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Category:Emergency Preparedness-FEMA Correspondence to NRC
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[Table view] Category:Letter
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U.S. Department of Homeland Security Washington, DC 20472
September 13, 2024
Catherine Nolan Chief Policy and Oversight Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U. S. Nuclear Regulatory Commission
Re: Fermi 2 Nuclear Power Plant Level 1 Finding
Dear Ms. Nolan:
The purpose of this letter is to officially inform the Nuclear Regulatory Commission (NRC) of the Federal Emergency Management Agencys (FEMA) identification of a Level 1 Finding that occurred during the Fermi 2 Nuclear Power Plant Radiological Emergency Preparedness (REP)
Exercise conducted on August 27, 2024. A Level 1 Finding is being assessed against the County of Monroe under Capability Target 3.2: Alert and Notification of the Public - Offsite Response Organizations demonstrate the capability to provide instructions to the public:
Objective 3 - Alert and Notification Capability Target 3.2 - Alert and Notification of the Public
Monroe County failed to provide accurate and complete information in the Emergency Alert System (EAS) message, at the Emergency Classification Level (ECL) General Emergency (GE). This message included the wrong date and time for the Governors declaration of a state of emergency/disaster (1330 Eastern Daylight Time on May 18, 2021). Absent were key elements of the State of Michigans Protective Action Order (PAO), including evacuation of three of the six Protective Action Areas (PAAs 2,4, and 5).
Also absent was the recommendation for public ingestion of Potassium Iodide (KI). These oversights would have resulted in the public receiving an unnecessary exposure to radiation.
Monroe County did not implement three of the four required components of the countys EAS coordination procedures, including coordination of EAS messages with Wayne County before the messages were sent, notification to Wayne County of each EAS message sent, entering each EAS message in the Monroe County WebEOC database, and forwarding a copy of each message to Wayne County and to the Joint Information Center (JIC).
Both the first and second EAS messages selected and attempted for primary notification exceeded the 2-minute/1800-character FCC/FEMA limits, with the result that at least one of
www.fema.gov
four required EAS message information elements - a closing statement directing the affected and potentially affected populations to stay tuned to their local EAS radio or TV stations for further information, and the listed stations, would have been truncated from the EAS message by the automated notification system.
In addition, prior to release of the second EAS notification message, Monroe County did not activate the sirens, did not coordinate the message with Wayne County before the message was sent, and did not document the message in WebEOC, as required by the Monroe County Public Warning and Notification System Procedures (Rev. 3).
Finally, the Monroe County EOC did not assign anyone to monitor EAS messages transmitted to the public in order to identify incomplete, inaccurate, or ambiguous information. Had someone been assigned, many of the identified errors and omissions could have been avoided.
The failures identified above would have adversely affected the health and safety of the public by delaying evacuation and exposing the public to radiological hazards.
In accordance with 44 CFR 350.9(d) and the DHS/FEMA Radiological Emergency Preparedness (REP) Program Manual, we have thoroughly reviewed and discussed this issue with the pertinent organizations participating in the offsite exercise evaluation. The FEMA REP Program Manual, defines a Level 1 Finding as an observed or identified inadequacy of organizational performance in an assessment activity that could cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant.
Because of the potential impact of a Level 1 Finding on the protection of the public health and safety, it must be corrected within 120 days from the date of the exercise through appropriate remedial actions including remedial exercises, drills, or other actions. In accordance with the FEMA REP Program Manual, if the remedial exercise can be successfully completed within 75 days of the biennial exercise, FEMA includes the results and findings of the remedial exercise in the final after-action report (AAR) for the biennial exercise.
Please contact me at (202) 657-2301, if you have any questions or require any further information on this matter.
Sincerely,
Thomas Warnock, Chief Radiological Emergency Preparedness Branch
CC: Sean OLeary, FEMA Region 5 RAC Chair