ML20072L374

Supplementary Testimony of a Lookabaugh & J Benton Re Emergency Preparedness

ML20072L374
Person / Time
Site:	Comanche Peak
Issue date:	03/30/1983
From:	Benton J, Lookabaugh A Federal Emergency Management Agency
To:
Shared Package
ML20072L357	List: ML20072L374
References
NUDOCS 8303310266
Download: ML20072L374 (5)

Text

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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING COMPANY, Docket Nos. 50-445 ET AL. 50-446 (Comanche Peak Steam Electric Station, Units 1 and 2)

FEMA STAFF SUPPLEMENTARY TESTIMONY OF ALBERT LOOKABAUGH AND JOHN BENTON ON EMERGENCY PREPAREDNESS Q.1 Mr. Lookabaugh, please state your name and occupation.

A.1 My name is Albert L. Lookabaugh. I am the Supervisor, Community Planner, Natural and Technological Hazards (" NTH") Division, Region VI, of the Federal Emergency Management Agency (" FEMA") in Denton, Texas.

Q.2 Mr. Benton, please state your name and occupation.

A.2 My name is John W. Benton, Chief, Training and Education Branch, Resources Management and Administration Division, Region VI, of FEMA.

Q.3 Messrs. Lookabaugh and Benton, please describe the nature of the responsibilities you have had regarding nuclear power plant emergency preparedness.

A.3 (Lookabaugh) I am responsible for the review and evaluation of all off-site Radiological Emergency Preparedness Plans (" REPS") for fixed nuclear generating facilities within FEMA's Region VI. I 8303310266 830330 PDR ADOCK 05000445 T PDR

participated in FEMA's review of the state of emergency preparedness at CPSES.

(Benton) I was formerly responsible for the review and evaluation of off-site REPS for fixed nuclear generating facilities within FEMA's Region VI. During that time, I participated in FEMA's evaluation of the state of emergency preparedness at CPSES.

Q.4 Gentlemen, have you prepared statements of professional qualifications?

A.4 (LookabaughandBenton) Yes. Mr. Lookabaugh's statement of provessional qualifications was received into evidence at Tr. 5762.

Mr. Benton's statement of professional qualifications was received into evidence at Tr. 5761.

Q.5 Are you familiar with the Memorandum from Lee M. Thomas, Associate Director, State and Local Programs and Support, FEMA, to William Dircks, Executive Director for Operations, NRC, entitled, " Interim Findings on Comanche Peak Steam Electric Station Offsite Emergency Preparedness," dated September 29, 1982?

A. (LookabaughandBenton) Yes. This one page memorandum is the FEMA Interim Findings for CPSES, which was referred to in our previous written testimony for the September 1982 hearing session (NRC Staff Exhibit 203). A copy of the FEMA Interim Findings for CPSES is attached to our testimony.

Q.6 Gentlemen, was the FEMA Interim Findings released to the public prior to the filing of your prefiled written testimony for the September 1982 hearing session?

A.6 No. The FEMA Interim Findings was released after the filing of our written direct testimony (Staff Exhibit 203) as well as our oral testimony at the September 1982 hearing session (Tr. 5696-5742).

Q.7 Messrs. Lookabaugh and Benton, please identify the attachments to the FEMA Interim Finding.

A.7 The first attachment, " Hood County, Texas, Evaluation of Radiological Emergency Response Plan for Comanche Peak Steam Electric Station," is an evaluation of the Hood County emergency plan which was prepared by Argonne National Laboratories for FEMA.

This document is 13 pages in length. The second document, "Somervell County, Texas, Evaluation of Radiological Emergency Response Plan for Comanche Peak Steam Electric Station," which is 14 pages in length, is a similar evaluation prepared by Argonne National Laboratories. Both of these documents were submitted to the FEMA Radiological Assistance Committee (RAC) on July 21, 1982, and were prepared before our prefiled written testimony (Staff I

Exhibit 203), as well as our oral testimony at the September 1982 hearing session.

The third document, "RAC Review Comments, Texas State Planned Hood and Somervell County Plans," is a cover letter for the RAC Consoli-dated Coments for the State, and Hood and Somervell County emer-i

gency plans. The RAC Consolidated Comments for Hood and Somervell County Plans is a four page attachment to the letter. It is followed by the RAC Consolidated Comments for the Texas State Plan, which is 5 pages in length. The RAC Consolidated comments were prepared in early August, and were prepared before the filing of our written direct testimony (Staff Exhibit 203), as well as our oral testimony at the September hearing session. The RAC Consolidated Comments incorporate the Argonne National Laboratory evaluations referred to above.

f The final two documents, " FEMA Review of Texas REP Plans," a 9 page document, and " Hood /Somervell Counties REP Plans, Organization," a 7 page document, are FEMA Region VI's review of the State's and counties' emergency plans. They were prepared in July, 1982, and were FEMA's input to the RAC Consolidated Comments. These documents were prepared prior to the filing of our written direct testimony (Staff Exhibit 203) and our oral testimony at the September 1982 hearing session.

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Q.9 Do the FEMA Interim Findings for CPSES (September 29,1982) change your conclusions regarding the state of emergency preparedness for CPSES, as contained in your written direct testimony (Staff I

Exhibit 203) or your oral testimony at the September,1982 hearing session?

l A.9 (Lookabaugh and Benton). No. The FEMA Interim Findings confirm, 1

l and are consistent with, our previous written and oral testimony.

1

Q.10 Do the attachments to the FEMA Interim Findings for CPSES change your written direct testimony (Staff Exhibit 203) or your oral testimony at the September 1982 hearing session?

A.10(LookabaughandBenton) No. Since these documents were prepared before our written and oral testimony, our written and oral testi-mony more accurately reflected the state of emergency preparedness for CPSES at the time of the September 1982 hearing session.

Q.11 Have you received any information since the September 1982 hearing session that would adversely affect your testimony and conclusions regarding the state of emergency preparedness for CPSES?

A.11 (Lookabaugh and Benton) No.

Q.12 Have you received any information since the September 1982 hearing session that would adversely affect the conclusion of the FEMA Interim Finding for CPSES, which states:

Based on this initial review of the relevant State and County Plans there is reasonable assurance at this time i that the off-site protection of the public's health and safety is adequate.

A.12 (Lookabaugh and Benton) No. In fact, we have reviewed additional information from the State and the Counties that favorably address many of the previously unresolved objectives and review elements set forth in the RAC Consolidated Comments for CPSES.

. _ _ _ . _ . . _ =

Federal Emergency Management Agency Washington, D.C. 20472

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(/ i,\

SEP 29 B82 EMORANDUM FOR: William Dircks Executive Director for Operations

.S. ulatory Commission FROM: ee M. Thomas )

Associate Director State and Local Programs and Support ,

SUBJECT:

Interim Finding on Commanche Peak Steam Electric Station Offsite Emergency Preparedness Attached is a copy of the Federal Emergency Management Agency (FEMA) Region VI Radiological Assistance Committee and FEMA Region VI review of the State of Texas Emergency Management Plan and the Mood and Somervell Counties Emergency Operations Plans. These offsite plans were submitted for the Comanche Peak Steam Electric Station.

The review of the plans was based on Section II (A thrdugh P), Planning Standards and Evaluation Criteria, NUREG-0654/F.EMA-REP-1, Rev.1.

Based on this initial review of the relevant State and County Plans there is reasonable assurance at this time that the off-site protection of the public's health and safety is adequate. The first joint exercise for the demonstration of off-site preparedness based on these plans is scheduled for early next I calendar year.

Attachment As Stated 1

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. Bood County, Texas Evaluation of Radiological Emergency Response Plan

• For Comanche Peak Steam Electric Station

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A. Assignment of Responsibility (Organizational Control)

Planning Standard Primary responsibilities for emergency response by the nuclear l facility licenses, and by state and local organizations within the.,

l Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

i Location / Item Refarence'S Conssent A.1.a.  ? Page 22, Sec. VIII and page 43, Sec. III.A and

3. are referenced. However, none of those sections identify Federal and private sector response organizations.

A.1.b.

• Sec. V.A page 6 and Sec. IV. A and B.

j ,

A.1.c.

• Tab. 1 of Annex F, p. 52; Annex F, p. 31; Annex F, p. 39; Annex B, p. 41 l ,

A.1.d.

• Sec. V.A p. 6; Sec. 7, A.1, p. 7; Tab. 1,

p. 52, Annex F.

A.1.a.

• Sec. V.3.1, Annex F.

A.2.a.

• Sec. VI.A and B, pp. 7-20; Sec. Y, Annex F, pp. 46-47; Tab. 1. Annex F.

A.2.b .

• Sec. I, p. 4.

A.3  ? The cross reference N/A indicates that no organizations other than the local governments will have any emergency response role within the Emergency Planning Zones. However,'it is conceivable that at least some assistance .

from state and federal agencies could be needed.

• A.4 e' Sec. V.N. Annex F. .

C. Emergency Response Support and Resources Planning Standards ,

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Hood County, Texas Eg3 2

. Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate state and local staff at the licensee's near site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned responsa have been

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r identified.

Location / Item Reference & Comument C.1.a. N/A Not a NUREG criteria for local plans.

C.1.b. N/A Not a NUREG. criteria for local plans.

C.1.c. 7 Sec. IV.D is ' cited in the cross reference for resources available to support Federal response.

Bovaver, this section shows only the duties of the response support group and no mention is made of available resources.

C.2.a N/A only the Bureau of Radiation Control will send representatives to the near site EOF. (See Tab.1, Chap.1, par. e of Sec. Y, appendix 7 to State plan).

C. 2.b . N/A Licensee responsibility.

C.3 N/A State plan identifies radiological laboratories.

C.4

• Sections III.A and III.3, Annex F. identify l

1 organizations that can be relied on for emergency assistance; but the nuclear facility should be added.

D. Emergency Classification System Planning Standard .

A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and state and local response plans call for reliance on information provided by facility licensees for determination of minimum initial off site response measures. .

Location / Item Reference & Comment ,

D.1 N/A Licensee responsibility i D.2 N/A Licensee responsibility D.3

• Documented in Sec. VI, Annex F..  ;

D.4 ,

• Sections I through VII; attachments A through R, Manual of Emergency Procedures, Annex F.

- ' Cross reference D.4 should be corrected to

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Hosd C:unty, Tczas 7:g2 3 include Sections I through VII, pages53-142.

E. Notification Methods and' Procedures Plann4 g Standard Procedures have been established for notification, by the licensee, of ,

state and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and follow up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the, populace within the plume exposure pathway Emergency Planning Zone have been established.

Location / Item Reference and Conment E.1

• Sections I through YII.and Attachments A through C, Manual of Emergency Procedures, Annex F.

E.2

• Attachment D and Sec. II, Manual of Emergency Pro-cedures, Annex F. .

E.3 N/A Licensee responsibility.

E.4 N/A Licensee. responsibility.

E.5

• Attachment F. Manual of Emergency Procedures, Annex F.

E.6

• Attachment F and Section VII, Manual of Emergency Procedures, Annex F.

E.7

• Provisions are made in Attachment 0, Manual of Emergency Procedures for written messages to the public .but samples are not included in Attachment 0.

F. Emergency Communications Planning Standard l Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public. .

Location / Item Reference and Cotement F.1.a.

• Sec. V.B. Annex F.

F.1.b . N/A There are no contiguous state or local governments within the plume exposure path-l -

way Emergency Planning Zone. Communications with organizations outside the plume exposure

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Hord Csunty, Tcza3 ,

Page 4 pathway Emergency Planning Zone is a state function and is the responsibility of the District Disaster Headquarters at Waco.

F.1.c. N/A Comment for F.1.b applies.

F.1.d.

• Attachment D Manual of Emergency Procedures, Annaz F.

F.1.e.

• Attachment I,'and Sec. II of the' Manual of Emergency Procedures, Annex F.

F.1.f. N/A Licensee responsibility.

F.2

• Attachment i and Sec. IV of the Manual of

'mergency E Procedures, Annex F.

F.3 N/A Tab.1, Appendix 7 eekes the State Department of Public Safety responsible for testing com-munications systems.

G. Public Education and Information Planning Standard .

Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dis-semination of information during an emergency (including the physical ,

location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.

, Location / Item Reference and Comnent

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G.1

• Attachments F and Sec. VII, Manual of Emergency Frocedures, Annex. F.

G.2  ? The cross reference cites Sec. IV.B.3, page 7 of the Hood County Emergency Operations Plan and Sec. IV, A, pages 128 and 129 as <

providing information for transients. ,

However, the information contained therein is ,

specifically for residents. These sections should also contain detailed information for transients.

G.3.a.

• Sec. VII.B.3 and B.4, Manual of Emergency Procedures, Annex F.

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Bood County, Texas ,

Page 5 l G.3.b. N/A Licensee responsibility G.4.a. * -

Sec. VII, III.A. and III.B Manual of Emergency Procedures, Annex F.

G.4.b.  ? The cross reference cites Sec. VII, IV.B.#3 and IV B.5 for arrangements for exchange of information between spokespersons. However, these references are directed tio media brief-hp .

G.4.c.

• Sec. VIII, IV.B.7, Manual of Emergency Procedures, Annex F.

G.5  ? The cross reference cites Sec. VII. III.B but no mention is made therein of a coordinated program to be conducted at least annually to acquaint the media with the emergency response plans and information on radiation.

H. Emergency Facilities and Equipment ,

Planning Standard Adequate emergency facilities and equipment to support the emergency response are provided.

Loeaeion/ Item Referenee/Comunent .

H.1 N/A H.2 N/A B.3

• Section V, Part 3 of the Emcrgency Operations Plans,Section III, Part 3 of the Hood County Annex F, and Attachment B, Standard operating procedures.

H.4

• Section I, Procedures for the Executive Group in combination with Attachment B, Standard Operating Procedure for the EOC.

H.S.a-d ,

N/A ,

H.6 a-c N/A H.7  ? Annex F,Section V.M states that the Radiological Defense Officer will provide assistance as requested to the Texas Department of Health if resources are available. This does not address the

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Bood County, Texas ,

Fage 6 requirements of NmtEG 0654-H.7 that each organization, where appropriate, shall provide for offsite radiological monitoring equip 6ent in the vicinity of the nuclear facility.

gection VII Part 3 of the state plan described the assignment of seeident assessment responsi-bilities. The state appears to have adequate equipment and personnel to determine the magnitude of the emergency, and to provide monitoring of the radioactivity. The county should state what eguipment, if any, is available to measure whole body gasuna ex-posures and airborne radiciodine concentra-tions. A plan for transmitting these data, if any, to the EOF should be included.

'H.8 N/A H.9 N/A

. H.10  ? See comment for H.7 above.

H.11 7 See comment for H.7 above. .

H.12 7 See comment for H.7 above.

I. Accident Assessment Planning Standard ,

Adequate methods, systems and aquipment for, assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Location / Item Reference / Comment I.1 N/A-I.2 n/A I.3 N/A I.4 ~

N/A I.5 n/A .

I.6 N/A ,

I.7 7 Hood County Annex F.Section V.}! does not address I.7 which requires that"Each organi-

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sation shall describe the ' capability and

. resources for field monitoring,within the J' ----,-s

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Hood County, Texas -

Page 7 plume exposure EPZ which are intrinsic

' parts of the concept of operations for the facility." If the county is not depended

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upon to supply radiological data to the state and to the utility for use in assessing the magnitude of the emergency, the, plan should so state.

4 I.8 7 See cosment for I.7 ,

I.9 N/A I.10 N/A

. . I.11 N/A J. Protective Response Planning Standard A range of protective actions have been developed for the pluma ,

exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistant vfth l yederal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

Location / Item Reference / Comment e J.1 ,

N/A J.2 7 This is not addressed. The utility is primarily responsible for this but cooperative arrangements for sheltering, decontamination, medical attention, etc. are needed.

J.3 N/A J.4 . N/A' J.5 N/A J.6 N/A ,

J.7 N/A .

J.8 N/A J.9 7 Attachment I to the Hood County plan for Emergency Husbandry Procedures addresses the

' problem of contamination of human and animal foods in an adequate manner. Gamma ray and

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Botd County, Texas Fene 8 t

the airborne plume are not adequately addressed.

The response indicated in the procedures for the Executive Group is one of ordering i

evacuation or sheixaring when recommended by t the state or by the utility. If this is the case the cross-reference for J.9 should include a reference to Section I - The Executive Group Procedures. , .

J.10.a.

• Attachment G Evacuation Procedures J.10.b.

• See J.10.a.

J.10.c.

• Attachment y, Warning.

J.10.d..

• Attachment C, Evacuation Procedures.

( Tab. 2 - Section II.C.3.

i J.10.e.

• Annex F,Section V, Paragraph L.3.

J.10.f.

• See J.10.e. ,

J .10.. g .

• See J.10.d.

l J.10.h.

• Attachment E - Sheltering.

J.10.i.

• Attachment G.

J.10.j.

• This is adequately addressed in the plan.

The cross-reference should include a reference to Manual of Emergency ProceduresSection II.

J.10.k.

• Attachment G,Section IV, Tab 2, to Annex F.

I J.10.1.

• Attachmant G,Section IV, Tab 2, to Annez F.

J.10.m. N/A J.11 N/A J.12

• Attachment E - Standard operating procedures for sheltering evacuees.

l K. Radiological Exposure Control Planning Standard Means for controlling radiological exposures, in an emergency, are .

established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protection Action Guides.

Location /It'em Reference / Comment K.1 ' N/A o

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Ecod County, Texas Page 9 K.2 , N/A K.3.a.  ? . Iood County Annex F Section V N states that exposure control is the function of the Tazas Department of Health but that the county EDO will assist as requested if resources are available. Attachment G - Evacuation - Tab. 3 lists the contents of the list for roadblock personnel. Only a T1D is to be furnished.

NUREG 0654-K3 requires both self reading (e.g. , pocket ion dosimeter) and permanent I

record dosimeters (p g., TLD). In addition the self reading devices must have appropriate

! sensitivities to permit meeting NUREG-0654, K4.

Each emergency worker should be provided a sensitive direct reading dosimeter (e.g.,

0-200 m Rem) plus a higher range direct reading ,

i dosimeter (e.g., 0-20 Rem) plus a permanent record device (e.g., TLD or film badge) . l Improvements in the plan are needed to insure the availability and proper distribut. ions of appropriate dosimeters. Section VII-B-7 of Appendix 7 to Annex L of the state plan (contamination control) implies that all workers entering a contaminated area will have dosi-matars but the number available, the source

' of supply, etc., is not detailed.

K. 3.b . 7 Dose record forms need to be included in the l

plan and need ter be " distributed to esmergency workers. In addition, requirements neid to be developed for frequent reading and timely reporting of doses to the EOCs by the emergency workers.

K.4 7 The procedure for authorization of emergency workers to incur exposures in excess of PACS needs to be clearly stated in the county plan.

This should clearly name the officin1 who is e

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. should also clearly require that the decision take into account the exposure data from K.3.a.

and K.3.b. above.

K.5.a. 7 The Attachment I - Shelter; Monitoring and

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Frecontamination Procedures of the Hood County plan does not specify action levels for l decontamination. The Tab 1 Chapter 1. Procedure I

5. Part VI does specify action levels foi~inicia . j ting decontamination.

K.5.b. 7 Sections VII.B.8 of Appendix,7 to Annex L of the state plan states that the Bureau of Radiation Protection will advise the local officials in decontamination actions, that are to be conducted in accordance with "NCRP ,

I Raport No. 65." No procedures for the disposal of vastes was found. No procedures were found in the Hood County plan for waste disposal. NCRP Report No. 65 should be made a part of the plan if it is the appropriate procedure to be followed.

K.6 N/A K.7 N/A L. Medical and Public Health Support i Planning Standard Arrangements are made for medical services for contaminated, injured individuals.

/

Locarion/ Item Reference / Comment L.1 . ? Provisions'are made in Attachment Q, Manual of Emergency Operations for listing hospitals. ,

However, the list is not developed. When l

added, this section should list other medical i l

facilities for backup and should state the capabilities for evaluating and treating radiological exposure injuries. .

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Fag 3 11 Hood County, Texas L.2 N/A Licenaea responsibility.

L.3 . N/A Applies to state only.

L.4

• Sec. VI.E.4 of the County Emergency Operations

• Plan makes the Hood County Fire Chief and the l

Pire Chief and Marshalls of the cities

• responsible for transportation of radiological ,

accident victims.

M. Recovery and Reentry Planning and Post-accident operations ,

Planning Standard General plans for recovery and reentry are developed.

Location / Item Reference / Comments N.1 7 Section III.R. Manual of Emergency Procedures,  ;

Annez 7 states that " details and criteria for recevery and reentry "will be provided by the Tazas Department of Realth." Iowever, there is i

no evidence in the plan that general plans and procedures have been developed.

M.2 N/A Licensee responsibility.

N/A State responsibility. $

M.3 M.4 N/A State respons,ibility.

N. Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions

' of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a resnit of exercises or drills are (will be) corrected.

location / Item Reference / Comment N. 7 The cross reference cites the utility emergency I

plan, but the state plan makes some of the '

exercises and drills the responsibility of the .

utility, the Bureau of Emergency Management, and the Bureau of Radiation Control There is no evidence in the local plan that local organizations receive training or participate in exercises and drills or that training pro-

- grams for local emergency response personnel O

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l Bood County, Texas Page 12 j J

have been developed. These comments apply to

• each item in this NUREG-0654 section.  ;

0, ' Radiological Emergency Rasponse Training ,

Planning Standard Radiological emergency response training is provided for those who any be called on to assist in an emergency. .

7 Location / Item Heforance/Cosment N 7 Comument for N, Exercises and Drills, above applies.

P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans

Planning Standard Responsib111 ties for plan development and review and for distribution of esargency plans are established, and planners are properly trained.

Location / Item Reference / Comment P.1

• Hood County Emergency Operations. Plan Sec. VI.3.e.p.8.

- P.2

• Hood County Emergency operations Plan Sec. VI.3.b.p.8.

P.3 *- Hood County Emergency Operations Plan l Sec. VI, 3, p.8.

P.4

• Hood County Emergency Operations Plan Sec. II, p.23.

P.5 7 The cross reference is marked N/A. The state plan, Sections XI.B and II.D. Annex 7 addresses only state plans and changes.

Provisions should be made for forwarding local plans and changes to all responsible emergency response personnel. ,-

P.6 7 Supporting plans and their sources are not listed for the local plans. The cross-reference is marked N/A. The listing of

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supporting plans found in Tab.1, Intro-duction Sections III and IV, Annex 7, state plan pertains only to supporting plans for

- 'the state.

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Hood County, Texas Page 13 4

F.7

• Annex A, Sec. VII; Manual of Emergency Procedures, Annex 7.

F.8

• Table of contents and Cross References are # included.

P.9 N/A Licensee responsibility.

F.lb 7 The cross reference indicates that provisions for updating telephone numbers are in the utility emergency responsa' plan. They should also be included in the local plans.

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- Sousservell County, Texas l Evaluation of Radiological haargency Easponse Pisa l For Comanche Peak Steam Electric Station I

' l A. Assignment of Responsibility (Organizational Control) ,,

Planning Standard Prihary. responsibilities for emergency response by the nuclear facility licensee, and by state and local organizations within, the Emergency Planning Zones have been assigned, the emergency responsi-bilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Location / Item Reference / Comments A.I.a.  ? Page 20, Sec. VIII add page 43, Sec. III.A and B. are referenced. Bovaver, none of those sections identify Federal and private sector response organizations.

A .1.b . * -

Sec. V.A. page 6 and Sec. IV.A and 3, page 44.

A.1.c.

• Tab. 1 of Annex F, p. 51; Annex F, p. 31; Annex F, p. 39; Annex 3, p. 41.

A.1.d.

• Sec. V.A, p. 6; Sec. 7, A.1, p.7; Tab. 1, p. 31.

A.1.a.

• Sec. V.E.1, Annex 7.

A.2.a.

• Sec. VI.A and 3, pp. 7 - 17; Sec. V, Annex F, pp. 45-48; Tab. 1. Annex F.

A.2.b .

• Sec. I, p. 4; Attachment 2/1, p. 23.

A.3 7 The cross reference N/A indicates' that no organizations other than the local governments will have any emergency ,

response role within the Emergency Planning Zones. However, it is conceivable that at least some assistance from state and federal agencies could be needed.

A. 4

• Sec. V.N, Annex F.

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Sommervall County, Texas , 7:33 2 C. Emergency Response Support and Resources

' plannin's Standard .

Arringements for requesting and effectively using assistance. 1 resources have been made, arrangements to acconnodate state and local e staff at the licensee's near site Emergency Operations Facility have been made, and i other organizations espable of augmenting the planned response have been identified.

_ Location / Item Reference / Comments I

C .1. a . - N/A Not a NUREG criteria for local plans.

C .1.b . N/A Not a NUREG criteria for local plans.

c.1.c.  ? Page 138, Sec. IV.D. Attachment B. Manual of Emergency Procedureg. Annex 7, is cited in the cross reference for resources available to support Federal response. However, this section shows only the duties of the response support group arid no mention is made of available resources. .

C.2.a. N/A Only the Bureau of Radiation Control will send representatives to the near site EOF. (See Tab. 1, Chap. 1, par. C of Sec. V. Appendix 7 to S'cate plan).

• C.2.b. N/A Licenses responsibility.

C.3 N/A State plan identifies radiological laboratories.

C.4

• Sections III.A and III.3, Annex F, identify organizations that can be relied on for emergency assistance; but the nuclear facility is not included.

D. Emergency C3,assification System .

Planning Standard ,.

A standard emergency classif.ication and action level scheme, the .

basis of which include facility system and affluent parameters, is in use by the nuclear facility licensee, and stata and' local response plans call for reliance on information provided by facility licensees for determina -

tion of minimum initial off site response measures.

Location / Item Reference / Comments D.1 N/A Licensee responsibility l

l I

l

Sonenerv:11 County, Tczas Page 3 D.2 N/A L'icensee responsibility l

D.3

• Documented in Sec. VI. Annex P.

D . 2.

• Sections I through VII; Attmeh= ants A through 1, Manual of Emergency Procedures #,

Annez F. Cross reference D.4 should be ,

corrected to include Sections I through VII, pages 55 - 130. -

E. Notification Methods and Procedures . .

Planning Standard Procedures have besn established for notification, by the licensee, of state and local response organizations and for notification of emergency personnel by all response organizatione; the content of initial and follow up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been, established.

I Location / Item Reference /Conenents E.1

• Sections I through VI and Attachment A

~

through D, Manual of Emargency Procedures, Annex F.

E.2

• Attachment D, and Sec. II, Manual of Emergency Procedures, Annex F.

E.3 N/A Licensee responsibility.

E.4 N/A Licensee responsibility.,

E.5

• Attachment F. Manual of Emergency Procedures, Annex T.

E.6

• Attachment F, and Sec. VI, Manual of Emergency Procedures.

E.7

• Provisions are made in Attachment 0, Manual of Emergency Procedures for written messages to the public, but samples are not included in ,

Attachment O.

F. Emergency Communicacions ,

Planning Standard ,

Provisions exist for prompt communications among principal response e

b , . , . ,-- - , . - -,- --- ,, . , , - - . .- ', _ . . , . - - . _ ,,__ -,._.,--

Pa'ge 4 Sommerve11 County, Texas f

organizations to emergency personnel and to the public.

Location / Item Reference / Comment

~

F.1.a.

• Sec. V.B. Annex F. ,

F.1.b . N/A There are no contiguous state or local *

• governments within the plume exposure pathway Emergency Planning Zone.. Com-munications with organizations outside the .

plume exposure pathway Emergency Planning Zone is a state function and is the responsibility of the District Disaster Headquarters at Waco. ,

F.1.c. N/A Comment for F.1.b. applies.

F.1.d.

• Attachment D, Manual of Emergency Procedures, Annex F.

F.1.e.

• Attachment D and Sec. II of the Manual of Emergency Procedures, Annex F.

F.1.f. N/A Licensee responsibility.

F.2

• Attachment E and Sec. IV of the Manual of Emergency Procedures, Annex F.

F.3 N/A Tab. 1, Appendix 7 makes the State Department of Public Safety responsible for testing communications systems.

G. Public Education and Information .

Planning Standard Information is made available to the public on a periodic basis on how.they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dis-semination of information during an emergency (including the physical location or locations) are established in advance, and procedures for j

l coordinated dissenination of information to the public are established.

Location / Item Reference /Conssents G.1

• Attachments F and Sec. VII, Manual of Emergency Procedures, Annex. F.

s. .

~ ,

Ssamerv311 Cokuty Texa3 ,

Pcss 5 G.2 7 The cross reference cites the Manual of Emergency Procedures, Sec. IV, Part IY, A, pages 118:and 119 as providing information for transients. Bowever, the information/

~

contained therein is specifically for residents. These sections should also contain detailed information foir transients.

G.3.a. '

• Sec. VI.B.3 and B.4, Manual of Emergency N -

Procedures, Annex F, page 119.

G . 3.h . N/A Licensee responsibility.

G.4.z.

• Sec. VI, III.A. and III.B. Manual of Emergency

. Procedures, Annez Fe G.4.b . 7 Sec. VI, IV.B.3 and IV.B.5, p. 119.

G.4.c.

• Sec. VI, IV.B.7, Manual of Emergency Procedures.

Annex F.

G.5 7 The cross reference cites Sec. VI III.B. but x no mention is made therein of a coordinated program to be conducted at least annually to acquaint the media with the emergency response plans and information on radiation.

H. Emergency Facilities and Equipment Planning Standard Adequate emergency facilities and equipment to support the emergency

. response are provided:

l ,

L Location / Item Reference / Comments H.1 . . N/A ,

H.2 . N/A s,

H.3 ,* Section V Part B of' the Emergency operating Plan;Section IV Part B of Sommervell County, Annex F ; and Attachment B, Standard Operating Procedures for the EOC.

H.5 a-d N/A H.6 a-c N/A H.7 3 Sommerve11 iCounty Annex F Section V M states

,. that the Radiologien1 Defense Officer will b

O e o

Sommerve11 County, Texas ,Page 6 provide assistance as requested to the Texas

. Department of Health if resources are available. This does not address the reqpire-ments of NURIG-0654-R.7 that "Each ors =a4*=-

tion, where appropriate, shall provide for offsite radiological monitoring equipment in the vicinity of the nuclear facility."

Section VII Part 3 of the State Plan describes the assignment of accident assess-ment responsibilities. The state appears to have adequate equip, ment and personnel to determine the magnitude of the emergency and to provide monitoring of the radioactivity.

The county should state what instruments if any are available to measure whole body I gamma exposures and airborne radio iodine, concentrations. A plan for transmitting ,

these data, if any, to the EOF should be included.

H.8 N/A H.9 N/A ,

4 E.10  ? See H.7 above.

H.11 7 See H.7 above.

H.12  ? See B.7 above. .

I. Accident Assessment Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use. ,

Location / Item Reference / Comments I.1 N/A I.2 N/A i

I.3 N/A I.4 N/A I.5 N/A e

e

-~ -

=, ..

. Sommerve11 County, Texas page 7 I.6 N/A I.7 7 Sommerve11 County Annex F Section V.M does not address I.7 which requires that "Each ,

organization shall describe the capability

, and resources for field monitoring within the plume exposure EPZ which are an intrinsic part of the concept of operations for the

. facility." If the county is not depended upon to supply radiological data to the state and to the utility for use in assessing the magnitude of the emergency, the plan should so state. -

I.8 7 See comment for I.7.

I.9 N/A I.10 N/A I.11 '. N/A J. Protective Response Planning Standard A range of protective actions have been developed for the plume exposure pathway EPZ for eme'rgency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for. the ingestion exposure pathway IPZ appropriate to the locale have been developed.

Location / Item Reference / Comments J.1 N/A J.2 7 This is not addressed. The utility is primarily responsible for this requirement but cooperative arrangements for sheltering, decontamination, medical treatment, etc.

are needed. -

J.3 N/A

,J.4 N/A J.5 N/A .

J.6 N/A

Page A Sommerve11 County, Texas ,

J.7 N/A .

J.8

• N/A Attachment K to the Sommerve11 County plan .

J.9 7 is cited in the cross reference. This

- attachment addresses Emergency Husbandry Procedures in an adequate menner, _but Gamma ray exposure and radiciodine exposures directly from tha airborne plume are not adequately addressed. The response indicated in the procedures for the Executive Group is one of ordering evacuation or sheltering when recommended by be State or by the Utility. If this is the case, the cross reference should include a reference to Section I - The Executive Group Procedures.

• Attachment G, Evaluation Procedures.

J.10.a.

J.10.b.

• See J.10.a. .

J.10.c.

• Attachment F, warning.

• Attachment G, Evacuation Procedures Tab. 2, J.10.d.

i Section II C 3 l

• Sommerve11 County (Annex F,Section V 4 J.10.e.

state that the ItD0 vill as'sist the State Department of Health in administering l

radioprotective d~ rugs if requested.

J.10.f.

• See coment for J.10 e.

l J.10.g.

• See comment for J.10.d. '

J.10.h.

• Attachment H - Shelter - Describes location and procedures.

J.10.1.

• Attachment G - Evacuation Procedures.

\

• This it adequately addressed in the plan.

), J.10.J.

- The cross reference should include a reference e

e g a g & l

Sommerve11 County, Texas p g. g l

to the Manual of Emergency Procedures -

. Section II.

J.10.k.

• Possible impeM= ants to evacuation (e.g.

4 ice on roads) is addressed in the evacua-tion plan, Attachment G.

J.'10.1.

• The evacuation plan, Attachment.G includes analyses of times required for evacuating each sector under each of several weather conditions.

J.10.m.

• N/A

, J.11 N/A t.

J.12

• Attachment E - Standard Operating Procedures l

for Sheltering Evacuees.

K. Radiological Exposure Control Planning Standard ,

Means for controlling radiological exposure, in an emergency, are established for emergency workers. The means for controlling radiological.

exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Location / Item Reference / Comments K.1 N/A K.2 N/A K.3 7 Sommervell County' Annex F Section V M l

states that exposure control is the function l of the Texas Department of Health but that the county RDO vill assist as requested if resources are available. Attachment ~G Evacuation - Tab. 3 11stis th'e contents of the kit for roadblock personnel. Only a '

TLD is to be furnished. NUREG-0654-K3 requires both self reading (e.g. pocket ion chamber) and a permanent record desi-meter (e.g. TLD). In addition, the self m.,_ _ . ,_ _ _ , _ _ . _. _

. = - . . . -

Sonsnervall County, Texas Page 10 I

reading devices must have appropriate

, sensitivities to permit meeting IMtEG 0654-K4. Each emergency worker should be ,

. provided a sensitive direct reading dosimeter (e.g. 0 - 20 m Rea) plus a higher range direct reading dosimeter (e.g. 0 - 20 Ram) plus a permanent record device (e.g. TLD or film badge). Improvements in the plan are needed to insure the availability and proper distribution of appropriate dosi-asters. Section VII-B-7 of Appendix 7 to Annex L of the StatEPlan (Contamination l

Control) implies that all workers entering l

a contaminated area vill have dosimeters but the number available, the source of supply, etc., is not detailed.

I K.3.b.  ?

Dese record forms need to be included in the plan and need to be distributed to emergency workers. In addition, require-ments need to be developed to insure timely readings and timely reporting of doses to the EOCs by the emergency workers.

K.4  ? The procedure for authorizing emergency workers to incur exposures in excess of -

PACS needs to be clearly stated in the county plan. This should clearly name the official who is able td authorize this action. The procedure should also clearly require that the decision take into account the exposure data from K.3.a and K.3.b above.

K.S.a.  ? The Attachment H - Shelter - Monitoring and Decontamination Procedures for the l

1 Sommervell' county plan does not specify action levels for decontamination. Sectio.n

~

VII B-7 of the State Plan - Contamination 1 . .

. ~ . - . . . . . . . - - . . .

' ^

Sommerve11 County, Texas Page 11

. Control - does not specify action levels for

. decontamination.

K.5.b. 7 Section VII B 8 of Appendix 7 to Annex L of the State Plan specifies that the Bureau of Radiation Protection will advise the local officials in decontamination actions that are to be conducted in accordance with

%CRP report No. 65." No procedu e for the-disposal of contaminated wastes was found.

No procedure was found in the Sommerve11 ',

county plan for vast,e, disposal. "NCRP Raport No. 65" should be made a part of the plan if it is the appropriate procedure to be followed.

L. Medical and Public Health Support Planning Standard .

Arrangements are made for medical services for contaminated injured individuals.

Location / Item Reference /Coments L.1 7 Provisions are made in Attachment Q, Manual of Emergency Operations for listing hospitals.

However, the list is not developed. When added, this section should list other medical facilities for back up and should state the capabilities for evaluating and treating radiological exposure injuries.

L.2 N/A Licensee responsibility.

L.3 N/A Applies to state only.

L.4

• Sec. VI.B.4 of the State Emergency Opera-l .

1 tions Plan.

M. Recovery and Reentry Planning and Post-accident Operations Planning Standard General plans for recovery and reentry are developed.

Location / Item Reference /Coments M.1 7 Section I, Par III S, page 69, Manual of e

e

_ _ - . - - - - - - m-- - - --,-w-

. ~ . - . - . . . . . ..

Somarvell County, Texas ,

Page 12 Emergency Procedures, Annex F, states that details and criteria for recovery and reentry "will be provided by the Texas ,

Department of Health." However, there is

, no evidence in the plan that. general plans and procedures have been developed.

M.2 N/A ,

Licensee responsibility.

. M.3

• Sec. 3. Par. III L p. 94. This should be added to the cross reference.

M.4 N/A State responsibility only. Reference to

, appropriate section,of state plan. -

N. Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencias identified as a result of exercises or drills are (will be) corrected,

~

j Location / Item Reference /Connents N. 7 The cross reference cites the utility emergency plan; but the state plan makes some of the exercises and drills the l responsibility of the utility, the Bureau of Emergency Management and the Bureau of Radiation Control. Ther's is no evidence in the local plan that local organizations receive training me participate in exercisas and drills or that training programs for local emergency response personnel have been developed. These consnents apply to each item in this NURIG-0654 section.

O. Radiologic,a1 Emergency Response Tra'ining Planning Standard Radiological emergency response training is provided for those who may be called on to assist in an emergency. . ,

k a

• e 9

Sonumerv011 County, Texas Page 13 Location /Icem Reference /Conssents 0 . _7 Comment for N, Exercises and Drills, above applies.

e P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans P1maning Standard Responsibilities for plan development and review and for distribu '

tion of emergency plans are established, and planners are properly trained.

Location /Itam Reference / Comments P.1

• Sonsnervell County Emergency Operations Plan Sec. VI.2,.g, p. 8. .-

P.2

• Sonsnervell County Emergency Operations Plan Sec. VI.2.d. p. 8.

P.3

• Soncnervell County Emergency Operations Plan Sec. VI, 2, p. 8.

P.4

• Sonumerve11 County Emergency Operations Plan Sec. XI. p. 23.

P.5  ? The cross reference is marked N/A. The state plan, Sections XI.B and II.D, Annex 7 addresses only state plans and changes.

Provisions should be made for forwarding local plans and changes to all responsible emergency response persont.al.

P.6  ? Supporting plans and their sources are not listed for the local plans. The cross reference is marked N/A. The listing of supporting plans found in Tab.1, Introduction Sections III and IV, Annex 7, state plan.

pertains only to supporting plans for the ,

state.

P.7

• Annex A, Sec. VI, Manual of Emergency .

Procedures, Annex 7, p. 132.

P.8

• P.9 N/A Licensee responsibility.

e er

- - - -' - ' ^ -

5:mmervall County, Tcxas Page 14 P.10  ? The cross reference indicates that provisions for updating telephone numbers are in the utility emergency response plan. They should l also be included in the local plans. l i

l O

E

. e e

= n 4

.e RAC REVIEW COMMENTS -

Texas State Plan and ,

Hood and Somervell County Plans

REFERENCES:

State of Texas Emergency Management Plan Texas Department of Health. Annex L Bureau of Radiation Control, Appendix 7 Fixed Nuclear Facilities Accidents, Tab 1 Comanche Peak Steam Electric Station, Chapter 1 Hood and Somervell County Emergency Operations Plan Attachments 1 and 2

. Annexes A-F -

Manual of Emergency Procedures Sections I-VII .

l AttachmentsA-R(SaveI) ,

Tabs ,

t CRITERIA: NUREG-0654, FEMA REP 1 Rev.1 The RAC and their letter designation for the consolidated

. coments are as follows:

l F-FEMA - Federal Emergency Management Agency i

N-NRC - Nuclear Regulatory Comission l E-DOE - Department of Energy P-EPA - Environmental Protection' Agency R-FDA - Food and Drug Administration H-HSA - (HHS) Health Services Administration '

T-DOT - Department of Transportation '

A-USDA - U. S. Department of Agriculture

• L - Argonne National Laboratories '

i (FEMAcontract) -

l C-DOC - Department of Comerce (no review requested) l

HOOD AND SOMERVELL COUNTY PLANS RAC CONSOLIDATED COMMENTS Agency C0tHENTS Element A.1, a . L The plan does not identify the Federal organizations that should be party the overall response organization.

A.3. L There is no concise definition as to the need or lack of need for assistance from Federal and state agencies regarding emergency response roles.

F Consider letters of agreement with any other than govern-mental organizations who may respond.

c.1,a. F Can local government request Federal / military assistance directly?

L The section shows only duties of the response support Col .c.

group and no mention is made of available resources.

C.2.a. F plan does not designate local official to serve as representative at EOF.

C.4. F L tters of agreement may be appropriate.

E.3. F Indicate not designated state / local planning responsi-bility. However, feel this element should be addressed by state and local. (See page 156, warning message "Similarto")

E.6. T Time required for notifying and informing public of accident / incident not noted.

F.1.b. F No provisions for comunications with contiguous local governments (eg. through DPS District Office, Waco).

F.2. F Plans indicate N/A as does state plan. Local plans should address this element (capability to comunicate between ambulance / hospital.

G.2. F,L Lack of provision for infomation to transient population.

G.4.b. L Section VII IV, B.3. and 5. regarding arrangements for exchan'ge of information between spokespersons is. directed

. mainly at media briefings.

G 4,c, F Suggest telephone number or central locatirn for factual infomation and disspelling runors.

G.5. F,L No provisions or programs to acquaint media with' plans, radiation and points of contact on annual basis.

~~- _ _ _ _ _ _ _ _

._.___m _

Hood & Somervell County Plans Element Agency Coments H.7. L Does not address NUREG-0654 regarding off-site radio-logical monitoring equipment requirements.

H.10. L' Same as H.7.

H.11. L Same as H.7. .

H .12.- L Same as H.7.

I.7 L Plans should state that the county does not need to be.

.~ depended upon .to supply radiological data to the state and utility. .

I.8. L Same as I.7. -

J 2. L Not addressed. Need cooperative agreements for shelter-ing, decontamination, medical treatment, etc. of on-site personnel.

J.9. L Gama and radio-iodine exposure in the ingestion pathway

- not adequately addressed. -

J.10.a. F No maps of evacuation areas. Lack of precise evacuation T procedums (assume these will be included in public information. package).

J.10.c. F Outdoor warning devices to cover entire 10-mile EpZ -

hownotifyhardofhearing?

J.10.d. F No provisions for hard of hearing or handicapped per-sons not institutionalized. ,

J.10.g. F Plan should identify residents not having' access to j T transportation and assure capability for evacuation.

Transportation resources not listed.

J.10.h. F Shelter facilities should be outside 10-mils EpZ.

Glenrose High School listed as shelter facility and is within 10-mile epi.

i t

T . Shelter facilities not located. .

J.10.1. F Tab 2 - misspelled word. " Area" section is upside down.

K.3.b. L Procedures for reporting dose readings by emergency workers should include more frequent readings and excessive exposure procedures should be addressed.

Instructions for public who might move into exclusion areas should be provided.

, _ . -_ . _ . . . . , - - _ . ~ _ , . . ._.-.i_,,__.._ - .

= - .  :  :. -

Hood & Somervell County Plans , ,

-31 Element Acency Coments K.4. L Who authorizes emergency workers to exceed PAGs? -

K.5.a. L' Monitoring and decontamination procedures do not specify levels for decontamination.

K.5.b. L No procedures for disposal of contaminated weste.

L.1. H L,N No hospital listing. .no backup medical facilities, no listed capabilities for receiving, evaluating, and treating radiologically exposed individuals.

L.2. H No mention of transporting victims.

L.3. F Need letters of agreements from hospitals, need capa-bility of hospitals to accept or treat patients.

N See L.1.

L Need citations from appropriate appendices of hospital plans relative to handling contaminated / injured per- -

sonnel. l L.4. L No capability for handling radioactively contaminated N patients ~ by ambulance services noted. Number of am-bulances available not noted.

M .1. F State plan does not address details of recovery and reentry such as time-phased movement, etc. If this is local plan responsibility, should be addressed.

L No does criteria not cover for recovery)and for local . reentry (state plan R Plans lack procedures for reentry.

N.2.c. N No provisions for emergency medical drills.

N.all F Scenario development primarily responsibility of state.

l However, local plans should indicate willingness of local governments to participate in exercises and drills.

L No evidence that local organizations will participate in exercises and drills or training programs.

0.1.a. R No plans for training of local personnel. ,.

0.1.b. F Local plans should indicate that local organizations participate in appropriate training and if mutual aid pacts exist, all training for those entities will also l be made available.

0.4.a. F Same as 0.1.b. -

s

• 4 O

^ _ . , . , _ _ ___ ,__ _ ___ _ ,,_.._ __ _

• _ _ _ . _ _ _ _ . _ _ , . _ _ _ , . _ _ _ , . _ _ _ _ _ _ _ _ _

Hood & Somervell County Plans El ement Agency Comments 0(General) L Lack of provisions for training of local response groups.

0.5. F Same as 0.1.b.

P.1 F' Plan.does not state qualifications or training for Emergency Management Director / Coordinator.

P.4. F Plans should indicate updates will occur as a result

of plan review.

P.S. F Local plan should contain distribution lists of plan and indicate changes to plan will be dated and marked.

L There should be provisions for forwarding plans and changes thereto to all emergency response personnel.

P.6. F Supporting plans and authority,while cross reference indicates N/A,are found on Page 2 as II and I respectively.

L Supporting plans and sources not listed for local plans.

Listing of supporting plans found in Tab 1 and other parts of plan.

P.8. F. Suggest that. plan organization and addendum be better deffned and tabbed for easy re,ference.

P.10. F Plan should contain revisions for updating telephone numbers on a quarterly basis.

1 -

l l

8

e . /

TEXAS STATE PLAN RAC CONSOLIDATED COMMENTS .

Element Agency Coments A.1.a. L The plan dc. is not identify the Federal organizations that should be part of the overall response organiza-

. tions.

A.1.e. L Plan does not specifically state that each respons~e organization can provide 24-hour per day response in manning communication links.

1 A.2.a. R Due to lack of capabilities in fire protection at local level. state should consider augmenting fire protection.

A.3. A Needs to review Annex C.

E Planning for Federal response should be included even though there is no intent to use Federal resources. ,

The plan at a minimum should recognize the need for Federal assistance is at least possible and assign responsibilities and authorities to appropriate staff and establish procedures for requesting Federal assist-ance.

A.4. F Correction t,o cross reference of Appendix 7.

B.2. F -

Generally not considered state / local planning responsi-bility. However may wish to note utility spokesperson responsible for initial notification.

C.1.b. L Although requests for Federal operational assistance is not anticipated, according to Appendix 7 this does not preclude a possible need. (SeeA.3.)

C.3. R University of Texas backup and Texas N&M backup capa-bilities not stated.

N Availability of radiological laboratories not noted.

C.4. L Federal organizations which can be relied on for assist-ance should be named and letters of agreement included.

E .1. R,P Verification in accordance with state SOP; SOPS not available for review.

E.2. N Procedures for mobilizing emergency response personnel -

lacking. -

l e

- - , , . - . , - D -, . - - - --

c. . _ - - . , , . .-

. s Texas State Plan Element Agency Comments E.3. F Indicate not designated state / local planning respogsibility.

However, feel this element should be addressed by state and local .

E.5. .L Local government and DPS plans (Annex R. Appendix 2) should also be in the state plan.

E.6. T Time required for notifying and informing public of

. accident / incident not noted.

L. Same E.5. comments apply.

F.1.a. L Appropriate. sections of Annex R and Annex AA should be included in the state radiological emergency re-sponse plan, Appendix 7, to make the plan more con-venient for emergency response personnel.

F.1.b . L Same comment as F.1.a. applies.

F.1.d. N Description of communication systems need enhancing.

G.4.a, N Who are state spokespersons, by title, who coordinate news media? -

G.5, L References in local plans make no mention of coordi-nated program for the media.

H.4. L EOC activation procedures should be made part of the plan. ,

H.7. - N No listing of specific monitoring equipment.

H.10 N Monitoring capability questioned without list of in-struments.

I H.11. P Monitoring kits do not include equipment operating manuals, site maps, and check sources.

L Question capability of Ludlum 14c for measuring high-range gama radiation.

I.7. L Field monitoring teams lack. high-range non-validating survey meters (see coments for item H.11.)

I.8. N Need BRC activation procedures. Need monitoring team communications capability and deployment times.

I.9. N Radiciodine monitoring not found.

e O -- ., - - , ,

_. .. . . ..m _._m... _ .

Texas State Plan . -

Element Agency Comments I.10 P Suggest plan for PAGs include nomograms.

l J.9. H Appendices 2 and 9 and Annex L not available for review.

J.10.b. L Necessary maps should be available in state EOC, dis-trict EOC, and state plan.

J .10. e . H KI quantity and distribution not provided for in the plans.

J.10.m. H No reference to shelter protection for direct and in-halation exposures or evacuation time estimates listed in the plan.

J.11. H Did not observe any land use maps, detailed c' rop infor-mation maps on food processing facilities maps in the plan.

A Did not receive Annex C (assigned to Texas Department of Agriculture).

J.12. P Did not find monitoring procedures indexed anywhere in attachment H of the CPSES. Monitoring equipment should be specified.

Procedures for reporting dose readings by emergency K.3.b. L I

workers should include more frequent readings and j excessive exposure procedures should be addressed.

! Instructions for public who might move into exclusion areas should be provided.

K.4. P No specific reference to responsible authority dealing with exposure of emergency workers to doses in excess of the PAGs.

L Who authorizes emergency workers to exceed PAGs?

K.5.a. L Monitoring and decontamination procedures do not specify-levels for decontamination.

K.5.b. L No procedures for disposal of contaminated waste.

L.3. F Need letters of agreement from hospitals, need capa-bility of hospitals to accept or treat patients.

L Need citations from appropriate appendices of hospital plans relative to handling contaminated / injured personnel.

k

- , - , - - - - , -,_,-~wn, e- ?,?--,,.,-,._-. _ , - - . , , . . , , - - - . - . - - _ , , - , - - - - - - ,n ,n-

.: z.__...-.....

--^ - - - - - - - -

. o .

l Texas State Plan -

Element Agency -

Coments L.4. F Functional statement insufficient to determine capability for transporting RC patients to medical facilities.'

.L See L.3. coments.

M.1. H Need for general plans to include exposure levels which would be acceptable from ingestion or inhalation pathways.

. Plan should also include potential buildup conditions of contamination in food pathways or transfer of contamina-tion (i.e. drainage from land not potable water supplies)

N.1,a. N NRC rules not referenced.

N.2.d. N Radiological monitoring drills not addressed.

N.all R,P Plans lack procedures for reentry. Plan should indi-cate additional drills / exercises if critiques so indi-cate or as staff changes occur or new equipment is acquired.

A Suggest USDA be involved in drills and exercises.

L No provisions for exercises between 6 p.m. and 6 a.m.

No-dates, times, places noted for exercises or drills.

No time schedule of events. No exercises or drills for such things as simulated casualties ~, off-site fire assistance, rescuing, etc. No provisions for advanced materials for off-site observers.

0.1.a. F Reference should be made to Tab 1. Attachment 4, which further addresses training.

0.4.d. L Information from annexes R,AA, and FF relative to training should be made available for review and included in the plan.

0.4.f. L Same as above.

0.4.g. L Cross reference indicates training for locals; however, not found in local plans.

0.4.h. L Training for medical personnel not responsive. Same comments as found in 0.4.d. applies. -

0.4.J. L Same comments as 0.4.d.

• 0.5. L Cross reference refers to documents not available for review (same coment' as 0.4.d. applies).

P .1. L' Inc6rrect cross : reference . - .

.==

O n

Texas State Plan Element Agency Coments P.7. L No listing by title of detailed implementing procedures, o

P.10. F Telephone numbers should be updated quarterly rather than annually.

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V FEMA rcview of Tcxno REP Plono .

STATE OF TEXAS EMERGENCY MANAGEMENT PLAN

• TEXAS DEPARTMENT OF HEALTH,. ANNEX L BUREAU OF RA,DIATION CONTROL, APPENDIX 7 (RADIOLOGICAL EMERGENCY RESPONSE TAB 1: FIXED NUCLEAR FACILITY ACCIDENTS CHAPTER 1: COMANCHE PEAK STEAM ELECTRIC STATION PROCEDURES (IMPLEMENTING OR STANDARD OPERATING) ,

GF.NERAL:

Plan is wel,1 organized with an excellent cross-reference to NUREG-0654. Both 'the planning and operating concept for the state of Texas are easily identified and portrayed as one in which Radio-logical Emeagency Preparedness is treated as another potential emergency situation with assigned responsibilities being accomp-tished in the same manner as they would for any other emergency.

SPECIFIC: (NUREG-0654 criteria)

A. ASSIGNMENT OF RESPONSIBILITY l.a. The State of Texas Emergency Management plans adequately l identify State, Local Federal and Utility response organ-l izations. (State Plan p.5 and pp.1-2-3 of tab 1 to appendix 7)

O.K.

b. At the State level the Bureau of Radiation Control is organized into 3 operational divisions on a day-to-day basis and into 3 elements for emergencies. (p. 4 ,. ,

appendix 7)

O.K.

c. State Department assignment of responsibilities for radiological emergency response illustrated in block diagram. (p.25 attachment 2 to appendix 7) 0.K.

d. The Director of the Division of Emergency Management as Chairman of the Emergency Management Council has

) overall control. He is advised appropriately by other state agencies. For radiological emergencies in descend-ing order he would be advised by the Commissioner of Health, thechief of the Bureau of Radiation Control and the Chief of Field Operations.

. O.K. -

r

e. Receipt of warning of or actual emergency conditions

! exists on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis both at the district and state level of the Disaster Emergency Management offices. Re-sponse would be initiated at the Public Health Region or State level of response, determined by the Director, Division of compliance and Inspection.

O.K.

~

2.a. Within the state plan, primary and support responsibilities

. for major elements are shown by table. (Annex L)

Functions and responsibilities defined. (Appendix 7 lists functions a function.) nd title of responsible individual for each O.K.

c ..

As'signment of responsibility cont'd .

b. State Emergency Management Plan, Annex L, Appendix 7 all list legal basis for authorities.

O.K.

3. State plan has signature page for state agencies ,

American Red Cross functional statement included M.

(Annex L) Tab 1 to Appendix.7 has responsibilities l i

of other state departments and utility listed. -

Written agreements with U.T. Austin and Texas A&M.

O.K. ,

4. State plan. Capability of Health Department contained in annex L. State EOC (DPS/DEM) capability for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day operations noted. Appendix 7 under

' Logistics Support, Emergency Recall Procedures and Supervisory responsibility assignments by individual

. O.K. (NOTE CORRECTION TO CROSS-REFERENCE OF APPENDIX 7)

B. ONSITE EMERGENCY ORGANIZATION

2. While 0654 does not indicate nor require that this ele-ment should be addressed by State / Local governments m may wish to consider noting the individual (by title) at the licensees facility who is responsible for initiating emergency actions, including recommendations regarding peotective actions to 6ffsite authorities.

s .

C. EMERGENCY RESPONSE SUPPORT AND RESOURCES l.

2.a. State response team will consist of a utility liaison i team (three, 1-man shifts) which will be deployed to I

the near-site EOF. -

O.K.

4. SMARAP listed as first option for outside assistance.

Note also that laboratory facilities at U.T. Austin add TEM &S A&M have agreed to pro 4 ride assistance.

Letters of agreement and cypabilities included.

O.K.

D. EMERGENCY CLASSIFICATION SYSTEM

3. s State ciassification scheme is consistent withFederal Guidance and that of the utility.

. O.K.

4. State response levels are appropriate and cossisten with the stility's and 0654 warning classification.

O.K.

E. NOTIFICATION METHODS AND PROCEDURES l 1. Bases for notification consistent with 0654, appendix 1.

Veriffcation Procedures will be employed.

• O.K.

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', ', 3_

NOTIFICATION METHODS AND PROCEDURES cont'd .

2 State Plan. Each. state department designates three individuals to be contacted in time of emergency.

Within DOH, the Director of Disaster Response has Regional and Bureau Chiefs telephone numbers who in

. turn have designated 3 - 5 individuals for contact. e Appendix 7 indicates once the Bureau of Radiation C Control receives notification it is passed to the Director, Division of C t I descending to 3 branch administrators. Attachment 5 indicates recall procedures by name and telephone number. (See also appendix 7, VI B, " Organization for Emergencies" for mobilization of emergency response personnel.

O.K.

3. Appendix 7 only. Referenced part of plan is a sample message for#which includes'those objectives addressed

• in the 0654 element.

O.K. ,

5. This item to be addressed by local plans and normal DPS procedures (Annex R) to be followed.

O.K.

6. Responsibility assumed by local government and DPS.

(Annex R) -

. OK.

l 7. Local government responsibility. Bureau of Radiation Control will advise local government re: protective me.asures . ,

O.K.

F. EMERGENCY COMMUNICATIONS 1.a. State plan directs agency heads to develop appropriate notification procedures. Reference DPS (Annex R) and .

DEM (Annex AA) as primary responsible agencies for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day communications links. Also references

" loeal plans.

l 0.K.

1 I

b. Annex R (DPS ) , local plans. Contigudous states not applicable to this site. .

O.K. ,

c. DPS/DEM (Annex R and AA respectively) Tab 1 indicates proper channels are DEM/ FEMA Region VI via telephone, '

NAWAS and NACOM.

O.K.

i

d. Annex R. Local plans for communications. Radiation Monitor team members will have radio contact with team

~

leaders.

0.K. '

-- .,.-.,. , gn-, *$w,= - - - . . . _ . . -

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. e EMERGENCY COMMUNICATIONS cont'd -

e. State plan assigns responsibility to agency heads.

Indicates priority of order call to be established within council agencies. Health Department responsibility for alert and activation of emergency personnel is responsi-e bility of the Director of Disaster Response Program.

(Warning and emergency communications is responsibility of DPS. Agency notification is responsibility of DEM)

O.K.

1 -

2. Local plar/ responsibility only. ,

G. PUTnLIC EDUCATION AND INFORMATION

1. Annex AA and local pl'an O.K. ,

2. Local Plan O.K.

I 3.a. Responsibility of State Emergency Public Information officer; Bureau of Radiation Control will have spokes-person who will coordinateDPS withcoordinates licensee andall local public government counterparts.

DEMRcoordinates public,information from information.

State EOC. .

0.K.

( 4.a. DEM has primary responsibility for dissemination of emergency public information. Single point of contact for EPI release and for persons seeking information is DEM. Bureau of Radiation Control will have public information coordinator.

O.K.

b. Bureau of Radiation Control Public Information coordinator will arrange for tiniely exchange of information with appropriate licensee and local government public inform-ation personnel.

O.K.

~

c/ Same individuals as above will coordinate information realeses to cormect or forestall rumors. ,

O.K.

5. Local government responsibility. Bureau of Radiation Control will assist in development of Public INformation mathmials to be released for annual exercise of plan.

H. EMERGENCY FACILITIES AND EQUIPMENT

3. State ROC, DPS Austin and State Districe EOC (Waco)

~

(See local plans)

O.K. , .

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EMERGENCY FACILITIES AND EQUIPMENT Cont'd

4. State agency personnel who have operational responsi bility will staff ' State and District EOC's O.K.

11. Applicable emergency supplies and protective equipmente listed in procedures. Communications equipment DPS responsibility. Radiation monitoring team equipment and sdpplies listed in attachment 6 of Chapter l'of tab 1 to appendix 7 annex L. Other emergency supplies listed as procedures 2 - 6.

O.K.

I. ACCIDENT ASSESSMENT No FEMA assigned rev&&w elements J. PROTECTIVE RESPONSE 10.a. Map depicting monitoring points located in Chapter 1 of tab 1. Other maps local government responsibility.

! O.K.

b. Local government responsibility

c. Local Government responsibility

d. Consideration made for mobility impa!. red through sheltering, ,

respiratory protection (filtering air, limiting outside air intake etc.) evacuation or use of KI.

l 0.K.

l I f. No KI to be used for general populace. KI will be ad-l ministered to emergency workers in accordance with Protective Action Guides.

[ O.K. .

. Local government responsibility 3.

i.

j . " Contamination Control" addresses control of access. to exclusion area and responsibilities for control.

O.K.

k. No significant impediments noted l 1. Local guvernment responsibility

11. Annex C and appendix 2 and 9 of Annex L not available for review, however, tab 1 appears to sufficiently address this element. Department of Agriculture responsible for land-use maps. Monitoring points mapa noted.

! O.K. ,

1 _ _ _ _ _ . _ , _ _ _

~ ~ ^

O

'.. . .' PROTECTIVE RESPONSE Cont'd ,

12. State plan indicates evacuees are responsibility of hosting government. Local plan responsibility.

O.K.

K. RADIOLOGICAL EXPOSURE CONTROL ,,

3.a. Bureau of Radiation Health Contamination Control team will provide dosimetay. Emergency worker dose record noted.

O.K.

L. Medical and Public Health Support

3. (Appendix 3,11 and 12 to annex L. Appendix 3 contains functional statement for Bureau of Emergency Management.

Appendix 11, Public Health Regions functional statement "to be developed". Appendix 12. Fundtional statement for licensing and certification.)

Tab. 1, Chapter 1 Page 10, item 9 lists 3 hospitals capablie of handling radioactively contaminated individuals.

i

Hospitals have agreed to accept these individuals.

Hospitals do not have letters of agreement (Local plans?)

How many radioactively contaminated individuals can the hospitals handle at one time? .

4. Reference is made to appendices 3 and 11 of annex L.

Functional Statements for the appendices is insufficient to determine the capability for transporting contaminated individuals to medical facilities. Either the functional statements should be expanded to include this or appendices 3 and 11 made available for review. If this is local plan responsibility for addressing, O.K. Needs clarifications.

s M. Recovery and Reentry planning and Postaccident Operations

1. State plan part 3, describes concept of operation by the State for recovery and reentry following a disaster. Annex L, Appendix 7, Procedures 1-5. The Emergency Management Council supervises all disaster recovery operations.

Division of Emergency Ma'nagement is focal point for managing l all phases of disaster operations. Bureau of Radiation Control (accident assessment team) makes assessment and recommendations to Council. Procedfures for Chapter.1, '

to Tab 1 describe methodology and reference PAG's.

3. Part 3 of the State Plan references general state procedures for recovery operations. Appendix 7 indicates the Chief of the Bureau of Radiation Control will be responsible for determining when operations may be phased down or concluded.

O.K. ,

, . ~. . . . . . . . .

7

. N. EXERCISES AND DRILLS 1.a. Annex L. General. Inherent skills maintained day-to-

. day. Appendix 7 ' tab 1. VIII of introduction, page 8 indicates all emergency response personnel will receive initial and annual retraining applicable to their duties.

Attachment 4 addresses training, drills and exercises both generally and specifically. Exercises are to be in accordance with FEMA requirements.

O.K.

b. Criteria addressed in tab 1, attachment 4, II.A. No reference to.anannounced exercise however, indication is that exercises will be inaccordance with FEMA requirements.

O.K.

2.a. Communications drills adqquately addressed. While some drills not conducted explicitly for GNGF accident /inci-dent, in essence capability is exercised through normal day-to-day use more frequently than criteria requires.

O.K.

2.e. Appendix 7, tab 1. attachment 4, B.2. p.20 indicates H.P. drills to be conducted semi-annually.

O.K.

3.a. Scope of exercises to be in accorda'nce with FEMA re-quirements. Plan does not specifically address exercise objectives and evaluation but is implied if conducted

! in accordance with ; EMA requirements.

O.K.

I b. Same as above. .

c.

l i " " "

e.

f.

4. Tab 1. Attachment 4, II. A, p.19 indicates critique will be conducted, evaluation made of exercise comments and neee.ssary plan changes made.

O.K. .

5. Tab 1, attachment 4, II, A. p.19 addresses evaluation of dbserver comments and procedural changes in plans. Plan '

review and up-date is addressed sufficiently in appendix 7, XI, " Plan Maintenance".

O.K.

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O. RADIOLOGICALEMERGENCYRESPONSbTRAINING t

i

1. Training of state response personnel add'essed in annex L.., appendix 7, VIII addresses training of response team members. Tab 1, attachment 4 further addresses training. (Not referenced) e

b. Training of off-site state response personnel sufficiently addressed. Local emergency response personnel training to be addressed in local plans. .

1 4.a. Attachment 4 to tab 1 indicates all Boreau of Radiation Control personnel will receive training.

b. Planners, utility liaison, accident assessment, monitor-

c. ing, analysis, contamination control, decontamination,

e. medical liaison, instrumhat calibration and maintenance,

h. public information, logistics support per'sonnel are specifically identified for - training.

d. Identified as local plan items of concern g, . . . . . . . ,

g. .

1

j. Local responsibility primarily. DPS to supply capability for communicating emergency information 4f necessary and for field monitoring teams.

O.K.

5. Plans generally indicate the necessary training to perform assigned duties are inherent in position the individual holds. Tab 1 indicates individuals will re-ceive initial and annual retraining applicable to their duties.

O.K.

P. RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS

1. Plan notes responsibility for appropriate training; for plannars specifically, they will or have attended FEMA planning course. -

l O.K.

( 2. Plans indicate the coordinator, DEM is responsible for overall State Emergency Management Plan. The Chief, Bureau of. Emergency Management has planning responsibility for the Health Department. Wtihin the Bureau, the i Director, Division of Compliance and Inspection has the authority and responsibility for REP plans.

O.K.

3. Same lines of responsibilities and authorities as above.

~

O.K.

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RESPONSIBILITY FOR PLANNING cent'd

4. Provisions for up-date for all plans. All persons holding plans. or having emergency assignments under the-plan within the health department will rev66w and make recommendations for changes annually. 'Same for '

t appendix 7. If no. changes needed, certification of

' currency will br issued annually.

' O .,K . : ,

) 5. Plans will be distributed; changes will be dated and marked to iddicate where changes have been tede.

O.K.

s

6. State Plan, part 1. attachment 4 lists state agency and respoective annex. Annex 1. references _the State Pland ~

a'nd 12 appendiews thereto. Appendix 7 notes tabs, while

. tab 1 consists of chapter (s). Supporting plans w&&l noted.

\'O.K.

7. Implementing procedures for tab 1 are contained as a separate part of the plan. The procedures are self-explanatory (by name) as to that part of the plan they are designed to implement.

. Q.E.

8. Table of contents and,0654 cross-reference suppled.

While the cross-reference is not a part of the plan, constructed separately fr.,r the State Emergency Plan, Annex L and Appendix 7 it is more easily referenced by reviewers.

0.K.

10;- ' Telephone numbers of response personnel will be up-dated annbally. fueus.o GE ouddrtA&v Etaa N h

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sf Hood /Somervell'Co. REP Plans Organization Basic Plan - (2 attachments - organization - court order)

Annex A - Warning Annex B - Communications Annex C -

Annex D - Shelter

- Radiological Plandefense (Not included?(not plan included)

Annex E - Crisis Relocation Plan (not included)

Annex F - Fixed Nuclear Facility Response Plan Manual of Emergency Procedures (50P)-for Incidents involving the CPSES (called an addendum to county E0P)

(called an extension of Annex F)

Section I - Procedures for Executive Group

, Section II - Procedures for Law Enforcement Section III - Procedures for Fire & Rescue Section IV - Procedures for Hospital / Medical Section V - Procedures for Shelter & Transportation Section VI - Public Information .

Section VII - Attachm.ents Attachments A. Initial Notification -

B. EOC C. Verification

. D. Notification / Communications E. Call List F. Warning G. Evacuation H. Shel te r J. Transportation K. Husbandry L. Media M. Government Agencies .

N. Situation Form - -

O. Protective Measures P. Emergency Actions (PIO)

Q. Medical Facilities R. State Disaster Act (Attachments above have tabs)

GENERAL COMMENT

Plan needs to be tabulated for quick reference. Page numbering is inconsistent for base plan. Plan organization is confusing.

Either should be two separate plans or organization for 1 plan consistent throughout ments for entire plan)(. eg. 1 warning annex and 1 set of attach-O

. . . . - ~ . . . . . .

~

HOOD /SOE RVELL COUNTY EMERGENCY PLANS NUREG 0654 ELEMENT e

j A. ASSIGNMENT OF RESPONSIBILITY 1.a.

• Plans indicate procedures for requesting support from State, Federal or military. Identified at the local level is Hood County and the incorporated cities of Granbury, Tipan and Tolar; and Somervell County and the city of Glen Rose. The Division of Occupational Health and Radiation Control will assist counties with planning and operations relating to fixed nuclear incident.

Okay

b. County Judge and Mayors of incorporated towns are responsi-ble for emergency measures including requests for assist-ance. Department / agency responsibilities summarized.

Okay

c. Primary and support responsibilities of. agencies shown in diagram p. 51 (Somervell) P. 52 (Hood)

Okay

d. County Judge has responsibility for emergency response in the County including unincorporated comunities. The mayors of incorporated towns / cities have responsibility in towns /

cities. Each city / county agency has director / chief who is responsible for that agency.

Okay

e. The Sheriff's Office is responsible for 24-hour manning of comunications link and warning-technical res Other response (fire, law enforcement, etc.) normal.ponse by State.'

Okay 2.a. Executive grou -

Comissioners)p (mayor comand represent / counciland members control.and A&N, County Judge /*

Comunications - Sheriff - all major elements addressed -

Functional agency responsibility chart included p.51, (Somervell) and p. 52,(Hood).

Okay l

l b. Legal basis.

Okay,

. o

.g. -

. 3. .Cocal plans'eress-reference indicates this element is nct applicable. American Red Cross is covered by State, however, local volunteer organizations if they are to be e used should have letters or agreements as to what with and how they will respond / assist local governments. School

. busses are to be used. If these are fiscally independent school districts and busses are either owned by the district 1 or are contract busses and are to be used to evacuate people, j letters of agreement may be appropriate. I feel local plans should address this element if any resources are to be used other than those comnitted by law.

4. County Judges and Mayors of incorporated towns will assure continuity of operations in their respective jurisdictions.

Okay B. ONSITE EMERGENCY ORGANIZATION

2. While not designated as an element to be addressed in local plans, local governments may wish to include the title of

tne person from the licensees' facility who is responsible

}or initiating emergency actions and providing recommenda-tjons for protective actions to offsite officials.

C. EMERGENCY RESPONSE SUPPORT AND RESOURCES '

1.a. Cross reference indicates N/A. Base plan VI A.1.d. and VIII, indicates County Judges or Mayors may request State, Federal Not FEMA of military assistanca through State Disaster Districts.

assigned Can local government request Federal or military assistance element directly? If so, it should be indicated and the proper procedures for doing so.

2.a. Cruss reference indicates this element N/A. Plan should designate local offical to serve as representative of local government at the EOF. This doesn't mean a representative must be there; only that a representative may, be there if he/she so chooses.

4. Local government relies heavily upon State' assistance for .

technical capabilities. Local resources other than schools and local government not addressed. Letters of agreement with school districts may be appropriate unless school re-sources have been cannitted previously through legal instru-ments.

e 8 9 g

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D. EMERGENCY CLASSIFICATION SYSTEM

3. Incidents occurring at Comanche Peak have been classified consistent with NUREG-0654 criteria and assumedly that of <

Utility facility operator.

4.

• Emergency classification system listed and increased readi-ness action given in basic plan. Lengthy " Manual of Emergency Procedure for Incidents involving the Comanche Peak Steam Electric Station" is included as an addendum to the plan and appears to cover procedures to be employed by various entities consistent with the emergency action level.

E. NOTIFICATION METHODS AND PROCEDURES

1. Procedures for verificaticn are found on 'pp.147 and 148.

Proper response by organizational entity noted.

2. Page 71 gives procedures for notifying response organizations for unusual event. Similar procedures for all action levels given.

3. Cross reference indicates 'N/A', however, feel this alement should be addressed by S and L. I do not find copy of initial emergency message or any indication that local government is aware of the contents of such a message (See p. 156, warning message "similar to")

5. P.156 addresses type infomation which might be broadcast to the public in the event of an accident / incident at Comanche Peak.

6. Si en coverage on P. 40 appears to provide notification to the public. Means for providing instructions to the public by EBS or mobile PA units (pp. 157-162)

E.7. Pp. 227-231 gives sample message fomat for press for pro-tactive measures and evacuation procedures.

F. EMERGENCY COMMUNICATIONS 1

l 1.a. '

P,45 indicates sheriff's office to maintain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day comunications capability. Capability consists of telephone

• and radio with DPS (currently not with utility).

b. N/A according to cross-refe'.ence however, it should be indicated what provisions are made for communications with contiouous local (county) governments within 50 mile ingestion pathway. (eg.

through OPS District Office, Waco).

l

s.,. .

c. Cross reference N/A. State responsibility (See comment C.la.)

d. Communications from utility is apparently only through DPS District Office to local government at this time. RadiologicW1 monitoring teams and communications between teams and local EOC or utility's EOF not addressed at local level. (State

. responsibility for monitor team connunication)

Okay

.' e. Plans have sufficient provisions and procedures for alerting emergency response personnel.

2. Plans indicate N/A as does State REP Plans. Local plans should address this element. (Capability to communicate between ambulance / hospital)

G. PUBLIC EDUCATION AND INFORMATION 1.a. Public education and information is generally well-addressed.

b. I question the need to distribute the information package c.

d. annually to each or bi-annually residence.

would (IV.A.2,p.118)(as seem more changes feasible. Criteria says info occur will be distributed annually, not necessarily the same info package as the plans imply) The plans also indicate public meetings will be held annually. This is not required but is certainly okay if it is desired by local government.

2. The resident populace appears to be well covered regarding

! public education and information. I do not find provisions for assuring the transient populace has access to such infor-mation. Placing signs in public places, hotels, motels, stores, P.0's, etc. and publishing of info in telephone di-rectories would be some ways of making the information avail; able to the transient populace.

3.a. The Waco District DPS office is noted as the point of contact for the media briefings schedule. The utility's operations facility (EOF) is designated as the site for the city and county news media. The alternate for the city / county will be the connissioners courtroom.

4.a. The chief executive of the County (Judge) and the Cities (Mayors) will be spokespersons for their jurisdictions (or their appointed representative) e w

b. Rress briefings wil1 be scheduled and conducted for all news media at which time any exchange of information will occur. ,,

c. The cross reference indicates the county and city will dis-courage independent news dissemination to the press; this may discourage some rumors, however, there will no doubt be some rumors and unsubstantiated info passed in the event of an accident / incident at CPSES. There should be a telephone num-ber to call or a central location where one can go for factual infomation and where rumors can be verified or corrected.

5. I do not find specific provisions for programs to acquaint the news media with plans, radiation and points of contact on an annual basis. The plans should provide for this.

H. EMERGENCY FACILITIES AND EQUIPMENT i

~

3. Both counties have established E0C's (Somervell Co. has alternate EOC also).

4. Activation and staffing of EOCs addressed satisfactorily.

. 7. State Health Department is primarily responsible for mon-itoring but County RDO will provide assistance if resources are available.

i 11. Primarily responsibility of State Health Department.

I. ACCIDENT ASSESSMENT (No FEMA assigned element review)

J. PROTECTIVE RESPONSE ,

10.a. Maps showing evacuation routes are included but I do not find maps of evacuation areas as such. There is a general lack of precise evacuation procedures in the plans. I assume instructions and procedures including arear to be evacuated will be included in the public information package.

l Radiological sampling and monitoring points are included in .

State Plan. I do not find maps of shelter or relocation areas.

These may not be needed due to common knowledge of area by all and the low evacuee population. Plans should so state if this is true.

a w -- ,e , , - - . , -

a----,-,---

b. Segmented population totals shown on p. 192.

Okay a

c. Outdoor warning devices to cover entire 10 EPZ. How to locate and warn hard-of-hearing or deaf?

d. ' Institutionalized persons compensated for: No mention of hard-of-hearing or handicapped persons not institutionalized.

f. Decision is . State's - County may assist in administration of KI if requested.

g. Means of relocation is primarily by auto (or school busses if duringschool). Assumes what few residents who do not have autos, have access to rides with friends, neighbors or relatives.

Plans should identify such persons and assure they will be evacuated.

h. Shelter facilities should be outside the 10 mile EPZ (Glen RoseSeniorHighislistedasshelterfacility)

1. Projected traffic capacities of roads are cited and sup-porting studies referenced.

J. County Sheriff is responsible for control points for evacua-tion)p.47)andTabG.VIindicatescontrolwillbemaintained over access to evacuated area (cross reference shouli indicate appropriate procedures which address this element).

k. The only impediments (highway) noted would be icing or roadways.

Okay

1. Table 2 - misspelled word. " Area" section is upside down.

Summary of evacuation time analysis appears viable considering population.

l

12. Shelter registration form included in plan as Tab 2 to attach-ment H. Decontamination procedures seem reasonable. (Where Not does the temporary clothing come from if individual's. clothing i

FEMA is contaminated?) -

a l

K. RADIOLOGICAL EXPOSURE CONTROL 3.a. State responsibility primarily - County RDO may assist.

Okay 1

1 e.

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. .. . . . . = - . . - - _ . . - . - . . -

7

4. State responsibility primarily - County RDO may assit.

Okay ,

L. MEDICAL AND PUBLIC HEALTH SUPPORT

3. Cross reference indicates N/A. State plan implies some local responsibility. Letters of agreement may be appro-priate to assure a willingness and capability to accept radioactively contaminated individuals.

How many R.C.

patients can hospitals accannodate? Do they have capability to monitor? ,

4. Cross reference indicates p. 3 item f. of plan. This merely indicates the Sheriff's Office has the responsibility to dis-patch ambulances. Is this private ambulance service? Does utility have medical transfer capability? If private ambu-lance service are personnel trained in handling R.C. patients?

How many ambulances are available?

M. RECOVERY AND REENTRY PLANNING AND POST A'CCIDENT OPERATIONS

1. Plan indicates procedures and information regarding recovery and reentry will be provided by State Health. State plan does not address details of recovery and reentry such as time phased movement, etc. This decision to be made based on time and circumstance of occurrence?

N. EXERCISES AND DRILLS .

1.a. Exercising, scenario development and drills are primarily '

b. responsibility of State and Utility according to plan; 2.a. however, local plans should address willincness of local

b. governments to participate in exercises anc drills noted and with the frequency recommended by NUREG-0654.

(note communication, medical drilis required for locals) ,

3.a. All same as above - Local government plans should indicate

b. its willingness to participate and support where necessary-

c. all elements noted that are related to and appropriate for *

e. local government.

f.

4. Same as above. -

5. Same as above.

- , - ,