ML20236L429

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Forwards FEMA 871015 Memo to State of Mo Addressing FEMA Findings from 871007 Joint Exercise of Plant.Five Deficiencies Identified for State Emergency Mgt Agency & Atchison County.Fema Requested Remedial Drill Be Conducted
ML20236L429
Person / Time
Site: Cooper Entergy icon.png
Issue date: 11/05/1987
From: Callan L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Trevors G
NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8711100334
Download: ML20236L429 (6)


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a J NOV 5196T - 1 1

In. Reply _ Refer To: _ s <

l Docket: '50-298/87-25 I

Nebraska'Public' Power District 1

! ATTN: . George A Trevors j

n Divistor. Manager -: Nuclear: Support ,7 '

P., 0. Box 499- -

Columbus, NE- :68601 L j

Gentlemen: .,

1 Attached is a copy.of a memorandum; dated Octoberc15,=1987, from the-Federal; Emergency Management' . Agency (FEMA)! Regional' Director, J' D. 0verstreet tolthe :

Missouri? State Emergency ManagementiAgency Director, R. D..Ross.- The-memorandum addresses, FEMA findings resulting from the October 7, c1987, Cooper -- ~~

. Nuclear Station _ joint-exercise.

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a, There were five deficiencies identified.during this exercise for the Missouri.

State Emergency Management _ Agency and Atchison County. . The FEMA Regional.

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,1 Director-has requested that a remedial drill be conducted byithe Missouri-  ;

State. Emergency Management Agency.and Atchison Co'unty. The drill 11s to be; j conducted utilizing several scenario requirements. The requirements are .q listed on page 3. '

It is requested that you cooperate with the sta'te and' county in expeditiously correcting these deficiencies,

~i If you have.any further questions please contact this office.-

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a Sincerel'y, >

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,Oilginal Signed By .

A. B.- Beach ! i

,i L. J.. Callan, Director Division of~ Reactor Projects J

l cc-Guy Horn, Division Manager of Nuclear. Operations-Cooper Nuclear Station P. O. Box 98 .

'Brownville,' Nebraska 68321  : !.

Program Manager '

FEMA Region 7 _

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Nebraska Public Power District 'l Director Nebraska Civil Defense Agency 1300 Military Road Lincoln, Nebraska 68508 Kansas Radiation Control Program Director Nebraska Radiation Control Program Director l 1 bec to DMB (IE35) >

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RRI R. D. Martin, RA Section Chief (RPS/C) L. Shea, RM/ALF  ;

RPSB-DRSS MIS System RIV File Project Engineer, RPS/C _

RSTS Operator W. Long, NRR Project Manager R. E. Hall DRS Inspector (s) W. L. Fisher R. L. Bangart D. B Matthews, NRR NMEPB I

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1 Federal Emergency Management Agency j' Region VII RM y*

911 Walnut Street. Room 300 Kansas City, MO 64106 R.

T. o DCT I 5198 l

, sa- l MEMORANDUM FOR: R.D. Ross, Director Sta e Emergency Management Agency FROM: .u. vverst ._ Regional Director }

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SUBJECT:

Deficiencies, Cooper Exercise, October 7, 1987 The October 7, 1987 exercise of the State of Missouri, 'and Atchison County l Radiological Emergency Response Plans for the Cooper Nuclear Station revealed serious deficiencies in the administration of the execution of said plans, i showing a failure to properly exercise elements of the criteria set forth in NUREG-0654/ FEMA-REP-1 Rev. 1, D.4., E.5, E.6., J.9., J.10.j., 0.1. and 0.5.

The inescapable conclusion, resulting from the initial review of the exercise data, is that the Atchison County EOC, operating in conjunction with the Missouri State Emergency Management Agency Forward Command Post demonstrated  !

a general lack of ability to make the appropriate decisions required by the circumstances of the exercise, and to effectively coordinate a wide ,

range of emergency response activities. '

This conclusion is based on five specific deficiencies to be enumerated below. However, this -conclusion is also reinforced by the fact that these deficiencies are a continuing repetition of problems cited at the exercise of September 24 and 25, 1986.

To wit, Atchison County was cited for a deficiency resulting from the failure to activate sirens prior to the EBS announcement. The corrective action required plan revisions and checklist development. The materials submitted were partially unacceptable and contributed to the necessity of a remedial j exercise ou February 19, 1987 under the provisions of 44 CFR 350.13. The I portion of the remedial exercise relating to Atchison County's coordination l of EBS release and siren activation was not totally successful and also j resulted in thE need for further corrective action to be demonstrat&d at  !

the 1987 exercise. This demonstration cisc failed. {

l This pattern of four failures in 13 months, all related 'to the ; operation i and ' administration of the ~ A&N, sys tem, casts grave do'ub't on tho' capability l of the State of Missouri and Atchison County to provide for the health and I safety of its citizens.

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The five deficiencies specific to this exercise are as followst

1. The notice of the General Emergency was received at the Atchison i County EOC from an unofficial source at 1234 and became the basis 1 for the County's subsequent response. At 1238 the County PIO finished  !

dictating the initial alert message to the EBS station, but did

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i not indicate a time for broadcast. At 1240 the County Coordinator called the Sheriff's dispatcher and ordered.the immediate activation of the sirens.

The sirens should have been activated prior to the simulated release of the EBS message. This failure to coordinate in proper sequence these two actions of the County Public Information Of ficer and the County Coordinator was precisely the same problem cited after the remedial exercise of February 19, 1987. A quote from that exercise-report follows:

"At 1200 the County Director was notified that a General Eraergency had been declared. The County Emergency Management Director instructed the County PIO to release the General Emergency public notification message to the EBS station at'1203. The PIO completed the dictation of the message to the station at 1204. t.ls o at l 1204, the County Emergency Management Director telephoned the j County Sheriff's dispatcher to request the activation of the l sirens. ...

Also, the timing by the County Emergency Management Director i

for siren activation and initial EBS message release would not assure siren sounding immediately preceding the message release.

This remedial exercise demonstrated correction of the deficiency cited at the exercise of September 24, 1986, i.e., not accompanying the initial EBS message with a siren sounding. However, the precise times of siren activation and EBS message release need to be better demonstrated." )

As a result of the above, FEMA Region VII called for the following corrective action to be demonstrated at the exercise of October i 7, 1987:

"At the next exercise, actual siren sounding in coordination with an actual E.BS message release will be required to demonstrate siren sounding immediately preceding the actual EBS release in concert with the scenario."

Since tee activation of the EBS was only simulated, Atchison County failed to accomplish the required corrective action called for.

This failure is related to, but separate from, the deficiency arising from the failure to coordinate EBS release and siren activation at the General Emergency.

2. At 1034 the Atchison County EOC received notice of Site Area Emergency; however, there were no protective action recommendations.

Nevertheless, the County PIO simulated release of an EBS message announcing the Site Area Emergency. This was contrary to the plan which statec that public alert and notification should occur at the General Emergency or prior to the General Emergency only 'if a protective action is to be issued.

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In addition, the simulated EBS message was released . without any discussion of, or request ' for' activation of the sirens. This same failure occured again when, at 1112 Atchison' County, without recommendation from the EOF, unilaterally decided to place dairy animals on storad feed out to two miles in sector B,C, and D. -This message was released (simulated) to EBS without any' discussion or.

1 decision regarding activation of strens.

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3. At the General Emergency, Atchison County decided to evacuate all Missouri sectors out to five' miles, and in sectors B, C, and D out. ,

to ten miles. The EBS message announcing this protective action l used erroneous landmark descriptions. The area described would only extend out about 8 miles instead of 10, and would also have included sectors E and F.

4. Evacuation was called for at 1245. However, it required an hour and twenty minutes to determine where the access control points ought to be established. This resulted in permitting a heavy North-South traffic flow on Interstate 29 to drive through the plume.

Additionally, when the access control points had been determined, l four of nine were located within the area to be evacuated.

l 5. The airborne siren system used to ' alert persons ' in the Brickyard I Hill State Wildlife Area was flown by one of the back-up pilots.

l According to the observer at this lccation, the first leg (north bound) of the flight was approximately one mile east of the assigned route, and the second leg (south bound) was a- proximately % mile west of course. This resulted. in most of tPs flight being beyond the boundaries of Brickyard Hill and would not have provided an alert signal at the required 60 dB level.

l In addition, the notification sign prescribed for the Charity Lake -

area of Brickyard Hill was missing. The absence of this sign was

noted at the remedial exercise of February 19, 1987, and its replacement required. .

These deficiencies,Lseveral of which show a: persistent pattern of repetition, I make it necessary for this office to require a remedial exercise for the

! State of Mis'souri and Atchison Cou'nty.

l To remedy the above cited deficiencies, the scenario must begin not later than the Alert emergency action level, and escalate through the ' General Emergency classification. It must remain at this level long enough to pe.rmit dissemination of appropriate protective action recommendations through. the actual activation of sirens and the EBS station serving Missouri.

These protective actions must include evacuation in order to permit both the use of accurate landmark descriptions and the ' timely. determination of the appropriate location of access control points. '

s . .C ti For the results of this remedial exercise to become part of the official I 1

exercise report, the remedial exercise must be conducted prior to December 7, 1987. Even though FEMA Guidance Memorandum EX-1 permits an additional 60 days following submission of the report, it is my position that all remedies be accomplished by December 7, 1987.

Since the State and local plans and' the alert and notification system have. I received full approval from FEMA under 44 CFR 350, it would appear that the failures cited are administrative rather than defects in the plans and/or systems. For this reason, training will be required as an ' integral part of the remedial action. Specifically, the following will be required:

1. All positions having responsibilities in the areas related to. the cited deficiencies must be identified.

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2. The key functions performed by these positions must be delineated. .1
3. Based on these functions, training programs must be developed and administered. l
4. A syllabus of this training, including persons to be trained, number ,

of hours, and training objectives for each course, must be submitted j l to FEMA for review prior to its implementation.

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5. All training must be accomplished prior to the remedial exercise. I Due to the serious nature of this situation, I expect the State to bend every effort to meet the requirements and time frames prescribed, i

Any questions should be addressed to Frank Begley or Dick Sumpter at (FTS) l 758-2161 or (816) 374-2161.

I cci Dave McLouglin, HQ Robert D. Martin, NRC IV t

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