ML20248D864

Forwards FEMA Transmitting FEMA Exercise Rept for Plant May 1989 Exercise.No Deficiencies Noted.Nine Areas Requiring Corrective Action Identified.Nrc Expects That Util Will Devote Attention to Resolve Concerns

ML20248D864
Person / Time
Site:	Quad Cities
Issue date:	08/04/1989
From:	Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
NUDOCS 8908110155
Download: ML20248D864 (2)

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AUG 041989 Docket No. 50-254-Docket No. 50-265 Commonwealth Edison Company -

ATTN: Mr. Cordell Reed Senior Vice' President Post Office Box.767 Chicago, IL 60690 Gentlemen:

We have received the enclosed Federal Emergency Management Agency (FEMA) letter, dated June 27,,1989, which transmitted the FEMA Region VII Exercise Report for the May 1989 exercise at the Quad Cities Nuclear Generating Station.

No deficiencies were identified regarding the activities of emergency response personnel. representing.the. State of Iowa and Clinton and Scott Counties.

However,' nine Areas Requiring Corrective Actions (ARCAs) were identified by FEMA Region VII. Based on the status of corrective actions, FEMA has concluded

-that offsite radiological emergency preparedness remains adequate to provide. .

reasonable assurance that appropriate measures can be taken by State'and county officials to protect public health and safety in portions of the State of Iowa in the vicinity of the Quad Cities Station.

We understand that the successful completion of corrective actions on. items identified by FEMA involves actions by organizations other than Commonwealth Edison Company. Nevertheless, we expect that your staff will continue to devote the attention necessary to resolve these offsite emergency planning concerns.

.If you have any questions, please have your staff contact Mr. T. Ploski of my staff at (312) 790-5529.

Sincerely, 7

B908110155 ADOCK890804 05000254, ?w PDR ,

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. Ro er G ger, Chief Reactor Programs Branch

Enclosure:

As stated j See Attached Distribution N' RII RIII,, RIII RII II

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Commonwealth Edison Company 2 MG 04 M9 Distribution cc w/ enclosure:

T. Kovech, Nuclee.c Licensirig M:r,ager R. L. Bax, Station Manager DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division l

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Washington, D.C. 20472 O O JN 27 IRB Mr. Frank J. Congel Director, Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Hr. Congel:

Enclosed is a copy of the report for the unannounced drill conducted for the Quad Cities Nuclear Power Station on May 10, 1989. The report dated June 20, 1989, was prepared by the Federal Emergency Management Agency (FEMA) Region VII staff. The State of Iowa and the Counties of Clinton and Scott participated in this drill. The scope of this drill was limited to demonstrating the ability of State and local governments to fully activate Emergency Operations Centers (EOC's) and to mobilize all staff that report to the EOC's.

There were no deficiencies identified during the drill.

However, nine Areas Requiring Corrective Action (ARCA's) were identified. Five were cited at the State Emergency Operations Center (SEOC) . Two ARCA's were identified at the State Forward Command Post (FCP) . An ARCA was identified for both Clinton and Scott Counties due to the improper use of a primary communication system between the SEOC, FCP and County EOC's. A final ARCA was related to the Scott County Radiological Emergency' Plan. The Assistant to the Director acted as an alternate for the Director during the drill.

However, the plan does not account for this individual assuming this position. A summary of the ARCA's is located in Section 3 of the report; they are explained in detail in Section 2. Plan revisions are to be provided by the State and the appropriate objectives regarding the ARCA's cited at the May 10, 1989, drill will be included for demonstration at the next exercise, currently scheduled for December 5, 1990.

Based on the status of corrective actions, FEMA considers that offsite radiological emergency preparedness is adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public living in the vicinity of the site in Iowa, in the event of a radiological emergency. Therefore, the approval of the ~offsite plans for the State of Iowa, site-specific to

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the Quad Cities Nuclear Power Station granted under 44 CFR 350 on March 26, 1986, continues to be in effect.

We have also enclosed a copy of the FEMA semorandum, dated March 20, 1989, transmitting to the NRC the August 31, 1988, exercise report in which we provided reasonable assurance for the health and safety of the public living in the .

vicinity of the Quad Cities Nuclear Power Station. We would like to clarify that our statement of reasonable assurance in that memorandum was meant to specifically address only the population which is living in the vicinity of the site in Iowa.

If you have any questions, please feel free to call me on 646-2871.

Sincerely, h, V Dennis H. Kwiatkowski Assistant Associate Director office of Natural and Technological Hazards I

Enclosures  !

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x s O O UNANNOUNCED DRILL EVALUATION OF THE IMPLEMENTATION OF STATE :

AND LOCAL RADIOLOGICAL EMERGENCY RESPONSE PLANS CONDUCTED MAY 40, 1989 for the QUAD CITIES NUCLEAR POWER STATION Naar Cordova, Rock Island County, Illinois Commonwealth Edison, Licensee

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PARTICIPANTS:

State of Iowa Clinton County

, Scott County r , o, ,

JUNE 20, 1989

,  !. L-prepared by Federal Emergency Management Agency Region VII .

911 Walnut, Room 200 '~.

Kansas City, Missouri 64106 Jerone,D. Overstreet, Regional Director .

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4 CONTENTS I

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ABBREVIATIONS AND ACRONYMS...................................iii j DRILL

SUMMARY

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. I 1 INTRODUCTION.............................................. 1 1.1 Drill Background..................................... 1 1.2 Drill Evaluators..................................... 2 1.3 Evaluation Criteria.................................. 2 1.4 Drill Objectives..................................... 2 1.5 Drill Scenario....................................... 3 1.6 State and Local Resources............................ 3 2 DRILL EVALUATION.......................................... 5 2.1 Iowa Operations...................................... 5 2.1.1 State Emergency Operations Center............. 5 2.1.2 State Forward Command Post..................., 7 2.1.3 Field Team Coordination / Field Monitoring Teams 9 2.1.4 Dose Assessment............................... 10 2.2 County Operations.................................... 10 2.2.1 Clinton County Emergency Operations Center... 10 2.2.2 Scott County Emergency Operations Center..... 12

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SUMMARY

OF AREAS REQUIRING CORRECTIVE ACTIONS............. 13

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,, ABBREVIATIONS AND ACRONYMS l

ARC American Red Cross ARCA Area Requiring Corrective Action ARFI Area Recommended for Improvement CCEOC Clinton County Emergency Operations Center CFR Code of Federal Regulations

'DNR Department of Natural Resources DOC Department of Commerce

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DOC Department of Corrections DOE Department of Energy DOI Department of Interior DOT Department of Transportation DPH Department of Public Health

(' DSD Disaster Services Division EBS Emergency Broadcast System EOC Emergency Operations Center EPA Environmental Protection Agency EPZ Emergency Planning tone r

FEMA Federal Emergency Management Agency i

FCP Forward Command Post h HHS/FDA Health and Human Services / Food and Drug Admini-stration HHS/PHS Health and Human Servicss/Public Health Service KI . Potassium Iodide NARS Nuclear Accident Reporting System .

NRC ' Nuclear Regulatory Commission j

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, DRILL CUMMARY

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The purpose of an exercise, or in this case a drill, is to determine the ability of appropriate off-site agencies to respond to an cmergency covered by State and local Radiological Emergency Response Plans. The scope of this drill was limited to demon-strating the ability of State and local governments to fully ac-tivate Emergency Operation Centers (EOC's), and to mobilize all staff that report to the EOC's. The evaluation of such an effort will, of necessity, tend to focus on the negative aspects of the exercise, on inadequacies in planning, preparedness and perfor-mance.

This focus of attention on the negative should not be taken to mean that there were not positive accomplishments, as well.

Indeed, there were; however, in the interest of brevity, only inadequacies will herein be summarized.

FEMA classifies exercise or drill inadequacies as deficien-cies or areas requiring corrective action. Definitions of these categories folicw.

Deficiencies are demonstrated and observed inadequacies that would cause a finding that off-site emergency preparedness was not adequate to provide reasonable assurance that appropriate C protective measures can be 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.

Areas reauirina ec yective action are demonstrated and ob-served inadequacies er dcate and local government performance, and although their correction is required, they are not consid-ered, by themselves, to adversely impact public health and

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In addition, FEMA identifies areas recommended for imorove-mant, which are problem areas observed during an exercise that are not considered to adversely impact public health and safety. __

i While not required, correction:. of..these would enhance an organization's level of emergency preparedness.

There were no deficiencies identified during this drill.

However, nine areas requiring corrective Lction were identified.

Five were cited at the State Emergency Operations Center (SEOC) .

as follows:

• Due to technical complications, the Nuclear Accident Reporting System (NARS) failed to operate properly. The SEOC could not be contacted for notification of the Alert classification level utilizing this system.

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h 1 INTRODUCTION

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1 1.1 PRILL BACKGROUND On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume lead responsibility.

for all off-site nuclear planning and-response.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

• Taking the lead in off-site emergency planning and in the review and . evaluation of radiological emergency response plans developed by State and local governments.

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• Determining whether such plans can be implemented on the ba-sis of observation and evaluation of exercises of the plans conducted by State and local governments.

• Coordinating the activities of the following Federal agen-cies with responsibilities in the radiological emergency planning process:

- U.S. Department of Commerce (DOC)

- U.S. Ns". ear Regulatory Commission (NRC)

'(' - U.S. Environmental Protection Agency (EPA)

- U.S. Department of Energy (DOE)

- U.S. Department of Health and Human Services (HHS) 1

- U.S. Food and Drug Administration (FDA)

- U.S. Public Health Service (PHS)

- U.S. Department of Transportation (DOT)

- U.S. Dipartment of Agriculture (USDA)

- U.S. Department of the Interior (DOI)

I Representatives of these' agencies serve.as members of the Regional Assistance Committee (RAC), which is chaired by FEMA.

Formal submission of the radiological emergency response plans for the Quad Cities Nuclear! Power Station (QCNPS) to the RAC by the State of Iowa and affectea local jurisdictions was followed by a critique and evaluation of these plans.

An unannounced radiological emergency preparedness drill was conducted for the Quad Cities Nuclear Power Station (QCNPS) on May 10, 1989, between the hours of 0930 and 1230, to assess the capability of. State and local emergency preparedness organiza-tions to fully activate their facilities, mobilize their response staff, and complete the notification of all participating organi-zations during a radiological emergency at the Commonwealth Edison's Quad Cities Nuclear Power Station. The plans evaluated 5

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In this drill only Objective Number 36, regarding unannounce,d and off-hours drills and exercists, was in-a new objective fs tended for demonstration and evaluation.

portion was tested, as the off-hours portion had Only the unannounced been demon-J strated during a previous full-scale exercise.

The term unannounced" refers to a drill or exercise which is held without the time and date being made known to the re-sponders. For purposes of evaluating response capabilities, it is deemed appropriate to inform responders that an unannounced drill will be held during a particular week, keeping the date and time confidential until off-site notification prompts the re-sponders to activate.

This evaluation concerns a drill, and as such, required ,a specific, limited degree of response.

The drill was to include the activation of the State Emergency Operations Center (EOC), both Clinton and Scott County EOC's, and the State Forward Command Post (FCP) . The State dose essessment and radiological field team coordination functions were also to be activated and report to the appropriate locations. Two radiological field monitoring teams were to accompany the field team coordinator. Other field personnel who deploy from EOC's were to report to their appropriate EOC's to

( establish their readiness, but were not required to then deploy to their assigned locations.

Each of the above facilities were to establish communications with other organizational EOC's. When all appropriate staff at each facility had been mobilized and the appropriate notification to other organizations completed, the drill was to terminate.

1.5 DRILL SCENARIO -

a . a.. r At 0920 an Alert was -declared due to the required shut down of the QCNPS Unit 1 reactor'because of the unavailability of backup equipment required by technical specifications. At 0938 off-site notification : occurred. -

1.6 STATE AND LOCAL RESOURCES Listed below are organizations that planned to participate: .,

State of Iowa

1. Iowa Disaster Services Division

2. Iowa State Department of Public Health

3. Iowa National Guard

4. Iowa Department of Public Safety (Iowa Highway Patrol)

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g 2 DRILL EVALUATION

.C 2.1 IOWA STATE OPERATIONS 2.1.1 giate Emereenev onorations center (BEOC)

Objective to be demonstrated: 36.

Objective Number 36, ability to carry out emergency. response

) functions (i.e., activate EOC's, mobilize staff that report- to

! the. -EOC's, establish communications linkage and complete

- telephone call down) during an unannounced drill, was not adequately demonstrated.

l An inadequacy was identified as the Nuclear Accident Reporting System (NARS) failed to operate properly during 'the notification of the Alert emergency classification level. Due to technical complications, the State Emergency Operations Center (SEOC) could not' he contacted by the utility utilizing this system. The SEOC was eventually contacted at 0938 over the commercial telephone line. However, the NARS technical failure was not- corrected during this drill and thus precluded a full demonstration of the system. Based on the above, the technical problem must be corrected and this communication system be demon-( strated during the next scheduled exercise.

At 0942, the dispatcher began notifying the appropriate organizations to report to the SEOC. The notification procedure was completed at 0959, with full staffing and SEOC activation achieved at 1054. All appropriate staff were notified and mobili~ zed pursuant to the plan. However, an inadequacy was identified as the Iowa Disaster Services Division (DSD) failed to notify the Forward Command Post (FCP) of the Alert classification level in a timely manner. The. Iowa DSD was notified of the Alert i at 0938. However, the FCP was not- subsequently notified until 1015 when the Iowa State Highway Patrol representative arrived at This delay occurred in'part because the the SEOC. State Plan fails to specify who is responsible for the initial notification

to .the FCP of emergency classification levels and to provide instructions to begin activation of the facility. The initial contact with the FCP by the Iowa State Highway Patrol representative was with the expec already been alerted and begun activation,tation . The State that the PlanFCP musthad be amended to reflect this responsibility.

The Iowa DSD representatives who would normally report to the Clinton and Scott County Emergency Operations Centers, Forward Command Post, Emergency Operations Facility, and the Joint Public Information Center, all reported to the SEOC.

During this drill, these representatives were not required to ,

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cystem demon 2trnted during tha n2xt echeduled exercise.

!r (NUREG-0654, F.1.d.)

.( 2. The Iowa Disaster Services Division (DSD) failed to notify -

the Forward Command Post (FCP) of the Alert classification level in a timely manner. The Iowa DSD was notified of the Alert at 0938. However, the FCP was not subsequently noti-fled until 1017 when the Iowa State Highway Patrol represen-tative arrived at the SEOC. This delay occurred in part l because the State Plan fails to specify who is responsible l for the initial notification to the FCP of emergency clas-sification lovels and to provide instructions to begin acti- I vation of the facility. The State Plan must be amended to reflect this responsibility. (NUREG-0654, F.1.e.)

3. 'The Iowa State Highway Patrol representative who reported to the Clinton County Emergency Operations Center (CCEOC) did not have dosimetry. As the CCEOC is located in the plume emergency planning zone, dosimetry is required for all emergency workers who report to this facility. This must be demonstrated during the next r;cheduled exercise.

(NUREG-0654, K.3.a.)

4. The State Plan is inconsistent regarding what organizations will report to the SEOC. For example, page II-13 indicates that the Department of Commerce and Capitol Security will on page II-10,

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report to the SEOC. However, these organizations are not included. A similar problem exists with the Department of Corrections. The State notification procedures require this organization to report to the SEOC.

However, the plan, in some cases, does not. The appropriate plan amendments must be made to correct the aforementioned concerns. (NUREG-0654, E.2.)

5. The State Plan does not indicate how dosimetry is distributed to the State Highway Patrol representatives who enter the EPZ. Therefore, the State Plan must be amended to indicate where the dosimetry (self reading and permanent) is stored and how it is distributed to the Iowa State Highway Patrol. This amendment must also include all organizations Tr i assigned to the State FCP who ;may enter the emergency planning zone. (NUREG-0654, K.3.a.)

2.1.2 State Forward Command Post fFCP)

Objective to be demonstrated: 36.

Objective Number 36, ability to carry out emergency response functions (i.e., activate EOC's, mobilize staff that report to the EOC's, establish communications linkage and complete telephone call down) during and unannounced off-hours drill or exercise, was not adequately demonstrated. -

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(CCEOC) .;and instructed to report to his respective depart-ment, per the Clinton County Plan. These inconsistent in-q(' -l structions may have contributed to the failure to report to the FCP. Based on the above, the inconsistency between the .

State and local plans must be resolvsd and the appropriate amendments made. (NUREG-0654, E.2.)

'7. The State Forward Command Post (FCP) staff was not aware of the. procedures for establishing. the administrative conference line between the SEOC, County EOC's, and FCP.. As a result, the activation of this primary communication system was delayed for thirty-four-minutes. The. appropriate training.must.be provided and the activation of this system must be demonstrated during the next scheduled exercise.

(NUREG-0654, F.1.d.) -

2.2.3 Field Team coordination / Field Monitorine Teams

• Objective to be demonstrated: 36.

Objective' Number 36, ability to' carry ou't emergency response functions'(i.e., activate EOC's,. mobilize staff that report. to the EOC's, establish communication, linkage and complete telephone call down) during an unannounced off-hours drill or exercise, was fully demonstrated.

Field Team Coordination was performed at the Clinton County Emergency Operations Center (CCEOC) by staff from the University Hygienic . Laboratory (UHL) located in Iowa City, Iowa. The field team- coordinator and two radiological field teams were deployed during this drill. At 0950, the UHL was contacted by the State Department of Public Health and instructed to mobilize to the CCEOC. Per documentation provided by the field team coordinator, operational. checks were made of the field monitoring instruments which were subsequently loaded into two vans; both teams departed

. at 1055. The UHL staff ultimately arrived at Clinton County at

1232. , ,,

In addition to the radiological nonitoring equipment, both primary and backup communication systems utilized by the field team coordinator and the radiological field monitoring teams were

. transported to the county. Cosmun'ications were established between the field team coordinator and the dose assessment staff located at -the SEOC in Des Moines, Iowa. Tne field . team coordinator also transported the computer, software, and the standard operating procedures and other instructions / manuals required for this function.

All of the UHL staff had the appropriate dosimetry when they arrived.at the county. Since the CCEOC is located in the pluma EPZ, all emergency workers who arrive at this facility must have dosimetry. .

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i ctaff b3gan St 0950. Full ettffing for the county lovel occurred 3

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arrived at this location at 1232.

The State field tocm coordinator and . field teams-The CCEOC was fully activated I

'. with all appropriate organizational staff reporting to the .

facility.

The ability to establish communications was not adequately demonstrated. An area requiring corrective action was identified as the administrative conference line (primary communication link) between the SEOC, FCP, and County EOC's was improperly used by Clinton and Scott Counties. This occurred because Clinton and Scott Counties utilized this line for. a communication link.

However, this action prevented the SEOC from establishing the ad-ministrative conference line between the State and local EOCs for twenty-four minutes.- The SEOC eventually contacted the counties -

on a separate line and instructed them to stay off the line until the conference line was estab?.ished. Based on the above, the ap-propriate training must be provided and the activation. of this system must be demonstrated during the next scheduled exercise.

With the exception of the inadequacy identified with the administrative . conference line, all appropriate communication links were fully demonstrated. The Nuclear Accident Warning System (NARS) was demonstrated successfully to th2 county.

As the CCEOC is within the plume emergency planning zone, dosimetry was required for a.11 emergency workers. All of the l county organizations who repCrted to the EOC were provided with the appropriate dosimetry. However, the Iowa State Highway Patrol officer. who responded to this facility did not have dosimetry. This concern is detailed in Section 2.1.1. of this report. ,

Summary: Objective Number 36 was not adequately demonstrated during this drill.

- Area Recuirine corrective Action ,,

8. The administrative conference line (primary communication link) was improperly used by Clinton and Scott Counties.

i This occurred because Clinton and. Scott Counties utilized ---

this line for a communication' link. However, this action prevented the SEOC from establishing the administrative conference line between the aforementioned organizations for twenty-four minutes. The SEOC eventually contacted the counties on a separate line and instructed them to stay off the line until the conference line was established. The appropriate training must be provided and the activation of this system must be demonstrated during the next scheduled exercise. (NUREG-0654, F.1.d.)

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SUMMARY

OF AREAS REQUIRIN2 CORRECTIVE ACTION

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IOWA STATE OPERATIONS  ;

state Emercancy Operations Center (SEOC) -

1. Due to. technical complications, the Nuc;. ear Accident Reporting System (NARS) failed.to operate properly during'this drill. The State Emergency Operations Center (SEOC) could not be contacted for notification of the Alert classification level utilizing this I, system. The NARS system never successfully contacted the SEOC during this exercise. Therefore, the technical correction must be made and this system demonstrated during the next scheduled exercise. (NUREG-0654, F.1.d.) i

2. The Iowa Disaster Services Division (DSD) failed to notify the Forward Command Post (FCP) of the Alert classification level in a timely manner. The Iowa DSD was notified of the Alert at 0938.

However, the-FCP was not subsequently notifiel until 1017 when the Iowa State Highway Patrol representative arrived at the SEOC.

This delay occurred in part because the State Plan fails to specify who is responsible for the initial notification to the FCP of emergency classification levels and to provide instructions to begin activation of the facility. The State Plan must be amended to reflect this responsibility. (NUREG-0654, F.1.e.)

3. The Iowa State Highway Patrol representative who reported to the Clinton County Emergency Operations Center (CCEOC) did not have dosimetry. As the CCEOC is located in the plume emergency planning zone, dosimetry is required for all emergency workers who report to this facility. This must be demonstrated during the next scheduled exercise. (NUREG-0654, K.3.m.)

4. The State Plan is'inednsisitent regarding what organizations will f report to the SEOC. For example, page II-13 indicates that the Department of Commerce and Capitol Security will report

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to the SEOC. However, on page II-10, these organizations are not included. A similar problem exists, with the Department of Corrections. The State notification procedures require this organization to report to the SEOC. However, the plan, in come cases, does not. The appropriate plan amendments must be zade to correct the aforementioned concerns. (NUREG-0654, E.2.)

5. The State Plan does not indicate how dosimetry is distributed to the State Highway Patrol representatives who enter the EPZ.

Therefore, the State Plan must be amended to indicate where the dosimetry (self reading and permanent) is stored and how it is distributed to the Iowa State Highway Patrol. This amendment L

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