ML20054F960

Forwards Tn Ofc of Civil Defense & Emergency Preparedness Evaluation of 800616-17 Offsite Emergency Preparedness Exercise W/Fema Observations.Fema to State Noting Deficiencies of 810707-08 Exercise Also Encl

ML20054F960
Person / Time
Site:	Sequoyah
Issue date:	06/02/1982
From:	Krimm R Federal Emergency Management Agency
To:	Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8206180275
Download: ML20054F960 (75)

Text

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y JU % Federal Emergency Management Agency

/h Washington, D.C. 20472 60' NY

?59 Y JUN 2 1982 MEMORANDUM FOR: Brian Grimes Director Division of Emergency Preparedness U.S. N clear Re ulatory Commission

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FROM: ci r . r ii Assistant Associate Director Of fice of Natural and Technological Hazards

SUBJECT:

Sequoyah Nuclear Power Plant Exercise Evaluation of Offsite Emergency Preparedness for the June 16-17, 1980 Exercise Attached herewith ( Attachment 1) is a report prepared by the Tennessee Office of Civil Defense and Emergency Preparedness regarding the June 16-17, 1980, exercise at the Sequoyah Nuclear Power Plant. This report dated August 1, - 1980, ' includes the observations of the FEMA Regional staff and the Radiological Assistance Committee (RAC) members. The State's schedule for deficiency corrections is also included. This material was included in the " Formal 350 Submission" resulting in FEMA's approval of the Plan on August 7, 1980.

Although the utility did not participate, an exercise of the offsite preparedness was held at the Sequoyah Plant on July 7-8, 1981. A letter describing the deficiencies from the RAC Chairman to the Director of the Tennessee Emergency Agency dated July 24,1981 ( Attachment 2) is furnished for your information.

Also, another exercise is scheduled for July 1982.

If you have any questions on this matter please contact Mr. Verron Adler, Chief, Technological Hazards Division, at 287-0200.

Attachments 1

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8206180275 820602 PDR ADOCK 05000327 F p9g ff i

( lf MILITARY DEPARTMENT OF TENNESSEE OFFICE OF CIVIL DEFENCE AND EMERGENCY PREPAREDNESS EMERGENCY OPERATIONS CENTER 3041 SiDCO DRIVE NASHVILLE 37204 PHONE (615) 1415181 01 August 1980 Mr. Frank Newton Regional Director Federal Emergency Management Agency Region IV 1373 Peachtree Street NE Atlanta, Georgia 30309

Dear Mr. Newton:

We in the State of Tennessee have reviewed the findings of the RAC and the ooservations which they have made on the Sequoyah Exercise which we conducted with TVA on June 16-17, 1980. In addition to the RAC observations (Inclosure No. 1) we have reviewed the comments of the State ooservers and the observations made by participants in the exercise.

Observations of the exercise from all sources have been analyzed and specific action taken to correct deficiencies. The Exercise Report (Inclosure No. 2) contains background information on the exercise, a Scenario Abstract, Objectives, Summary of Observer Procedures, a list of participating agencies, the Critique Agenda, a listing of comment sources and twenty-six (26) specific findings. Each finding includes brief discussion of the problem and a recommendation for resolving the deficiency. Responsibility and a completion date have been assigned to each one, and we will follow up on these until they have been re3olved. (Inclosure No. 3)

The deficiency in the Tennessee procedures for utilization of Radiological Monitoring Teams which was identified by Mr. Ed Williams and others has been given special attention. We have concluded that an additional Appendix to Annex F of the Plan is necessary to establish and  ;

maintain direction and control of these teams. I have attached a draf t copy of the Radiological Monitoring Team Utilization Appendix for your information. (Inclosure No. W This outlilnes the procedures which we will use in any future exercise or emergency.

@TCPicRh6%T I

Mr. Frank Newton Page 2 01 August 1980 Let me assure you that we will follow up on all deficiencies which the RAC and we identified in the Exercise. I will keep you advised of progress in their resolution.

Sincerely, t ne P. Tanner te Director

/ luc Inclosures (4)

RAC Observations Exercise Report Completion Date and responsibility Draf t of Radiological Monitoring Team Utilization Appendix

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. ,; y G FEDERAL EMERGENCY MANAGEMENT AGENCY f ,

f[g Region IV 1375 Peachtree Street, NE Atlanta, Georgia 30309 ( /

JUN 2 51990 M r. Eugene P. Tanner Dtrector of Civil Defense Milita ry Depa rtment of Tennessee Tennessee Emergency Operations Center Sidco Drive Na shville, Tennessee 37204

Dear hir. Tanne r:

I have enclosed obse rve r and pa rticipant reports on the State /Sequoyah exe rcise conducted June 16-17, 1980.

It is my understanding State and local participants and observers did an excellent job of c ritiquing the exercise and have, in fact, identified most of the problem areas discussed in our reports. While I am aware you have made a number of corrections in your Plan as a result of the exercise c ritique, I must ask special attention be given to critique items which specifically address off-site radiological monitoring team procedures and ca pability. We must assure ourselves, prior to submitting the Plan to FEMA National for review, these problem areas are resolved.

Your State has done much in a short period of time to accomplish what you have on the REP Plan. I compliment you for the excellent effort and assure you that RAC IV membe rs and FEh1A IV staff look forward to supporting future REP activities in your State.

Sincerely yours, Ha r ris hl. Pope cl+44 f l C hai rma n, RAC IV E nclo s u re

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. i FEDERAL EMERGENCY MANAGEMENT AGENCY

[ Hegion IV 1375 Peachtree Street, NE Atlanta, Georgia 30309 JUN 2.519b0 MEh10RANDUhi FOR: Ha r ris bl. Pope Directo r Plans and Preparedness Division d.--

cA3.

Jack Dichardson. 13 .1 .

FROM:

Plans and Prepa redness Division l SU BJECT: Tennessee REP Exercise (Sequoyah)

I have attached copies of subject exercise observer and participant reports fo r you r review. In my opinion these should be forwarded to the State as

w ritte n.

The State and local exercise participants did an excellent job o c ritiquing themselves and , in fact, pinpointed the items discussed in our reports.

.i In an effort to avoid repetition, I have only three areas to recommend for

, plans improvement:

(1) State should plan to notify FEhiA Region of situation when " Alert" eme rgency clas sification is reached.

(2) Adjacent state notifications should be handled by FEhiA Region

! rathe r than State.

1 (3) State should reconsider and better define the functions and responsibilities of the State Command Center (forward) located '

in Chattanooga.

Exe rcise Obse rve r and Pa rticipant As signments we re as follows:

Obse rve rs TVA CECC Dick Van Neil l State EOC (Nashville) Jack Richardson l State CC (Chattanooga) Ray Boyett Bob Trojanowski i Hamilton Co. EOC Ve rnon Darley Frank Vogel B radley Co. EOC Don Hammonds State Rad Health ( Atobile Team) Ed Williams 2

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. 2 Pa rticipants S ta te EOC (Nahsville) Bob Gantt State CC (Chattanooga) Martin Bevans A tta c h me nt -

, FEDERAL EMERZENCY MANAGEMENT AGENCY Pleic and Prgperedn=2 of fica Radiological Test Pacility

, Bldg. 22, Washington Navy Yard Washington, D.C. 20374 Jinie 20, 1980 1'

MF.MORANDUM FOR: Frank Vogel, Director, Skl. Operational Systems Division

[ FROMt dward F. Williams Jr. Chief, Radiological Test Facility i'

SUBJECT:

Consnents on the Sequoyah Nuclear Plant Exercise I served as an observer at the State Command Center ih chattanooga, Tennessee on June 16, 1980. I also travaled with one of two radio-logical monitoring teams deployed from Nashville to Chattanooga after

they arrived on the scene. During- this observation the following defi-

! ciencies were noted in the Tennessee response and in particular in the radiological monitortug prograin-t l 1. Were appeared to be no plan by the Tennessee Departiment I

of Radiological Health (TDRH) personnel for inobile inonitoring and deployment of the teams appeared to be without purpose.

[ The tearn with which I traveled was only assigned to unke the i mameuremento during the entire deployment of 9 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

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2. Consatmications were grossly inadequate in that tiv TDRH

- Director of the radiological inonitoring was not in' direct

[ contact by radio with his teams and had to relay his in g

structions through a conusunicator who was not familiar g with the radiological jargon or technical terus..

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3. There was no direct cotanunication between the TDRH radio-

, logical monitoring prograta and the radiolo'gical nonitoring

,d program of the TVA at the State Conraand Center in Chattanooga.

j Theue two elements appeared to be oporating independently of each other.

4. The map system and the technique used for deploying 3RH nonitoring teams to a particular location was inadequate.

Preplanned monitoring poluts should be employed. This deficiency caused the tems which I observed to be lost on a number of occasions.

5. 'lh e total number of moultoring teams deployed for this appil-cation (two) is not adequate and the deployment time f or the

} State tearna w,en too long s 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

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6. The team did not report monitoring information back to the Con =nand Center. However. Mr. West of TDRH says that he instructed the teams not to report monitoring data during the exercise.

7. The air sample instrumentation essential for this kind of monitoring appears to be quite limited requiring the use of an AC generator. It is recotanended that air movers that can be operated directly off the automobile electrical system be procured.

8. 'Ihe tearn turned in their ID badges to the State Command r

/ Center when they deployed to Command Post West and there-i fore had no means of identification. Once identification y is issued to esmergency personnel it should be carried by thers throughout the exercise or accident.

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9. Communications to State Command Center in Chattacooga were

[ extremely poor. Their knowledge of what was happening in

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the field and at the site vere limited and of ten ran from 30 minutna to i 1/2 hours behind the time of the actual events.

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10. The TDRH monitoring team did not use good monitoring or nessuring techniqaes. Most of the measurements were made inside the vehicle which is not acceptable. However, Mr..

West stated that he had not asked the teams to take and transmit readings or to actually go through their nonitoring procedures. This was done because he felt that they were well versed of what they would be required to do, f

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Stuma.ry of Observat.lons at SCC and Hamilton County EOC - June 16, 1980 - Frank Vogel e Most of the comments I would have submitted were covered by others in the critiques. Therefore, only a few points which I feel needed repetition.

e For a no-notice exercise there were alot. of people on station prior to the start.

. Tim scenario adequately exercised the plans of the participants.

i e The SCC was behind the scenario some 1 1/2 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in the middle of  !'

ttm morning. State must either develop procedures to keep the SCC up to l g , date or decide whether SCC is needed in the early period of an incident uiuce control is exercised from Nashville.

e Mad llesith must develop procedures for c. loser liaison with TVA monitor-  :

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l ing activities.

l e The llamilton County EOC was very adequately manned by local goveneent I

agencies and voluntary agencies operated efficiently and procedures appeared to be adequate.  ;

i e Voice communications need to be reviewed and reports more closely t i monitored for correctness; for example, at 1523 the following message '

was circulated in the Itamilton County EOC: Puff released 1200 Rims at '

6 1 mile and 37 Rime at 10 miles. " This message was not questioned, yet  !-

/( it luid to be incorrect for two reasons; there la no such thing as Rim nnd 1200 Rems at 1 mile p1ve 37 Rems at 10 miles would be a major event, t e NOAA Westher Radio and EBS were ef fectively used.

i e The 1.ovell Field 111ght pattern places aircraf t in potential danger ,

t f rom a release at the Sequoyah Plaut. Hmn11 ton County kept. the FAA .

( infonned concerning exercise releases. This is an action which could im overlooked and should be atreuned in all local plans.

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l Sununary of Observations Energency Operations Facility (EOP) of IVA l at Chestnut Tower, Chattanooga, Tennessee,. June 16, 1980 - C. R. Van Niel i,

1. TVA personnel performed in a professional saanner

2. Tlwre was soine delay and difficulty with the dissemination of information within the EOF.

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3. EOF is on Eastern time while all of the TVA plants, including Sequoyah, ,

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are on Central time. Some confusion might. result.  !

4. NOAA Weather Radio alert reported status of exercise at.1100 and 1550 hours0.0179 days <br />0.431 hours <br />0.00256 weeks <br />5.89775e-4 months <br />. Good use of system.

5. Sir.e and General Einergencies confused because of different numberlag T systets (IP-4 & IP-5) for Division of Nuclear Power (DNP) and Sequoyah procedures. ,

6. Some confusion on part of EOF personnel as to when to terminste exarcise on Monday af ternoon.

7. Some question if EOF received last acenario messata (change of wind to 030*).

8. Status board not ut111 ed effectively.

9. Good telephone consnunications system with ring down capability to States, counties and reactor plants.

10. There may be some delay in coordinating plant. data with Escle Shoals g/$ and Nashville.

NOTE: Copy of log being sent separately.

. .@ T FEDERAL EMERGENCY MANAGEMENT AGENCY U N Region IV 1375 Peachtree Street, NE Atlanta, Georgia 30309 tw; June 24, 1980 MEMORANI>UM FOR: DIRECTOR, PLANS AND PREPAREDNESS DIVlSION FROM: Rayford H. Boyett, Health Physicist .

SU3 JECT: Tennessee REP Exercise (Sequoyah) the Tennessee Sequoyah exercise held on June 16-17 was applauded as a success-ful exercise by local State and Federal observers. The Regional Health Phy-sicist observed the exercise f rom the State forward command center at Lovell Field in Chattanooga, Tennessee.

It is the opinion of this observer that the State and local officials have exercised the major parts of the Tennessee REP plan (i.e., Warning, Protective Response, Communications, Piblic Information, Notification, Accident Assessment, Radiological Exposure Control, and Medical Support). Due to time constraints, recovery and reentry was not exercised.

rwo minor cri ticisms were observed from the forward command center:

L. The lag of inf ormation flowing to the decision makers at Lovell Field, and

2. Slowness of response of State agency personnel to the facility.

i These are classified as minor by this observer because they, in fact, may be entirely real in an actual emergency.

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(i' i;. FEDERAL EMERGENCY MANAGEMENT AGENCY y ji Remon IV 1375 Peachtree Street, NE Atlanta, Georgia 30309 June 20, 1980 At24uvANDUA FOR: . ACK D[PI )[ARDSON FRud:

l 't.lL.<. J e % c.-

Martin .~Bevans Robert'J. Gantt

SUBJECT:

Sequoyah Nuclear Power plant Exercise Based upon our participation in the Sequoyah Nuclear Power Plant exercise at the Emergency Control Center (ECC) in Chattanooga, and in the State EOC in Nashville on the 16 and 17 of June 1980, the following recommendations are provided.

1. An initial briefing should be conducted by the responsible individual jg outlining how the situation developed. Thereaf ter periodic updates should be given indicating whether the situation is improving or deteriorating at the plant.

2. One of the functions of the FEMA position in the ECC in a real emergency would be to prepare periodic SITREPS to be forwarded through the State EOC in Nashville to the National Office. The information that was available l(' was not current. In discussing this with my counterpart at the State EOC he had most information well in advance of the time we received it in Chattanooga. If the ECC is to be of value in an emergency then some system has to be devised to obtain current information for more timely decisions.

3. The configuration of the ECC was not set up properly for an efficient f1 operation. Better separation of elements would be needed in an actual operation.

4. The display systen in the State EOC needs revision to provide a better i visual description of the developing emergency situation. Maps were the iI only displays used and could not adequately present all information in a clear manner that could be seen by all participant s.

5. The tripartite system worked very well but they were too involved with operations in the State EOC. A location away from the operations tables

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should be selected for their use which provides some degree of privacy.

6. The FEMA representative needs a position from which to operate in the State EOC that includes access to the FTS system.

7. The front table arrangement in the State EOC needs some thought. A better info rma tion display system would have reduced this problem by allowing participants to keep up without moving to the front af the room.

e 01151.R_yl R. W. _O.R_K_ S.ill i I-lor a State and Local exercise in ~tonjunction with SEOUOYAll NUCLEAR PLANT on 16-17 June 1980 TeaniIeader is _%c#,[j4Myhe g(~MM (Please do not divulge the !xercise'date, since a number of participants wish to be uninformed on this point in the interest of realism).

POSI I AERLISE EVALUAT10ft SESS10ft WILL BE IIELD on 6-17-80; 1:30 p.m. ~ at Lovell Field, Tennessee (Date/ Time) } Location)

1. OBSERVLR DA1A:

a. flame VERNON 0. DARLEY L. Organization U.S. DOT /FAA

,, L. Iitle Regional Emergency Transportation Representative

d. Business Address P. O. Box 20636 246-7595 FTS Atlanta, Georgia 30320 Phone: 404 763-7595 (Comm.)

.' GLt1LRAt AS5 t h!.Mf i4 T . You are requested to participate as a Federal Observer in the above listed exercise and attend the Post Exercise Evaluation.

I'lcase he present at z Chattanooga

(.Loca

, _ llamilton_ Coun ty, EOC tiori)

FOR DUTY.

t> y 0800 g - - -

o' clock, on --June 16, 1980 ~4 W6-f M-ne--

(datel

{ 3. SPEClf lC .bblGriMErlT. (lo be completed by Team Leader)

Your 3pecifit locatiori/ area of interest during the exercise will te See above. .

6 tarn these original work sheet s (or . .>at'able copy) direct ly to H. W. Gaut -

X RC not I .i t e r than _ , , , _, f o r c omp t l a t f ort irito a f inal report. (Please

.c i te in complete s ta tements s ince, 'n the interest of procipt response, Od. ting of 3ectioris b and t> will be allPO:.t riori-ex i s tarit. )

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.e. ar. otnerver fou should t>e prepared to-

a. Observe the operational response activities of the Organization /

Area to whit.h you are assigned and record your observations and evaluat ioris and reconstiendations on the attached fanns during or inanediately af ter the Exercise.

h. I' rov i.h a (opy of the coinpleted sections 4, 5 and 6 to the State l xerc ise Coordiriator (or his designee) af ter the Exercise (if requested).

c. Report orally on Exercise activities during the Critique if called upon to do so.

Attached - Section 4 - Factual observation sheets Section 5 - Evaluation sheets Sec t ion 6 - General conunen t sheets

- s - Ob',e rv e r V.'O. 1)A HLEY 1)a l e

.19 .80 1 .E 10/it bipi fi,'il I UJh . To the extent i eas ible, r et.oi ct yr,or observa t iorr.

on he i o i l o.v i rol ',ub j et f a rea', i n i he .pui e , provided. Plea *.e br> a.

u,nci e t e , ite8 a iled arnt objective as pouible. (l'rel uc.e a l l toninerit *.

with an ette tive L inie i t relevant).

a Wa rn i n<j . (Indica te Liines received arid disserraissa ted, f roni whons, warning means , warning f ortnat , etc. )

Notice of unusual event received by te lecon f rom stat e EOC at 0826.

b. I meppry,q J:onaaun ica t ions ., (!nd it a te. methods of ( ornnion ica : i ori ,,

et in t iveness of equi [xnent, control measnres cr.iployed, ete . )

Telephone and radio--both effective.

Ob.orvir V. O. ,

DARLEY D.i t e. 6-19-80 , _ ,

. [ mergent / Ndical Actions. (What occurred and when; how hendled and by wnom; hospitals, ambulances and medical personne! i nvo l veel ,

etc.)

Well directed from the EOC by a Dr. Clark, local orthopedic surgeon serving as a volunteer. He and a volunteer assistant did an outstanding job in that they kept on top of the situation by maintaining a running account of available hospital beds and other medical services. Incidentally, during the simulation of responding to an emergency call there occurred an actual emergency in which medical services people actually picked up a heart attack victim who was DOA at hospital.

/ d. Public Informa tion. (Indicate what public information was disseminated, when, bTy wha t means, by whom, on whose authority, etc. )

Excellent cooperation from the press. County CD Director used them effectively to keep public informed. Local emergency b roadcast stations carried the simulated emergency six or eight times t h ro ughou t the day.

Obsert4e r V. O. DARLEY b -

Dale 6-19-80 e l e'c hn i ca l Ay lv i te. (linlicate wha t tec hn ica l adv ice , when , tiy wittie:i, to whom, means of tormunicat ion, etc. )

Not obse rved .

f. Team Response. (Indicate what Team; how organized; when notified- ,

when ecsuonded; how transported; equipment; conmunications; att ion >

ufo ~n~ io t i f i ca t i on , en rout e , a t s i te , etc . )

All ennty teams were being competently directed from the county EOC: eithe r employees from the respective response organizations or vo,.un:eers with skills in those areas were present to effeet coord'xat ion of each required ef fort or response.

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Ob,orver N Date 6-19-80

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• l. ACliort . its I hl'ed terled Ar ea'. .

(1) Road blocking ar tivities. (Indicate when, where, cri what advice, by whorn, how s intula ted , etc. )

Not obse rved di rect ly but it was apparent from telephone reports f rom the " field" that roadblocks were established at the proper places on a timely basis.

.s (2) Ivotection Actions. (Indica te when, what, wher e, ori wha t aifv~ ice 7Ty~Motii, how s iniul a t'ed , ett. )

Not observed directly but it was apparent f rom cont rol room status reports that all protective actions were taken on a timely basis--including simulated evacuation.

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Udte 6-19-80

, .; . Ai.tions (tontinued)

(3) Reception Ccnters. (Indicate when, where, by whom Tor 9aniiation), procedures employed, how simulated, etc.)

Not observed directly but it was apparent that all county centers designated in the plan were established in a timely manner.

(4) O tjier. (Area Control, protective actions other thari evacuaLior,etc.)

Apparently adequate.

[Jate 6-19-80

h. Coordiriation of Support Effort. (Who coordinated what or.livitie',,

how,whpo,etc.7 Very effective. Coordination was ef fected by E0C director, his staf f, assigned departmental representatives and volunteers.

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i. Other actions.

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. Obst r ver V. O. D.AR. .L. E_Y

, lle l e 6-19-80 9_

IVill U Al LOT 3. isu ording to your fifts t judr)iierif , pled .e prov1<!* o .unno.ir i /ed au oun'. arnt ova lua t tori of Lfie rs",ponse activil.ies observed:

a. Sunana ry . ( ,untinarite the respotise isc tions noted ill orie or- two p.)ragraph . . )

All required or appropriate actions were taken. No further elaboration is needed.

b. -

' em e to Plan. (Did the orgariizatiori observed adhere to

'>'? If not, in what respect? Should the plan be s s .l * '

u> 3dhered to the plan. An excellent job.

Observer V. O. DARLEY Date .. 5 . l.9 .8_0 , , , , , _ ,

c. Maior St ry,niths arid Weaknesses. Bearing iii mind the i ritended participation of the organization, what wei e the triajor '.treriijttis arul weaknesses noted?

(1) Major Strengths.

(a) Professionally directed.

(b) Adhered to the plan.

(c) Excellent cooperation on the part of all participants, s

( .' ) Major Weaknesses.

(a) None noted in the county.

(b) Positive and timely direction from the state Control Center at Lovell Field was not apparent in the county EOC.

. Gh',er vr:r V. p. DARLEY lla l" 6-19-80 , .

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d. Sujy,,t eel (peryc,t i ve, Meayo,res . The f ollowing incans for itaprov e ri j t re or gan iza t ion's resporise capabil i t ies . ire sugge .t.ed.

No specific recommendations.

e. Lxerc se Objectives. (Indicate degree of accomplishinent of Lxercist Obj ec' 4ves).

I th in'< that all objectives were met at the county level.

Otr,e rif e r V.O. DARLEY Ud I .,6.l.9-40, ._

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t or ::..f n t 2 Overall, I would ,,rade the exercise play at the county level as very ef fect ive. In my opinion, all objectives were met at the county level.

However, I got the d is t in c t impression that some of t he part icipants had advance knowledge of the scenario--especially the timing.

VERNON 0. DARLE7 Regional Emergency Transportation Representativ.

DOT Region IV

Ey hd FEDERAL EMERGENCY MANAGEMENT AGENCY Region IV 1375 Peachtree Street, NE At!anta, Georgia 30309 Kw.)

June 25, 1980 MEMORANDUM FOR: Di r ec to r, Plans & repa rednes s Division L- 4 Donough' C.dHa mmond s l FROM:

Plans and Preparedness Division SU BJ EC T: b radley Co. , Tennessee, Sequoyah Exercise Report ACC OM PLISHME NTS The county response was complete and timely. All key city and county o rganizations and voluntee r se rvice g roups we re represented in the Emergency Ope rations Cente r (EOC). These representatives had evidently been thoroughly briefed on their eme rgency roles and responsibilities and performed enthusiastically and effectively. The Mayor of Cleveland was present in the EOC th roughout the exe rcise. The County Judge was present during the crucial s ta ge 3 All res ponse organizat+ ors we re; activated to the degree necessa ry to dete rmine that a viable capability exists. 'Two of the planned five evacuee cente rs we re activated and staffed by red c ross, public health, civil preparedness and school boa rd pe rsonnel. Eme rgency Medical Se rvices (EMS) ambulances we re coordinated by the ae vice supervisor and were positioned at forward duty lo ca tio n s . Bus runs we re actually conducted to simulate evacuation of persons who have no private means of transportation. Monitoring instruments were distributed to eme rgent.y worke rs. Polic e , she riffs and fire units pa rticipated by deploying and sub-sector command posts we re established.

B radley County ts obviously capable of initiating and controlling an evacuation on rela tively sho rt notice.

SiiO R TC OMINGS K1 is to be pre-dist rtbut.ed to all families within the 10 mile EPZ with instructions jQ to b ring the d rug with thero when they evacuate. It is obvious that in the haste

' and anxiety of an evacua non many families will fail to do this. The re a re no p rovisions tu r coping wt* 'hi s s ituation.

Evacuee shelte rs a re '

t ' inked by amateur radt- ope rato rs. This system wa s not exe rcised. C- c.v ne rgency management officials should examine

- alte rnatives in the es- f stem cannot be actisated during an actual eme rgenc y. County o- ' - shoula also investlyare phone company "line load cont rol" p rovisions to ' ne whethe r they wouM benefit emergency com-niu ni c a tio n3.

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2 The county evacuation plan makes the director of each participating organization responsible for maintaining radiation exposure records for their wo rke rs. During the exercise, however, the county RADEF office r explained I0 that he would maintain all exposure records. This conflict should be re-conciled, it is recommended that the planned procedure be adhered to.

There is no provision for handling contaminated evacuees except segregation within the evacuee centers. Neither are there provisions for decontaminating hfWp enie rgency. wo r ke rs and vehicles. The county is relying upon State personnet and othe r resources to cope with contamination. In at least one evacuee center (Oak Grove School) there are no showe rs. It is unrealistic to expect the State to unde rtake all decontamination. Local resources must be employed, possibly unde r state guidance / supe rvision.

The county EOC is not well suited to support emergency operations. The a rea (pa rking ga rage unde r courthouse) is poorly ventilated and small. This is E, pa rticula rly true of the communications equipment a rea. Arrangement of g

tables and chairs does not leave wall space available for good information dis pla y. During the exercise there was little information display and no easily visible posting of wind directions on operations maps.

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• Meo Department of Energy Oak Ridge Operations RO. Box E Oak Ridge. Tennessee 37830 JUN 2 0,1980 E. P. Tanner, Director Division of Civil Defense and Emergency Preparedness State of Tennessee 3041 Sidco Drive Nashville, TN 37201 DOE COMMENTS ON JUNE 16-17, 1980 SEQUOYAH EXERCISE The June 16-17 Sequoyah Nuclear Plant emergency exercise required

r. '-tively little actual and/or simulated response by Interagency R .togical Assistance Pla n , IRAP, signatories. Emphasis appeared to ue heavily weighted toward evacuation decisions and related actions. We were pleased to hear the positive comments during the June 17 critique held in the SCC at Lovell Field relative to the successful demonstration of this highly important activity. On the other hand, we were disappointed with the communications problems that once again a ro se and the lack of a clear understanding as to the role of the 3CC .

Focusing more directly on IRAP concerns, three needs ver.: pa rticu-larly evident . e first need is space. During an actual emer-gency, we cat ? s si'.y envision directing the monitoring activities of four mobile .a baratories, one field laboratory,10-20 monitoring teams , and aor.J. s'2 rveilla nce . Sufficient space must be provided for this effo~.

The second need ,

for a clearly defined goal and local (SCC)

State direction % these monitoring activities. Additional preplann-ing would reduce -N associated uncertainties evident during this e xe rcis e .

L' he third need 's cr direct communication between counterparts.

l i This point was a dd .>3 sed a t the critique by Bill Graham. ) With the various operar ng centers, this could be a formidable problem; j 5

E. P. Tanner JUN 2 O W -

however, good decision making demands an interchange of data and insights. The ability to accomplish this goal. may rest ~ with

, the particip. ants rather than with the system; nevertheless, the j- plan shouldireflect the desirability of this type .of communication and, where possible, f acilities should be oriented toward ' this goal.

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c fb H. W. Hibbitts Health Physicist MS-33t. ."' Environmental Protection Branch CC:

Bill Graham, TN/ Rad. Health V . J . D ' Amico , MS-30 W. H. Travis, MS-33 W. L. Smalley, MS-30

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MILITARY DEPARTMENT OF TENNESSEE OFFICE OF civil DEFENSE AND EMERGENCY PREPAREDNESS EMERGENCY OPERATIONS CENTER 3041 SIDCO DRIVE NAsHvlLLE 37204 PHONE (615) 741-5181 07 July l'330 Major oeneral Carl D. Wallace The Adjutant General Military Department of Tennessee Sidco Drtve, National uuard Arrnory Nashvtlle, Tennessee 37204

Dear General Wallace:

Attached hereto is the Exercise Report for the Tennessee Multi-Jurisdictional 1(adiological Emergency Response Plan for the Sequoyah Nuclear Power Facility.

The exercise was conducted successfully on June 16-17, 1980. Minor changes have been made to the plan, and it has been forwarded to FEMA by Region IV with their reconunendation that it be accepted.

I have designated Gilbert Smith as the individual in civil defense to follow-up on actions which are necessary as a result of the observer and participant comments on the Exercise.

We have a line working relationship with the utility operator - TVA, and I am contident that if an einergency artses, Tennessee will handle it expeitly to protect all of the citizens.

Sir erely, I- ; GENE P. TANNElt tate Director

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SEQUOYAll NUCLEAR POWER FACILITY EXERCISE

, 16-17 JUNE 1980 REPORT PREPARED BY DIVISION OF CIVIL DEFENSE AND EMERGENCY PREPAREDNESS

I BACKGROUND The Tennessee Multi-Jurisdictional Radiological Ernergency Response

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Plan which was tested by this Exercise was written during the past three (3) months. .When new criteria were published in NUREG 0654/ FEM A-REP-1, the plan which was tested by Tennessee /TVA' last October (October 1979) was no longer adequate. Approval and exercising of the plan -was required prior to TVA receiving an Operating License from NRC for the Sequoyah Facility.

Although this was the first Exercise of the Tennessee Plan for Sequoyah under the criteria specified in NUREG 0654/ FEMA-REP-1, three (3) previous test exercises had been conducted involving.the Sequoyah Facility. They were on March 30,1977, July 6,1973, and October 23-29, 1979.

Planning sessions between the State and TVA of ficials were held to prepare the Scenario and the plan for conducting the Sequoyah "30" Exercise.

The details of the Scenario and Exercise were discussed on May 6, in Chattanooga and May 15, at Watts Bar. On June 6 in Nashville, the Exercise Plan was finalized. An observer's briefing was conducted in Chattanooga on June 10, 1930. Observers from the Tennessee Valley Authority, State Civil Defense, Federal Emergency Management Agency, and Nuclear Regulatory Commission attended the briefing.

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l SCENARIO ABSTRACT The exercise was initiated from the Sequoyah Nuclear Power Facility-at 0715 CDT, June 16, 1980, by simulating severe weather damage to the SQH _

switchyard which caused loss of of f-site A-C power supply. On-site A-C .

power was lost due'to diesel generator malfunction. At 0920 a leak developed in a subsystem of a reactor coolant system loop. An obstruction in the loop caused reduced coolant flow and elevated fuel rod temperatures. The-temperature increase caused fuel cladding damage and release of the fuel element gap radioactivity into the primary coolant and subsequently into the O

containment building. Containment radiation continued to increase and by 1335 EDT, the projected dose rates were 1 Rem /Hr (whole body) and 5 Rem /Hr (thyroid) based on containment activity. Declaration of a General Emergency was indicated. At 1400 EDT a earth-moving pan was pulled away fron . the reactor containment revealing a containment building crack. A Health Physics survey indicated a gamma radiation level of 100 R/Hr. at 200 meters from the containment building.

Containment activity was released in a short time. The exercise continued until 1630 EDT when evacuation of the risk counties was completed.

The exercise was halted until 0300 EDT/17 June when sampling in the Ingestion Pathway was resumed until 1200 EDT, when the Exercise was terminated.

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! OBJECTIVES -

The objectives of the Exercise are covered in the Scenario and are listed as . functions -of the Scenario. Each response organization had pre-planned specific objectives. which they wanted 1o achieve. The :following objectives -

' were provided in accordance with Para N.3.a of-NUREG-0654.

1. Ensure activation of State of Tennessee Emergency Operations Center (EOC), local EOC's, State Control Center and TVA - Central Emergency Control Center (CECC).

2. Activate alerting, notification and warning procedures for State, TVA, Hamilton, and Bradley Counties.

3. Include events that will activate the site Radiological Emergency P1an (it EP).

4. Ensure that communication links are exercised. These include TVA -

ECC's, State EOC, Hamilton and Bradley County EOCs', and all Command Posts.

5. Test the emergency -response capabilities of TVA, -State Organizations, local support agencies, and appropriate Federal Agencies.

6. Itequire certain protective actions be taken for the plume exposure and ingestion pathways. This includes evacuation (simulated or actual) of of f-site creas.

7. Ensure periodic public infortnation releases.

3. Acquire the use of designated of f-site emergency medical facilities

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and ambulance services.

9. Test recovery procedures.

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. OBSERVER PROCEDURES Staf f planners froin the Division of Civil Defense, Tennessee Department of Agriculture, and Tennessee Department of Public Health were designated as Exercise Observers with the following general responsibilities.

Observers planned to be in-place at their designated locations prior to declaration of the unusual event. They were instructed to keep a record of directions given, when and by whom, so that operation and control of the ernergency could be evaluated. Observers were also furnished situations and problems which were pre-numbered to be introduced at a specific time. These situations were intended to " add to the problems", which would occur in an emergency. Evaluation of the adequacy of Planning, Manning, Training, Communications, I acilities, Operations, and Logistics were to be provided by.

the observers.

Observers were also instructed to evaluate the planning which was done to provide coverage over an extended period of time if that became necessary.

Since the Exercise was planned to be no-notice, observers were directed to keep the date and time confidential and not let participants know when the exercise would be conducted.

Self-evaluation is an important part of any Exercise, and participants were requested to provide comm'ents on the exercise. Written comments from participants and State Observers are available at the Tennessee Civil Defense Division. Specific Findings and Recommendations are included in this report.

An oral critique was conducted at 1330 on 17 June 1930 at the State l

l Control Center, Lovell Field, Chattanooga. Tennessee. A transcript of the l

oral critique is available at the Tennessee Civil Defense Division. Highlights i

of the critique are included in Findings and Recommendations.

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PARTICIPATING STATE AGENCIES OFFICE OF THE GOVERNOR e

-DEPARTMENT OF AGRICULTURE DEPARTMENT OF CONSERVATION DEPARTMENT OF HUMAN SERVICES DEPARTMENT OF MILITARY DEPARTMENT OF PUBLIC HEALTH

-DEPARTMEN T OF SAFETY DEPARTMENT OF TRANSPORTATION TENNES5EE WILDLIFE RESOURCES AGENCY DIVISION OF CIVIL DEFENSE AND EMERGENCY PREPAREDNESS HAMILTON AND BR ADLEY COUNTIES PARTICIPATING FEDER AL AGENCIES DEPARTMENT OF ENERGY FEDERAL EMERGENCY MANAGEMENT AGENCY U. S. CO AST GU ARD NUCLEAR REGULATORY COMMISSION NATIONAL WEATHER SERVICE PARTICIPATING FRIVATE/ SEMI-PRIVATE AGENCIES AMERICAN RED CROSS TENNESSEE VALLEY AUTHORITY ADVISORS S AMUEL E. BEALL, JR.

Consultant to the Governor 5

SEQUOY AH "30" CRITIQUE Tuesday,17 June 1980 1330 State Control Center AGENDA Invocation H. H. Bixler .

Opening Remarks Gilbert Smith Acknowledgements Scenario Preparation Team State Observers FEM A Support TVA Cooperation State Emergency Operations Center Lacy Suiter/

David Inman State Control Center John Keese Hamilton County Bill DeBrocke Bradley County Don Gardner TVA John Lobdell/

Ed Webb State Observer Comments Ray Bird - BC EOC _ Harold Fuque -- HC EOC Jake Brooks - BC CP Don Dallenbach - SEOC Charles Edwards - Mobile Charles West --Rad. Health Gil Smith - SCC Jimmy Cagle - Agr.-SCC Radiological Health Bill Graham FEMA Jack Richardson /

Bob Trojanowski NRC John Sears /

Don Cameron /

Joe Neudecker Tripartite Comments Samuel Beall Closing Remarks Col. Eugene P. Tanner NOTE: Complete tape et Critique available at Tennessee State l Division of Civil Defense.

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LISTING OF COMMENTS FROM SEQUOY AH "80". EXERCISE

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Tennessee' Valley Authority ,

U. S. Department of Energy State of Georgia State Emergency Operations Ce nter Operations -

Public Information Department of Public Health Water Quality Control -

Department of Agriculture Hamilton County EOC.

Bradley County EOC State Liaison Of ficer (Hamilton, Bradley, TVA),

Department of Transportation-Department of Military-State Control Center (2)

Information Department of Safety Communications State EOC State Control Center State observers l- State EOC (CD, R AD Health, AGR.)

State Control Center (CD, AGR.)

t Harntiton County EOC i

Bradley County EOC Cornmund Post Mobile

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Transcript of Critique Federal Emergency Managernent Agency NOTE: Findings and recommendations are included in this Repor t. Complete file of commen+:. 3 available at Tennessee Division of Civil Defense.

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FINDINGS BY SUBJECT AREA

l. Arrange:nent and Procedures in EOC's

2. Standardize Display Boards.

3. Message Handling within EOC's

4. "Get Ready" Warning Messages

5. Update Briefings in EOC

6. Requirements for State Control Center

7. ' Recommended EOC Layout for Counties

3. Keeping all informed

9. TVA Representation at SEOC & SCC

10. ' Adequacy of Warning System

11. Hard Copy Information on Facility Status

12. Requirement for "as of" Time of Events

13. Timing of Meteorological Data

14. Using Assistance Available

15. Timely Dose Projections-

16. Control of Radiological Monitoring Teams

17. Sainple Size Information in Plan Public Information 13.

19. Agriculture Extension Agent & TDA Agents

- 20. ' Chattanooga Water Storage Capacity

21. Communications Equipment Requirements

22. Training Radio Communicators

23. Requirement for No-Notice

24. Planning for FAA Support

25. Risk Counties Coordinating Assistance

26. Test Recovery and Restoration Procedures I

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FINDING No.1 The Emergency Operations Center (EOC) arran~gements did not provide '

optimuin conditions f or utilization of personnel. -.

DISCUSSION Congestion around status maps, tables, and controller's telephones caused sorne problerns because of interference from noise and the crowded conditions.

EOC staff personnel were not located adjacent to other personnel with whom they needed to coordinate various actions. For example, Rad tlealth, Air Pollution Control (Metro), Agriculture, TVA Radiation Specialists, and Water Quality Control all are invo!ved in the sarne kinds of activity. They should be physically located near each other. Other agencies have the same requirement.

RECOMMENDATION Review the job to be done by each rnember of the EOC staff and locate those within a spect!ic area of responsibility adjacent to one another insofar as possible.

Review EOC arrangement and procedures and change to increase el1iciency.

Action Agency: Tennessee State Civil Defense Action Of ficial: Lacy Suiter Completion Date: 1 October 1980 9

FINDING NO. 2 Visual ' display boards did not provide sufficient information in some of trie Einergency Operations Centers (EOC's).

DISCUSSION As much of the area situation, both static and active, as can be displayed, needs to be shown on situation maps and status display boards. This information is absolutely essential in a real emergency because personnel must

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be able to grasp the status changes readily-especially when a personnel change takes place. Such information as location of Traffic' Assist Teams, Command Posts, Shelter Information Points, Road Blocks, Mass Care Shelters, and Radiological Laboratories should be displayed for all to see. Sector designa-tions and the status of evacuation from each area, plume location, weather info.mation (wind direction and velocity, and atmospheric stability), and current Emergency Classification are essential items of 'information for several agencies in the EOC to have available to them. A tone alert system may be necessary to indicate that a change in status is being posted. Status of some items may be indicated by a magnetic rniniature of one (1) color for the planned location and another color when it is activated. Each Department can provide inf ormation on status boards af fecting them.

RECOMMENDATION Require input f rom all personnel who have any EOC responsibility and deterinine what display infortnation will be available in each Operations and Control Center. Standardize di3 played information.

Action Agency: Tennessee State Civil Def ense.

l Action Of ficial: John Wlute Completion Date: 1 October 1980

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FINDING NO.' 3 Message handling and distribution within the Emergency Operations Centers (EOC's) 'were not entirely satisfactory. A message-handling system which will keep all people in the EOC informed is required.

DISCUSSION Message traf fic involved many agencies. Some were operational and others were of a technical nature. Personnel who are unfamiliar with technical terms have difficulty copying the information if it is given over telephone circuits. Accuracy of technical information can be very critical in the decision process. Hamilton , County Civil Defense has developed a

, mes3 age-handling system which worked extrernely well during the Exercise.

Well intorrned participants are better prepared to handle problems effectively.

RECOMMENDABON Review the Hamilton County Civil Defense EOC message-handling system, and adapt it as necessary for use in all EOC's.

Action Agency: Tennessee State Civil Def ense Action Official: Gilbert S tith Completion Date: 1 September 1980 11

FINDING No. 4 Get-ready warnings were provided by the State Emergency Operations Center (EOC) to subordinate units. This helped them be prepared to execute:

directions more expeditiously. .

DISCUSSION The Plan does not require that "get ready" messages be sent to the State Control Center (SCC) and County EOC's prior to a change in Emergency Classification. When the system provides hard copy information to all EOC's and the SCC, they will be aware of a stable, improving, or deteriorating condition at the f acility and can prepare accordingly.

RECOMMENDATION -

Discuss the advantages as well as the problems in providing "get ready f or" messages, and if it is determined they are helpful, establish procedures.

Action Agency: Tennessee Division of Civil Defense Action Official: La y Suiter Completion Date: 1 October 1980 12

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- FINDING No. 5 Procedures for providing information to be included in up-date briefings j should be reviewed.

2 DISCUSSION l Various procedures were~used at the Emergency Operations Centers / State j Control Center (EOC's/ SCC) to keep personnel' informed of status changes periodically. In some cases, the person in charge attempted to bring everyone

up to date while in others, a microphone was passed around for each agency to

l. report upiated information.

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i J RECOMMENDATION 4

j A standard method of receiving and giving updated information to all 1 personnel in the EOC/ SCC should be developed. Develop a Standard Format.

! Action Agency: Tennessee State Civil Defense.

Action Of ficial

Gilbert Smith Completion Date: 1 September 1980 1

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FINDING '

NO.6 The functions of the State Control Center (SCC) as currently planned at Lovell Field was questioned by a number of observers.

DISCUSSION

- Personnel at the SCC were highly mot' ated. The SCC is envisioned as a command and control agency near the site. The current facility cannot provide such capability due to physical layout and communications. limitations. -It is generally agreed that there is a requirement for media handling in the Sequoyah area. The SCC, as currently set _up, cannot perform. that f unction. A near-site facility to coordinate utilization of various State resources is considered necessary. Plant information available to the SCC _was late and inaccurate which rnade it innpossible to be in a position to control activity.

RECOMMENDATION I

Determine the requirements for a State near-site f acility and its func -

tions. Consider a location adjacent to the Central Emergency Control Center (CECC) where media information can be provided and essential functions in the near-site area can be coordinated.

f I Action Agency: rennessee State Civil Defense and TVA Action Otticial: Elgan Usrey Completion Date: 1 October 1980 l

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FINDING NO. 7 Soine counties have inadequate facilities to manage an emergency which can occur f rom a Nuclear Power Facility.

DISCUSSION It was reported that some f acilities lacked water, sanitation, adequate roorn and comf ort for extended operations.

R ECOMMENDATION Prepare a docurnent which lists the recommended Emergency Operations Center (EOC) layout and requirernents for those counties involved in the Emergency Planning Zone (EPZ) of Nuclear Power Facilities.

Action Agency: Tennessee State Civil Defense and Risk Counties Action Official: John Keese Completion D.ite: 1 April 1981 15

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FINDING NO. 3 The Bradley County Ernergency' Operations Center (EOC) was no't kept tully informed of plans conditions until late in the Exercise.

DISCUSSION

- Since inforrnation on a radiation release f rom Sequoyah was slow arriving at the State Ernergency Operations Center (SEOC), wind information f rom Muscle Shoals did not arrive when it should to coincide with the radiation release information. This caused a problem in plotting the direction in which the plume traveled initially. Since the plume was not plotted to travel toward t$radley County, they were not involved. Subsequent action in the form of a "puf f" did get thern involved. Radiological Monitoring crews did not send information which verified where the simulated radiation was located.

' RECOMMEND ADON All EOC's should receive a hard copy of what's happening at the facility.

RAD Health should provide simulated radiation readings for monitoring crews to send to the SEOC.

Action Agency: Tennessee State Civi! Def ense, TVA, and RAD Health Action Otticial: Elgan Usrey Completion Date: 1 October 1980 16

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j FINDING NO. 9 +

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Validity of need for. . TVA ' representation at the. State Emergency Operations Center (EOC) and State Control Center requires review, i

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i DISCUSSION A TVA representative was not assigned to the State Control Center when specified in the Plan. Although TVA stated that a representative would be

assigned in an actual emergency, it'is important to have one during~an Exercise i

to work out procedures which will be used during an actual emergency. The

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State needs to know the significance of problems which are reported concerning -

the f acility. Decision makers should also be advised whether the problem is 4 stable, deteriorating, or improving.

! RECOMMENDAT10N 1

i State Civil Defense and TVA discuss the need for TVA representation at i the SEOC and SCC. If the need is valid, a representative knowledgeable with -

5 the plant operation should be in place at Site Emergency or General Emergency.

, Action Agency: Tennessee State Civil Defense and TVA Action of ficial: John Keese Completion Date: 1 October 1980 -

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FINDING ~

' NO.10

.The warning system is not adequate to' alert all people.within the ten-mile -

(10) Emergency Planning Zone (EPZ) within fif teen (15) rninutes. .

DISCUSSION .

Tl'e primary warning system. is the use of ernergency vehicle sirens. If the counties are given adequate warning so that the vehicles can be prepositioned-at.the start of their warning route, they can cover the area within fif teen (15) minutes. .Without prior notification, it will take 30-45 minutes to alert the population-at-risk. This does not meet the warning criteria.

The design objective in NUREG 0654 specifies notification of all people within five (5) rniles of the facility and ninety percent (90?6) of these located between live and ten miles (5-10) within fif teen (15) minutes. - The remaining ten percent (10%) must be notified within 45 minutes.

The expected frequency of incidents / accidents at a nuclear power facility .

are as follows according to NUREG-0610.

Unusual event -- Once or twice per year- per unit.

I Alert -- Once in 10 to 100 years per unit.

i Site Emergency -- Once in 100 to once in 5,000 years per unit.

General Ernergency -- Less than once in about 5,000 years per. unit.

Lif e-threatening doses off-site (within 10 miles) once in about 100,000 years per unit.

RECOMMENDABON yuestion the validity of the requirernent for all people Itving within five (5)Imles and ninety percent (90%) of those within 5 - 10 miles to be nc:ified

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within D minutes. When the cost of notification within 15 minutes, compared to the cost in 30 45 minutes is considered, according to the risk, the shorter time appears unjustifiable.

Action Agencies: Tennessee State Civil Defense, Tennessee Valley Authority, Federal Einergency Managernent Agency, and Nuclear Regulatory Commission Action Of ficial: Truett Frazier Completion Date: Open 19

FINDING NO.11 -

A report of the conditions at the Sequoyah Facility was not forwarded to all activities who needed the information on a timely basis.

DISCUSSION If timely _ decisions are to be made to handle an emergency situation and to protect the public, decision makers must have information accurately and as soon af ter the condition occurs as possible. Dedicated . telephone circuits were available to provide this information. Simulated conditions were introduced by a TVA Observer at the Sequoyah Facility starting at 0715 EDT on 16 June 1980. Delays from several minutes to over an hour were common in getting the information to some Emergency Operations Centers. Although the plant information may not be essential for decision making at the county level, it does help keep the county officials informed so that they are more nearly ready to respond when directed by the State EOC.

RECOMMENDABON A system should be provided which will transmit plant condition infortna-tion and other critical data to the State EOC, County EOC's, and State Control Center simultaneously with the flow of data to TVA. This information snould be in "hard copy" form so that the chance for error is minimum.

l Action Agency: Tennessee Division of Civil Defense and Tennessee Valley Authority.

Action otticial: Elgan Usrey/ David inman Completion Date: 1 October 1980 20 1

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,. - FINDING I 'No.12

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The "as ot" tirne et events at the f acility could not be determined.

' DISCUSSION in the Exercise, simulated conditions and'e' vents were introduced at the j Sequoyah Facili_ty at tirnes specified 'by the ' Scenario. This information was passed .by voice over a dedicated circuit- to ;the TVA - Central Einergency l Control Center (CECC) in Chattanooga where it was then' passed to the State-

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I Einergency Operations Center (EOC). It was not possible to determine when the event took place ,at the f acilty. In-a real emergency, this information would be critical.

1 RECOMMENDATION i

include inessage number and time of event in a hard copy of information -

concerning f acility conditions.

Action Agency: TVA and Tennessee State Civil Defense Action Of ficial: Elgan Usrey/ David Ininan . Cornpletion Date: 1 October 1980 i.

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FINDING NO.13 Meteorological data.did not arrive at the Agencies.where 'it was needed in a tonely inanner.

DISCUSSION The Metro Tow'er near the~ facility normally sends weather'information directly to Muscle Shoals. This weather information is furnished to Health Physics personnel for them to calculate projected dose rates to be forwarded to the State Emergency Operations Center (EOC). Since the. Exercise Plan called for weather data to be introduced as specified (not current actual.

weather) it was important that the timing'of weather condition coincide with reported conditions at the plant for that same time. - Delays in furnishing plant .

information to the State EOC caused decisions to be made from out-of-phase weather data. In some cases, the weather data was introduced from the TVA-Central Emergency Control Center (CECC) at Chattanooga, further compli .

catmg the problem.

RECOMMENDADON TVA Metro at Muscle Shoals should use the simulated weather data for their report to State Rad Health and to TVA Health Physics in an exercise. In an actual einergency, use the weather data f rom the Metro Tower at Sequoyah to Metro-Muscle Shoals, then to all concerned agencies.

Action Agency: TVA.

Action Of ficial: Elgan Usrey Completion Date 1 October 1980 22

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', FINDING g.

- NO.14 .y 4 _o -/ s '.

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Sonne Agencies coordIrjated extremely well with their counterparts, while y

others tried to handle every problem themselves and f ailed in some cases.

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< . DISCUSSION 1.

The Division of Water Quality Control personnel at the State Control Center (SCC) worked close'ky wi$h their counterpcrts at the State Emergency Operations Center (SEOC) and'r,ecommended timely action to prevent simulated radiation of the water systems downstream from Sequoyah. A situation was gi en to the Hamilton County'EOC and the SCC requesting information on the extent of radiation five (5) miles from Sequoyah. Hamilton' County contacted the SCC. This question was never answered. In an actual emergency situation, snany people can call requesting . information on the emergency. Timely -

response to queries is necessary. If the answer is not available at one level, it should be passed on to the next Agency for reply.

t RECOMMENDATION Each response organization indoctrinate its personnel to handle problems expeditiously and not hesitate to codtact other individuals for assistance.

Action Agency: All participating agencies Action Of ficial: David Inman/ Anne Stringham Completion Date: 1 September i  ;

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• FINDING No.13 4

Accurate and rapid calculation of projected dose exposure was not provided.

DISCUSSION in order for the Tripartite Committee and other decision snakers to inake accurate,/ timely decisions, they must have accurate, timely information on the radiation dose projection involving the population-at-risk. TVA has the capabitety at the f acility and at Muscle Shoals to make these calculations. The dose r'ates can be validated by Tennessee Division of Radiological Health

( TD R H). If an einergency develops at Sequoyah, and the problem deteriorates to a General Ernergency Einergency Classification - 4 (EC-4), prompt action must be taken to protect the people. There may not be time to discuss the calculations when the public is endangered. Action is necessary.

RECOMM END ATION TVA provides the 5 tate EOC projected dose information. The TDRH should calculate dose projections to confirm the TVA figures. The State Linergency Operations Center (EOC) and TDRH should present the information to the Tripar tite for their recommendations to the Governor concerning evacuation.

Action Agencie3: TV A, TDRH, Tennessee State Civil Defense Action otticial: Anne 5tringharii - TDPH Completion Date: 1 September 1930 24

1 lNDING NO. 16 Coordination of Radiological Monitoring Team Activities was not conducted by Tennessee Division of Radiological Health (TDRH) personnel.

DISCUSSION Some Divisions of Publ;c Health were not aware of suppen available f rom TVA, Department of Energy (DOE), Southern Mutual Radiation Assistance Plan (SMRAP), and other State Agencies in monitoring tearns and laboratories. Control of teams available was not coordinated so that Rad

\1onitoring Team location in the field was known at all times or so that sample collectors could be directed to the nearest laboratory with field samples.

Location of laboratories is necessary so that any agency which collects samples can be directed quickly and safely to the lab. The primary responsibility at Radiological Monitoring Teams is to provide radiation intormation t rom various pre-selected locations to verify projected dose calculations.

RECOMM END ATION The appropriate Dtvision of Public Health should establish a grid system with easily located landtnarks or crossroads for Rad monitoring teams to be directed to for sainpling, primarily within the ten-mile (10' Ernergency Planning Zone (EPZ). Rad Health predetermines where motile and fixed laboratories should be located for expedited analysts of samples. Identif y these locations on a map f or ease in locating them. Several suitable locations for mobile labs should be selected so that the saf est can be utilized depending upon the wind condition 3.

Action Agency: TDRH.

Completion Date: 1 September Action Ot ticial: Anne 5tringham-TDPH 19$0 25

FINDING NO.17 1

Sainple size requirements were not provided Tennessee Department of l

Agriculture (TDA) personnel by R AD Health. '

DISCUSSION l

l Agriculture Department personnel were ordered to the Ingestion Pathway area to collect samples to be checked for radiation. When they returned with 1

the samples of inilk, produce, and grain; they were told that the samples should l have been larger.

RECOMMENDATION Tennessee Division of Radiological Health (TDRH) provide the TDA specitic information to be included in Part 111 of the Plan on sample require-1 ments.

Action Agency: TDRil and TDA Action Of ficial: Arine Stringharn - TDPH Completion Date: 1 Septernber 1930 )

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FINDING NO.18 Release of Public information appeared to be handled very ef fectively.

DISCUSSION The Plan does not require a Public Information representative at the State .

Control Center (SCC) in Chattanooga. Dne was assigned there during the Exercise. News Media will arrive at various places to obtain information on the emergency. The Plan is specific in the guidance on who may release off-site information. The release of off-site .information by the Einergency Broadcast System (EBS) (WDOD) and National Oceanic and Atmospheric Administration (NOAA) Radio was very effective for Harnitton County. However, Bradley County was not covered with evacuation announcements by their EBS Radio Station (W BAC). A primary function of the State near-site location is to handle news media representatives in the area. Most of this function was assumed by-Harnilton County Emergency Operations Center (EOC). It was handled very ef fectively. However, the Plan does not specif y that method.

RECOMMENDADON The Emergency Information Officer should review the procedures specified in the Plan, the procedures used during the Exercise, and in coordina- i tion with other information personnel deterinine what changes to the Plan are appropriate.

Action Agency: En.ergency Information Of ficer

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Action Olticial: Keel Hunt Completion Date: 1 September 1980 27

FINDING NO.19 6

itesponsibilities of the University of Tennessee Agriculture Extension Service personnel is not generally understood by Non-Agriculture Department personnel. Tennessee Departrnent of Agriculture (TDA) agents are difficult to contact in the field.

DISCUSSION Extension Service personnel are not employees of the Tennessee Departtiient of Agriculture. They have, however, been very helpful in surveying farins to obtain infor: nation which is included in the Plan. With prior coordination, they would be available to assist, if required, . during an emergency. The TDA agent in the area could not be contacted until over five (3) hours af ter the Exercise started. Although this was soon enough to handle Ingestion Pathway matters, it did not satisfy coordination requirements for-Adriculture sampling in the Emergency Planning Zone (EPZ). Overall, the responsibilities of the TD A were carried out exceptionally well.

RECOMMENDADON TDA provide information to all county Civil Defense Directors in the 50-mile radius around the Nuclear Power Facilities concerning the functions and responsibilities of Extension Agents. Also, that TDA take action to establish a system to get in touch with TDA personnel in the EPZ within a reasonable period of time.

Action Agency: Tennessee Departinent of Agriculture Action otticial: Jim Thornas Completion Date: 1 September 1980 23

FINDING 140. 20 Water storage capacity for the City of Chattanooga is sufficient for less than one (1) day at norinal consurnption rate.

DISCUSSION Downtown Chattanooga is suppited with finished water directly frorn the high service punips operated by Tennessee Water Company without benefit of storage capacity in addition to the clear well which supplies the high service punips. It a radiation release frorn Sequoyah rnade it necessary to close the intakes troin the Tennessee itiver, the water supply to the city would be critical.

RECOMMENDATION Deterrnine whether the risk is so great that additional water storage capacity f or the City of Chattanooga is ess-ntial for the safety and well being of its citizens.

Action Agency: Tennessee Department of Public Health.

Action Of ficial: Terry Cothern Completion Date: 1 September 1930 l

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FINDING No.21 Telephone lines failed and were not immediately repaired.

Co ntounications requirements should be reviewed.

DISCUSSION The person who normally expedites resolution of . telephone problems for the State Emergency Operations Center (SEOC) was on vacation when the tixercise started. Two '2) critical (TVA Chairman and RAD Health) ringdown :

circuits f ailed at the SEOC. The circuit to Signal Mountain from the State Control Center (SCC) was also inoperative. Some of these circuits were out f or over six (6) hours. One (1) member of the Tripartite Committee was located at the TVA - Central Emergency Control Center (CECC). He utilized the dedicated circuit to SEOC to discuss Tripartite matters with the conunittee members there. This was necessary and important for the job, but it prevented the State Liaison official at the CECC from talking over the line to his counterpart at the SEOC.

l RECOMMENDABON l

Analyze total comununications requirements. Schedule system and line l

l changes based upon the analysis. Indoctrinate all concerned personnel with changes and publish change to Annex G of the Plan.

Action Agency: Tennessee State Civil Def ense and TVA.

Action Otinctal: Truett Frazter Completion Date: 1 September 1980 L

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s FINDING

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NO. 22 Sonne personnel who needed to receive and trandinit inforination via radio had little or no training in radio procedures. -

DISCUSSION The Civil Defense radio net was set up with network cohtrol at th'e State-Control Center. The individual who handled the base station was well qualified -

and inaintained control of radio traffic. The-two (2) channels planned for the exercise were inoperative until'about six (6) hours af ter the exercise started.

The THP radio net was used during this time. RAD Health should have had a person near the radio net controller to talk to the Radiological Monitoring Tearns and to guide and coordinate their eff orts. Any personnel who operate radio equipment need some training in proper procedures.

RECOMMENDATION All response organizations should arrange to receive training in radio procedures from Civil Defense personnel unless they have qualified radio operators to provide their own training.

l Action Agency: T emessee State Civil Defense Action Of ticial: David inman Completion Date: 1 June 1981 l

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FINDING -

NO. 23 1.

50me participants were aware of the date of the' Exercise although it._

}l was no-notice.

DISCUSSION

When inany Agencies take part in an Exercise of 'this nature and the i

public needs to be. notified, it is dif ficult to conduct it on a no-notice basis.

Although every effort was made by the Exercise Planners to keep the date confidential, some participants knew ahead of time when it would occur. Itis understandable that all response organizations want to do an outstanding job.

! In an exercise, several individuals who would take an active part in an -

{

einergency are not available because they are observers of the exercise.

i Several agencies had to be ready if they were to participate. These included the Governor's office, Federal Emergency Management Agency (FEM A),

, Nuclear Regulatory Commission (NRC), as well as State and local organiza-l tions, TVA, and the news media. The period of 7-21 June was published as the j liability period for the Exercise. Although the State was not criticized for j some people knowing ahead of time and being " set on go" when the Exercise

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i starts realistically in an actual einergency, there would be no advance I .

warning.

i RECOMMENDADON i

All agencies which "need to know", select a person to be contacted by I

the Exercise Planner. This person will be given the specific date, time, and scope of the Exercise. FEMA, NRC, and TVA appoint a " trusted agent" who

-7 will be contacted by the State Exercise Planner. The liability period should i

cover a thirty (30) day time span.

Action Agencies: All participating organizations

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Action Of ficial: Gilbert Samth Completion Date: 1 Septemoer 1930 i

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FINDING No.24 Federal Aviation Administration (FA A) support was not pre-planned although it was handled ef fectively when the requirement was presented.

DISCUSSION 11 an emergency -occurred at the Sequoyah Nuclear ' Power Facility, general aviation aircraf t could be a problem if not restricted from the area.

Passengers of commercial aircraf t . landing at Lovell Field could also be -

endangered if flown through the Plume Exposure Pathway. A simulated-problern was introduced at the SCC and was handled well by local FAA control.

personnel when contacted.

RECOMMENDATION include appropriate FAA Agencies as Task Organizations to handle air i trattic rnatters during an emergency at Sequoyah.

Action Agency: Tennessee State Civil Defense.

j Action Official: Gilbert Smith Completion Date: 1 September 1980 1

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FINDING

, NO. 25 The pian requires various State Agencies to provide support to the counties. It does not specify how the counties and State Agencies will coordinate requirements.

DISCUSSION Departments of Safety, Transportation (TDOT), Agriculture (TDA),

Military, etc., will be required to furnish some resources to the risk counties, especially if the emergency is prolonged. All requirements may not be known until the actual emergency arises. Some Departments have coordinated with

• the counties, and specific requirernents have been identified. ~ Others expect to provide assistance but contact was not made with them during the exercise.

For example, TDOT was never contacted to help the counties block roads af ter the evacuation was ordered.

RECOMMENDATION Risk counties deterinine, so f ar as possible, what various departments will be called on to fursush. Appropriate parts of the county procedures should be coordinated with the applicable department.

Action Agency: Risk Counties and State Departments as applicable.

Action Of ficial: 1.acy Suiter Completion Date: 1 October 1930 m

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FINDING NO. 26 s

> 1 Recovery and rest 6 ration procedures were not exercised.

DISCUSSION Alter an area has been evacuated, the emergency terminated and radiation release stopped, the evacuated area must be checked so that people may return to their homes safely. Procedures for recovery and restoration are included in Part IV of the Sequoyah Plan. However, no recovery actions were -

exercised.

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RECOM'MENDATION '

Review procedures outlined in Part IV of the Sequoyah Plan and determine their adequacy, insure that recovery procedures are tested in all' future exercises.

Action Agency: Tennessee State Civil Defense and Tennessee Division of Radiological Health Action Otticial: Gilbert Smith Completion Date: 1 December 1980 l

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MILITARY DEPARTMENT OF TENNESSEE OFFICE OF CIVIL DEFENSE AND EMERGENCY PREPAREDNESS EMEHGENCY OPEHATIONS CENTER 3o4: stoco osivt NASHVILLE 31204 PHONE iniS)148 Stel 01 August 1930 lu: See Distribution Below ,

lilt: Lagene l'. Tanner h

Director , Civil Delense SJ: l'ollow-Up Action on Sequoyah Exercise lhe Exercise l<epor t for Sequoyah dated 7 July 1930 has been forwarded to your Departrnent. In order to correct those deficiencies which were identified in the ewicise, I appointed Col. Gilbert Sinith to follow up with the responsible ager.cy.

As a pari of the follow-up action, a schedule has been prepared which indicates the individual, by narne, responsible for the follow-up action and a scheduled conipletion date when the deficiency should be resolved. Attached hereto is a copy of the schedule and a itepart Forin on which progress in correcting each deticiency may be recorded.

I' lease keep Col. Nnith uitorined of the status of the finding for which you are responsible. Ihs phone nuinber is 741-5181.

/ luc xpe: Mr. Lacy Suiter Mr. John White Mr. Elgan U srey Mr. John Keese Mr. Truutt l'raeler Mr. Davitt innion

- Mr. Gilbert Smiti.

Ms . Atute Stringhain, Tenn. Dept . of Public Health Mr. Terry Cothern ,

Mr. Jim Thoinos , Tenn. Dept . of Agriculture 36

AC lluN Ol;l !CI AL FOtt COMI'LETION Ol' DEltlCIENCIES COMl'LETION DATE5 I lNiilNG AC l ION COMI'LETION D ATE N o. Ol;l lCI A L 1 Lucy Suiter i October 1980 2 John white i October 1980

$ Gilber t buiith 1 Septernber 1980 4 Lacy suiter i October 1980

) Gilbei t Sinith 1 Septeinber 1980 6 Elgan (J3:ey i October 1980 7 Johntseese i April 1981 8 Elgan Usr ey i October 1980 9 John heese i October 1980 10 Ti uet t I;razier Open i! Elgan tIsrey/ David Ininan i October 1980 12 Elgan tJsrey/ David Ininan 1 October 1980 13 Elgan tisr ey 1 October 1980 ,

14 David Ininan/ Anne Stringhain i Septernber 1980 la Anne stringhain - TDPli i Septernber 1980 16 Anne 5tr inghain - TDPtf I Septernber 1980 17 Anne 5tringhain - TDPri i Septernber 1980 18 heel llunt t Septeinber 1980 19 Jtin ihoina3 l bepternber 1980 20 l'er a y Cot her n l 5epteinber 1980 21 Tr oet t t r azier i depteenber 1980 2 .' Dav al Ininan 1 June 1981 21 Gilbet t 5nnth 15epternber 1980 24 olluert snuth  ! 5epteinber 1980 J4 Laty 5 niter i October 1980 26 vilbe r t booth i Decernber 1980

TliNNE5SEE MULTI-JURISDICTIONAL RADIOLOGICAL EMERGENCY RESPONSE PLAN DEFICIENCY CORRECTION REPORT FINDING NO. FIXED NUCLEAR POWER FACILITY SU L5]EC T:

ACTION AGENCY:

ACTION OFFICER:

TELEPHONE NO.

COORDINATING AGENCY:

PLANNED COMPLETION DATE:

STATUSOJ PROGRESS

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. APPENDIX 22, ANNEX F RADIOLOGICAL MONITORING TEAM UTILIZATION d I. PURPOSE This Appendix provides the procedures to be used to control and direct the efforts of a;' radiological monitoring teams (RADMONT) to be used I in off-site monitoring.

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!!. SCOPE The Radiological Monitoring Teams are the mobile _ sensors for the f

agencies which determine the radiation risk to people located in the Emergency Planning Zone. Control of the teams assigned and made

, available to the State is a responsibility of the TDRH.

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!!!. EX ECUTION i When an Unusual Event occurs at a nuclear power facility, RADMONT j control personnel from TDRH will prepare to proceed to the TVA

Environmental Data Station (EDS). When the Alert Emergency

! Classification (EC-2) is declared, the personnel will proceed to the EDS.

The EDS is located at the TVA Met Tower near the Sequoyah NPF.

l Facilities are-available at the EDS for team control personnel from TDRH to work alongside TVA personnel during an exercise or an j emergency. The EDS is equipped with radio equipment to maintain contact with and control each team's movements. The EDS also has j ringdown telephones for contact with the MSECC and the SEOC.

i RADMON teams will be provided by Agencies listed in Tab A. With the exception of TVA teams who are dispatched from the Nuclear Powr Facility, all R ADMON teams will report to the Field Team Control Center (FTCC) at Lovell Field. The teams will be issued maps of the area which shows the specific monitoring points, radio procedures and frequencies, data forms, and anycther materials needed for them to tunction in that area. Equipment and training for the field teams is a

, respansibility of their parent organization.

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q IV. DATA TRANSMISSION Radiation data will be sent by radio from each field team to the EDS.

From the EDS, it will be passed to the nuclear power facility and to Muscle Shoals. Field data will be consolidated with data generated at the facility and dose projections calculated at Muscle Shoals. The TDRH will validate TVA calculations and advise the Tripartite Committee of their concurrence in the TVA findings.

TAB A, APPENDIX 22, ANNEX F SOURCE OF RADIOLOGICAL MONITORING TEAMS

1. PURPOSE This Tab lists the Radiological Monitoring Teains to be provided by all Agencies to support Tennessee in case of an accident at a Nuclear Power Facility.

11. R ADIOLOGICAL MONITORING TEAMS (R ADMONT)

SOURCE RESPONSE TIME TVA (Facility) .3 HR.

State 4.0 HR.

TVA (Muscle Shoals) 4.0 HR.

IR AP (DOE) 2 - 24 HR.

SM R AP 8 - 24 HR.

Universities 12 - 24 HR.

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JUL 22 a::

Colonel Eugene P. Tanner State Direcccr Tennessee Linergency Mana9eacnt Agency 3u41 staco Drive

'mshville, lennessee a7204 Dear Ccionel Tanner.

The follu.ein, ueficiencies were noted during RAC IV/FCIA :taf f participation in anu cvaluation of the Sequoyah Nuclear Power Plant exercisc July 7 >a, 19ol .

. General Cor.nents:

1. Tims (CDT vs. EDT) caused problens throughout the exercise.

2. There was confusion on wind direction as it affects alume travel. A firr.

decision should be f.iade on usinb wind direction " fro:n" or "to" in future exercises.

Specific Comments:

1. Notification ana Alerting of Staff Adequate.

2. Notification and Alerting of the Public The warning systen utilized in this exercise did not nieet the requirements of D654.

3. External Comaunications Capability Between Sites ,

Cosamunications break-downs with Bradley County curing the exercise caused delays in message transmission. '

l There were several instances where messages were garbled in transaission causing figures to be reported in error and unit terms to be confused.

Training should be conducted to familiarize both operations and communica-tions personnel with the appropriate tenninologies used in these operations.

4. EOC Facility The Bradley County EOC needs improvenents in space, ventilation, and

- comniunications.

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.; . L.C int *rt.cl ',n..anicatiens an i .;.l e.y:.

l.:. prove..cnts in plottin; ,;rotecurcs . I: csta ;e hsnJlin.. anc lo;. gin; are nee 6ed.

Pells on soie phones were cisconnected in trie FCC causing calls to be missed when flashir.., li nts .cre not noticeu, i The FCC status boards were not updated to reflect the current situation as i of t,;00 a.n. 7/i> when the ewrcise resu.:cd.

The pia..c was not plotted on the FCC ...aps.

. o. i4ec,uscy of 5taffin.. .

neco;. reno a review of staf fing over a sustainea period.

l i 7. Facility Access / Control The functions of security and dosimetry should be separated.

3. Support by hcsponsible Elected or Appointed Officials

/,oeqda te.

S. Direction and Control iws ne..ia.rs ni the tripartite o, crated fro:. the CECC which lic.iteu their

, ability to function by re.,oving then. fro.a i;m.ediate and airect contact with their support staff and thus hatpcred the 'Jirection and Control function of

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the State E C.

! Tnere was a lack of infonaation exchange between liamilton and Bradley County

! EOC's and the State E0C in i;ashville. Coordination between the State EOC

! and the FCC was lacking at times. Delays were experienced in implecenting

. decisions because of limited information.

Direction and control of monitoring teaus needs improvement in these areas:

a. Pre-assigrr.

cnt briefings were not complete in that expected exposure

rates, types of release, plant conditions, nission exposure limits and

. recor. mended protective tr.easures were not discussed.

b. lionitors did not refer to nor follow SOP's.

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c. Eackup monitoring teams were not assigned to assist teams following the pl u.c.e .

d. Assigned monitoring team identification numbers did not follow the 50P.

10. Coordination ,

The State LOC /FCC relationship and functions should be better defined. At tir.ies infonr.ation by-possed the FCC as it went frou State to local governments.

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11. O er e, . c;. ,1ons Acequate.

12. Public Inf on'..ation The FCC diu not receive press releases from the CECC or the State EOC.

There were no arrangements uade for press briefings at the FCC.

13. i.ccident 1.ssess:..ent Radiological teams were not instructed nor did any teams conduct monitoring on route to pre-designateo nonitoring points.

Tem.. nien.bers were not asked for personal exposures during missions.

TVA and Rac health usea different population dose projection models which createa a significant difference in projected exposures offsite. Field monitoring data was not used for verification of projections.

Use of Public service Commission oersonnel as members of monitoring teams wa- goou. This capability and traineu resource can be immediately utilized when needed anu snould be further explored.

14. Protective Actions Reasons for evacuation ano sheltering cecisions were not raade clear to fielo locations.

Shelter personnel should be aware of decontamination procedures. Plans should be developed for implementation of decontamination as a protective action for shelterees.

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Evacuation was ordered for some areas where monitoring teams were reporting background readings only.

15. Exposure Control The decision to asuinister potassium iodide was not explained satisfactorily at all field locations. -

Decontaatination stations and procedures to be followed for personnel and eaers ency vehicle decontamination were not established during the exercise.

16. Recovery ano Re-entry

1och work and planning remains to be done in the areas of recovery and re-entry.

17. Auequacy of the Scenario to Test the Plan Deviation from the senario caused much confusion for exercise observers and staff alike. .

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~16. Lanciits of t.5e Lxcrcise to 1articipant:

Self critique t,rcujht out Lenefits of ex::rcise to the participants.

19. Capability of Observed Jurisdiction to Execute Plans Acequate.

Sincerely.

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" Jack D. Richardson 0 _

Chairman, RAC IV i

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