ML20211B446

Advises NRC of Several Deficiencies in Alert & Notification Sys Around Plant.Fema Cannot Make Statement of Reasonable Assurance That Plant Alert Notification Sys Adequate to Provide Prompt Alerting to Population

ML20211B446
Person / Time
Site:	Cooper
Issue date:	10/10/1986
From:	Mcloughlin D Federal Emergency Management Agency
To:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20211B451	List: ML20211B446 ML20211B467 ML20211B475 ML20211B485 ML20211B489 ML20211B497 NLS8600164, Confirms That Official 30-day Response Period Re Concerning Offsite Public Notification Begins on 860505 Based on 860429 Discussion.Related Info Encl
References
NUDOCS 8610170238
Download: ML20211B446 (23)

Text

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J y Federal Emergency Management Agency l I .

Washington, D.C. 20472 O O OCT I 0190s Mr. Victor Stello, Jr.

Executive Director for Operations U.S. Nuclear Regulatory Ccanission Washington, D.C. 20555  ?

Dear Mr. Stello:

The purpose of this letter is to advise you of several deficiencies in the alert and notification system (ANS) installed around the Cooper Nuclear Station in Brownsville, Nebraska. The Federal Emergency Management Agency (FEMA) has conpleted a review of the Cooper ANS pursuant to FEMA Rule 44 CFR 350; selected evaluative criteria and Appendix 3 in NUREG-0654/ FEMA-REP-1, Revision 1; and FEMA-43, the " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" (now published as FEMA-REP-10 ) . Thus far, FEMA has completed a preliminary engineering review of the ANS design submitted by the Nebraska Public Power District (NPPD),

evaluated the results of a telephone survey of residents of the emergency planning zone (EPZ) following activation of the Cooper ANS on October 17, 1985, and evaluated ANS components during several offsite radiological '

emergency preparedness exercises and remedial drills. l FEMA's review of the Cooper ANS design and evaluation of the capabilities of  !

offsite authorities to implement alert and notification procedures has revealed I deficiencies and inadequacies in various components of the system that have essentially renained uncorrected for over two years despite attempts by the States of Missouri and Nebraska and NPPD to correct the problems. Below is a listing of reoccurring inadequacies and deficiencies related to the Cooper ANS that have been cited by FENA during various exercises. Although some of these deficiencies and inadequacies were corrected during remedial exercises, scune have been repeated in the latest exercise conducted on September 24-25, 1986, despite the past corrective actions.

• May 15,1984 Exercise Evaluators cited 75 " Deficiencies" (these deficiencies would now be classified as areas requiring corrective action) of which five were directly related to the ANS and two of these related to alerting transients at the Indian Cave State Park.

• October 16, 1985 Exercise Evaluators cited three " Deficiencies" directly related to ANS procedures at. Indian Cave State Park, Brickyard Hill State Wildlife Area, and the Atchison County, Missouri Emergency Operations Center (EOC). The Deficiency related to the Atchison County EOC was subsequently corrected at a November 26, 1985 remedial exercise and the deficiency related to the Brickyard Hill State Wildlife Area was subsequently corrected at a June 16,1986 remedial exercise.

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• September 24-25, 1986 Exercise Evaluators cited 2 " Deficiencies" directly related to ANS procedures for Indian Cave State Park, Brickyard Hill State Wildlife Area, portions of-the Missouri River between the two States, and the.Atchison County, Missouri EOC. 'Ihe results of this exercise will be forwarded to you in early November 1986.

The. enclosed chronology prepared by FEMA Region VII, and supported by relevant documentation,- details efforts to resolve the inadequacies and deficiencies -

-identified in the Cooper ANS . review and exercises wer the past two years.

-In consideration of the Cooper ANS deficiencies cited in the September 24-25, 1986,' exercise and the fact that these deficiencies have reoccurred despite the efforts of. Nebraska,: Missouri, and NPPD to correct them over the past two years, FEMA must advise NRC that the Cooper ANS does not currently satisfy the require-ments of FEMA Rule 44 CFR 350 and the Nuclear Regulatory Comunission (NRC) Rule-10 CFR 50, Appendix E; nor have the design objectives in NUREG-0654/ FEMA-REP-1, Revision 1, and FEMA-43 been satisfied. Therefore, FENA cannot make a statement ,

of reasonable assurance that the Cooper ANS is adequate to provide prompt alerting and notification to the population in the event of an emergency at the site. In light of this, FEMA finds that the condition on the adequacy of the ANS in the 44 CFR 350 approval of offsite plans dated July 2,1984, is not satisfied, .thus creating a serious shortfall in the werall adequacy of offsite planning ~ and pre-paredness. FEMA is, therefore, invoking the provisions of FEMA Rule 44 CFR 350.13 to withdraw apprwal of the Missouri and Nebraska offsite plans site-specific to the Cooper Nuclear Station.

The Gwernors of the States of. Missouri and Nebraska will be officially notified through. the Director of FEMA Region VII of the specific reasons for FEMA's in-voking of 44 CFR 350.13. - 'If after four nonths from the date of their official notification, Missouri and Nebraska have not either corrected the deficiencies noted, or' submitted an acceptable plan for correcting the deficiencies, FEMA will withdraw approval of both State plans and innediately inform the NRC and the Governors of both States of the determination to withdraw the approvals. At that time FEMA would also publish notification of the withdrawal in the Federal i Register and in the local newspapers having the largest daily circulation.

Copies of all correspondence regarding this matter will be provided to you.

If you have any questions please contact Mr. Robert S. Wilkerson, Chief, Techno-I logical hazards Division at 646-2860.

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Sincerely,

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_T p-1 Dave McIoughlin Deputy Associate Director Enclosure

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f @7 q Federal-Emergency Managernent Agency Region VII 911 Walnut Street Kansas City, Missouri 64106

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SUBJECT:

Findings of Inadequate Planning to Protect Public Health and Safety for the Transient Population in the 10 mile EPZ of the Cooper Nuclear Station In accordance with kk CFR 350.13(a), the purpose of this memo is to provide the information necessary to support my position that the portions of Nebraska and Missouri State Plans addressing Planning Standards E, F, N, and Appendix 1, relating to the Cooper Nuclear Station, 3 of NUREG-065h/FDM-REP-1, Rev.Therefore, I can no longer attest that these State and are deficient.

plans are adequate to protect public health and safety by providing reasonable assurance that appropriate protective measures can be taken.

This action is necessary since, on July 2, 198h these plans were approved on "the condition.

the adequacy of the public alert and notification

. .that and ' operational must be verified as meeting the system already installed 1". (See standards set forth in Appendix 3 of UUREG-065h/ FEMA-REP-1, Rev.

exhibit #1.)

The recent exercise of September 2h and 25, 1986, failed to demonstrate alert and notification within 45 minutes in accordance with the special alerting provisions of Revision 5 to the Alert and Notification System (ANS)

Design Report. (See exhibit #2.) Specifically, the aircraft failed to fly the assigned route over the Brickyard Hill State Wildlife Area in Missouri. Indian Cave State Park in Nebraska, and portions of the Missouri River separating the two States in the time required; and the State of demonstrate the ground vehicle route alerting within -

Nebraska declined to The State declined, due to the reported unwillingness Indian Cave State Park.

of Park Officials, to run the routes because of personal injury sustained This failure in itself would not when the system was initially tested.

cause me to adopt such a strong position, except that it has been preceeded by a history of persisting deficiencies in the ANS.

Following is a chronicle of events outlining FEMA's rGationship vith Missouri, Nebraska and the Nebraska Public Power District (NPPD) in attempting to provide an ANS that will conform to the applicable requirements:

Evaluators May 15, 198h - The annual exercise was conducted this date.

(now known as " areas requiring corrective action").

cited 75 " Deficiencies" Two of them occurred in Five of them were directly related to the ANS. (See exhibit the process of alerting transients at Indian Cave State Park. required a successful

1. 3.) The corrective actions called for by FDM VII demonstration at the 1985 exercise.

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October 9,198h - In response to a FEMA VII inquiry, HPPD promised delivery of its ANS not later than March 31, 1985 May 23, 1985 - HPPD's MIS arrived in FDM VII, forwarded by State of Nebraska.

October 16, 1985 - Conducted annual exercise at Cooper. Six deficiencies were cited, three were directly related to ANS. One was at Brickyard Hill State Wildlife Area, one at Indian Cave State Park, and one at the Atchison County EOC. (See exhibit #h.)

October 31, 1985 - FDM VII sent a memo to Missouri detailing the ANS exercise deficiencies. relating to the Atchison County EOC and the Brickyard Hill State Wildlife Area. A remedial exercise was needed. This memo followed numerous telephone co==unications regarding the matter. (See exhibit #5.)

November h,1985 - Received from FDM Headquarters the preliminary technical review of the Cooper MIS. It indicated the lack of any provisions for alert at the Brickyard Hill State Wildlife Area. (See exhibit #6.)

November 8, 1985 - The Director and staff of the Missouri State E=ergency Management Agency (Missouri SDM) came to the FEMA VII to discuss alert and notification at Brickyard Hill.

November 14, 1985 - FEMA VII memo responded to Missouri's proposed remedy to the mis deficiencies. FDM VII response was essentially negative, due to the lack of sufficient information regarding equipment specifications.

(See exhibit #7.)

November 26, 1985 - Remedial exercise successfully demonstrated correction of ANS deficiency at Atchison County EOC.

December 20, 1985 - Cooper Exercise Evaluation Report was issued. The deficiency at Brickyard Hill remained open. (See exhibit #8.)

January 27, 1986 - FDM VII memo responded to Missouri notification that they cannot accomplish remedies for Brickyard Hill by the February 1h,1986 deadline. Called _ for Missouri response by February 3, 1986. (See Exhibit

1. 9.)

February 3, 1986 - Missouri memo to FDM VII gave proposed time frame for correcting alert and notification at Brickyard Hill. (See exhibit #10.)

February 10, 1986 - FDM VII response to Missouri said they continue to ignore the issue of amendments to the ANS Design Report and again cited required actions and timetables. (See exhibit #11.)

February 13, 1986 - Missouri submitted proposed changes to State and local plans implementing the revised (and still " proposed") ANS.

February 20, 1986 - Missouri Director of SDR'came to Kansas City to meet with FDM VII concerning remedial action for Brickyard Hill.

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e March 7,1986 - FDM VII sent detailed critique to Missouri regarding proposed alert and notification plan changes. Memo noted that there is still no amendment to the Design Report, 'and plan changes are based on assumptions that_may not be substantiated by the Design Report. (See exhibit #12.) ,

March 18,1986 - Memo from FDM Headquarters concerning FDM VII's position that the procedures for alerting transients 'on the Missouri River are inadequate. Stated that ANS vould not be approved until the issue is settled.

(See exhibit #13.)

April 3, 1986 - FDM VII memo to Missouri and Nebraska cited alert and notification problems on the River. (Sec exhibit #1h.)

April 17, 1986 - Memo from NRC to NPPD directed them to interact with the appropriate State agencies and coordinate with FDM VII to solve the river problem within 30 days. (See exhibit #15.)

May 13, 1986 - NPPD memo to. NRC claimed they never received the April 17, 1986 meco and asked for extension to June 5, 1986. (See exhibit #16.).

May 1h,1986 'FDM VII memo to Missouri expressed concern that no amendment to the Design Report had yet been received, and that the remedial exercise depended on this document and the revised plans. (See exhibit #17.)

May 16, 1986 - Missouri SDM submitted a description of the alert and notification for Brickyard Hill, dated May 12, 1986. (See exhibit #18.)

May 21.- 1986 . FDM VII held a Regional meeting for_ States and Utilities to discuss a variety of issues including the new Guidance Memoranda.

Principal participants from Cooper met at length with FDM VII staff. Alert and notification was fully discussed, especially the river and Brickyard Hill.

May 23, 1986 - FDM VII faxed memo to Missouri SDM responding to their May 16, 1. T submission. Main concern was the continued absence of Design Report amenament to support the proposed plan changes. (See exhibit #19.)

May 30,1986 - FDM VII received from Missouri Revision 1 to ANS for Brickyard Hill and the plan changes necessary to implement the system. (See exhibit

1. 20.)

June 2, 1986 - FDM VII memo to Missouri SDM evaluated the ANS Revision 1 and the plan changes; cited lack of coverage of Missouri River, and several other short comings. ~A response date of June 9, 1986, was established.

(See_ exhibit #21.)

June 5,1986 - FHM VII received from Nebraska copies of NPPD letters sent to Missouri and Nebraska, and NPPD letter to NRC. They are:

(1) May 30, 1986 NPPD to Missouri and Nebraska stating that NPPD's closed circuit TV security camera which monitors river traffic for 2 miles up and down stream detected only 66 craft carrying

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'i transients in a period from May 15, 1982 to May 1 -1983 Based on this activity level NPPD asserted that its ANS was adequate.

They did agree with FDM that signs should be erected at public river access areas and the boundaries of the EPZ. NPPD agreed to erect the river access signs by September 1, 1986. (As of September 2h, 1986 this had not been done.) Boundary signs were scheduled to be in place on or before January 1,1987.

(2) June 2, 1986, NPPD to NRC stated that a true assessment of the ANS is not possible without the results of FDM VII's evaluation of the Design Report, and results of FD!A VII's telephone survey taken on October 17, 1985 (But FDM VII had, as chronicled above, issued to NPPD the portion of the evaluation pertinent to the issue at hand. ) They also propose to NRC that they can deal with FD4A VII's ANS river concerns using their TV cameras, mobile alerting, Cox Aviation, the Nebraska Civil Air Patrol, and the United States Air Force. (Cox Aviation is the only one mentioned in Revision 1 to the ANS and that is for alerting Brickyard Hill, not the river.)

(3) June 3, 1986, NPPD memo to Missouri and Nebraska stated that Cox Aviation vill perform alert on the north segment of the river between 5 and 10 miles. NPPD is currently negotiating with the USAF 'and the Nebraska CAP to perform alert on the south segment of the river, and project August 1, 1986 for the completion of arrangements.

(See exhibit #22.)

June 6.1986 - FDM VII memo to Missouri and Nebraska responded to the NPPD memos cited above. FEMA VII referred to the NPPD correspondence as a " concept paper" with no substantiation and cited applicable regulations requiring an amendment to the Design Report. Deadline August 15, 1986. (See exhibit

1. 23.)

June 6,1986 - FDM VII received fax from Missouri SD!A containing Revision 2 to the ANS, and necessary changes in State and local plans. They described the conbined use of a Park Ranger in a vehicle to provide route alerting and Cox Aviation flying over Brickyard Hill to provide initial alert. Also included was description of route alerting by park employees at Indian Cave State Park. (See exhibit #2h.)

June 9,1986 - FD4A VII memo to Missouri SDM approved proposed plan changes as suitable for testing at Brickyard Hill remedial exercise on June 16, 1986, and provisionally accepted ANS Revision 2, for Brickyard Hill contingent upon technical review. (See exhibit #25.)

June 11, 1986 - FDM VII' forwarded ANS Revision 2 to FD4A Headquarters for technical review. (See exhibit #26.)

June 19, 1986 - FDM VII transmitted to FDM Headquarters the report of a successful remedial exercise at Brickyard Hill held on June 16, 1986.

(See exhibit #27.)

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July 15, 1986 - HPPD, Nebraska and Missouri met with FHM VII to present a " DRAFT" of Revision 3 to the ANS. It. included two new fixed sirens for the Missouri River within 5 miles; provision for signs on the river; and airborne alerting for portions of the river without sirens between 5 and 10 miles. However, Letters of Agreement (LOAs) were unsigned and the DRAFT left 3/h mile of the river within the 5 mile ring uncovered by any means of alert. These inadequacies were cited by FDIA as requiring correction by August 15, 1986 in a final ANS revision. (See exhibit #28.)

August 15, 1986 - NPPD submitted Revision 3 to the ANS, but still in DRAFT form without having corrected the inadequacies cited at the meeting of July 15, 1986.

August 19, 1986 - FDM memo to Nebraska and Missouri rejected NPPD's submission due to the fact that the Design Report amendment was only a DRAFT; it still did not address a 3/h mile stretch of river within the 5 mile ring; ar.d LOAs were still unsigned. Gave deadline of September 9, 1986, for corrective action. (See exhibit #29.)

September 9,1986 - FDM received from NPPD Revisions 3 and 4 for the ANS.

Revision 3 restated the addition of two more sirens for installation in mid October, 1986. Revision h addressed alert and notification of transients on the Missouri River and presented NPPD rationale to eliminate the need for airborne alert on the southern portion of the river. The rationale was that 50 dB siren coverage would be extended to these areas based on the loss of 10 dB per distance doubled, and the claim that ambient noise levels are 38.3 dB. NPPD applied the same rationale to the 3/4 (See mile stretch exhibit of river within the 5 mile ring previously unaccounted for.

1. 30.)

September 15, 1986 - Revisions 3 and h were sent to FHM Headquarters for technical review, particularly in the area of the ambient noise survey.

(See exhibit #31.)

September 18, 1986 - FDM VII memo to Nebraska acknowledged receipt of Revisions 3 and 4. It also noted that we had received verbal com=unication that Nebraska vould use aircraft for alert at Indian Cave State Park.

Requested additional amendment to Design Report. (See exhibit #32.)

Primary alert on September 23, 1986 - NPPD submitted Revision 5 to ANS.

all parts of the river without sirens was to be covered by Cox Aviation.

It also added a third new siren, and introduced airborne alerting for Indian Cave State Park for the first time. (See exhibit #33.)

September 2h and 25, 1986 - FDM VII evaluated exercise for Missouri and Nebraska at Cooper Nuclear Station and observed deficiencies related to the ANS.

September 26, 1986 - FDM VII memo to FD4A Headquarters detailed the two (2) deficiencies and recommended a negative finding regardin6 the Cooper ANS. (See exhibit #3L.)

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O September 26, 1986 - Received memo from IEAL to FEMA Headquarters concerning Revisions 3 and it . Preliminary analysis indicated a failure to provide information required by FEMA REP-10, pages E-8 and E-9 to justify the claimed ambient noise levels. (See exhibit #35.)

As a result of the information provided herein, I find that I no longer have reasonable assurance that the health and safety of the public can be protected and recommend that the Alert and Notification System for the Cooper Nuclear Station be returned to the licensee as disapproved; that the Associate Director, SLPS, take the action outlined in hk CFR 350.13 of informing the States of Nebraska and Missouri that the Plans submitted by those States, and their respective local governments, are no longer adequate, as described in 350.13; that the Associate Director, SLPS, give notice to the affected States, that within four months of the date of said letter, should the planning deficiencies herein noted fail to be corrected, action vill be taken by the Federal Emergency Management Agency for full vithdrawal of the approval of the 350 Planning submission for the Cooper Nuclear Station.

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.w 2'/211 s Federal Register / Vol. 49. No.128 / Monday. July 2.1984 / Notices plans in accordance with I 350.10 of the FEMA rule. In addition the Regional Director submitted an addendum dated May 22.1964 that considered the -

revision in plans and preparedness si ice the final report on the April 6.1963.

esercise.This last evaluation reported r.g outstanding -

that the rer densenee . e been res.Ned.

Cooper 350 Basedc Region v evaluation by the r and the review by the E

rm^ > i ~ ers stalr.i find and Approval determine that s.bject to the condition statedbelow the State andlocalplana and preparedness for'the Cooper

" Nuclear Station are adequate to protect MO & 9 u .

the health and safety of the public living in the vicinity of the plant.These offsite plans and preparedness are assessed as adequate in that they provide reasonable assurance that appropriate protective actions can be taken offsite in -

the event of a radiological emergency and are capable of beingimplemented.

The condition for the above approvalla that the adequacy of the public alert and notification system already installed

. - and operational must be vertfled as meeting the standarda set forth in appendix 3 of the Nucleair Regulatory Commission (NRC)/ FEMA criteria of

, NUREG-0654/ FEMA-REP-1, Revision 1.

FEMA willcontinue to review the status of offsite plana and preparedness associated with the Cooper Nuclear Station in accordance with section 350.13 of the FEMA rule.

For further details with respect to this

- action. refer to Docket File FEMA-REP-7-MO-2 maintained by the Regional Director. FEMA Region VII.911 Walnut g ,, g pg ,3,,gpq ,,,,,, Street. 2nd Floor Kansas City. Missouri The MissouriEmergency 64106.

Preparedness Plan Site-Specific for For the Federal Emergency Management the Cooper Nuclear Station ^8 5 u W.5 peck, Action: Certification of FEMA findings *D"**

accordanc th the Federal h#$f ,,", #'"##

Emergency Management Agency l

" **State ***" "* '*' * * " "****l (FEMA) rule 44 CFR Part 350.

of Missouri submitted its plans relating the to the Cooper Nuclear Station to the Director of FEMA Region VII on May 26. go ,,,,, ,,,pgga ,g ,,7,yg,,y 1963. for FEMA review and approval. The Nebraska Emergency On November 30,1963 the Regional Preparedness Plan Site Specific for Director forwarded his evaluation the to the Cooper Nuclear Station Associate Director for State and I.ocal

Programs and Support in accordance Action: Certification of FEMA findings with I 350.11 of the FEMA rule. Included and determination.

FEDERAL. EMERGENCY in this evaluation is a review of the In accordance with the Federal State and local plans around the Cooper Emergency Management Agency MANAGEMENT AGENCY Nuclear Station, and evaluations of the (FEMA) rule 44 CFR 350, the State of joint exercises conducted on March 10. Nebraska submitted its plans relating to 1962, and April 6.1963.in accordance the Cooper Nuclear Station to the with I 350.9 of the FEMA rule, and a Director of FEMA Region VII on May it.

report of the public meeting held on 1963, for FEMA review and approval, August 6.1961, to discuss the site. On November 30.1963, the Regional specific aspects of the State and local

i 'd i

27212 Federal Register / Vol. 49. No.128 / Monday. July 2.1984 / Notices Director forwarded his evaluation to the Associate Director for State and 1.ocal Programs and Support in accordance with i 350.11 of the FT.MA rule. Included in this evaluation is a review of the State and local plans around the Cooper Nuclear Station, and evaluations of the joint exercises conducted on March 10, 1962, and April 6. i983. in accordance with l 350.9 of the FT.MA rule, and a report of the public meeting held on August 6.1961, to discuss the site.

specific aspects of the State and local plans in accordance with I 350.10 of the FEMA rule. In addition the Regional Director submitted an addendum dated May 22.1964 that considered the revision in plane and preparedness since the final report on the April 6.1983. ,

exercise.This last evaluation reported that the remaining outstanding deficiencies have been resolved.

Based on the evaluation by the Regional Director and the review by the FEMA Headquarters staff. I find and determine that. subject to the condition stated below, the State and local plans

. cnd preparedness for the Cooper Nuclear Station aos adequate to protect the health and safety of the public living

(, in the vicinity of the plant.These offsite plans and preparedness are assessed as cdequate in that they provide reasonable assurance that appropriate protective actions can be taken offsite in the event of a radiological emergency cnd are capable of being implemented.

The condition for the above approval is that the adequacy of the public alert and notification system already installed l

cnd eperational must be verified as

( meeting the standards set forth in tppendix 3 of the Nuclear Regulatory Commission (NRC)/FT.MA criteria of

(

NUREG-0654/ FEMA-REP-1. Revision 1.

FEMA will continue to review the status of offsite plans and preparedness "tssociated with the Cooper Nuclear l Station in accordance with section 350.13 of the FEMA rule.

For further details with respect to this tction. refer to Docket File FEMA-REP-7-NE-2 maintained by the Regional Director. FEMA Region Vll. 911 Walnut Street. 2nd Floor. Kansas City. Missouri 64106.

For the Federal Emergency Managernent Agency.

Samusi W. Speck.

Associate Director. State andlocalProgmms UdSupport inomesmcome m ees.t amasse caos erou

, 1 Federal Emergency Management Agency ~

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< Kansas City, Missouri 64106 Region VII 911 Walnut Street

• September 26, 1986 s MEMORANDUM FOR: Dave McLoughlin Acting Associate Director nd Local Programs and Support k

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. Over treet FROM: .

Regional Director

SUBJECT:

Exercise Deficiencies and AENS Negative Finding -

Cooper Nuclear Station On September 24 and 25, 1986, FEMA Region VII evaluated an exercise of the Radiological Emergency Response Plans of the States of Nebraska and Missouri and the local jurisdictions located within the 10-mile EPZ of the Cooper Nuclear Station.

Two deficiencies we,re observed. The first was observed at the Atchison County, Missouri EOC where local officials failed to sound'the sirens in conjunction with the initial public notification message.

The second was the failure to accomplish timely alert of transients within the 5 to 10 mile areas of the EPZ. The alert signal was to be sounded from an aircraft the flight pattern of which would carry it over the Brickyard Hill State Wildlife Area in Missouri, Indian Cave State Park in Nebraska, and portions of the Missouri River sepsrating the two states.

The aircraft did not complete its route within the required 45 minutes.

CORRECTIVE ACTIONS:

1. Atchison County EOC - The county plans must be revised to clearly indicate: When the sounding of sirens will be required, and who will be responsible for giving the order to sound the sirens.

In addition, a check list of this procedure should be prepared for use by the person who orders the activation of the sirens.

2. Timely Aerial Alerting - FEMA Region VII recommends that the Design Report for the Alert and Notification System for Cooper Nuclear Station be found unacceptable and, by this memorandum, we are issuing a Negative Finding for the Cooper AEN System.

A comprehensive memo supporting said finding is being prepared and will be sent forthwith.

Both states have been notified of the above by means of a telephone message from this office. A written notification to the states will follow.

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The purpose of this memo is to document the "conferral process" called "

for in GM EX-1.

k cc Fran I,aden R. D. Ross Region VII RAC I

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g /P(Y '3 gg procedures, equipment and personnel performance and capabilities at the decontam- -

Instion facility were very good.

Deficiencies That Would Lead to a Negative Finding

\-

No deficiencies that would lead to a negative finding were observed at the a"'

Auburn decontamination station.

s 2.2.8 Route Alerting -Indian Cave State Park Overview Route alerting in Indian Cave State Park was effectively demonstrated during the exercise. However, initiation of the alerting procedure did not occur until 0954; approximately one hour after the declaration of the General Emergency. A more prompt notification of park officials is needed. Two vehicles, equipped with public address systems were used on the paved roads. The road network was covered in approximately 10 minutes (completed by 1005). Two all-terrain vehicles (ATVs) were used on the trail system. The trail system, except Hardwood Trail, was covered in 20 to 30 minutes.

Hardwood Trail is five miles long, and would require an additional 20-30 minutes to cover with 2 ATVs. In a worst case situation, assuming good weather condition, it is estimated that 45 minutes to an hour would be required to cover the entire park.

During the winter, a large population of cross-country skiers is often present in the park, but away from the trails. Existing park vehicles may not be adequate to operate on the trails. It is not clear that the dispersed skiers could be alerted effectively under existing plans. More time to evacuate the park might be gained if the procedures were changed to initiate route alerting at the Site Area Emergency instead of the General Emergency. Another remedy might include the use of a fixed siren system with alert instructions contained in the park brochure. Each suggestion has associated drawbacks, but some method should be implemented to ensure park visitors can be alerted and evacuated.

Park personnel were observed to be untrained in the various aspects of radiation i exposure control. Park personnel were not equipped with personal dosimeters and were not aware of the need for them. As the park is within the 10-mile EPZ, the emergency workers should be equipped with personal dosimetry and be trained in reading and recording values. As such, they were unaware of the maximum allowable dose, the need and procedures concerning K!, and the need and procedures for decontamination. Park personnel require training in radiation exposure control.

Deficiencies That Would Lead to a Negative Finding No deficiencies that would lead to a negative finding were observed during the

! exercise at Indian Cave State Park.

,6 45 e.

Deficiencies and Recommendations e

1. Deficiency: Initiation of route alerting did not occur until approximately one hour after the declaration of the General Emergency (NUREG-0654,11. E.1, E.6).

Recommendation: A more prompt alert and notification of park -

s officials is required.

3

2. Defleiency: During inclement weather, especially deep snow, '"

existing park vehicles may not be adequate to operate on the trails (NUREG-0654, II, E.5, J.10.c, k).

Recommendation: The state should develop procedures to alert, notify, and evacuate transient park visitors during all seasons of the year and weather conditions.

3. Deficiency: Park personnel were observed to be untrained in the varied aspects of radiation exposure control (NUREG-0654, II, J.10.e; K.3.a,b; K.4; K.5.a,b; O.1; O.4.]; O.5).

Recommendation: As the park is within t'ae 10-mile EPZ, training in personal dosimetry and record keeping, the use of KI, maximum allowable doses, and decontamination is required. A schedule for annual retraining should be developed.

213 MISSOURI OPERATIONS 2,3,1 Atchison County EOC/ Missouri Forward Command Post Overview Activation and staffing at the Atchison County EOC/ Missouri Forward Command Post was well demonstrated in accordance with the planned procedures. The call initisting activation of the ACEOC was received by the Sheriff's Office from SEMA at 0510 and verification was simulated. The sheriff's dispatcher contacted the Emergency Management Director, who completed the notification of EOC staff. The state personnel n:tified the required state resource people. The EOC was fully staffed by the Atchison Ccunty staff by 0630. Although the state staff was prepositioned in Rock Port, Missouri, th';y simulated travel from Jefferson City by helicopter and arrived at the Forward Ccmmand Post by 0900. A round-the-clock staffing capability was demonstrated by the pr:sentation of a roster and a shif t change at the ACEOC.

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The County Presiding Judge or an assistant was effectively in charge and was pr:sent throughout the exercise. Periodic briefings were conducted and the ACEOC st:ff was involved in decision making. A copy of the plan and written procedures and ch:cklists were available for reference. Messages were reproduced and efficiently distributed to appropriate representatives. Message logs were maintained. ACEOC g

access was controlled.

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• P QERCISE OF / 0 - /6- 8 5~

co=pleted. At 13k0 the EOF called to ask about the location of the tec ss + ol roadblocks. It became apparent that roadblock not been -

cstablished. vere credered to be set up at 13h ure to establish ccc:ss control in a =anner was a defici a .

On Nove=ber 29, 1985, the submitted changes to the Ne=aha County Plan clarifying responsi . ies re to access control. A training s:ssion for County etors with REP resp 111 ties has been scheduled for January, 1 . Access control vill be a point o sis. k s deficiency will be closed, pending a demonstration next Q 3 . 1 . 16 Alert and Notification - Indian Cave State Park Indian Cave State Park was not notified by the Nemaha County EOC in sufficient time to conduct route alerting, thus providing alert and notification to park users within h5 minutes from the time off-site cuthorities are notified, as required by NURm-065k.

On Nove=ber 18, 1985, a meeting was held with Nebraska Game and Parks officials, the Superintendent of Indian Caves State Park, the Director of R2diological Health and the Assistant Director of State Civil Defense.

The resultant decision was that all State evned parks, recreational cnd vildlife areas within 10 miles of a nuclear power plant vould begin Gv2cuation procedures no later than the announcement of a Site Area Emergency.

Also, State and local Plans have been amended to specify both the persons responsible and the times for notification to assure that parks and recreation ar: s can co= ply.

This deficiency vill be closed pending a de=enstration of the capability of the County to notify Indian Caves State Park, and the Park to alert and notify transients in the park within the alotted time at the next exercise.

3.2 MISSOURI DEFICIENCIES 3.2.1 Atchison County EOC The first is the failure of the Atchison County EOC to provide both cn clert and an instructional message to those citizens of Atchison County within the 10 mile EPZ vithin 15 minutes as prescribed by NUREG-065k, Appendix 3.B.

The 15 minutes begins when the plant notifies the off-site authority _

of the emergency.

At 110k the General E=ergency was declared. The licensee attempted, cecordirg to the State Plan, to notify SEMA at the State EOC. The line was busy, and after two failed atte= pts, the utility liaison gave notification instead to the Atchison County PIO Liaison at the ECF. The County FIO, k

in turn, called the County EOC at 1112 and notified the=. Sirens were l cetivated (si=ulated) at 1125 and the EBS station was called at 1127.

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• -5h- l f This notification sequence was not in accordance with the Plan. Proper routing would be from the utility to the SEOC to the County. This vould- I have added time to the process, resulting in more than 15 minutes for alert and notification.

To remedy this deficiency a remedial drill was held on November 26, 1985 FD!A staff were present as evaluators. At 15hl a General Emergency was declared at the Cooper Nuclear Station. The licensee immediately //;

contacted the Missouri State EOC in Jefferson City. The message was completed by 15hh. At 15h6 the State EOC called back to verify. They then notified the A'tchison County EOC of the General Emergency. By this time it was 15h9 At 1550 the Atchison County EOC contacted the EBS station and dictated the notification message, with instructions that it be repeated every 10 minutes.

Sirens were also sounded at this time (1550). These actions successfully demonstrated the ability of Atchison County to accomplish alert and notification within 15 minutes. This deficiency is closed.

3.2.2 Brickyard Hill State Wildlife Area As a result of the pre and post exercise review it was discovered that neither the Missouri Radiological Emergency Response Flan nor the Atchison County Plan make any provision for the alert and notification within h5 minutes of transients at the Brickyard Hill State Wildlife Area.

,The, State was informed of this deficiency on October 31, 1985 and were told that remedial actions will include a revision of State and local plans to provide for the alert and notification (within h5 minutes) to the transient i population of the Brickyard Hill State Wildlife Area. These revisions shall fully comply with all applicable provisions of NUREG-065h, FEMA-REP-1, Rev.

1, and FEMA-h3 (now REP-10).

On November h, 1985, the State of Missouri sub=itted changes to the State Plan.

Upon review, the response was judged inadequate. On November lb, 1985, the following was sent to the State Emergency Management Agency:

"Regarding deficiency number 2, you propose a change to the Missouri Plan. It states that the Department of Conservation. ' vill provide prompt notification (alert and notification) of the public in the conservation areas within the ten mile EPZ at the Alert Classification. This notification vill be acco=plished within h5 minutes of notification of a Site Area Emegency Declaration'.

There are five problems with this change.

1. You cannot know the time interval between the Alert and the Site Area Emergency, and therefore cannot say with absolute certainty that the notification vill be accomplished within h5 minutes of a Site Area Emergency.

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2. Since no sp;cific cons;rvation cr:a is m2ntion;d, it must ba assumed that this change applies to all conservation areas. Those within 5 miles of a plant (callaway) only have 15 minutes for alert and notification. Response for each contingency must be addressed individually.

3. There is no description of hov prc=pt alert and notification vill be performed. As stated in c:y memo of October 31, 1985, 'These revisions shall fully comply with all applicable provisions of NUREU-065h, FDfA-REP-1, Rev. 1, and FEMA-h3 (Reissued in November, 1985 as FEMA-REP-10).' Co=pliance with these documents would require that any mobile siren system be subjected to the same tests and '

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requirements as fixed sirens.

h. At a minimum, the signs that are proposed must be at all points  %

of ingress / egress as well as at all parking areas. They must also include reference to the EBS Station, including location on the dial, plus evacuation routes to lead them away from the nuclear power plant. Reference, FEMA REP 11 'A Guide to Preparing Emergency Public Information Materials'.

5. You must indicate how you vill deal with rumors which may be generated from an .early evacuation not followed by an i==ediate EBS message."

On the date of this report no response from the State had been received.

1 Th2 deficiency still exists.

As cdvised on November ik, 1985, the State of Missouri vill have until bbruary lh, 1986, to acco=plish the remedial actions cited above.

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Federal Emergency Management Agency Region VII 911 Walnut Street Kansas City, Missouri 64106

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OCT 31 1985 k

MEMORANDUM FOR: Richard Ross, Missouri State Director State Emergency Management Agency FROM: Patrick J. Breheny, Regional Director FIMA - Region VII

(

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SUBJECT:

Deficiencies--Cooper Exercise, October 16, 1985--

RESPOESE RESTIRED 30VEMBER 7.1985 This is to confinn the telephone conversation between you and my staff rsgarding the above referenced subject and to delineate the details cf the deficiencies.

FINA Guidance Memorandum EX-1 " Remedial Exercises" (copy enclosed) states:

" Deficiencies are demonstrated and observed inadequacies that would cause a finding that offsite emergency preparedness was not adequate to provide reasonable assurance that appropriate protective measures can be taken to protect the health and safety of the public living in the vicinity of a nuclear power facility in the event of a radiological caergency."

Based on this definition there were two deficiencies for Missouri at th2 Cooper exercise of October 16, 1985.

1. The first is the failure of the Atchison Ccunty EOC to provide both an alert and an instructional message to those citizens of Atchison County within the 10 mile EPZ vithin 15 minutes as prescribed by NURID-065h, Appendix 3.B.

The 15 minutes has been determined to begin when the plant notifies the off-site authority of the emergency.

The notification of a General Emergency vent frc= the plant to the EOT/IAC at 11:05 AM. (Time calculatico begins here.) The Atchison County / State liaison person at the EOF called Notice of the General Emergency to the Atchison County EOC at 11:12 AM.

The sirens were activated at 11:25, and the Emergency Broadcast Station was called at 11:27, thus requiring more time than the allotted 15 minutes.

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2. As a result of the pre and post exercise review it was discovered 4 .that neither the Missouri Radiological Emergency Response Plan nor the Atchison County Plan make any provision for the alert and notification within h5 minutes of transients at the Brickyard Hill State Wildlife Area.

The nature of the first deficiency is such that a remedial exercise demonstrating Atchison County's ability to accomplish 15 minute alert and notification vill be required. Such an exercise vill include, ct a minimum; (n) The Atchison County / State liaison person dispatched to the EOF M (b) The Atchison County Director (c) The Atchison County PIO If you wish to have the results of the remedial action included in P the Exercise Report, the remedial exercise vill have to be completed g by December 6, 1985 Failing this, the Exercise Report will show the v dIficient area and the results of the remedial exercise vill be detailed L in a supplemental report.

This can Please give us your decision on this by November 7, 1985 be done by phone or telefax and confirmed in writing.

As to the second deficiency, the corrective action vill consist of two parts:

(A) A revision of State and Iccal plans to provide for the alert and notification (within h5 minutes) to the transient population of the Brickyard Hill State Wildlife Area. These revisions shall fully comply with all applicable provisions of NURIXI-065k, FDM-REP-1, Rev.1 and FDIA-k3 (B) A successful demonstratice of the capability to carry out the plan revisions detailed above in (A).

l If the results of this remedial exercise are to be included j

' in the main exercise report, the demonstration vill have to .

be completed by December 6, 1985. If it cannot be accomplished within this timeframe, then, according to the enclosed Guidance Memorandum EX-1, it must be successfully demonstrated by February 1k,1986 and detailed in a supplemental report.

This can Please give us your decision on this by November 7,1985 be done by phone or telefax and confirmed in writing.

If you require any assistance, please contact Dick Sumpter at MS 37L-2161.

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N,4 Federal Emergency Management' Agency k Washington, D.C. 20472 2 o gy 4 1985 MENORANDlM EDR: Richard J. Leonard Chairman onal Assistance Ccxnmittee FROM: rt' Chief bI Technological Hazards Division g SUBJEL7: Preliminary Review of the Alert and Notification System for the Cocper Nuclear Station [E*"

The preliminary technical review of the prcmpt alert and notification system [

(ANS) for the Cocper Nuclear Station has been ccupleted by International i Energy Associates Limited (IEAL), the Federal Energency Management Agency's i (FENA) technical assistance contractor. The report, which has already been '

forwarded to you under separate cover, is entitled " Cooper Station Site-Specific Offsite Radiological Emergency Preparedness Alert and Notification System Quality Assurance Verification." This review was limited to an evaluation of the ANS design submitted by the Nebraska Public Power District against evaluation criterion E.6 in FEMA-43 and Appendix-3 in NUREG-0654/ FEMA-REP-1, Rev.1. In addition to reviewing the report, please review evaluation criteria E.5, F.1, N.1, N.2, N.3, and N.5 in the State of Nebraska, State of Missouri, and local radiological emergency preparedness plans to reconfirm their adequacy as reported in the 44 CFR 350 approvals dated June 29, 1984.

I I As stated in the draf t report, the design and implementation of the ANS for

( the Cocper Nuclear Station and its supporting procedures conform sufficiently to the acceptance criteria, as stated in FEMA-43, for evaluation criterion E.6 of NUREG-0654/ FEMA-REP-1, Rev.1. Therefore, the prerequisites for cctivation of the ANS on October 17, 1985, followed by a telephone surwy of the residences within the plume energency plannirg zone were met.

An issue that nust be investigated before the Cooper ANS can receive a final approval involves alertirg for the Brownville. State recreational area and

the Brickyard Hill State Wildlife area. The ANS design report addressed I

cpecial alerting for the Indian Cave State Park but did not discuss pro-cedures for the other two areas. Please confirm that procedures exist for these areas.

Findirgs for evaluation criterion N.1 will be included in a draf t final j report which will be forwarded to you for review. Note that before the 1 Cocper ANS can receive a final approval, the capabilities of the States y

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l of Nebraska and Missouri and local governments to provide an alert signal and instructional nessage on an area-wide basis throughout the plume EPZ i*n cccordance with the time frames in FEMA-43 and NUREG-0654/ FEMA-REP-1, Rev.1, Appendix 3, nust be reconfirmed.

The Cocper ANS design report as submitted, did not contain sufficient infor-nation on the routine siren testing procedures and siren operability for us to catplete the review. We are aware that you have requested the necessary infornation frce the States involved. Our objective is to confirm the requirement in FEMA-43 on page E-8 which states, "he cperability of the ciren system will be considered acceptable when an average of 90% of the sirens can be shown to be functional over a 12-nonth period, as determined by a cinple average of all tests conducted." i he rcutine siren testing procedures for the Cocper ANS must be determined to be adequate since these procedures will form the basis for the operability '

calallations in the cutyears af ter the initial approval. Please provide a copy of this information to FEMA Headquarters once you receive it frce the '

States or licensee. Confirmation of the adequacy of the routine siren testing procedures and operability nust be ccmpleted before the Cooper ANS can receive a final FEMA approval.

If you have any questions, please contact ne at 646-2861.

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Fcderal Emergency Mancgement Agency 7

, Region VII 911 Walnut Street Kansas City, Missouri 64106 ,D.

8e O.' I d l935 MDORANDUM FOR: Richara h ia State 5mer5ehty-Management Agency 4 .

,h/ ,

Patrick i Breheny, Regional Director OM:

a p .[

FDfA - Region VII

SUBJECT:

Rehnse to SDIA Comments on Cooper Exercise Deficiencies:

Responses Due: 11-22-85 -

l We have received your November 4, 1985 response to our notice of the

• two deficiencies observed at the Cooper exercise. While this response  %

provides information which may shift the locus of the first deficiency >

(15 minute alert and notification), it does not eliminate the need for a remedial exercise.

As you observed, neither the Missouri State Plan nor the Atchison County Plan include (or even mention) a county liaison person in the notification chain.*

According to the State Plan, when General Emergency is reached via cscalation through the lover emergency classifications, the chain calls for the licensee to notify SEMA and SDfA to notify the Atchison County Sheriff, and the Sheriff to notify the County Emergency Coordinator.

According,to the Atchison County Plan, under the circumstance described cbove, notification is from the licensee to the Nebraska Highway Patrol, to the Missouri Highway Patrol, Troop F, to SDM to the Atchison County Sheriff to the County Emergency Management Director. (Since the 15 minute clock ,begins when the first off-site authority is notified,

! this elongated chain vould seem to be unduly time consuming. This j is particularly relevant in review of the fact that at the exercise I of 10-16-85 it took Atchison County 15 minutes frem the time they received notification.)

During the exercise, neither of these methods was de=enstrated. The cetual course of events occurring at the General Emergency (1105) had l the licensee attempting to notify SDM via the listed emergency phone number. Notification by this method could not be accomplished since SD% had incorrectly hooked up a computer and rendered the line inoperative.

l (This was later discovered and corrected.)

I When the licensee representative could not get through on the appointed l phone line, no official back up com=unication was attempted. Rather he notified the liaison no standing in the Plan) person from Atchison This person called theCounty County(a EOCvolunteer at 1112.with L

_ _ _ _ _ _ _ _ , , _ _ _ _ - - - - - - - - - - - - ' ' - ' - ~ - - ' - - '

s

• SDM did not receive notice of the General Emergency until 1132 when the Atchison County EOC called.

n Based on the above, we vill require the following information: -

1.

Clarification of the alert and notification discrepancies between the State and Atchison County Plans and adoption of one methodology to be used and evaluated at the remedial exercise.

2.

Selection of a date to accomplish this remedial activity prior

} to December 6, 1985 (if you wish these results to be shown in the Evaluation Report).

I A remedial exercise vill include all persons or elements in the approved notification chain from notification by the licensee to dictation of an informational being duly recorded. message for broadcast over the EBS with all times Regarding deficiency number 2, you propose a change to the Missouri Plan.

It states that the Department of Conservation " vill provide prompt notification (alert and notification) of the public in the conservation _'

areas within the ten mile EPZ at the Alert Classification. This notificatien vill be accomplished Emergency Declaration." within 45 minutes of notification of a Site Area l

There are five problems with this change.

1.

You cannot know the time interval between the " Alert" and the " Site Area Emergency," and therefore cannnot say with absolute certainty that the notification vill be accomplished within h5 minutes of a Site Area Emergency.

2.

Since no specific conservation area is mentioned, it must be assumed that this change applies to all conservation areas. Those within 5 miles of a plant (Callavay) only have 15 minutes for alert and notification.

Response for each contingency must be addressed individually.

3.

There is no description of hov prompt alert and notification vill be performed. As stated in my memo of October 31, 1985, "These revisions shall fully comply with all applicable provisions of NUREG-065h, FEMA-REP-1, Rev.1, and Fam-h3 (Reissued in November 1985 as FDM-REP-10)." Compliance with these documents would require that any mobile siren system be subjected to the same tests and requirements as fixed sirens.

k.

At a minimum, the signs that are proposed must be at all points of ingress / egress as well as at all parking areas. They must also include reference to the EBS Station, including location on the dial, plus evacuation routes to lead them away from the nuclear power plant.

Reference, FDM REP 11 "A Guide to Preparing Emergency Public Information Materials."

, - . - FMLJs j you pst indicate how you vill deal with rumcrs which may be generated

- 5* g early evacuation not followed by an immediate EBS message.

I t medy to this second exercise deficiency to be accomplished F

We would e%* a by February cc, prt S. Wilkerson, FDIA HQ y les Hackney, NRC IV gen Green, FD!A HQ i

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f'ky j Federal Emergency Management Agency n Washington, D.C. 20472

,3 MR IT 1988 MEMORANDlM EOR: Edward L. Jordan Director Division of Onergency Preparedness and Engineering Response U.S. Nuclear Regulatory Conmission FROM: r .

Assistant Associate Director Office of Natural and Technological Hazards Progran

SUBJECT:

Exercise Report of the October 16, 1985, Exercise of the Offsite Radiological Dnergency Preparedness Plans for the Cooper Nuclear Station Attached is a copy of the Exercise Report of the October 16, 1985, joint exercise of the offsite radiological emergency preparedness plans for the Cooper Nuclear Station at Brownville, Nebraska. W e joint exercise was full participation for the State of Nebraska and the Counties of Nemaha and Otoe; ard, the State of Missouri and the Counties of Atchison and Nodaway.

De report dated December 20, 1985, was prepared by Federal Dnergency Management Agency (FEMA) Region VII.

FEMA Region VII identified four deficiencies in Nebraska. 'IWo concerned field monitoring and decontamination by the State. 'IWo concerned Nemaha County's alert & notification ( A&N) of Indian Cave State Park and access control throughout the jurisdiction. In addition, two deficiencies were identified in Missouri. Rese concerned the inability to successfully danonstrate the 15-minute A&N function by the Atchison County Onergency Operations Center (EOC) and the lack of provisions in both the Missouri and Atchison County plans for A&N in the Brickyard Hill State Wildlife Area.

On tbvember 26, 1985, the deficiency in 15 minute A&N of the public by the Atchison County EOC was corrected in a remedial exercise. All but one of the other deficiencies have been corrected by trainirg, plan revisions, and letters of agreement. 'Ihe remaining deficiency is concerned with Brickyard Hill and is scheduled for correction by June 15, 1986. % is correction will include not only plan revisions and letters of agreement but a remedial exercise.

On Septonber 24, 1986, another full-participation joint exercise of offsite plans and preparedness is scheduled to be held in support of the Cooper Nuclear Station. W1ere appropriate, all of the training, plan revisions and letters of agreement will be tested at this exercise.

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n. In the October 16, 1985, exercise there were other inadequacies identified as requiring corrective actions. The States of Nebraska and Missouri have re-ceived a copy of the exercise report and are preparing schedules of corrective actions. When they are received and analyzed, we will send you copies.

Although there were deficiencies observed at the exercise, the States of Nebraska and Missouri have made substantial progress in correctimJ them; the only remaining deficiency is scheduled for ccznpletion by June 15, 1986.

Based on this progress in the correction of deficiencies, there is reasonable assurance that the public health and safety can be protected in the event of an accident at the Cooper Nuclear Station. Therefore, the November 30, 1983, approval under FEMA Rule 44 CFR 350 will remain in effect.

If you have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division at 646-2861.

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EXERCISE EVAIDATION OF THE IMPIJMENTATION OF STATE AND IACAL RADIOIAGICAL EMERGENCY RESPONSE PLANS EXERCISE CONDUCTED OCTOBER 16, 1985 RDEDIAL DRILL CONDUCTED NOVEMBER 26, 1985 for the COOPER NUCLEAR STATION Brovnville, Ne- h County, Nebraska Nebraska Public Power District PARTICIPANTS:

State of Nebraska State of Missouri County of Nem h County of Atchison County of Otoc County of Nodaway' (All affected jurisdictions participated) prepared by l Federal Boergency Management Agency l Region VII Kansas City, MO l

t l DECEMBER 20, 1985 l

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T (V CONTENTS

{V3 s

ABBREVIATIONS AND ACRONYMS......................................... iv EXERCISE SUDMARY................................................... vi 1 INTRODUCTION.................................................... 1 1.1 Exercise Background........................................ 1 1.2 Exercise Evaluators........................................ 1 1.3 Evaluation Critdria........................................ 2 1.h Exercise Findings Classification........................... 3 15 Exercise Objectives........................................ 3 1.6 Exercise Scenario......................................... 22 1.7 State and Local Resources................................. 22 2 Exercise Evaluation............................................ 2h

. 2.1 Joint Operations.......................................... 2h 2.1.1 E=ergency Operations Facility / Nebraska FCP. . . . . . . . . . 2h 2.1.2 Information Authentication

~

Center................... 26 2.1.3 Media Release Center................................ 27 2.2 Nebraska Operations....................................... 30 2.2.1 State Energency Operations Center (SEOC ) . . . . . . . . . . . . 30 2.2.2 Radiological Assessment / Field Team Coordination..... 31 2.2.3 Field Monitoring Teams.............................. 32 2.2.h State Radiological Laboratory....................... 36 2.2.5 Decontamination Facilities.......................... 36 2.3 County operations......................................... 38 2.3.1 Nemaha County E0C................................... 38

2. 3. 2 Nemaha County Ambulance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 2.3.3 Otoe County EOC and Reception Center................. h0 2.h Missouri State Operations.................................. h1

) 2.h.1 State E=ergency Operations Center.................... kl 2.h.2 Forward Co==and Post................................. hl 2.h.3 Field Team Coordination / Dose Assessment.............. h3 2.h.h Field Monitoring..................................... hk 2.5 county operations.......................................... h6 2 5.1 Atchison County E0C.................................. h6 2.5.2 Atchison County Decontamination Facility............. h8 2.5.3 Relocation Center, Maryville, Missouri............... kB 2.5.h Decontamination Facility, Maryville, Missouri........ h9 2.5 5 Atchison County Medical Support...................... L9-3 ACTIONS 'ID REMEDY DEFICIENCIES PREVIOUSLY CITED. . . . . . . . . . . . . . . . 51

. 3.1 Nebraska Deficiencies..................................... 51 3.1.1 Field Monitoring.................................... 51 3.1.2 Nebraska City Decontamination Facility.............. 52 3.1.3 Nemaha County Access Contro1........................ 52 3.1.k Alert & Notification - Indian Cave State Park....... 53 i

3.2 Missouri ~ Deficiencies..................................... 53 3.2.1 Atchison County E00................................. 53 3.2.2 Brickyard Hill State Wildlife Area................... Sh h SUDMARY OF AREAS REQUIRING CORRECTIVE ACTION................... 56 5

SUMMARY

OF REC 0DMENDATIONS..................................... 58 3

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ABREVIATIONS AND ACRONDE ACEOC Atchison County (MO) Emergency Operations Center AEOF Alternate Emergency Operations Facility ANL Argonne National Laboratory ARC American Red Cross BLUEBIRD Nebraska State Patrol Mobile Emergency Communications Center BRH Missouri Division of Health, Bureau of Radiological Health CD Civil Defense CNS Cooper Nuclear Station CRUSH Nebraska Civil Defense Portable Operations Center / Field Co==and Post .

DOE Department of Energy EBS E=ergency Broadcast System .

EPA Environ = ental Protection Agency EOC E=ergency Operations Center EOF Etergency Operations Facility EPZ E=ergency Planning Zone FCP Forward Command Post FEMA Federal Emergency Management Agency IAC Infor=ation Authentication Center INEL Idaho National Engineering Laboratory KI Potassium Iodide

) HRC- Media Release Center

r O

O ,,

EKERCISE SUltfARY The purpose of an , exercise is to determine the ability of appropriate off-site agencies to. respond to an emergency covered by State and local Radiological Emergency Response Plans. The evaluation of such an effort vill, of necessity, tend to focus on the negative aspects of the exercise, on inadequacies in planning, preparedness and performance.

This focus of. attention on the negative should not be taken to mean that there vere not a great many positive acco=plishments as well. Indeed, there were, however, in the interest of brevity, only inadequacies will herein be summarized.

JOINT OPERATIONS Baergency Operations Facility (EOF)/ Nebraska FCP The only objective not demonstrated fully was Number 3 for Nebraska.

There were two areas requiring corrective action. The first relates to a clarification of the Nebraska State Plan regarding certain aspects of alert and notification. The second concerns backup communications to the Atchison County E00. ,

There were four recommendations for operational improvement. Details are found in Section 2.1.1. .

Information Authentication Center All objectives were achieved by both States. There is one area of required corrective action relating to Nebraska coordinating with Missouri prior 'to release of EBS messages not accompanied by sirens. Details are in Section 2.1.2.

Media Release Center

. Nebraska failed to demonstrate Objective Number 26, as it requires a telephone hotline for rumor control. There were also three required '

corrective actions. Two related to the manner in which press briefings are conducted, and the third relates to Nebraska's responsibility for rumor control. Details are in Section 2.1.3.

NEBRASKA OPERATIONS State Bnergency Operations Center (SEOC)

All objectives were demonstrated.

Radiological Assessment and Field Team Coordination

) Only Objective Number 6 was not fully demonstrated. There was also a single recommendation for operational improvement. Details are in Section

.2.2.2.

f i- ( viii

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Forward C - nd Post (FCP)

Objectivec Number 13 and lh (alert and notification) were not demonstrated due to the fact that the General Emergency occurred before the FCP became operational. One inadequacy was observed. Details are in Section 2.h.2. .

Field Team Coordination / Dose Assessment Objectives Number h and 5 vere not fully demonstrated. There was one area requiring corrective action. This related to the use of a single map for radiological monitoring. Details are in Section 2.h.3 Field Monitoring Two objectives were not fully demonstrated: One related to clarity of radio co==unications after the EOF relocated; the other related to the transport of field samples.

There was a required corrective action relating to the use of a single equipment checklist. Details are in Section 2.L.L.

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Atchison County EOC Objectives not de=onstrated: 1, 5, 13, lk, 18, and 20. Several of these contributed to two deficiencies. The first related to the failure g

to provide timely alert and notification to the residents in general; the second relates to failure of the State and local Plans to provide for timely alert and notification of transients within the Brickyard Hill State Wildlife Area.

In addition, there vere areas requiring corrective action related to backup co==unication with the EOF, special needs of mobility impaired, and sheltering inforcation for transients. Details are in Section 2.5.1.

Atchison County Decontamination Facility Objective Number 29 was only partially demonstrated. There was no percon :e1 decontamination. Details are in Section 2.5.2.

Relocation Center, Maryville, Missouri Objective Number 27 was only partially demonstrated. They will be required to use proper registration procedures at the next exercise.

Details are in Section 2.5.3 Decontamination Facility, Maryville, Missouri Objectives were demonstrated; no inadequacies were observed.

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7 1 INTRODUCTION 1.1 EXERCISE BACKGROUND Radiological emergency response plans for the Cooper Nuclear Station (CNS) for the States of Nebraska and Missouri and affected local jurisdications were conditionally approved by FEMA on July 2, 1984.

The plans of both States were evaluated in joint exercises annually since 1982. This report concerns the results of the joint exercise of October 16, 1985 It was classified as " full scale" for Missouri and "small scale"

. for Nebraska. The exercise was conducted between the hours of 0800 and 1630.

1.2 EXERCISE EVALUA'IORS Seventeen Federal Agency personnel and seven FDM Contractors evaluated the off-site emergency response functions:

OBSERVER AGDICY ASSIGNMDIT

, Wolf Biedenfeld PHS NE & M0 Medic Bob Bissell FEMA Nemaha Co. (NE) EOC James Bogard DOE M0 Rad Team /Atchison Co. Decon Bill Brinck EPA FT Coord./ Dose Assessment (MO)

Marlee Carroll FEMA EOF /FCP (NE)

Nate Chipman INEL NE Rad Team #2 J,ohn Cole =an- FEMA Regional Office Coordination Caroline Herzenberg ANL Nebraska City & Auburn Decon Tom Hogan FEMA M0 FCP/Atchison Co. EOC Rochelle Honkus INEL NE FT Coord./ Dose Assessment Chuck Huyett FEMA Regional Office Coordination Eric Jenkins FDM NE State EOC Rich Leonard FEMA Overview Jamie Majors FDM Regional Office Coordination Gary McClure FEMA M0 State EOC Dorothy Nevitt USDA M0 FCP Eileen O' Hare ARC Nodavay Co. Decon Facility /

Maryville Relocation Center Jim Opelka ANL NE Rad Lab Gary Sanborn NRC IAC Chris Saricks ANL Nemaha Co. (NE) EOC Lyle Slagle INEL NE Rad Team #1 Tim Seidel FDM MRC Dick Sumpter FEMA Overview Dianne Wilson FDM Nebraska City Relocation Center /

Otoe Co. EOC

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O O 1.4 EXERCISE FINDINGS CLASSIFICATION

') FEMA classifies exercise inadequacies as deficiencies or areas requiring corrective action.

Deficiencies are demonstrated and observed inadequacies that would cause a finding that off-site emergency preparedness was not adequate to provide reasonable assurance that appropriate protective measures can be taken to protect the health and safety of the public living in the event of a radiological emergency.

Areas requiring corrective actions are demonstrated and observed inadequacies of State and local government performance, and although their correction is required, they are not considered by themselves, to adversely impact public health and safety.

In addition, FEMA identifies areas recommended for improvement, which are problem areas observed during an exercise that are not considered to adversely impact public ' health and safety. While not required, correction of these vould enhance an organization's level of preparedness.

1.5 EXERCISE ORIECTIVES On August h, 1985, the State of Nebraska Civil Defense Agency submitted final off-site objectives for the exericse.

On August 5, 1985, the off-site objectives from the Missouri State y Emergency Management Agency were received.

Objectives - Nebraska State Support Capabilities (Verbatim, as submitted)

1. Activation of staff with subsequent deployment and operation of the State Field Command Post to include local and long-range communications. If plant scenario permits, test relocation of State Field Co= mand Post. Participation of Nebraska State Patrol BLUEBIRD will be si=ulated.

2. Notification and follow-up contacts with State, Federal, and private agencies having responsibilities described in the Nebraska Plan.

3. Operational status and functioning of State EOC as well as coordination with agencies and field elements. Includes State EOC interstate coordination. With the exception of the Health Department, Agency representation at the State EOC will be

[

simulated. State EOC will implement apprcpriate protective actions as approved by the Governor and/or the Governor's Authorized Representative. i

h. State field radiological . monitoring activities, off-site dose assessment, and coordination of protective action recommendations with Governor's Authorized Representative and State EOC.

Coordination vill also be effected with the utility and Missouri.

3 This will include timely mobilization, deployment and operation J I I

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I k. Coordinated access control and security decision-making by selected law enforcement agencies.

5 Increased readiness measures for potential operations at Nebraska City /Otoe County relocation center. This facility vill be operated on a training 8 asis, but will be subject to observation.

6. Decontamination station operations at Auburn to support emergency workers vill be demonstrated.

T. Demonstrate capability to activate public alerting ' system and provide an informational message to the public within 15 minutes.

Actual activation of alerting system and EBS will be simulated.

However, preparation and handling of public notification messages

' vill be demonstrated. (The public alert and notification procedures vill be accomplished during the FEMA-h3 test, to be conducted on October 17, 1985.)

8. Coordination with IAC/MRC where appropriate concerning local public information activites. Demonstrate capability to define hazard area by referencing local landmarks.

9. Provision of fire and rescue support as required by plant.

Transport and reception of simulated radiation casualty to the Ne=aha County Hospital by a 1ccal Rescue Squad.

10. Decision-making and coordination planning for recovery and reentry.

11. The Nebraska City /Otoe County reception registration and decontamination activities in support of Nemaha County evacuees vill be operated on a training basis, but vill be subject to observation.

12. Demonstrate effective system for distribution and record keeping of dosimetry - to include permanent record devices (TLDs').

13. Demonstrate timely communication and coordination with coc= unity facilities for mobility impaired, disabled, etc. that may require ~

special actions; such as, early notification or other support -

functions as identified.

lb. Decision-making vill be demonstrated to simulate and control g

allocation of local resources, and determine need for State support, as necessary.

15 Decision-making vill be demonstrated to simulate allocation of '

appropriate support for the evacuation of the public with special needs, if required.

Since Missouri submitted its objectives in a format utilizing the 35 FEMA Objectives, they are reproduced in full.

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I iEDC IFEP~ilh6~l665E~h5557IFEE~iEith-~lbE6i6EEI l ___ l _____ I ___ I ______ __ ! ___ l __ __ ! ____ _ l

~9. Demonstrate appropri- I I I I I  : I cte equipment and i I I I I I I I procedures for collec- I N/A I N/A I N/A I YES IN/A IN/A I N/A I-tion, transport and ( I I I l l'  : I cnalysis of. samples I I I I I I I of soil, vegetation, I I I I I I i cnow, water and milk. l____I_____!_____I__________I____I______I__ _3

!  !  ! I I I I i 110. Demonstrate ability i I I I I 1 1 1 to project dosage i N/A I YES IN/A 1 YES IYES IN/A I N/A I to the public via I I i  !  ! I I I plume exposure, based i I I I I I I I on plant and field i I I I I I I I

. dcta, and to determine i I i  ! I I I I appropriate protective  ! I I I I I I I

• i  ! I measures, based on  !  ! I I I PAG's, avail able i I I I I I I I chelter, evacuation i I I  !  ! I I ,!

time estimates, and i I I I  ! I i  !

cther appropriate l i I I I I I I fcctors. l _ _ _ _ I _ _ ___ I _ _ __ l _ _ _ _ _ _ _ __ _ i _ __ _ I ____ l _ ___I I  ! I l'  !  !  ! i

11. Demonstrate ability i I I I I I t  !

to project dosage  ! I I  !  ! I I I to the public via iN/A I YES IN/A I YES IN/A IN/A IN/A I ingestion pathway i I I I I I I I cxposure, based on  ! I I I I I I I field data, and to i I I i i I I l

d termine appropriate  ! I  ! I I I  : i l

protective measures  !  ! I I I I I I bcsed on PAG's and i I I I I I I I cn other relevant i I I I  !  !  ! I fcctors (NUREG-0654, i I i I  !  !  ! I I.10, J.11). l____I_____t __I___ ____!____I______!____

1 I I  :  ! l I i

12. Demonstrate abiity to I i i I i l i l implement protective  ! I I  ! I I I I cetion for ingestion iN/A I YES IN/A I YES IN/A IN/A IN/A I pathway hazards  ! I I I I I I I (NUREG-0654, J.9, I I I I I I I I J.11). l____I_____I __I__________I____I______I_______t

! I I i  !  ! I i

13. Demonstrate abilly to i I I I I i i olert the public with- IN/A I YES IN/A I N/A lN/A lN/A I N/A  :

in the 10-mile EPZ, t 1. I I I I I I disseminate an initial i I I i  !  !  ! I instructional message 1 I I I I I i i within 15 minutes l____I_____I_____!__________I____! l_______I

)

. _____________________________ -_____=-- ___

IEDC IFCP IIAC IDOSE ASSM IFMC IMRC INEDICALI

, l____l__- .

l _____I__________I____3______I_______I I I  !  !  ! I I i

19. Demonstrate the organi-l I I I  !  ! I I actional ability and IN/A I N/A IN/A I NM4 IN/A IN/A I NM4 I rcsources necessary to I I i i  !  ! I I offect an orderly 1 I I I i I  ! I cvacuation of schools  ! I I I I I l  !

within the plume EPZ l i I I I I I I (NUREG-0654, J.9, I f I I I I I I J.10.g). I l ___ _ _ I _ ____ I __ __ _ l____I______I_______I

! I I  !  ! I I I 2n. Demonstrate the abilityl  ! I I I I I I to continously monitor ! N/A I YES IYES I YES SYES I N/A I N/A I cnd control emegency i I I I I I I I worker exposure. l____I_____!_____I__________!____I______I_______I I I I I I I I I

21. Demonstrate the abilityl i I I  !  ! I I to make the decision, I N/A I YES IN/A ! YES IN/A IN/A l N/A 1 bcsed on predetermined i I I I I I  ! I criteria, whether to 1 I I I I I I I issue KI to emergency ! I  ! I I I I l-wrrkers and/or the  ! I I I I I I  !

gsneral population. l____I_____I_____!_______ l____I______I_______

I I I I I I I I

22. Demonstrate the abilityl I I I I I I  !

to supply and adminsteri N/A 3 YES IN/A I N/A IN/A IN/A I N/A  !

KI, once the deci sion i I I I I I  ! I has been made to do so.!____!_____I_____!__________l____I______!_______!

! 1  !  !  ! I I I

23. Demonstrate the ability!  !  ! I I I  ! I to effect an orderly i N/A I N/A IN/A  ! N/A  ! NM4 IN/A I N/A i svecuation of onsite  !  ! I I I I I I l personnel (NUREG-0454, !  !  ! I i i  ! I J.2). I I l_____I__________!____f______!_______I I I I I  !  !  ! I

24. Demonstrate ability to 1 I  !  ! I I I I

brief the media in a iN/A ! NO IN/A I N/A IN/A LYES I N/A I l

clear, accurate and i I I I I I I I timely manner. l____I__ l_____!__________I____!______!_______I i

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_11_

aIEDC IFCP IIAC IDOSE ASSM IFMC IMRC n IMEDICAll I____t____f___,_t__________I____t______t______t

. I I I I  : 1 I I 3i. ~ Demonstrate ability to I i i I  !  ! I I ic'entify need for, LYES I YES IN/A I N/A IN/A IN/A I N/A I rcquest, and obtain i I I I I I I  !

Federal assistance. l____!____I_____t .

l____I_____I______l 4 I I I I I I I

33. Demonstrate ability to i I I I 1 I t I rolocate to and operatei N/A I NO !N/A i N/A IN/A IN/A IN/A I the alternate EDF/EOC 1 1 I  !  ! I I I (NUREG-0654 H.2, H.3).I I -!____I______ __I____I __I_______t i I I I l  ! I I

'34. Demonstrate ability to 1 I I I I I I I octimate total pop- IN/A I N/A IN/A i 10 IN/A IN/A IN/A I ulalon exposure i  !  : 1 I I  :  !

(NUREG-0654, M.4) l____I_____I_____I_________I____1_____f_______

I I I I  !  ! I  !

35. Demonstrate ability to i I I I i I , .. .: I datermine and isple- 1N/A I YES IN/A i N/A IN/A IN/A . IN/A i ment appropriate  !  !  ! I I I I I measures for contro11ed! I I I I i  ! I rccovery and reentry. l____f_____I_____I______. __f. I l 8 I

i i

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o o IATCHIGON I NODAWAY I

. I ___ l _ l I I I

9. Demonstrate approprate l l 8 equipment and procedues  ! I I for collection, trans- I I I N/A N/A I port and analysis of I I samples of soil, vege- 1 I I tation, snow, water and i I I milk. l _____ l__ i i i i

10. Demonstrate ability to I I I project dosage to the I gjg i I public via plume exposurel i N/A I based on plant and field i I I data. and to determine i I I appropriate protective i I I measures, based on PAG's,i I I available shelter, evacu-l I I ation time estimates, I I I and all other appropri- 1 I I ate factors. l____ _ I _ __ ___ l i I I .

11. Demonstrate ability to I I I project dosage to the i IA I N/A g public via ingestion I I I pathway exposure, based i I I on field data,~and to i i 1 determine appropriate  ! I I protective measures, I I I based on PAG's and other I i i relevant factors. I I I (NUREG-0654, I.10, J.11).l__________l____________l ^

l I i

12. Demonstrate ability to i I I implement protective i I '

actions for ingestion i N/A I N/A I pathway harards. (NUREG- 1 I I 0654, J.9, J.11). I _______l___________I I I I I

13. Demonstrate ability to i I I alert the public within I g i ' ~"

the to-mile EPZ, and i I N/A I disseminate and initial i I I instructional message i I i .

within 15 minutes. I__________l____________l i.

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. - - - - , , - - . , - , . , , , - , , - . - - - , , - - - , - , - - - , - - - , . , - - - - - , , - _-____m,-

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I 5YCEIB0U~lYDdEdY~~ l I__________I_ l I I

19. Demonstrate the organi- 1 sational ability and re- I g i t I N/A I sources necessary to I I I effect an orderly evacu- 1 ation of schools within I i I I I the plume EPZ (NUREG- 1 ,

0654, J.9, J.10.g). I______ _ I __ _ -__l I s i I i I I

20. Demonstrate the ability to continously monitor i YES I N/A l i I I and control emergency worker exposure. !__________I l

I I i i I I

21. Demonstrate the ability I N/A I to make the decision, 1 N/A I based on predetermined i I i I crieteria whether to i I

I i issue KI to emergency i I I workers and/or the general population. I__________l_______ 1 I I I i I I

22. Demonstrate the ability to administer KI, once t YES I N/A I the decison has been madel i I l__________f_______ i

) to do so. l-l i

23. Demonstrate the ability i I I l

to offect an order 1y i N/A I N/A I

evacuation of onsite per-l I j

sonnell (NUREB-0654, J.2)I__________l____________l i I I

24. Demonstrate ability to I I I i NO I N/A I brief the media in a clear, accurate and i I I timely manner. l__________I____________I I I I

25. Demonstrate the ability i I I I I to provide advance co-  ! YES N/A I I ordination of informa- 1 tion releases. l__________I____________I

-u-9 O I arcmaarT naarury- T I- - ____l __ _ __ l l

i I I

33. Demonstrate ability to i I I relocate to and operate i IC I N/A i 1 the alternate EDF/EDC 1 I I

( (NUREG-0654, H.2, H.3) I ______I___ i l I I I

! 30. Demonstrate ability to i I I

! estieste total.popula- I N/A I N/A I tion exposure (NURES- 1 I I

! 0654, M.4). I_ __

_ _ . I____ ___l I I I

~ 35. Demonstrate ability to 1 I I detereine and implemernt i I I appropriate measures for I YES I N/A I controlled recovery and i I I reentry. l_________I_______ __I i

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osJECIIVE PAET(5) 0F FORM NUEEG-0654 1 -

10. Demonstrate shility to project EOC Sec. V 1.10, J.10.m dosage to the public via plums W Sec. 11 exposure, based es plant and field data, and to, detetsdas appropriate protective seasures, a based ou FAC's, availabla shelter, evacuation tima estimates, and all other appropriate factors.

11. Demonstrate ability to project EOC Sec. V I.10, J.11 essage to the public via ingestion EOF Sec. VI patturay exposure, based on field data, and to datermine appropriate -

protective measures, based on FAGS and other relevant factors. ,

12. Demonstrate ability to implement EOC Sec. VII.C J.9, J.11 protective actions for ingestion pathusy hazards.

13. Demonstrate ability to alert the EOC Sec. VI E.6 public within the 11% EP2. and & Sec. III disseminate an initial instructional

) message, within 15 ainstes.

14 Demonstrate ability to formulate EOC Sec. VI E.5 and distribute appropriate l

l instructions to the public, in a timely fashion.

15. Demonstrate the organizational EOC Sec. VII.A J.9, J.10 1 ability and resources necessary E Sec. I to manage an orderly evacuation of all or parc of the plume EPZ.

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16. Demonstrate the organizational EOC Sec. VII.A J.10.k ability and resources necessary FA Sec. I to deal with Supediments to evacuation, as inclement weather or traffic obstructions.

17. Demonstrate the organisational EOC Sec. VII.A J.10.j ability and resources necesegry F1 Sec. I to control access to an evacusted area.

_ _ . _ _ _ _ _ _ . - - - - . - . . . - - - - _ . - - . _ - _ . _ - . _ . - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -------E-

O O CORRESPONDING

. OBJECIIVE PAII(5) 0F FORM N 54

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29. Daaosstrate adagnate equipasst DECOM all LS.a. b and preesdares for encontamination of eenrgency workara, equipannt.

and vehicles. .

30. Demonstrate adegascy of ambulanca EDIC Sec.111 L.4 facilities and precedoras for handling contaminated ipdividuals.

. 31. Demonstrate adequacy of hospital MEDIC Sec. II L.1 facilities and procedures for handling contaminated individuals.

32. Demonstrate ability to identify need (to be developed) C.1.a. b for, request, and obtain Federal assistance.

33. Demonstrate ability to relocate to (to be de veloped ) B.2, E3 and operate the alternate EOF /EOC.

34. Demonstrate ability to estimate EOC Sec. V M.4 total population exposure. EU7 Sec. TI I

35. Demonstrate ability to determine EOC Se c. I M.1 and taplement appropriate sensures for controlled recovery and reentry.

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-) 2. Otoe County (a) Civil Defense (b) Sheriff .

(c) County Commission (d) PIO ,

(e) Social Services

3. City of Auburn (a) Mayor (b) Fire Department / Rescue Squad

h. Nebraska City (a) Mayor (b) Police Chief

. (c) Fire Chief Volunteer Agencies

.l . American hed Cross - Nemaha and Otoe County Chapters Numerous other volunteers not affiliated with formal organizations, but recruited by the Civil Defense Directors were active participants.- Their contributions _ are acknowledged and appreciated.

, State of Missouri

1. Department of Public Safety, State Emergency Management Agency

2. Division of Health, Bureau of Radiological Health

3. Department of Public Safety, Missouri State Highway Patrol

h. Department of Public Safety, Headquarters Missouri National Guard

5. Northwest Missouri State University' Local

• Resources

1. Atchison County (a) County Commissioners (b) County Highway Department (c) Sheriff's Department (d) Atchison County Anbulance (e) Fairfax Community Hospital

2. Nodaway County (a) Sheriff's Department Volunteer Agencies

! merican Red Cross - Atchison and Nodaway County Chapters Numerous other volunteers not affiliated with formal organizations,_

but recruited by the local Civil Defense Director were active

) participants. Their contributions are acknowledged and appreciated.

The extensive use of teenage volunteers at the Atchison County EOC was especially noteworthy.

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) Primary and secondary communications links were all eventually demonstrated, satisfying Objective Number 5 It is noted that the Missouri radio should be in place before the arrival of the BRH representative to ensure backup communication from the EOF to the Atchison County EOC.

According to the Ffebraska State Plan, and local portions site specific to Cooper Nuclear Station, there are multiple alternative means for accomplishing the administrative and physical functions of alert and notification. However, no preferred or primary method could be determined.

During this exercise the procedure used was notification by the licensee to the Nebraska FCP and the Atchison County, Missouri PIO. The FCP notified the local Nebraska EOCs. When the utility was unable to contact the Missouri SEOC the utility instructed the Missouri representative at the EOF to notify the Atchison County EOC.

If this is to be the primary or preferred means of alerting the various Missouri and Nebraska off-site authorities, it should be clearly set forth in the Plans, with secondary and tertiary methods so identified. These Plan ' clarifications will be shown as " required corrective action" for Nebraska. Missouri has since corrected their Atchison County Plan to correspond with both the State and the utility notification sequences. .

For both States the type and number of dosimeter were adequate, as was the use of TLDs, thus, demonstrating Objective Number 20, and eliminating a Nebraska inadequacy from the 198h exercise. However, the evaluator

' reco= mends the development of a dose record to be issued with the self-reading dosimeters to assist staff in correctly recording their readings at the appropriate intervals. Recommended dose limits and reading intervals should be provided as a reminder.

At approximately 1155 there was a simulated power failure in the EOF.

Emergency lights came on, but the decision was made to relocate to the alternate EOF in the armory at Auburn as a precaution.

Evacuation of the EOF began around 1200. Staff arrived at the alternate EOF at 1227 No preparations had been made, but tables, phones, status boards are permanently stored on site and by 1235 Nebraska operations were set up and they received the first plant update at 12h0. During the relocation process the SEOC assumed command of the Nebraksa operations with CRUSH handling much of the communications.

This activity provided a full demonstration of Objectives 23 and 33, for both States.

A sufficient supply of KI was available, and appropriate personnel from both States engaged in a lengthy discussion of the advisability of administering the drug and also the methodology.

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9

- (l General Emergency. In an area vere there are 2 States, 2 EBS stations,

) 2 points of contact, and 2 points of siren activation, this could lead to a great deal of confusion and the need for an early activation of all rumor control systems.

The facility is rather small for the number of people and amount of equipment it would house in a real emergency. However, this situation did not deter the staff from carrying out their tasks. Primary and back-up communications to all required sites was demonstrated fully accounting for Objectives Number h and 5 At the General Emergency, alerting the public through sounding the sirens is the responsibility of local governments. In Nebraska the IAC is responsible for coordinating and releasing to the EBS subsequent messages regarding plant coordination and recommended protective actions. In Missouri, EBS is notified by the FCP or the County.

To the extent called for, these portions of Objectives 13 and lh were demonstrated.

However, it should be noted that the Nebraksa State and local Plans are very ambiguous in describing the steps required and the specific parties responsible.

In the Nebraska State Plan, page 52, paragraph b. , and pages B-5 and B-6_ permit the activation of public alert and notification through several channels. They fail to prescribe a primary or preferred methodology; neither do they identify which means are to be used under which conditions. While this cultiple option approach permits a great deal of flexiblity, it also promotes uncertainty.

Clarification of precise alert and notification terminology and methodology vill be required. (Detailed under EOF Section.)

Throughout the exercise the staff monitored and recorded exposure values, fully demonstrating Objective Number 20.

There was constant coordination between both States, local and the licensee PIOS once the IAC was staffed, fully demonstrating Objective Number 25.

Summary: All objectives planned for this facility were demonstrated.

Areas Requiring Corrective Action

3. When Nebraska releases EBS messages prior to the sounding of sirens, they must notify Missouri of.their intention to do so.

2.1.3 Media Release Center (MRC)

This facility is located in the Douglas County EOC in Omaha, Nebraska, and is staffed by representatives of the utility and both States.

Objectives to be demonstrated for both States were: 1, 2, h, 5, 25, and 26 (for Nebraska).

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) 5 NPPD should provide plant schematics and not rely on gestures and vague verbal descriptions given by the PIO. (NUREG-0654, 6.3.a.,

, 6.4.a.)

6. The Nebraska Plan should be clarified to delineate lead responsibility" for the rumor control hotlines, and an agreement reached between NPPD and NSCDA. (NUREG-065k, G.h.c.)

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O I 2.2.2 Radiological Assessment and Field Team Coordination Objectives to be demonstrated: 1, 2, 3, h, 5, 6, 20, 21, 22, and 35 The call initiating activation of the radiological group was received at 0757. All required staff members were in place at the EOF by 0957, fully demonstrating Objective Number 1. Objective Number 2 was demonstrated insofar as the facility was fully staffed. They did not intend to demonstrate 2h hour capability at this exercise.

The Radiological Health Coordinator worked very effectively with the Governor's representative to carry out all required decision making, fully demonstrating Objective Number 3.

. The facility did not afford adequate space or furniture.for the functions that needed to be performed within the EOF. Noise was also a problem, but was controlled. It is recommended that headsets be used to reduce noise levels. However, teams worked around these ' difficulties to carry out their tasks.

As mentioned . above, due to a simulated power failure it was necessary to relocate to an alternate facility in the middle of the exercsie. Before, during and after this event, communication systems functioned without any problems, fully demonstrating Objective Number 5

Field team deployment from the EOF was delayed due to problems with the equipment belonging to OPPD. (This problem vill be examined in more -

detail under Section 2.2.3, " Field Monitoring". ) 'This delay of nearly 30 minutes kept them from demonstrating Objective Number 6.

The Dose Assessment team was well trained. Calculations were made via primary and back-up computers. Projections were verified with the utility and the State of Missouri and shoved high correlation. PAR's were made in a timely manner and coordinated with both the utility and Missouri.

The plume was defined via field data; iodine calculations were checked.

However, it is recommended that data sheets should be improved to allow

- verification of field data. Currently, they use two separate forms which do not permit all relevant data to be arrayed in a single format. This makes verification difficult.

The staff was equipped with dosimetry adequate to monitor ard . control exposure, demonstrating Objective Number 20.

However, it is recommended that record keeping forms for self reading dosimeters be developed and readings taken en a more regular basis.

The decision regarding use of KI was made according to the State Plan.

Though it was not administered, its availability and the capability to administer vere shown, thus demonstrating Objectives Number 21 and 22.

) At the appropriate time a table top discussion was held to cover the l* -issues related to recovery and reentry. Field samples of vegetation and l vater were taken and screened using the ND-6700 multi channel analyser.

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.) Since both team members were totally unfamiliar with the maps used, the terrain, or the predetermined monitoring points, there were unacceptable  !

delays in finding monitoring locations requested by the EOF. About an hour was spent within the plume while trying to determine where they were before any sampling was done., Also, there was no consistency in surveying for ambient radiation. When survey was performed, they used the high range (ionization chamber) instrument instead of the low range instrument, and thus, they were unable to obtain an accurate reading. This was noted as a deficiency in the 198k exercise.

No monitoring was done outside the vehicle. No ground level and 3' (above ground) readings were taken. When asked by the EOF to locate the "1 R/hr level" of the plume and take an air sample, the team was not sure how to proceed.

Also, they were not adequately versed in use of the formula provided for calculating radiciodine concentration. After the sample was counted, three attempts were made before correct values were derived. Although they were aware of the necessity to proceed out of the plume to count the air sample, they did not monitor to assure that radiation levels outside the plume were background before counting the second air sample.

They did demonstrate proper techniques for collecting soil, vegetation and water samples, but did not package or transport them.

Objectives Number .7 and 8 vere not demonstrated; Objective Number 9 was partially demonstrated.

Team members failed - to read their dosimeters on any scheduled or predetermined basis. The BRH member had mid and high range pocket dosimeters (20R and 100R) and the OPPD member had 2 low range instruments (200 mR and 500 mR). Neither of them were aware of any maximum dose allowed -without further authorization, or any " turn around" levels. Both members had permanent record dotimeters, as required (Simulated TLD).

When the team members did remember to take readings in the vicinity 1 of the plume, they used the high range instruments instead of the recommended i low range. The controller calculated that they accumulated an estimeted

dose of. 1500_ mR before they first examined their dosimeters. It is l questionable whether this would. have been detectable on the high range instruments, and would- have far exceeded the' scales of the low range

, dosimeters. For these reasons, the recommendation made under field team l coordination for maintenance of field team dose records applies here . as well.

[ They did have a supply of KI and were aware of procedures for its use.

l They failed to demonstrate Objective Number 20, but did demonstrate

Objectives Number 21 and 22.

l l Communication throughout was excellent, fully demonstrating Objective

) Number 5

_ _ _ _ _ _ _ _ _ _ _ ___ __  :._..__u_..___...

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-) Remaining within the plume for over an hour, they failed to survey for ambient radiation on any consistent basis.

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c. When surveying was done, . they erroneously used high range instruments.

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d. No monitoring was done'outsiCa'the vehicle.

e. Calculation of radioiodine concentration required three attempts to obtain correct values,

f. Background readings were not verified before counting air samples.

g. The team exhibited an overall lack of training.

Areas Requiring Corrective Action 7 Team was unaware of maximum dose allowed, or turn around levels.

Recommend that individual dose rate record cards be developed showing above data.

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I O O

) The Nebraska City Decontamination facility failed to demonstrate the capability to perform personnel decontamination. Specifically, there were no shower facilities available. Persons staffing the facility reported that a portable shower would be used in a real emergency. However, they had not looked into thy particulars of how and where it vould be obtained and installed. Also, the segregation of clean and contaminated areas would be by masking tape on the floor. Due to the restricted space, the likelihood of recentaminating persons who had been decontaminated was high.

Summary: Objective Nunber 29 was not fully de=onstrated.

Deficency That Would Icad To A Negative Findingl

3. The Nebraska City Decontamination Facility failed to demonstrate the capability to perform personnel decontamination.

AUBURN, NEBRASKA A facility for decontamination of emergency workers was set up at the fire station in Auburn.

A well trained staff demonstrated the equipment and procedures for monitoring people and vehicles.

Facilities for personnel decontamination were limited in that they had only one shover.

3 Vehicular decontamination was fully explained with excellent facilities. The procedures for handling radioactive vaste were well thought out and suitable.

Summary: Objective Number 29 was demonstrated.

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) 1 See supplemental report, Section 3, detailing correction of these E-deficiencies.

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Sufficient resources were available to deal with any impediments to evacuation, fully demonstrating Objectives. Number 15 and 16.

The Sheriff also dealt with mobility impaired during the exercise, accounting for a demonstration of. Objective Number 18.

Appropriate dosimetry equipment and procedures were shown, fully demonstrating Objective Number 20.

As metioned above, the PIO was unsure of EBS procedures, however, he did coordinate with the IAC in a demonstration of Objective Number 25 At 1538, a message from the IAC advised of status deescalation to Site Area Emergency. It also reminded farmers that reentry was still on hold until State Health Officials could check the area. The message further advised: "No action required by you." This effectively terminated Recovery and Reentry activities without permitting demonstration of Objective Number 35 Sum =ary: Objectives not fully demonstrated: 13, 17, and 35 Deficiencies That Would Icad To A Negative Finding l

h. Failure to notify Indian Cave State Park in sufficient time . to permit alert and notification of transients in the 5 to 10 mile area within h5 minutes.

5 Failure to establish access control road blocks to evacuated area in a timely manner.

Area Requiring Corrective Action 9 The State should provide the needed training regarding proper PIO procedures.

2.3.2 Nemaha County Ambulance Unit Objectives to be demonstrated were: 5, 20, and 30.

The ambulance responded to a plant request to transport a con'taminated, injured patient to the hospital. The vehicle was equipped with all appropriate communication equipment satisfying an inadequacy from the 198h exercise.

i However, messages are relayed through the radio at the Law Enforcement

Center. The operation failed to relay the message totally and accurately.

! He failed to say that the patient was contaminated.

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i 1 See supplemental report, Section 3, detailing response to these

) deficiencies.

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) 2.4 MISSOURI STATE OPERATIONS At the " Unusual Event" staff are dispatched from the SEOC to the Atchison County EOC to establish a Forward Command Post (FCP). When this has been accomplished, most decigion-making vill' occur at the FCP. Until this time, the SEOC is the control center, and vill communicate with the team while enroute.

2.k.1 State Bnergency Operations Center (SEOC)

Objectives to be demonstrated: 1, 2, 3, h, 5, and 32.

Activation of the SEOC began at 0815 vith~ receipt of the call announcing the " Alert" status. Only members of the State Emergency Management Agency were called upon to staff the office for this exercise. These positions were double staffed and engaged in a shift change.

To this extent Objectives Number 1, 2, and 3 were demonstrated.

While the building facilities and communications are adequate, it was noted that they do not have a large scale map of the Cooper area showing the EPZ, the sector designations or population by area. .If evacuation or other protective actions are called for prior to the establishment of the FCP, these visual aids vould be required for informed decision-making by the SEOC staff. These same inadequacies remain from the last two Cooper exercises.

Therefore, Objective Number h was not fully demonstrated; Objective Number 5 was.

At 1122 the FCP announced they were operational and command was transfered to the FCP.

Through the rest of the exercise the SEOC was kept posted on all developments.

At 151h, after conferring with the FCP, the SEOC contacted FEMA to coordinate a request for Federal Assistance, demonstrating Objective Number 32.

Summary: Objective not demonstrated: Number h.

Recounnendation

6. Use of large scale map for Cooper area showing EPZ and population figures. This is not required, due to the reduced role of the SEOC resulting from delegation of control to the FCP.

2.k.2 Forward Cn-and Post (FCP)

The Missouri State FCP was located at the Atchison County EOC.

Objectives to be demonstrated vere: 1, 2, 3, h, 5, 12, 13, lb, 20, 21, 22, 25, 32, and 35

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) 2.k.3 Field Team Coordination / Dose Assessment Objectives to ' be demonstrated: 1, 2, 3, k, 5, 10,. 11, 20, 21, 22, and 35 The team from the' Bureau of Radiological Health was prepositioned at Rock Port and arrived at the EOF 'at 1120. Staffing was completed at 1125 Double staffing was used to demonstrate 2h hour capability.

Objectives Number 1 and 2 were fully demonstrated.

- Dose assessment and radio logs were kept and coordination of teams with the utility was very well done. Coordination with Nebraska or protective actions was also excellent.

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Upon arrival, they received no briefing by the utility to bring them up to date on the situation. Instead, they vandered from person to person trying to gather infor=ation as best they could.

Objective Nu=ber 3 was pa'rtially demonstrated.

When the Missouri team arrived at the . EOF at 1120 there was. virtually no space to accomodate them. Not enough chsirs or desks were available and the noise level was rather high though controlled. (It should be noted that these condition improved when they relocated to the alternate EOF about

)

1230.)

The rad monitoring maps for the States and the utility were all different and quite confusing in coordinating field team movements.

For these reasons, there was not an adequate' demonstration of Objective Number k.

All com=unication equipment worked well'before and during the relocation of the EOF. However, after relocation of the EOF, makeshift antenna placement caused co=munication dead spots for Missouri. Objective Number 5 was fully demonstrated.

Dose projection utilized both plant and field data. Calculations by hand vere demonstrated prompt 2y, and the team was directed effectively in defining the plume.

A two day time jump in the scenario allowed vegetation samples to be taken and dosage in the ingestion pathvay ~ to be projected. As mentioned above, coordination with Nebraska was good.

Objectives Number 10 and 11 vere fully demonstrated.

Staff were all equipped with high and low range dosimeters and TLDs, as well as appropriate record cards. KI was available and all were aware of the proper procedures concerning its use.

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When the EOF relocated to Auburn, the radio communication was not always audible.

It was subsequently determined that the antenna arrangement at the alternate EOF was inadequate.

To this extent, Objective Number 5 was not fully demonstrated.

The team possessed sufficient equipment and demonstrated the proper procedures to monitor and control exposure. However, the evaluator noted that a mid-range dosimeter should be included in their equipment. This vould give greater assurance that the 3 rem dose limit not be exceeded.

The availability and policies governing the use of KI were demonstrated, thus accounting for Objectives Number 20 and 22.

Summary: Objectives not fully demonstrated: 5 and 9 Area Requiring Corrective Action 12.

There were two different equipment checklists with the equipment, as well as third version in the plan. More equipment is carried than listed. Lack of single comprehensive checklist can result in (NUREG-065h, H.ll.). all necessary equipment before dispatch.

failure to include Recomunendation

7. Soil and vegetation sa=ples vould double-bagged.

be better protected if Also, water samples collected by syringe, rather

• than immersion of containers would be less likely to have surface contamination. Standard Operating Procedures for all sampling equipment (not just air sampler and radioiodine sample analyzer) should be compiled in a reference manual.

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) Neither the State nor County Plan address the issue of alert and notification of transients in the Brickyard Hill State Wildlife area. Alert and notification of persons in this area must be carried out in accordance with the requirements of NUREG-065h and REP-10 (formerly FEMA-h3).

Objectives Number 13 and lh were not demonstrated.

At proper times traffic control was ordered, and evidence was given of sufficient resources to handle evacuation, if required.

Objectives Number 15 and 17 vere demonstrated.

However, the organizational ability to evacuate mobility impaired persons was not demonstrated. The failure was due to the absence of sufficient

. Written information to give reasonable assurance that all mobility impaired could be accounted for.

There was no written list of those needing assistance.

Objective Number 18 was not demonstrated.

The resources to effect school evacuation vere successfully demonstrated, accomplishing Objective N mber 19 As mentioned above, the State representative assisted in the distribution of dosimeters before he actually would have arrived.

)

His involvement plus the absence of the County Health Officer who is charged with distribution of . dosimetry made it impossible. to assess the County staff capability to achieve that portion of Objective Number 20.

Also, TLDs were delivered by BRH and did not arrive until about 1130.

TLDs need to be stored and available at the County EOC.

Objective Number 20 was not fully demonstrated.

The ability to supply and administer KI was demonstrated, accomplf shing Objective Number 22.

The PIO for the County provided one formal press briefing, and the Civil Defense Director gave several status briefings throughout the exercise.

Objective Number 25 was demonstrated.

As the status at the plant deescalated, the County staff discussed recovery and reentry.

They arranged to secure evacuated areas, provided for reentry for i essential services, described safety precautions and communicated their j conclusions to all response organizations.

) Objective Number 35 was demonstrated.

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Summary: Objective undemonstrated: 27.

) .

Area Requiring Corrective Action

16. Proper use of registration forms to separate contaminated raid decontaminated evacuees will be required at the next exercise.-

2 5.h Decontamination Facility, Maryville, Missouri If monitoriong at the Maryville Relocation Center indicated the need to decontaminate evacuees, they were directed to the . decontamination site which was staffed by personnel from St. Francis Hospital, Maryville. Surface decontamination would be handled here; internal decontamination would be done at the hospital.

While there was no actual demonstration of decontamination of personnel.

Procedures were described and facilities were displayed and explained.

Objective Number 29 was demonstrated.

2.5.5 Atchison County Medical Support Objectives to be demonstrated: 5, 20, 30, and 31.

Medical support capabilities included both the amublance service and the Fairfax Co== unity Hospital.

Proper com=unication capability were exhibited by both the ambulance dispatch, the ambulance itself, and the hospital.

Objective Number 5 was demonstrated.

The ambulance crew summoned to the vehicle accident correctly used survey meters and took proper precautions to prevent contamination of the ambulance.

However, Deputy Sheriffs at the scene who did not have dosimetry, respirators, or protective clothing, assisted in loading the contaminated patient.

The ambulance proceeded to deliver the patient to the Fairfax Community Hosiptal where the emergency room was prepared to handle the contaminated individual. All proper procedures were observed for decontamination and vaste disposal.

The use of a radioactive source made the procedures quite realistic, and provided an opportunity to deal with cross-contamination.

Objectives 30 and 31 were demonstrated.

However, the evaluator noted that both the ambulance and hospital staff

~) lacked TLDs. Ambulance staff also seemed to lack an awareness of the fact that the use of KI could be initiated at their own discretion when the limits are projected to be reached, and need not wait for a specific authorization.

O O k**' ~ .

) 3 ACTIONS TO RBEDY DEFICIENCIES PREVIOUSLY CITED A preliminary reviev of the exercise findings revealed deficiencies attributable to both Ne.braska and Missouri. Details of these deficiencies were sent ' to ' both States, FDIA Headquarters, and the Regional Assistance Concittee on October 31, 1985.

The nature of the Nebraska deficiencies was such that they were correctable by training, plan revisions, and letters of agreement.

. One of the Missouri deficiencies required demonstrated capability through a remedial drill. It was successfully conducted on November 26, 1985 Details regarding the remedial actions of both States are contained in this supplement to the Evaluation Report.

3.1 NEBRASKA DEFICIENCIES 3.1.1 -Field Monitoring The following deficiencies were assessed against the Field Monitoring activity:

1. There was not sufficient operational radiation detection equipment available to place two fully equipped monitoring teams in-the field,

) nor was there a Letter of Agreement (LOA) between the Stati and both utilities to provide the means for such. (NUREG-065h, A.3, I. 7-10.)

2. Field team operation was deficient to the extent that:

a. One team was unable to locate predetermined monitoring points.

b. Re=aining within the plume for over an hour, they failed to survey for ambient radiation on any consi tent basis.

c.

When surveying was done, they erroneously used high range instruments.

d. No monitoring was done outside the vehicle,

e. Calculation of radiciodine concentration required three attempts and an unacceptable length of time to obtain correct values.

f. Background readings were not verified before counting air samples.

g. The team exhibited an overall lack of training.

The State was notified of these deficiencies October 31, 1985 On l November 29, 1985, the FD4A Regional Office received a letter detailing the following accomplished and intended remedial actions.

l On November 8, 1985, there was a joint meeting involving the State Division of Radiological Health, the State Civil Defense Agency, Omaha Public j Power District and Nebraska Public Power District. The purpose was to reviev

.) the details of the deficiencies cited above, and discuss a LOA covering l

the critical points.

l All parties agreed on the necessity for such letters and indicated

! that the following stipulations vould be acceptable.

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) been completed. At 13hD the EOF called to ask about the location of the access control roadblocks. It became apparent that roadblocks had not been established. They were oredered to be set up at 13h3. Failure to establish access control in a timely manner was a deficiency.

On November 29,15%5, the State submitted changes to the Nemaha County Plan clarifying responsibilities related to access control. .A training session for County Directors with REP responsibilities has been scheduled for January, 1986. Access control vill be a point of emphasis.

This deficiency will be closed, pending a demonstration at the next

, exercise.

3.1.4 Alert and Motification - Indian Cave State Park l

Indian Cave State Park was not notified by the Nemaha County EOC in sufficient time to conduct route alerting, thus providing alert ~ and notification to park users within h5 minutes from the time off-site authorities are notified, as required by NUREG-065h.

On Nove=ber 18, 1985, a meeting was held with Nebraska Game and Parks officials, the Superintendent of Indian Caves State Park, the Director of Radiological Health and the Assistant Director of State Civil Defense.

The resultant decision was that all State owned parks, recreational and wildlife areas within 10 miles of a nuclear power plant would begin

) evacuation procedures no later than the announcement of a Site Area Emergency.

Also, State and local Plans have been amended to specify both the persons responsible and the times for notification to assure that parks and recreation areas can comply.

This deficiency vill be closed pending a demonstration of the capability of the County to notify Indian Caves State Park, and the Park to alert and notify transients in the park within the alotted time at the next exercise.

3.2 MISSOURI DEFICIENCIES 3.2.1 Atchison County EOC The first is the failure of the Atchison County EOC to provide both an alert and an instructional message to those citizens of Atchison County within the 10 mile EPZ vithin 15 minutes as prescribed by NUREG-065h, Appendix 3.B.

The 15 minutes begins when the plant notifies the off-site authority of the emergency.

At 110h the General Emergency was declared. The licensee attempted, according to the State Plan, to notify SEMA at the State EOC. The line vas busy, and after two failed attempts, the utility liaison gave notification instead to the Atchison County PIO Liaison at the EOF. The County PIO,

) in turn, called the County EOC at 1112 and notified them. Sirens were activated (simulated) at-1125 and the EBS station was called at 1127.

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) 2. Since no specific conservation area is mentioned, it must be assumed that this change applies to all conservation areas. Those within 5 miles of a plant (callaway) only have 15 minutes for alert and notification. Response for each _ contingency must be addressed individually. ,

3. There is no description of how prompt alert and notification vill be performed. As stated in Iqy memo of October 31, 1985, 'These revisions shall fully comply with all applicable provisions of NUREG-065h, FDfA-REP-1, Rev. 1, and FEMA-h3 (Reissued in November, 1985 as FEMA-REP-10).' Compliance with these documents would require that any mobile siren system be subjected to the same tests and requirements as fixed sirens.

h. At a minimum, the signs that are proposed must be at stil points of ingress / egress as well as at all parking areas. They must also include reference to the EBS Station, including location on the dial, plus evacuation routes to lead them away from the nuclear power plant. Reference, FEMA REP 11 'A Guide to Preparing Emergency Public Information Materials'.

5 You must indicate how you vill deal with rumors which may be generated from an early evacuation not followed by an immediate EBS message."

On the date of this report no response from the State had been received.

The deficiency still exists. '

As advised on November 14, 1985, the State of Missouri vill have until February lb, 1986, to accomplish the remedial actions cited above.

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) MISSOURI STATE OPERATIONS Forward Cn-and Post (FCP)

10. 'Ihe FCP staff did not issue subsequent proper messages to alert transients regarding appropriate protective actions.

Field Team Coordination / Dose Assessment

11. Coordination of field teams was complicated by the use of three different maps. A single map indicating predesignated radiological

' monitoring points should be adopted and provided for use by both States and the licensee. However, the one currently in use by the licensee is not recommended.

Field Monitoring

12. There were two different equipment checklists with the equipment, as well as a third version in the plan. More equipment is carried than listed. Lack of a single comprehensive checklist can result in failure to include all necessary equipment before dispatch.

(NUR E-065h, H.11.) -

COUNTY OPERATIONS Atchison County EOC i

13. Backup communication with the EOF prior to arrival of SEMA staff -

, is required.

Ih. People requiring trans$)ortation assistance must be listed by name and address, with special needs of mobility i= paired being clearly indicated. This list must be updated et least annually.

(NUREG-065h, J.10.d.)

15 EBS messages on sheltering should contain sheltering information for transients.

Relocation Center, Maryville, Missouri

16. Proper use of registration forms to separate contaminated and decontaminated evacuees vill be required at the next exercise.

Atchison County Medical Support

17. TLDs should be available for both the ambulance crew and the hospital staff when handling a contaminated patient.

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18. Ambulance crews need to be better trained in the use of KI.

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O O o

- - Atchison County Medical Support

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9 Since the hospital does not have a health physicist on staff, the utility should provide one when the hospital expects to receive a contaminated patient. The utility should also reimburse the hospital at lesst for its use of supplies, equipment and consun:mables used during an exercise.

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Cf Federal Emergency Management Agency Region VII 911 Walnut Street Kansas City, Missouri 64106 l

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JAN 2- E {

MD!ORANDUM FOR: R.D. Ross, Director  !

Missouri State Emergency Management Agency Mi FROM: l John P. Coleman, Acting Regional Director, FEMA-Region VII '

SUBJECT:

Cooper Exercise Deficiency - Brickyard Hill - Response Due Due February 3, 1986 1

W3 have received your memo of January .22, 1986, in which you inform us of your inability to accomplish all the remedial actions necessary to eliminate th2 deficiency associated with the Brickyard Hill State Wildlife Area by the February 1h, 1986 date.

In tddition to the reasons you cite, we also consider the absence of a written plan to be significant. a f.

To cssist you, let me chronicle what has transpired.

31, 1985 stated. Our memo of October A

."As a result of the pre and post exercise review it was discovered that neither the Missouri Radiological Emergency Response Plan nor the Atchison County Plan make any provision for the alert and notification within h5 minutes of transients at the Brickyard Hill State Wildlife Area.

...the corrective action vill consist of:

(A) A revision of State and Local plans to provide for the alert and notification (within h5 minutes) to the transient population of the Brickyard Hill State Wildlife Area. These revisions shall fully comply with all applicable provisions of NUREG-065k, FEMA-REP-1, Rev.1, and FDIA-h3 (now FEMA REP-10).

(B) A successful demonstration of the capability to carry out the plan i

revisions detailed above in (A).

If the results of this remedial exercise are to be included in the main exercise report, the demonstration vill have to be co=pleted

by December 6, 1985. If it cannot be accomplished within this -

timeframe, then according to the enclosed Guidance Me=orandum EX-1, it must be succescrully demonstrated by February 14, 1986, and detailed in a supplemental report."

Your memo of November h, 1985, attempted to deal with the required plan ravisions called for in "(A)" above. g 1

-- o- r

-g-3 In our subsequent memo to you dated November Ib, 1985, we rejected the proposed plan changes and set forth five specific reasons why. These reasons are again -

s;t out in the Cooper Exercise Evaluation Report, p. Sh, Section 3.2.2.

Before staging a remedial exercise, acceptable plan revisions are required.

A3 mentioned above, any revisions must fully comply with applicable provisions of NUREG-065h, FEMA-REP-1, Rev. 1, and FEMA REP-10 (formerly FEMA-h3).

Rrgr.rding the later document, you should particularly note Appendix 1,

" Procedures for Preparation and Submission of a Design Report Describing Alert E

/

cnd Notification Systems", as Plan changes or amendments will also require Design Report changes or amendments.

Pinse provide us by February 3, .1986, your anticipated timeframe for cecomplishing the above listed requirements.

cc: Robert Martin, NRC IV Charles Hackney, NRC IV Clem Morgan, NPPD Ken Green, FEMA H.Q.

I N&TH: Sumpter /csw 1/24/86 arroll Leonard Be y Sumpter

Ch:rits M. Histnir Rich:rd D. Ross

{A*eheroh

• Ccior Gmircl Directer ernor I Th7 Adj:taat G niral STATE OF MISSOURI EMERGENCY MANAGEMENT AGENCY .

i.  ; I -

1717 Industrial Drive - P.O. Bo s 116 4 /

Jefferson City, Missouri 65102 Phone 314 - 7512321 February 3, 1986

,-QWu E

MENORANDUM ,

h FB1986

'IO: John Coleman, Acting Director Q tq FENA Region. VII d, '

4 bFROM: Richard D. Ross, Director '

Missouri State Emergency Management Agency y

SUBJ: Schedule of Corrections Brickyard Hill Wildlife Area 1 There has been considerable discussion on the necessary procedure e to neet the Alert and Notification deficiency for Brickyard Hill Wildlife Area. The first problem, as we see it, was your office g*

establishing a remedial exercise date without following the pro-  %

The last para-visions as outlined in Guidance Memorandun EX-1.

graph on page 2, states "The Regional Office will promptly initi-ate a consultation process with the members of the RAC, the state, and FEMA HQ's etc..." If this process had been followed, the state would have had scrre input into the time required to properly implement effective Alert and Notification procedures, and there would have been no need to postpone the remedial exercise.

Obviously, further explanation is needed to cover the five specific reasons why the proposed plan changes were rejected.

1. The Department of Conservation has elected to clear the conservation areas at the " Alert" emergency classification as a precautionary measure. They understand the time limit of 45 minutes. If the plant were to go directly to Site Area Dnergency the sane 45 minute constraint would apply.

2. The Missouri Nuclear Accident Plan containing information -

regarding the 10 mile emergency planning zone around Cooper Nuclear Station deals with just Cooper and not Callaway.

If it is still confusing as to which plan is being referenced, please refer to the lower left hand corner of the page. Each page, except Letters of Agreement, has " Cooper" on it.

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. ME20 - Cooper :. edule of Corrections page 2 l

3. When revisions to the Conservation Department's SOP are cm plete the means and procedures will be spelled out. ,

'Ihe reason these procedures were not outlined in our 4 .

November 1985 nemo was because the conservation Depart- [

ment had not yet agreed to the placement of suggested  :

signs in these areas. A sound propagation test had not 3 yet been run on the proposed mobile siren to ensure f effectiv= coverage. ,

4. 'Ibe Department of. Conservation has now agreed to place- [-

ment of signs in all parking areas. We expect an answer L very soon as to whether they will agree to signs at all 6 ingress / egress routes. @

5. Rtrnors generated by the Conservation Department closing of 1 their conservation areas will be resolved in a LOA with the L Atchison County Sheriff which will be forthecming.

As you can see, due to cmplications arising with the inplemen-

• tation of an effective Alert and Notification system, a consultation I as stated in G1 EX-1, would have been nore appropriate, than dic-tation, which led to the eventual postponing of the renedial 10.

exercise.

Following is a list of dates of the inplementation of an effective Alert and Notification system to be inplemented for the Brickyard

. Hill Wildlife Area:

1. Proposed changes to the Conservation SOP will arrive at your office - NLT 13 February 1986.

2. Once these changes are approved, it should take approxi-mately 30 days to print and make distribution. 1

3. Construction and erection of signs should be empleted by 1 June 1986. See attached letter for wording, size and construction. .

4. The sound propagation test results will be completed and sutmitted to your office for approval - NLT 1 April 1986.

5. If the coverage shown by this test is not acceptable we will have to request a vehicle nodification to nount a larger siren higher on the vehicle. .If this vehicle modification is necessary it could take scme tine for approval, since the modification would have to be requested through Department levels of state government.

a MDO - Schedule of Corr:ctions page 3 JOINT OPERATIONS EDF

2. On 18 January 1986, CNS received a radio for use as a back-up means of ccmrunications between the plant and Atchison County. The first monthly connunications check was conducted 28 January 1986 between the utility's on-site emergency coordinator and the Atchison County Dner-gency Coordinator.

MISSOURI STATE OPERATIONS FCP

10. There are several preformatted messages in the Cooper Plan that should contain information concerning alerting /

sheltering information for transients. These changes will be made in both the State and County plans. 'Ibese changes will be distributed on or about 1 April 1986.

Field Team Coordination / Dose Assessment

11. This topic has been discussed with E BRH and the utility; '

they agree to resolve this problem - NLT 1 May 1986. 4 Field Monitcring *

12. There were outdated lists with the equipnent. This V list is being brought up to date and will be distri-buted NLT 1 April 1986.

COUNTY OPERATIONS Atchison County EOC

13. See 2. above.

14. The list of the people needing transportation assistance was available fran the FCP coordinator, the Atchison Co.

Family Services office, or the Emergency Coordinator of -

CNS. The Atchison Co. Coordinator has now been told to contact one of these three sources for that information. '

I 15 . See 10. above. '

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MEm - Cooper Schedule of Corrections I . Page 4 Relocation Center, Nryville, m  !

16. New contamination survey forms had been added to the Noda-way Co. Disaster Preparedness Plan after the 1984 exercise.

Not using these forms was an oversight by those in charge in Nodaway Co.

Atchison County & dical Equignent

17. 'Ihe Atchison Co. Ibalth Nurse has started working with Dnergency Operations Personnel; from now on she will be handling the issuing of dosimetry to emergency workers.

18. 'Ihe County nealth Nurse will be making KI available to -

county emergency workers after she gives them a briefing, on the hazards and the effectiveness.

For further information contact Les Kanpen at (314) 751-2321 ext 343.

l7 LK:sb P3 f g, cc: Ken Green, FDfA HQ

%4 Charles Hackney, NRC IV Clem Morgan, NPPD t

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ATTENTION -

1 F YOU REAR A BTEADY BURST ON A BIREll TilERE RA8 BEEN AN INCIDENT AT l t

COOPER NUCLEAR STATION, RETURN TO YOUR VElllCLE AINI EVACUATE THE AREA  !

IMME0lATELY. TlHE YOUR RADIO TO g

RFEQ,080 ON YOUR AM BIAL, FOR 1 o. ,

. EMERRENCY INFORMATION. AFTER j

i LEAVING Tile WILDLIFE AlthA PROCEED l IN A NORTH OR EAST $RLY DIRECT 10'N

- ~

--DO NOT 00 SOUTil OR. MEST.iYOU

. i WILL BE MET ON "A illGHWAY NORTH

. OR lil0RWAY 275 BY EMERGENCY  !

, PERSONNEL WITil FURTilER  :

INSTRUCTION 8. '

l MISSOURI EMERGENCY

u n eE m T neeney

a l...

MISO 0URI DEPARTMENT OF CONSERVA r* MAILING ADDRESS:

P.O. Box 180 STREET LOCATION:

Jefferson City, Missouri 65102-4180 2901 West Truman Boulevard

- Jefferson City, Missouri Telephone 314/751-4115 LARRY R. GALE, Director January 15, 1986 Mr. Les Kampen State Emergency Management Agency Adjutant General Building P. O. Box 116 l

J:fferson City, MO 65102 Dear LCs3 De Department proposes to erect five signs on the Brick one at each of the river accesses in the evacuation area. yard Hill Wildlife Area and W;tson, Langdon Bend and Hoot Owl Bend. 'These accesses are De proposed post construction.signs (Textare' 18"x24" and will be silk screened on masonite, using one attached).

i In addition v2hicle siren. to the signs, the local agent will travel through the areas sounding10* the arise. By so doing, the agent would be able to answer questions that might i

'M*

. I 60db Civil Defense siren and much more economical.De use of the 1 De unattended siren will be expensive to install and to maintain.

Dere is no Glactrica) power at any of the parking lots or accesses; therefore, siren installation would require bringing power lines to each site.

r -..to vandalism and might.not be operable in a real emergency.Also, the siren would be su Signs can quickly be expected and the public better toprotected.

be vandalized; however, signs can be replaced more De Department pl:ase staff has concurred in this approach.

let me know. If you have any questions, Sincerely, .

duY Y DAVID D. HURLBUT Operations Officer 5 DDH:JRW:sb Att.

f 4 l COMMISSION lHURAN kothe JOHN POWELL Rolla JOHN B. MAHAFFEY Sprin[ifleid RICHARD T. REED r- n-- ~

g ,)

/

~

Federal Emergency Management Agency ,

- Region VII 911 Walnut Street Kansas City, Missouri 64106 FEB I 0 G 6 -

MD40RANDUM FOR: Richard D. Ross, Director State Emergency Management Agency M FROM:

Y-ohn P. Coleman, Acting Regional Director l FEMA - Region VII

SUBJECT:

Remedial Actions - Cooper Exercise, 1985 I have received your memo of February 3,1986 dealing with corrective cetions necessary to rectify inadequacies in the . Cooper Exercise of October 16, 1985. In that memorandum you discuss both the deficiency et Brickyard Hill and several lesser inadequacies at various other sites.

s At this time, I will address only your response covering the corrective N.

cetions at Brickyard Hill. I will respond to tne other lesser s inadequacies under separate cover.

While you do address some of the issues relating to the deficiency, there is no mention of an amendment to the Design Report. Since this will form the basis for the required State and local plan changes, its omission is critical.

The Region has detailed ' the deficiency and the necessary corrective cetions in memos dated October 31, 1985, November IL, 1985, December 11, 1985, and January 27, 1986. These are in addition to the Exercise Evaluation Report, itself, December 20, 1985 Rather than again restate the explanatory details, let me su==arize:

1. The licensee, the Cooper Nuclear Staticn, must submit an amended design report covering the alert and notification of the transients at the Brickyard Hill State Wildlife Area. _

2. State and local plans must be amended to reflect the administrative and physical means to accomplish the methodologies set forth in the design report.

Based on the materials you have attached, it appears that the k physical means you intend to use vould include the posting of signs and a mobile siren. Two comments are in order;

~ts-as

, (A) Tha wording on tha signs is cd quSta with th2 cxcIption of "a steady burst." Since the siren is mobile, it would seem difficult to guarantee that the sound v111 be heard as a " steady burst". Unless the design report vould give technical support to such a statement, the words should be omitted and the sign read: "If you hear a siren there has been ." ~

(B) Any changes in State or local plans 'must fully account for a 2h hour capability for implementation of the A&N system at Brickyard Hill.

3 The amended plans must be tested in a remedial exercise.

All of the above must be acco=plished by June 15, 1986 so that we can E proceed with the activities necessary to prepare for the Cooper exercise of September 2h, 1986.

Failure to rectify the Brickyard Hill deficiency by June 15 could make it impossible to participate in the 1986 exercise.

If your staff requires assistance in properly interpretating the relative FD(A-related guidance pertinent to these issues, we vill be happy to cssist them. In this regard, please contact me or, have your staff contact Richard Sumpter at FTS 758-2161.

cc: Bob Wilkerson, FEMA HQ Charles Hackney, NRC IV ,

Clem Morgan, NPPD 6' Fran Laden, Nebraska Civil Defense Agency y*

Ken Green, FD4A HQ p..

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[

6 0 jg

, Federal Emergency Management Agency Region VII 911 Walnut Street Kansas City, Missouri 64106 MAR 7 mee MENORANDUM FOR: Richard Ross, Director E State Emergency Management Agency FROM: Frank Begley, Division Chief Natural & Technological Hazards Division

SUBJECT:

Proposed A&N Changes - Brickyard Hill Your memo of February 13, 1986 transmitted a large number of proposed changes to State and Local plans relating to the Alert and Notification Methods to be used at Brickyard Hill.

My memo ' of February 21, 1986 promised a detailed commentary on those F proposed changes. The comments are as follows:

Q

1. Page Cooper 21. The letter of agreement (LOA) between SEMA and A the Atchison County Sheriff refers to a specific role for staff members of the Rock Port and West Atchison Fire Departments. These two organizations should be added as signatories to the LOA.

?. Page Cooper CC3. Paragraph III. B.5 of The Censervation Department's SOPS says that "If the Atchison Ccun'y Ccnservaticn Agent is not available to clear conservation areas, the Holt County Conservation Agent vill be called upon to report to the FCP in Rock Port, Mo."

Is this for the purpose of being dispatched to Brickyard Hill for route alerting? If so, at what level vill the Holt County agent be summoned? What is his response time?

If the A&N Design Report calls for a special type siren, where vill the Holt County agent obtain it?

Also, in paragraph number 6. , you refer to the role of the Atchison County Sheriff as back up for route alerting. The key issue is whether or not he (she) vill have access to a mobile siren of the type required by the forthcoming amendment to the Design Report.

3. Page Cooper CC3. Paragraph III. C.2. does not indicate how or who v111 notify the Atchison County Conservation Agent when the

" Alert" stage is declared.

i. .

e Paragraph III. C.3. refers to evacuees from the conservation areas encountering emergency worker teams. If evacuation is accomplished at the " Alert" stage, there vill probably not be any emergency E workers in the field at that time.

h. Page Cooper 3.2.

who vill notify The notification chart should indicate specifically the conservation agent at Brickyard Hill. This can then be reflected in the narrative under III.

shown somewhere on page 3.k.

C.2., and also

5. Page Cooper SHP 4:

ParagraphIII.B.3.shouldalsoreflech, location of aircraft to be used (i.e. point of departure) and location of point of arrival. In addition, the new elapsed travel time estimates should be included here, the estimates should be attached.and a copy of the letter from SHP giving

6. Draft EBS Messages:

is the statement: At the bottom of some of the EBS drafts there

" Transients within 5 miles of the plant are asked to seek shelter or leave the area immediately."

Other draft messages state:

are asked ...." " Transients within the affected area This latter format is more appropriate, and all drafts should be changed to read this way.

V~

As noted in an earlier memo, these plan changes are based on the casumption that an amended design report will call for the use of a g*

mobile siren system to accomplish initial alert.

v.

Should other means be called for, the State and local plans vill have to be changed accordingly.

Please direct any questions to Dick Sumpter at FTS 758-2161.

l

[

( Federal Emergency Management Agency Washington, D.C. 20472 - /3

, MAR I 81986 MNERNDlM PCR: Ridard J. Leonart!

' Chairman Regi saistancs e- 5. W[ p**gG FROM: Robert . Wi reon as Chief 1 Techonological Hazards Division .

SLEDECT:

Cooper Ibclear Station Alert and Notification System (ANS)

Design Review In recent discussions between aanbers of our staffs, it was agreed that '

procedures for alerting and notifying the transient population along the Missouri River within the Cooper Ibclear Station pitane exposure emergency planning sone (EPZ) are not adequate. 'the purpose of this memorandan is to reiterate our ocncurrence with Region VII's assessment that the States of Missouri and Nebraska and the Nebraska Public Power District must develop adequate comprehensive alert and notification proce& ares for stretches of the Missouri River not covered by sirens.

Many options for providing an alert signal to persons on or along the river are cvailable; however, regardless of Wich gwhos are adopted they mast -

fully ocuply with all fem requirements (e.g.15- and 451ninute alerting re-quirements as outlined in NURErA654/PEm-REP-1, Rev.1, Appen51x 3 and FEE- N.

3EP-10).

s The Cooper ic tetorily Nuclear Station ANS will not be approved until this issue is set-addressed.

i Despite the fact that the Missouri River in the EPZ io mostly rural and used predcninantly by conmercial river traffic, it is large enough and potentially accessible enough to the surrounding population to warrant further procedures by the consideration and the developnent of special alerting appropriate authorities.

If you have any questions please contact me at 646-2860

a Fedarai Emargency Managena nt Agency Region VH 911 Walnut Serost Kansas City, Missouri Hies APR 3 1986 MD00RANDLM FOR: Fran Inden, Assistant Director State of Nebraska Civil Defense Richard Ross, State Director k Missouri State knergency Management Agency FR(Mt Frank Begley, Division Chief Natural & Technological Har.ards Division

SUBJECT:

Cooper Alert and Notification System (ANS) Design Review Response Due June 1, 1986 Attached is a copy of a recent memorandum from Robert Wilkerson addressing issues related to the Cooper ANS.

You will note that approval of the system is being withheld due to a lack of ciren coverage on the Missouri River.

In addition to the aforementioned " alert" problem, ve also have the concern that transients on the Missouri River are without " notification", since they would not be expected to have radios. r Also attached is a copy of FD(A REP-11. This document allows for the use 4 cf cigns (pp. 9 and 10) as a means for notification in the absence of other  %

notification methods.

If the use of signs is selected as a notification methodology, they should be placed in such a way as to be readable by boaters entering the EPZ via the river and at other access points to the river.

Please inform us by June 1, 1986, of the licensee's proposed remedies and an cctinated time frame for completion.

Attachments cc: Jay P11 ant, NPPD Charles Hackney, NRC IV Robert Wilkerson, FDIA HQ Ken Green, FEMA HQ Tom Carter IEAL N&TH Sumpter /csw 4/2/86 b

Carroll k

Leonard egley Sumpter IM Y V

1. '"% UNITED STATES s

, NUCLEAR REGULATORY COMMISSION

+

REGION IV

$11 RYAN PLAZA DRIVE. SulTE 1000

, y ' '* #

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[ ARLINGTON. TEXAS 79011 APR I T 1986 In Reply Refer To:

Docket: 50-298 bis Nebraska Public Power District ATTN: J.' M. Pilant, Manager, Technical Staff-Nuclear Power Grcup P. O. Box 499 Columbus, Nebraska 68601 Genticmen:

Attached are copies of letters from the Federal Emergency Management Agency (FEMA) concerning the Cooper Nuclear Station (CNS) Offsite Public Notification System. It was noted that approval of the system is being withheld due to a lack of notification coverage on the Missouri River. It is requested that representatives from Nebraska Public Power District and the appropriate state agencies coordinate with FEMA.to reach a timely resolution to this problem.

Additionally, it is requested that interim compensatory measures be in place for notifying the affected sectors until approval for the system is achieved.

You are reauested to submit to this office, within 30 days, a description of those compensatory actions that you have taken.

If you have any further questions, please contact this office.

Sincerely, ,

, \ s J. E. Gagliardo, Chief Reactor Projects Branch cc w/ enclosure:

frankBegley,DivisionChief Natural & Technological Hazards Division Federal Emergency Management Agency Region VII 911 Uainut Street Kansas City, Missouri 64106 Guy Horn, Division Manager of Nuclear Operations Cooper Nuclear Station o _

I P. O. Box 98 -$ $ Q 7h,51R Brownville, Nebraska 68321 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director