ML20203E850

Discusses Fema,State of Oh & Local Activities Re Offsite Radiological Emergency Preparedness Plan.Requests Response Re Adequacy of Submitted Info

ML20203E850
Person / Time
Site:	Davis Besse
Issue date:	07/23/1986
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20203E855	List: ML20203E850 ML20203E857
References
NUDOCS 8607240280
Download: ML20203E850 (3)

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f s Federal Emergency Management Agency i # Washington, D.C. 20472 g'o O JUL 2 31986 MEMORANDlM EOR: Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U . Nuc ar ulatory Ccmnission

-2;ac y Fl(N: 'Kr'Em Assistant Associate Director Office of Natural ard Technological Hazards Programs SUBJECE: Offsite Radiological Bnergency Preparedness for the Davis-Besse Nuclear Power Station In February 1981, the Ohio Plan for Response to Radiation Bnergencies at Licensed Nuclear Facilities, site-specific to the Davis-Besse Nuclear Power Station (NPS), was submitted to the Federal Bnergency Management Agency (FEMA) Region V for review and evaluation in accordance with FEMA's rule 44 CFR 350. A radiological energency preparedness (REP) plan for Lucas County had not been included in the State's subnission. During the Rajion V review process it was concluded that a separate Incas Ccunty plan was required. In the absence of this part of the required Ohio plan, the Ohio Disaster Services Agency (OWA) was notified that further processirg of the State's submission was being placed on hold pendirg submittal of a Lucas County REP plan. On February 13, 1985, FEMA Region V notified ODSA of the need to either submit a Lucas County REP plan to FEMA by March 15,1985, or submit alternative solutions.

On April 30, 1985, ODSA provided FENA Region V with the Toledo Edison proposal to redefine the 10-mile plume energency plannity zone (EPZ)

. around the Davis-Besse NPS. Ohio recormnended approval of the proposal which, in addit on to eliminatirg a portion of Incas County within the 10-mile EPZ, would have also eliminated that part of the City of Port Clinton (Ottawa County) previously included in the original plannirg effort. It is noted that the permanent population of the affected area of Lucas County is approximately 900 persons. However, the transient popula-tion during late Sprirg and Sunner at the Federal and State parks within the Lucas County EPZ is estimated to averzge between 2,000-3,000 people, with peaks of nearly 14,000. As indicated elsewhere in this memorandum ard the attachments, considerable discussion and effort has especiallly been devoted to resolvirg Lucas County plannirg issues. 'Ihe State, of course, as well as the Nuclear Regulatory Commission (NRC) Region III ard Toledo Edison were of ten directly involved in the various activities asmciated with the EP2 ard plannirg issues. For exa.rplc, the attached June 7,1983, NRC Region III letter announced a meeting "...to discuss and resolve concerns raised by Lucas County regarding emergency preparedness

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c around the Davis-Besse Station." Photocopies of the slides used at that meeting identifying issues and the chronology of key events up to that time are also attached. In addition, I have attached a copy of Toledo Edison's April 2,1984, letter and proposed agenda for a meeting held on April 11, 1984, to discuss Davis-Besse planning issues.

FEMA Headquarters and Regional staff reviewed the State's proposal and supporting documentation to redefine the 10-mile EPZ and determined that it was not acceptable as subnitted. In letters to Ohio Governor Celeste and ODSA on December 9, 1985, (copies of which were provided to you as attachments with my December 13, 1985, morrorandum transmitting the exer-cise report of the July 16, 1985, REP exercise for the Davis-Besse NPS) we identified the specific reasons why we found the proposal to redefine the 10-mile EPZ unacceptable.

On February 4,1986, ODSA submitted a detailed response to our letter of December 9, 1985. ODSA specified the actions taken or proposed to resolve the outstanding Davis-Besse EPZ issues. Following our review and analysis

- of the State's response, we provided ODSA with our determination on March 19, 1986, and identified the remaining information the State would be re-quired to provide. ODSA was given an additional 120 days frun the March 19 date to resolve the remaining outstanding issues. A copy of our March 19 letter ic attached for your information.

On May 12, 1986, ODSA responded and subnitted a proposed schedule to resolve the various issues. In essence, the proposal as then submitted by ODSA would have prolonged resolution of the outstanding issues until the Surrmer of 1987. (We had specified that all issues should be resolved no later than December 1986.) Following the State's letter of May 12, Toledo Edison requested a meeting with reprgsentatives fran the NRC and FEMA regional offices and the State. 'Ihe m3eting was held in Chicago on May 20, 1986.

Since that time, a number of activities have occurred culminating in the recent correspondence dated July 8,1986, (copy attached) frun ODSA identifying additional actions taken or progosed to resolve the outstand-ing issues. Included with the July 8 letter was an attachment identifying milestones and completion dates including the following: (1) September 3, 1986--Incas County REP plan subnitted by Incas County Conmissioners for State review; (2) September 23,1986-key players from Lucas County, Ottawa County and ODSA derronstrating certain emergency response functions in conjunction with a utility-only exercise conducted for the Davis-Besse NPS; (3) December 30,1986--subnission of a Incas County REP plan, and revisions to the Ottawa County arx1 State of Ohio plans to FEMA Region V for review under 44 CFR 350; (4) March 31,1987-an exercise involving full participation by Lucas County; and, (5) April 30,1987- a public meeting in accordance with FEMA regulations.

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Most recently, on July 16, 1986, we received a copy of the attached undated Menorandum of Understanding (MOU) signed by representatives of Lucas County, Jerusalem Township, ODSA and the Toledo Edison Conpany. As the MOU indicates, the parties agree to complete certain activities prior to the Davis-Besse NPS planned start-up in October 1986, as.well as to interim measures which will remain in effect until the final approved Lucas County REP plan and facilities are in place.

While planning is incorplete, we believe the State and local governments have in recent nonths put forth a good faith effort in resolving the outstanding REP issues around Davis-Besse as indicated by the agreed to interim measures and the connitment by the parties to complete specific actions by specified dates. I would like to point out that the comnitment to conduct the exer-cise in March 1987, (instead of June, as previously scheduled) should enable FEMA to assess the capability of Incas County to implement its REP plan p -ior to the beginning of the sunner season. It should be noted that FEMA has provided NRC with past REP exercise reports. The exercises were conducted on November 6,1980, April 13,1983, and July 16, 1985. The exercise re-ports were transmitted to you on March 30, 1982, May 4, 1984, and December 13, 1985, respectively.

The regional staff will continue to work with Ohio on the interim measuruc and steps for formal approval of the State's site-specific plans. In this regard, we are returning the previously subnitted FEMA Regional Director's Evaluation to FEMA Region V. Following the completion of necessary plan nodifications, exercise activity and a public meeting, we anticipate that FEMA will have sufficient information to proceed with an evaluation of the Ohio's plans under 44 CFR 350. However, should the State anci local goverments fail to carry out its connitnents within the time frames specified, we will return the site-specific plans in accordance with our regulations.

FEMA will continue to monitor progress concerning the interim measures and the meeting of formal requirements for offsite safety. We plan to provida you with status updates following the planned drill in September and the March 1987 offsite 1(EP exercise.

I l Due to NRC's current review of onsite issues and your overall responsibility for determining the adequacy of emergency planning and preparedness, please advise FEMA in writing if this information is sufficient for your delibera-tions and if you desire that FEMA take any other actions at this time.

Attachments As Stated l

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