ML20245C217
| ML20245C217 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/13/1989 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8904270051 | |
| Download: ML20245C217 (2) | |
Text
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' APR 13 1999
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" Docket No.'50-289 m
lGPU Nuclear Corporation:
ATTN: ~Mr. H. D. Hukill r
Vice President and Director of TMI-1 P. O._ Box.480-Middletown, Pennsylvania 17057:
P Gentlemen:
Subject:
FEMA; Report On the February 1,'1989 Three Mile Island Nuclear Generating State Remedial Exercise Enclosed is~a memorandum from Dennis H. Kwiatkowski, dated March 17, 1989, which transmits the' Federal-Emergency Manaoement Agency report. of the February
- 1, 1989 Three Mile' Island remedial. exercise.
PThe Report in'dicates the remedial exercise correcte'd a deficiency identified
- during the 0ctober 22,:1987. full participation exercise of. your facility when LLower Paxton Township did not.pe.rticipate and Dauphin County failed to take-action'to protect the health and safety of.the Lower Paxton Township residents.
ofntystaff'at(questionsconcerningthismatter,pleasecontactCraigGordon If you have any
. 215) 337-5372.
Sincerely, Original Signed W 4 Ronald R.'Bellamy, Chief Facilities. Radiological Safety and' Safeguards Branch
~cc w/en'cl:
T. G. Broughton, Operations and Maintenance Director, TMI-1 C. W. Smyth,4 Manager, TMl-1 Licensing R.'J. McGoey, Manager, PWR Licensing E.' L. Blake, Jr., Esquire TMI-Alert (TMIA)
-SusquehannaValleyAlliance'(SVA)
Public Document Room'(PDR)-
-Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
LNRC Resident' Inspector'
' Connonwealth of Pennsylvania L
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( -Federal Emergency Management Agency o
7 Washington, D.C. 20472 MAR I 7 L989 MDORANIDI FCR:
Frank J. Omgel Director Division of Radiation Protection and Emergentf Preparedness fice of Nuclear Reactor Regulation
. S. Nuclear Regulatoryy4==len
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Assistart late Director Office of Natural and Technological Hazards SUE 7ECT:
Pdial Exercise Report on the February 1,1989,
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3 Remedial Exercises for the 'Jhree Mile Island Nuclear Power Station Attadied is a copy of the r=madial exercise report cri the February 1, 1989, r=madial exercisas conducted to cou ct a deficiency identified during the October 22, 1987, full-participation exercise for the 'Ihree Mile Island Nuclear Pwer Staticri.
'Ibe deficiency was the resralt of the non-participaticr1 of Iower Paxton
'Ibwnship and the failure of Dauphin County to take acticri to protect the health and safety of Iower Paxton Township residents. 'Jhe Dauphin County rhial' exe2x:ise indicated that Dauphin County has the capability to implemnt ocritingency procedures to address the failure of municipal officials to respcrid to en senergercy. 'Jhe lower Paxtcri Township rMial iexercise demonstrated that Township officials can take protective measures to protect the health and safety of its residents.
Based on the res.11ts of the @+=r 22,1987, ful.1-participation exercise and the February 1,1989, rWial exercises, the offsita radiological emewf preparedness for 'Ihree Mile Island is adequate
. to provide reascnable assurance that appropriate manenes can be taken to protect the health and safety of the public in the event of an accident et the 'Ihree Mile Island Nuclear Power Staticri.
If you should have additional questions, please contact Craig S. Wingo, Chief, Tectinological Hazards Division,.at 646-3026.
Attacf1 ment
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.l. f-i ENCLOSURE
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RADIOLOGICAL EMERGENCY PREPAREDNESS o
REMEDIAL EXERCISE EVALUATION REPORT i
FACILITY:
THREE MILE ISLAND NUCLEAR POWER STATION OPERATOR:
THE GPU NUCLEAR CORPORATION LOCATION:
MIDDLETOWN, PENNSYLVANIA REPORT DATE:
FEBRUARY 15, 1989 EXERCISE DATE:
FEBRUARY 1, 1989 PARTICIPATING JURISDICTIONS:
DAUPHIN COUNTY LOWER PAXTON TOWNSHIP NON-PARTICIPATING JURISDICTIONS:
NONE
. REPORT PREPARED BY:
FEDERAL EMERGENCY MANAGEMENT AGENCY AND REGIONAL ASSISTANCE COMMITTEE REGION III PHILADELPHIA, PENNSYLVANIA Prepared in accordance with 44 CFR 350; j
and FtJREG 0654/ FEMA-REP-1, Revision I, of November 1980.
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jNdOdO90.)
EXECUTIVE
SUMMARY
The following is a report on two remedial Radiological Emergency Preparedness Exercises conducted on February 1.
1989 for the Three Mile Island Nuclear Power
- Station, involving the participation of Dauphin County and Lower Paxton Township.
This report has been prepared in accordance with 44 CFR 350 and NUREG-0654 REP-1, REV-1.
These remedial exercises were necessitated by a
deficiency observed in the October 22, 1987 Joint, biennial Radiological Emergency Preparedness Exercise at Three Mile Island, wherein Lower Paxton Township failed to participate, and Dauphin County failed to take action assuring the protection of the health and safety of township residents.
Both remedial exercises were conducted in a tabletop format, and were designed and controlled by the Pennsylvania Emergency Management Agency.
The performances by the exercise participants adequately addressed the deficiency from the October 22, 1987 exercise.
During its tabletop discussions at the County EOC, the Dauphin County Emergency Management Agency clearly demonstrated the ability to implement contingency procedures addressing the failure of municipal officials to respond to an actual radiological emergency incident or a joint, biennial Radiological Emergency Preparedness Exercise at the Three Mile Island Nuclear Power Station.
In the second tabletop
- exercise, Lower Paxton Township fully staffed its EOC with plan designated personnel who proved themselves committed to, and capable of, the provision of protective measures for the residents of the township.
Although their tabletop discussions revealed some need for continued training and plan familiarization, and resulted in the identification of one Area Requiring Corrective Action, the township EOC
- staff, nonetheless, adequately demonstrated the majority of exercise objectives.
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3.
TABLE OF CONTENTS EXECUTIVE
SUMMARY
1.
1 3
TABLE OF CONTENTS............................................
2
'I.
INTRODUCTION
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A.
BACKGROUND.......................................
3 B.
' EVALUATION CRITERIA U5ED.........................
4 II.
OBJECTIVES A.
LIST OF OBJECTIVES...............................
5 B.
OBJECTIVES NOT ADEQUATELY DEMONSTRATED........... 6 III.
EXERCISE RESULTS A.
DAUPHIN COUNTY...................................
7 B.
LOWER PAXTON TOWNSHIP............................
8 C.-
SUMMARY
LIST OF ISSUES..........................'.
11 D.
STATUS 13F PRIOR ISSUES....-.......................
13 APPENDICES PARTICIPATING. JURISDICTIONS............................
14 EVALUATOR ASSIGNMENTS..................................
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- 1. ;
INTRODUCTION
~A.
BACKGROUND.
As required byJthe provisions of 44 CFR 350.9 (c) (5), State and local governments will participate in remedial exercises 1
when their. performances in -joint, biennial Radiological.
Emergency Preparedness (REP) exercises. result in findings thatL offsite emergency preparedness is.not adequate to provide reasonable-assurance that protective measures can be w
taken to protect the health and safety of the public living in the vicinity of a nuclear. power facility in the event of a' radiological' emergency (see also FEMA Guidance Memorandum.
EX-1, July 15, 1985).
The two remedial exercises conducted on February 1,
1989, involving the participation of Dauphin County and Lower Paxton Township -- that are the subjects of this report
- are the result of a deficiency identified dur'ing the October 22, 1987 Three Mile Island
- joint, biennial REP exercise.
This deficiency (Problem ID TMIX87-ID) has been. described as follows:
" Lower-Paxton Township did. not participate in the-exercise.
When Dauphin' County.was informed of this, neither Dauphin county: officials nor the State. liaison officer took any action to protect the health and safety of the residents of this township.
State and County-emergency management
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officials must. develop procedures to ensure the protection of.the. population 11n the' event this problem occurs."
(See page 29 of'the November 4, 1988 FEMA and Regional Assistance
{
' Committee' Exercise. Report'on the Three-Mile Island joint, biennial REP exercise of October 22, 1987.)
The
' Pennsylvania Emergency Management Agency (PEMA) responded to this
- finding, in
- part, with the following statement:
"The township-manager hired subsequent to-the exercise and the new Emergency Management Coordinator have restructured the emergency organization.
Coordination of necessary training is on-going with Dauphin County in preparation'for a remedial exercise."
(See page 29 of the November 4, 1988 FEMA report on the October-22, 1987 Three Mile Island REP exercise.)
In responding to the deficiency, PEMA also stated that the i
Commonwealth's draft Annex E.
Radiological Emergency Response' to Nuclear Power Plant Incidents, (revised in December of 1988) would include specific instructions for the contingent provision of emergency protective measures in the event that a risk county or municipality is unable or fails to respond to a radiological emergency incident or participate in a required REP exercise.
These instructions 3
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are pursuant to the provisions of the Ccanonwealth Emergency Management Services Code (35 Pa.
C.S.A.
Sections 7101-7707) and can be found in the
" Direction, Coordination and Support" subsection of the Annex E Basic Document (page E-11).
B.
EVALUATION CRITERIA USED l
The performances by Dauphin County and Lower Paxton Township during the remedial exercises were evaluated according to the criterion of their ability to respond to a radiological emergency incident in the manner prescribed by.their plans:
respectively, the Dauphin County Emergency Response Plan for Incidents at the Three Mile Island Nuclear Station (revised August 1987) and the Lower Paxton Township Emergency Operations Plan (revised April 1987).
These plans were prepared in accordance with NUREG-0654/ FEMA REP-1,
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.
Both exercises were conducted in a tabletop format, designed and controlled by PEMA.
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. OBJECTIVES' A.
LIST OF OBJECTIVES The following objective was : attempted by Dauphin County during its tabletop, remedial exercise.
To demonstrate that risk counties have contingency procedures.to-be implemented in the event that any of the risk municipalities fail to respond to an actual incident or to participate in a federally required exercise.
The following objectives. were attempted by Lower paxton Township during its
- tabletop, remedial exercise..
The objectives are numbered so as to correspond to their standard counterparts identified in FEMA Guidance Memorandum EX-3 (February 1988).
The objectives are followed-by references to NUREG-0654/ FEMA-rep-1, REV.
1, Evaluation Criteria, and, where appropriate, specific limits of play.
1.
Demonstrate'the ability to monitor, understand, and use i
emergency classification levels (ECL) through the appropriate implementation of emergency functions and activities corresponding to ECL's as required by the acenario.
The four ECL's are:
notification of an unusual event, alert, site area emergency, and general emergency.
(D.3,.D.4) 2.
Demonstrate the ability to fully alert, mobilize, and activate personnel for both facility and field-based i
emergency functions.
(E.1, E.4)
Lower paxton Township will fully alert and mobilize personnel to activate their EOC.
3.
Demonstrate the ability to direct, coordinate and-control' emergency activities.
(A.1.d. A.2.a) 5.
Demonstrate the adequacy of facilities, equipment,
- displays, and other materials to support emergency operations.
(G.3.a, H.2, 3) 13.
Demonstrate the ability to coordinate the formulation and dissemination of accurate information and instructions to the public in a timely fashion after j
the initial alert and notification has occurred.
(E.5, j
G.4.b)
L 16.
Following the decision to recommend the use of KI to emergency workers and institutionalized persons, 5
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be prepared to explain to the evaluator when KI.
would be issued, when taken, and based on.whose direction'.
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be prepared to point-out to the evaluator the l-dosimetry /KI storage facilities.
.c.
explain the use of dosimetry to include the procedures. to zero; how the dosimeters are worn-and read; and.how the record-keeping forms are prepared.
(J.10.e, f. E.3) 18.
Demonstrate the ability-and resources necessary to
-implement appropriate protective action forL the impacted permanent and transient plume EPZ population (including transit-dependent
- persons, special needs populations, handicapped persons, and institutionalized persons).
(J.9, J.10.d. g)
The risk municipality will be prepared to discuss with the FEMA evaluator procedures for developing and maintaining a-list of individuals with impaired l
- hearing, non-English
- speaking, and homebound; their notification by route alert teams, and display the list for review.
- 20..
Demonstrate the organizational ability and resources necessary to control evacuation traffic flow and to control: access to evacuated and sheltered areas.
(J.10.j, k)
One municipal TCp will be demonstrated.
This demonstration may consist of briefing personnel manning the post on-their duties and assigning them to a post.
Deployment to the post may be simulated.
B.
OBJECTIVES NOT ADEQUATELY DEMONSTRATED All of the above listed objectives were adequately demonstrated with the exception of Objective 18.
(See Section
- III, Exercise Results, Objective 18, for specific j
details.)
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e III. EXERCISE RESULTS A.
DAUPHIN COUNTY The, core objective for Dauphin County in the remedial exercise.-the demonstration of contingency procedures to be implemented in the event that any risk municipality fails respond to an actual incident.
to I
or to participate in a required
- joint, biennial REP
- exercise, was adequately achieved.
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The executive staff of the Dauphin County EMA effectively responded to the tabletop challenges provided by the PEMA controller.
Discussion and responses on part of the County EMA staff centered on the spontaneous assignment of personnel and resources to provide those emergency measures
'for the residents of Lower Paxton Township that are formally identified'as. municipal responsibilities in the County and Township plans.
. The staff qualified any assimilation of prescribed municipal emergency ' management duties with thorough. attempts to contact Township officials (via a roster maintained in.the County EOC) and obtain their proper response.
.In the event that such contact was-not achievable, the County would immediately dispatch liaison officers to. the ' Township EOC (the Lower Paxton Police Headquarters) to maintain a
local presence and enhance coordination'of~ protective' measures from the County EOC.
By use of the media and the dedication of a separate phone line for the Township in the County EOC, the County EMA would advise Lower. Paxton residents that all necessary local protective measures were being provided.
Discussion on specific protective measures included the manning of municipal ACP's and TCP's, coordination of Township route
- alerting, alerting of hearing impaired residents, and the provision of transportation of special needs (including non-ambulatory) individuals and other transit-dependent residents of the Township.
The ability of the County EMA to provide for the manning of the 5 ACP's and 7 TCP's identified as Lower Paxton Township responsibilities was effectively demonstrated.
Acquisition of supplemental personnel for this end is enhanced by a county-wide mutual aid agreement.that would render as available, an adequate number of special police and fire police to man these posts and also conduct route alerting if necessary.
Fire police personnel can be contacted directly from the County EOC via tone alert radios.
The briefing of substitute personnel would be conducted by the County 7
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-liaison office'rs stationed at the Township police department'..
The Township police have
-access to the
-redistributed dosimetry and El maintained'at the Township h
'EOC, which would be distributed to emergency workers by the County liaison. officers.
The tabletop discussion revealed that attending to the needs of hearing impaired and special needs residents would be more problematic..
For-purposes of confidentiality, the lists of hearing impaired residents requiring special
-notification and non-ambulatory individuals-requiring special transportation means'e are only maintained at the municipal level:and not available in the County EOC.
During theLexercise, the County.EMA staff generated alternative methods for identifying-these special needs residents in the event that the liaison officers could not obtain the municipal. lists.
These siternatives involved requests through the media for County area residents to identify.any relatives, friends, or neighbors living in Lower Paxton that are.
hearing.
impaired or might
' require special transportation, and also the use of referrals from various County social service agencies that likely serve these residents.
Responses to Controller questions on part of the County EMA staff indicated that the County could readily coordinate the provision of buses for those Lower Paxton residents lacking private -means of transportation in the event of' an evacuation.
The-announcing of pickup points would be accomplished through the efforts of the County p10 and the l
liaison officers working with the municipal police L
department.
B.
LOWER PAXTON TOWNSHIP j.
Objective 1,
to demonstrate the ability to ' monitor, understand, and use emergency classification levels through the' appropriate implementation of emergency functions and activities corresponding to ECL's as required by the scenario, was adequately achieved to the extent applicable L
to township responsibilities and permitted by the tabletop format of the exercise.
Objective 2, to demonstrate the ability to fully alert,
- mobilize, and activate personnel for both facility and field-based emergency functions, was adequately achieved as limited by pre-exercise agreements and the tabletop format.
No actual alerting of EOC staff members or field personnel was conducted, as all participants were repositioned pursuant to the facilitation of the tabletop format of the exercise.
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p-With the-exception of local elected officials, the EOC was
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1 fully andLpunctually: staffed-by plan designated pr.rsonnel.
.The staff. responses to Contro11erLeha11enges and tabletop
- discussion indicated.that the Lower Paxton EOC personnel are committedito-their responsibilities and capable'of carrying out'their prescribed. duties' in a. radiological emergency.
With..the' exception of the Communications Officer and Deputy.
u-Emergency.-Management Coordinator,
- however, no EOC staff NV.
' member has participated in.a biennial. REP exercise in his or
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her present role.-
Some questions raised by the exercise participants and answered by the Controller concerning emergency procedures and terminology indicated that the EOC personnel.
are in need of "further training and familiarization-with the Township plan. Such questioning was in compliance, however, with the pre-exercise agreement that the remedial exercise would also serve as an opportunity for training.
Objective, 3,
to demonstrate the ability to
- direct, coordinate,'and control emergency activities, was adequately achieved to-the extent applicable within the limitations of a tabletop exercise.
Responses to Controller challenges on part ofLtheJEOC staff -- especially the Emergency Management.
Coordinator-(EMC) -- indicated that in an actual emergency or full. scale exercise, periodic briefings would be held, internal and external messages would be recorded and logged, and EOC-staff personnel would be effectively involved in decision making processes.
Objective 5, concerning the adequacy of EOC facilities, equipment, displays and materials to support emergency operations,.was adequately demonstrated.
Objective'13, the ability to coordinate the formulation and dissemination of accurate -information and instructions to the public-in a timely fashion after the initial alert and notification' has
- occurred, was adequately demonstrated as applicable to municipal responsibilities.
The EMC and Public Information Officer (PIO) effectively responded to two rumor control messages, and thoroughly explained that all local dissemination of information. regarding a
radiological emergency would be coordinated with the County PIO.
Objective 16, concerning the use of KI and dosimetry, was adequately demonstrated through a
thorough briefing l
conducted by the Radiological Officer (RO) on behalf of the 1
EOC' staff.
The briefing accurately described the purpose, I
proper and authorized use, and recording of KI ingestion.
The briefing also included a physical demonstration on the charging and use of pocket dosimetry, and the issuing and 9
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' tracking of TLD cards. (The redistributed municipal supply of dosimetry was.actually' displayed by the RO in the EOC.)
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~ Objective 18, the ability ~ and resources necessary to-L implement appropriate protective actions for the. impacted f'
permanent and transient plume! Ep2 population (including transit-dependent
- persons,
~special needs populations, handicapped persons and institutionalized persons),
as applicable to municipal responsibilities', was not adequately demonstrated.:
By-oral admissions on part of the EMC and Medical Services Officer, the EOC lists of. hearing impaired and special needs residents -- although generated within'the r
last 6' months
-. were identified as: incomplete. and'the products-of a' problematic survey..The EMC stated, however, that the Township intends to ameliorate this problem in.the near. future with the generation of more complete lists.
Regarding the evacuation of transit-dependent residents,.the pIO was not. familiar with the process by which information on the location of pickup points is disseminated to the public.
Discussion and. responses to Controller questions also~ indicated-a lack. of~ familiarity -- on part of several.
EOC staff members
[
with' the pre-established evacuation L
routes to be utilized'by Lower paxton residents.- Confusion over this matter was eventually dispelled by the EMC.
Objective 20, the organizational ability and resources to control evacuation traffic flow and'to control access to evacuated and' sheltered areas, was adequately demonstrated as applicable to the limitations of a tabletop exercise.
The ' police Director-explained how he would brief: the personnel assigned to the townohip TCp's and ACp's -- all of which were visible on a map displayed in the EOC.
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SUMMARY
' LIST OF ISSUES
-Exercise-issues have been summarized and classified
-according to the following categories:
t Deficiencies are demonstrated and observed inadequacies that cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be'taken to protect the_ health and
-safety of_the public living within the vicinity of the Three i
Mile. Island Nuclear power Station in the. event of a
radiological emergency.
Because of the potential impact of deficiencies on emergency preparedness, they are required to be'promptly corrected through appropriate remedial actions including remedial exercises, drills, or other actions.
No deficiencies were identified during-these two remedial exercises.
Areas Reauiring Corrective Action are demonstrated and observed-inadequacies of performance.
Although their correction is required during the next scheduled biennial
~ exercise, Areas Requiring Corrective Action are not
. considered, by.themselves, to have adverse impact on public healthfand safety.
One Area Requiring Corrective Action, involving the demonstration of Objective 18 on part of Lower Paxton
- Township, was identified during its remedial exercise.
Areas Recommended for Improvement are problem areas observed during an exercise that are not considered to have adverse impact on public health and safety.
While not required, correction of these issues would enhance an organization's level of emergency preparedness.
No specific Areas Recommended for-Improvement were identified during these remedial exercises.
As stated during~the discussion of the demonstration of exercise objectives,
- however, the inexperience of Lower Paxton Township staff members does indicate a
need for their continued training and plan familiarization.
All of the objectives attempted during this remedial-exercise are also scheduled for Lower Paxton Township during the October 18, 1989
- joint, biennial exercise at the Three Mil'e Island Nuclear Power Station.
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AREAS REQUIRING CORRECTIVE ACTION 9
l Problem ID-Location / Activity NUREG Proposed Confirmed Element Correction Correction Date Date TMIX89R-1R Lower Paxton J.9, 10/18/89 TWSP EOC J.10.d The current Lower Paxton Township EOC lists of hearing impaired individuals and special needs' residents are incomplete and inaccurate..
~More complete lists should be generated as soon as possible.
(See the discussion on Objective 18.)
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D.
STATUS OF PEIOR ISSUES Three Areas Requiring Corrective Action were identified for the Lower Paxton Township EOC during the November 20, 1985 Three Mile Island joint, biennial REP exercise.
The status of each with regard to the February 1,
1989 remedial exercise is discussed below.
16.
All individuals with assigned EOC tasks during a
radiological emergency at TMI should participate in future exercises.
Corrected.
All EOC staff positions with the exception of elected officie,1s, were manned during the remedial exercise.
(See the discussion on Objective 2.)
17.
The listing of names and telephone numbers for volunteer emergency workers in the Township should be updated.
Corrected.
During the remedial exercise the EMC presented an EOC staff roster with work and home phone numbers, current as of January 1989.
18.
No message was observed at the township level indicating that sirens had been activated.
The EMC should take measures to ensure that route alerting is conducted in coordination with siren and EBS activation in future exercises.
Not Corrected.
The tabletop format did not adequately support the demonstration of the coordination of siren activation and the dispatching of route alert teams; no actual county-township communications were conducted.
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s APPENDICES
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APPENDIX ONE PARTICIPATING JURISDICTIONS Dauphin County Lower Paxton Township APPENDIX: TWO EVALUATOR ASSIGNMENTS i
Dauphin County -- Scott Fina (FEMA)
Lower Paxton-Township -- Scott Fina (FEMA) i 14
_ _ _ _ _ _ _ _ _ _ _. _ _ _ _. _ _ _ _. _ _ _ _ _