ML20212M669
| ML20212M669 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/19/1986 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Williams J TOLEDO EDISON CO. |
| References | |
| NUDOCS 8608260445 | |
| Download: ML20212M669 (2) | |
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AUG 191986 Docket No. 50-346 Toledo Edison Company ATTN: Mr. Joe Williams, Jr.
Vice President Nuclear Edison Plaza 300 Madison Avenue.
Toledo, OH 43652 Gentlemen:
Enclosed is a memorandum dated July 23, 1986, from the Federal Emergency
, Management Agency to the NRC discussing offsite radiological emergency preparedness for the Davis-Besse Nuclear Power Station. This memorandum outlines time commitments that have been established to complete specified.
tasks. We fully recognize that the tasks to be implemented may involve actions by other parties and political institutions which are not under your direct control. Nonetheless, we would expect the subject of offsite preparedness for the area around the Davis-Besse Nuclear Power Station to be addressed by you as well as others.
We also request that you keep us informed of progress that is made toward the completion of the various commitments outlined in the July 23 memorandum and the Memorandum of Understanding dated July 16, 1986, and signed by representatives of Lucas County, Jerusalem Township, Ohio Disaster Services Agency and Toledo Edison Company. In addition, we would like to meet with you to discuss the progress on the above issues as an adjunct to our inspection to observe the September 23, 1986 exercise.
Please contact Mr. William Snell (312/790-5513) or Mr. Tom Ploski (312/790-5529) of my staff if you have any questions and/or to keep us informed of the status of completing the commitments.
Sincerely, W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch
Enclosure:
As stated
,See Attached Distribution
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Toledo Edison Company 2 Distribution cc w/ enclosure:
L. Storz, Plant Manager DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Harold W. Kohn, Ohio EPA James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health cc w/o enclosure:
D. Matthews, OIE, EPB
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[ Federal Emergency Management Agency Washington, D.C. 20472 JUL 2 31986
.m ME!ORANDlM FOR: Biward L. Jordan ..
Director > UI Division of Dnergency Preparedness and Engineering Response h$g . Q Office cf Inspection aM Enforcenent ~ h ' .ih #
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FR]M: E .Kr'fa:m::;;1+J Assistant Associate Director Office cf Natural and Technological Hazards Programs SUBJECr: Offsite Radiological Energency Preparedness for the Davis-Besse Nuclear Power Station In February 1981, the Ohio Plan for Response to Radiation Bnergencies at Licensed Nuclear Facilities, site--specific to the Davis-Besse Nuclear Power Station (NPS), was submitted to the Federal Bnergency Management Agency (FEMA) Region V for review and evaluation in accordance with FEMA's rule 44 CPR 350. A raliological emergency preparedness (REP) plan for Lucas County had not been included in the State's submission. During the Region V review process it was concluded that a separate Lucas County plan was required. In the absence of this part of the required Ohio plan, the Ohio Disaster Services Agency (ODSA) was notified that further processirg of the State's submission was being placed on hold pendirg submittal of a Lucas County REP plan. On February 13, 1985, FEMA Region V notified ODSA of the need to either submit a Lucas County REP plan to FEMA by March 15,1985, or submit alternative solutions.
On April 30, 1985, ODSA provided FEMA Region V with the Toledo Edison proposal to redefine the 10-mile plume energency planniru zone (EPZ) around the Davis-Besse NPS. Ohio reccmnended approval of the proposal which, in aldition to eliminating a portion of Dicas County within the 10-mile EPZ, would have also eliminated that part of the City of Port Clinton (Ottawa County) previously included in the original planning effort. It is noted that the permanent population of the affected area of Lucas County is approximately 900 persons. However, the transient popula-tion during late Spri'y and Stmner at the Federal and State parks within the Lucas County EPZ is estimated to average between 2,000-3,000 pecple, with peaks of nearly 14,000. As inclicated elsewhere in this memorandum arri the attachments, considerable discud31on and effort has especiallly been devoted to resolving Lucas County planning issues. The State, of course, as well as the Nuclear Regulatory _Ccmnission (NRC) Region III arti Toledo Edison were of ten directly involved in the various activities associated with the EPZ and planniry issues. For exanple, the attached June 7,1983, NRC Region III letter announced a meetirg "...to discuss and resolve concerns raised by Lucas County regarding energency preparedness AUG 6 1986 bb
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B607240280 860723 ADOCK 05000346 IEE
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e around the Davis-Besse Station." Photocopies of the slides used at that meeting identifying issues and the chronology of key events up to that time are also attached. In addition, I have attached a copy of Toledo Edison's April 2,1984, letter and proposed agenda for a meeting held on April 11,1984, to. discuss Davis-Besse planning issues.
FEMA Headquarters and Regional stcff reviewed the State's proposal and supporting documentation to redefine the 10-mile EPZ and determined that it was not acceptable as subnitted. In letters to Ohio Governor Celeste and ODSA on December 9, 1985, (copies of which were provided to you as attachments with my December 13, 1985, menorandum transmitting the exer-cise report of the July 16, 1985, REP exercise for the Divis-Besse NPS) we identified the specific reasons why we found the proposal to redefine the 10-mile EPZ unacceptable.
On February 4,1986, ODSA submitted a detailed response to our letter of December 9, 1985. ODSA specified the actions taken or pro [xmed to resolve the outstanding Davis-Besse EPZ issues. Following our review and analysis of the State's response, we provided ODSA with our determination on March 19, 1986, and identified the remaining information the State would be re-quired to provide. ODSA was given an additional 120 days frcm the March 19 date to resolve the remaining outstanding issues. A copy of our March 19 letter is attached for your information.
On May 12, 1986, ODSA responded and subnitted a proposed schedule to resolve the various issues. In essence, the proposal as then submitted by ODSA would have prolonged resolution of the outstanding issues until the Sunner of 1987. (We had specified that all issues should be resolved no later than December 1986.) Following the State's letter of May 12, Toledo Edison requested a meeting with representatives frcn the NRC and FEMA regional offices and the State. 'Ihe meeting was held in ' Chicago on May 20, 1986.
Since that time, a number of activities have occurred culminatirg in the recent correspondence dated July 8,1986, (copy attached) frun ODSA identifying additional actions taken or proposed to resolve the outstand-ing issues. Included with the July 8 letter was an attachment identifying milestones and completion dates including the following: (1) September 3, 1986-Lucas County REP plan submitted by Lucas County Conmissioners for State review; (2) September 23,1986-key players from Lucas County, Ottawa County and ODSA denonstrating certain emergency response functions in conjunction with a utility-only exercise conducted for the Davis-Besso NPS; (3) December 30,1986--subnission of a Lucas County REP plan, and tuvisions to the Ottawa County and State of Ohio plans to FEMA Region V for review under 44 CFR 350; (4) March 31,1987-an exercise involving full participation by Lucas County; and, (5) April 30,1987- a public meeting in accordance with FEMA regulations.
Most recently, on July 16, 1986, we received a copy of the attached undated Munorandtra of Understanding (MOU) signed by representatives of Incas County, Jerusalem Township, ODSA and the Toledo Edison Conpany. As the MOU indicates, the parties agree to complete certain activities prior to the Davis-Besse NPS planned startmp in October 1986, as well as to interim measures which will remain in effect until the final approved Lucas County REP plan and facilities are in place.
While planning is inconplete, we believe the State and local governments have in recent months put forth a good faith effort in resolving the outstanding
-REP issues around Davis-Besse as indicated by the agreed to interim measures and the ominitment by the parties to conplete specific actions by specified dates. I would like to point out that the consnitment to conduct the exer-cise in March 1987, (instead of June, as previously scheduled) should enable FEMA to assess the capability of Incas County to inplement its REP plan prior to the beginning of the surener season. It should be noted that FEMA has provided NRC with past REP exercise reports. The exercises were conducted on November 6, 1980, April 13, 1983, and July 16, 1985. The exercise re-ports were transmitted to you on March 30, 1982, May 4, 1984, and December 13, 1985, respectively.-
The regional ~ staff will continue to work with Ohio on the interim measures and steps for formal approval of the State's sitempecific plans. In this regard, we are returning the previously submitted FEMA Regional Director's Evaluation to FEMA Region V. Following the cmpletion of necessary plan modifications, exercise activity and a public meeting, we anticipate that FEMA will have sufficient information to proceed with an evaluation of the Ohio's plans under 44 CFR 350. However, should the State and local goverments fail to carry out its connitnents within the time frames specified,-we will return the site-specific plans in accordanco with our regulations.
FEMA will continue to monitor progress concerning the interim measures and the meeting of formal requirenents for offsito safety. We plan to provide you with status updates following the planned drill in September and the March 1987 offsite REP exercise.
Due to NRC's current review of onsite issues and your; overall responsibility for determining the adequacy of emergency planning and preparedness, please advise FEMA in writing if this information is sufficient for your delibera-tions'and if you desire that FEMA take any other actions at this time.
Attachments As Stated
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UNITED STATES 8 NUCLEAR REGULATORY COMMISSION
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7es noosEVELT ROAD GLEN ELLYN,ILLINots 50137
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June 7,1983 Mr. James R. Williams State Liaison Officer 2825 W. Granville Road Worthington, OH 43085
Dear Jim:
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On June 24, 1983, NRC Region III and FEMA Region V wiLL meet with representatives of th'e Toledo Edison Company to discuss and resolve concerns raised by Lucas County regarding emergency preparedness around the Davis-Besse Station.
You are invited to participate in this meeting which will commence at 11 a.m. in the Administration Building at Davis-Besse.
Please let me know of your plans to attend as your participation is central to the resolution of these issues.
S~ncerely,
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William B. Menczer, Directo State and Government Affairs cc: Judy Hirsch, ',
Toledo Edison Co.
t Deffiel Bement, FEMA V f:-
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TOLEDO EDIS0N COMPANY - EMERGENCY PLANNING LUCAS COUNTY - KEY CHARACTERISTICS 0 APPROXIMATELY 6 SQUARE MILES, OR 1.7% OF LUCAS COUNTY IS CONTAINED IN THE DAVIS-BESSE 10 MILE EPZ.
0 766 PERMANENT RESIDENTS - PRIMARILY LOCATED IN SECTOR P, BETWEEN 9 AND 10 MILES FROM DAVIS-BESSE -- REPRESENTS- 0.2%
OF THE PERMANENT LUCAS COUNTY POPULATION, O 6241 TRANSIENT POPULATION - PRIMARILY RECREATIONAL BOATING, SOME CAMPING AND COTTAGES - SUMMER ONLY. hT A V ' S O PI*
O IN ACCORDANCE WITH THE 0TTAWA COUNTY EMERGENCY RESPONSE PLAN AND THE PROPOSED LUCAS COUNTY PLAN, LUCAS COUNTY DOES NOT PROVIDE EMERGENCY RECEPTION CENTERS FOR OTTAWA COUNTY EVACUEES.
O EMERGENCY RECEPTION CENTER FOR LUCAS COUNTY RESIDENTS IS THE CLAY HIGH SCHOOL IN OREGON, APPROXIMATELY 6 MILES FROM AFFECTED EPZ AREA.
r 0 LUCAS COUNTY EOC IS LOCATED IN TOLEDO, APPROXIMATELY 12 MILES FROM THE SECTOR OF LUCAS COUNTY CONTAINED IN THE 10 MILE EPZ.
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't TOLED0 EDIS0N COMPANY - EMERGENCY PLANNING LUCAS COUNTY - CHRON0 LOGY OF KEY EVENTS OCT. 2, 1981 -
LUCAS COUNTY LETTER TO OHIO DSA QUESTIONING THE ADEO.UACY OF PROMPT NOTIFICATION SYSTEM (PNS) AND.
THE EXISTING RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR LUCAS COUNTY.
OCT. 23, 1981 -
OHIO DSA RESPONSE TO OCTOBER 2 LETTER. EXPLAINED TOLEDO EDISON ACTIVITIES REGARDING REVIEW OF
- PNS ADEOUACY. INDICATED THAT FEMA - REGION V INFORMALLY REVIEWED / APPROVED STATE PLAN PLUS LUCAS COUNTY APPENDIX. >
IlEC 31, 1981 -
LUCAS COUNTY LETTER TO TOLEDO EDISON RAISING CONCERN REGARDING PROMPT NOTIFICATION SYSTEM IN LUCAS COUNTY.
JAN. 1982 - TOLEDO EDISON INSTALLS 38 NEW SIRENS, INCLUDING 2 SIRENS IN LUCAS COUNTY.
JAN. 8, 1982 -
TOLEDO EDISON LETTER TO LUCAS COUNTY INDICATING I NEW PROMPT NOTIFICATION SYSTEM ANALYSIS RESULTS AND DESIRE FOR CONTINUATION OF " EXCELLENT WORK-ING RELATIONSHIP".
JUNE 29, 1932 -
FEMA - REGION V LETTER TO OH10 DSA RAISING CONCERN ABOUT THE LACK OF A STAND-ALONE LUCAS COUNTY DLAN. FEMA WILL HOLD ON REVIEW OF THE DAVIS-BESSE OFFSITE EMERGENCY PREPAREDNESS UNTIL A SPECIFIC PLAN FOR LUCAS COUNTY IS l PREPARED.
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LUCAS COUNTY - CHRON0LOCY OF KEY EVENTS CONTINUED JULY 12, 1982 -
LUCAS COUNTY, IOLEDO EDISON, OTTAWA COUNTY AND OHIO DSA MEETING AT DAVIS-BESSE - LUCAS
- COUNTY AND OHIO DSA SEE NO PROBLEMS WITH TOLEDO EDISON HIRING A CONSULTANT TO PREPARE I THE LUCAS COUNTY PLAN.
JULY 15, 1982 -
TOLEDO EDISON ISSUES PURCHASE ORDER REQUISITION TO EDS NUCLEAR TO PREPARE LUCAS COUNTY EMERGENCY RESPONSE PLAN.
SEP. 22, 1982 -
EDS COMMENCES WORK ON PREPARING LUCAS COUNTY EMERGENCY PLAN- PLANNING MEETING HELD AT DAVIS-BESSE WITH LUCAS COUNTY, OTTAWA COUNTY, OHIO DSA, AND TOLEDO EDISON REPRESENTATIVES.
I DEC. 15, 1982 -
EDS SUBMITS DRAFT PLAN TO LUCAS COUNTY.
JAN. 7, 1983 -
LUCAS COUNTY LETTER TO TOLEDO EDISON -
! ACKNOWLEDGING PLAN AS AN " EXCELLENT JOB",
- IDENTIFYING POSSIBLE PROBLEMS WITH THE COSTS FOR IMPLEMENTING THE PLAN.
JAN. 24, 1983 -
EDS TRANSMITS REVISED PLAN CONTAINING CHANGES REOUESTED BY LUCAS COUNTY DSA.
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LUCAS COUNTY - CHRON0 LOGY OF KEY EVENTS CONTINUED PEE. 10, 1983 -
FEMA - REGION V LETTER TO OHIO DSA REQUESTING SUBMISSION OF LUCAS COUNTY PLAN BY FEB. 18.
NO PROCESSING OF REGIONAL DIRECTORS EVALUATION OF DAVIS-BESSE WILL OCCUR UNTIL THE PLAN IS DEVELOPF.D AND EXERCISED. FEMA SUGGESTS DELAYING 1983 EXERCISE IF PLAN IS NOT. SUBMITTED.
FEB 18, 1983 -
TOLEDO EDISON LETTER TO LUCAS C0bNTY DISCUSSING THE AVAILABLE SUPPORT POSSIBILITIES TO LUCAS COUNTY - INCLUDED TAX DOLLARS, EDS ACTIVITIES, FEDERAL COST SHARING.
FEB. 25, 1983 -
LUCAS COUNTY LETTER TO TOLEDO EDISON REOUESTING EMERGENCY PLANNING SUPPORT FROM TOLEDO EDISON IN LIEU OF THAT REFERRED TO IN THE CEB. 18 LETTER.
MAR. 30, 1983 -
OHIO DSA LETTER TO LUCAS COUNTY INDICATING THAT LUCAS COUNTY WILL NOT BE EVALUATED AS PART OF THE 1983 EXERCISE. DISCUSSED POSSIBILITY OF A REDUCED EPZ.
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TOLEDO EDIS0N COMPANY - EMERGENCY PLANNINC-LUCAS COUNTY - EXISTING SITUATION O ADOPTED STATE RADIOLOGICAL EMERGENCY RESPONSE PLAN -
INCLUDES LUCAS COUNTY AS APPENDIX TO OTTAWA COUNTY PLAN.
O COUNTY SPECIFIC RADIOLOGICAL EMERGENCY RESPONSE PLAN HAS BEEN PREPARED BY CONSULTANTS RETAINED BY TOLEDO EDISCN
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WORKING CLOSELY WITH LUCAS COUNTY PERSONNEL.
0 ALL SUBMITTED COMMENTS FROM LUCAS COUNTY HAVE BEEN INCORPORATED INTO COUNTY SPECIFIC PLAN.
O LUCAS COUNTY SPECIFIC PLAN CURRENTLY NOT APPROVED BY COMMISSIONERS - PROBLEM RELATED TO COST REIMBURSEMENT FOR LUCAS COUNTY PERSONNEL TIME AND EXPENSES AND COSTS FOR JERUSALEM TOWNSHIP " DECONTAMINATION CENTER".
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. TOLEDO EDISON COMPANY - EMERGENCY. PLANNING LUCAS COUNTY - TOLEDO EDISON POSITION O EXISTING EMERGENCY PREPAREDNESS AROUND THE DAVIS-BESSE NUCLEAR POWER STATION ADEQUATELY ASSURES THE PROTECTION I 0F PUBLIC HEALTH AND SAFETY OF LUCAS COUNTY RESIDENTS EVEN ASSUMING THE HIGHLY IMPROBABLE EVENT THAT RADIATION ,
IS RELEASED FROM THE DAVIS-BESSE PLANT. -
1 RADIOLOGICAL EMERGENCY RESPONSE PLANS EXIST TO PROTECT THE PUBLIC IN LUCAS COUNTY.
-STATE OF OHIO RADIOLOGICAL EMERGENCY RESPONSE PLAN 4
ASSURES STATE SUPPORT TO THE COUNTY IF REQUIRED.
EXISTING SOURCE-TERM ASSUMPTIONS CREATES A CONSERV-ATIVELY LARGE EPZ, WHICH IS THE ONLY REASON THAT 1
, LUCAS COUNTY IS ACTUALLY IN THE DAVIS-BESSE EMERGENCY PLANNING ZONE.
t O TOLEDO EDISON WOULD REIMBURSE LuCAS COUNTY FOR:
ACTUAL PERSONNEL COSTS ASSOCIATED WITH DAVIS-BESSE
] RELATED RADIOLOGICAL EMERGENCY TRAINING FOR DISASTER SERVICES PERSONNEL.
1 ACTUAL PERSONNEL COSTS AND ASSOCIATED EXPENSES FOR PERMANENT EMPLOYEES IN LUCAS COUNTY DEPARTMENTS, OTHER THAN DISASTER SERVICES, INCURRED AS A RESULT OF DAVIS-l BESSE R' ELATED RADIOLOGICAL EMERGENCY RESPONSE TRAINING, DRILL / EXERCISE PARTICIPATION AND ASSOCIATED PREPARATION J
- AND CRITIOUES.
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2 TOLEDO EDISON SEES NO NEED TO FUND A NEW DECONTAMINATION BD
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8 April 2, 1984 Totuoo EDISON A84-194H EPL #84-009
. E 1.30.2 E 1.33.3 Mr. Wallace Weaver, RAC Chairman -
Federal Emergency Management Agency Region V One Norch
Dearborn Street,
Room $40 Chicago, Illinois 60602 Daar Mr. Weaver:
In accordance with our recent telephone conversation, I would like to confirm that Toledo Edison representatives plan to meet with you, other Federal Emergency Management Agency (FEMA) representatives, and Nuclear Regulatory Commission (NRC) personnel at the FEMA Region V offices in Battle Creek,. Michigan, on Wednesday, April 11, 1984, at 1:30 P. M. The personnel representing Toledo Ediscn that will attend the meeting include:
Ted J. Myers - Director, Nuclear Services - Toledo Edison Judith Hirsch - Emergency Planning Supervisor - Toledo Edison Thomaa Kevern - Operations Director - NUTECH Engineers Marvin Fartel - Vice President - Delian Corporation Toledo Edison feels there are actions that can be supported to resolve the acceptance of the State of Ohio Radiological Emergency Response Plan.
From our perspective, to aid in that goal, we would like this meeting to accomplish the fo.11 ewing ob,jectives:
- 1. Clarify the current status of the State of Ohio Radiological Emer-r gency Response Plan, including clarification of the background leading up to the current status.
- 2. Present the current status of Toledo
- Edison activities towards finalizing the Davis-Besse Emergency Planning Zone (EPZ) and re-solving the concerns on the part of TEMA in regards to Lucas County.
- 3. Identify the follow up actions and associated organizational responsi-l bilities required to finalire the Davis-Besse EPZ and, therefore, obtain approval from FEMA of the State of Ohio Radiological Emergency Response Plan.
Given these stated objec:1ves, we would like to propose a meeting agenda as presented on Attachment A. As you will note from the agenda, we have identified the basic information that we would like discussed for each item. With regard to the information we are requesting from FEMA, we have l
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EPL #84-009 April 2,1984 Fage 2 specified a series of statements that would provide that information as part of agenda item I.
I trust this letter and the attached agenda are responsive to your needs.
If you desire additional information from us relative to the material on the agenda, or if you have any questions concerning the information being requested from FDIA, please don't hesitate to contact me.
Sincerely, udith Ritsch Emergency Planning Supervisor JR:MSF nif encl.
cct T. J. Myers Monte Phillips, NRC Rolland Lickus, NRC Thomas Kevern, NUTECH Harvin Fortel Delian l
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EPL #84-009 April 2. 1984 Page 3 Attachment A l
FR0 POSED ACENDA April 11. 1984 Meetina i Federal Emerteney Manasement Aaency/Niiclear Regulatory i Commission / Toledo Edison Company
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I. Clerification of status of State of Ohio Ra_diolonical Emermency Response Plan - FEMA
- Results of the RAC review
- Formal correspondence asisting between FEMA Region V - State of Ohio F* ' ,vicn III. FEMA National regarding the State Plar.
- Results and recipients of reviews of the State Plan performed by Region V
- - Results and recipients of reviews of the State Plan performed by
- FEMA - National -
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Current status of FEMA's review of the Stata Plan 5
- Issues preventing the completion of the review and approval of the State Plan by FEMA - Region V and TEMA - National
- FEMA's position (s) regarding the Lucas County 1seums and baain for those positions II. Discussion of T*m Activitie_a_ Since the June Meetina with FEMA and the NRC and tus State of Ohio - Toledo Edison
- 1. Background Chronology Leading up to the June Meeting
- 2. Activities Subsequent to the Heating
- Regulatory Review of Davis-lesse EPZ Compliance and ,
Emergency Planning review to finalise EPZ boundaries III. Identification of Follow Up Activities
- Actions required
- Responsible parties: TED FEMA. NRC
- Schedule .
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D .:'?.T C H i J MAR 1 S 1986 Pk . Richard M. Iockhart " ' -' "i. 3 l.,a Adjutant General's Department
. Pli 2. Sti Deputy Director ',.,...,I,.,
Ohio Disaster Services Agency C "F
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2825 West Granville Road it>rthington, Ohio 43624 r
Dear Mr. tockhart:
Dank you for your letter of February 4,1986, with supporting doctsnentation, concernirq the proposed resolutions for the pltre exposure pathway emerge.r*
planning zone (EPZ) for the Davis-Besse Nuclear Pbwer Station (NPS). Speci-fically, your correspondence addressed the five areas of concern identified in our letter of Decenber 9,1985, concerning the State's April 30, 1985, proposal to change the pltane EPZ.
He appreciate the positive, thorough and timely manner of your response, and the cooperation of local officials.
FDIA's resnonse to the actions taken or proposed by the Ohio Disaster Services Agery:y (OIEA) for each of the five geographical areas affected by the 10-mile Davis-Besse EPZ as' contained in the "EPZ Realigrrnent Prc.posal Follow-Up Renort" submitted on February 4, 19R6, is outlined belcW. A more detailed review of the issues by FDtA Reaion V is attached.
(1) City of Port Clinton--FEMA had determined that the entire oeogra-phic area of the city had to be incitried in the plume EPZ, or an acceptable justification for excluding all or part of the city submitted.
t ODSA Resnortse f- De city has repealed its earlier resolution reeviry itself frcm the EPZ and has entered into a memorandtsu of understanding (POU) with the Toledo Edison Conpany. De MOU identifles assistance to be provided to the city to ensure adequate planning and preparedness.
Port Clinton's planning requirenents will be included in the Ottawa County Radiological Dnergency Preparedness (REP) plan in accordance with FEMA regulations and NUREG-0654 guidance. H e city agrees to
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participate in exercises, drills and training as appropriate.
FEMA Decision he actions taken and those proposed are appropriate. It should be noted, however, that the Ottawa County plan revision nust be sttrnitted to PEMA Ibgion V within 120 days of the date of this letter. (Note: See also requirenant for a public neeting on page 4.)
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(2) Ottawa County (exclusive of the City of Port Clinton)--FD4A had
[ determined that more justification was needed for genpolitical boun-g dary changes.
1 00SA Fesponse Ottawa County has proposed three major changes to the E'PZ affecting Benton Township, Harris Township and the City of Port Clinton.
' Justification for the changes has been provided. It is noted that I additional sirens will be required to ensure conclete coverage of I the areas added to the EPZ. The utility has agreed to prcvide the -
sirens needed for full coveraqe. A small portion of Harris Township containirq 15 permanent households and a small camnaround used
! primarily by migrant workers has been recorrnended for exclusion.
Should protective actions be necessary for this area, notification would be through sirens and door-to-door verification.
i FD1A Decision
' 'Ihe proposed actions are appronriate. However, O T A will be required to provide written assurance, as part of the State's annual plan I
certification, that there is no sianificant population at risk l
(permanent or transient) within that portion of Harris Township to j be excluded fran the EPZ.
! (3) Lucas County--FDtA had determined that a REP plan nust be developed in accordance with the guidance in NUREG-0654.
't ODSA Response OEA correctly points out that FDtA's Decenber 9,1985, letter and accorpanying FDiA staff report apparently lef t "...some leeway for development of a pssible ecmpronise that would satisfy the desires of local goverrrnent and still meet the demands of FDiA." Accordingly, OT A submitted additional supportinq justification / documentation for exclusion of Ixcas County frczn the EPZ.
FEMA Decision Ibe to the substantial ponulation (2,700 peak maximtrn) potentially at risk, and for the reasons cited in the attached FDiA Region V review, 1
FDtA's final decision is that an approved REP plan for Lucas County
! mst be submitted to FDtA Region V within 120 days. This plan nuy be l a Iucas County plan or an annex to the Ottawa County plan. However,
_l if the plan is an annex to the Ottawa County plan there e st not be any questions or doubt as to the leaality of such an arrangement or to its implementation. As you kncw, FD1A placed the original Davis-Besse REP submission on hold in 1982 because of the "... potential of coera-
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tional, logistical, and legal emplications..." associated with Ottawa County taking protective actions for Iucas County. Since that time, FDM has not been advised that these potential problem have been resolved. 'Iherefore, if these same concerns should exist for the future plan for Imcas County, FD1A will have no alternative
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but to return the State's original submission and take action in accordance with FDiA regulations. Any plan, of course, nust comply with all applicable FatA regulations and NUREU-0654.
In addition, dates for a full-scale exercise c,f the plan and a public meeting (see page 4 for explanation of the public meeting requirement) must be agreed to within the 120-day period. The exercise and public meetina must occur within calendar year 1986.
g (4) Iake Erie--FDiA had determined that the U. S. Coast Guard (USCG) needed to be consulted and several apparent inconsistencies needed l
to be addressed related to West Sister Island and the Iake Erie EPZ boundary.
ODSA Response i
Ohio submitted information clarifying the issues. W st Sister Island j is a bird sanctuary closed to the public; the LECG has been consulted; i
and, the EPZ boundary inconsistencies have been resolved.
j FEMA Decision l
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FDiA finds the State's actions appropriate.
(5) Sandusky County--FD4A had determined that Ohio would have to provide written assurance annually that there is no population at risk within
'l that portion of the County to be excluded, and County officials would l have to review and accept the EPZ proposal.
l ODSA Response OIEA has provided further justification for excludinn the County fron the EPZ and noted that the area to be excluded is either marshland or rural farmland with no known plans for major develcprient. Field surveys revealed there are 12 households in the area reccnnended for exclusion. Parther, the proposed EPZ is supoorted by written docu-mentation fron the Rice Township Trur/ tees and the Sandusky County Ccmmissioners. 1 FDiA Decision FDiA finds OIEA's actions appropriate. However, it will be necessary for the State to provide written assurance, as part of the State's annual plan certification, that there is no significant population at risk (permanent or transient) within that portion of Sandusky County excluded from the 10-mile EPZ.
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A public meeting to discuss State and local REP plans in accordance with Section 350.10 of 44 CFR 350 is beinq required because of the lona period of :
time which has elapsed since the 'bvember 7,1980, public meeting and the l changes associated with local plaw and the EPZ over the past several years.
If the State is not able to provide the information required within 120 days of the date of this letter, we will be required to take action in accordance with FEMA regulations.
FEMA is eager to continue cocoeration with Ohio so that the necessary infor-mation for the long sought-af ter annroval under FEMA rule 44 CFR 350 can be prcNided within the 120-day time period.
Sincerely, 1 Sanne Speck Associate Director State and local Progrars and Support Attachment As Stated
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. Ju 09 '06 09:
kEMANGIONVCHICAGO1 iO2
.. t STATE OF OHIO ADJUTANT GENEftAL'8 DEPARTMNIT asas east enAnvua coas eonnamoron,cien anosa ana DISASTER SERVICES AGENCY ACOH-DS July 8, 1986 Mr. Wallace Weaver, Chairman Regional Assistance Committee Federal Emergency Management Agency Region V 300 South Wacker Drive Chicago, IL 60606
Dear Mr. Weaver:
This letter is a follow-up to the conference call of June 30, 1986, between you and representatives from the Toledo Edison Company and this agency.
As a result of that telephone call, we have complied a listing of milestones and completion dates leading up to and including an exercise and public meeting. A progress report will be provided to you period!cally or as milestones, as listed in the attachment, are completed.
During our telephone conversation, the possibility of Lucas County officials demonstrating certain aspects of their "All Hazards Plan" during the September 23rd utility exercise was discussed. Lucas County does not have a completed "All Hazards Plan" but does, however, have an Emergency Operations Plan (EOP) that has been used in the past for disasters and drille. Based on conversations with Lucas County Civil Defense offic!als, they would be willing to demonstrate certain aspects of this EOP with key personnel during the September drill.
i Presently, the Ottawa County Radiological Emergency Response (RER)
Plan is being revised to incorporate changes brought about by the inclusion of Port Clinton and Lucas County planning activities. The Ottawa County Plan and the revised State Plan will be ready for submission along with the Lucas County Plan prior to December 30, 1986.
i in meetings with the U.S. Coast Guard, the western boundary of the waterway Emergency Planning Zone (EPZ) was changed to reflect the inclusion of Coast line in Jerusalem Township. The western boundary, which was described as "a line extending northeasterly from Ward's Canal (located approximately 1.5 miles southeast of Reno Beach, Ohio) to the southwe9t tip of West $1 ster Island" has been changed to read "a line extending north-easterly from Coolle Canal to the scuthwest tip of West Sister Island." The Coast Guard has agreed to draft a new letter of agreement to reflect this change. This letter of agreement will be included in the revised State RER Plan.
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Q TO: Mr. Wallace Weaver '
July 8,1986 J RE: June 30,1986 Conference Cell Page 2 Based on the progress to date in meeting obilgations outlined in previous correspondence to FEMA, I am confident that we w ll be able to bring together the resources, cooperation and efforts of all parties concerned to ensure the completion and testing of adequate plans to protect the public within the EPZ for the Davis-Besse Nuclear Power Station. If you have any questions, please do not hesitate to contact me.
FOR THE DIRECTOR f ^
s RICHARD M. LOC HART ,
Deputy Director DM:kjs !
Attachment:
as stated cc: James Creer, Ottawa County Disaster Services Agency Donald Hickey, Toledo-Lucas County Civil Defense Jennifer Weslik, Toledo Edison Company s
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' / JUL. E '85 5:38 FEMA REGION V CNICHGO 3 P.@S
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., .l-Ohio Disaster Services Agency MILESTONES Davls-Besse Nuclear Power Station Offsite Emeroency Plannina COMPLETION DATE MILESTONE July 15,1986 Working draft of Lucas County Radiological Emergency Response Plan submitted to Lucas County officials for review. J l
July 30, 1986 Memorandum of understanding pertaining to !
emergency planning signed by Lucas County l Commissioners, Jerusalem Township Trustees, Ohio DSA and Toledo Edison Company. ,
Aug. 15, 1986 Lucas County officials complete review of Lucas '
County RER Plan.
l Aug. 1986 Public forum conducted in Jerusalem Township to acquaint trustees and residents with Lucas I County RER Plan and the memorandum of understanding (date to be announced but prior to Plan submittal to the State).
Sept. 1, 1986 Rewrites incorporating County review changen completed.
Sept. 3,1986 Lucas County RER Plan submitted by Lucas County Commissioners for State of Ohlo review.
Sept. 10, 1986 State completes review of Lucas County RER Plan f and returns Plan for any needed corrections.
i Sept. 23,1986 Key players from Lucas County, Ottawa County and Ohio DSA demonstrate certain emergency response functions in conjunction with a utility-only exercise conducted for Davls-Besse Nuclear Power Station.
Nov. 15, 1986 Lucas County officials complete review of training program modules.
' Dec. 1, 1986 Training for Lucas County emergency workers begins.
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MILESTONES P
COMPLETION DATE MILESTONE __
Dec. 30, 1986 The Lucas, County RER Plan, and revisforus to the Ottawa County and State of Ohio Plann submitted to FEMA V for an Informal rev!ew as provided for under Title 44, Part 350 of the Code of Federal Regulations.
Jan. 15, 1987 Stata and Toledo Edison jointly submit exercise objectives to FEMA and NRC Regional Offices.
Jan. 31,1987 Ohio DSA provides written assurance, as part of the State's annual plan certification, that the number of people at risk in the portions of Sandusky and Ottawa Counties that are within the 10-mile radius but excluded from the emergency planning sone is not significant.
Feb. 13, 1987 State and Toledo Edison submit exercise scenario to FEMA and NRC Regions for review.
Mar. 31, 1987 Emergency response exercise conducted.
Apr. 30,1987 Public meeting conducted.
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POR FROTECTICII 07 CITitans IN J33tD8ALBf IUWN881F M
Jerusalem Twenship lies within the tem a11e redine of the Davis-sesee maelser Fever Staties in ottawa County, but is not ouvrently inalafed ta the planaias efforts of the tem sila Energesey Plaestag sees (RPS) as described in the Chie Flas for Beesense to Radiation_
-i_ ma Licensed Buelear Fee 111 ties. There has been einse 1983 en operettag sissa j warsias system (a Jerwealem Township so well as the asessaary a-8=m-tions links with 1mese county at their omorgency feeilities. Winrains implenostation measures have been ta piste since them and are sedressed in the ottews county snargemey Plan. sectaen 711-E-4. ,
stsens of Lease county F1=
m parties to this agreement coseer that the fo11ewsag settvittee asse-etated with the protantion ei the reetdente of Jerussian Toonenty will be couplete by abe pleased cetsbete eters tap of the Devia-geese Nuclear Power staties.
The estating eiren warsias system trill be upgraded.
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Pete 8 is ruese covaty charlency Plan Taylenesting ProceduNs Will be
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the teone comaty meergesey Flam and implementsas r waaderse.
%s parties further recommise not it to essential ta esatimus win the
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posture that provides reas.nable segurance that the residente of Jerusales Township are afforded complete preteetten.
u _ To.acacious providtag this asseremos. the parties saves to the fellowtag interia measures which wG1 reunis ta offeet until the find approved Lucas County Insraemey Plan and facilities are in ytane.
The feetitties eoeplettes to oebeduled for March 1987. ~
l In the event of any emergener decieraties Talede Edioen will estabitsh a eettiaucusAy menned +==an==4catism poet in er is elese prendastty to -
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._. _ _ page 3 the fire station in Jenselen Township to provide a todendast, dedicated commenatestian lish with Davis-sesse. Ottese County anergemey Operetiene Center (30C). Sad the existing Imesa Covaty Emersoney Operettese Center (300).
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- Toledo Edison will contisse to provide a dedtested sammaisetten link fres its Emergency Coetrol Center (30C) et Devia-4 sees to the taste * '
County 30C whi4h will be in additten to the presamt ring deum telepheme circuit leested ta the Incas Comacy 300.
- I tuese County commissiesers will es the advies of Toledo 4 mons County Civil Defense representatives in.aseerdanee with tafemmettaa provided l by Toledo Edison SDd the efficiale of Olde Disseter Servises Agency (OD$A) emetsies their meisting emergency decision making procase te order protective actione for Jerweeles Township by motivettag the existing ave 11able ecumsad and esatrol ettvetare that the enesty tople-weets for non-redselosteal emersencies. 1 Upon activatime.1mese causty and Jerusales Township Offisiete will bring to beer all of the facilities and resoursee at their dispeesi to Igle-i meet any and all mecaeeery protective actions. This would instade le?,a1 fire sad subulemos services. local low esfersement speacias and the County sheriff's Department acting in sencart te zeepend to the estuetten following asisting plane end procedures metanily stilised for ether typee of emergency responsa etteettene. '
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Tolede Edises w'111 secure that provistees are im Flece to provide for the treataeat of any injured cmatastaated Jermaales Teenship reetdante !
i at traised/ equipped medical foo111ttaa.
Betes One of the major t andiaal fea111 ties fave1N ta the estettag Ogssys Cegacy Flea for !
Rasseeme to Radiation brasasise et timessed NumM= Fee 111 ties is 1oested is Laese Ceesty and.can be utilised y tmose Geesty 1a the i event of an inesdent.
Tolede 3diese wi n prodnee and distribute tydated public Informattau '
Stechurce is Jerusalem Townektp tMtish will address the tacInstas ad Jeroeslaan Teamship and provide the appropriate taformatism te 41reet the citisses to take the eerrest estanna. ,
l Jerusalem Teenship Trustees win provide a forum for Toledo 981eene Chie Dimester Services Agosty (CDSA). and Lasse Ceesty to explaim i these lateria tinaaeros to the residenta of Jestealan Township.
Tolede Edises will provide a direet tattial -1settes line to the ;
Dsese Ceesty Sheriff's Offies e em 1a currastly done for the Ottese Cesary Sheriff's Office.
l Otto Disaster Services Asesey (CDSA) will provide a representativs t
to toepend to the Laeta caanty 30c to provida eassetenes sa may ine% teleted to movia-seees.
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- - - - Jonesian Dewmete Trustene Imass consty ekte: '
Jettaales Tsunship.
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