ML20211Q380
| ML20211Q380 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/26/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML20211Q386 | List: |
| References | |
| NUDOCS 8703030077 | |
| Download: ML20211Q380 (14) | |
See also: IR 05000498/1986035
Text
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FEB 2 619M
In Reply Refer To:
Dockets:
50-498/86-35
50-499/86-35
Hcuston Lighting & Power Company
ATTN:
J. H. Goldberg, Group Vice
President, Nuclear
P. O. Box 1700
Houston, Texas
77001
Gentlemen:
SUBJECT:
EMERGENCY PREPAREDNESS APPRAISAL
This refers to the inspection conducted by Mr. J. B. Baird of this office and
other accompanying personnel during the period December 1-12, 1986, of activities
authorized by NRC Construction Permits CPPR-128 and CPPR-129 for the South Texas
Project, and to the discussion of our findings with Messrs. R. Frazar, W. Kinsey,
and other members of your staff at the conclusion of the inspection.
{
Region IV conducted a preoperational inspection (hereafter called the
inspection) of your emergency preparedness program to verify the adequate state
of onsite emergency preparedness at the South Texas Project, Units 1 and 2,
prior to the determination for issuance of an operating license.
The objectives
of the inspection were to evaluate the overall adequacy and effectiveness of
emergency preparedness and to identify areas of weakness that need to be
strengthened. We will use findings from this inspection as a basis for
requesting action to correct deficiencies and effect improvements.
Areas examined during this inspection are described in the enclosed report.
Within these areas, the inspection team reviewed selected procedures and
representative records, inspected emergency facilities and equipment, and
interviewed personnel.
The findings of this emergency preparedness inspection indicate that certain
deficiencies exist in your emergency preparedness progrr.m.
These are addressed
in Appendix A, " Emergency Preparedness Deficiencies." You are requested to
provide to this regional office within 30 days after receipt of this letter a
schedule for correcting or dispositioning these deficiencies prior to fuel load.
Further review of this emergency preparedness inspection also indicates that
there are other areas that should be evaluated and considered for improvement in
your emergency preparedness program.
These areas are discussed in Appendix B,
" Emergency Preparedness Improvement Items."
Your corrective actions, addressing each of the items identified in the
attachment to the enclosed report, are to be incor crated into the South Texas __ _
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Houston Lighting & Power Company
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,
' Project emergency plan and procedures as appropriate.
This matter will be the
subject of a followup review during a subsequent emergency preparedness
inspection.
Within the scope of the inspection, no violations or deviations were
identified.
.-The response requested by this letter is not subject to the clearance
procedures of the Office of Management and Budget as required by the Paperwork
'.
Reduction Act of 1980, PS96-511.
Should you have any questions concerning this inspection, we will be pleased to
discusstpemwithyou.
Sincerely,
ORIGINAL SIGNED BY:
J. E. Gagliardo, Chief
Reactor Projects Branch
Enclosures:
1.
Appendix A - Emergency Preparedness Deficiencies
2.
Appendix B - Emergency Preparedness Improvement Items
3.
Appendix C - NRC Inspection Report
50-498/86-35
50-499/86-35
cc w/ enclosure:
Houston Lighting & Power Company
ATTN:
M. Wisenberg, Manager,
Nuclear Licensing
P. O. Box 1700
Houston, Texas
77001
Texas Radiation Control Program Director
bcc to DMB (IE35)
bec distrib. by RIV:
- RPB
DRSP
- RRI-0PS
R. D. Martin, RA
- RRI-CONST.
- Section Chief (RPB/C)
- R&SPB
- MIS System
- RIV File
- D. Weiss, RM/ALF
- RSTS Operator
R. Pirfo, ELD
- R. G. Taylor, RPB/C
- RSB
- Project Inspector
- J. B. Baird
- L. A. Yandell
- W. L. Fisher
R. L. Bangart
D. B. Matthews, IE
G. F. Sanborn
Chief, Radiological Preparedness Team, FEMA, RVI
,
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APPENDIX A
EMERGENCY PREPAREDNESS DEFICIENCIES
The NRC's i.nspection of the South Texas Project Emergency Preparedness Program
identified'a number of emergency preparedness deficiencies which were discussed
~with Mr. Kinsey and members of your staff during the exit meeting on
' December-.12, 1986. Areas in which deficiencies were identified are presented.
'below along with specific findings numbers from the NRC inspection report.
,
2.0.~ Emergency Organization
'
,
Staff and support positions in the emergency response organization below
'-
the manager level had not been identified, and duties and responsibilities
for these positions had not been developed.
(498/8635-001; 499/8635-001)
-
A method had not been developed to notify personnel of their assignment to
-
the emergency response ~ organization, identify names to Training, and
include the name af qualified individuals on the call-out roster.
(498/8635-002; 499/8635-002)
'
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An unannounced augmentation drill had not been conducted to provide
reasonable assurance that augmentation times in Table C-2 can be met.
(498/8635-003; 499/8635-003)
3.0 Training
-
General Employee Training (GET) and specific emergency response training
had not been completed for operations staff and personnel assigned to the
emergency response organization.
(498/8635-004; 499/8635-004)
4.0 Emergency Facilities and Equipment
The Heating, Ventilation, and Air Conditioning (HVAC), Regulatory
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l
Guide 1.97 instrumentation, Emergency Response Facility Data Acquisition
and Display System (ERFDADS), and Qualified Display Processing
System (QDPS) systems were not operational in the control room.
(498/8635-005; 499/8635-005)
The identification and control of emergency equipment, supplies, and
-
decisionmaking aids was not adequate for the control room, and outfitting
was inadequate.
(498/8635-006; 499/8635-006)
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Installation of the Technical Support Center (TSC) access door, status
boards, communications, ERFDADS, radiation monitoring, HVAC, toxic gas and
'
smoke detection systems, acoustic wall panels, and emergency power
provisions were incomplete.
(498/8635-007; 499/8635-007)
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The TSC was not supplied with an adequate range and depth of equipment and
supplies to support emergency operations.
(498/8635-008; 499/8635-008)
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The physical layout and concept of operations for the Operations Support
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Center (OSC) was inadequate to perform the functions stated in NUREG-0737.
(498/8635-009; 499/8635-009)
-
Responsibility,. equipment, and procedures had not been provided for
determining continuous habitability of the OSC.
(498/8635-010;
499/8635-010)
-
The OSC emergency equipment locker was not supplied with the inventory
stated-in procedure OEPP02-ZA-0002.
(498/8635-011; 499/8635-011)
Installation, testing, turnover, and personnel training for the QDPS,
-
ERFDADS, and Radiation Monitoring System (RMS) for the E0C had not been
completed.
(498/8635-012; 499/8635-012)
Filter leak testing and charcoal efficiency determinations had not been
-
conducted for the Emergency Operations Center (EOC), and the filter system
had not been put on a defined testing frequency.
(498/8635-013;
499/8635-013)
-
No provisions for protective clothing, personnel dosimetry, or respiratory
protection had been made for the E0C.
(498/8635-014; 499/8635-014)
-
There was no contingency plan for performing E0C functions in the TSC in
the event that the E0C was not functional.
(498/8635-015; 499/8635-015)
-
The post-accident coolant sampling and analysis system was not completed
and operable, and the capability to sample and analyze a sample within the
required 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> had not been demonstrated.
(498/8635-016; 499/8635-016)
The post-accident containment air sampling and analysis system was not
-
completed and operable, and the capability to sample ano analyze a sample
within the required 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> had not been demonstrated.
(498/8635-017;
499/8635-017)
The post-accident gas and particulate sampling and analysis system was not
-
completed and operable, and the capability to sample and analyze a sample
under accident conditions had not been demonstrated.
(498/8635-018;
499/8635-018)
-
The post-accident. liquid effluent sampling and analysis system was not
completed and operable, and the capability to sample and analyze a sample
under accident ' conditions had not been demonstrated.
(498/8635-019;
499/8635-019)'
-
Specific provisions and arrangements had not been made for offsite
assembly areas.
(498/8635-020; 499/8635-020)
No provisions had been made for decontamination of personnel at assembly
-
areas outside of the normal radiological controlled area.
(498/8635-021;
499/8635-021)
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The HL&P principal spokesman position was not included in the Plan,
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Section C, Figure C-3, and Table C-3.
(498/8635-022; 499/8635-022)
-
Job descriptions for MIC positions below the principal staff were not
included in the implementing procedures.
(498/8635-023; 499/8635-023)
The' number of electrical outlets in the Public Information Office (PIO)
-
support room of the Media Information Center (MIC) was not adequate to
support planned activities.
(498/8635-024; 499/8635-024)
Non-radiation process monitor systems installation, testing and turnover
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were not complete.
(498/8635-025; 499/8635-025)
Provisions for respiratory protection at emergency response facilities
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were incomplete and not adequate.
(498/8635-026; 499/8635-026)
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The Plan and implementing procedures were not consistent with the
respiratory protection provisions listed in the FSAR.
(498/8635-027;
499/8635-027)
-
Provisions were not made for respiratory protection for control room
personnel and field monitoring teams, and supplies of respiratory
protection devices for OSC emergency workers were inadequate.
(498/8635-028; 499/8635-028)
Provisions for protective clothing at emergency response facilities were
-
incomplete and not adequate.
(498/8635-029; 499/8635-029)
-
The licensee had not addressed protective clothing in the Plan, and had
not designated the type, number, and location of protective clothing units
in an inventory procedure for each facility and emergency kit, including
the control room.
(498/8635-030; 499/8635-030)
The backup communications system between STP and the County and State E0Cs
-
was incomplete.
(498/8635-031; 499/8635-031)
-
The prompt public notification system was incomplete and not verified to
be. operable.
(498/8635-032; 499/8635-032)
5.0 ' Procedures
-
Emergency plan implementing procedures were not always consistent with the
Plan which they were implementing.
(498/8635-033; 499/8635-033)
The licensee's emergency plan implementing procedures were incomplete, and
-
normal station operating procedures used to implement the emergency plan
failed, in many cases, to adequately address emergency conditions.
(498/8635-034; 499/8635-034)
No procedure had been provided to govern the activation, operation and
-
deactivation of the TSC and EOC.
(498/8635-035; 499/8635-035)
.A
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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4
The OSC activation procedure lacked a policy statement on eating,
-
drinking, smoking, and chewint,.
(498/8635-036; 499/8635-036)
Procedures for assembly areas were not consistent with the Plan and were
-
incomplete.
(498/8635-037; 499/8635-037)
A specific procedure had not been provided to implement and control the
-
decontamination of vehicles used offsite during an emergency.
(498/8635-038; 499/8635-038)
HL&P had not designated the type, number, and location of protective
-
clothing units in an inventory procedure for each facility and emergency
kit, including the control room.
(498/8635-039; 499/8635-039)
No procedure had been provided to govern the required testing of the
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emergency communications system and provide for periodic updating of the
offsite emergency response organization telephone numbers.
(498/8635-040;
499/8635-040)
$
No procedures had been provided to control the use of vehicles designated
-
~for use during an emergency.
(498/8635-041; 499/8635-641)
The Emergency Response Roster required by paragraph 4.1.1 of EPIP
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OEPP01-2A-0004 had not been issued.
(498/8635-042; 499/8635-042)
The: instructions for notification of the NRC in an emergency were not
-
consistent with the requirements of 10 CFR 50.72(a)(3).
(498/8635-043;
499/8635-043)
The implementing procedures for the prompt public notification system were
-
incomplete.
(498/8635-044; 499/8635-044)
The pager system indicated in OEPP01-ZA-0004 had not been completed,
-
including the duty roster and pager distribution.
(498/8635-045;
499/8635-045)
-
The installation and testing of the protected area personnel notification
system was incomplete, and training and verification that the system could
be heard by all onsite personnel had not been conducted.
(498/8635-046;
499/8635-046)
An emergency response personnel call-out system, including a call-out
-
directory for all emergency response personnel down to the working level,
had not been developed.
(498/8635-047; 499/8635-047)
The licensee's primary method of performing offsite dose calculations
-
(RM-21A) was not operational, thus the assessment procedure OEPP01-ZA-0008,
Revision 0, had not been tested.
(498/8635-048; 499/8635-048)
-
The licensee had no approved procedure for performing backup dose
calculations using the IRDAM code.
(498/8635-049; 499/8635-049)
,
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Provisions for activation of the E0C were not consistent in describing
'
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when the E0C was required to be activated.
(498/8635-050; 499/8635-050)
Inconsistencies were noted in the normal and emergency response
-
organization, and the assignment of station management responsibilities,
,
as-described in various sections of the Plan.
(498/8635-051;
499/8635-051).
,
-l Procedures had not been provided to govern offsite radiological monitoring
--
activities, including personnel protection measures.
(498/8635-052;
- 499/8635-052)
Procedures had not been provided to govern onsite, out-of plant
.
radiological monitoring activities.
(498/8635-053; 499/8635-053)
-
Procedures had not been developed to verify and maintain the facility
public address system such that all personnel within the owner controlled
area can be given warning and verbal instructions in an emergency.
(498/8635-054; 499/8635-054)
Provisions had not been made for notification and evacuation of the owner
-
controlled area (including Unit 2 and the reservoir area).
(498/8635-055;
499/8635-055)
-
The installation, testing, and implementation of the security access and
accountability system, which would be employed in an emergency, had not
been completed.
(498/8635-056; 499/8635-056)
Procedures for personnel monitoring and decontamination were not adequate
-
to address emergency needs outside of the normal radiological controlled
area.
(498/8635-057; 499/8635-057)
'
The licensee had no plans or dedicated equipment for personnel mon
' .g
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at assembly / reassembly areas.
(498/8635-058; 499/8635-058)
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Procedures had not been developed to support response to a raciological
emergency and govern radiological protection for the security force in an
emergency.
(498/8635-059; 499/8635-059)
-
Procedures had not been provided that describe the concept of operations
for damage control / repair or corrective action activities.
(498/8635-060;
499/8635-060)
-
The provisions for and implementing procedures did not adequately address
recovery and reentry.
(498/8635-061; 499/8635-061)
-
Individual news media, including name and address, to be contacted by the
.
commercial news v; ire service selected to disseminate the news releases,
l
and the name of a principal contact were not provided.
(498/8635-062;
499/8635-062)
-
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-The method for coordinating internal dissemination of news information had
-
not been clearly specified.
(498/8635-063; 499/8635-063)
An alternate principal HL&P spokesperson had not been identified.
-
(498/8635-064; 499/8635-064)
The procedure governing inventory, operational check and calibration of
-
emergency equipment was not adequate to assure that emergency
instrumentation would be available and functional.
(498/8635-065;
499/8635-065)
The emergen'cy equip $ent inventory lists did not include onsite and offsite
-
monitoring kits, and did not include necessary equipment and supplies.
(498/8635-066; 499/8635-066)
Procedures had not been provided for Plan change review and submittal to
-
the NRC to meet the requirements of 10 CFR 50.54(q).
(498/8635-067;
499/8635-067)
'
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Procedures had not been provided to describe how the 12-month independent
review and audit of the emergency preparedness program would be conducted.
(498/8635-068; 499/8635-068)
-
The Operations Quality Assurance Department was not independent of
implementation of the emergency preparedness program as the manager was a
member of PORC, which reviewed and recommended approval of the Plan and
procedures.
(498/8635-069; 499/8635-069)
6.0 Coordination With Offsite Groups
-
Fire department personnel had not been provided sufficient information and
training to enable them to provide the emergency support described in the
Plan.
(498/8635-070; 499/8635-070)
1
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Training and drills for offsite response and support agencies (excluding
medical) and necessary equipment and supplies for offsite agencies had not
,
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been completed.
(498/8635-071; 499/8635-071)
The public information for transients had not been distributed within the
-
10-mile EPZ.
(498/8635-072; 499/8635-072)
,
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7. 0 Drills, Exercises, and Walkthroughs
A formal system had not been developed to implement and control the drills
-
and exercises program.
(498/8635-073; 499/8635-073)
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The operations crew walkthrough and drill identified problems in timely
l
notification of offsite agencies, errors in emergency classification, and
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unfamiliarity with nondelegatable responsibilities of the Emergency
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Director (ED).
(498/8635-074; 499/8635-074)
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The number of onshift control room communicators. appeared to be inadequate
-
and training for the communicators was incomplete.
(498/8635-075;
499/8635-075)
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APPENDIX B
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's inspection of the South Texas Project
emergency preparedness program conducted December 1-12, 1986, the NRC
inspectors observed several areas in which improvement could be effected to
achieve a more effective program.
The following are observations the NRC inspectors called to the licensee's
attention.
These observations are neither violations nor unresolved items.
These items are recommended for licensee consideration for improvement, but
have no specific regulatory requirement.
1.0 Administration
Provide an administrative mechanism for direct interface between the
-
emergency preparedness staff and other HL&P departments on changes to
organization, personnel, procedures, and equipment.
2.0 Emergency Organization - None
3.0 Training
-
A lesson plan for offsite training should be prepared and controlled
similar to the onsite training plans.
A formal record keeping system should be established for control of
-
offsite training and retraining.
Provisions should be made in procedures for special retraining to
-
accommodate significant changes in the emergency preparedness program.
Emergency plan training modules should provide for hands-on and
-
walkthrough training utilizing emergency response facilities and
equipment.
-
Internal audits of the training records and record system should be
conducted periodically to assure consistency in identifying discrepancies.
-
Emergency plan trainers should be credited on their training records for
emergency plan training they teach.
Followup interviews with training participants should be conducted to
-
check training effectiveness in accordance with 10 CFR 50, Appendix E,
paragraph IV.F.5.
All working copies of emergency plans and implementing procedures should
-
be provided with tabs to make use faster and more effective.
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4.0 Emergency Facilities and Equipment
-
Measures should be taken to mitigate the potential safety hazard
represented in the TSC by the floor mounted, raised 120 VAC and telephone
receptacles.
-
Remote indication of the HVAC system lineup should be made available in
the TSC.
'
The external threat represented by the nearby chemical plants should be
-
clearly defined.
-
Provisior.. should be made and included in procedures for relocation of the
OSC.
' Responsibility for habitability monitoring should be assigned in the OSC
-
activation procedure.
-
Procedure OEPP07-DZ-0001 should define the emergency diesel testing
frequency and notification of the Manager, Support Division if the diesel
will be out of service.
~
Procedures should be developed for radiological control, radiological
-
monitoring of personnel, and radiological monitoring equipment for survey
of emergency response personnel arriving at the E0C.
Procedures should be developed for manual activation of the E0C HVAC
-
emergency filter mode.
Damper positions should be labeled (normal / emergency operating position)
-
and controls and control panel identified in the EOC HVAC room.
-
The Plan should be revised to describe the E0C filter system actually
installed.
The need for shielding post-accident liquid effluent sampling lines to the
-
liquid effluent sample station should be evaluated and provided if
indicated.
-
Reconcile the differences between the Plan and procedure OEPP01-ZA-0007
relative to assembly areas, and provide the data required in addendum 3 of
this procedure.
Consideration should be given to administration of KI to station emergency
-
workers that request the thyroid blocking agent while performing emergency
duties.
STP procedures should be developed for maintaining the State of Texas KI
-
stock.
'
[
3
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Self-Contained Breathing Apparatus (SCBA) bottle refill capability should
be addressed in the Plan and implementing procedures.
-
Respirator protection for control room staff in an emergency should be
addressed in the Plan and implementing procedures.
Provisions for respiratory protection for offsite radiological field teams
-
should be made.
-
A communications specidlist or technician should be included in the STP
emergency response organization.
-
A procedure should be provided to govern the required testing of the
emergency communications system.
A procedure should be provided for the periodic updating of the offsite
-
emergency response personnel telephone numbers.
Implement mutual assistance plans with other nuclear power utilities with
-
the goal of ensuring a supply of compatible equipment and instrumentation.
Establish minimum levels of emergency equipment and instruments to be
-
maintained onsite.
Emergency vehicles to be provided by offsite support agencies should be
-
defined.
The feasibility of using an open bed, non 4-wheel drive vehicle for field
-
monitoring teams should be reevaluated.
A survey should be conducted to determine if portable hand-held radios are
-
satisfactory for communications with and between field monitoring teams.
5.0 Procedures
-
Provide and employ a standard format for emergency plan implementing
procedures.
Generate a matrix of all Plan elements which require implementation and
-
the procedures written to implement those elements to identify areas which
have not been addressed by implementing procedures.
Paragraph 4.1 of EPIP OEPP01-ZA-0009 should include considerations of dose
-
projections in determination of emergency classification.
A new paragraph should be added to EPIP OEPP01-ZA-0009 which states, in
-
effect, that notification to the NRC shall be made immediately after state
and local notification and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
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4
Separate.EPIPs should be issued for each of the four emergency
--
classifications, Notice of Unusual Event (N0VE) through General
Emergency (GE).
- 4
' Consideration should be given to limiting the NOVE call-out list to the
plant manager or duty plant manager.
Additional personnel may be notified
,
- on an as needed basis.
i
The siren located near the reservoir area should be included in the
-
?
notification procedure.
Reconcile inconsistencies in the normal and emergency organization, and
-
the assignment of station management responsibility described in the Plan
and implemented in the EPIPs.
Reconcile differences in describing STP plans for when EOC activation is
-
required in the Plan and EPIPs.
Consider assigning the plant manager or plant superintendent as TSC
-
director whey they are not required to function as Emergency Director.
Clarify the fire brigade composition inconsistency between
-
Procedures OPGP03-ZF-0001 and OPGP03-ZF-0011.
Complete paragraph 3.1.3 of
Procedure OPGP03-ZR-0001.
The manual dose calculation procedure, OEPP01-ZA-0008, Revision 0, should
-
be edited or upgraded to include human engineering factors.
Markers for the primary and secondary evacuation routes should be
-
provided.
Provisions for security officers to give verbal instructions from their
-
vehicles to personnel in trailers and buildings should be developed.
The " Accountability / Evacuation" procedure should address how
-
accountability would be maintained throughout the duration of the
emergency in the control room, OSC, TSC, and Unit 2 construction area.
A drill should be conducted verifying that personnel accountability, which
-
includes identification of all personnel in the protected area, could be
accomplished within 30 minutes and missing persons found within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Procedure OPRP08-ZC-0002, Revision 2, " Personnel Decontamination," should
-
specify a level for personnel contamination and reference a definition of
personnel contamination.
In the emergency equipment procedure, corrective actions to be taken when
-
an instrument either fails an operational check or a battery check should
be specified.
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The Emergency Equipment procedure should require an instrument response
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check in addition to a battery check.
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Inventory lists in the Emergency Equipment procedure should be written to
insure that replacement instruments do not provide a lesser detection,
measurement, or sampling capability.
Emergency Equipment inventory lists should include both onsite and offsite
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monitoring kits or emergency equipment stored in the control room and
Wagner General Hospital.
Emergency equipment lists should be reviewed and revised to include all
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necessary equipment and supplies.
The document control procedure should be revised to strengthen the action
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taken in regard to delinquent responders to the document control receipt,
in agreement with the Plan.
A controlled document distribution list should be developed for sending
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appropriate documents to agencies outside of HP&L.
Letters transmitting Plan and procedures to the NRC would include a
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statement documenting the 10 CFR 50.54(q) review concucted, and status
concerning the results of the review.
The Vice President, Nuclear should be identified as a recipient of a copy
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of the 12-months program review and the annual audit report.
Results of the 12-months review related to offsite agencies should be sent
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to the agencies and corrective actions required identified.
6.0 Coordination With Offsite Groups
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Include exchange of emergency plans in coordination efforts between STP
and the offsite agencies that could be called on to provide support during
an emergency.
Review the emergency plans for offsite agencies to a,sure that the plans,
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including telephone numbers and verification methods, are consistent with
the STP Plan.
The Matagorda County, Bay City, and Palacios Emergency Management Plan and
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the STP Plan should be distributed to the appropriate offsite response
agencies.
Procedures for specific activities should be distributed to
those personnel who would provide support in a particular functional area;
i.e. , county public notification procedures to the EBS radio station that
provides emergency instructions to the public.
Provide a rumor control number to be inserted in the calendar-brochure.
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7.0 Drills, Exercises, and Walkthroughs - None