ML24276A203

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FEMA Level 1 Finding Transmittal Letter
ML24276A203
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 10/03/2024
From: Michael Ziolkowski
NRC/RGN-III/DRSS
To: Mann A
DTE Electric Company
References
Download: ML24276A203 (1)


Text

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Allen Mann Emergency Preparedness Manager DTE Electric Company 6400 North Dixie Highway Fermi 2 - 260 TAC Newport, MI 48166

SUBJECT:

FERMI POWER PLANT, UNIT 2 - FEDERAL EMERGENCY MANAGEMENT AGENCY LEVEL 1 FINDING FROM 2024 EVALUATED EMERGENCY PREPAREDNESS EXERCISE

Dear Allen Mann:

On August 27, 2024, the U.S. Nuclear Regulatory Commission (NRC) and Federal Emergency Management Agency (FEMA) completed an evaluation of an emergency preparedness exercise at Fermi Power Plant, Unit 2. During this exercise, FEMA identified a Level 1 Finding related to the performance of activities performed by Monroe County, Michigan.

Enclosed is correspondence from FEMA Region 5 to the State of Michigan, Emergency Management and Homeland Security Division dated September 9, 2024, which provides detailed information about the issue involved in the Level 1 Finding (ADAMS Accession No. ML24254A356). The NRC is performing our responsibilities described in the Memorandum of Understanding (MOU) between FEMA and NRC (Appendix A to 44 CFR 353). This MOU is also available in ADAMS at Accession No. ML15344A371.

Specifically, this letter and its enclosure serve as formal notification of the Level 1 Finding and our responsibility to monitor Fermis efforts to work with State and local authorities to correct the identified inadequacy. Approximately 60 days after official notification of the Level 1 Finding, the NRC, in consultation with FEMA, will assess the progress being made towards resolution. This is to ensure that reasonable assurance remains, and the offsite organizations retain their ability to take appropriate protective measures to ensure the health and safety of the public.

October 3, 2024

A.Mann 2

If you have any questions, please do not hesitate to contact Jure Kutlesa, Senior Emergency Preparedness Inspector, at (630) 829-9860.

Sincerely, Michael E. Ziolkowski, Chief Security, Emergency Preparedness, and Incident Response Branch Division of Radiological Safety and Security Docket No. 05000341 License No. NPF-43

Enclosure:

FEMA Level 1 Finding Letter (ADAMS Accession No. ML24254A356) cc: A. Mann, Fermi EP Manager C. Bebrich, FEMA 5 MI POC S. OLeary, RAC Chair cc w/ encl: Distribution via LISTSERV Signed by Ziolkowski, Michael on 10/03/24

ML24276A203

SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available OFFICE RIII/DRSS RIII/DRSS NAME JKutlesa:dc MZiolkowski DATE 10/02/2024 10/03/2024

U.S. Department of Homeland Security Region 5 536 South Clark Street, Floor 6 Chicago, Illinois 60605 September 9, 2024 Captain Kevin Sweeney Deputy State Director of Emergency Management Michigan Department of State Police Emergency Management and Homeland Security Division P.O. Box 30634 Lansing, MI 48909 Dear Captain

Sweeney, This is to inform you of the U.S. Department of Homeland Security/Federal Emergency Management Agency's (DHS/FEMA) Region 5 Office identification of one Level 1 Finding during the Fermi 2 Nuclear Power Plant, Full Participation, Plume Exposure Pathway, Radiological Emergency Preparedness Exercise conducted on Tuesday, August 27, 2024.

A Level 1 Finding is defined in the DHS/FEMA REP Program Manual as an observed or identified inadequacy of organizational performance during an assessment activity that could cause a determination 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.

The County of Monroe received a Level 1 Finding under Capability Target 3.2: Alert and Notification of the Public - Offsite Response Organizations demonstrate the capability to provide instructions to the public.

The Level 1 Finding assessed was based on Monroe County's failure to provide accurate and complete information in the initial primary notification Emergency Alert System (EAS) message. (Advisory A - This is a Drill FERMI General Emergency). This message included the wrong date and time for the Governor's declaration of a state of emergency/disaster (1330 Eastern Daylight Time on May 18, 2021), omitted key components of the State of Michigans Protective Action Order (PAO), including evacuation of three of the six Protective Action Areas (PAAs 2, 4, and 5), and omitted the recommendation for public ingestion of potassium iodide (KI). These omissions would have resulted in the public receiving an unnecessary exposure to radiation.

Monroe County did not implement three of the four required elements of the county's 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 EAS message to Wayne County and to the Joint Information Center.

www.fema.gov

Kevin Sweeney Michigan State Police Page 2 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 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 C.F.R. Section 350.9(d), we have thoroughly reviewed and discussed these issues with the U.S. Nuclear Regulatory Commission (NRC). Because of the potential impact these findings have on public health and safety, appropriate corrective actions and a Remedial Exercise will need to be conducted within 120 days after the August 27, 2024, exercise date. These issues were presented to the exercise participants, including the State of Michigan and Monroe County staff during the post-exercise Participants' Briefing conducted on August 30, 2024, and through a subsequent, more detailed discussion with your staff.

The DHS/FEMA Region 5 contacted the Michigan State Police on August 29, 2024, and informed them of the Level 1 Finding. Following a thorough discussion of the circumstances regarding the Level 1 Finding, the DHS/FEMA offered the State of Michigan and Monroe County the opportunity to conduct any necessary retraining and redemonstrations regarding the affected capability target.

Please coordinate with this office no later than September 19, 2024, regarding a Schedule of Corrective Actions, including what corrective actions will be conducted (e.g., training, plan/procedure revision, and/or drills), along with the date, time and identification of those organizations and participants by title who will participate in the Remedial Exercise.

A copy of this letter has been forwarded to the DHS/FEMA Headquarters, the U.S. NRC Headquarters, and the U.S. NRC Region III.

Kevin Sweeney Michigan State Police Page 3 Your cooperation in this matter is sincerely appreciated. If you have any questions, please contact S. P. O'Leary, Chair, Regional Assistance Committee, at (312) 952-3310.

Sincerely, Thomas C. Sivak Regional Administrator Cc:

DHS/FEMA Headquarters U.S. NRC Headquarters U.S. NRC Region III