a coordinated fashion.

A.2.a

'1he County did not demonstrate A.4 ability to fully staff and maintain

. staffing around the clock at the Joint Public Information Center as stated in exercise objective #1.

P 46 l

l UTILITY: Palisades Nuclear Power Station Sunmary Listing of Reconnded Inprovement Michigan August 20, 1985 (State)

(Date)

Allegan County (Cormonity) 1.

'Ihe present hand carrying system of deliveringmessages between.the Sheriff's Office and the EOC should be revised to a more efficient system.

2.

The County should consult with the State Radiological Health Division before adding or deleting information contained in protective action instructions issued by the State Health Department.

3.

A more conplete and extensive demonstration involving the actual processing of individuals through the reception / congregate care center should be conducted during the next exercise of the Palisades Nuclear Power Plant.

4.

Hard copy capability is reconmended between the EOC and the JPIC.

47 l

l UTILITY: Palisades Nuclear Power Station Sumary Listing of Deficiencies Michigan August 20, 1985 (State)

(Date)

Berrien County (Comunity)

NUREG Narrative-Stat'ement Corrective Action Scheduled Actual i

Item of Deficiency Proposed Date Date 4

t i

I i

48 3

l

.. ~

r UTILITY: Palisades Nuclear Power Station Sumary Listing of Areas Requiring Corrective Action Michigan August 20, 1985 (State)

(Date)

Berrien County -

(Comunity) i j

NUREG Narrative Statement Corrective Action Scheduled Actual Item of Weakness Proposed Date Date 1

1 e

I 49 i

i 4

1 t

UTILITY: Palisades Nuclear Power Station Stamary Listing of Recommended Inprovements Michigan August 29, 1985' (State)

(Date)

Berrien County (Conmunity) 1.

It is recw...rakx1 that a permanent wall map depicting the population distribution by sectors around the Palisades Nuclear Power Plant be obtained and used during future exercises involving the utility.

2.

Hard copy capability is reconmended between the EOC and the JPIC.

59

~

UTILITY: Palisades Nuclear Power Station Sumary Listing of Deficiencies Michigan August 20, 1985 (State)

(Date)

Van Buren County (Comunity) i NUREG Narrative Statenent Corrective Action Scheduled Actual Item of Deficiency Proposed

.Date Date i

1 l'

None i

I f

4 1

J J

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51 4

1 1

1

0 g

l UTILITY: Palisades Nuclear Power Station Samary Listing of Areas Requiring Corrective Actions Michigan August 20, 1985 (State)

(Date) l Van Buren County (Comunity)

NUREG Narrative Statement Corrective Action Scheduled Actual Item of Weakness Proposed Date Date J.9 Van Buren County did not J.10.g demonstrate an evacuation of schools within the 10 mile l

plume EPZ.

E.2

'Ihe County prepositioned their JPIC staff rather than alert, mobilize and deploy in real time. Also, there was no l

english/spanish interpretor_at the JPIC from Van Buren County as outlined in the plan.

A.4 Van Buren County did not demonstrate twenty-four (24) hour capability to man the rumor contol position at the JPIC.

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• 4 3

UTILITY: Palisades Nuclear Power Station Sunmary Listing of Reconinended Inprovements Michigan August 20, 1985 (State)

(Date)

Van Buren County (Consnunity) 1.

Placing the overhead projector further away from the Status board in the EOC will project a larger image for easy reading. Calling the staff's attention to the projected information will insure the staff is aware of new information on the board before the projector is turned off.

2.

Hardcopy capability is reconmended between the EOC and the JPIC.

3.

The 1st shift Public Information Officer in the Van Buren County EOC needs additional training in the proper / sequence of activating the EBS, the use of prescripted messages and writing out all messages given to the EBS to document the inforrution.

k 53

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