ML20214S162

Forwards Interim Finding on Offsite Radiological Emergency Planning & Preparedness for plant,site-specific to Commonwealth of PA & State of Wv.Plan Acceptable.Unresolved Issue in Commonwealth of PA Plan Re Exposure Limits Noted

ML20214S162
Person / Time
Site:	Beaver Valley
Issue date:	05/29/1987
From:	Krimm R Federal Emergency Management Agency
To:	Congel F Office of Nuclear Reactor Regulation
References
NUDOCS 8706090160
Download: ML20214S162 (139)

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' g Federal Emergency Management Agency Washington, D.C. 20472

{(S MM 2 9 lgg7 MEM0lWIDUM EUR: Frank J. Congel Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation U. S. Nucle r atory Comission FIl0M: Richard W. Krimm Assistant Associate Director Office of Natural and Technological Hazards

SUBJECT:

Interim Finding on Offsite Radiological Emergency Planning and Preparedness for the Beaver Valley Power Station Site-Specific to the Carronwealth of Pennsylvania and the State of West Virginia Attached is documentation prepared by the Federal Emergency Management Agency (FEMA) staff in Region III that will form the basis of an interim finding on offsite radiological emergency planning and preparedness around the Beaver Valley Power Station. 'Ihe offsite jurisdictions addressed in this finding are the Cmmonwealth of Pennsylvania and Beaver County; and the State of West Virginia and Hancock County.

This interim firding consista of three parts: Part I contains documentation on the review of offsite radiological energency planning for the Cmronwealth of Pennsylvania and Beaver County, and the State of West Virginia and Hancock County; Part II contains the results of the remedial exercise which corrected the remaining deficiency cited for Pennsylvania in the November 19, 1986, exercise; and Part III contains a list of support hospitals.

The only unresolved issue in the Pennsylvania offsite plan concerns the deci-sion making chain for authorizing emergency workers to exceed exposures in the 1-5 rem range. 'Ihis issue is currently being addressed and does not adversely affect the adequacy of the Pennsylvania plan. As soon as it is finalized, you will be advised. Based on the plan reviews and exercises conducted to date, there is reasonable assurance that offsite radiological emergency planning and preparedness in the Comnonwealth of Pennsylvania and the State of West Virginia is adequate to protect the health and safety of the public in the event of a radiological emergency at the Beaver Valley Power Station.

If you should have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 646-2860.

Attachments 8706090160 870529

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y( f' Region Ill 105 South 7th Street Philadelphia, Pennsylvania 19106

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MAY 121987 MEMORANDUM FOR: Dave McLoughlin, Deputy Associate Director State and Local Programs and Support ATTENTION: Robert S. Wilkerson, Chief Technological Hazards Division FROM: Paul P. Giordano

.g Regional Director 1 hhh '

SUBJECT:

Interim Finding, Second Unit, Beaver Valley Power Station As requested by your Memorandum of December 19, 1986, this letter is submitted to provide an Interim Finding on the planning and preparedness capabilities within the 10-mile Emergency Planning Zone of the Beaver Valley Power Station. An Interim Finding is necessary for the licensing process for the second unit at the Beaver Valley site.

Review and Evaluation of the radiological emergency preparedness plans has been underway at this site since 1980. At that time draft plans were submitted by the West Virginia Office of Emergency Services to FEMA Region III for coment. A review of the West Virginia State plan was completed and comments provided to the State in December 1981 (Hancock County plan review, Attachment 1) and in March 1982 (State Plan Review, Attachment 2).

In 1982, West Virginia and Hancock County Radiological Emergency Response Plans were again submitted and underwent another Regional Assistance Committee Review. Comments were provided to the State, with problems still not adequately addressed, in September and October, 1982. (Attachments 3 and 4).

Corrections were made and plans were again submitted . This submission was for formal 350 approval . However, the Regional Assistance Committee evaluation still identified twenty-three planning inadequacies. The evaluation report was submitted to the State on January 10, 1986.

(Attachment 5).

FEMA Region III has received plan changes from the State of West Virginia which correct the 23 inadequacies. See the attached Corrective Actions to the FEMA Region III RAC Comments (Attachment 6).

The State of West Virginia and Hancock County participated in a full-scale exercise on November 19, 1986. All elements of the radiological emergency response plans were adequately demonstrated. See Beaver Valley Exercise Report submitted to you January 7, 1987 and April 9, 1987.

The initial Regional Assistance Committee review of the Beaver County, Pennsylvania Radiological Emergency Response Plans was conducted in 1983.

The evaluation report was submitted to the State on August 23, 1983, with several inadequacies identified (Attachment 7).

TTY FOR DEAF 215-5974850

The Beaver County and 27 municipal plans were submitted for formal 350 review and approval in April,1985. However, after another Regional Assistance Committee review,12 elements were still identified as requiring additional clarification (Attachment 8). Three of which had to be corrected before the plans could be recommended for 350 approval. A status of corrective actions taken is included in Attachment 9.

Beaver County and the 27 municipalities participated in a full-scale exercise on November 19, 1986. The Exercise Reports were submitted to you on January 7,1987 and April 9,1987. Two Deficiencies were identified and have since been corrected. See FEMA Region III Memorandum dated March 30, 1987 and May 11, 1987.

Based on the above documentation, FEMA Region III hereby presents an Interim Finding that the plans and preparedness demonstrated by the State of Pennsylvania, Beaver County, 27 municipalities and four support Counties, the State of West Virginia and Hancock County are adequate to protect the health and safety of the citizens located within the 10-mile EPZ of the Beaver Valley Power Station, cc: Pennsylvania Emergency Management Agency West Virginia Office of Emergency Services I

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December 18, 1981 Mr. Cecil Russell Director

Office of Emergency Services Room EB-80 State Capitol Building Charleston, W 25305 Dear Mr. Russells Baciosed are two copies of an informal FINA in-house review of the Hancock County Radiological Emergency Plan for the Beaver Valley Nuclear Power Plant.

The purpose of this review is to enable Saata and County planners to address the identified issues in advance of submitting their plans for a full IAC review.

If you or your staff have any questions or comments, please contact Bruce Swiren directly at 597-7791.

Sincerely yours, Steven A. Adukaitis Chairman Region III Regional Assistance Coenittee ec: Andy Kondik, Director. H.C.0.E.S.

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File Chron B.Swiren:me:12/18/81 ORIGIN A T OR CONCURRE NCE CONCURRENCE CONCURRENCE CONCURRE NCE CO NCURRE NC E BS/mc Name Date _..

OFFICIAL RECORD COPY ,

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.- 1 Hancock County Plan Rating Key: A-Adequate I-Inadequate Element Rating A Assignment of Responsibility A.1.a I The County plan identifies the County's emergency response organization very well. A clearer descrip-tion of state agency and federal assignments is needed.

A.1.b I Again, the County's concept of operations and how it relates to the total effort is defined very clearly, but the responsibilities and concept of operations for state agencies, (especially those with primary responsibilities in the plan) private organizations, and the responsibilities of federal agencies need to be provided.

A.1.c ,

I An organization chart has not been developed yet.

A.1.d A The Director of the Hancock County Of fice of Emer-gency Services (HCOES) or his designee is in charge of the emergency response. The name of the indivi-dual should be included in the final plan.

A.1.e A Communicat ions appear adequate. The Hancock County Sheriff is responsible for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of the systems. Procedures for the notification of members of the County emergency response organi-zation are provided.

A.2.a I No listing of key individuals with title are included in the plan. Within the respontibility matrix in Annex B column headings for Public. Information (press relations is inadequate), Accident Assessment (in-volves monitoring, data evaluation and recommenda-tions for protective actions), Social Services, Fire and Rescue (stated on page B-6 as a responsibility of the United Hancock County Fire Fighters) and Radio-logical Exposure Control (involving those responsi-bilities stated in Annex I-1) should be in:1uded.

A.2.b A Authorities referenced on page I-4.

A.3 I No written agreements incit.ded. They will be devel-oped for final plan.

. 2 A.4 . I Capability for continuous emergency response is implied, but not explicitly stated. A Standard Operating Procedure (SOP) for continuous operation of the County Emergency Operations Center should be included in the plan to help demonstrate this capa-bility.

C Emergency Response Support and Resources C.1.c I Although the burden on meeting this criterion rests primarily with the State of Pennsylvania and Beaver County, the County plan states that this is a re-sponsibility of the West Virginia Office of Emergency Services (WV0ES). The County's plan should reflect more coordination with the state on this matter.

C.2.a A This is a state responsibility.

C.3 The County references West Virginia University and the West Virginia Institute of Technology as sources of radiological monitoring teams, instruments and laboratory support. These sources are not referenced in the state plan. Clarification should be made on this point as to whether the resources at these two institutions will be used in a radiological energency. This clarification is especially impor-tant in the state plan.

C.4 I Letters of agreement with public and private agencies (e.g., Red Cross, RACES, Weirton School District, Etc.) and the institutions referenced in C.3.

D Emergency Classification System D.3 A The four emergency action levels are consistent with those of the facility.

D.4 A County response as provided in Section 4 appear ade-quate. The follow-up notification procedure allows for information to be passed to the County by the Beaver Valley Power Station (BVPS) on recommended

i. emergency actions.

l l E Notification Methods and Procedures i E.1 A The procedures for notification by the BVPS, dupli-cate notification by the Beaver Valley Police, the notification and verification of WV0ES by the County are in place.

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E.2 I Although the procedure for notifying County response personnel is adequate, no names of individuals to be called is provided. It is sugg'ested that the County establish a chain of notification so that one or two persons are not responsible for calling the officials and emergency response personnel listed in Annex C-3.

E.5 I A detailed EBS plan needs to be developed which is coordinated with the two other jurisdictions in Ohio and Pennsylvania. Also, EBS messages need to be developed. . If the messages in Annex K-Attachment 1 are intended to be used by the County, then detailed information as to how and what information on protec-tive measures is incorporated into those messages is required.

E.6 A Until the siren system is operat ional, the County will rely on a route alerting system. The County has provided route maps and has identified which vehicles will operate on each route.

Although this question might more appropriately be addressed by the state, there are t.o means provided in the plan for alerting traffic on the Ohio River and the Penn Central Rail Line.

E.7 I See comments for E.5.

F Emergency Communications F.1.a A The System is adequate and backup methods of commni-cation are provided for, but comment on element E.2 is relevant here regarding the County response organization.

F.1.b A The Hancock County communications Center (HCCC) is able to contact Beaver and Columbiana Counties via commercial telephone or the Duquesne Light Industrial l

Radio System.

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F.1.c A This is a state function in coordination with the Pennsylvania Emergency Management Agency.

F.1.d A Provision for communication with the BVPS-EOC, State j EOC, Beaver and Columbiana County EOC's, and radio-l logical monitoring teams.

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I See comment regarding element E.2.

F.2 A EMS Radio System will be used as the communciations link between emergency medical' units and the Weirton Area Medical Center. Should the Ohio Valley Gen-eral Hospital also be included in the communications link?

F.3 A Monthly test of communications between BVPS and HCCC.

Weekly test of Plextron system for county emergency personnel alerting.

G Public Education and Information G.1 I The County st ates their intent to develop the mater-ials called for under this element and has identified the means of dissemination, but no target dates for development, publication, and dissemination are provided. No outlines of information to be included in these publications are provided.

G.2 I See comment in element G.I.

G.3.a A The Public Information Officer will meet with the news media at the New Cumberland Junior High School.

G.4.a A The name of the individual should be incorporated into the final plan.

G.4.b I The exchange of information for release to the public between the BVPS, WV0ES, and HCOES is not dealt with in the plan. The only statement made in the plan is in regard to referral to the proper source. There should be some means by which the County knows what information BVPS, the state, and federal agencies have released to the public.

G.4.c I Not developed in the draft plan.

G.5 I Discussed in Annex K, but details as to the location of the briefing and the approximate scheduling should be given.

H Emergency Facilities and Equipment H.3 A The county EOC is the County Court House. Space available also for a state field EOC.

. 5 H.4 I Again, the comments in element E.2 apply here.

H.7 A This criterion is a WV0ES and West Virginia Depart-ment of Health responsibility,"although RADEF members will monitor radiation levels outside their homes upon notification of an incident at_BVPS. It is suggested that these individuals be assigned locations near population centers. Also, the plan should state how many RADEF members will conduct this confi:matory monitoring. What types of instrissents shall be used?

H.10 I An inventory of radiological equipment is needed.

How often will representatives of the WV0ES come to Hancock County to calabrate equipment?

H.11 I See comment in element H.10.

H.12 I Although this is a state responsibility, provision should be made for a state field EOC for central collection of field monitoring data.

I Accident Assessment

.I.7 I Although the responsibility of meeting this criterion rests primarily with the BVPS and the state, . a concise description of the capability of the RADEF team along with an inventory of radiological equip-ment available to the County should be provided.

l l I.8 I Comment relative to I.7 applies here also. '

l l J Protective Response J.2 Not applicable to Hancock County.

J.9 A The County has developed a scheme of protective actions consistent with EPA recommendations.

J.10.a 1 The County has developed very good plans and maps for evacuation routes, reception and transportation staging, alternate evacuation routes, but the follow-  ;

ing points still need to be addressed:

1) Location of mass care centers on maps.

2) Location of suitable areas for the public to take shelter.

3) Planned location of radiological sampling and monitoring points.

Also, it is suggested that the use of Route 7 in Ohio be evaluated as an alternate evacuation route.

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6 J.10.b A Population maps are presented in sector f o rm a t .

J.10.c I Plan provides for route alerting by the fire depart-ment as an interim measure until a siren system is installed, but information materials and EBS announcements need to supplement that alerting process. The comments in elements E.5 and G.1 should be met to rectify this inadequacy.

J.10.d I Basic plan la good, but details as to what transpor-tation resources will be available are needed (e.g. ,

how many vehicles and of what type does the county childrens home have, is there an agreement for the use of Hancock County Senior Citizens group vans, etc.).

J.10.e I County is responsible for administering KI, however this is an overall state responsibility. But state does not have KI plan. Also, County plan should identify the amount and location of KI supplies.

J.10.f I No information as to what conditions would warrant administration of K1 to emergency workers and to the general population.

J.10.g A Means of relocation is primarily by auto, but County has provisions for non-car owning public, school children, special populations, and transients.

J.10.h A Both reception centers are outside the EPZ. ,

J.10.1 I Traffic capacities for evacuation routes is not yet availale.

J.10.j A Control of access is provided by security checkpoints maintained by the County Sheriff.- Since each of the three county jurisdictions could possibly declare

, evacuations at different times, access control can be

! completely meaningless if traffic can enter from Ohio

! or Pennsylvania. This point reinforces the need for close cooperation between the three counties within the EPZ.

J.10.k A The County plan addresses impediments caused by flooding. Other impediments such as accidents on the i evacuation routes should be dealt with. Is Waterford

[ Park a suitable reception center if the Ohio River is j flooded?

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,.- 1 J.10.1 I Time estimate for the evacuation of the whole EPZ in Hancock County is provided which includes auto-owning population and school children. What about non-auto-owning population and special facility population?

Evacuation time estimate is only made for one condi-tion (which is not identified). Evacuation roadway network is provided , but no t able of road segment characteristics is provided.

J.12 I Mass care and reception centers are provided for, but

• the plan does not state who is responsible for the operation and management of those centers and how long they can be continuously manned.

K Radiological Exposure Control K.3.a I An SOP for RADEF operations during a radiological emergency is needed along with a count of the members of the RADEF team. A decontamination center for emergency workers should be identified as well as inventories of emergency worker dosimetry, survey meters, and dosimeter chargers.

K.3 b te I The above mentioned SOP should include the procedure to be followed in maintaining accurate dose records and instructions to emergency workers as to when

, dosimetry should be read.

K.4 I Although the County has stated exposure in excess of v' general public limits will be voluntary, a decision ,

chain should still be developed for authorizing exposures of emergency workers above those levels which includes a review of a workers dose levels.

K.5.a A Decontamination levels are set.

K.5 b I Procedures for decontamination should be included

, within the plan (preferably with the RADEF SOP).

l Contaminated waste will include both liquid and solid i matter (e.g., clothing), procedures for the dis-l posal of this solid matter should be developed.

i L Medical and Public Health Support L.1 I There are no hospitals in the County. Two hospitals serve Hancock County: Weirton Medical Center and the i

Ohio Valley General Hospital. No statement is l provided as to their capability to handle contami-

! nated patients. There is no indication that the l Brooke-Hancock Emergency Medical Services Council l will be able to properly handle injured individuals who are also contaminated.

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,. *. 8 L.4 A The Brooke-Hancock Emergency Medical Services Council will provide a minimum of 18 asbulances and three rescue units. .

M Recovery, Reentry, and Post Accident Operations M.1 I The County provides the guidelines which will be followed in terminating protective actions and a general plan for recovery and reentry. No proce-dures, though, are identified by the County (e.g. ,

traf fic controls, maintenance of ingestion path-way protective actions, notification, transportation back to evacuated areas, etc.).

N Exercises and Drills N.1.a A Exercises will verify the adequacy of the County plan, SOPS, pamunications systems, emergency equip- i ment, and the interrelationships of participating organizations.

N.1.b A See element N.1.a N.2.a A Plan states that a drill monitor will evaluate drills. Provision is made for monthly test of communication system with BVPS, WOES , Columbiana County, and Beaver County. Plextron system in the county is tested weekly.

N.2.c A Medical emergency capability will be tested at the ,

annual exercise.

N.2.d I This area is primarily a state responsibility, but RADEF personnel have monitoring responsibility pirar to the arrival of state personnel.

N.3.a . I Objective is provided, but no evaluation criteria are included.

N.3.b.c.d.e.f State responsibility.

N.4 A The Plan does not provide for local observers, but l critique of County organization is provided for in l the plan.

N.5 A Director, HOES will be responsible for ensuring that deficiencies in the County response will be corrected '

and that corrections will be incorporated into <

the County plans and SOPS.

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0 , Radiological Emergency Response Training.

0.1 I outlines of topics for orientation sessions are provided, but no specifics are given as to when these sessions will be conducted and who will attend. Has the County looked into training offered by FEMA and the state?

O 1.b I No assurance that each County response organization will receive training. No discussions of mutual aid organizations.

0.4.a-j I No identification is provided as to whom the " key personnel" are that will receive training at the BVPS. No indication as to whom in the emergency response organization will receive training.

0.5 I Although County states that they will undertake a training program, the question as to their ability to provide training especially to RADEF personnel remains to be proven.

P Responsibility for the Planning Ef fort.

P.1 I Training of planners is not addressed in either Annex A or Annex M.

P.2 A Director, HCOES, but the name of the individual is not provided.

P.3 A Director, HCOES.

P.4 A Annu61 review of plan. Quarterly review of telephone numbtre, radio communications, and Plextron assign-ments.

P.5 A Director, HCOES, responsible for transmittal of updates to all holders of the plan.

P.6 I To be provided in final plan.

P.7 I To be provided in final plan.

P.8 A P.10 A See element P.4

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March 25, 1981 Mr. Thomas Carr Director of Planning Office of Emergency Services Room EB-80 State Capitol Building Charleston, West Virginia 25305

Dear Mr. Cat :

The following comments are the result of my review of the December 1980 Draft West Virginia State REP plan, as was promised to you in Hancock County on January 22, 1981. My review of the Hancock County plan should be available by the end of April. The delay is the result of expedited staff work at FEMA on revised TMI plana.

It is hoped that most of these comments will be helpful to you in pre-paring the State plan for FEMA's formal RAC review.

Due to pressing demands on the RAC from THI, West VirSinia's State and county plans will not be reviewed probably until June by the RAC. Therefore,

! time is available to work out any planning difficulties that currently .

exist.

The best way to use these comments is side-by-side with NURE & 0654. The consnents, for the most part, are neared to each individual planning criteria.

The planning criteria are not restated in the text of the comments.

l If you or Sam have any quantions, or wish to discuss these comments, feel free to call me at (215) 597-0180.

Sincerely yours, Bruce J. Swiren Encesure Emergency Management Specialist ect Sam Paletta, West Virginia State Flanner Steve LaVie, Health Physicist, NUS Corporation PP-OR PP-R PPD /B. Swiren/de/3-25-81

• a 3/25/81 COMMENTS ON THE WEST VIRGINIA RADIOLOGICAL EMERCENCY PLAN A. ASSIGNMENT OF RESPONSIBILITY (ORGANIZATIONAL CONTROL).

Planning Standard Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organi-zations within the Emergency Planning Zones have been assigned, and emergency responsibilities of the various supporting org'anizations have been specifically established, 1

and each principal response organization has staff to

! respond and to augment its initial response on a continuous basis.

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l A.1.a. The State Plan identifies 9 State agencies, 2 county level i

entities, 2 private agencies, and only 1 Federal Agency (FEMA Region III) specifically in its responsibilities section. However, in Appendix 15, other Federal Agencies are directly referenced. They are the IRAP Teams (DOE).

EPA, NRC, and DilEW/FDA. These Federal agencies should be included and adequately described as to their responsibilities i in the Responsibilities portion of the State Plan.

A.1.b. There seems to be considerable gaps in the State Plan re-garding how the responsible agencies will actually interface under the concept of operations scheme outlined in the Plan.

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A.l.b. Specifically, Appendices 15 through 17 describe the specific (cont'd) roles to be performed by the West Virginia Departments of Health, Agriculture, and 0.E.S. The State should develop separate appendices, or SOP's as it may be which describe the specific or unique roles that the remaining six State agencies are expected to perform during a fixed nuclear facility emergency.

The above comment also applies to the Red Cross and RACES.

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In general, the format of using the four Emergency Action Levels (EAL's) to organize the concepts of operations is good. Concerning the State concept of operations, there are some questions this reviewer needs to have clarified.

Under the Alert classification level, it states that con-firmation radiation monitoring of the 10 mile EPZ will be performed if a release has occurred. It is my understanding that the County would be responsible for this. Does the State also plan to conduct confirmatory radiation monitoring?

If so, then by whom?

Another question I have concerns the State's concept of Operations regarding the Site and Cencral Emergency classifications. In both cases, it is indicated that the State will put personnel needed for evacuation on alert or activate them, and that shelters would be manned and readied to receive evacuees. I thought these two functions were County responsibilitics?

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3 A.1.b. Finally, it is necessary to include in the State Plan the (cont'd)

Concept of operations for the four Federal agencies referred to under Comment A.1.a.

A.1.c. The block diagram on Page 14 illustrates satisfactorily the interrelationships of the responsible organizations in the State Plan.

A.1.d. On page 17-8, a listing of facilities and telephone numbers are given. However, no specific individuals and their ticles are provided with the facility telephone numbers. There also is no indication of what part of the facilities organization structure is being referenced; i.e., County EOC's, facility EOF, TSC, etc.

On page 17-9, the listing of State Agency Coordinators ,

and their telephone numbers is satisfactory.

A.1.e. On page 17-9, the 24-hour telephone numbers satisfy this requirement for State agencies. However, there are no 24-hour communication numbers and contacts for the Counties, facility, other State agencies, Federal agencies, etc. Are the facility and agency numbers on page 17-8 24-hour ones? If so, then it should be indicated. If not, then they should be provided along with indicating the specific contact involved, as mentioned in comment A.1.d.

The State Plan should also reference (mention) in its Con-cept of operations section the capability to establish and maintain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> communications.

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A.2.a. The matrix on page 15 is totally inadequate for meeting this criteria. In fact, it appears that the matrix was xeroxed from the State's Emergency Disaster Plan and inserted directly into the Radiological Emergency Plan. The matrix in its present form does not match the State, local, Federal and private organizations relied on for this Plan.

Secondly, the emergency response tasks on the side of the matrix don't match that closely the criteria for this element; ex/no radiological exposure control, requesting Federal assistance, etc.

A new matrix should be designed using the effected State agencies, County agency (s), all Federal agencies with responsibilities (see previous comments), and neighboring State and County agencies.

The new matrix should also use the task functions contained in this element,,and more if the State feels that its necessary.

A.2.b. It would be informative if, in the Authorities and Re-ferences section on page 2, a brief description were added to each authority (or Act) explaining the powers contained 1

therein.

i A.3. Appendix 22 provides for written agreements between the State

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and the facilities, PEMA, and the Red Cross. These agreements, as provided, do cause several questions con-j cerning their scope to be raised.

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5 A.3. 1. PEMA to WV- When will this agreement be signed? Also, (cont'd) will Pennsylvania do any rddiological monitoring in West Virginia? Either way, this issue should be stated in this agreement.

2. Beaver Valley to West Virginia - 0.K.

. 3. Shippingport to West Virginia - When will this agree-ment be available.

4. Red Cross to West Virginia - This appears to be a restating of Red Cross national policy from the Eastern field office to the West Virginia Red Cross State representative. As such, this is not an agreement at all. The State still needs to negotiate an agreement between the appropriate Red Cross Chapter (Pittsburgh or Weirton?) and West Virginia which reflects the services that the Red Cross will -

1-supply the State.

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l 5. West Virginia to PEMA - The status and nature of this l agreement is unclear. There is no copy of a modified l agreement, which is referenced in letter between John i

i Anderson and Colonel Henderson. Apparently, the modi--

l fication referenced involves a clause committing West Virginia to a planning function subject to the availability of funding. What type and amount of funding i

i is involved?

6. West Virginia to Beaver Valley - adequate

7. West Virginia to Shippingport - adequate A.4. The WV0ES S0P adequately provides for continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> k

6 A.4. operations at the State level.

(cont'd)

C. Emergency Response Support and Resources Planning Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.

C.l.a. The Department of Health Plan (Appendix 15) requires that the logistician notify the Federal RAP Team at Oakridge National Laboratory. The responsibility for determining ,

whether the logistician requests federal assistance lies with the Division Incident Manager. This adequately meets

. this criteria.

l l C.l.b. In Appendix 15, pages V-5 to V-7 there is a brief dis-cussion of the specific federal resources expected; those being the IRAP Teams, EPA, NRC and FDA. However, in the Concept of Operations part of the State Plan, there are no roles defined specifically for these Federal agencies.

See previous comments under Planning Standard A.

In general, it is felt that the discussion of Federal re-sources is not extensive enough. If circumstances warrant, what specific services would the State expect the Federal l

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7 C l.b. government to perform? How many sampling points? Hou (cont'd) '

much laboratory analysis? etc.

Also needing to be included are estimated times of arrival at the Beaver Valley power plant, or Hancock County (see comment C l.c.)

1-C.l.c. There is no discussion of resources to be made available to the Federal teams to support their responses. For instance, page V-6 of appendix 15 states that if the request for Federal assistance is coordinated, then it will be handled through PEMA's EOC at Blackhawk High School.

If it is not, then it will interface with the Hancock l County EOC. What resources will be made available under both circumstances in Hancock County? And how much of this is the State's responsibility?

• C.2.a. The Department of Health will send two representatives to 4 the near-site EOF for technical assistance. WV0ES will also 1

j send two representatives to the EOF to assist in coordinating State actions. This adequately meets this criteria.

C.3. It is the responsibility of the Department of Health to identify radiological laboratory capabilities and availability.

On page V-7 of Appendix 15, West Virginia University, and f the West Virginia Institute of Technology are identified as available in an emergency in the State of West Virginia.

The Presbyterian University Hospital in Pittsburgh is a source of radiation medicine expertise, which could be T

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o

. 8 C.3. accessed through PEMA.

(cont'd)

While the State has obviously identified suitable facilities, the State Plan should also enumerate the level of support which can reasonably be depended upon; i.e.,

numbers of samples and types of analysis which could be performed, turn around time, and so forth.

Significantly, there was no mention of in-house State laboratory support. Is this available, and if so, what are its capabilities? See comment C.4.

C.4. The Department of Health has identified the Beaver Valley Power Plant as being responsible for offsite radiological monitoring until Divisional personnel or IRAP personnel can be deployed. This raises a couple serious questions.

First, does this mean that the utility intends and has agreed to perform offsite monitoring in Hancock County?

If so, this is not stated in the letter of agreement between

! the utility and West Virginia. Secondly, does this imply l that should IRAP personnel be called up, then State employees will not perform offsite monitoring?

On page 1X-2 of Appendix 15, it is stated that the Depart-i ment of Health has an agreement with West Virginia Univer-sity to analyze environmental samples. A copy of that agreement should be provided in the Plan. Referring back l

' to a comment under C.3. , does this agreement with the 1.

w

1 8(a)

C.4. University supplement in-house capabilities, or substitute (cont'd) for them?

D. Emergency Classification System Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and for determinations of minimum initial offsite response measures.

i, si -

9 D.3. The emergency classification and action level scheme for the Shippingport facility, as found in Appendix 14, is the same as that found in NUREG-0654, Appendix 1.

The emergency classification and action level scheme for the Beaver Valley facility, as found in Appendix 13, uses basically the same classification and action levels as NUREG-0654.

The State Plan has an emergency classification scheme consistent with both utilities (contained in Appendices 15 through 17). Appendix 15 (Department of Health) also incorporates the emergency action levels utilized by Beaver Valley and Shippingport. Since the Department of Health is the lead agency for making State accident assessments, the EAL's location in their plan is appropriate.

D.4. The State level emergency actions seem to be consistent with the nuclear power facilities recommendations. However, it is somewhat difficult to pick up the specific recommenda-tions associated with the EAL's and classification levels for Beaver Valley; the reason being that Beaver Valley does not have a table or distinct section dealing with recommended off-site actions. However, since the State's recommended off-site actions are consistent with NUREG-0654 and the Shippingport facility, the present scheme is adequate for the Departments of Health, Agriculture, and 0.E.S.

a .

10 D.4. It becomes less clear how the other 6 State agencies (cont'd) with response functions fit into the action levels and associated responses. It is recommended, as mentioned in previous comments, that SOP's be developed for these other 6 agencies specific to FNF emergency response. These SOP's do not have to be particularly long, and should be designed to tie in agency responses to the classification and action levels.

E. Notification Methods and Procedures Planning Standard Procedures have been established for notification, by the licensee of State and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

i l

E.1. The procedures for notification and verification of an incident at the utility appear to be adequate. Pages 1-1 thru l-3 indicate that the facility will notify Hancock County directly and immediately concerning any serious

,r potentially serious incident. Beaver County will also notify Hancock County, providing an acceptable back-up notification.

11 E.1. WV0ES also receives its notification initially from two (cont'd) ,

sources; PEMA and Hancock County.

There is one inconsistency,~however, that needs to be cleared up. On Page 12, under Facility Responsibility, it states that the facility will notify Hancock County 0.E.S. immediately in the event of an Alert, Site Emergency, or General Emergency. On page 17-4, under WV0ES Plan, it states that the facility will-notify Hancock County immediately for a Site or General Emergency. Which is it? Hopefully the first.

Verification occurs by the Hancock County OES director or his representative calling the facility back, then calling WV0ES. If the County can't verify, then WV0ES will verify by calling the facility and PEMA.

E.2. The WV0ES Duty Officer Procedures, on pages 17-62 and 17-7, provides for the alerting of State agencies, activating the State EOC consistent with the four classification levels, and for mobilizing WV0ES emergency response personnel.

l The Department of Agriculture Plan indicates that field personnel will be put on alert during an emergency,and that representatives will be sent as required to the State EOC. The Department of Agriculture plan should outline the procedure or details, of how this will be done.

The Department of Health plan does iticlude procedures for mobilizing emergency response personnel.

12 E.2. To be complete, all three above State agency plans also (cont'd) c should provide the names, titles, locations, and phone numbers of the emergency response personnel to be relied 4 upon. .The other State agencies should also have their own procedures for the above mentioned items included in the State Plan.

E.5. The reference cited in the cross reference, pages 1-1 i'

through 1-3, does not address this criteria. Appendix 9 does say that the public information center established

. at Beaver County, Pa., will provide a location for news media to receive information.

What about the public's access to early information? Will Hancock County be responsible for disseminating periodic bulletins to the broadcast media? Or will the State? Or -

l

will PEMA? Whichever alternative is accurate, the State Plan should describe in detail how notification to the public will be coordinated.

E.6. The discussion in Appendix 2 does not address this criteria; it merely states what types of things Hancock County should do in providing prompt notification and warning instructions to the public.

Recognizing that this is the County's primary responsibility, the State Plan should describe what the County is actually planning to do to administrative 1y and physically carry out its notification and warning functions.

l 1

13 E.7. Appendix 18, News Releases, is very skimpy and does-not address adequately this criteria. The concept is to have pre-positioned, already- prepared (just need to fill in a few blanks) messages for the public regarding various protective actions; such as sheltering, respiratory protection, evacuation, etc.

F. Emergency Communications Planning Standard Provisions exist for prompt communications among princi-pal response organizations to emergency personnel and to the public.

F.1.a. There is a 24-hour capability at the State level through the W.V.0.E.S. duty officer. Back up radio communications will supplement the above commercial telephone lines at both the County and State levels through their respective l

Emergency Communications Centers. Duquesne Light also l

has direct radio communications capability with Hancock County via the utility's radio network. According to Annex C of the W.V.E.O.P. radio communications capability exists between W.V.O.E.S. and Hancock County.

Concerning the telephone links they all seem to be commercial.

Are there any plans to have dedicated lines installed between the Utility and Hancock County and between Han-cock County and the State?

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14 F.1.a. Concerning the various radio communications systems, (cont'd) there should be a description of the frequencies in-volved and their locations (proximity) via the pri-mary communications links..

F.1.b. The reference (page 17-1) for communications with continguous State / local governments is not adequate.  !

On page 17-8, telephone numbers of facilities are listed.

There is none for Ohio and Columbia County. Are there any alternate radio links between the parties, such as: W.V.0.E.S. to Beaver County EOC to ?EEA EOC to Hancock County EOC to Columbia County to Ohio?

F.1.c. The reference provided (page 19-1) for communications with Federal emergency response organizations is in-adequate. In the Department of Health Plan, it is .

envisioned that a coordinated request for IRAP assistance will come from the PEMA EOC in Blackhawk High School.

It is also the responsibility of the I.H.D. for notifying IRAP in Oakridge, Tennessee. Is this pri-marily just a notification function, which in reality backs up PEMA, or a requesting function?

On page 17-8, telephone numbers for DOE are listed, along with FEMA Region III . I assume the DOE numbers are for Oakridge, Tennessee?

F.1.d. Appendix 19 indicates that there are a duplicity of communications links between the facility control room, EOF and TSC. The TSC has the radio communications

15 F.1.d. capability . The EOF has commercial and PAX tele-(cont'd) phone lines, with commercial communication links to State and local organizations. Are there any dedicated telephone lines available from the EOF? Is there any back-up (radio) communications from the EOF to State and local organizations? If commercial power is lost, is there a back-up power system?

I was unable to find any mention of communications to radiological monitoring teams. This must be elaborated on.

F.1.c. The reference cited (page 17-3) does not unequivocably provide for alerting or activating emergency personnel in each response organization. The W.V.0.E.S. does provide for activation and staffing of the State E0C.

However, except for Department of Health, W.V.0.E.S.

and to lesser degree the Department of Agriculture, there are no written procedures provided for activating emergency personnel in the other State agencies.

Agency plans should be developed for these other agencies (including the sprucing up of Agriculture's) outlining alerting and activating procedures.

F.2. The reference in the State Plan (page 3-1) does not address at all the coordination of communication for fixed and mobile medical support facilities.

16 F.2. If this is a County responsibility, which in fact I (cont'd) believe it is, then the State Plan should state so and give a synopsis of how it will be accomplished.

F.3. Appendix 10, seems to deal adequately with the re-quirement for periodic testing of the emergency communications system, as described.

G. Public Education and Information {

Planning Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with ,

the news media for dissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.

G.1.a. thru G.1.d. Public education and information is identified as being the responsibility of the County. The Covernor's Press Office Secretary will provide assistance as needed. In what way?

On page 10, the categories of informational material required to be developed by the County is not in-clusive enough. For instance, not included are cor-

O 8 16 (a)

G.I.a. thru tain protective measures such as relocation centers G.1.d.

(cont'd) and radioprote crive drugs, and the special needs of handicapped.

What the State Plan should really reflect is a synopsis i

of how Hancock County intends to implement this en-tire planning standard.

G.2. Not covered in State Plan. See comment for G.I.

G.3.a. On page 9-1, it states that the Public Information Center established in Beaver County will be the Central location for all news media. However, the Governor's Office (Press Secretary) is assigned the responsibility for all State-level press releases.

It is uncicar how these two seemingly conflicting procedures fit together.

Also, are there physical facilities for use by the media at the State EOC7 G.4.a. In general, the State has an adequate amount of appro-priate representation at llancock County and Pennsylvania EOC's to have access to all necessary information.

As such, the Governor's Press Secretary has adequate

! sources to function as the principal State spokesman.

i l There is a strong need, however, to tie it all together in an expanded public information appendix containing i

17 C.4.a. the State's concept of operations and procedures in (cont'd) this very important area. This comment applies to all elements in planning standard G.

G.4.b. It is unclear from the State Plan as to how a timely exchange of information among spokesman from different

. organizations would be accomplished. Page 18-1 seems irrelevant to this criteria.

G.4.c. Pages 9-1 and 9-2 describe the State's intention of using its EOC as the State rumor control center. lioweve r, the State Plan does not adequately discuss how Ilancock County will deal with this issue. Its appropriate that the State plan do this, since there is a great need for coordination between the County and State governments.

G.5. Appendix 10 is not an adequate reference, since it does not deal at all with the news media. The State should develop plans for an annual briefing of the news media about its FNF emergency planning in coordi-nation with llancock County, preferably through the Governor's Office.

II . Emergency Facilitics and__ Equipment Planning Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

t I

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18 H.3 and The State Plan adequately provides for the establishment H.4 of a State EOC, and for timely activation and representative State staffing of the State EOC, facility near-site EOF, Hancock County EOC representation, etc.

It would be useful for the State Plan to indicate the individuals by title and name who are to be utilized in representing the State in Hancock County, Beaver County and the facility.

H.7. Appendix 8 provides for monitoring stations to be established by the Department of Health in the 10 and 50 mile EPZ's.

TLD's will be permanently located at these monitoring stations to determine background radiation levels.

During an incident, if more monitors are needed, the State can provide additional monitors and survey equip-ment through the West Virginia State Radiological Assistance Program, which is activated through the W.V.0.E.S.

The State plans also to make use of IRAP monitoring resources.

Appendix 8, as it stands, is more a statement of general intentions than monitoring capability. How many monitoring

?

stations are to be established, and when? Where are they located? What types of equipment will be at them? What types, and in what quantity, of equipment is available

i 19 H.7. under the W.V.R.A.P.? And where is this equipment (cont'd) located?

H.10. Appendix 15 XIII-2 states that equipment will be checked and tested at least once a year. What equipment, instruments etc. Why not quarterly?

The State Plan does not address this criteria adequately at all.

H.11. The State Plan does not identify emergency equipment at all. Appendix 15,Section XIV does call for this, but the tables describing such are missing.

H.12. The State Plan does not make clear at all whether a central point is established for the receipt and analysis of all field monitoring data and coordination of sample media. Will this be out of the Hancock County EOC? -

I. Accident Assessment Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

I.7. I could not find a comprehensive description of capabilities and resources for field monitoring within the 10 mile EPZ i by the State. If the State does not intend to provide any field monitoring teams, it should clearly state so and describe the County's capabilities, or how both I

efforts will interface if the State does have monitoring l

teams for accident assessment.

i i

l L

20 I.8 I could not find any described State capability, parti-cularly concerning field level staffing and equiping of monitoring teams, for rapid accident assessment. There are no complete field teams SOP's for accident assess-ment, no discussion of monitoring team deployment times, field team communications, etc.

I.9. There does not seem to be any field capability described for detecting airborne radioiodine concentrations as low

~

as 10 uCi/cc.

I.10. This reviewer does not have the technical background.to comment adequately on this criteria. The tables provided seem to deal with known dose rates. How will projecting dose rates (estimating) be accomplished?

1.11. It is not clear at all what the planned arrangements are -

for locating and tracking an airborne radioactive plume.

Will both Federal and State resources be used? Just Federal? And how?

J. Protective Response Planning Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

21 J.2. Licensee on-site evacuation plans fall within the purview of Pennsylvania.

J.9. Appendix 15,Section VI uses the EPA PAG's for exposure to the plume. The facility recommends protective actions based on these PAG's. DER /BRP will confirm and relay this information to PEMA, who in turn informs W.V.0.E.S.

W.V.0.E.S. then informs the Department of Health. It is the responsibility of the Director, H.C.O.E.S. to implement recommended protective actions.

Will the Department of Health use the PAG's to make their own assessment, or rely entirely on PEMA? And who in the Department of Health will use them?

J.10.a. thru The Governor will order or recommend an evacuation. If J.10.d.

Governor is absent, then the President of the County Commission, then the Director of H.C.O.E.S. The rest of these four criteria are all County responsibilities.

In general, the State has not demonstrated its responsibi-lity to offer assistance to the County in such areas as j would be appropriate under these criteria; ex/ monitoring locations.

J.10.e. and Appendix 4 identifies the West Virginia Department of Health J.10.f.

as being responsible for a plan to use radioprotective drugs (KI). However, there is no plan for such in Appendix

! 15. This needs to be developed.

1

i 22 J.10.g. thru These are all County responsibilities. The State plan J.10.1.

should include at least a synopsis of how the County will accomplish these tasks, and indicate what potential State involvement, if any, is possible (and as such planned for).

J.10.m. The bases for the choice of recommended protective actions from the plume is not adequately discussed in Appendix 15. There should be n range of pre-decided decision criteria to assist in making a rapid decision.

The reference 4-1 is far too general to have planning significance.

J.11. Appendices 16 and 15 describe the activities and responsi-bilities of the Department of Agriculture and Health relating to protective measures for the ingestion pathway.

The criteria seem to be pretty well covered although final judgement will have to be deferred to the RAC.

There are some areas still requiring elaboration, however.

Dosimetry and survey equipment are planned to be drawn from State and local emergency service organizations, by Depart-i ment of Agriculture personnel. What kind of equipment?

The Department of Agriculture Plan does not tie together the protective action criteria as well as the Department of Health Plan does. One suggestion to remedy this would be a common chart for both plans linking specific PAG ranges with specific protective action recommendations.

23 J.ll. If possible, it would also be beneficial to include maps (cont'd) '

showing locations of water supplies and ingestion products, which are maintained in-house aircady.

J.12. This is a responsibility of the County. As for all elements which are County responsibilities, the State Plan should give a synopsis of the County scheme and in-tegrate possible areas of State assistance to the County.

K. Radiological Exposure Control Planning Standard Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides. -

K.3.a. In general, Appendix 15,Section XI provides a very sketchy picture at best, for determining doses and ex-posure control for emergency personnel.

The State Plan allows for the distribution of dosimetry equipment by the County OES organization. W.V.0.E.S. and the Department of Health will obtain additional dosimetry from the Federal Government to satisfy unmet needs. If this is the case, then the types and amount of dosimetry equipment available should be described and so must the types and amount of equipment expected to be provided by the Federal government.

24 K.3.a. Whole body and organ scanning will be performed on a (cont'd) small sample of emergency workers. Also, there will probably be only one TLD badge per group, when available.

Before they are available, in-place TLD's will be relied upon for estimating exposures. From this discussion, there is no understanding gained concerning 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capability for reading the available dosimeters. There is definitely an insufficient number of TLD's. And there are no pro-visions described for self-reading dosimeters.

K.3.b. I could not find any provisions for the reading of TLD's at appropriate frequencies. Such frequencies should be established in the Plan, and then taken into account in the planning.

Also, how will dose records be maintained?

K.4. County and local emergency workers must be authorized by the Director of the County OES, and then the individual's agency chief, to exceed the exposure recommended by the EPA PAC's.

State personnel need the approval of the Department of Health and W.V.0.E.S., and the individual's agency chief, to exceed the PAC's.

The concept of operationn here seems adequate. Ilowever, referring back to the comments for K.3.b. and K.3.a., this whole process hinges on the State's capability for l

l accurately determining an emergency worker's dose or ex-l posure.

l

25 K.5.a. Action levels for determining the need for decontamination are covered in Appendix 15,Section XI -4. I will defer any comments on these to the EPA RAC member.

K.5.b. The means for radiological decontamination and waste ,

disposal are the responsibility of the County. The State Plan, then, should give a synopsis of how the County will accomplish this, and outline any arean where State assistance would be appropriata.

{

L. Medical and Public Health Support Planning Standard Arrangements are made for medical services for contaminated injured individuals.

L.1. I could not find any description of arrangements for local and back-up hospital and medical services specific to radiation exposure and associated contamination problemsc, Appendix 15,Section XII, Table A is supposed to list hospitals and medical facilities. It was not in the plan, however.

L.3. Nothing in this critoria was present in the State Plan.

It needs to be developed, in coordination with the County.

L.4. The transporting of victims of radiologieni accidents to medical facilities is assumedly a County responsibility.

If so, a synopsis of the County capability should be pro-vided. The State should also indicate how it would assist, if needed, in this effort. At any rate, this criteria is not covered at all in the State Plan.

26 M. Recovery and Reentry Planning and Pontaccident Operations Planning Standard General plans for recovery and reentry are developed.

M 1. In general, the State Plan does not contain very much in the way of procedures for reentry, recovery, and the decision process to relax protective measures.

Page 7-1 says the decision to reenter comes from the Gove-nor or President of the County Commission. Which one will it be, and under what circumstances?

Appendix 15 Section X says an agreement will ty; established between the Department of livalth and other State agencies with regard to exposure monitoring for emergency workers.

This must be done before formal submittal of the State Plan, and included in such.

M.3. The means for initiating a recovery operation, and its organizational ramifications, are not c1carly described.

The best way to handle this would be the designing of a recovery S0P for every involved agency, or a master S0P

\

covering all agencies.

M.4. The State plans to rely on IRAP, particularly the EPA, for periodically estimating total population exposure. This in acceptable, although the State should make specific provisions for EPA staff to perform this function (i.e.,

where will they be located, how w!!! they interface with the Department of Ilealth, etc.),

b

27 N. Exercinen and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic i drills are (will be) conducted to develop and maintain i

key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

i N.1.a. This criteria is adequately covered.

a j

N.1.b. There is no mention of times of exercises, weather condi-tions, and unannounced exercises.

N.2.a. Communications between State and Federal organizations are planned to be conducted on an annual basis. The criteria calls for quarterly testing.

Also, there is no mention in the drills section for assessing the understanding of message content.

'i N.2.d. For radiological monitoring drills, there is no mention of local participation, which would be appropriato in this circumstance. Also, there is no mention of record-kooping and communications associated with the sampling.

1 i

i N.2.o.l. No discussion is given as to what actually constitutes a health physics drill.

I N.3.a. There is no mention of evaluation criteria.

i c

o .

28 N.3.b. Adequate.

I N.3.c.,d., & e. Verbatim from N-0654.  ;

i No mention is made of advance materials to be provided to N.3.f.

l of ficial observers. t i

N.4. There is no mention of a formal evaluation.

N.5. Verbatim from'N-0654. The State Plan must describe how l this will be done.

0. Radiologient_ Emergency Responno Training Planning Standard i ,

Radiological emergency response training is provided to those who may be called on to assist in an emergency.

0.1. What are the W.V.0.E.S. training procedures which page 11-1

• says will be used for conducting training? Also, what

)

specific otganizations will requito training of their personnel, and how many?

0.1.b. What organizations? What mutual aid agreements?

O 0.4.a. The directors or coordinators should be identified by j organisation.

i 0.4.b. Personnel responsible for accident assessment should be identified. i 0.4.c. Radiologient monitoring teams and analysis personnel aro

! not montioned, avon by category (i.e. a verbatim quote).

29 l

l 0.4.c. This is a very important group which must be accounted (cont'd) l for, both here and elsewhere in the plan.

0.4.d. The State indicates it may assist Counties in the training of police, security, and and fire fighting personnel.

l This is not an adequate training committment.

l 0.4 f. The State's committment to first aid and rescue personnel is not adequate. See previous comment.

l t 0.4.h. The State should specify and identify the medical support personnel to be involved in training.

l

! 0.4.J. There is no mention of personnel responsible for trans-mission of emergency information and instructions in the Plan. These personnel should be identified and included for appropriate training.

0.5. Verbatim from N-0654. There are no details provided, no

! demonstrable committments to training, etc. In general, l

what still needs to be done in addition to all the above comments, is for the State to develop a comprehensive l

schedule of appropriate training courses for its effected personnel. Courses offered by FEMA should be utilized, along with possibly some offered in adjacent States. What about in-house training 1 P. RffPE!tajAi_lity_for the P1n,nning, Effort: Devo1opment, forlodic Hcview and Distribution of Emergency Plans p

_lanning Standard Responsibilities for plan development and review and for L----__ _ __ _ _ __------__ _ _---__--____ __ ___---

.'e 30 P. Planning Standard (cont'd) distribution of emergency plans are established, and planners are properly trained.

P.1. The State has not adequately provided for the training of individuals responsible for the planning effort.- In its

, training appendix the State should develop a list of those requiring training, their training needs, and provide for training courses to meet those needs.

P.2. In Appendix 12, the Director of Planning, WOES, is assigned overall planning responsibility. This is adequate.

P.3. Responsibility of Director of Planning, WOES. Adequate.

P.4. Adequate.

P.5. For the purpose of clarity, the plans should list those

• organizations which would receive updated planning material.

P.6. Adequate.

P.7. Appendix 17 does not address this criteria. A new appendix needs to be developed which lists all implementing pro-cedures which effect this Plan. Included in this list l should be a cross reference to the sections of the plan l

impacted.

l P.8, The cross reference supplied with this plan is inadequate.

! It is much less specific than it should be.

l t

.f.

)

c 31' P.10. The reference given, page 12-1, is not inclusive enough..

All telephone numbers relevant to the State Plan should be updated quarterly. The same goes, of course, for-

, changes in personnel.

O t

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2, SEP'l 51982 Mr. Cecil Russell Director r s Office 'of Bsergency Services State Capitol Building Room EB 80 Charleston, WV 25305 s ,

Dear Mr. kusacil:

s Enclosed are the counents of Region 111's Regional Assistance Comnittee (RAC) relative to the West Virginia State Radiological Ersergency Plan for the Beaver Valley Power Plant facility.

The drsft plan already meets many of the planning standards and criteria outlined in NUREG-0654/FDIA REP-1, Revision 1. Those areas which are still inadequate are identified in these RAC covements, which also provide a clear indicat' ion of the detail and procedures necessary to achieve a more complete response to the Federal planning standards. If you or nenbers of your staff have questions concerning these comments, please contact Joseph N. Zagone directly. .

Sincerely, s

N John Wo. Brucker Regional Director Enclosures cc:

File Chron Read File h/

J4N.Z go e:me:9/14/82

'l / r l' tf

N TlSl82 - f

. _ . . _ . - ~ _ , _

s s

4 1 1

Regional Assistance Committee (RAC) Review and Comments on the '

West Virginia State Radiological Emergentf Response Plan Beaver Valley Power Station General Comments t

I

1. The plan is difficult to use in its present organization. The pages should be numbered and a consistent organizational framework for the annexes and appendices should be used. The table of contents should be consolidated and expanded to provide a reader subject reference.

2. On page 11-16, Federal roles are briefly summarized. The Environmental Protection Agency (EPA) is not mentioned in this summary although the role is detailed in later sections. This could be misleading to a person using the summary in order to locate the help needed.

3. On page 8-1, it'is noted that all of the State monitoring equipment is in <

l Charleston (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> away) and there is no equipment capable of measuring radioiodine. If this is not covered by the County, it is a serious deficiency.

4. On page 11-1, the training section is not nearly specific enough. Detailed training was not discussed in the individual SOPS.

5. In section 4.1.2. the statement is made that "it is reasonable to assume"

that EPA support would be provided. The State should be aware of the

! specific capabilities of EPA and should include them in the plan so they-know l what to ask for. ,

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6. West Virginia University and. Marshall University are identified as possible

, sources of laboratory support. It would be helpful to know the resources and capabilities of these labs and to have agreements to provide support in an emergency. This is especially important in view of the long distance and minimal capabilities of the State.

7. In section 2.2, it is clearly identified that there is insufficient dosimetry for all emergency workers. The plan suggests that one dosimeter could be sent out with each group of workers. This is clearly inadequate. Each person working in the plume should be euqipped with a TLD or film badge and should also have high and low-range direct-reading dosimeters. Also, the frequency of dosimeter reading quoted (i.e., daily) is clearly inadequate.

8.- On page 19, the Chart, " Interrelationships of State, Local, Federal and Private Organizations" should have the United States Department of Agriculture added as a response agency under FEMA Region III.

9. In Annex 24, " Acronyms," there should be added: USDA - U.S. Department of Agriculture.

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• Specific Commento A - Adequate I - Inadequate Element Rating Comments A.I.a. A The Plan defines the State, local, Federal, and private sector organizations (including facilities), that are intended to be part of the overall response organization for Emergency Planning Zones.

A.1.b. A The Plan has a concept of operations and explanation of organizational relationships for the major operational organizations. However, some improvement is needed in supplying additional concept of operations for those organizations that have lesser roles. These would include West Virginia Department of Highways, American Red Cross, RACES, and others.

A.1.c. A A.1.d. A NUREG-0654 clearly requires of each organization the manning of a specific individual by title who is to be in charge of emergency response. This information can be gleamed from the body of the Plan, but should be set out clearly in a separate sheet or bold print.

A.1.e. A A.2.a. A A.2.b. A A.3. A A.4. A C.1.a. A C.1.b. I NUREG-0654 requires a tabulation of Federal resources expected and the time of the resource arrival at each specific nuclear facility site. This requirement may be taken care of by reference to the Pennsylvania REP plan.

C.I.c. A Specific licensee, State and local resources are not tabulated in a concise format, but are referred to throughout the Plan. A possible improvement would be a

" quick reference" chart with operational organizations on one axis and resources on the other.

C.2.a. A C.3. A C.4. A D.3. A i

Element Rating Comments D.4. A E.1. A E.2. A E.5. A There is no clear specification of who has the responsibility to notify the broadcast media (EBS).

However, the counties have access to EBS and public media, and have EBS plans.

E.6. A The alternate.to the President of the United Hancock County Firefighters should be identified in case of the President's absence during a radiological emergency.

E.7. A More detail should be added to messages, i.e.,

respiratory protection, evacuation routes, etc.

F.1.a. A F.1.b. A F.1.c. A F.1.d. A F.1.e. A F.2. A The County is responsible for the coordinated communication link for fixed and mobile medical support ,

facilities.

i F.3. A l G.I. I Responsibility for the dissemination of public information is laid on the county and local organizations. However, there is much information that could and should be supplied at state level, and a schedule for distribution should be established.

G.2. I The state may pass this responsibility on to the county, but a monitoring effort should be established to assure the requirements are being met. This monitoring effort l

should be part of the radiological emergency response plan.

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G.3,s. A Actual sites for rumor control stations should be l specified.

I G.4.a. A G.4.b. A-

e Element Rating Comments G.4.c. A See comment on G.3.a. above.

G.5. I There does not seem to be a program designated to acquaint news media with the emergency plans, etc. for the State of West Virginia.

H.3. A H.4. A H.7. A H.10. I The plan does not specify the provisions made to inspect, inventory, and operationnally check equipment. The plan states it will be done, but does not specify when, where, or how. There is no specification of replacements for inadequate equipment.

H.11. I Tabs A, B, and C in Annex 15,Section XIV of the Plan are missing and should be supplied.

H.12. A There should be a preselected designated facility described in the plan such that a team could simply pick up the plan, turn to the proper section, and know where to phone in their data.

I.7. A Found in Annex 8 and 15 (IX).

I.8. A I.9. I No mention of equipment with the stated capability is made. However, this capability is probably in support agencies.

I.10. A I.11. A J.2. A More details in Hancock County Plan.

J.9. A J.10.a. A Relies on County Plan.

J.10.b. A Relies on County Plan.

J.10.c. A J.10.d. A J.10.e. A

Elcment Rating Comments J.10.f. A J.10.h. I State plan should note the relocation centers in host areas, especially those outside of Hancock County.

J.10.1. I State plan should note non-county evacuation routes.

J.10.j. A Found in WVEDP.

J.10.k. I State plan should identify alternatives for non-county evacuation routes.

J.10.1. I State plan should show time estimates for evacuation routes that are out-of-county.

J.10.m. A J.11. I NUREG-0654 specifcally requests maps for recording survey data, key land use data (e.g., farming), dairies, food processing plants, water sheds, water supply intake and treatment plants and reservoirs. The maps shall start at the facility and include all of the 50 mile ingestion pathway EPZ. Also, there should be up-to-date lists of the name and location of all facilities which regularly process milk products and other large amounts of food or agricultural products originating in the ingestion pathway EPZ, but located elsewhere. This information may exist elsewhere and could easily be included by reference.

J.12. A Relies on County Plan. Could be improved by providing additional detail on the evacuation and monitoring requirements.

K.3.a. A j

K.3.b. A Should be elaboration on reading and recording dose rates.

K.4. A K.5.a. A L.1. I The West Virginia Department of Health probably has the information appropriate for this requirement, but it is not referenced in this plan.

L.3. I The annexed West Virginia Department of Health Plan refers to a " Tab A" which is not there. This omission should be corrected.

L.4. I A reference should be developed for transporting victims i of radiological accidents to medical support facilities.

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56 Element Rating Comments M.I. A M.3. A M.4. A N.I.a. A N.I.b. A N.2.a. A N.2.d. A N.2.e.(a) A N.3.a. A N.3.b. A N.3.c. A N.3.d. A N.3.e. A N.3.f. A N.4. A .

N.5. .A 0.1. A 0.1.b. A 0.4.a. through 0.4.J. except for O.4.e. and 0.4.1. are Not Acceptable. Although the State does not have the resources to present training, there should be some indication of available training from other sources. Who is eligible to go and on what time schedule should be presented. In other words, the State has the responsibility to get the personnel trained, although not able to present the training itself. I suggest that the State compile a list of available courses and their sponsors and a corresponding list of personnel needing training and match the two in a scheduled format.

0.5. A See comment above.

P.I. A P.2. A

Element Rating Comments P.3. A P.4. I The State should specify agreement with the facility for review and update of the plan as called for in NUREB-0654.

P.5. A P.6. A P.7. I A Procedures appendix should be prepared. This should be a list of activity phases and what procedure should be implemented at each phase. These procedures should then be referenced to the proper section in the plan.

P.8. A P.10. A f

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?

OCT 5 882 i

Mr. Cecil Russell I Director

% Office of Energency Services Room EB 80 -

State Capitol Building

Charleston, WV 25305

Dear Mr. Russell:

Enclosed are the corrients of Region III's Regional Assistance Connittee (RAC) relative to the l'ancock. County, West Virginia Fadiological Emergency Plan for 4

the Beaver Valley Power Plant facility.

The draf t plan already meets many of the planning standards and criteria i' outlined in .VJREG-Of,54/FDIA REP-1, Revision 1.

Those areas which are still f! inadequate are identified in these RAC corrents, which also provide a clear

', indication of the detail and procedures necessary to achieve a nore complete response to the Federal planning standards. If you or menbers of your staff j have questions concerning these co~unents, please contact Joseph N. Zagone directly. .

7 S' cere1 ,

r Jo 1 th. Brucker Peg onal Director 1; Enclosure 1

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CC:

. - File

!. Chron h

J.N. Zag c:90/4/82

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Regional Assistance Committee (RAC)

Review and Comments on the Hancock County, West Virginia Radiological Emergency Response Plan -

Beaver Valley Power Station General Comments

1. Pages should be numbered and the Table of Contents should reflect these numbers.

2. Under Definitions:

a. Under Alert, change to read:

... indicate an actual og; potentially substantial degradation...

b. Under General Emergency, add as first phrase An emergency classification.

Also change last sentence to read: Off site protective actions most likely.

c. Under' Site Area Emergency, add as first phrase An emergency classification. Also change last sentence to read: Off site protective actions may bji necessary.

3. Under Section 2.6.4. General Emergency, paragraph 4, change to read:

... required actions will include activation....

4. Under Annex E, Accident Assessment; under Section 3. County and State Government; ,

a. Wording should be modified to show that the County only has the capability to confirm dose rate projections and will be supplemented by State projections for airborne (iodine) thyroid dose and ' projected total dose.

b. Under paragraph 2: change second to last sentence to read: ... survey data to confirm the facility operator's off site dose rate projections can be available.

c. Under paragraph 4: modify wording to stress that the RADEF officer should also coordinate with State liaison on protective action recommendations if time permits.

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l 5. The county plan should address internal (inhalation) contamination to the workers and the general public and the need for follow-up surveys and bioassays. This can be done by reference to State plan or other assistance groups.

l 6. Under Annex H:

l Section 5. Control of Internal Exposure; paragraphs 2 and 3 talk about both respirators and SCBA. The present wording and sentence structure i could lead to the erroneous conclusion that SCBA is ineffective against noble gasses. The statements should be rearranged to avoid confusion.

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7. Under Annex J:

a. Section 2. Medical Support: The Emergency Medical Services Council should have a designated organization to report to, and it should be explained how the EMS Council interfaces with the State Department of Health,

b. Under Section 3. Public Health, under subsection 3): The plan should state who is responsible in the Public Health organizations for monitoring potentially contaminated supplies and where and what kind of equipment they will have. Also, there should be a statement of what level of radiation is acceptable.

8. Under Annex K: The discussion in subsection 4. should be expanded to include monitoring, decontamination, and accident assessment drills and a frequency should be recommended for all drills.

9. The Appendix 1 to Annex M should be provided.

10. References to the interim use of the route alerting procedure pending installation of the siren system should be eliminated. The third paragraph of Annex P has one such reference.

11. All tables that have information that could change with time should be dated and have a revision number. An example is the EAL table in Annex Q.

12. Under S0P #1:

a. Under section 3.0 Responsibilities add:

3.1.8 Habitability 3.1.9 Assessment

b. Under section 6.0 Procedure there should be a subsection showing the appropriate action steps for surveying.

13. Under SOP #2, attachments #1 and 2 should be made available and the notification procedure should also include de-escalation notifications.

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14. Under S0P #5:

a. Under section 4.0 Precautions, subsection 4.7, there should be a backup

method of communication for RADEF survey personnel. Emergency contact phone lists and change for pay phones should be available in survey kits.

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! b. Under subsection 6.1.5, there should be an explanation of what to do if the State cannot be contacted.

! c. Under subsection 4.4: Regarding radiological monitoring, it is indicated I that a handkerchief or scarf over the nose and mouth should be part of the dress for the survey team personnel. This seems to imply that this action af fords protection f rom particulate inhalation. If in fact it is considered necessary to provide protection from inhalation, this should be accomplished by using appropriate respiratory protective equipment as a handkerchief or l

. i scarf affords little protection from such hazards. If respiratory protective equipment is required, then an appropriate respirator program (e.g., fit testing, training, etc.) is required. A decision on this issue would most appropriately be made through the joint efforts of county and state personnel.

15. Under SOP #6, subsection 6.4.3., there should be a clarification of the dosimeter range for the high range dosimeter.

16. Under S0P #8, there should be a discussion of:

a. If contamination is found among the populace, when will decontamination be conducted and what attempts will be made to track where those persons have been.

b. How to communicate back to RADEF officer when contamination is found in general populace.

c. Procedures for separation of contaminated persons by degree of contamination and methods recommended for follow-up.

17. In SOP #9, attachment #2, there should be a warning against evacuating at this time because of the risk of receiving radiation exposure and that the release will be short term, etc.

18. The background discussion on radiation is quite useful in providing insight to county personnel whose main expertise is not in the radiation field. It is a good feature.

19. In Annex C, the notification list given should include telephone numbers. In addition, it would be helpful if the caller were instructed as to a priority order for the calls in view of the length of the list. This may be the order given in the list, but an explicit instruction would be helpful.

20. The long transit time to the state offices places a great burder on the county.

For example, the four-hour transit time for the state monitoring teams places the burden on the county if radiological monitoring is to be performed within a reasonable time of a sudden occurrence. When one adds the transit time to the time needed to issue equipment and get on the road, a state response to an incident could probably not be expected within five hours of an incident. In addition, the state monitoring capability does not appear to be complete - in particular there is no capability to measure radioiodine. Since the bulk of the monitoring capability seems to rest with the county, it would make the best sense if the county were to obtain a SAM-2 or other instrument capable of radioiodine measurements.

21. In radiological monitoring, the civil defense survey meters are often used to measure the gamma radiation from noble gasses, but since the county is heavily involved in monitoring, there should be a cautionary statement in the SOP which describes the energy-dependence error associated with the low-energy gamma from 133 Xe. This can result in a substantial error in the readings obtained with a G-M survey meter.

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22. In addition to the fact that they are in the residences of the emergency workers, the number of survey meters available in each district should be specified in the plan. Also, as noted previously, there is no capability to measure radioiodines. It would make sense for the county to assume this responsibility unless one of the University labs mentioned is equipped to do so.

In any case, the capabilities of the University labs and support agreements should be in the plan.

23. In personal dosimetry, the plan shows good use of the ALARA concept in attempting to limit emergency worker dose to the 5 REM PAG for the general public. Also, the l introductory section on radiation fills the need to explain to decision-makers the consequences of emergency exposures. Note, however, that the dosimetry planned for issue to emergency workers is not adequate. It is highly desirable to include a TLD or film badge along with the direct-reading dosimeters because it provides a permanent record. In addition, the dosimeters can show erroneous readings due to electrical leakage or mechanical shock. A TLD is not subject to these effects and so can confirm or deny that an excessive dose has been received. Also note that the range of the dosimeters to be provided is too low. The plan specifies 0-1 or 0-5R units for the high range and 0-200mR units for the low range. The recommended ranges in FEMA-REP 2 are 0-20R for low range and 0-200R for high range.

24. Note that the county plan specifies dosimetry for every worker while the state plan provides a dosimeter for each group of workers. This conflict.should be resolved in favor of issuing dosimetry to every worker. The number of available dosimeters and their location should be specified in the plan. The daily reading frequency specified as a minimum in the plan is insufficient. The recommended 1/2 hour reading time should be mandatory. Also note that the self-reading dosimeters are not subject to the energy dependence error associated with the survey meters, .

so they might be used by survey teams as a supplementary measurement.

25. There is no designation of airports and other local facilities for use by Federal assistance teams.

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Key to Rating

, A = Adequate

! I = Inadequate Element Rating Comments A.1.a. A Appendices 1-1, 2-1, 3-1, 7-1 Pages 9-16 A.1.b. A Pages 16-22 Appendix 2-1 A.1.c. A Appendices 1-1, 3-1 A.1.d. A Page 9 Appendices 1-1, 4-1 Although the plan establishes the Commissioner as the person responsible for emergency responses, and the Emergency Management Coordinator as the implementor of emergency response, a statement should be added which individual is in charge of the emergency i response.

A.1.e. A Annex B-2 It shauld be clearly stated that the Emergency Response organization is prepared for response 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

A.2.a. A Appendices 2-1, 4-1, 3-1 Pages 9-16 A.2.b. A Page 1 A.3. I Annex T must be expanded to show that the agencies and organizations mentioned in the body of the plan agree to provide the support as mentioned in the plan. An acceptable alternative would be for the plan to have a signature page which would serve to verify the agreements. A notation indicates this will be provided at a later date.

A.4. I Annex B.3.

Although the plan obliquely refers to the Emergency Management Coordinator as the person responsible for assuring continuity of resources (technical, administrative, and material), it does not clearly state that. A sentence should be added to the explanation in part K., Section E, page 12-13, under paragraph 1. " Emergency Management Coordinator" saying that he has been given the responsibility for assuring continuity of resources (technical, administrative, and material).

C.1.c. A Covered in detail in the State Plan.

C.4. A There are no letters of agreement in the County Plan, but the State Plan covers identification of nuclear facilities and various agreements. The County Plan identifies hospitals that can handle irradiated or contaminated individuals in Annex G, Appendix 6.

Element Rating Comments D.3. A Parts 2.5 and 2.6 Pages 2-17 and 2-18 D.4. A Section 4, pages 4-1 through 4-7 E.1. A Section 4 Annex C E.2. A Section 4 Annex C Annex D.3 E.5. A Section 4 Annex P E.6. A Section 4 Annex P E.7. I There are no draft written messages that tell the public about emergency respiratory measures to take. Messages should be written and copies should appear in the Plan. As note indicates these are to be provided in future.

F.1.a. A SOP #4, part 3.1.1.1 Annex D, Communications Section 4.3 and 4.4 F.1.b. A Section 4 -

Annex B, part 4.0 Annex D F.1.c. A Annex B Also covered in State Plan f F.1.d . A Annex D i F.1.e. A Sections 3 and 4 Annex D F.2. A Annex D F.3. I Annex D and Annex M There is no provision documented to inspect, inventory, and operationally check emergency requipment/ instruments at least once each calendar quarter and af ter each use. There is no mention of I reserve instruments for use when others are out for repair. There l is no provision documented to test the communications with State i and local governments within the plume EPZ on a monthly basis. Nor is there mention of testing communications with Federal emergency response organizations and States on a quarterly basis.

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Element Rating -

Comments G.I.a.,

b.,c.,d A Annex K The plans do provide for the dissemination of information to the public regarding how they will be notified and what actions should be taken in an emergency as part of the public information program. Appropriate protective actions should be directed to

'affected farmers and other agribusinesses in the EPZ by the USDA County Emergency Board.

When requested by the State, the USDA State Emergency Board will aid recovery efforts by providing economic assistance from regular Federal assistance programs. Cost share financing may be available to farmers and other rural residents in rehabilitation efforts; dairy farmers will be indemnified for milk removed from commercial channels; loans and other assistance may be provided to farmers, ranchers, agriculture and other rural residents.

Other assistance will be available from regular USDA programs as necessary. Assessment of damage to crops and livestock will be performed by the SEB through the County Emergency Boards (CEB).

The CEBs will estimate damage based on radiological contamination and monitoring data. Damage reports will be made to the USDA SEB for consideration in emergency relief programs.

G.2. A Annex K G.3.a. I There was no designated physical location specified for use by news media. Although the PIO was designated and his responsibilities were described, no location was mentioned in the ,

plan where he could be contacted.

G.4.a. A Annex K G.4.b. A Annex K G.2.c. I There is no mention of coordinated arrangemants of rumor control.

G.5. A Annex K H.3. A Section 3 Annex N.2 H.4. A Section 4 Annex N.2 H.7. -

A Not appropriate H.10 I See F.3.

H.11. I The listing of emergency equipment should be in Appendix 1 of Annex N, but the appendix is missing. There is a note that it will be provided at a later date.

Element Rating Comments H.12. A Annex B I.7. A Annex E - It would be useful to have the type and capability of the instruments listed.

I.8. A Annex E, Section 4, Annex N The County depends heavily on the State capabilities.

J.9. A Annex 0, Annex P, Annex F Annex G, Annex H 4

I.10. A Annex H, Annex E, Annex F, Annex G Sampling and monitoring largely handled by State. However, maps showing monitoring points and sampling points would improve this plan.

J.10.b. A Section 2 Annex H J.10.c. A Annex P Section 3 Annex H J.10.e. A Annex G, Annex I, Annex 0 Primarily a responsibility of the State Health Organization and covered in the State plan.

J.10.f. A Annex G, Annex I, Annex 0 Covered in the State plan. .

J.10.g. A Annex H J.10.h. A Annex H J.10.i. I Annex H gives some indication but more information must be

provided. A note indicates it will be provided in the future.

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J.10.j. A Annex H J.10.k. A Annex H J.10.1. A Annex H f J.12. A Annex H, Annex I i

K.3.a. A Annex I The We st Virginia Office of Emergency Services has primary l responsibility for monitoring personnel radiation exposure.

l K.3.b. A Annex I i

K.4. A Annex I l

Element Rating Comments K.5.a. ~A Annex I K.5.b. A Annex I Primary responsibility for decontamination lies wth the State.

L.1. A Annex J L.4. A Annex J M.1. A Annex L N.1.a. A Annex M N.1.b. A Annex M. This Annex should mention that the exercises are followed by critiques; have the scenario varied from year to year; that all major elements of the plans and preparedness organization are tested within a 5 year period; that exercises will be scheduled to start between 6:00 PM and midnight or midnight and 6:00 AM once every 6 years; and that some exercises will be unannounced.

N.2.a. I See F.3.

N.2.d . I " Refer to State Plan" is not sufficient. The County plan should emphasize the State Plan by rewriting the County's portion.

N.3.a . A Annex M

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N.3.b. A Annex M N.3.c. A Annex M N.3.d . A Annex M N.3.e. A Annex M N.3.f. A Annex M i N.4. A Annex M l

N.5. A Annex M

, 0.1. A Annex M and SOPS 1

t l 0.1.b. A Annex M i

l 0.4.a. A Annex M The Director should be mentioned directly and specific training at specific intervals should be scheduled and shown.

0.4.b. A Annex M

6*

Element Rating Comments 0.4.c. A Annex M 0.4.d . I There is no mention of specific training for police, security, and fire-fighting personnel.

O.4.f. I There is no mention of specific training for first aid and rescue personnel.

0.4.h. I There is no mention of specific training for medical support personnel.

0.4.j. A Annex M There should be specific references to specific training for personnel responsible for transmission of emergency information and instructions.

0.5. A Annex M P.1. A Annex A P.2. A Annex A P.3. A Annex A P.4. A Annex A P.S. A Annex A P.6. I There is no list in the plan, but a notation that such a list will be provided at a later date.

P.7. I This plan does not contain the title listing of procedures required to implement the plan. However, it is noted that this will be provided in the future.

P.8. A Table of Contents P.10. A The plan should note specifically who is responsible to update these telephone numbers.

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January 10, 1986 Mr. Mannie R. Griffith, Director Office of Emergency Services State Capitol Building, Room EB-80 Charleston, West Virginia 25305

Dear Mr. Griffith:

Enclosed are two (2) copies of the FEMA Region III/ Regional Assistance Committee evaluation of the Radiological Emergency Response Plans for the Beaver Valley Power Station which were submitted for formal review and approval. The evaluation has identified twenty-three (23) planning inadequacies. We request that you provide one copy of the report to Hancock County Office of Energency Services.

As soon as the twenty-three (23) inadequacies are adequately addressed in the State and county plans, FEMA Region III will subnit them to FEMA National with the recommendation that formal 350 approval be granted.

If we can be of assistance in addressing the inadequacies, please contact Janet Lamb, Project Officer for Beaver Valley, at ( Area Code 215) 597-1789.

Sincerely, James R. Asher Chairman Regional Assistance Committee Enclosures cc: Sam Paletta Duquesne Light c-Rdg Chron [

RD Chron t File NTH /JLamb/1789/jj/1-10-86 x..

ORibeN A T OR CONCuRAENCE CONCUREENCE CONCURAENCE CONCURRENCE CONCURRENCE JLamb JAsher Name lb y d Oate , { {.[

. --gg OFFICIAL RECORD COPY ,

.u.s. cm 19a3-6ce

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• l BEAVERVALLEYPO$ERSTATION EVALUATION OF STATE AND LOCAL PLANS SUBMITTED FOR FORMAL REVIEW AND APPROVAL BY THE STATE OF WEST VIRGINIA 6

FEDERAL EMERGENCY MANAGEMENT AGENCY REGION III JANUARY 1986 l

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BEAVER VALLEY POWER STATION EVALUATION OF STATE AND LOCAL PLANS SUBMITTED FOR FORMAL REVIEW AND APPROVAL l'"16tr6866ti66 A."Ni10iti66'Bibligr666a This report represents the Regional Assistance Committee, Region III evaluation of the State and local Radiological Emergency Response Plans (RERPs) submitted by the State of West Virginia for formal review and approval, in accordance with the Federal Emergency Management Agency's (FEMA) regulations published under 44 CFR 350. The planning package submitted included the Radiological Emergency Response Plan for the State of West Virginia and the Radiological Emergency Response Plan for Hancock County, West Virginia. This evaluation incorporates all plan changes which have been submitted to date.

Previous plan evaluations for the West Virginia plans were submitted by the Office of Emergency Services in March 1981, December 1981, October 1982, and January 1984.

A separate review entitled Beaver Valley Power Station Alert and Notification Evaluation was completed in conjunction with this review of the radiological emergency response plans. The findings of that report, which was submitted to West Virginia Office of Emergency Services on August 20, 1985, have been incorporated into this evaluation.

B '. ' Scope'of Revibw This Report includes evaluations of the following Plans:

1. " West Virginia Emergency / Disaster Plan " West Virginia Office of En:ergency Services, May 1981.

2. " West Virginia Radiological Emergency Preparedness Plan,"

West Virginia Office of Emergency Services, 1983, with change, March 1985.

3. "Hancock County Radiological Emergency Response Plan for the Beaver Valley Power Station," Hancock County Office of Emergency Services, May 1985.

4. Local EBS Operational Area Plan for Wheeling, West Virginia.

1

5. " Beaver Valley Emergency Alert and Notification System Design," Duquesne Light, July 1984.

II. Pli6616g'Evi16iti66 The plans are evaluated against the criteria of Planning Standards A through P, as established by NUREG-0654/ FEMA REP-1, Rev.1.

Additional evaluation criteria for Planning Elements E.5, E.6, F.1, N.1, N.2, N.3, and N.5 are provided by FEMA-REP-10, (formerly FEMA-43.)

A F ' " Asii66fn&6t ' 6 f ' Riip66ii 6111t9 ,

All response organization have been identified in both state and county plans. The state plan refers to federal participation and addresses each federal agency separately.

The plan should be updated to reflect the Federal Radiological i Emergency Response plan (FRERP) published on September 14, 1984 With the FRERP, federal response is now a single phone call away, if a state requests it. EPA has been noted twice, item 9 and item 11, in the listing of federal agencies. Item 9 is obsolete and should be deleted.

Concepts of Operation and interrelationships to the total response effort have been provided for each organization and suborganization at the state and local level.

Block diagrams and charts depict interrelationships and functional responsibilities of organizations at each response location.

The West Virginia State' plan implies that the Office of Emergency Services uses a duty officer system to maintain 24-hour notification coverage. More detailed procedures on how the duty officer system works should be included in the state plan.

The Hancock County Emergency Communications Center and the Beaver Valley Power Station are manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week.

The state and county plans do include a table of primary and support functions of major elements and key officials of emergency response organizations. However, the state plan, on page 8 indicates that the Department of Health is responsible to assess the situation and to advise the Governor and local officials of potential radiation problems to the public and to make recommendations for applicable protective actions. It is understood that each element of response should list one primary responsible organization; however, in this case it may be clearer if a primary organization was included for each level of response as was done for command and Control, since all levels will have responsibilities when protective actions are initiated.

2

The appropriate authorities, laws and references have been included in the state and county plans to permit response in an emergency.

The State of West Virginia Office of Emergency Services has entered into mutual aid agreements with the Comonwealth of Pennsylvania, the Duquesne Light Company, the American Red Cross, the West Virginia University Medical Center, Marshall University and with the United States Department of Energy.

During an emergency in any portion of the state, the Governor may be required to activate the state EBS Operational Plan in order to provide infonnation to residents of the State of West Virginia. Letters of Agreement should be established with the CPSC-1 radio station for West Virginia and with the RACES organization who is listed in the plan to provide backup comunications for the state. All letters of agreement should be included in the state plan at Annex 20.

The Hancock County Emergency Response Plan contains Letters of Agreement with various agencies who have accepted responsibility to provide assistance during an emergency at the Beaver Valley Power Station. The Letters of Agreement do not state specifically what service or assistance will be provided. In addition, there are no letters of agreement with the School Districts who have been tasked to provide buses for

transportation of evacuees and schools to be used as mass care centers. ,

Although 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing is implied in the state plan and in Standard Operating Procedures, first and second shift personnel for each staff position in the E0C and for other state support agencies should be identified and included in the state plan.

C. ' ' Emergency Response Support and Resoubess The Federal response capabilities have been incorporated into the state plan. However, the state plan (as discussed in Planning Standard A above) should be updated to reflect the new Federal Radiological Emergency Response Plan. The West Virginia Office of Emergency Services is responsible for requesting Federal assistance.

Minimal state and local resources have been identified to support the -federal response personnel. Since the facility is located in Pennsylvania it is felt that the federal response team will locate in that state. West Virginia State will provide resources if necessary.

The state has adequately planned for dispatchina technical analysis representatives to both the E0F and Hancock County EOC. It is recommended that since the state personnel will be

providing additional dosimetry equipment to Hancock County that these people be dispatched at the alert stage in an incident.

3

4 The West Virginia Office of Emergency Services has identified two laboratories who have signed Letters of Agreement to provide technical and laboratory support to the West Virginia Department of Health. The Letters of Agreement are included at Annex 20 of the state plan.

The state and county have identified facilities and individuals who will assist in an emergency. As stated in Planning Standard A; however, the letters of agreement with these facilities or individuals should state the specific services that will be supplied, laboratory, medical emergency treatment, etc.

0 " " ' Em4 rgi6 ci ' C l iiii f i cit io6 ' Siit sin The four emergency action levels contained in the state and county plans are cons.istent with those used by the utility.

State and local plans contain procedures and checklists that provide emergency actions to be taken at each emergency classification level. Follow up notification procedures provide the necessary information to off-site response organizations from the utility on recommended emergency actions. However, the PAGs listed in the Hancock County plan on page F-2 are not consistent with EPA PAGs or with those given on page I-2 of the same county plan. There is no problem with a recommendation to shelter at a 170 m/ rem dose, but the choice of the top of the range of the EPA PAGs does not allow evacuation at the low end of the range if deemed appropriate.

Evacuation should also be a recommendation based solely on plant conditions, even if there is no projected dose and the plan should allow for this.

E. Notification' Methods and Procedures

, Initial notification of an incident is provided by the Beaver Valley Power Station to Hancock County ECC. Hancock County ECC will verify the infonnation with the utility and then notify the EOC. Backup notification procedures through Pennsylvania Emergency Management Agency and the West Virginia Office of Emergency Services have been established in the appropriate plans.

The State of West Virginia Office of Emergency Services is responsible for notification of Federal and State agencies, involved in the response operations and West Virginia counties within the 50 mile EPZ of the Beaver Valley Power Station.

The Utility is responsible for notifying Hancock County comunications center. The Hancock County dispatcher will notify the Emergency Services. Backup notification to the state is provided by the Pennsylvania Emergency Management Agency; backup notification to Hancock County is provided by 4

the Beaver County E0C. Procedures and rosters for notification of other organizations involved in the response are contained in the plans.

The Hancock County Office of Emergency Services has the overall responsibility for alerting the public within the 10-mile EPZ of the Beaver Valley Power Station. EBS stations, both CPCS-1 and CPCS-2 stations, are identified in the Hancock County Radiological Emergency Response Plans. Both stations operate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week.

The Hancock County Commissioners have designated the County Emergency Services Director as the official responsible for the activation of the alert and notification (siren /EBS) system.

Due to the unique location of the Beaver Valley Power Station (the 10 mile EPZ impacts three states, Pennsylvania, West Virginia and Ohio) the state and local plans call for the coordination of siren and EBS activation between the three states and the three counties involved.

Specific procedures for EBS activation for Hancock County officials and radio station personnel are contained in the Wheeling, West Virginia Extended EBS Operational Area Plan which is referenced as a support document in the Hancock County Radiological Emergency Response Plan.

The State Office of Emergency Services is responsible for notifying those counties within the 50 mile Ingestion Pathway and for providing information to the general public through the -

Governor's office. The West Virginia Radiological Emergency Plan should list the West Virginia EBS Operational Plan as a support document.

Hancock County participates in the Wheeling EBS Operational Area Plan. In addition, the county plan contains letters of agreement with the specific radio stations involved. The state plan should contain letters of agreement with the CPCS-1 station in Charleston. The prescripted announcements to be aired over EBS are included in the state and county plans.

Protective action announcements for sheltering will be repeated every five minutes. General evacuation announcements and school evacuation announcements will be aired continually until the station is informed to end transmissions by the county Emergency Services Director.

The Emergency Alert and Notification System Design report states that Hancock County has equipment in the E0C to monitor the EBS station to insure announcements are accurate. This has been observed to be correct in past exercises. In addition, copies of prescribed messages have been provided to EBS stations, thereby precluding the station from broadcasting erroneous infonnation.

5

The primary means of alerting the public is via a siren system which is installed within the 10 mile EPZ of the Beaver Valley Power Station. Special alerting requirements have been well documented in the county plans. Specific route alert teams have been assigned and route maps included in the plan.

The utility is responsible for provision, operability and maintenance of the siren system. Hancock County, in coordination with Pennsylvania, Ohio and West Virginia OES, is responsible for activation of the system as needed.

The county plan contains pre-scripted messages which include instructions for specific protective actions.

F.'Em4rgi6ci'06mm06ibiti66i Provisions have been made for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification and activation of state and local response functions. However, although the state plan implies that a duty officer system is used to maintain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage, specific procedures should be included in the state plan. .

l Communications with the Pennsylvania Emergency Management

! Agency, Ohio State Disaster Agency and the Federal Emergency l Management Agency will be via telephone, dedicated hot line, CDNARS, CDNATS and NAWAS.

Hancock County Communications Center is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Communications between the three risk counties is via ,

dedicated telephone, commercial telephone and the Duquesne Light Radio System.

The West Virginia Office of Emergency Services will communicate with federal response agencies through the FEMA Region 3 office in Philadelphia via telephone, NAWAS, CDNARS and CDNATS.

Provisions for communications with BVPS/ EOF, State EOCs, County E0Cs and radiological monitoring teams have been established in the state and local plans.

Personnel call down lists have been included in the Hancock County plans for each position. Procedures for alerting and activating emergency personnel have been included in the Standard Operating Procedures. A coordinated communications net between fixed and mobile medical support teams has been documented in the county plan at Annex R, S0P 5.

The state plans include test schedules for the entire consnunications network as outlined in NUREG-0654.

6

G: " ' P 5 bl i c ' Ed 0 c a t i 66 ' ihd ' 16 f 6 rmit i o6 Public Information brochures containing specific information as outlined in NUREG-0654 have been prepared and are distributed annually. Information to the transient population is distributed to hotels, motels and recreational areas in the EPZ. Brochures were last mailed to the public in August 1985.

In addition, full page ads are published in the local newspapers annually.

News media will be briefed periodically during an incident by the Governor's Press Secretary at the State E0C and the Hancock County Public Information Officer in the New Cumberland Courthouse. A Joint Media Center has been established by Duquesne Light. A County Public Information Officer will be dispatched to the Joint Media Center during an emergency.

The Governor's Press Secretary has been appointed as the state spokesperson. The Hancock County Public Information Officer, with the coordination and approval of the Hancock County Office of Emergency Services Director, has been designated as the County Spokesperson.

Telephone lines have been assigned as rumor control numbers at both the State and County E0Cs . Staff persons are available to man these telephone lines.

A policy of coordinating public information releases with all spokespersons has been established in the plans. The County will send a public information representative to the Joint Public Information Center who will be responsible for coordinating all public information with other agency representatives.

H'. 'Emerghncy' Facilities'nd a Equipmb6t Emergency Operations Centers have been established for both the State and Hancock County Response organizations.

The Hancock County plan does not call for activation of the t

County E0C until General Emergency. In order to respond to an emergency, if at all possible, the E0C should be activated much earlier in an incident. The State should consider mobilizing state response personnel to Hancock County earlier than the l

times specified in the plan. These people will be responsible for bringing needed radiological exposure control equipment and monitoring equipment needed to Hancock County.

I i l The State Department of Health is responsible for bringing i

monitoring equipment and personnel from Charleston to Hancock County. As stated in Planning Standard C, the monitoring equipment and personnel should be dispatched as soon as possible, i

l 7 1

> -et .

ProOisionshavebeenmadetoinventoryandcheckemergency equipment once each quarter. Calibration of equipment will occur at intervals recommended by the manufacturer.

There are inventory lists contained in the plan as to what equipment is included in emergency kits. However, the kits do not contain dosimeters of any kind, potassium iodide or communications equipment.

The State Department of Health will send technical representatives to the Emergency Operations Facility to receive and analize field monitoring data and provide protective action recommendations to Hancock County E0C and the State E0C.

I'."" Accid 56t Asi5iiin56t Field monitohing will be provided intially by the utility. The State Department of Health will deploy monitoring teams from the State E0C. Once they arrive in the EPZ, they will begin monitoring and analysis. The County RADEF Officer will serve as a liaison with State and Utility monitoring teams. He will apprise the County Director of conditions in the EPZ and provide appropriate recommendations.

Annex 15 of the State plan has provided methods, equipment and expertise for accident assessment. The annex addresses team activation, notification, composition, transportation, monitoring equipment, communications and travel time from the State E0C. It is recommended that the monitoring teams and '

Department of Health representatives be dispatched from Charleston to Hancock County earlier than the Site Area Emergency since they will be bringing additional self-reading dosimetry and TLDs with them for use by emergency workers in Hancock County.

Although Annex 15 of the State Plan includes an equipment list that shows the instruments needed to measure radioiodine concentrations are available, the specific procedures to perfonn this function have not been described.

J. Protective Re' sponse Since the plant is physically located in Beaver County, Pennsylvania, the evacuation of non-essential plant employees will be coordinated with offsite officials in Pennsylvania.

State and local plans have developed the capability for implementing protective actions which may include sheltering or evacuation. As stated in Planning Standard D, on page F-2 in the Hancock County plan, the PAGs are not consistent with EPAs PAGs, nor with those on page I-2 of the same plan. There is no problem with the reconsnendation of sheltering at a 170 m/ rem dose, but the choice of the top of the range of the EPA PAGs 8

does not allow evacuation at the lower end of the range if deemed appropriate. Evacuation should also be recommended based solely on plant conditions, even if there is no projected dose and the plan should allow for this.

Actions included in the plans to support protective actions include: activation of alert and notification systems, traffic and access control, mass care, transportation, agricultural and medical support assistance.

The plans state that the County Agent will provide technical assictance to the agricultural comunity in the vicinity to include effective liaison with the county emergency services and farmers in the affected area.

Farmers within the 10 mile EPZ may insist on reentering the EPZ to feed their livestock. If this occurs, procedures must be developed to monitor and limit radiological exposure to this segment of the population.

A method used at other sites to address this problem is the designation of farmers as emergency workers. Once this designation is made farmers would be called into a central location, issued dosimetry, KI, record keeping farms and instructions on the use of this equipment.

Radiological exposure control actions will be used to protect emergency workers. However, page XI-3 mentions dosimetry to be obtained from Federal sources. The plan also states that .

"unless additional dosimetry can be acquired from outside sources, it is unlikely that each emergency worker could be issued a dosimeter." One dosimeter per group is not suf ficient. Self-reading dosimeters are subject to mechanical shock and leakage, making them less than perfectly reliable.

The ideal complement of dosimetry is one high-range (0-200R),

one mid-range (0-20R) and a TLD. At a minimum each worker should be issued a TLD and a dosimeter.

Page VI-2 makes reference to EPAs protective action guides.

While these guides are still only recomendations and parts of them are still under development, the 1979 reference is not current. It is recommended that the latest version of the PAGs be obtained by the state and county. Reference could be made to this set and allowance made for the continuing development of the PAGs.

On page 0-3 of the Hancock County plan, the ingestion PAGs given are not consistent with the latest EPA guidance. Hancock County uses 1.5 rem thyroid dose and 0.5 rem whole body. EPA specifies these levels for preventative response and 15 rem thyroid and 5 rem whold body as emergency action levels. The 9

.05 rem PAG for water given by Hancock County conflicts with the .5 rem PAG in EPA guidance.

All appropriate maps are contained in the state and county plans. It is recommended that different symbols be used to depict traffic and access control points and monitoring

points. Presently the symbol for both locations is a triangle.

Populations of the 10 mile and 50 mile EPZ 'are discussed in both state and county plans.

The prini ?y means of alerting and notifying the public is the siren system and EBS activation. - Route alert teams have been designated in case of siren failure and to notify hearing

impaired individuals (See Planning Standard E).

There are three institutions in Hancock County that will be evacuated and may require assistance. Arrangements for evacuation of patients have been addressed in the county plan to include transportation,_both buses and ambulances.

Transportation has also been arranged for those residents who

may be mobility impaired. Letters of Agreement have not-been.

included from the School Districts, who will provide bus transportation (See Planning Standard A).

The State Department of Health is responsible for making the decision for the use of KI. The state plan indicates that the administration of KI will not be considered as a protective action for the general public. The county plan infers that KI .

will be used for institutionalized individuals. This decision

should be consistent in both plans.

Both the state and county plans contain detailed procedures on the use of KI. However, the plans do not state how much KI is available, where it is stored, if it is prepositioned in Hancock County or who is responsible for delivering it to Hancock County.

l As stated in Planning Standard J, the' State and county plans contain detailed instructions and procedures for determining the need for the use of KI.

The means of relocating the population within the 10 mile EPZ of Hancock County has been discussed in detail for five different group classifications to include: School children, non-car-owning population, car-owning population, special populations with restricted mobility and transients. Buses

! will be supplied by the Hancock County Department of Education and if needed the Brook County Department of Education (see i planning standard A).

10

Reception and relocation centers have been identified in the Hancock' County Plan. Relocation Centers are at least 15 miles from the plant.

There is no discussion as to expected traffic capacities during an evacuation of the area of Hancock County located within the 10 mile EPZ of the Beaver Valley Power Station. The only infonnation regarding traffic is that " traffic will initially be restricted and then controlled consistent." There is a graph depicting time estimates to evacuate sections or specific population categories.

Traffic and Access control is the responsibility of the Sheriff's Department.' The traffic and access control points have been identified for primary and alternate evacuation routes and have been depicted on a map in Annex H of the County plan.

An alternate evacuation route has been identified from the reception centers to the relocation centers in case of flooding of the Ohio River. However, the county plan does not address

~

how traffic impediments (such as stalled, vehicles, snowbound roads, etc) from within the EPZ to the reception centers will be handled.

A time estimates graph depicting various population groups evacuation times is contained in annex H of the Hancock County Plan.

The West Virginia Department of Agriculture is responsible for providing protective measures for the ingestion pathway. The Rural Resources Division maintains crop and herd lists which tabulate actual agricultural activity in the risk area. County extension Agents will provide technical assistance to the agricultural community.

County Fire Departments are responsible for providing monitoring of vehicles at the reception centers and evacuees at the relocation centers. Evacuees are registered at the relocation centers. The Hancock County Plan contains specific standard operating procedures on activation and operation of mass care centers.

K.* Radiological' Expos ~u re' Control A dosimetry short-fall is mentioned in the plans which also states that unless additional dosimetry is obtained from outside sources it is unlikely that each emergency worker could be issued a dosimeter. The ideal complement of dosimetry is high-range (0-200R), one mid-range (0-20R) and a TLD. At a minimum each worker should be issued a TLD and a dosimeter. If i

11

one dosimeter is issued it is recommended that the mid-range or 0-20R be used since this dosimeter covers most of the range of interest (5-20R). It is not acceptable to have emergency workers unmonitored. The County plan calls for each emergency worker to be issued two self-reading dosimeters, and one TLD.

However, the county plan indicates the availability of 120 CDV 742 dosimeters (0-20R) only. The plan does not indicate the availability or amount of TLDs and KI at the county level.

In the Emergency Worker Procedures, in the county plan, emergency workers are instructed to inform their supervisors if they receive a total of 1 rem during that day. However, the CDV 742 dosimeters (0-200R) will not accurately measure 1 rem.

On page XIV-C-1 of the State plan, there are 3000 COV-742 dosimeters. It would be prudent if the state prepositioned some of these doisimeters in the Hancock County E0C.

The emergency worker procedures for reading dosimetry and recording and/or reporting exposures are contained in the plan.

The Emergency Worker Procedures for dose control are good (page R-10-21), but there is no link from the supervisors to the County Radiological Officer. When a worker is to exceed the 5 rem dose for the general population, and especially the 25 rem emergency worker dose, the decision, as stated in the county plan, should be made by the Emergency Management Coordinator in

, coordination with the County Radiological Officer. It should not be made by the supervisor unless he is trained and qualified to interpret dose readings. An untrained supervisor does not constitute a decision chain for radiological exposure control.

Decontamination limits given are unusually detailed for emergency response and are expressed in terms that can only be understood by a health physicist. There is no quarrel with the levels indicated for surfaces as they are drawn from standard practice in the radiation field. However, for personnel contamination, the level indicated is somewhat different from wnat has been seen in other plans. Typically a gamma level of

.05 mR is used since it is readily detectable using a CDV-700 survey meter. The philosophy being that anything that is readily detectable should be removed if possible. This-is consistent with the ALARA principle. The West Virginia State limit is .002 mR/ hour which is not detectable on a survey meter. In contrast, Hancock County specifies a decontamination limit of .75 mR/ hour. This is 15 times higher than most states specify and 375 times higher than that specified by the West Virginia State Plan. Although there is no " correct" level, State and local plans should agree on decontamination limits and those limits should be at the lowest level detectible on survey meters.

12

Decontamination stations for emergency personnel equipment and disposal of contaminated wastes have been . adequately addressed.

L ; ' ' Midicil ' 46a ' P66116' Riil th' $6pp6 Ft -

State and county plans have identified primary and backup medical facilities who can be relied on to assist in a radiological emergency. None of the medical facilities supplying services to Hancock County are within the EPZ.

The licencee has provided for onsite first aid and medical support through medical and ambulance associations in Beaver County, Pennsylvania.

The State plan lists various facilities capable of.providing medical support for any contaminated injured victims. Training is provided through sither the parent state or the utility.

H; ' ' ' ' Ric 6vi Fi's h a ' Ri&6 t Fi' P l i6616 g ' i6a ' P 6 s t ' A6 E i d&6t ' OpiFit i 66 s General plans and procedures have been developed for reentry and recovery. The State Department of Health is responsible for assessment of an incident to include recommendations to terminate imposed protective actions and post accident assessment of emergency workers and the general public. The licensee and state govermnent will use existing methods to inform response organizations to initiate recovery phase.

N. Exercises and' Drills - '

The state and county plans have been updated to reflect the requirement'for participation in an exercise every two years.

However, the county plan indicates that the county may participate with the State'and in some years may be required to participate in a joint exercise with Federal, West Virginia State, Ohio State. Pennsylvania State, risk county agencies and the utility. 44 CFR, Part 350, " Review and Approval of State and local Radiological Emergency Response Plans and Preparedness," published in the Federal Register on September 28, 1983, states that "each State which has a connercial l nuclear power site within its boundaries or is within the 10  ;

! mile plume exposure pathway EPZ of such a site shall fully l participate in an exercise jointly with the nuclear power plant i licensee and appropriate local governments at least every two l years." The state and county plans should be changed to

, reflect that the county will participate fully in an exercise i

with the utility, the State of West Virginia and other states

and local governments within the 10 mile EPZ of the Beaver Valley Power Station at least once every two year.

West Virginia will arrange for Federal observers to evaluate the exercises. FEMA evaluators will provide a critique of the exercise. The critique will provide an evaluation of the

( 13 i

ability of State and local governments to respond as called for in their plans. Participants-in the exercise will be invited to the critique.

Comunications drills between Hancock County, the utility, West

- Virginia OES, Beaver County EOC, and Columbiana County EOC are held monthly. All elements of the comunications system are tested on an annual basis.

The Beaver Valley Power Station has made special arrangements for medical treatment and transportation of L

contaminated / injured individuals with hospitals and ambulance services _in Pennsylvania. Hancock County EMS personnel routinely respond to emergency situations. The County feels

! that this routine response plus participation in required l- exercises adequately addresses this requirement.

Radiological monitoring drills will be conducted with local organizations during the annual on-site exercise and the off-site biennial exercise. Since radiological monitoring assistance is provided by state agencies the state plans should indicate this participation in required drills.

Health physics drills will be held semi-annually with the assistance of the West Virginia Department of Health.

The state and county plans contain lists of items to be provided to official observers in advance of the exercise.

The Director, Hancock County, Office of Emergency Services, with assistance from West Virginia Office of Emergency Services, is responsible for planning, scheduling and coordinating all emergency plan related exercises. Preparation of scenarios for joint exercises will be coordinated by West Virginia Office of Emergency Services with the State of Ohio, the Commonwealth of Pennsylvania and the utility.

Official observers from federal government agencies will be requested by West Virginia Office of Emergency Services through the Federal Emergency Management Agency.

A critique, which will be attended by exercise participants will be held as soon as possible after the exercise. A formal exercise report will be prepared.

Each organization shall establish means for evaluating observer coments on deficiencies and areas needing improvement, including emergency plan procedural changes and for assigning responsibility for implementing corrective actions. Management controls will be established to insure corrective actions are taken.

14

0. ' ' " Rid 1616g 16il ' EmiFi 6cy ~ Riipo65E' Trii6 t hi The Director, West Virginia Office of Emerge'ncy Services is responsible for insuring that training is offered on an annual basis to all appropriate response individuals.

Basic core courses and annual . refresher. training is available for all emergency workers. This is illustrated in the State ,

plan at Annex 11, page 2, attachment 1, and in the county plan in Annex M, page 2-1, attachment 2.

P.

~~-

Rii bb6 i i 6 i l i t i 6i" f 6 F' t hi' P l i66166 ' E f f6 Ft i ' ' Div&16pm&6t , '

Periodic Review and Distribution of Emergency Plans >

Training matrixes contained in both state and county plans

' indicate that training for those individuals responsible for the planning effort is conducted annually.

Both state and county plans indicate the individual by title who is responsible for radiological emergency response planning.

The West Virginia Office of Emergency Services Director is the official at State level responsible for development, review, update and coordination of plans with other appropriate organizations. The State Department of Health and State Department of Agriculture will provide assistance for updating respective annexes to the State plan.

The Director, Hancock County Office of Emergency Services is responsible for reviewing the county Plan at least annually. '

Telephone call down lists are reviewed at least quarterly.

I 15 l

$6mmary' List of'Dsficisnciei/Rscomm ndations

1. All reference to the IRAP in the state and county plans should be updated to reflect the Federal Radiological Emergency Response Plan (FRERP) published on September 14, 1984. Under federal responsibilities, EPA has been listed at number 9 and 11. Number 9 is obsolete and should be deleted. (Ala)

2. The West Virginia Office of Emergency Services uses a duty officer system for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage. The state plan should contain more detailed information and instructions on how the duty officer system functions. (Ald,Fla)

3. The State Department of Health has the responsibility for accident assessment and protective action recommendations. It is understood that each element of response should list one primary responsible organization; however, in this case it may be clearer if a primary organization was included for each level of response as was done for Command and Control, since all levels will have responsibilities when protective actions are initiated. (A2a)

4. The state plan should include Letters of Agreement with the CPCS-1 radio station for West Virginia and with the RACES organization.

(A.3)

5. The Hancock County plan does not contain Letters of Agreement with School Districts who are to provide buses for transportation and schools to be used as mass care centers. All letters of agreement do not state specifically what service or assistance will be provided.

(A.3) ,

6. The state plan does not contain first and second shift personnel for each staff position. (A4)

7. It is recommended that state personnel bringing additional dosimetry equipment to Hancock County be dispatched to Hancock County at the alert stage. (C2a,H4)

. 8. PAGs listed in the Hancock County plan on page F-2 aren 'ot consistent with EPA PAGs or those given on page 1-2 of the same county plan.

The use of the top of the range of the EPA PAGs does not allow evacuation at the low end if deemed appropriate. Evacuation should also be recommended based solely on plant conditions even if there is no projected dose and the plan should allow for this. (04)

9. The Hancock County plan does not call for activation of the E0C until General Emergency. In order to adequately respond to an emergency the EOC should be activated much earlier in an incident (H4)

10. Inventory lists contained in the plan as to what equipment is included in emergency kits do not include dosimeters of any kind, potassium iodide or communications equipment. (H-11) 16

11. Although Annex 15 of the state plan includes an equipment list that shows the instruments needed to measure radioiodine concentrations are available, this specific capability has not been described. (19)

12. Fanners within the 10 mile EPZ may insist on reentering the EPZ to feed their livestock. If this occurs, procedures must be developed to monitor and limit radiological exposure to this segment of the population. (J9)

13. The plans indicate that there is not sufficient dosimetry available to provide each emergency worker adequate dosimetry. In addition, there are only enough CDV-742s to provide one per group. It is not acceptable to have any emergency worker unmonitored. At a minimum each worker should be issued one TLD, on high range (0-200R) dosimeter and one mid-range (0-20R). No indication of the number of TLDs available to Hancock County has been included in the plans.

(J9,K3a)

14. State and County plans should be consistent as to who will be authorized to take KI as a protective action. There is no statement as to how much KI is available, where it is stored, if it is pre-positioned in Hancock County or who is responsible for delivering it to Hancock County. (Hil,J10e)

15. Emergency workers are to report an exposure of Ir to their supervisors. The county plan indicates the availability of CDV 742s only. The CDV 742 will not accurately measure IR. (K3a)

16. The state plan states that there are 3000 CDV-742 dosimeters stored in the state E0C. It is recommended that some of these dosimeters be pre-positioned in Hancock County (K3a)

17. There is no link from an emergency worker's supervisor to the County Radiological Officer for authorization to exceed the 1-5 rem and 5 to 25 rem exposure. This decision, as stated in the county plan, should be made by the County Emergency Management Coordinator in conjunction with the Radiological Officer. It should not be made by a supervisor unless he is trained and qualified to interpret dose readings. The Emergency Worker Procedures, page R-10-21 of the county plan should include the link between the supervisors and the County Radiological Officer. (K4)

18. Although there is no " correct" level at which decontamination of individuals is required, the state and county plans should agree on what that level is. In addition those levels should be at the lowest level detectable on survey meters. (K5a)

19. The state and county should obtain the most current version of EPA PAGs. (J9)

20. Ingestion PAGs given in the Hancock County plan are not consistent with the latest EPA guidance. (J9) 17

21. Dif ferent symbols should be used on appropriate maps to depict traffic and access control points and monitoring points. (J10a)

22. The county plan does not address how traffic impediments (stalled vehicles, snowbound roads, etc.) will be cleared from evacuation routes. (J10k)

23. State and county plans should be changed to state that the county will participate fully in an exercise with the utility, West Virginia and other states and local governments within the 10 mile EPZ of the Beaver Valley Power Station at least every two years. (Nia) i 18

MAk18 '87 13:26 EPP PAGE.02 1/87 Corrective Actions to the WVREP For the January 19oo FEMA III RAC Comments The comments and responses in this report reifect the " Summary List of Deficiencies / Recommendations" on pages 16, 17 and 18 of the FEMA Report. ,

1. Comment All reference to the IRAP in the State and County Plans should be updated to reflect the Federal Radiological Emergency Response Plan (FRERP) published on September 14, 1984 Under Federsi responsibilities, EPA has been listed at number 9 and 11. Number 9 16 obsolete and should be deleted. (Ala)

Response

• All references to IRAP have been updated in the State Plan to reflect FRERP.

• Under Federal responsibilities, #9-EPA, has been removed, #11, has been renumbered #9. Basic Plan Page 18.

2. Comment The West Virginia Office of Emergency Services uses a duty officer system for 24-hour coverage. The State Plan should contain more .

detailed information and instructions on how the duty officer system functions. (Ald, Fla) ,

Response

• [ Comment should reference Ale and Fla not Ald, and Fla].

• Ale of the Cross Reference has been changed to include Annex 1 Page 1-1.

• A " Twenty-four Hour Notification" section has been added to Annex

14. This section providos more detailed information on the duty officer system. Annex 14, Page 14 4.

l

• Annex 1 has been updated to reflect the addition of the " Twenty-four Hour Notification" section to Annex 14. Annex 1. Page 1-1,

3. Comment The State Department of Health has the responsibility for accident assessment and protective action recommandations. It is understood i

that each elemet of responso should list one primary responsible f

1 4

_,.---.e , ...-m#.- - . . - . . _ , -.-,,.--_-.-__m,_ _ . - - - . - . - , - _ , . . , _ . - , , _ _ . , _ , . , - - - , , , . . . - . - _

f1AR 18 '87 13:26 EPP PAGE.03 1/87 organization; however, in this case it may be clearer if a primary organization was included for each level of response as was done for l l Command and Control, since all levels will have responsibilities when protective actions are initiated. (A2a)

Response

i, * 'The State and County " Task Assignments" charts have been redeveloped to clarify this conunent. Basic Plan, Pages 24, 25 4 and 26.

4. Comment The State Plan should include Letters of Agreement with the CPCS-1 radio station for West Virginia and with the RACES organization.

(A.3)

Response

Letters of Agreement with the State EBS Organization and the

. State RACES Organization have been added to the Plan. Annex 20

5. Comment

. The Hancock County Plan does not contain Letters of Agreement with School Districts who are to provide buses for transportation and schools to be used as Mass Care Centers. All Letters of Agreement do j not state specifically what service or assistance will be provided.

'. (A.3) 1 j Response

• Hancock County Plan only.

I

6. Comment l

)

! The State Plan does not contain first and second shift personnel for each staff position. (A4)

Response

• Key and alternate individuals (first and second shift) are listed by position. Basic Plan, Page 26.

• Key and alternate individuals (first and accond shift) are listed by name. Annex 14, Page 14-10.

• WV0ES staffing of the EOC has been added by position and name.

Annex 14, Page 14-11.

l

}

l I

i *2-

j. l

MAR 18 '87 13:27 EPP PAGE.04 1/87

7. Comment .

It is recommended that state personnel bringing additional dosimetry equipment to Hancock County be dispatched to Hancock County at the alert stage. (C2a, H4)

• sufficient dosimetry has been relocated to Hancock County on a permanent basis. Annex 15,Section XIV, Tab-C, Page XIV-C-5

8. Comment PAGs listed in the Hancock County Plan on Page F 2 are not consistent with EPA PAQs or'those given on Page 1-2 of the snee County Plan. The use of the top of the range of the EPA PAGs does not allow evacuation at the low end if deemed appropriate. Evacuation should also be recommended based solely on plant conditions even if there is no projected dose and the Plan snould allow for this. (D4)

Response

• Although this comment does not reference the State Plan, it does apply. The State Plan has been changed to reflect the entire range of the EPA PAGs.

- Annex 15,Section VI, Page VI-7, 6.3.1 has been changed from "5 rem" to "I rem to 5 rem".

- Annex 15, section VI, Page VI-7, 6.3.2 has been changed from "25 ree" to "5 rom to 25 rem". .

- Annex 15 Section VII, Page VII-6, Under 3. Evacuation, the second paragraph has been changed from: "An appropriate proaching or exceeding 5 rem whole situation body andwould. . . .does 25 rom..." tor ap'An appropriate. . . dose of 1 rem to 5 rem whole body or S rem to 25 rom...".

• A section titled " Plant Conditions" has been added to the Plan.

Annex 15 Section IX, Page IX-9, AS.

9. Comment The Hancock County Plan does not call for activation of the EOC until General Emergency. In order to adequately respond to an emergency, the EOC should be activated much earlier in an incident. (H4)

Rospon_gg J

• Hancock County Plan only.

3

(1AP 18 *G7 13:28 EPP PAGE.05 1/87

10. Comment Inventory lists contained in the Plan as to what equipment is included in emergency kits do not include dosimeters of any kind, potassium iodide or communications equipment. (H-11)

Response

• Dosimetry and potassium iodide has been added to the VVDH Resources. Annex 15,Section XIV, Tab A, Page XIV-A-1 and XIV-A-2

• Communications equipment is outlined in Annex 3. A note has been added to Annex 15.Section XIV. Tab A. Page XIV-A-2, referencing Annax 3.

11. Comment Although Annex 15 of the State Plan includes an equipment list that shows the instruments needed to measure radioiodine concentrations are available, this specific capability has not been described. (I9)

Response

-

• Analysis sheet added. Annex 15,Section XI, Tab B, Page XI-B-1

12. Comment Farmers within the 10 mile EPZ may insist on reent ering the EPZ to

• feed their livestock. If this occurs, proceduras must be developed to monitor and limit radiological exposure to this segment of the population. (J9)

Response

• Hancock County Plan only.

13. Comment The Plans indicate that there is not sufficient dosimetry available to In addition, there provide each emargency worker adequate dosimetry.

It is not are only enough CDV-742s to provide one per group. At a minimum acceptable to have any emergency worker unmonitored.

each worker should be issued ono TLD, on high range (0-200R) dosimeter and one mid-range (0-20R). No indication of the number of TLDs available to Hancock County has been included in the Plans. (J9, K3a)

Responso

• Sufficient donimetry has been relocated to Hancock County on a permanent bania. This includes: High Range ( 0200 R), Mid-Range (0 20 R), and TLDs. Annex 15 Section XIV, Tab A, Page XIV A-1; Annex 15,Section XIV, Tab C, Page XIV-C 5.

4

MAR 18 '87 13:28 EPP PAGE.06 1/87

14. Comment State and County Plans should be consistent as to who will be authorized to take KI as a protective action. There is no statement as to how much K1 is available, where it is stored, if it is for delivering ,

propositioned in Hancock County or who is responsible '

it to Hancock County. (Hil. J10e)

Response

• The State Plan now states that KI is for emergency workers only.

Annex 15,Section VII, Page VII-9.

Annex 15, Section

• KI is now prepositioned in Hancock County.

XIV, Tab A, Page XIV A-1; Annex 15,Section XIV, Tab C, Page XIV-C-5,

15. Comment Emergency workers are to report an exposure of 1R to their supervisors. The County Plan indicates the availability of CDV 742a only. The CDV 742 will not accurately measure IR. (K3a)

Response

- Mid-range dosimeters (CDV-730) have been relocated to Hancock County. Annex 15,Section XIV, Tab C, Page XIV-C.S.

'# 'uet. . . sov. ~~. .-- .... ..... .

TEL State Plan states cnu6 the State EOC. It is recommended that some of these dosimeters be prepositioned in Hancock County. (K3a)

Response

• A sufficient number of CDV-742s have been relocated to Hancock County. Annex 1!,Section XIV, Tab C, Page XIV-C-5.

17. _ Comment There is no link from an emergency worker's supervisor to the County to Radiological Officer for authorization to exceed the 1-5 rem and 5 25 rem exposure. This decision, as stated in the County Plan, should be made by the County Emergency Management Coordinator in conjunction with the Radiological Officer. It shculd not be made by a supervisor dose readings. The unless he is trained and qualified to interpret Emergency Worker Procedures, Page R-10-21 of the County Plan should include the link between tha supervisors and the County Radiological Officer. (K4)

MAR 18 '87 13:29 EPP PAGE.07 1/87

Response

• Hancock County Plan only.

18. Comment Although there is no " correct" level at which decontamination of

individuals is required, the State and County Plans should agree on what that level is. In addition, those levels should be at the lowest level detectable on survey meters. (K5a)

Response

• The State Plan has been changed to agree with the County Plan.

Annex 15,Section XI, Pages XI 4, XI-10, XI-12.

19. Comment The State and County should obtain the most current version of EPA PAGs. (J9)

Response

• The USEPA Manual of PAGs is currently in draft form. Once it is finalized, the State Plan will be changed to reflect the final EPA PAGs.

20. gomment Ingestion PAGs given in the Hancock County Plan are not consistent with the latest EPA guidance. (J9)

Response

• Hancock County Plan only.

21. 9amment Different symbols should be used on appropriate map to depict traffic and access control points and monitoring points. (J10a)

Response

• Hancock County Plan only.

22. Comment The County Plan does not address how traffic impediments (atalled vehicles, snowbound roads, etc.) will be cleared from evacuation routes. (J10k) 6-

f1AR 18 '

87 13:29 EPP PAGE.08 1/87

Response

• Hancock County Plan only.

23. - Comment State and County Plans should be changed to state that the county will participate fully in an exercise with the utility, West Virginia and other states and local governments within the 10-mile EPZ of the Beaver Valley Power Station at least every two years. (Nia)

Response

• The State Plan now reflects an exercise once every two years.

Annex 10, Page 10-1.

5 P

/

?

1

. - -' - -=r* M =---%_.a+-

[ MAR 18 '87 13:30 EPP PAGE.09 Correctiva Acticn to the HANCOCK COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN For the January, 1986 FEMA III_RAC_ COMMENTS NOTE: Numbers correspond with the Summary List on pages 16,17 and 18 of the FEMA Report.

Item HCRERP Pages Chenaed

1. References to IRAP should be Section 1, Pasa 4 updated to reflect FRERP. Annex A, Page A-5 Annex E, Page'E-2 Annex N, Page N-2

5. Include letters of agreement with Annox S, all pages.

School Districts that provide Brooke schools letter buses and/or schools for use as includad; Hancock schools mass care centers. Letters should letter and all other state specifically the service or letters revised and assistance that will be provided. renewed.

7. State personnel to bring Section 2, Page 18 Radiological monitoring equipment Section 4 Pages 30, 32

. to County at " Alert". Annex R, SOP #1, Page R-1-6 Annex R, SOP #10, Page R-10-4 8a. Incorrect PAGs. Annex F, Pages F-1, F-2 -

Annex 1, Page I-1 Annex J, Page J-2 8b. Evacuation should be considered Annex H, Page H-4 i based on plant conditions. Annex R, S0P #1, 9, Pages R-1-2, R-1-53

9. Hancock EOC should activate Section 2, Page 18 at " Alert". Section 4, Pages 30, 31 l Annex C, Page C-2 Annex N, Page N-1 Annex P, Page P-4 Annex R, SOP #1, Pages R-1-2, R-1-16, R-1-17, R-1-30 Annex R, SOP #2, Page R-2-27 1-

MAR 18 '97 13:31 EPP PAGE.10 Corrective Actions to HCRERP for FEMA III RAC Comment _s_ (Continued)

Item HCRERP Pages Changed

10. Dosimetry, KI and communications Annex N, Pages N-4, N-5, equipment not shown in inventory N-6 lists. Annex R, SOP #3, -

Page R-3-17 Annex R, SDP #10, Pages R-10-8, R-10-9, R-10-28

12. Arrange to monitor farmers Annex H. Page H-12 and limit their exposure. Annex R, SOP #8, Pages R-8-2, R-8-3 Annex R SOP #10, Pages R-10-3, R-10-4, R-10-6

13. Insuf ficient dosimetry, TLDs. Annex N, Pages N-4, N-5, N-6 Annex R S0P #3, Page R-3-17 Annex R, SOP #10, Pages R-10-8, R-10-9, R-10-28

14. Plans do not agree on who Annex G. Page G-2 is authorized to take XI; Annex N, Pages N-4, ,

no statement of how much is N-5, N-6 Annex R, SOP #3, available or where it is Page R-3-17 stored. Annex R, SOP #5, Pages R-5-4, R-5-5, R-5-6 Annex R, SOP #10, Pages R-10-1, R-10-8 R-10-24, R-10-28

15. No dosimetry available Annex N, Pages N-4, other than CDV-742s. N 5, N-6 Annex R, SOP #3, Page R-3-17 Annex R, S0P #10 Pages R-10-8, R-10-9, R-10 28 s

2-4

MAR 18 '87'13:31 EPP PAGE.11

_C_orrecti ve Actions to HCRERP for FEMA III RAC Comments (Continued)

HCRERP Pages Changed Item Annex R, SOP (/10,

17. Include a link from Pages R-10-5,

, field supervisor to Radiological Of ficer when R-10-6, R-10-22 discussing emergency exposure i authorization.

1. Annex F, Pages F-1,

19. Current EPA PAGs should F-2 be obtained. Annex I, Page I-1 Annex J, Page J-2 Annex F. Page F-2

20. Ingestion PAGs are not consistent with latest EPA guidance.

Annex I, Pages I-5,

21. Different symbols should j be used on maps to depict I-7 traffic and access control NOTE: FEMA comment points and monitoring points. should reference Reception

~

Centers and monitoring pointagin previous issue, both were depicted by triangles . Revised Plan

~

uses dome shapes to ,

represent monitoring points.

Annex F. Page F-3

22. Plan does not address Annex H, Pages H-1, i

removal of impediments H-14

- from evacuation routes.

Annex M. Page M-2

23. Plan should state that County will participate every two years in -

full-scale BVPS exercise.

l i

I l -

August 23, 1983 i

Mr. Craig Williamson Acting Director i Pennsylvania Emergency Managemer.t

• Agency I

, Transportation and Safety Building Boom B-151

, Harrisburg, PA 18120

$ Dear Mr. Williamson A: i

$( Enclosed are the comments of Region III's Regional Assistance Comittee (RAC) t~ concerning the Beaver County radiological emergency plans for the Beaver Valley

tower Station and the Shippingport Atomic Power Station. The plans were re-

viewed for their conformance with NUREG-0654/ FEMA REP-1, Rev. 1.

The County plans meet most of the planning standards and criteria of NUREG-0654.

J. .

Those areas which the RAC believes are not adequately met are so indicated by ii an "I" in the " Rating" column of the review. The comments column explains the fa reason for such a rating.

4, In addition, there are coments for various elements that were judged to be adequately met but which could be improved or clarified.

Po11owing the coments on the Beaver County plan are general coments on the I piens of the County's plume zone municipalities.

If you or your staff have questions concerning these comments, please contact f4 '

Joseph Cavin at the above address or at (215) 597-1849.

Sincerely,

?

James R. Asher

, Chairman Regional Assistance Comittee i

Enclosure

}-) i e '

cc File 4 Chron J.Gavintme:8/23/83 on,un en concu atste cowuaai~ce co~cuaaisce coNcsaa8ca ov~cuaatwa Name om Y e/rs /0

\ OF FICI AL HECOAD COPY j ..............

___-_ . . _ _ _ . _ _ . - ~ .

i A Corrected 0654 or Cross Rsfarence I Comments Reference A.1.e. A Appendix 1 charts the County and sub-County response Basic Plant entities; Appendix 3 lists and briefly summarizes Append!x 1 (p.1-1) the responsibilities of the major state, local, fed- Appendix 3 (p.3-1) eral and private sector organizations in regard to off-site planning and response.

A.1.b. A The Plan specifies concepts of operations for each Basic Plans organization and sub-organization through a com- Par. VIII(p.9-16) bination of Paragraphs VIII. RESPONSIBILITIES and Par. IX (p.16-23)

IX. CONCEPT OF OPERATIONS; Appendices 2 and 3 of Annexes B through '

the Basic Plan; and Annexes B through I, K through Annexes K through I Q and V. The concept of operations applicable to a Annex V particular County sub-organization is set forth in Basic Plan the annex or annexes devoted to the function (s) for Annexes 2 and 3 which the sub-organization is responsible. Concepts (p.2-1 and 3-1) of operations for the twenty-seven municipalities within the 10 mile EPZ are found in the municipal plans: Annex V.

A.1.c. A Basic Plan Appendix 1 (p.1-1)

Appendix 3 (p.3-1) l A.I.d. A County Commissioner and Emergency Management Basic Plan Coordinator. Par. VIII A (p.9)

A.I.e. A Annex A, Par. A.  !

(p.A-1)

Annex B. Par. IV.

(p.B-2) l A.2.a. I. The criterion has been met for all of the required Basic Plan functions except Public Ilealth and Sanitation, and Par. VIII (p.9-16)

Social Services. Basic Plan l

/

>. . s ." . '. , q. . . . . -......,7.,' -

Appendix 2 (p.2-1)

A.2.b. A ' Basic Plan Par. I.A. (p.1)

A.3. I Written support agreements are under development. Basic Plan,

, . c' ,, 3 . , , , o' . e < /.* * " . Appendix 3 (p.3-1)

/. / -

,. / j.. .<r.< % . .; . < p . . / ' i ,,

Annexes T U, V.

. , ...a.- n . ..c, *s.

on,.. <

A.4. A '. < , e ',/ O- " - ^ M / ','s 8 '- '" O Annex A, Par. A (p.A-1)

C.1.c. A Addressed in Annex E of the Commonwealth Dinaster Annex Q (p.Q-1)

Operations Plan.

\

A '

Corrected 0654 or Cross R7ference I Comments Reference C.2.a. A Beaver County will rely upon the Pennsylvania Bureau Annex Mt of Radiation Protection for representation at the Par. II.A. (p.M-1)

Beaver Valley Emergency Operations Facility. Par. IV (p.M-3)

C.4. I 1 Additional agreements are being developed with Annexes T, U, V,

. facilities and organization, who can be relied upon E, F G, H, and I.

in an emergency to provide assistance.

D.3. A Basic Plan Appendix 6 D.4. A Basic Plan, Par. I:

(p.16-23)

Annex B, Par. V (p.B-2)

Annex C, Par.IV (p.C-2 to C-4)

Annex D, Par. IV (p.D-2 to D-4)

Annex E Par. V (p.E-2 to E-4)

Annex F. Par. IV (p.F-2 to F-4)

Annex G. Par. IV (p.G-1 to G-3)

Annex II, Par. IV (p .ll-2) -

Annex 1, Par. V (p.I-2 to I-3)

Annex J Par. VI (p.J-3)

Annex K. Par. IV (p.K-1 to K-3)

I Annex L. Par. V (p.L-2 to L-3)

Annex M. Par. IV (p.M-3)

Annex N, Par. IV (p.N-2 to N-3)

E.1. A Verification in implied for telephone monnagen, but Basic Plan, a specific step of message verification would be Par. IX (p.16) desirabic in Appendix 2 of Annex C. Annexen B and C E.2. A Annex C E.5. A The plan should include back-up means of com- Annex B, Par, III.

munication between the EOC and EBS radio stations. B.4. (p.B-2)

Annex D, Appendice I through 7

G A Corrected 0654 or cross R7ference I Comments Reference E.6. A Annex C E.7. A Annex D. Appendice 1 through 7 F.1.a. A Annex A. Par. A (p.A-1)

Annex B and j Appendices 1-4 of Annex B l F.1.b. A Annex B. Par. III ,

1 (p.B-1)

Basic Plan 1 Par. VIII.D.3.

l (p.10) and  ;

K.2 (p.13) I F.1.c. A PEMA responsibility. Annex B, Par. III..

(p.B-2)

F.1.d. A Communications with EOF will be handled through PEMA. Annex B. Par. III.

(p.B-2) 1 F.1.e. A Basic Plan, Par. I f (p.16) 2 Annex A, Par. B I

(p.A-1)

Annex C, Appendix l (p.C-1-1) ,

F.2. A Annex B Par. III..

(p.B-1) j F.3. A Annex C Appendix (p.C-5-1) l Annex S

, [

. G.1 I I Exampics of pre-emergency information should be Annex D, Par. II.A l y f, r, / -j (* (p.D-1)  ;

p re s e n t ed . /) 1,, ,j , / ^ , ' ./ ' Par. III.A&B (p.D-

& / Par. IV, A.B.C ,

(p.D-2) ,

L G.2. A Annex D. Par. III A,B,6D (p.D-2)

Par. IV A&B (p.D-2 ,

i i

G.3.a. A Annex D. Par. IV.F '

l (p.D-3)

O.4.a. A Annex D. Par. IV.C (p.D-3)

I

_ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ . . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ . . . . _ _ _ _ _ _ . _ . _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ = _ _ _ _ . _ _ _ _

A Corrected 0654 or Cross R-ference I Comments Reference G.4.b. A Annex D, Par. IV.G.

(p.D-3)

G.4.c. A Annex D. Par. IV.E.

(p.D-3) ,

G.5. A Annex D Par. IV.C.

(p.D-2)

!! . 3. }A '

.- S a ,t [4..w 4 < c : [ e < . . /. Annex A, Par. A

/r

• 2 , ,) ,..I,7 >

. ,4 /a . < Y , ,, ,.,// (P.A-1)

.e ,

!! . 4. A Annex A, Par. B (p.A-1)

Annex C, Appendix 1 (p.C-1-1)

Basic Plan, Appendix 5 IL 7. A . State responsibility. Annex M. Par. IV.A.

(p.M-3)

H.10. A Annex M, Appendix 2 Par. II.C. (p.M-2-2) 11 . 1 1 . A Annex H. Par. II.D. G, H, I, J and X ,

(p.M-1 to M-3)

Appendix 3 (p.M-3-1) 11 . 1 2 . A Annex M. Par. IV.A.

(p.M-3)

I.7. A Annex M. Par. IV.A.

(p.M-3) 1.8. A Annex M. Par. IV.A.

(p.M-3)

J.9. A ,

Basic Plan, Par. IX.F.

(p.18) and Appendix (p.6-1)

Annexes C through 0 J.10.n. A Annex W J.10.b. A Annex W J.10.c. A Annex C. Annex D.

Basic Plan, Par. IX.D.

(p.18)

Annex E. Par. II.B.

(p.E-1)

A Corrected 0654 or Cross Riforence I Comments Reference J.10.d. I The plan does not make any provision for evacuation Basic Plan, Par.VIII.

of handicapped persons residing at home. In a popu- D.11 (p.11) lation as large as that of the Beaver Valley EPZ, a Basic Plan, Par. VIII substantial number of home-bound handicapped could E.9 (p.12)

Basic Plan, Par. IX.F.

J be expected. The municipal plans do provide for a list of such persons to be maintained by police or (p.18-2)

,' fire departments. However, none of the municipal Annex 1, Par. III.

si plans actually include this list, nor even give an (p.1-1)

,1' estimate of numbers. It appears that prompt evacu- Annex G, Par. II.

ation of the confinement institutions alone will (p.G-1) l require 75-100 ambulances. The ambulance list in ",

Annex G includes only 34 vehicles in all of the area up to 20 miles from the plant and another 120 in the 20-40 mile radius. Some of these will ob-viously be required to remain in their home area for local emergencies. Therefore, there are very few vehicles available beyond those needed for in-stitutional evacuation. Further, the plan does not address requirements and sources for other specialized vehicles, e.g. lift-equipped vans and buses, which might be used to evacuate handicapped residents. The county must take the lead in identifying vehicle requirements and vehicle

!.# sources and establishing procedures to insure protection for the handicapped citizens.

J.10.e. A Annex M (p.M-1 to M J.10.f. A KI is to be taken only on advice of the Secre- Annex M, Appendix 2, tary of the Commonwealth Department of Health. Par. III.B.2. (p.M-2-3 and Attachment C to Appendix 2 (p.M-2-C-1)

J.10.g. I Principal means for relocation will be private Annex I l vehicle, supplemented by buses for residents without access to private vehicles, which is f satisfactory. Annex I, Appendix 1, lists 2 I] ', o sources for buses. However, a number of vehicles (80) is given for only one source, McCarter Transit.

Eighty buses are abviously inadequate to meet the probable demand of an EPZ population exceeding 100,000.

Unfortunately, no demand figures are given. The county plan refers readers to the municipal plans for estinates of the number of persons needing bus transportation and vehicle requirements and the lo-cation of pickup points. In actuality, none of the local plans give demand estimates and only a few give the number of buses required. However, all of the lo-cal plans do list pickup points. Given the probable high demand for bus evacuation, the county plan should at the very least list unmet needs by jurisdiction, identify sources adequate to meet the demand, and pro-vide a coordinated procedure for mobilizing and dis-patching buses.

I A Corrected 4 0654 or Cross Riference' >I Comments Reference

, J.10.h. A Annex L, Par. IV.E.

3-(p.L-2)

J.10.1. 'A Traffic capacities are given on the Penn DOT Annex J, Appendix 3 "

evacuation plan map for major routes. (p.J-3-1)

Annex W J.10.j. I' Annex F presents'several lists of access control Annex F, Par. I, II, ,

posts to be set up by the Pennsylvania State IV (p.F-1 and F-2) i g ytt Police (PSP). These are repeated in Annex K. Un- Annex K, Appendix 2 fortunately, the posts cover only the northern (p.K-2-1) 0'j I(/. boundary of the EPZ from the Ohio line to Route 588

. I and the southern boundary from Route 60 to the West Virginia border. A review of the Penn DOT map suggests that even within these areas, coverage is incomplete. Additional posts would appear to be

'I required at:

1. S.R. 251 at T-342, South Beaver Township

2. T-360 and 115 Spur at Beaver / Washington Township County line

'3. T-476 and 115 Spur, Hanover Township l The eastern EPZ boundary from S.R. 588 on the north, along the Beaver and Ohio Rivers, to Crescent and .

S.R.'60 on the south is not covered by the lists.

This boundary includes densely populated areas ad-joining Beaver Falls, a number of river bridges, and the industrial South Heights / Crescent area. Obviously, scores of streets and highways cross- the EPZ boundary.

Notes at the bottom of the lists in Annexes F and K

/ indicate that 9 municipalities share the access control responsibility with PSP. Seven of these municipalities are in Beaver County and 2 are in Allegheny County.

only 2 are actually in the EPZ (Hopewell and Patterson Townships), while the remainder are outside, but ad-jacent to the EPZ.

The only municipal plans available are those from within

< the EPZ. Neither of the two municipal plans involved mention the access control responsibility. It is not

known if non-EPZ municipalities have or will be develop-j ing response plans. Lack of control of access into the

, EPZ along the most populus corridors is a critical i'

deficiency. Specific plans for post locations and manning procedures must be developed by PSP, the two j counties, or appropriate municipalities.

t s

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A Corrected 0654 or Crees R7farence I Comments Reference J.10.k. A Annex K, Par. III (p.K-1)

J.10.1. A Annex J, Appendix 3 (p.J-3-1)

J.12 A Evacuee monitoring is adequate as described in Annex L, Par. III.B&C Annex M. (p.L-1)

Annex M Par. V.B.

(p.M-5)

K.3.a. A Emergency worker dosimetry is adequate as described Annex M, Par. VI.

in Annex M. (p.M-6)

K.3.b. A Dosimeter reading frequency is accurate. Annex M Appendix 2 (p.M-2-1)

K.4. I The plan does not include a decision, point for Annex M, Appendix 2

r. L emergency worker exposure in the 1-5' rem whole- Par. IV.B.2.

/*ar b body range (PAG for general populat' ion exposures). (p.M-2-5)

More detail should be given as to exactly which

" elected officials in authority" may authorize an emergency worker to volunteer to exceed the pro-tective action guidelines.

K.S.a. A Annex M, Appendix 1 '

(p.M-1-1)

K.S.b. A Annex M, Appendix 1 (p.M-1-1)

Annex G, Par. III (p.G-1)

Annex G, Appendix 2 (p.G-2-1)

L.1. I e This evaluation criterion requires capability for Annex G, Appendix 2

,)/, ,

evaluation of radiation exposure and uptake. (p.G-2-1)

.a. ;-/ .f Appendix 2 of Annex G does not address the radi-ation exposure related capabilities of the medical facilities listed.

L.4. I The paragraphs '.isted in the County cross reference for this evaluation criteria do not exist. Annex

{ G makes reference in several places to the provision of emergency ambulance services onsite as requested.

A reference to a broader provision of transportation of victims of radiological accidents is needed.

M.I. A Annex P

1 A Corrected 0654 or Cross R3ference I Comments Reference N.1.a. As of this review publication of revised FEMA ds., . P- 0 regulations (44 CFR 350) governing exercise fre-quency is anticipated within the next few weeks.

As soon as notification of publication is re-ceived, the FEMA regional office will notify PEMA. If PEMA or Beaver County is ready to sub-mit the plan for formal approval prior to notice '

from FEMA concerning publication, the regional office should be contacted for consultation re- ,

garding how to handle N.1.a. and N.1.b.

N .' 1. b . See N.I.a. above.

N.2.a. A Annex S, Par. II.D.1.

(p.S-2)

N.2.c. A Annex S, Par. II.D.2.

(p.S-3) l N.2.d. A Radiological monitoring and health physics are Annex S, Par. II.D.3.

a State responsibility, so the county's partici-pation in drills involves only decontamination monitoring personnel.

i N.3.a._ A The county will rely on PEMA for the development Annex S through of exercise scenarios. ,

N.3.f.

N.4. A Annex S, Par. IV.

(p.S-3)

N.5. A Annex S, Par. IV.

(p.S-3 & S-4) 0.1. A Annex R O.1.b. A Annex R, Par. III.B.

(p.R-3) 4 0.4.a. A Annex R, Par. II.B.

(p.R-1) 0.5. A The entire Annex R should be included in the cross- Annex R (p.R-1 to R-3) reference.

P.1. A Annex R, Par. II.A.

(p.R-1)

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A Corrected 0654 or Cross Reference I Comments Reference P.2. A Emergency Management Coordinator Basic Plan, Par. VIII./

-(p.9)

P . 3.- A Basic Plan,~ Par. VIII.e (p.9)'

Basic Plan, Par.

VIII.K.1.d. & e.

(p.13)

P.4. A. Annex S, Par. IV.B&C (p.S-3)

Basic Plan, Par. VIII./

(p.9)

P.S. A Basic Plan, Par. X.D.

(p.24)

P.6. A Annex U and Annex V P.7. A Annex U P.8. A Table of Contents (p. iii)

P.10. A Basic Plan, Appendix 5 (p.5-1) ,

Annex A, Appendix 1 (p.A-1-2)

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Comments on Municipal Plans Beaver County, Pennsylvania General All 27 municipal radiological response plans follow an identical format. However, in some plans, key tables are blank or incomplete and other information is missing.

Each of the plans contains an " Appendix 4," intended as a listing of non-ambulatory residents. However, in each case, the list is not included and the reader is in-formed that the list is maintained in the municipal police or fire department.

While we'can appreciate the need for privacy, the list is a key informational element. There is no assurance that the police and fire departments are aware of this critical responsibility assigned to them and that the responsibility has been accepted and , implemented. Therefore, the list should be included in the controlled i copies of plan or, at least, the number and location of handicapped individuals and the number and type of vehicles required to evacuate them given. This is par-ticularly important since the Beaver County plan does not address homebound, non-ambulatory residents at all.

Another deficiency common to a number of the municipal plans relates to location of pickup points for bus evacuation of residents without access to private vehicles.

In several jurisdictions, there are only a few pickup points each covering many square miles. It may be as much as two or three miles from a residence to the nearest pickup point. By definition, citizens requiring bus evacuation do not have a vehicle available. Therefore, many may require transportation from home to pickup point, particularly older residents or families with small children. This would require vehicles and a dispatching plan and should be provided for in the municipal plans. The comment applies to Brighton Township, Centre Township, Chippewa Township, ,

Greene Township, Hanover Township, Independence Township, Industry Borough. Ohioville Borough, Raccoon Township, and South Beaver Township.

Finally, none of the plans gives an estimate of the number of residents who would require evacuation by bus. Some plans do include an estimate of the number of buses required, but do not give the basis for this estimate. It was noted during the 1982 Beaver Valley exercise that although the Shppingport Borough plan lists a require-l ment for 8 buses, there are actually only 4 borough residents who normally have no private vehicle and those persons will be picked up by a single van. Each municipal-ity should include demand and vehicle requirements, so that the county can adequately plan for bus services, assembly procedures, etc.

Comments on specific plans (in addition to general comments above) are as follows:

Aliquippa Borough - List of required resources (Appendix 9) is blank. Map in Appendix 8 does not show bus pickup points, traffic control posts (TCP), or evacuation routes.

Beaver Borough - Acceptable Bridgewater Borough - Acceptable

Brighton Township - The list of required resources (Appendix 9) is blank.

Center Township - The plan designates only two alert sectors for this very large jurisdiction, some of whic is not covered by sirens. Route alerting would, there-fore, take many hours. The plan lists 2 bus pickup points, but the map in Appendix 8 shows only one. Finally, the list of required resources (Appendix 9) is incomplete.

Chippewa Township - Plan incorrectly lists the evacuation center as " Lawrence Village Plaza," rather than West Gate Shopping Plaza. School evacuation destin-ation is,not listed. The list of required resources (Appendix 9) is incomplete (buses and ambulances are not listed).

Fallston Borough - The plan lists only 3 bus pickup points, but the map in Appendix 8 shows 5 points.

Frankfort Springs Borough - The list of required resources (Appendix 9) is blank.

Georgetown Borough - Although there is a long and detailed list of available re-sources, bus and ambulance requirements are not given. Bus pickup points and evacuation routes are not shown on map in Appendix 8.

Glasgow Borough - The list of resource requirements (Appendix 9) is incomplete.

Evacuation center is incorrectly listed as " Lawrence Village Plaza."

Greene Township - Plan lists 3 bus pickup points, but only one is shown on the map in Appendix 8. Also, the Township is divided into only two very large (16 sq. mi.+)

alert sectors, which would take many hours to alert through route alerting.

Hanover Township - Resource requirements are not listed in Appendix 9. Large areas of the Township are not covered by sirens, according to Appendix 5. But the Township is divided into only 3 very large (12 sq. mi. +) alert sectors for route alerting, which would take many hours to cover.

Hookstown Borough - Ambulance requirements are not shown in Appendix 9. Further, Appendix 9 lists the 28 available school buses as adequate to meet bus needs. How-ever, would these school buses not be needed for school evacuation? Also, are these same 28 school buses listed in the plan for surrounding Greene Township?

Hopewell Township - This Township was one of those listed as having access control responsibility in the county plan. The PSP posts do not cover the southern border of the Township and the Ohio River Bridge to Ambridge. The Township plan does not mention access control. Also, the plan does not designate alert sectors, even though according to Appendix 5 large areas are not covered by sirens. Bus pickup points, TCPs, and evacuation routes are not shown on the map in Appendix 8. Finally, there is no list of required resources.

s Independence Township - The entire Township, about 25 square miles, is a single alert sector, much too large for prompt route alerting. From the map in Appendix 5, it appears that much of the Township is not covered by sirens, so route alerting is necessary. Map in Appendix 8 does not show bus pickup points, TCPs and evacuation routes. The resource list (Appendix 9) is missing.

Industry Borough - School evacuation center (Union Area School) is not listed.

Appendix 9 indicates that no buses or ambulances are needed. Does this mean that all Borough residents have constant access to a private vehicle and none will re-quire evacuation by ambulance?

Midland Borough - Plan incorrectly lists " Lawrence Village Plaza" as evacuation center and does not list the school evacuation center. The plan lists 4 bus pickup points, but 6 are shown on the map in Appendix 8. Appendix 9 indicates that bus needs will be met entirely with school buses. Will these buses not be needed for evacuation of the schools?

Monaca Borough - Acceptable Ohioville Borough - The evacuation center is incorrectly listed as " Lawrence l

Village Plaza" and the school evacuation center is not listed. The resource listing (Appendix 9) is missing.

r Patterson Heights Borough - The evacuation center is incorrectly listed as

" Lawrence Village Plaza" and the school evacuation center is not listed. Bus pickup points, TCPs, and evacuation routes are not shown on the map in Appendix 8.

Finally, Appendix 9 indicates that no buses are needed for evacuation. Does this mean that all Borough residents have constant access to a private vehicle?

Patterson Township - Appendices 5 and 6 are missing. The plan incorrectly lists

" Lawrence Village Plaza" as the evacuation center and does not list the school evacuation center. The Township is assigned access control responsibility in the County plan, but this is not discussed in the municipal plan. Note that the PSP posts do not cover the Township's border with Beaver Falls and White Township. ,

Potter Township - The resource listing (Appendix 9) is blank.

Raccoon Township - The plan lists Arden Downs as the evacuation center and Canon-MdMillen School as the school evacuation center, which is inconsistent with the County plan.

Shippingport Borough - Acceptable. The plan calls for the Shippingport-Industry Bridge to be closed by Borough police. During the 1982 exercise it was observed that the bridge was closed on both ends by nuclear plant security personnel. The authority of such persons to close a public highway was questioned, and this question remains. Also, closure of the bridge would isolate many workers employed in the Shippingport area from their families north of the river and vice versa.

The workers would be forced to evacuate one direction while their families evacuate in the opposite.

South Beaver Township - The plan incorrectly lists " Lawrence Village Plaza" as the evacuation center and does not list the school evacuation center. Only a portion of the Township is in the EPZ, but this is not shown on any map in the plan. The map in Appendix 8 does not show bus pickup points, TCPs, or evacuation routes. The entire Township is shown as a single, huge alert sector in Appendix 6, even though not all is in the EPZ. The area is too large to be covered promptly with a single route alerting team. Since siren coverage is incomplete, according to Appendix 5, route alerting is critical,

, , _ _ _ - , - - - , , _ , _ . ,y... , , e.-- - . . . _ , _ . _ _ _ ~- ,

. , f South Heights Borough - The plan lists " South Park High School" as the school evacuation center, while the county plan lists " South Park Fairgrounds." Otherwise, plan is acceptable.

'Vanport Township - This excellent plan gives much more thorough evacuation procedures than the other municipal plans. The only question is the need for 40 buses for evacuation of residents without access to private vehicles, as shown in Appendix 9.

This sounds excessive for a population of only 2000.

/

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i July 1, 1985

/

Mr. John L. Patten. Director Pennsylvania Emergency Management Agency Transportation and Safety Building Room B-151 Harrisburg, Pennsylvania 17120

Dear Mr. Patten:

FEMA Region III has completed its review of the formal submission of State and local plans applicable to the Beaver Valley Power Station.

We have identified twelve elements which require additional infomation.

Three elements must be addressed prior to submission of these plans for formal 350 approval. These elements are:

1. A.4. - Twenty-four hour staffing capability.

2. J.10.d. - The county plans do not address protective actions for prisoners and staff of the Beaver County Jail. The RERP for this facility is still under development.

3. H.3. - Although the Beaver County E0C is located within the 10-mile EPZ, County plans do not include protective measures for the staff of the E0C.

The other nine elements that require additional information should be addressed during the next annual plan review and update.

If you have any questions concerning the review, please contact me or Janet Lamb at (215) 597-1789.

Sincerely, James R. Asher Chairman Regional Assistance Committee Enclosure cc: Chron File

, NTH /JLamb/1789/jj/7-1-85 ORG NATON CONCURAENCE CONCURRENCE CONCURRENCE CONCURRENCE CONCURRENCE JLamb JAsher Name

((SI Skk Date U ]-I - ff OFFICI AL RECORD COPY

.t:.s. mo 1983-4 ras-9s t

- A 1 '

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FEDERAL EMERGENCY MANAGEMENT AGENCY REGION III REVIEW 0F 0FFSITE RADIOLOGICAL EMERGENCY RESPONSE PLANS FOR THE BEAVER VALLEY POWER STATION PENNSYLVANIA EPZ JUNE 1985 i

l

Rating Key: A = Adequate I = Inadequate PLANNING STANDARD /

ELEMENT RATING COMMENTS ,

A. Assignment of Responsibility (Organizational Control)

A.1.a. A Various appendices chart State, county and subcounty response entities; in addition the responsibilities of offsite planning and response of the major State, local, federal, and private sector organizations are listed and briefly summarized.

All references in the State plan and Annex 12, DER /BRP plan to IRAP should be replaced with Federal Radiological Emergency Response Plan (FRERP). The FRERP identifies the responsibilities of each Federal agency involved in response to a radiological incident.

A.1.b. A The State and county plans specify concepts of operation for each organization and suborganization through a combination of paragraphs within the basic plan. Concepts of operation applicable to specific suborganizations at State and county levels are addressed through annexes devoted to the responsibilities of the suborganizations. Concepts of operation for the 27 municipalities within the 10-mile cPZ are addressed in the municipal plans.

A.1.c. A All applicable plans have illustrated the inter-relationships of response organizations in block diagrams.

A.1.d. A Specific individuals in charge of emergency response have been identified in the plans.

A.1.e. A The State EOC uses the duty officer concept for 24-hour communications capability. Beaver County Communications Center is manned 24-hours a day and procedures are in place for 24-hour notification to all resp,onse agencies and support organizations.

A.2.a. A The criterion in this element has been met. Functions of Public Health, Sanitation and Social Services have been added to Basic Plan, Appendix 2, p. 2-1.

A.2.b. A A.3. v/ I Support county plans for Allegheny, Butler, Lawrence and Washington counties and 12 school district plans have been developed and submitted for review.

However, no plans have been submitted for the Beaver County Jail. The Beaver County Plans state that this plan is still under development.

1 l

l The primary means of disseminating emergency instructions to the public is the EBS. Speci fic instructions for EBS activation are contained in the Pittsburgh Extended EBS Operational Area Plan; however, EBS Operational Area Plans are not listed as support documents in the Beaver County RERP. The county plan does contain letters of agreement with specific radio stations. The EBS Operational Area Plans should also be included as support documents.

A.4.

bgE E I Staffing of Beaver County and the 27 municipalities has not been adequately addressed in the RERP plans.

All plans state that each staff officer is responsible for notification of deputy and staff. However, deputies or second shift personnel should be listed in the plans. In some cases in the municipal plans the emergency management organization chart and emergency notification list positions do not match.

Only four communities demonstrated 24-hour staffing capability, as outlined in their plans, during the June 25, 1984 exercise. These communities are Aliquippa Borough, Beaver Borough, Midland Borough and South Heights Borough.

The following communities adequately demonstrated a 24-hour staffing capability during the June 25, 1984 exercise, but the RERP plans do not reflect the 24-hour staffing capability that was demonstrated. Plans should include the second shift roster: Brighton ,

Township, Independence Township, Monaco Township, Ohioville Borough, Patterson Township. Raccoon Township, Shippingport Borough and Beaver County.

The following RERP plans do not contain information on second shift personnel and no second shift capability was demonstrated during the June 25, 1984 full-participation exercise: Center Township, Industry Borough, South Beaver Township and Vanport Township.

The RERP plans for Hopewell and Chippewa townships do not contain complete staffing of positions noted in the plan for first shift. Complete first shift staffing was not demonstrated as outlined in the RERP

• ~

during the June 25, 1984 exercise. A roster was presented for the second shift.

The following communities' staffing lists are not complete in the RERPs; and full staffing for both shifts was not demonstrated during the June 25, 1984 full-participation exercise: Bridgewater Borough, Hookstown Borough, Fallston Borough, Georgetown Borough, Glasgow Borough, Greene Township, Potter Township and Hanover Township.

2

i C. Emergcncy Response Support and Resources C.1.a. A These elements are adequately addressed in Annex E of C.I.b. A the Disaster Operations Plan on page E-36.

C.I.c. A .

C.2.a. A Beaver County will rely on the Pennsylvania Emergency Management Agency who in turn sends a representative from the Bureau of Radiation Protection to the Beaver Valley Emergency Operations Facility.

C.3. A See Appendix 12 of Annex E, State Disaster Operations Plan.

h g[@ I C.4. Ten bus companies have been listed in Annex I to provide buses to the county for evacuation purposes; however, the plan contains a letter of agreement from only one (Beaver County Transit Authority).

The municipal plans state that letters of agreement are on file in the E0C. A copy of letters of agreement or, at a minimum, a list of agreements with specific companies / individuals should be included in municipal plans.

D. Emergency Classification System D.3. A State and local plans have established an emergency classification and action schene consistent with that established by the utility.

D.4. A State and local plans have procedures in place for actions to be taken at each action level which '

consider conditions at time of the emergency.

E. Notification Methods and Procedures E.1. -( ((&

I Procedures have been established for notification of emergency response organizations consistent with emergency action levels; however, a specific step for verifi. cation of messages should be included.

E.2. A Procedur's e have been established for alerting, notifying and activation of emergency response personnel.

E.5. A EBS stations, both CPCS-1 and CPCS-2 stations, are identified in the Beaver County Plan, in addition to other alternate radio stations. Both stations operate 24-hours a day, seven days a week, and have backup power capabilities available.

3

O The Beaver County Commissioners have designated the fa)' I Emergency Management Coordinator as the official responsible for siren /EBS activation. Specific procedures for EBS activation for Beaver County officials and for radio; station personnel are contained in the Pittsburgh Extended EBS Operational Area Plan; however, this plan is not listed as a supporting document in the Beaver County Plan, or in the Alert and Notification System design.

A Beaver County, the one Pennsylvania risk county for the Beaver Valley Power Station, participates in the Pittsburgh Extended Operational Area EBS Plan. In addition, letters of agreement are included in the Beaver County Plan with radio station KDKA, the CPCS-1 station and two other local stations. The county plan does not include a letter of agreement with WTAE, the CPCS-2 station.

A The prescripted EBS announcements on protective actions included in the plan contain broadcast instructions to repeat announcements every five minutes. The General Evacuation will be repeated continuously until the authorized county official instructs the radio station to end the EBS messages.

A The alert and notification system design states that Beaver County E0C has a radio in the E0C to monitor EBS announcements. In addition, the prescripted EBS announcements have been provided to the EBS stations and thereby minimizes the possibility of an error in -

the announcements.

E.6. A See Final Draft Report on the Alert and Notification System Design Report and Public Survey conducted at the Beaver Valley Power Station.

E.7. A State and county plans have included in Appendix 8 of the State Plan and Annex D of the county plan, appropriate prescripted public announcements with proper instructions pertaining to protective actions.

F. Emergenc'y Communications F.1.a. A Should an incident occur, the Beaver Valley Control Room will send initial notification to Beaver County (parent county) and the PEMA. PEMA is responsible for initial notification to the Bureau of Radiation Protection. The Beaver Valley Power Station and Beaver County E0C are manned 24-hours a day, seven days a week. PEMA and BRP use a duty officer system to maintain 24-hour coverage.

4

PEMA uses commercial telephone lines for initial notification to BRP. Should telephone communications be inoperable, the secondary means of communication is via the Duquesne Light Company industrial radio system. This radio system is available in the Beaver County 24-hour communications center. Additional backup means of communications are available between the State and county and municipal E0Cs.

The primary (Bell Telephone net) and secondary (radio net) communications nets were selected to preclude the possibility of common failure. The communications systems at the utility and State and local locations have provisions for backup power in the event of loss of normal AC power.

F.1.b. A Communications with contiguous states and federal F.1.c. A agencies is available via commercial telephone and Civil Defense National Teletype System (CDNATS) with backup voice communciations through the Civil Defense National Radio System (CDNARS) both operated through FEMA Region III, Olney, Maryland.

F.1.d. A Once emergency operations centers have been activated, the primary means of communications will be replaced by separate "on-demand" dedicated telephone lines.

Dedicated telephone lines have been established between Beaver Valley Power Station, BRP, the EOF, Beaver County E0C, and PEMA. These dedicated telephone lines are outside the regular commercial network and are not subject to telephone switching offices or unauthorized interception.

F.1.e. A The primary means of communications between Beaver County and various emergency services organizations is via already existing radio nets. Beaver County maintains backup radio communications with municipal E0Cs, Pennsylvania State Police, American Red Cross, EBS stations, RACES and REACT, support counties and contiguous counties. Hard copy verification of oral messages is available through a telefax system and a Warning,and Communications teletype between PEMA and Beaver County.

F.2. A Communications with fixed and mobile medical facilities are via telephone and the county radio net, a well-established radio net which is used on a routine basis.

F.3. A Communications drills between the utility, Si: ate, county and municipal emergency organizations are conducted monthly.

5

G. Public Education and Information G.I.a. A The Beaver Valley Power Station, Pennsylvania G.I.b. Emergency Management Agency and Beaver County G.I.c. Emergency Management Agency coordinate in the advance G.1.d. development and distribution of public information to inform persons living, working and travelling in risk areas of the plans and procedures for their notification and points of contact for information in the event of an incident at the Beaver Valley Power "

Station. Publ4c4nformat3DfL b rochures-were-l ast -

mailed-out-4 n-May-1984.

G.2. A Public information brochures to the public and for farmers in the EPZ a#pr'elsntlftIsiWg' updated and Mdi~56 distributed throughout the EPZ again in August 1985.

G.3.a. A Points of contact and locations have been identified in the State and county plans.

A near site media center has been established by the utility. A State Public Information Officer is dispatched to this Joint Media Center.

G.4.a. A Spokespersons have been named for each principal response organization.

G.4.b. A The PEMA Public Information Officer is responsible for coordination of information exchange between all principal response organizations.

G.4.c. A A rumor control center will be established by the Governor's Press Secretary at State level and by the Beaver County Public Information Officer at county level . Rumor control telephone numbers will be disseminated to the public at the time of an incident. All rumor control activities will be coordinated between State and county rumor control centers. At the municipal level, the police services office is responsible for rumor control. However, this responsibility is not listed in the Appendix for Police Services in municipal plans.

G.S. A A news media orientation, which is co-sponsored by the Beaver Valley Power Station and PEMA, is presented to news media representatives annually. Beaver County Emergency Management Agency participates in this annual orientation. The orientation familiarizes news media representatives with Radiological Emergency Response Plans and points of contact for the release of information to the public.

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H. Emergency Facilities and Equipment H.3. O I As stated in the PEMA June 21, 1983 letter and B

- NY reiterated in the PEMA July 26, 1983 letter

Subject:

I Updated Status Report on Deficiencies Noted During the March 23, 1983 Exercise for Susquehanna, the State's pnlicy to implement an all-sector (360 degree) EPZ

.j evacuation does apply to all E0Cs within a 10-nile radius of the nuclear facTTTty. The Beaver County E0C lies within the 10-mile EPZ of the Beaver Valley Power Station. Although plans do address the evacuation of municipal E0Cs, no plans for the protection of.the county E0C personnel have been included. Planning for protective actions for the Beaver County Emergency Operations Center personnel must be included in the Beaver County Radiological Emergency Response Plans.

H.4. A Specific notification and activation procedures are identified for staffing of all facilities and centers in the emergency action level guidelines.

l' H.7. A The Bureau of Radiation (BRP), through PEMA, will provide a representative at the Emergency Operations i

Facility to provide for receipt and analysis of field monitoring data. The BRP representative will provide

this information along with recommendations to PEMA,.

who, in turn, makes decisions and coordinates the .

implementation of those decisions with the risk county.

H.10. A PEMA will physically conduct an annual inventory /

inspection / operational check of special equipment. '

Each risk and support county is responsible for performing a complete inventory of all special equipment and for making equipment available to PEMA at a central location.

Thermoluminescent Dosimeters (TLDs) are replaced annually. PEMA will exchange TLDs on a one for one basis.

H.11. A Lists. of special equipment kits and a breakdown by response organization is provided in Appendix 3 to

Annex M of the Beaver County Plan.

H.12. A See comments for H.7.

I. Accident Assessment I.7. A The State Bureau of Radiation Protection provides technical personnel and performs those tasks

<. associated with incident assessment and field monitoring.

l 1 7 B

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I.8. "

A The State Department of Agriculture, Environmental Resources and Bureau of Radiation Protection provide monitoring teams for sampling for radiation contamination within the EPZ. Procedures for notification and activa, tion of monitoring teams are contained in Appendix 12 of the State plan.

I.9. A This is a State responsibility which has been adequately addressed in the Beaver County RERP.

J. Protective Response J.2. g I The licensee is responsible for planning for the

( evacuation of all non-essential personnel from onsite to offsite. The State plan does contain a reference that the licensee should coordinate the plan developed for this purpose with PEMA and the parent county (Beaver) to avoid conflict with State and county evacuation procedures. The Beaver County plan does not address an onsite evacuation at all. As a minimum, those sections of the licensee plan dealing with evacuation routes and relocation areas for onsite personnel should be highlighted in the Beaver County Plan.

J.9. A The State and local plans, in most cases, have developed the capability for implementing protective measures. Protective measures for the general public will include sheltering, selective evacuation and general evacuation. Various actions will be implemented to support these protective actions to ~

include: activation of alert and notification system, traffic and access control, mass care, agriculture, transportation and medical support.

Radiological exposure control actions will be used for protection measures for emergency workers. The necessary dosimetry, radioprotective drugs (KI) and critical information and instructions will be provided. Monitoring and decontamination is provided for the general public and emergency workers.

Protecti,ve measures for institutionalized individuals is disucssed under element J.10.d.

J.10.a. q 2I Appropriate maps are contained in tiie State and county Q plans. The maps should be added to the municipal plans, especially the evacuation routes and relocation centers that each jurisdiction should use.

Information in Appendices 1 and 2 to Annex J should be included in each applicable municipal plan, J.10.b. A Population of the 10 and 50 mile EPZ are discussed in both State and county plans.

8

J.10.c. A This element has been adequately addressed. See comments for E.5 and E.6.

J.10.d. fg I Plans are being developed'for the two hospitals and three nursing homes loc 4ted within the 10-mile EPZ.

(g The Beaver County Jail is located within the 10-mile EPZ; however, the county plan does not address protective actions for the prisoners and staff of the jail; in addition, the plan for the Beaver County Jail is still under development.

The municipalities are responsible for the evacuation of homebound individuals with assistance by the county who will coordinate ambulance resources. The county now lists 223 ambulances available which should be sufficient for the needs of the Beaver County 10-mile EPZ.

Municipal plans state that names of homebound and hearing-impaired individuals are on file with the EMA Medical Officer and fire department. At a minimum, the numbers of homebound and hearing-impaired should be included in the municipal plans.

J.10.e. A Liquid KI is predistributed to risk hospitals for staff and patients to be taken only when instructed by the Pennsylvania Secretary of Health.

J.10.f. A J.10 9 A The primary means of relocation is the private -

automobile with bus transportation for those individuals without automobile transportation. The county and municipal plans now include an estimate of the number of individuals requiring transportation assistance. Additional bus resources have been identified. The plan goes on to allocate specific buses to each municipality.

J.10.h. A Relocation centers have been identified and are all located at least 20 miles from the facility.

J.10.1. A o

J.10.j. I Annexes F and K present several lists of access and

( traffic control points to be set up by state police.

These posts only cover the northern boundary of the EPZ from the Ohio line to approximately Route 588 and the southern boundary from about Route 60 to the West Virginia border.

9

The eastern EPZ boundary from SR 588 on the north along the Beaver and Ohio. Rivers to Cresent on the south is not covered by the lists. This boundary includes densely populated areas adjoining Beaver Falls. Lack of control,of access into the EPZ along the most populous corridors is a critical problem.

Specific plans for access control points and manning procedures must be developed by PSP, the county or ,

appropriate municipalities.

J.10.k. A J.10.1. A K. Radiological Exposure Control K.3.a.

4) I

\,

1 Each emergency worker assigned tasks in the plume exposure pathway will be issued one COV-730 or one DCA h 622 (0-20R) and one CDV-742 (0-200R), a thermoluminescent dosimeter (TLD) and a 14 day supply of KI. Presently, not enough dosimeters are on hand, but a contract has been signed. Verification that equipment has been delivered should be provided to FEMA Region III.

K.3.b. A Emergency workers are responsible for proper reading and recording of dosimetry.

K.4. I The plans do not present a decision chain for .

3 g emergency workers to exceed the exposure in the 1-5 g P3 p rem range (PAG for the general public). Emergency F g workers are allowed to go to the full 25 rem dose. A decision point at the lower dose should be established djf to ensure minimum dose possible is received by any one c, d emergency worker.

s The plans state that unnamed, untitled elected officials in authority may authorize emergency workers to exceed the 25 rem in a life threatening situation.

The official authorized to give permission for emergency workers to exceed emergency worker PAGs should be a specifically named and titled person within the elected State, county or local government.

K.5.a. A BRP has set the action level at which decontamination of an individual is necessary to be 0.05 mR/h above background.

K.5.b. A Five emergency worker decontamination stations have been set up in the plan. In addition, emergency workers may be monitored and decontaminated, if necessary, at any of the mass care centers. If necessary, the decontamination team will refer individuals to one of the medical facilities listed in Annex G of the county plan.

10

L. Medical and Public Health Support L.1. A Forty hospitals have been.. included in the Beaver L.3. County plans as having the capabilities for receiving and treating radiation victims. Two of these are listed as primary; the Medical Center of Beaver Valley and Aliquippa Hospital . The State plan lists all hospitals in the State with this capability.

L.4. A Local ambulance services within Beaver County, which are also dispatched on a routine basis by the county, will be used to transport victims of radiological accidents.

M. Recovery and Reentry Planning and Post Accident Operations M. A The Governor, with the recommendation of PEMA and BRP will announce when citizens may return to their homes. The order to initiate reentry will be announced over EBS by the County Commissioners.

N. Exercise and Drills N.1.a. A State and local plans have been updated to reflect N.1.b. their full participation in exercises every two years. PEMA has elected to participate fully every year with one of the five sites in Pennsylvania.

N.2. A State and local plans state that the required drills '

are held within the time frames stated in NUREG-0654.

N.3. A The Pennsylvania Emergency Management Agency is responsible for the development of offsite scenarios for full-participation exercises. The scenario for an exercise is supplied to FEMA 45 days prior to the exercises. The utility, county, and municipal emergency response organizations are to participate in scenario planning. A basic concept of operation for all Pennsylvania full-participation exercises is the

" free flow" concept, whereby exercise actions are

. based on decisions and implementing actions taken by the players, and not from prearranged times for events to occur.

N.5. A The State and local emergency response plans adequately provide for critiques of exercise activities. A critique is held within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the exercise with State, county and municipal players in attendence. PEMA is responsible for review of federal observers evaluation and for assigning responsibility for implementation of corrective actions.

11

0. Radiological Emergency Response Training

0. A State and local plans adequately address training programs as outlined in NUREG-0654.

P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans P. A State and local plans have designated the Emergency Management Coordinators as the persons responsible for development, review and annual update of Radiological Emergency Response Plans.

9

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REPORT OF RESOLUTIONS OF FORMAL RAC COMMENTS FOR THE BEAVER VALLEY POWER STATION PENNSYLVANIA EPZ (BEAVER COUNTY) s k

Inadequacy *as related to. Support county plans for Allegheny, Planning Standard / Element A.3. Butler, Lawrence and Washington counties and 12 school district plans have been developed and submitted for review.

However, no plans have been submitted for the Beaver County Jail. The Beaver County Plans state that this plan is still under development.

The primary means of disseminating emergency instructions to the public is the EBS. Specific instructions for EBS activation are contained in the Pittsburgh Extended EBS Operational Area Plan; however, EBS Operational Area Plans are not listed as support documents in the Beaver County RERP. The county plan does contain letters of agreement with specific radio stations. The EBS Operational Area Plans should also be included as support documents.

Corrective Action: Jail Plan developed and approved by County Prison Board and Warden on October 10, 1985.

Beaver County EBS Plan developed using Commonwealth Plan is guidance approved by Chairman of Board of Commissioners and Emergency Management Agency on October 7, 1985.

• Both County approved documents have been '

referenced in the Beaver County RERP as support documents as reflected in proposed Change 1, dated October 1985.

Copies of plans and developmental material comprise the Attachments to this report.

Inadequacy as related to Staffing of Beaver County and the 27 Planning Standard / Element A.4. municipalities has not been adequately addressed in the RERP plans. All plans state that each staff officer is responsible for notification of deputy and staff. However, deputies or second shift personnel should be listed in the plans. In some cases in the municipal plans the emergency management organization chart and emergency notification list positions do not match.

Only four communities demonstrated 24-hour staffing capability, as outlined in their plans, during the June 25, 1985 exercise. These communities are Aliquippa Borough, Beaver Borough, Midland Borough and South Heights Borough.

1

The following communities adequately demonstrated a 24-hour staffing capability during the June 25, 1984 exercise, but the RERP plans do not reflect the 24-hour staffing capability that was demonstrated. Plans should include the second shift roster: Brighton Township, Independence Township, Monaco Township, Ohioville Borough, Patterson Township, Raccoon Township, Shippingport Borough and Beaver County.

The following RERP plans do not contain information on second shift personnel and no second shift capability was demonstrated during the June 25, 1985 full-participation exercise Center Township, Industry Borough, South Beaver Township and Vanport Township.

The RERP plans for Hopewell and Chippewa townships do not contain complete staffing of positions noted in the plan for first shift.

Complete first shift staffing was not demonstrated as outlined in the RERP during the June 25, 1984 exercise. A roster was presented for the second shift.

The following communities' staffing lists are not complete in the RERPs' and full staffing for both shifts was not demonstrated during the June 25, 1984 full-participation exercise Bridgewater Borough, Hookstown Borough, Fallston Borough, Georgetown Borough, Glasgow Borough,

• Greene Township, Potter Township and Hanover Township.

Corrective Action: The County and each of the 27 municipalities at risk have identified second shift personnel or deputies for every position in their respective organization. All organization charts have been revised to reflect personnel and staff as stated in the emergency notification lists of each plan.

Each of these municipalities have committed to training and participation in exercises for both shifts' personnel.

Inadequacy as related to Ten bus companies have been listed in Annex I Planning Standard / Element C.4. to provide buses to the county for evacuation purposes; however, the plan contains a letter of agreement from only one (Beaver County Transit Authority).

The municipal plans state that letters of agreement are on file in the EOC. A copy of letters of agreement or, at a minimum, a list of agreements with specific companies / individuals should be included in municipal plans.

2

Corrective Action: Each of the bus providers listed in Annex I to provide buses to the County were approached to sign statements of understanding wherein they are aware of the necessity.should an evacuation be ordered. Eight of the companies have signed a statement of understanding for use of their available resources whenever necessary. One company has signed at statement with the school district it is contacted to, which is a risk district.

A listing of all local fuel providers.and towing i services has been included in the 27 municipal plans, Appendix 13.

Inadequacy as related to Procedures have been established for notification Planning Standard / Element E.1. of emergency response organizations consistent with emergency action levels; however, a specific step for verification of messages should be included.

Corrective Action: A step for the verification of messages has been included in proposed Change 1, Beaver County RERP,.

Annex C, Appendice 2.

Inadequacy as related to The Beaver County Commissioners have designated Planning Standard / Element E.5. the Emergency Management Coordinator as the official responsible for the siren /EBS activation.

Specific procedures for EBS activation. Specific procedures for EBS activation for Beaver County officials and for radio station personnel are contained in the Pittsburgh Extended EBS Operational Area Plant however, this plan is not listed as a supporting document in the Beaver County Plan, or in the Alert and Notification System design.

Corrective Action: A Beaver County EBS Plan was developed and approved by the County on October 7, 1985. The plan follows and complements the Commonwealth EBS Plan, the procedure entitled the Pittsburgh Extended EBS Operational Area Plan and has been included in the County and 27 municipal plans as support documents.

3

Inadequacy as related to Emergency Facilities and Equipment Planning Standard / Element H.3. .

As stated in the PEMA June 21, 1983 letter and reiterated in the PEMA July 26, 1983 letter, Subject ~ Updated Status Report on Deficiencies Noted During the March 23, 1983 Exercise for Susquehanna, the State's policy to implement an all-sector (360 degree) EPZ evacuation does apply "

to all EOCs within a 10-mile radius of the nuclear facility. The Beaver County EOC lies within the 10-mile EPZ of the Beaver Valley Power Station.

Although plans do address the evacuation of municipal EOCs, no plans for the protection of the county EOC personnel have been included.

Planning for protective actions for the Beaver County Emergency Operations Center personnel must be included in the Beaver County Radiological Emergency Response Plans.

Corrective Action: The Beaver County EOC is located marginally within the 10-mile EPZ. (9.6 miles from site boundary)

In the event of an incident at the Beaver Valley Power Station, all County EOC staff will be treated as emergency workers to include units of dosimetry for each. The EOC also serves as the County's Communications Center on a day to day basis providing radio communications to 35 police and 38 fire departments. Unless extreme circumstances present themselves, the County EOC will not relocate. Should this become a necessity, the EOC would relocate to Rochester township, to a county owned facility. This position has been included in the County plan under Annex A, Direction and Control.

Inadequacy as related to The licensee is responsible for planning for the Planning Standard / Element J.2. evacuation of all non-essential personnel from onsite to offsite. The State plan does contain a reference that the licensee should coordinate the plan developed for this purpose with PEMA and the parent county (Beaver) to avoid conflict with State and County evacuation procedures. The Beaver County plan does not address an onsite evacuation at all. As a minimum, those sections of the licensee plan dealing with evacuation routes and relocation areas for onsite personnel should be highlighted in the Beaver County Plan.

Corrective Action: All information pertaining to the evacuation of non-essential personnel from onsite has been coordinated with the County and applicable municipalities. The information has been included in Annex J, Evacuation of the Beaver County Plan and also the affected municipalities plans to include Shippingport, Raccoon and Hookstown and Potter.

4 -

Inadequacy as related to Appropriate maps are contained in the State and Planning Standards / Element J.10.a. County plans. The maps should be added to the municipal plans, especially the evacuation routes and relocation centers that each jurisdiction should use.

Information in Appendices 1 and 2 to Annex J should be included in each applicable municipal plan.

Corrective Action: Resolution to this inadequacy has been resolved by including in each municipal plan a map of the Beaver Valley Evacuation Plan which designates main evacuation routes and their respective destinations.

Inadequacy as related to Plans are being developed for the two hospitals Planning Standard / Element J.10.d. and three nursing homes located within the 10-mile EPZ. The Beaver County Jail is located within the 10-mile EPZ; however, the county plan does not address protective actions for the prisoners and staff of the jails in addition, the plan for the Beaver County Jail is still'under development.

The municipalities are responsible for the evacuation of homebound individuals with.

assistance by the county who will coordinate ambulance resources. The county now lists 223 ambulances available which should be sufficient for the needs of the Beaver County 10-mile EPZ.

Municipal plans state that names of homebound .

and hearing-impaired individuals are on file with the EMA Medical Officer and fire department. At a minimum, the numbers of homebound and hearing-impaired should be included in the municipal plans Corrective Action: Plans for the two hospitals are being finalized for final approval by the hospitals and nursing home plans are under development.-

The Beaver County Jail Plan has been developed and approved by the Prison Board and Warden of the Beaver County Jail on October 11, 1985.

Appendix 5 of the municipal plans has been revised to indicate the numbers of homebound and hearing impaired individuals in each municipality.

Duquesne Light reissued the annual mailer with special needs cards for 1985 and those cards received have been incorporated into applicable municipal plans and the information kept on file at the County Emergency Management Agency.

5

Inadequacy as~related to Annexes F and K present several lists of access Planning Standard / Element J.10.j. and traffic control points to be set up by state police. These posts only cover the northern boundary of the EPZ from the Ohio line to approximately Route 588 and the southern boundary from about Route 60 to the West Virginia border.

The eastern EPZ boundary from SR 588 on the north along_the Beaver and Ohio Rivers to Cresent on the south is not covered by the lists. This boundary includes densely populated areas adjoining Beaver Falls. Lack Of control of acces:

into the EPZ along the most populous corridors is a critical problem. Specific plans for access control points and manning procedures must be developed by PSP, the county or appropriate municipalities.

Corrective Action: A review of access and traffic control points around the 10-mile area of Beaver Valley has been conducted by the County. There have been 5 ACP's added to the eastern boundary of the EPZ along the Beaver and Ohio Rivers, which are included in the proposed Change 1 to the Beaver County RERI These have been coordinated with the Pennsylvania State Police in Harrisburg, the local barracks 1 . and the county.

Also resolved was the elimination (and subsequent assignmen-) of local police being assigned to man principle points. All points designated as -

major will be manned by PSP.

Inadequacy as related to Each emergency worker assigned tasks in the plume Planning Standard / Element K.3.a. exposure pathway will be issued one CDV-730 or one DCA 622 (0-20R) and one CDV-742 (0-200R) , a thermoluminescent dosimeter (TLD) and a 14 day supply of KI. Presently, not enough dosimeters are on hand, but a contract has been signed.

Verification that equipment has been delivered should be provided to FEMA Region III.

Corrective Action: State response required.

Inadequacy as related to The plans do not present a decision chain for Planning Standard / Element K.4. emergency workers to exceed the exposure in the 1-5 rem range (PAG for the general public).

Emergency workers are allowed to go to the full 25 rem dose. A decision point at the lower dose should be established to ensure minimum dose possible is received by any one emergency worker.

6

(

The plans state that unnamed, untitled elected officials in authority may authorize emergency workers to exceed the 25 rem in a life threatening situation. The official authorized to give permission for emergency workers to exceed emergency worker PAGs should be a specifically named and titled person within the elected State, county or local government.

Corrective Action: State or address decision chain for emergency workers to exceed the exposure in the 1-5 rem range.

All 27 municipal plans have been changed to reflect that titled elected officials in authority may authorize exceeding PAG's and each has referenced the organization chart in Appendix 1 of their respective RERP.

Comments address and actions implemented A.1.a All references to IRAP have been changed to FRERP in the County RERP.

E.5. Statement of Understanding obtained and included in the County RERP for WTAE, CPCS-2 Station.

G.4.c. Rumor control responsibility has'been taken away

. from the municipalities and given to the County ^

as the sole source for rumor control, s

7 1

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u iy Federal Emergency Management Agency j Region III 105 South 7th Street Philadelphia, Pennsylvania 19106 i Tk z .e May 11, 1987 MEMORANDUM FOR: ' Robert S. Wilkerson, Chief Technological Hazards Division FROM: James R. Asher, Chief M L Technological Hazards Br inch

SUBJECT:

Corrective Action for eficiency Noted for the Pennsylvania State EOC During Beaver Valley Exercise, November 19, 1986 During the Beaver Valley full participation Exercise held on November 19, 1986, the Pennsylvania Emergency Management Agency (PEMA) did not participate. The lack of participation on the part of the State E0C resulted in a Deficiency. Corrective actions supplied to FEMA Region III stated that this Deficiency would be corrected during the Susquehanna Exercise.

On April 29, 1987, the Pennsylvania Emergency Management Agency did participate in the Susquehanna Exercise; thereby correcting the Deficiency identified in the Beaver Valley Exercise Report.

TTY FOR DEAF 215-597-o850

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4 Federal Emergency Management Agency i .p Region III 105 South 7th Street Philadelphia, Pennsylvania 19106 EAY 111987 MEMORANDUM FOR: Robert S. Wilkerson, Chief Technological Hazards Division ATTENTION: Megs Hepler FROM: James R. Asher, Chie [NJtfJd '

Technological Hazards ra ich

SUBJECT:

Support Hospitals for eaver Valley Power Station Attached per your request is a list of all hospitals available to support an inicident at the Beaver Valley Power Station.

TTY FOR DEAF 215 597-0850

ATTACHMENT I APPENDIX 13' LOCAL AND BACKUP HOSPITALS SERVING IN A GENERAL SUPPORT CAPACITY TO THE BEAVER VALLEY POWER STATION I. RISK COUNTIES A. Beaver County - Note: The Medical Center of Beaver County and the Aliquippa Hospital are located in the risk area and arc listed in Attachment D in this Appendix.

II. SURROUNDING COUNTIES Number of Beds A. Allegheny County

1. North Hills Passavant Hospital 296 9100 Babcock Boulevard Pittsburgh, PA 15237

2. East Suburban Health Center 318 2570 Haymaker Road Monroeville, PA 15146 fr.

tu

3. Sewickley Valley Hospital 259 Blackburn Road .

Sewickley, PA 15143 (412) 741-6600

4. McKeesport Hospital 617 1500 Fifth Avenue McKeesport, PA.~15132 (412) 664-2300

5. Allegheny General Hospital 726 320 East North Avenue Pittsburgh, PA 15212 i (412) 237-3131

6. Central Medical Health Services, Inc. 233

1200 Centre Avenue Pittsburgh, PA 15219

'(412) 562-3000

7. Children's Hospital of Pittsburgh 243 1200 Centre Avenue Pittsburgh, PA 15219 (412) 647-2345 CHANGE 2 NOV. 1982 E-13-I-1

Numbtr of Bedt

8. Divine Providence Hospital 177 1004 Arch Street

< Pittsburgh, PA- 15212 (412) 322-0700

9. Mercy Hospital 645 1400 Locust Street Pittsburgh, PA 15219 (412) 232-8111

10. Presbyterian University Hospital- 564 DeSoto and Ohara Streets Pittsburgh, PA 15213 (412) 647-3010

11. Saint Francis General Hospital 706 45th Street off Penn Avenue Pittsburgh, PA 15201 (412) 622-4343

12. Shadyside Hospital- 462 5230 Centre Avenue Pittsburgh, PA 15232 (412) 622-2121

13. South Hills Health System 390 Box 18119, Coal Valley Road Pittsburgh, PA 15236 (412) 664-5000

14. St. Clair Memorial Hospital 385 ,

1000 Bower Hill Road Pittsburgh, PA 15243 (412) 561-4900

15. St. Johns General Hospital 194 3339 McClure Avenue Pittsburgh, PA 15212 (412) 766-8300 i

l- 16. St. Margaret Memorial Hospital 250 l 815 Freeport Road l Pittsburgh, PA 15215 (412) 784-4000

17. South Side Hospital of Pittsburgh 306 l S. Twentieth and Jane Streets Pittsburgh, PA 15203 (412) 481-3300

18. Montefiore Hospital Association of 429 Western Pennsylvania 3459 Fifth Avenue Pittsburgh, PA 15213 (412) 683-1100 CHANGE 2 NOV. 1982 E-13-I-2

Numb 2r of Beds

19. Suburban General Hospital 218

. South Jackson Avenue Pittsburgh, PA 15202 (412) 734-1800

20. Western Pennsylvania Hospital 604 4800 Friendship Avenue Pittsburgh, PA 15224 (412) 682-4200

21. Allegheny Valley. Hospital 333 1301 Carlisle Street Natrona Heights, PA 15065 (412) 224-5100

22. Braddock General Hospital 235 400 Holland Avenue Braddock, PA 15104 (412) 351-3800

23. Columbia Health Center 240 Penn Avenue & West Street Wilkinsburg, PA 15221 (412) 247-2424

24. Ohio Valley General Hospital 168 Heckel Road McKees Rocks, PA 15136 ,,-

(412) 777-6161 Vi,

25. West Allegheny Hospital 93 ,

7777 Steubenville Pike Oakdale, PA 15071 (412) 788-4900 B. Butler County

1. Butler County Memorial Hospital 391 East Brady Street Extension Butler, PA 16001 (412) 283-6666 C. Lawrence County

1. Elwood City Hospital 107 724 Pershing Street Elwood City, PA 16117 (412) 752-0081

2. Jameson Memorial Center 277 West Leasure Avenue New Castle, PA 16105 (412) 658-9001 CHANGE 2 E-13-I-3 NOV. 1982

~

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Number of Beds

3. Saint Francis Hospital of New Castle 202

( South Mercer at Phillips Street New Castle, PA- 16101 (412) 658-3511

'D. Washington County

1. Cannonsburg General Hospital 105 Barr Street Cannonsburg, PA 15317 (412) 745-6100

2. Washington Hospital 502 155 Wilson Avenue Washington, PA 15301 (412) 225-7000

3. Monogahela Valley Hospital, Inc. 311 Route 88, County Club Road Monogahela, PA 15063 (412) 258-2000 f

CHANGE 2 NOV. 1982 E-13-1-4