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JAN 0 81986 Docket No.: 50-461                                        Distribution iDocket Filey NRC'PDR PDh4 WButler Mr. Frank A. Spangenberg                                  OELD Manager - Licensing and Safety                            Edordan Clinton Power Station                                      BGrimes P.O. Box 306                                              JPartlow Mail Code V920                                            BSiegel Clinton, Illinois 61727                                    EHylton ACRS (10)
 
==Dear Mr. Spangenberg:==
DMatthews RMeck
 
==SUBJECT:==
FEMA INTERIM FINDING FOR CLINTON The enclosed memorandum frcn Richard W. Krimm, Assistant Associate Director, Office on Natural and Technological Hazards Programs, FEMA, dated Decerc.ber 13, 1985, forwards for your information and use as appropriate, the interim finding on offsite radiological energency preparedness (REF) plans for the Clinton Nuclear Power Station. The finding was based on the FEMA Region V Regional Assistance Committee's (RAC) review of the preliminary site specific REP plan for Clinton, dated August 1985. The RAC found the Clinton plan inadequate on the basis of deficiencies identified in connection with the following NUREG-0654 planning standards: Assignment of Responsibility; Emergency Response Support and Resources; Public Education and Information; Protective Response; Medical and Public Health Support; Exercises and Drills; and Radiological Emergency Response Training.
The RAC is currently evaluating the schedule of corrective actions provided by the Illinois Emergency Services and Disaster Agency and will provide an assessment of the corrective actions. It is our understanding that FEMA estimates that final version of Clinton's REP plan will be submitted by February 1986, and that      '
the likely date for providing a supplemental finding on the plans is April 1986.
FEMA's preliminary analysis of the offsite preparedness plan based on the jo:nt full-participation exercise of December 4, 1965, indicates no deficiencies affecting public health and safety.
Walter R. Butler, Director BWR Project Directorate No. 4
,j                                                    Division of BUR Licensing
 
==Enclosure:==
As stated cc:  See rext page PD#4 /            PD#4 BSie i :dh        WRButler 01Qf85            01/f/85 4 -              8601270335 860108 lh              PDR ADOCK O      4jl
        \                                                                              _. - _ _
 
      #        'o                            UNITED STATES g
    !              o            NUCLEAR REGULATORY COMMISSION
* WASHINGTON, D. C. 20555
  , h            :
g g g c 1956 Docket No.:    50-461 Mr. Frank A. Spangenberg Manager - Licensing and Safety Clinton Power Station P.O. Box 306 Mail Code V920 Clinton, Illinois 61727
 
==Dear fir. Spangenberg:==
 
==SUBJECT:==
FEMA INTERIM FINDING FOR CLINTON The enclosed memorandum from Richard W. Krimm, Assistant Associate Director, Office on Natural and Technological Hazards Programs, FEMA, dated December 13, 1985, forwards for your information and use as appropriate, the interin finding on cffsite radiological emergency preparedness (REP) plans for the Clinton Nuclear Power Station. The finding was based on the FEMA Region V Regional Assistance Committee's (RAC) review of the preliminary site specific REF plan for Clinton, dated August 1985. The RAC found the Clinton plan inadequate on the basis of deficiencies identified in connection with the following h0 REG-0654 planning standards: Assignment of Responsibility; Emergency Response Support and Resources; Public Education and Information; Protective Response; Medical and Public Health Support; Exercises and Drills; and Radiological Emergency Response Training.
The RAC is currently evaluating the schedule of corrective actions provided by the Illinois Emercercy Services and Disaster Agency and will provide an assessment of the corrective actions. It is our understanding that FEMA estimates that final version of Clinton's REP plan will be submitted by February 1986, and that the likely date for providing a supplemental finding on the plans is April 1986.
FEMA's preliminary analysis of the offsite preparedness plan based on the joint full-participation exercise of December 4, 1985, indicates no deficiencies affecting public health and safety.
ll alter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing
 
==Enclosure:==
As stated cc: See next page
 
l'r. Frank A. Spangenberg                  Clinton Power Station Illinois Power Company                    Unit 1 cc:
Mr. Allen Samelson, Esquire                Jean Foy, Esquire Assistant Attorney General                  511 W. Nevada Environnental Control Division              Urbana, Illinois 61801 Southern Region 500 South Second Street                    Richard b. Hubbard Springfield, Illinois 62706                Vice President Technical Associates Mr. D. P. Hall                              1723 Hamilton Ave. - Suite K Vice President                              San Jose, CA 95125 Clinton Power Station P. O. Box 678 Clinton, Illinois, 61727
!    Mr. H. R. Victor Manager-Nuclear Station Engineering Dpt.
Clinton Power Station P. O. Box 678 Clinton, Illinois 61727 Sheldon Zabel, Esquire Schiff, Hardin & Waite 7200 Sears Tower 233 Wt. ker Drive Chicago, Illinois 60606 Resident Inspector U. S. Nuclear Regulatory Commission RR 3, Box 229 A Clinton, Illinois 61727 Mr. R. C. Heider Project Manager i
Sargent & Lundy Engineers 55 East Monroe Street                  -
Chicago, Illinois 60603 Mr. L. Larson Project Manager General Electric Ccmpany 175 Curtner Avenue, N/C 395 San Jose, California 95125 Regional Administrator, Region Ill 799 Roosevelt Road Glen Ellyn, Illinois 60137
 
gt g            Federal Emergency Management Agency
* c Washington, D.C. 20472 EMORANDIN FOR:      Edward L. Jordan Director, Division of Emergency Preparedness and Engineerirg Response Office of Inspection and Enforcenent U.S. Nuclear Regula ory Ccmnission FRCN:
                                                                        $c*  #,'
                                                                                ~
Assistant Associate Director Office of Natural and Technological Hazards Prcgrams
 
==SUBJECT:==
Interim Findirg on Offsite Radiological Emergency Preparedness Plans for the Clinton Nuclear Power Station Attached is an Interim Finding on offsite radiological energency prepared-ness (REP) plans for the Clinton Nuclear Power Station (NPS) dated November 6,1985. he finding was prepared by Region V of the Federal Emergency Managenent Agency (FENA). At the M;ne that the finding was prepared, neither an exercise nor public necting had been held in accordance with 44 CFR 350.      (ne initial Clinton exercise was held on Decenber 4,1985.) Therefore, the report is based on the FEMA Region V Regional Assistance Ccmnittee's (RAC) review of the preliminary site-specific REP plan for Clinton (Volume VIII of the Illinois Plan for Radiological Accidents (IPRA]), dated Atgust 1985.
Se RAC evaluated the preliminary Clinton plan in accordance with the criteria provided in NUREG-0654. Based on that evaluation, the preliminary plan was found to be inadequate. During the review, the RAC identified plannirg deficiencies which could adversely affect public health and safety. Specifically, deficiencies were identified in connection with the followirg NUREG-0654 planning standards: Assigrynent of Responsibility; Emergency Response Support and Resources; Public Education and Infonnation; i        Protective Response; Medical and Public Health Support; Exercises and Drills; and, Radiological Dnergency ResInnse Training.
On October 21, 1985, FENA Region V provided the Illinois Emergency Services and Disaster Agency with the RAC's consensus review of the preliminary Clinton plan. Prior to the initial Clinton exercise on Decenber 4,1985, Illinois provided a schedule of corrective actions to FEMA 1%!gion V.
This information has been provided to the RAC for review and evaluation.
Follcwing the RAC's evaluation, an assessnent concerning the adequacy of the corrective actions will be made. The results will be provided to the State. We estimate that the final version of the plan will be submitted to FENA Region V by February 1986. If this schedule is maintained, we would nost likely be able to provide a supplenental finding oc the plans
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by late April 1986. It is our judgment that a serious plannirg effort has been put forth to date, and we anticipate the final version of the Clinton plan (IPRA, Voltzne VIII) will be an adequate plan frtra which to conduct energency radiological response.
During the next few months, FDIA will provide NRC with an evaluation of preparedness based on the Decenber 4,1985, joint full-participation exercise. Although the exercise assessment report has not, of course, been Irepared, preliminary analysis of the exercise results indicate there were no deficiencies affecting public health and safety.
If pu have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 646-2861.
Attachnent As Stated t
m.__.          -              -,,
 
INTERIM FINDING Clinton Nuclear Power Station Off-Sire Radiological Emergency Preparedness State of Illinois DeWitt. Macon. McLean and Piatt Counties November 6, 1985 INTRODUCTION A. Area Description
: 1. Facility and Surroundings                            -
The Clinton Nuclear Power Station Unit 1 (Clinton Station) is co-owned by Soyland Power Cooperative, Western Illinois Power Cooperative and Illinois Power Company and is operated by Illinois Power Company of Decatur, Illinois. The Station mire encompansen about 14.000 acres. This includes the Station itself, about 150 acre =, and a msnmade. irregular U-shaped cooling reservoir of about 5000 surface acres, known as Clinton Lake.
The topography consists mostly of slightly rolling prairie land. The Station is in Harp Township within DeWir e County. approximately seven miles east of Clinton, Illinois, at 737 feet above sea level.
The location can further be defined by placing Clinton Station in an approximate center of a triangle f ormed by Bloomington, 22 miles to the north. Decatur. 22 miles to the south, and Champaign. 30 miles to the east.
The reactor containment, the focal point for the Station. is located approximately three miles northeast of the confluence of the North Fork River and the Salt Creek. The majority of the Clinton Station is located in the eastern half of DeWitt County with the arms of its man-made cooling reservoir (Lake Clinton) extending into the northeastern area of the County.
Land use within five miles is primarily agricultural with some rural I      residences. The 1980 permanent population within five miles of the Clinton Station is 998 for a population density of 13 persons per square mile. As a comparison, the density for the State of Illinois is 203 persons per square mile based on 1979 population estimates.
l Three communities with a total 1980 population of 9,313 lie between five and l        ten miles from the Clinton Station. An additional 2,705 persons live in rural residences or on farmsteads for a projected total of 12,018 persons living between five and ten miles from the Clinton Station.
: 2. Emergency Planning Zones                                              .
The plume exposure (10-mile) Emergency Planning Zone (EPZ) for the Clinton Station encompasses land aream in four Counties: DeWirt, McLean, Piatt and Macon. The boundary van defined following a detailed review of the l        demography, topography, land characteristics, access routes and I        jurisdictional boundaries in the area surrounding the power station. This 1
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review resulted in a determination that the primary basis f or the '10-mile EPZ boundary definition should be political jurisdictions, man-made featuras (e.g., highways, railrosos, canals. etc.) or strong topographical features (e.g. streams, rivers etc.) as well as Clinton Lake across the middle of the area, which could consistently serve as boundary segments.
Supportive evidence for the use of p'olitical jurisdictions to form the boundary is given by the strong bond between a given population and its political subdivision / city, rown or township of residence. Fur th e rmor e ,
political subdivision boundaries in the area of the Clinton Station have been very stable and are expect =d to maintain that stability. For this reason. political subdivision boundaries are highly appropriate when consid= ring the establishment of a stable. long-term EPZ boundary.
Another reason for the predominant use of political subdivisions in defining the 10-mile EPZ boundary is that many of the designated local response agencies (particularly fire and police departments) are structured on the basis of local political subdivisions and are established to serve these subdivisions. Designation of the 10-mile EPZ along these boundaries simplifies many aspects of offsite emergency response planning and preparation.
In cases where the local political jurisdictional boundaries were nor reasonably near the 10-mile radius to the Clinton Station, attempts were made to use man-made, or topographical featuren as a boundary basis. In such cases. highways v=re the pref =rred choice as the basis for the EP4 definition.
For dissemination of emergency instructions and information to the public, thirty Sub-Area boundaries have been identified and established based on demography. topography. lano characteristics, access routes and jurisdictional boundaries as discussed above. State and local emergency preparedness officials have participated in the development of the Clinton Station EPZ and Sub-Area boundarien.
In the event of a serious accident at the Clinton Station, the pluma exposure EPZ will be the area in which intensive efforts will be made to notify and protect resioents and transient populations from exposure to radiation. This EPZ includes the following municipalities:
Covernments within the 10-Mile Emergency Planning Zone DeWitt                    1980          Miles            Direction County                Population    From Site          Trom Site 8,014            7            West Southwest Clinton                                                  West Northwest Wapella                    768            7 Weldon                      531            6            Southwast DeWitt Villag.              232            3            East NorthEasr Total 1980 Population 9,545 2
 
      'NOV.22 '85 14:56 FEMA REGIOri V CHICAGO 1                                  P.02 l
l 1he primary land use around the Clinton Station is agricultural, with cash grain crops of corn and soybeans. The industries nearest the Station are            l located in the conmunity of Clinton. Recreational facilities outside the municipalities include the Clinton Lake State Recreational Area and the Weldor Springs state Park.
Major transportation facilities in the Clinton Station EPZ are State                  i Hichways 54,19 and 48, all of which cross the EPZ. Railroads are the 1111ncis Central Gulf which comes within 3/4 mile north of the Station and a rail spur of Illinois Central Gulf 3.5 miles south of the station.
Governments Within the 58-Nile Beergency Planning Zone me ingestion exposure pathway planning zone consists of a circle extending fifty miles outward with the Clinton station es the center pint. The 58-mile-EPZ includes the Illinois Counties of Chanpaign,
,              Christian, Coles, DeWitt, Douglas Ford, Iroquois, Livingston, Logan, NcLean, Macon, Mason, Menard, Moultrie, Platt, Sangamon, Shelby, Tazewell, Vermillion, and Woodford.
: 3. Spcial Dunographic Circumstances for Planning the area in the 18-mile EPZ of Clinton Station consists of slightly rolling prairie land. Drainage is toward the general vicinity of the Station into the lake / river-creek which surrounds the Station on three sides. The soil quality is desiramble for crop cultivation; mainly corn and soy beans.
Iarge farms dot the rural countryside. The only major sunicipality is the corsaurity of Clinton. It is the area's center of conseros and industry, Unique Considerations Recreational Areas l
Clinten take state Recreational Area and Weldon 8prings State Park are the recreerional facilities in the 19-mile EPZ.
Clinten take is a 4,895 acre man ende cooling lake within the Clinton i        statico property lines. Recreational facilities acecronodate canping, i        boatirg, hunting, fishing and hiking. Clinton Lake is unique in its natural state in that it forns a "V" pointing to the southwest. It rests in a l        natural formation of ancient creek and river beds now covered by water resultant from a man-ende dam constructed to hold water for the Station's l        water cooling needs. The man-ende creation has given miles and miles of shore line and vast areas of water which supports aquatic life. It provides a vast area for boaters, fisherman and water foul hunters.
i Maldor: Springs State Park enconpasses approximately 378 acres and contains a 28 acre lake with cenping, fishing and picnicking facilities.
Transportation Systems State Highways 54,18 and 48 cross the 19-mile EPZ. Othermajor thorotghfares are U.S. Highway 51 located about six miles west of the Statico. Interstate 74, although not in the 19maile EPZ, is a significant transportation route located about eleven miles northeast of the Station.
l 3
 
The nearent railroad is the Illinois Central Gulf Railroad (ICG) which crosses the 10-mile EPZ eamr-wear and comes within 3/4 mile of the Station to the north. Another ICC track bed is located 3.5 miles to the south of the Station.
Local Emergency Resources Within the 10-mile EPZ of the Clinton Station is one principal municipality; Clinton. An incident at the Station could very well demand the total emergency capability of the community of Clinton. Their emergency resources are suf ficient to meet the everyday emergency need of the residents, businesses and industries but the emergency resources may be limited to meet a technological emergency.such as a significant radiological accident at the Clinton Station. The State remources would supplement the local efforts to combat such an occurrence.
B. Emergency Planning Authority and Organizations The Illinois Emergency Services and Disaster Agency Act of 1975 (Ill. Rev.
Star. Ch. 27. para. 1101 er. seq.) establishes an Emergency Services and Disaster Agency and confers upon it broad authority to plan for a coordinated response by Srare and local agencies to all disasterm, whether from natural or manmade causes. The Act provides that the authority to deploy resources in response to an emergency shall be provided by an executive proclamation of a " State of Disaster Emergency."
The Illinois Nuclear Safety Preparedness Act (Ill. Rev. Stat.. Ch.111 1/2, para. 4301 et. seq.) designates the responsibility for emergency response planning for accidents ar fixed nuclear facilities to the Illinois Department of Public Health and provides for a fee to be assessed on licenmed nuclear power rescrors to fund the Illinois Nuclear Safety Preparedness Program. The Governor of Illinois, by Executive Order Number 3, dared April 1. 1980, creared the Department of Nuclear Safety (IDNS),
transferring to that uepartment the responsibilities of the Illinois Department of Public Health cefined in the Illinois Nuclear Saf ety Preparedness Program.                                                                _
C. History and Status of Planning and Preparedness
: 1. Plan Development The Illinois Plan for Radiological Accidents (IPRA) is contained in Volume I, the " State General Plan" (March 1982) and an accompanying book of Standard Operating Procedures (SOPS) as well as seven site specific volumes and SOPS. A reformatted version of IPRA Volume I was provided to the RAC in August of 1985 for consideration along with preliminary IPRA Volumes VII (Braidwood) and VIII (Clinton). The preliminary IPRA Volume VIII (Clinton) has been evaluated by the Region V Regional Assistance Committee (RAC).
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NOV.'22 '85 14:56 FEt% REGION V CHICAGO 1                                                P.03
: 2. P'an Review Review ecanents of the State (Volume I) and preliminary Clinton (Voltzne VIII) IPRA were prepared by FDIA Region V with the counsel of the RAC. The conso'.idated RAC finding of the plan was sent to the Illinois ESDA on October 21, 1985. The state will address the deficiencies and respond with a schedule of corrective actions by November 29, 1985. Subsequently, they will incorporate the corrective actions into the plan (Volunes I and VIII) and formally sulznit the p1.an in its final form scenetime after the December 4, 1935 full participatica joint exercise.
: 3. Public Meeting It is tentatively planned to conduct a public meeting following the publishing of the exercise report. %erefore, the date for the meeting will be in March or April 1986.
: 4. Exercises S e initial qualifying exercise is scheduled for December 4, 1985. It is full participation for all participants; Illinois ESDA, IDNS, DeWitt County, and the applicant, Illinois Power Company.
: 5. Intervenor Contentions Contentions were filed with the Atomic Safety and Licensing Board which pertain to offsite emergency planning for the Clinton Nuclear Power Station. In a Special Conference, the contentions were dismissed from a hearing and will be satisfied through agreenents between the intervenors and the S:ste and Applicant.
D. Cocunentary Evidence Available for Examination
: 1. P'.ans and Plan Reviews.
Illinois Plan for Radiological Accidents
,                        State General Plan, Voltana I, February 1981 state General Plan, Volume I, March 1982 (Reformatted 1981 edition) i                        State General Plan, Voltane I, (Draft Reformatted) June 1985 l                        State General Plan, SOPS, March 1982 l                        Clinton Plan, Volume VIII, August 1985 (preliminary)
Clinton SOPS, August 1985 (preliminary)
Clinton Public Information Brochure, (Draft) August 1985 RAC consensus review of the above plans dated October 1,1985 and relevant correspondence.
It is necessary to understand that the preliminary Clinton plans which have been sent to FD5A Region V cre not the formal sulanission as described in 44
.                  CFR Part 358. Boy are for review purposes only. Further, until the l                  reformatted Voltaan I is formally sulznitted and accepted, the 1982 State General Plan is the plan of record.
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PLAN EVALUATION SUNMARY The State General Plan (IPRA Volume I) has been formally reviewed and approved for the site-specific locations of Dresden ( FEMA-REP-5-IL-1) and LaSa11s ( FEMA-REP-5-IL-2 ) . Those approvals are based upon the IPRA Volume The 1982 I, dared February 2. 1981, which was reformatted in March 1982.
edition conder. sed the volume by printing on both sides of the pages. made monor changes'and corrections recommended by the Regional Assistance Committee ano placed the Standard Operating Procedures in a separate and o
binder. Based upon the Regional Assistance Committee review of plans    In addition, exercise results, FEMA determineo the document to be adequate.
under the IPRA Volume I. March 1982, the Regional Director's Evaluations for Quad Cities ( FEMA-REP-5-IL-3) and Zion (FEMA-REP-5-IL-4) were submit ted October 25, 1983, approved March 2.1984 and published in the Federal Register March 9, 1984. The Regional Director's Evaluation for Byron (FEMA-REP-5-IL-5) was submitted June 18, 1984, approved September 13, 1984 and published in the Federal Register September 19, 1984.
A nev idition of the State General Plan (IPRA Volume 1) was submitThe      tednew along with the preliminary Clinton (IPRA Volume VIII) Plans and SOPS.
version has eliminated extraneous material and has been condensed to a more useable document. It will undergo formal RAC review    for to determine if it IFRA Volume I.
signifiiantly alters sny of the early RAC findings
      -      For the purpose of this review, the Regional Assistance Committee has provided a consensu. finding of the preliminary Clinton (IPRAThe    Volume reviewVIII)
Plans and SOF6 and the Scare General Plan (IPRA Volume I).
participants included Federal Emergency Management Agency, U.S. Department of Energy. Food and Drug Administration, Public Health Services, U.S.
Nuclear' Regulatory Commission, U.S. Environmental Protection Agency, U.S.
Department of Transportation, and the U.S. Department of Agriculture.
as The following is a summarization of Clinton (IPRA    Volume VIII) and,  format of relevant. the State General Plan (IPRA Volume I)    and follows the
              " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Pcwer Plants," NUREG-0654 / FEMA-REP-1, Revision 1.
A. Assignment  of Responsibility (Organization Control)
The offsite radiological emergency plan for the Clinton Nuclear Power Station assigns responsibility to State and local governments for emergency response ef forts in the emergency planning zones.
The DeWitt County government has an operational role which is explained in its concept  and its relationship to the total effort. A block diagram illustrates the interrelationship of County agencies and departments.
In the case of the County, there is an individualforbythetitle24who is in charge hour per day of the emergency response and provision is made emergency response in addition to a 24 hour communication watch through the Sherif f's radio dispatch.
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In the Clinton Plan and for DeWitt County. functions and responsibilities for major emergency response elements and key individuals by title are provided in matrix form. A narrative of each major emergency service in provided with good explanation of response involvement.
The specific codes and statures arn referenced and are reflected in the State General Plan (IPRA Volume 1). A copy of the legal authorities pertaining to DeWitt County has been requested of the State.
Missing from the plan are the necessary letters of agreement between government agencies and support organizations with emergency response roles in the EPZ.
The County and municipalities operate from a central location in DeWitt County where the key agencies and departments gather when activated for the emergency response. The facility is the Emergency Operations Center. It is capable of 24 hour operations over a protracted period. - An individual, by title, is designated who is responsible f or assuring continuity of resources.
B. Onsite Emergency Organizations Onsite emergency organization is a licensee responsbility and is to be evaluated by the NRC.
C. Emergency Response Support and Resources The necessary non-government resources to support the Federal response are discussed in the State Plan but need further development in providing more information; specifically a listing of resources to support the Federal responte.
Missing from the plan are the necessary letters of agreement which form the basis of other facilities and organizations which can be relied upon to provide assistance in an emergency.
D. Emergency Classification System DeWitt County has adopted the emtrgency classification and emergency action l
level scheme which is consistent with the Scare and the applicant.
l
'  Contained in the plans are procedures that provide for emergency actions which are consistent with emergency actions recommended by the applicant.
I l
l  E. Notification Methods and Procedures The County plan establishes the procedures which describe mutually agreeable bases for notification of response organizations which are consistent with the emergency classification and action level scheme. The procedures include the verification of messages using the Nuclear Accident Reporting System (NARS) form.
Procedures are established for alerting, notifying and mobilizing emergency response personnel in the County.
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A system is in place in planning for disseminaring to the public appropriare information in initial and follow up messages which are received from the applicant. The planning includes the procedures for notifying the area emergency broadcast radio stations (WSOY AM/FM) for public announcements to advise the public on actions to take in the event of an emergency.
The County plan addresses the administrative and physical means and the time required for notifying and providing prompt instructions to the public. The RAC requested of Illinois ESDA an explanation of the notification system with specific reference to the reliability of the backup measures to assure that the necessary instructions are properly and accurately given to the public.
Written public information scripts are a part of the plan and contain important protective action recommendations.
F. Emergency Communications in planning, provisions are made for 24 hour per day notification to activate the local emergency response network and the communication links to emergency response groups. Planning has been formulated for communications with contiguous State and local governments within the Emergency Planning Zones. The notification of other State and the Federal family is the responsibility of the Illinois ESDA and is in the State General Plan (IPRA Volume 1).
Communications between the Nuclear Power Station. the Emergency Operations Facility, State and local emergency operations centers and radiological monitoring teams and the communications for alerting and activating emergency personnel is provided for through the NARS, other dedicated telephone lines. radio and commercial telephone.
Coordinated communications links for fixed and mobile medical support facilities do exist and are so stated in the plan.
Provision is made for testing the entire emergency communications system on a periodic basis.
C. Public Education and Information A public information brochure is to be distributed periodically to the public. The brochure disseminates information to the public regarding howof they will be notified and what the public actions should be in the event an emergency at the Clinton Nuc1 car Power Station. Included in the draft brochure is guidance on what to do with pets and livestock.
The plan designates the points of contact and physical locations for use by the news media during an emergency. Also listed are locations for the municipalities in the 10-mile EPZ and the State News Media Cenrer.
The plan designates a spokesperson for the release of public announcements.
The RAC wishes more specificity as to the individuals, by title, in each location who serve as spokesperson=.
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i                                                          ,
plan for the exchange of information among the
* Provision in made in the in the County and municipalities.
designated spokespersons the lowest leve.1 of government practical. Specifically, Rumor control is at                                    implemented at the local the plan needs to explain how rumor control isto handle rumors over a State network.
level. The State makes provision              the time of public press briefings and The phone numbers are made public at announcements.
l The State and applicant have provisions in planning for the conduct of press briefings annually to acquaint the news media with the emergency plans and for release of public information during an emergency.
points of contactUsually the annual briefings are held prior to the annual exercise.
H. Emergency Facility and Equipment Emergency Operations Centers are establisted in the County and in the State. Emergency operations and functions are carried out      from It is    these a temporary locations. There is concern over the EOC in Clinton. It has been brought facility located seven miles from the Clinton Station.for an alternate EOC outside the 10 to the attention of the Scare the need mile EPZ.
Provisions are made for the activation and staffing of the Emergency Operations Centers.
The Offsite radiological monitoring is the responsibility of the IDNS.
'                          assignment and function is in the Scare Plan and SOPS.
inventory and operationally checking emergency The criteria for inspection, instruments is satisfactorily addressed.
The identification of emergency kits by general category is included in the State Plan SOPS.
A central point is established for the receipt and analysis of all field monitoring data and the coordination of sample media.
I. Accident Assessment The capability and resources for field monitoring within the plume exposure EPZ are a part of the State General Plan (IPRA Volume I).
id The State Plan provides for methods, equipment and expertise to make rap assessments of the actual or potential magnitude and locations                of field radiological hazards. It includes activation, notificationi means,      i    nt and team composition. transportation, communications, monitor ng equ pme estimated deployment times.
The Stare has the capability to detect and measure radiciodine    for relating the Also established are the means              Provision concentrations in the air.
various measured paramet ers and gross                          Detailsradioactivity are                            me rates and for comparison with protective action guides.
described in the procedures.
9
 
Arrangements are made to locate and track airborne radioactive plumen using Federal and/or Scare remources.
J. Protective Response Provided for in the Scare planning, relative to the Clinton Station, is an entablished capability for implementing protective action guides and other criteria.
Contained in the Clinton plan are maps which depict the thirty subarea sectors. Contained in each subarea is the population distribution.
Refinements to the maps would enhance the presentation of the information.
An improvement would be to include EPZ boundary lines in map legends.
The transient and resident populations are to be notified by the Prompt Alert and Notification System. The plan cites the use of the emergency broadcast station, tone alert monitors, radio systems for schoole, businesses and institutions and by the outdoor sirens which have voice capability in addition to the wail siren, public information brochures, posted signs and notices in places frequented by the public.
Planning provides for the confined, in home bed-ridden and mobility impaired. Lists are held by local officials which locates those who need special arrangements. The Public Information Brochure takes the handicapped population into account.
The issue and recommendation for the intake of potassium iodide is a decision of the State Department of Health Administrator. Directives are drawn up and in the State General Plan (IPRA Vol'ume I) which clearly states the policy of the State on potassium iodide ume. Potassium iodide is pre-issued in dosimetry kits.
The Clinton plan and SOPS contain the procedures for relocating the population. Sheltering is planned and all reception / care centers are well outside the 10-mile EPZ.
Traffic capacities are not in the plan. The Clinton Evacuation Time Estimate Study which is referenced in the correlation document has been received and forwarded to the RAC for evaluation.
Control of access to evacuated areas and organization responsitility for such control is provided in 8-SOP-7, Traf fic and Access Control Guide. The accuracy of instructions for each point should be checked.                  .
The responsibility for dealing with impediments is assigned to the County's Highway Superintendent.
The choice of recommended protective actions is the responsibility of the IDNS and in contained in the State Plan SOPS. The IDNS has proven adequate plati:ag and capability in the methods and recommendations for protecting the r.sblic from consumption of contaminated food-stuf f s.
The Red Cross Chapters have the responsibility for registering and the IDNS is responsible for monitoring the evacuees. Procedures for monitoring can be found in the State Plan SOPS.
10
 
K. Radiological Exposure Control It is the responsibility of the IDNS to make provision for 24 hour capability to cere:mine radiation domen received by emergency personnel and it is provided for in State planning.
The plann cover the distribution of dosimetry, reading frequencies and the maintaining of racords and the control point for record data deposit.
Planning establishes a decision chain for exposure of emergency workers to radiation in excess of EPA Public Protective Action Guiden.
IDNS has established and published action levels for decontamination. They provide monitoring support and technical assistance to local officials for the decontamination of equipment and personnel.
L. Medi. cal and Public Health Support The Clinton plan and the State plan address the arrangements for local and backup hospitals and medical services. It would enhance planning if a discussion was included in local planning in modition to the listing provioed. Letterm of undereranding with the hospitals ano medical services      -
are required to complete the planning process.
The plan liars the location of hospirale. cype of facility. capacity and special radiological capabilities for providing medical support for contaminated injured individusls.
The plan does not make clear the local arrangement for transporting contaminated and/or injured individuals.
M. Recovery and Reentry Planning and Post-Accident Operations The SOPS to the Clinton Plan adequarely address the procedures fo: recovery and reentry into the evacuated ares.
The State plan specifien:        means for informing the response organizations char a recovary operation is to be initiated;          changes in the j          organizational structure; ano, in addition, specifies the means for periodically estimating total pop 11ation exposure.
N. Exercises and Drills The State is the responsible organization for conducting drills and exercises under guidance ser forth by NRC and TEMA and is ao stared in the plan. Exercises are to provide for mobilizing resources and personnel at the State and local levels and the exercise is to follow objectives and a scenario which is common to the applicant. Exercises are to be critiqued by the State and evaluated by FEMA and the RAC. There is provision is for the variance of exercise times. seasons and conditions.
Communications drills and rears are periodically conducted as a matter of routine in daily business. There is no provision within the plan for medical emergency d: ills.
11
 
The IDNS conducts radiological monitoring and health physics drills for
  '                their own department personnel and for emergency responders and officials in the local units of government.                  .
Exercise planning and the conduct of exercises is in accordance with Federal guidance. Following Federally observed exercises, the evaluation is critiqued in a joint State-local-utility public meeting as the Federal criteria specifies.
As a result of the evaluation, a report is provided the State. The State has provisions for acting on recommendations for corrective actions resulting from exercising.
O. Radiological Em'ergency Response Training The State General Plan (IPRA Volume I) provides for the conduct of training to any group or jurisdiction on an annual basis and training is available upon request at any time. But the plan does not address emergency training for those emergency government organizstions where mutual aid agreements are an integral part of the planning (Macon. NcLean and Piart Counties).
The Clinton Plan (IPRA Volume VIII) and the State General Plan (IPRA Volume I) establish a training program for instructing and qualifying personnel who will implement radiological emergency response. The training includes and is not limited to annual retraining.
l                    P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans The plans, in their training program, make provision for the training of      '
those individuals who develop general and site-specific plans. Individuals by title are designated with responsibility for the development. and updating of emergency plans and coordination of the plans with other response organizations. The updating of local plans is the responsibility of the
;                    County emergency direct.or.
The annual certification procedure is stated in the State General Plan (IPRA Volume I).
The approval process of changes in the plan and the forwarding of the changes are not adequately addressed in the local plan nor referenced to the State plan but it is accounted for in the State plan.
The State plan contains a listing of supporting plans and their source. And the plan has a correlation document (appendix) listing the procedures required to implement the plan. The plan also contains a table of contents. The correlation document cross-references the planning items to l
the criteria.
J Special consideration is given to the State of Illinois for this criteria element in that the State currently has five operating nuclear power c
stations within its boundaries and ultimately there will be seven. It poses an unusual and demanding hardship on the State to update telephone numbers quarterly. As discussed with the Illinois ESDA in past evaluations it is agreed an annual update is necessary to the Federal holders of the plan.
However, it is understood and agreed to that at the State and local levels, all telephone listings will be kept current as they change.
12 i-  -      - - -            ,, . . _ _ _ - _ _  _ _    _ _ _                    _
 
1 l
      ..                                                                                    1 i
* l COFCLUSION The foregoing is the status based on RAC consensus review of the preliminary offsite planning for the Clinton Nuclear Power Station. It is t.he conclusion of FEMA Region V that the preliminary Clinton Plan (IPRA Volume VIII) is currently inadequate. The Illinois ESDA must correct the noteo deficiencies in the detailed RAC consensus review. The State of Illinois will submit a schedule of corrective actions by November 20. 1985 for RAC review.
The planning deficiencies could adversely af fect public health and safety and must be corrected in order to provide reasonable assurance that the plan can be implemented. Also, important support documents are missing which are vital to the plan as a functional document. Specifically, planning deficiencies exist in the areas of Assignment of Responsibility, Emergency Response Support and Resources, Public Education and Information, Protective Response, Medical and Public Health Support, Exercises and Drills and Radiological Emergency Response Training. Thes= deficiencies and several recommendations from the RAC to enhance or clarify planning will be addressed by the schedule of corrective actions.
However, it is FEMA Region V's judgment thsr serious planning effort has been put forth to date and it is anticipereo the final version of the Clinton Plan (IPRA Volume VIII) will be an adequate plan from which to conduct emergency radiological responses. Further, the State and local governments will demonstrate implementation of their planning (preliminary Clinton Plan and schedule of corrective actions) during the December 4, 1985 full participati.1 exe:cise. Evaluation of this exercise as well as analysis of the schedule of corrective actions will allow a reassessment of the adequacy of offsite planning over the next few months.
13
  .}}

Latest revision as of 21:45, 30 June 2020

Forwards FEMA 851213 Memo Enclosing Interim Finding on Offsite Radiological Emergency Preparedness Plans.Plan Inadequate.Regional Assessment Committee Currently Evaluating Schedule of Corrective Actions
ML20137L210
Person / Time
Site: Clinton Constellation icon.png
Issue date: 01/08/1986
From: Butler W
Office of Nuclear Reactor Regulation
To: Spangenberg F
ILLINOIS POWER CO.
References
RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8601270335
Download: ML20137L210 (3)


Text

_.

b e .

JAN 0 81986 Docket No.: 50-461 Distribution iDocket Filey NRC'PDR PDh4 WButler Mr. Frank A. Spangenberg OELD Manager - Licensing and Safety Edordan Clinton Power Station BGrimes P.O. Box 306 JPartlow Mail Code V920 BSiegel Clinton, Illinois 61727 EHylton ACRS (10)

Dear Mr. Spangenberg:

DMatthews RMeck

SUBJECT:

FEMA INTERIM FINDING FOR CLINTON The enclosed memorandum frcn Richard W. Krimm, Assistant Associate Director, Office on Natural and Technological Hazards Programs, FEMA, dated Decerc.ber 13, 1985, forwards for your information and use as appropriate, the interim finding on offsite radiological energency preparedness (REF) plans for the Clinton Nuclear Power Station. The finding was based on the FEMA Region V Regional Assistance Committee's (RAC) review of the preliminary site specific REP plan for Clinton, dated August 1985. The RAC found the Clinton plan inadequate on the basis of deficiencies identified in connection with the following NUREG-0654 planning standards: Assignment of Responsibility; Emergency Response Support and Resources; Public Education and Information; Protective Response; Medical and Public Health Support; Exercises and Drills; and Radiological Emergency Response Training.

The RAC is currently evaluating the schedule of corrective actions provided by the Illinois Emergency Services and Disaster Agency and will provide an assessment of the corrective actions. It is our understanding that FEMA estimates that final version of Clinton's REP plan will be submitted by February 1986, and that '

the likely date for providing a supplemental finding on the plans is April 1986.

FEMA's preliminary analysis of the offsite preparedness plan based on the jo:nt full-participation exercise of December 4, 1965, indicates no deficiencies affecting public health and safety.

Walter R. Butler, Director BWR Project Directorate No. 4

,j Division of BUR Licensing

Enclosure:

As stated cc: See rext page PD#4 / PD#4 BSie i :dh WRButler 01Qf85 01/f/85 4 - 8601270335 860108 lh PDR ADOCK O 4jl

\ _. - _ _

  1. 'o UNITED STATES g

! o NUCLEAR REGULATORY COMMISSION

, h  :

g g g c 1956 Docket No.: 50-461 Mr. Frank A. Spangenberg Manager - Licensing and Safety Clinton Power Station P.O. Box 306 Mail Code V920 Clinton, Illinois 61727

Dear fir. Spangenberg:

SUBJECT:

FEMA INTERIM FINDING FOR CLINTON The enclosed memorandum from Richard W. Krimm, Assistant Associate Director, Office on Natural and Technological Hazards Programs, FEMA, dated December 13, 1985, forwards for your information and use as appropriate, the interin finding on cffsite radiological emergency preparedness (REP) plans for the Clinton Nuclear Power Station. The finding was based on the FEMA Region V Regional Assistance Committee's (RAC) review of the preliminary site specific REF plan for Clinton, dated August 1985. The RAC found the Clinton plan inadequate on the basis of deficiencies identified in connection with the following h0 REG-0654 planning standards: Assignment of Responsibility; Emergency Response Support and Resources; Public Education and Information; Protective Response; Medical and Public Health Support; Exercises and Drills; and Radiological Emergency Response Training.

The RAC is currently evaluating the schedule of corrective actions provided by the Illinois Emercercy Services and Disaster Agency and will provide an assessment of the corrective actions. It is our understanding that FEMA estimates that final version of Clinton's REP plan will be submitted by February 1986, and that the likely date for providing a supplemental finding on the plans is April 1986.

FEMA's preliminary analysis of the offsite preparedness plan based on the joint full-participation exercise of December 4, 1985, indicates no deficiencies affecting public health and safety.

ll alter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing

Enclosure:

As stated cc: See next page

l'r. Frank A. Spangenberg Clinton Power Station Illinois Power Company Unit 1 cc:

Mr. Allen Samelson, Esquire Jean Foy, Esquire Assistant Attorney General 511 W. Nevada Environnental Control Division Urbana, Illinois 61801 Southern Region 500 South Second Street Richard b. Hubbard Springfield, Illinois 62706 Vice President Technical Associates Mr. D. P. Hall 1723 Hamilton Ave. - Suite K Vice President San Jose, CA 95125 Clinton Power Station P. O. Box 678 Clinton, Illinois, 61727

! Mr. H. R. Victor Manager-Nuclear Station Engineering Dpt.

Clinton Power Station P. O. Box 678 Clinton, Illinois 61727 Sheldon Zabel, Esquire Schiff, Hardin & Waite 7200 Sears Tower 233 Wt. ker Drive Chicago, Illinois 60606 Resident Inspector U. S. Nuclear Regulatory Commission RR 3, Box 229 A Clinton, Illinois 61727 Mr. R. C. Heider Project Manager i

Sargent & Lundy Engineers 55 East Monroe Street -

Chicago, Illinois 60603 Mr. L. Larson Project Manager General Electric Ccmpany 175 Curtner Avenue, N/C 395 San Jose, California 95125 Regional Administrator, Region Ill 799 Roosevelt Road Glen Ellyn, Illinois 60137

gt g Federal Emergency Management Agency

  • c Washington, D.C. 20472 EMORANDIN FOR: Edward L. Jordan Director, Division of Emergency Preparedness and Engineerirg Response Office of Inspection and Enforcenent U.S. Nuclear Regula ory Ccmnission FRCN:

$c* #,'

~

Assistant Associate Director Office of Natural and Technological Hazards Prcgrams

SUBJECT:

Interim Findirg on Offsite Radiological Emergency Preparedness Plans for the Clinton Nuclear Power Station Attached is an Interim Finding on offsite radiological energency prepared-ness (REP) plans for the Clinton Nuclear Power Station (NPS) dated November 6,1985. he finding was prepared by Region V of the Federal Emergency Managenent Agency (FENA). At the M;ne that the finding was prepared, neither an exercise nor public necting had been held in accordance with 44 CFR 350. (ne initial Clinton exercise was held on Decenber 4,1985.) Therefore, the report is based on the FEMA Region V Regional Assistance Ccmnittee's (RAC) review of the preliminary site-specific REP plan for Clinton (Volume VIII of the Illinois Plan for Radiological Accidents (IPRA]), dated Atgust 1985.

Se RAC evaluated the preliminary Clinton plan in accordance with the criteria provided in NUREG-0654. Based on that evaluation, the preliminary plan was found to be inadequate. During the review, the RAC identified plannirg deficiencies which could adversely affect public health and safety. Specifically, deficiencies were identified in connection with the followirg NUREG-0654 planning standards: Assigrynent of Responsibility; Emergency Response Support and Resources; Public Education and Infonnation; i Protective Response; Medical and Public Health Support; Exercises and Drills; and, Radiological Dnergency ResInnse Training.

On October 21, 1985, FENA Region V provided the Illinois Emergency Services and Disaster Agency with the RAC's consensus review of the preliminary Clinton plan. Prior to the initial Clinton exercise on Decenber 4,1985, Illinois provided a schedule of corrective actions to FEMA 1%!gion V.

This information has been provided to the RAC for review and evaluation.

Follcwing the RAC's evaluation, an assessnent concerning the adequacy of the corrective actions will be made. The results will be provided to the State. We estimate that the final version of the plan will be submitted to FENA Region V by February 1986. If this schedule is maintained, we would nost likely be able to provide a supplenental finding oc the plans

__ . ~ - %f.1-~

, p6k"E66 5 050% ? P f=

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by late April 1986. It is our judgment that a serious plannirg effort has been put forth to date, and we anticipate the final version of the Clinton plan (IPRA, Voltzne VIII) will be an adequate plan frtra which to conduct energency radiological response.

During the next few months, FDIA will provide NRC with an evaluation of preparedness based on the Decenber 4,1985, joint full-participation exercise. Although the exercise assessment report has not, of course, been Irepared, preliminary analysis of the exercise results indicate there were no deficiencies affecting public health and safety.

If pu have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division, at 646-2861.

Attachnent As Stated t

m.__. - -,,

INTERIM FINDING Clinton Nuclear Power Station Off-Sire Radiological Emergency Preparedness State of Illinois DeWitt. Macon. McLean and Piatt Counties November 6, 1985 INTRODUCTION A. Area Description

1. Facility and Surroundings -

The Clinton Nuclear Power Station Unit 1 (Clinton Station) is co-owned by Soyland Power Cooperative, Western Illinois Power Cooperative and Illinois Power Company and is operated by Illinois Power Company of Decatur, Illinois. The Station mire encompansen about 14.000 acres. This includes the Station itself, about 150 acre =, and a msnmade. irregular U-shaped cooling reservoir of about 5000 surface acres, known as Clinton Lake.

The topography consists mostly of slightly rolling prairie land. The Station is in Harp Township within DeWir e County. approximately seven miles east of Clinton, Illinois, at 737 feet above sea level.

The location can further be defined by placing Clinton Station in an approximate center of a triangle f ormed by Bloomington, 22 miles to the north. Decatur. 22 miles to the south, and Champaign. 30 miles to the east.

The reactor containment, the focal point for the Station. is located approximately three miles northeast of the confluence of the North Fork River and the Salt Creek. The majority of the Clinton Station is located in the eastern half of DeWitt County with the arms of its man-made cooling reservoir (Lake Clinton) extending into the northeastern area of the County.

Land use within five miles is primarily agricultural with some rural I residences. The 1980 permanent population within five miles of the Clinton Station is 998 for a population density of 13 persons per square mile. As a comparison, the density for the State of Illinois is 203 persons per square mile based on 1979 population estimates.

l Three communities with a total 1980 population of 9,313 lie between five and l ten miles from the Clinton Station. An additional 2,705 persons live in rural residences or on farmsteads for a projected total of 12,018 persons living between five and ten miles from the Clinton Station.

2. Emergency Planning Zones .

The plume exposure (10-mile) Emergency Planning Zone (EPZ) for the Clinton Station encompasses land aream in four Counties: DeWirt, McLean, Piatt and Macon. The boundary van defined following a detailed review of the l demography, topography, land characteristics, access routes and I jurisdictional boundaries in the area surrounding the power station. This 1

I ww.mauva&M caAdAJ PDR ADOCK 05000461 f f) r F PDR

review resulted in a determination that the primary basis f or the '10-mile EPZ boundary definition should be political jurisdictions, man-made featuras (e.g., highways, railrosos, canals. etc.) or strong topographical features (e.g. streams, rivers etc.) as well as Clinton Lake across the middle of the area, which could consistently serve as boundary segments.

Supportive evidence for the use of p'olitical jurisdictions to form the boundary is given by the strong bond between a given population and its political subdivision / city, rown or township of residence. Fur th e rmor e ,

political subdivision boundaries in the area of the Clinton Station have been very stable and are expect =d to maintain that stability. For this reason. political subdivision boundaries are highly appropriate when consid= ring the establishment of a stable. long-term EPZ boundary.

Another reason for the predominant use of political subdivisions in defining the 10-mile EPZ boundary is that many of the designated local response agencies (particularly fire and police departments) are structured on the basis of local political subdivisions and are established to serve these subdivisions. Designation of the 10-mile EPZ along these boundaries simplifies many aspects of offsite emergency response planning and preparation.

In cases where the local political jurisdictional boundaries were nor reasonably near the 10-mile radius to the Clinton Station, attempts were made to use man-made, or topographical featuren as a boundary basis. In such cases. highways v=re the pref =rred choice as the basis for the EP4 definition.

For dissemination of emergency instructions and information to the public, thirty Sub-Area boundaries have been identified and established based on demography. topography. lano characteristics, access routes and jurisdictional boundaries as discussed above. State and local emergency preparedness officials have participated in the development of the Clinton Station EPZ and Sub-Area boundarien.

In the event of a serious accident at the Clinton Station, the pluma exposure EPZ will be the area in which intensive efforts will be made to notify and protect resioents and transient populations from exposure to radiation. This EPZ includes the following municipalities:

Covernments within the 10-Mile Emergency Planning Zone DeWitt 1980 Miles Direction County Population From Site Trom Site 8,014 7 West Southwest Clinton West Northwest Wapella 768 7 Weldon 531 6 Southwast DeWitt Villag. 232 3 East NorthEasr Total 1980 Population 9,545 2

'NOV.22 '85 14:56 FEMA REGIOri V CHICAGO 1 P.02 l

l 1he primary land use around the Clinton Station is agricultural, with cash grain crops of corn and soybeans. The industries nearest the Station are l located in the conmunity of Clinton. Recreational facilities outside the municipalities include the Clinton Lake State Recreational Area and the Weldor Springs state Park.

Major transportation facilities in the Clinton Station EPZ are State i Hichways 54,19 and 48, all of which cross the EPZ. Railroads are the 1111ncis Central Gulf which comes within 3/4 mile north of the Station and a rail spur of Illinois Central Gulf 3.5 miles south of the station.

Governments Within the 58-Nile Beergency Planning Zone me ingestion exposure pathway planning zone consists of a circle extending fifty miles outward with the Clinton station es the center pint. The 58-mile-EPZ includes the Illinois Counties of Chanpaign,

, Christian, Coles, DeWitt, Douglas Ford, Iroquois, Livingston, Logan, NcLean, Macon, Mason, Menard, Moultrie, Platt, Sangamon, Shelby, Tazewell, Vermillion, and Woodford.

3. Spcial Dunographic Circumstances for Planning the area in the 18-mile EPZ of Clinton Station consists of slightly rolling prairie land. Drainage is toward the general vicinity of the Station into the lake / river-creek which surrounds the Station on three sides. The soil quality is desiramble for crop cultivation; mainly corn and soy beans.

Iarge farms dot the rural countryside. The only major sunicipality is the corsaurity of Clinton. It is the area's center of conseros and industry, Unique Considerations Recreational Areas l

Clinten take state Recreational Area and Weldon 8prings State Park are the recreerional facilities in the 19-mile EPZ.

Clinten take is a 4,895 acre man ende cooling lake within the Clinton i statico property lines. Recreational facilities acecronodate canping, i boatirg, hunting, fishing and hiking. Clinton Lake is unique in its natural state in that it forns a "V" pointing to the southwest. It rests in a l natural formation of ancient creek and river beds now covered by water resultant from a man-ende dam constructed to hold water for the Station's l water cooling needs. The man-ende creation has given miles and miles of shore line and vast areas of water which supports aquatic life. It provides a vast area for boaters, fisherman and water foul hunters.

i Maldor: Springs State Park enconpasses approximately 378 acres and contains a 28 acre lake with cenping, fishing and picnicking facilities.

Transportation Systems State Highways 54,18 and 48 cross the 19-mile EPZ. Othermajor thorotghfares are U.S. Highway 51 located about six miles west of the Statico. Interstate 74, although not in the 19maile EPZ, is a significant transportation route located about eleven miles northeast of the Station.

l 3

The nearent railroad is the Illinois Central Gulf Railroad (ICG) which crosses the 10-mile EPZ eamr-wear and comes within 3/4 mile of the Station to the north. Another ICC track bed is located 3.5 miles to the south of the Station.

Local Emergency Resources Within the 10-mile EPZ of the Clinton Station is one principal municipality; Clinton. An incident at the Station could very well demand the total emergency capability of the community of Clinton. Their emergency resources are suf ficient to meet the everyday emergency need of the residents, businesses and industries but the emergency resources may be limited to meet a technological emergency.such as a significant radiological accident at the Clinton Station. The State remources would supplement the local efforts to combat such an occurrence.

B. Emergency Planning Authority and Organizations The Illinois Emergency Services and Disaster Agency Act of 1975 (Ill. Rev.

Star. Ch. 27. para. 1101 er. seq.) establishes an Emergency Services and Disaster Agency and confers upon it broad authority to plan for a coordinated response by Srare and local agencies to all disasterm, whether from natural or manmade causes. The Act provides that the authority to deploy resources in response to an emergency shall be provided by an executive proclamation of a " State of Disaster Emergency."

The Illinois Nuclear Safety Preparedness Act (Ill. Rev. Stat.. Ch.111 1/2, para. 4301 et. seq.) designates the responsibility for emergency response planning for accidents ar fixed nuclear facilities to the Illinois Department of Public Health and provides for a fee to be assessed on licenmed nuclear power rescrors to fund the Illinois Nuclear Safety Preparedness Program. The Governor of Illinois, by Executive Order Number 3, dared April 1. 1980, creared the Department of Nuclear Safety (IDNS),

transferring to that uepartment the responsibilities of the Illinois Department of Public Health cefined in the Illinois Nuclear Saf ety Preparedness Program. _

C. History and Status of Planning and Preparedness

1. Plan Development The Illinois Plan for Radiological Accidents (IPRA) is contained in Volume I, the " State General Plan" (March 1982) and an accompanying book of Standard Operating Procedures (SOPS) as well as seven site specific volumes and SOPS. A reformatted version of IPRA Volume I was provided to the RAC in August of 1985 for consideration along with preliminary IPRA Volumes VII (Braidwood) and VIII (Clinton). The preliminary IPRA Volume VIII (Clinton) has been evaluated by the Region V Regional Assistance Committee (RAC).

4

NOV.'22 '85 14:56 FEt% REGION V CHICAGO 1 P.03

2. P'an Review Review ecanents of the State (Volume I) and preliminary Clinton (Voltzne VIII) IPRA were prepared by FDIA Region V with the counsel of the RAC. The conso'.idated RAC finding of the plan was sent to the Illinois ESDA on October 21, 1985. The state will address the deficiencies and respond with a schedule of corrective actions by November 29, 1985. Subsequently, they will incorporate the corrective actions into the plan (Volunes I and VIII) and formally sulznit the p1.an in its final form scenetime after the December 4, 1935 full participatica joint exercise.
3. Public Meeting It is tentatively planned to conduct a public meeting following the publishing of the exercise report. %erefore, the date for the meeting will be in March or April 1986.
4. Exercises S e initial qualifying exercise is scheduled for December 4, 1985. It is full participation for all participants; Illinois ESDA, IDNS, DeWitt County, and the applicant, Illinois Power Company.
5. Intervenor Contentions Contentions were filed with the Atomic Safety and Licensing Board which pertain to offsite emergency planning for the Clinton Nuclear Power Station. In a Special Conference, the contentions were dismissed from a hearing and will be satisfied through agreenents between the intervenors and the S:ste and Applicant.

D. Cocunentary Evidence Available for Examination

1. P'.ans and Plan Reviews.

Illinois Plan for Radiological Accidents

, State General Plan, Voltana I, February 1981 state General Plan, Volume I, March 1982 (Reformatted 1981 edition) i State General Plan, Voltane I, (Draft Reformatted) June 1985 l State General Plan, SOPS, March 1982 l Clinton Plan, Volume VIII, August 1985 (preliminary)

Clinton SOPS, August 1985 (preliminary)

Clinton Public Information Brochure, (Draft) August 1985 RAC consensus review of the above plans dated October 1,1985 and relevant correspondence.

It is necessary to understand that the preliminary Clinton plans which have been sent to FD5A Region V cre not the formal sulanission as described in 44

. CFR Part 358. Boy are for review purposes only. Further, until the l reformatted Voltaan I is formally sulznitted and accepted, the 1982 State General Plan is the plan of record.

5 i

PLAN EVALUATION SUNMARY The State General Plan (IPRA Volume I) has been formally reviewed and approved for the site-specific locations of Dresden ( FEMA-REP-5-IL-1) and LaSa11s ( FEMA-REP-5-IL-2 ) . Those approvals are based upon the IPRA Volume The 1982 I, dared February 2. 1981, which was reformatted in March 1982.

edition conder. sed the volume by printing on both sides of the pages. made monor changes'and corrections recommended by the Regional Assistance Committee ano placed the Standard Operating Procedures in a separate and o

binder. Based upon the Regional Assistance Committee review of plans In addition, exercise results, FEMA determineo the document to be adequate.

under the IPRA Volume I. March 1982, the Regional Director's Evaluations for Quad Cities ( FEMA-REP-5-IL-3) and Zion (FEMA-REP-5-IL-4) were submit ted October 25, 1983, approved March 2.1984 and published in the Federal Register March 9, 1984. The Regional Director's Evaluation for Byron (FEMA-REP-5-IL-5) was submitted June 18, 1984, approved September 13, 1984 and published in the Federal Register September 19, 1984.

A nev idition of the State General Plan (IPRA Volume 1) was submitThe tednew along with the preliminary Clinton (IPRA Volume VIII) Plans and SOPS.

version has eliminated extraneous material and has been condensed to a more useable document. It will undergo formal RAC review for to determine if it IFRA Volume I.

signifiiantly alters sny of the early RAC findings

- For the purpose of this review, the Regional Assistance Committee has provided a consensu. finding of the preliminary Clinton (IPRAThe Volume reviewVIII)

Plans and SOF6 and the Scare General Plan (IPRA Volume I).

participants included Federal Emergency Management Agency, U.S. Department of Energy. Food and Drug Administration, Public Health Services, U.S.

Nuclear' Regulatory Commission, U.S. Environmental Protection Agency, U.S.

Department of Transportation, and the U.S. Department of Agriculture.

as The following is a summarization of Clinton (IPRA Volume VIII) and, format of relevant. the State General Plan (IPRA Volume I) and follows the

" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Pcwer Plants," NUREG-0654 / FEMA-REP-1, Revision 1.

A. Assignment of Responsibility (Organization Control)

The offsite radiological emergency plan for the Clinton Nuclear Power Station assigns responsibility to State and local governments for emergency response ef forts in the emergency planning zones.

The DeWitt County government has an operational role which is explained in its concept and its relationship to the total effort. A block diagram illustrates the interrelationship of County agencies and departments.

In the case of the County, there is an individualforbythetitle24who is in charge hour per day of the emergency response and provision is made emergency response in addition to a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> communication watch through the Sherif f's radio dispatch.

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In the Clinton Plan and for DeWitt County. functions and responsibilities for major emergency response elements and key individuals by title are provided in matrix form. A narrative of each major emergency service in provided with good explanation of response involvement.

The specific codes and statures arn referenced and are reflected in the State General Plan (IPRA Volume 1). A copy of the legal authorities pertaining to DeWitt County has been requested of the State.

Missing from the plan are the necessary letters of agreement between government agencies and support organizations with emergency response roles in the EPZ.

The County and municipalities operate from a central location in DeWitt County where the key agencies and departments gather when activated for the emergency response. The facility is the Emergency Operations Center. It is capable of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operations over a protracted period. - An individual, by title, is designated who is responsible f or assuring continuity of resources.

B. Onsite Emergency Organizations Onsite emergency organization is a licensee responsbility and is to be evaluated by the NRC.

C. Emergency Response Support and Resources The necessary non-government resources to support the Federal response are discussed in the State Plan but need further development in providing more information; specifically a listing of resources to support the Federal responte.

Missing from the plan are the necessary letters of agreement which form the basis of other facilities and organizations which can be relied upon to provide assistance in an emergency.

D. Emergency Classification System DeWitt County has adopted the emtrgency classification and emergency action l

level scheme which is consistent with the Scare and the applicant.

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' Contained in the plans are procedures that provide for emergency actions which are consistent with emergency actions recommended by the applicant.

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l E. Notification Methods and Procedures The County plan establishes the procedures which describe mutually agreeable bases for notification of response organizations which are consistent with the emergency classification and action level scheme. The procedures include the verification of messages using the Nuclear Accident Reporting System (NARS) form.

Procedures are established for alerting, notifying and mobilizing emergency response personnel in the County.

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A system is in place in planning for disseminaring to the public appropriare information in initial and follow up messages which are received from the applicant. The planning includes the procedures for notifying the area emergency broadcast radio stations (WSOY AM/FM) for public announcements to advise the public on actions to take in the event of an emergency.

The County plan addresses the administrative and physical means and the time required for notifying and providing prompt instructions to the public. The RAC requested of Illinois ESDA an explanation of the notification system with specific reference to the reliability of the backup measures to assure that the necessary instructions are properly and accurately given to the public.

Written public information scripts are a part of the plan and contain important protective action recommendations.

F. Emergency Communications in planning, provisions are made for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day notification to activate the local emergency response network and the communication links to emergency response groups. Planning has been formulated for communications with contiguous State and local governments within the Emergency Planning Zones. The notification of other State and the Federal family is the responsibility of the Illinois ESDA and is in the State General Plan (IPRA Volume 1).

Communications between the Nuclear Power Station. the Emergency Operations Facility, State and local emergency operations centers and radiological monitoring teams and the communications for alerting and activating emergency personnel is provided for through the NARS, other dedicated telephone lines. radio and commercial telephone.

Coordinated communications links for fixed and mobile medical support facilities do exist and are so stated in the plan.

Provision is made for testing the entire emergency communications system on a periodic basis.

C. Public Education and Information A public information brochure is to be distributed periodically to the public. The brochure disseminates information to the public regarding howof they will be notified and what the public actions should be in the event an emergency at the Clinton Nuc1 car Power Station. Included in the draft brochure is guidance on what to do with pets and livestock.

The plan designates the points of contact and physical locations for use by the news media during an emergency. Also listed are locations for the municipalities in the 10-mile EPZ and the State News Media Cenrer.

The plan designates a spokesperson for the release of public announcements.

The RAC wishes more specificity as to the individuals, by title, in each location who serve as spokesperson=.

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plan for the exchange of information among the

  • Provision in made in the in the County and municipalities.

designated spokespersons the lowest leve.1 of government practical. Specifically, Rumor control is at implemented at the local the plan needs to explain how rumor control isto handle rumors over a State network.

level. The State makes provision the time of public press briefings and The phone numbers are made public at announcements.

l The State and applicant have provisions in planning for the conduct of press briefings annually to acquaint the news media with the emergency plans and for release of public information during an emergency.

points of contactUsually the annual briefings are held prior to the annual exercise.

H. Emergency Facility and Equipment Emergency Operations Centers are establisted in the County and in the State. Emergency operations and functions are carried out from It is these a temporary locations. There is concern over the EOC in Clinton. It has been brought facility located seven miles from the Clinton Station.for an alternate EOC outside the 10 to the attention of the Scare the need mile EPZ.

Provisions are made for the activation and staffing of the Emergency Operations Centers.

The Offsite radiological monitoring is the responsibility of the IDNS.

' assignment and function is in the Scare Plan and SOPS.

inventory and operationally checking emergency The criteria for inspection, instruments is satisfactorily addressed.

The identification of emergency kits by general category is included in the State Plan SOPS.

A central point is established for the receipt and analysis of all field monitoring data and the coordination of sample media.

I. Accident Assessment The capability and resources for field monitoring within the plume exposure EPZ are a part of the State General Plan (IPRA Volume I).

id The State Plan provides for methods, equipment and expertise to make rap assessments of the actual or potential magnitude and locations of field radiological hazards. It includes activation, notificationi means, i nt and team composition. transportation, communications, monitor ng equ pme estimated deployment times.

The Stare has the capability to detect and measure radiciodine for relating the Also established are the means Provision concentrations in the air.

various measured paramet ers and gross Detailsradioactivity are me rates and for comparison with protective action guides.

described in the procedures.

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Arrangements are made to locate and track airborne radioactive plumen using Federal and/or Scare remources.

J. Protective Response Provided for in the Scare planning, relative to the Clinton Station, is an entablished capability for implementing protective action guides and other criteria.

Contained in the Clinton plan are maps which depict the thirty subarea sectors. Contained in each subarea is the population distribution.

Refinements to the maps would enhance the presentation of the information.

An improvement would be to include EPZ boundary lines in map legends.

The transient and resident populations are to be notified by the Prompt Alert and Notification System. The plan cites the use of the emergency broadcast station, tone alert monitors, radio systems for schoole, businesses and institutions and by the outdoor sirens which have voice capability in addition to the wail siren, public information brochures, posted signs and notices in places frequented by the public.

Planning provides for the confined, in home bed-ridden and mobility impaired. Lists are held by local officials which locates those who need special arrangements. The Public Information Brochure takes the handicapped population into account.

The issue and recommendation for the intake of potassium iodide is a decision of the State Department of Health Administrator. Directives are drawn up and in the State General Plan (IPRA Vol'ume I) which clearly states the policy of the State on potassium iodide ume. Potassium iodide is pre-issued in dosimetry kits.

The Clinton plan and SOPS contain the procedures for relocating the population. Sheltering is planned and all reception / care centers are well outside the 10-mile EPZ.

Traffic capacities are not in the plan. The Clinton Evacuation Time Estimate Study which is referenced in the correlation document has been received and forwarded to the RAC for evaluation.

Control of access to evacuated areas and organization responsitility for such control is provided in 8-SOP-7, Traf fic and Access Control Guide. The accuracy of instructions for each point should be checked. .

The responsibility for dealing with impediments is assigned to the County's Highway Superintendent.

The choice of recommended protective actions is the responsibility of the IDNS and in contained in the State Plan SOPS. The IDNS has proven adequate plati:ag and capability in the methods and recommendations for protecting the r.sblic from consumption of contaminated food-stuf f s.

The Red Cross Chapters have the responsibility for registering and the IDNS is responsible for monitoring the evacuees. Procedures for monitoring can be found in the State Plan SOPS.

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K. Radiological Exposure Control It is the responsibility of the IDNS to make provision for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capability to cere:mine radiation domen received by emergency personnel and it is provided for in State planning.

The plann cover the distribution of dosimetry, reading frequencies and the maintaining of racords and the control point for record data deposit.

Planning establishes a decision chain for exposure of emergency workers to radiation in excess of EPA Public Protective Action Guiden.

IDNS has established and published action levels for decontamination. They provide monitoring support and technical assistance to local officials for the decontamination of equipment and personnel.

L. Medi. cal and Public Health Support The Clinton plan and the State plan address the arrangements for local and backup hospitals and medical services. It would enhance planning if a discussion was included in local planning in modition to the listing provioed. Letterm of undereranding with the hospitals ano medical services -

are required to complete the planning process.

The plan liars the location of hospirale. cype of facility. capacity and special radiological capabilities for providing medical support for contaminated injured individusls.

The plan does not make clear the local arrangement for transporting contaminated and/or injured individuals.

M. Recovery and Reentry Planning and Post-Accident Operations The SOPS to the Clinton Plan adequarely address the procedures fo: recovery and reentry into the evacuated ares.

The State plan specifien: means for informing the response organizations char a recovary operation is to be initiated; changes in the j organizational structure; ano, in addition, specifies the means for periodically estimating total pop 11ation exposure.

N. Exercises and Drills The State is the responsible organization for conducting drills and exercises under guidance ser forth by NRC and TEMA and is ao stared in the plan. Exercises are to provide for mobilizing resources and personnel at the State and local levels and the exercise is to follow objectives and a scenario which is common to the applicant. Exercises are to be critiqued by the State and evaluated by FEMA and the RAC. There is provision is for the variance of exercise times. seasons and conditions.

Communications drills and rears are periodically conducted as a matter of routine in daily business. There is no provision within the plan for medical emergency d: ills.

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The IDNS conducts radiological monitoring and health physics drills for

' their own department personnel and for emergency responders and officials in the local units of government. .

Exercise planning and the conduct of exercises is in accordance with Federal guidance. Following Federally observed exercises, the evaluation is critiqued in a joint State-local-utility public meeting as the Federal criteria specifies.

As a result of the evaluation, a report is provided the State. The State has provisions for acting on recommendations for corrective actions resulting from exercising.

O. Radiological Em'ergency Response Training The State General Plan (IPRA Volume I) provides for the conduct of training to any group or jurisdiction on an annual basis and training is available upon request at any time. But the plan does not address emergency training for those emergency government organizstions where mutual aid agreements are an integral part of the planning (Macon. NcLean and Piart Counties).

The Clinton Plan (IPRA Volume VIII) and the State General Plan (IPRA Volume I) establish a training program for instructing and qualifying personnel who will implement radiological emergency response. The training includes and is not limited to annual retraining.

l P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans The plans, in their training program, make provision for the training of '

those individuals who develop general and site-specific plans. Individuals by title are designated with responsibility for the development. and updating of emergency plans and coordination of the plans with other response organizations. The updating of local plans is the responsibility of the

County emergency direct.or.

The annual certification procedure is stated in the State General Plan (IPRA Volume I).

The approval process of changes in the plan and the forwarding of the changes are not adequately addressed in the local plan nor referenced to the State plan but it is accounted for in the State plan.

The State plan contains a listing of supporting plans and their source. And the plan has a correlation document (appendix) listing the procedures required to implement the plan. The plan also contains a table of contents. The correlation document cross-references the planning items to l

the criteria.

J Special consideration is given to the State of Illinois for this criteria element in that the State currently has five operating nuclear power c

stations within its boundaries and ultimately there will be seven. It poses an unusual and demanding hardship on the State to update telephone numbers quarterly. As discussed with the Illinois ESDA in past evaluations it is agreed an annual update is necessary to the Federal holders of the plan.

However, it is understood and agreed to that at the State and local levels, all telephone listings will be kept current as they change.

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  • l COFCLUSION The foregoing is the status based on RAC consensus review of the preliminary offsite planning for the Clinton Nuclear Power Station. It is t.he conclusion of FEMA Region V that the preliminary Clinton Plan (IPRA Volume VIII) is currently inadequate. The Illinois ESDA must correct the noteo deficiencies in the detailed RAC consensus review. The State of Illinois will submit a schedule of corrective actions by November 20. 1985 for RAC review.

The planning deficiencies could adversely af fect public health and safety and must be corrected in order to provide reasonable assurance that the plan can be implemented. Also, important support documents are missing which are vital to the plan as a functional document. Specifically, planning deficiencies exist in the areas of Assignment of Responsibility, Emergency Response Support and Resources, Public Education and Information, Protective Response, Medical and Public Health Support, Exercises and Drills and Radiological Emergency Response Training. Thes= deficiencies and several recommendations from the RAC to enhance or clarify planning will be addressed by the schedule of corrective actions.

However, it is FEMA Region V's judgment thsr serious planning effort has been put forth to date and it is anticipereo the final version of the Clinton Plan (IPRA Volume VIII) will be an adequate plan from which to conduct emergency radiological responses. Further, the State and local governments will demonstrate implementation of their planning (preliminary Clinton Plan and schedule of corrective actions) during the December 4, 1985 full participati.1 exe:cise. Evaluation of this exercise as well as analysis of the schedule of corrective actions will allow a reassessment of the adequacy of offsite planning over the next few months.

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