ML20246Q040

Forwards Complete Unannounced Drill Evaluation of Implementation of State & Local Radiological Emergency Response Plans, Conducted on 890510.Due to Document Reproduction Error,Only Portions Submitted w/890804 Ltr

ML20246Q040
Person / Time
Site:	Quad Cities
Issue date:	09/01/1989
From:	Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
References
NUDOCS 8909110312
Download: ML20246Q040 (1)

Text

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._ SEP 011989 Docket No'. 50-254 Docket No. 50-265 Commonwealth Edison Company ATTN: Mr. Cordell Reed Senior Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

Enclosed is a complete copy of the Federal Emergency Management Agency (FEMA)

Region VII report for the May 1989 offsite exercise at the Quad Cities Nuclear Generating Station. This exercise involved energency response personnel from the State of Iowa and Clinton and Scott counties in Iowa. Due to a document reproduction error, only portions of this June 1989 FEMA report were provided to you as an enclosure to our letter dated August 4,1989.

If you have any questions, please have your staff contact Mr. T. Ploski of my staff at (312) 790-5529.

Sincerely, L RoertGre@er, Chief Reactor Programs Branch

Enclosure:

As stated cc w/ enclosure:

T. Kovach, Nuclear Licensing Manager R. L. Bax, Station Manager DCD/DCB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public  !

Utilities Division

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1 UNANNOUNCED DRILL EVALUATION OF THE IMPLEMENTATION OF STATE

• AND LOCAL RADIOLOGICAL EMERGENCY RESPONSE PLANS l

CONDUCTED NAY 40, 1989 for the

'l l QUAD CITIES NUCLEAR POWER STATION 1 Near Cordova, Rock Island County, Illinois Commonwealth Edison, Licensee

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PARTICIPANTS State of Iowa Clinton County Scott County 4 r , n ,

JUNE 2 0, 1989

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i prepared by Federal Emergency Nanagement Agency Region VII ,

911 Walnut, Room 200 Kansas City, Nissouri 64106 Jerome.D. Overstreet, Regional Director

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l-t l ,- . CONTENTS ABBREVIATIONS AND ACRONYMS...................................iii DRILL

SUMMARY

................................................ V 1 INTRODUCTION.............................................. 1 1.1 Drill Background..................................... 1 1.2 Drill Evaluators..................................... 2 1.3 Evaluation Criteria.................................. 2 1.4 Drill Objectives..................................... 2 1.5 Drill Scenario.......................................- 3 1.6 State and Local Resources............................ 3 l 2 DRILL EVALUATION.......................................... 5 2.1 Iowa Operations...................................... 5 2.1.1 State Emergency Operations Center...........--. 5 2.1.2 State Forward Command Post................... 7 2.1.3 Field Team Coordination / Field Monitoring Teamu 9 2.1.4 Dose Assessment............................... 10 2.2 County Operations................................... 10 2.2.1 Clinton County Emergency Operations Center... 10 e 2.2.2 Scott County Emergency Operations Center..... 12 3

SUMMARY

OF AREAS REQUIRING CORRECTIVE ACTIONS............. 13 9

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/ A y .. W."'* ABBREVIATIONS AND ACRONYMS ARC American Red Cross ARCA- Area Requiring Corrective Action ARFI Area Recommended for Improvement CCEOC 'Clinton County Emergency-Operations Center CFR Code of Federal Regulations DNR Department of Natural Resources ,

, 1 DOC Department of Commerce DOC Department of Corrections DOE Department of Energy DOI Department of Interior DOT Department of Transportation DPH Department of Public Health DSD Disaster Services Division EBS Emergency Broadcast System EOC Emergency Operations Center EPA Environmental Protection Agency EPZ Emergency Planning 2one FEMA Federal Emergency Management Agency ,

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FCP Forward Command' Post J HHS/FDA Health and Human Services / Food and Drt.y Admini-stration HHS/PHS Health and Human Services /Public Health Service KI . Potassium Iodide NARS Nuclear Accident Reporting System

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NRC Nuclear Regulatory Commission

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NUREG-0654 Criteria for Preparation and Evaluation of Radio-logical' Emergency Response Plans and Preparedness

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in Support of Nuclear Power Plants (NUREG-0654/~

FEMA-REP-1, Rev. 1)

QCNPS Quad Cities Nuclear Power Station -

RAC Regional Assistar.ce 'namittee RACES Radiological Am.*wur . communications Emergency Services-SCEOC Scott County Emergency Operations Center SEOC State Emergency Operations Center ,

SOP Standard Operating Procedure TSC Technical Support Center UHL University Hygienic Laboratory USDA United States Department of Agriculture 6 t j

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DRILL

SUMMARY

The purpose of an exercise, or in this case a drill, is to L determine the ability of appropriate off-site agencies to respond l to an emergency covered by State and local Radiological Emergency I. '

Response Plans. The scope of this drill was limited to demon-L strating the ability of State and local governments to tully ac .

l- tivate Emergency Operation Centers (EOC's), and to mobilize all I

staff that report to the EOC's. The evaluation of such an effort will, of necessity,' tend to focus on the negative aspects of the exercise, on inadequacies in planning, preparedness and perfor-mance. .

This focus of attention on the negative should not be taken to mean that there were not positive accomplishments, as well'.

Indeed, there were; however, in the interest of brevity, only inadequacies will herein be' summarized.

FEMA classifies exercise or drill inadequacies as deficien-cies or areas requiring' corrective action. Definitions of these categories follow.

Deficiencies are demonstrated and observed inadequacies that would cause a finding that off-site emergency preparedness was not edequate to provide reasonable assurance that appropriate C protective measures can be taken to protect the health and safety of the public living in t.e h vicinity of a nuclear' power facility in the event'of a radiological emergency.

Areas recuirina corrective acti2D are demonstrated and ob-served' inadequacies of State and lu al government performance, and although their correction is required, they are not consid-ered, by themselves, to adversely impact public health and safety.

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In addition, FEMA identifies areas recommended for improve-ment, which are problem areas observed during an exercise that are not considered to adversely impact public health and safety.

While not required, correction; ot ,these would enhance an organization's level of emergency preparedness.

There were no deficienci.es identified during this drill.

However, nine areas requiring corrective action were identified.

Five were cited at the State Emergency Operations Center (SEOC) as follows:

• Due to technical complications, the Nuclear Accident Reporting System (NARS) failed to operate properly. The SEOC could not be contacted for notification of the Alert classification level utilizing this system.

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T* The. Iowa Disaster. Services' Division (DSD) failed to' notify . -

the: Forward command Post (FCP) of the Alert classification '

level in a timely-manner.

• The.DIowa State Highway Patrol representative who reported to the Clinton County. Emergency Operations Center did not have -

dosimetry.

• The. : State- Plan does not indicate how dosimetry is

' distributed to the State Highway Patrol representatives who enter the plume emergency planning zone.-

• 'The State Plan is inconsistent regarding what organizations will report to the SEOC.

1Two: areas requiring' corrective action were identified at the

- State Forward Command Post ,(FCP) . The Iowa Department of Natural Resources (DNR) - representative did not report to the State FCP.

Secondly, the FCP staff was not aware of the procedures for establishing the administrative conference line between the State-

.EOC, County EOC's, and FCP, which delayed the activation of this primary communication link.

An area requiring corrective action was identified for both Clinton and Scott' Counties as the administrative conference line between the S t a t e' E O C , County EOC's, and FCP was improperly utilized.

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An area requiring corrective action was identified with- the Scott County, Radiological < Emergency Plan. The Assistant to the Director acted as an alternate for the Director during the drill.

.However, the plan does not account for this individual assuming this position.

l A summary of the areas requiring corrective action is

. located in Section 3:of.this. report.. These inadequacies are explained in detail in Section 2 o.f. this report under the respective facility. >  : ) i 4 $

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• 1 TA,AODUCTION 1.1 DRILL BACKGROUND on December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume lead responsibility for all off-site nuclear planning and response.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

• Taking the lead in off-site emergency planning and in the ~

review and evaluation of radiological emergency response plans developed by State and local governments.

• Determining whether such plans can be implemented on the ba-sis of observation and evaluation of exercises of the plans conducted by State and local governments.

• Coordinating the activities of the following Federal agen-cies with responsibilities in the radiological en.ergency planning process:

- U.S. Department of Commerce (DOC)

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U.S. Nuclear Regulatory Commission (NRC)

U.S. Environmental Protection Agency (EPA)

U.S. Department of Energy (DOE)

U.S. Department of Health and Human Services (HHS)

- U.S. Food and Drug Administration (FDA)

- U.S. Public Health Service (PHS)

- U.S. Department of Transportation (DOT)

- U.S. Department of Agriculture (USDA)

- U.S. Department of the Interior (DOI)

Representatives of these' agencies serve as members of the Regional Assistance Committee (RAC), which is chaired by FEMA.

Formal submission of the radiological emergency response 4

plans for the Quad Cities Nuclear -Power Station (QCNPS) to the RAC by the State of Iowa and affected local jurisdictions was followed by a critique and evaluation of these plans.

An unannounced radiological emergency preparedness drill was conducted for the Quad Cities Nuclear Power Station (QCNPS) on May 10, 1989, between the hours of 0930 and 1230, to assess the capability of. State and local emergency preparedness organiza-tions to fully activate their facilities, mobilize their response staff, and complete the notification of all participating organi-zations during a radiological emergency at the Commonwealth Edison's Quad Cities Nuclear Power Station. The plans evaluated

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included the " Iowa Radiological Emergency Response Plan", and the ,

Emergency Response Plans for Clinton and Scott Counties.

was the first unannounced drill for the State of Iowa and Clinton This (

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and Scott Counties.

Following the drill, an Exit Interview with the State and local governments and the licensee was conducted by the Regional .

Assistance Committee (RAC) Chairman to discuss the results of the drill.

1.2 DRILL EVALUATORS Seven- agency personnel evaluated the off-site emergency response functions. These individuals and their exercise assignments are given below:

Observer Agency Assignments Bob Bissell FEMA Clinton County EOC Tim Burke ARC. State EOC Marlee Carroll FEMA State EOC Kathy Crews FEMA Scott County EOC Jon Furst .

FEMA State Forward Command Post Rich Leonard FEMA Clinton County EOC Richard Sumpter FEMA Scott County EOC 1.3 EVALUATION CRITERIA The evaluation criteria for this exercise were:

1. 44 Code of' Federal Regulations (CFR), Part 360.9.

2. NUREG-0654/ FEMA-REP-1, Rev. 1 (All applicable require-ments).

2.a. Objective thirty-six of the thirty-six standard-ized objectives dev. eloped as a summary of observ-able elements contained in NUREG-0654.

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3. Iowa Radiological Emergency Response Plan, Section B Plant Accident / Incident. ,

4. Quad Cities - Site Specific Nuclear Power Plant Emer-gency Response Plans for Clinton and Scott Counties.

1.4 DRILL OBJECTIVES i

l The -drill was intended to demonstrate the ability of the

!. State of~ Iowa and Clinton and Scott Counties to carry out emer-I gency mobilization and activation functions.

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In this drill, only Objective Number 36, a new objective

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regarding unannounced and off-hours drills and exercises, was in- I tended for demonstration and evaluation. Only the unannounced portion was. tested, as the off-hours portion had been demon-strated during a previous full-scale exercise.

The term " unannounced" refers to a drill or exercise which l is held without the time and date being made known to the re-i sponders. For purposes of evaluating response capabilities, it is deemed appropriate to inform responders that an unannounced I drill will be held during a particular week, keeping the date and time confidential until off-site notification prompts the re- l l sponders to activate. I This evaluation concerns a drill, and as such, required ,a specific, limited degree of response.

The drill was to include the activation of the State .

Emergency Operations Center (EOC), both Clinton and Scott County EOC's, and the State Forward Command Post (FCP). The State dose assessment and radiological field team coordination functions I were also to be activated and report to the appropriate locations. Two radiological field monitoring teams were to accompany the field team coordinator. Other field personnel who deploy from EOC's were to report to their appropriate EOC's to

( establish their readiness, but were not required to then deploy to their assigned locations.

Each of the above facilities were to establish communications With other organizational EOC's. When all appropriate staff at each facility had been mobilized and the appropriate notification to other organizations completed, the drill was to terminate.

1 1,5 DRILL SCENARIO

, , . > . u At 0920 an Alert was-declared due to the required shut down of the QCNPS Unit 1 reactor because'of the unavailability of backup equipment required by technical specifications. At 0938 off-site notification. occurred. - '

1.6 STATE AND LOCAL RESOURCES Listed below are organizations that planned to participate:

't State of Iowa

1. Iowa Disaster Services Division

2. Iowa State Department of Public Health

3. Iowa National Guard

4. Iowa Department of Public Safety (Iowa Highway Patrol) 3

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5.. Iowa Department _of Natural Resources .

16.. Iowa Department of Transportation -

7.. University of. Iowa Hygienic Laboratory. '

8.- Office of the Governor -

9. ' Office of the Attorney General i- .10. Iowa Department of Human Services i 11'. - Iowa Department of Agriculture

12. Iowa Department:of Elder Affairs 113. Iowa Commerce Commission Office of the Adjutant General 14.

15. . American Red Cross

16. Capitol' Security.

Department.of Corrections

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ClintonjpggLtig ~ Scott County -

h 1. Board # Supervisors 1. Board of Supervisors

2. Emergency Management 2. Disaster Services

3. Emergency Management Council 3. County Administrator

4. Sheriff's Department 4. Sheriff's-Department 5.- Transportation Department 5. Engineering' Department

6. - Human Services Human Services

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7. . Engineering Department 7. Environmental Health

8. Public Information Office 8. Area Education Agency

9. Area. Education Agency 9. Health Department-

10. Medical Coordination 10. Communications Office:

11. ' Amateur Radio Club 11. Ameri ceu Red Cross f

12. Clinton Mayor 12. Public Information Office (

13. Camanche Mayor 13. . Leclaire Mayor

.14 . DeWitt Mayor 14. McCausland Mayor.

. 15. . Low Moor Mayor. 15. Princeton Mayor

16. Municipal Fire and Police 16. Municipal Fire and Police Clinton Princeton Camanche ImClaire DeWitt McCausland

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2 DRILL EVALUATION 2.1 IOWA STATE OPERATIONS 2.1.1 State Emeraency Operations Center (SEOC)

Objective to be demonstrated: 36.

Objective Number 36, ability to carry out emergency response functions (i.e., activate EOC's, mobilize staff that report to the EOC's, establish communications linkage and complete telephone call down) during an unannounced drill, was not adequately demonstrated.

An inadequacy was identified as the Nuclear Accident Reporting System (NARS) failed to operate properly during the notification of the Alert emergency classification level. Due to technical complications, the State Emergency Operations Center (SEOC) could not be contacted by the utility utilizing this system. The SEOC was eventually contacted at 0938 over the commercial telephone line. However, the NARS technical failure was not corrected during this drill and thus precluded a full demonstration of the system. Based on the above, the technical problem must be corrected and this communication system be demon-strated during the next scheduled exercise.

At 0942, the dispatcher began notifying the appropriate organizations to report to the SEOC. The notification procedure was completed at 0959, with full staffing and SEOC activation achieved at 1054. All appropriate staff were notified and mobilized pursuant to the plan. However, an inadequacy was identified as the Iowa Disaster Services Division (DSD) failed to notify the Forward Commar.d Post (FCP) of the Alert classification level in a timely manner. The Iowa DSD was notified of the Alert

, at 0938. However, the FCP was not subsequently notified until 1015 when the Iowa State Highway Patrol representative arrived at the SEOC. This delay occurred in part because the State Plan fails to specify who is responsible for the initial notification 4 to the FCP of emergency classification levels and to provide instructions to begin activation of the facility. The initial contact with the FCP by the Iowa State Highway Patrol representative was with the expec already been alerted and begun activation,tation that the

. The State FCP Plan hadbe amended must j to reflect this responsibility.

The Iowa DSD representatives who would normally report to the Clinton and Scott County Emergency Operations Centers, Forward Command Post, Emergency Operations Facility, and the '

Joint Public Information Center, all reported to the SEOC. l During this drill, these representatives were not required to l 5

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the aforementioned locations, but were, instead, drive to required to report to the SEOC for verification of notification by the FEMA evaluator.

As the SEOC is not located within the plume emergency planning zone (EPZ), dosimetry is not required for staff at this location. However, dosimetry kits and a charger were available .

at the SEOC during the dr371. Dosimetry and potassium iodide (KI) would be provided to che State emergency workers who would depart this facility to locations within the plume EPZ, such as the Clinton County Emergency Operations Center.

An inadequacy was identified concerning exposure control.

The Iowa State Highway Patrol representative, who reported to the Clinton County Emergency Operations Center, did not have dosimetry. As this local Emergency Operations Center is located in the plume EPZ, dosimetry for emergency workers is required. -

During this drill two State planning inadequacies were identified. The first inadequacy was cited as the State Plan is inconsistent regarding what organizations will report to the SEOC. For example, page II-13 indicates that the Department of Commerce and Capitol Security will report to the SEOC. However, on page II-10, these organizations are not included. A similar problem exists with the Department of corrections. The State notification procedures require this organization to report to The

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the SEOC. However, the plan, in some cases, does not.

appropriate plan amendments must be made to correct the aforementioned concerns.

The second planning inadequacy was identified as it was discovered that the State Plan fails to document where dosimetry is stored and how it is distributed to the s.ete Highway Patrol Officers who are dispatched from locations other than the SEOC.

Therefore, the State Plan must be amended to indicate where the dosimetry (self-reading and permanent) is stored and how it is distributed to the State Highway Patrol. This amendment must also include all organizations assigned to the State FCP who may enter the emergency planning zone.,

summary: Objective. Number 3 36 was not adequately demonstrated.

Areas Recuirina Corrective Action

1. Due to technical complications, the Nuclear Accident Reporting System (NARS) failed to operate properly during this drill. The State Emergency Operations Center (SEOC) could not be contacted for notification of the Alert classification level utilizing this system. The NARS system never successfully contacted the SEOC during this exercise.

Therefore,' the technical correction must be made and this 6

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.(NUREG-0654, F.1.d.)

!.' 2. The Iowa Disaster Services Division (DSD) failed to notify -

l the Forward Command Post (FCP) of. the Alert classification level in a timely manner. The Iowa DSD was notified of the Alert at 0938. However, the FCP was not subsequently noti-fled until 1017 when the Iowa State Highway Patrol represen-tative arrived at the SEOC. This delay occurred in part  !

because the State Plan fails to specify who is responsible ll for the. initial notification to the FCP of emergency clas- I I

, sification levels and to provide instructions to begin acti-vation of the facility. The State Plan must be amended to .

reflect this responsibility. (NUREG-0654, F.1.e.) I

3. 'The Iowa State Highway Patrol representative who reported to the Clinton County Emergency Operations Center (CCEOC) did not have dosimetry. As the CCEOC is located in the plume emergency planning zone, dosimetry.is required for all emergency workers who report to this facility. This must be demonstrated during the next scheduled exercise.

(NUREG-0654, K.3.a.)  !

4. The State Plan is inconsistent regarding what organizations will report to the SEOC. For example, page II-13 indicates that the Department of Commerce and Capitol Security will-on page II-10,

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report to the SEOC. However, these organizations are not included. A similar problem exists with the Department of Corrections. The State notification procedures require.this organization to report to the SEOC.

However, the plan, in some cases, does not. The appropriate plan amendments must be made to correct the aforementioned concerns. (NUREG-0654, E.2.)

5. The State Plan does not indicate how dosimetry is distributed to the State Highway Patrol representatives who enter the EPZ. Therefore, the State Plan'must be amended to indicate where the dosimetry (self reading and permanent) is stored and how it is distributed to the Iufa State Highway ~~

Patrol. This amendment must also include all organizations i assigned to the State FCP who 2may enter the emergency planning zone. (NUREG-0554, K.3.a.)

2.1.2 State Forward Command Post (FCP)

Objective to be demonstrated: 36.

Objective Number 36, ability to carry out emergency response functions (i.e., activate EOC's, mobilize staff that report to the EOC's, establish communications linkage and complete telephone call down) during and unannounced off-hours drill or exerciss, was not adequately demonstrated.

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Activation of the State Forward Command Post (FCP) began at 1017 when the Iowa State Highway Patrol representative at the SEOC contacted this facility. The State organizations represented at this facility were the Highway Patrol, National Guard, Department of Transportation, and Department of Natural an inadequacy was identified as Resources. However, the Department of Natural Resources (DNR) representative failed to report to the FCP. The SEOC contacted this individual at 1052 with instructions to report to the FCP. An estimated arrival time of fifteen minutes was indicated. However, as stated previously, the DNR representative failed to report.

Contributing to this inadequacy was the fact that this same individual was contacted by the Clinton County Emergency Operations Center (CCEOC) and instructed to report to his respec-tive department and establish communications with the County EOC, pursuant to the plans. These inconsistent instructions may have contributed to the failure to report to the FCP. Based on the above, the inconsistency between the State and local plans must be resolved and the appropriate amendments made.

A second inadequacy was identified at this facility as the staff was not aware of the procedures for establishing the administrative conference line between the SEOC, County EOC's, and the FCP. Specifically, the Iowa DSD, alone, has the ability and the responsibility to establish this line from the SEOC. To achieve this, all organizations must keep the lines open.

However, the staff of the FCP.made several attempts to establish this system by contacting the SEOC over this line.

prevented the State from establishing the conference line for This action (-

thirty-four minutes. In addition, it was noted that some difficulty was observed in the installation of the system at the FCP. Based on the above, the appropriate training must be provided to the staff at the FCP and the activation of this system must be demonstrated during the next scheduled exercise.

As the. FCP is outside the plume" emergency planning zone, dosimetry was not required for the staff at this facility and, therefore, was not evaluated.

Summary: Objective ' Number 36 was not ' adequately demonstrated.

Areas Recuirine corrective Action

6. The Iowa Department of Natural Resources representative did not report to the State FCP. (DNR)

The SEOC contacted this individual at 1052 with instructions to report to the FCP. However, as stated previously, the DNR representative failed to report. Contributing to this inadequacy was the fact that this same individual was contacted'by the Clinton County Emergency Operations Center 8

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, (CCEOC) and instructed to report to his respective depart-ment, per the Clinton County Plan. These inconsistent in-C. structions may have contributed to the failure to report to the FCP.- Based on the above, the inconsistency between the .

State and local plans must be resolved and the appropriate amendments made. (NUREG-0654, E.2.)

7. The State Forward Command Post (FCP) staff was not aware of the procedures for establishing the administrative conference line between the SEOC, County EOC's, and FCP. As a result, the activation of this primary communication system was delayed for thirty-four minutes. The appropriate training must be provided and the activation of this system must be demonstrated during the next scheduled exercise.

(NUREG-0654, F.1.d.)

2.1.3 Field Team Coordination / Field Monitorina Teems '

Objective to be demonstrated: 36.

Objective Number 36, ability to carry out emergency response functions (i.e., activate EOC's, mobilize staff that report to the EOC's, establish communication linkage and complete telephone call down) during an unannounced off-hours drill or exercise, was fully demonstrated.

Field Team Coordination was performed at the Clinton County Emergency Operations Center (CCEOC) by staff from the University Hygienic Laboratory (UHL) located in Iowa City, Iowa. The field team coordinator and two radiological field teams were deployed during this drill. At 0950, the UHL was contacted by the State Department of Public Health and instructed to mobilize to the CCEOC. Per documentation provided by the field team coordinator, operational checks were made of the field monitoring instruments which were subsequently loaded into two vans; both teams departed at 1055. The UHL staff ultimately arrived at Clinton County at

1232. . .

In addition to the radiological monitoring equipment, both primary and backup communication systems utilized by the field team coordinator and the radiological field monitoring teams were transported to the county. Commun'ications were established between the field team coordinator and the dose assessment staff located at the SEOC in Des Moines, Iowa. The field team coordinator also transported the computer, software, and the standard operating procedures and other instructions / manuals required for this function.

All of the UHL staff had the appropriate dosimetry when they arrived at the county. Since the CCEOC is located in the plume EPZ, all emergency workers who arrive at this facility must have dosimetry.

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summary: There were no inadequacies observed that would require corrective action for this function. Objective Number 36 ( .

was fully demonstrated. (

2.1.4 Dose Assessment Objective to be demonstrated: 36.

Objective Number 36, ability to carry out emergency response functions (i.e., activate EOC's mobilize staff that report to the EOC's, establish communications linkage and complete telephone call down) during an unannounced off-hours drill or exercise, was fully demonstrated.

Dose Assessment was performed at the State Emergency Operations Center (SEOC) in Des Moines, Iowa. The State Department of Public Health (DPH) was responsible for this function. At 0941 the DPH was contacted by the Iowa Disaster  ;

Services Division (DSD) and instructed to report to the SEOC.

Two representatives fully staffed this function by 1010 as the DPH office is near the SEOC.

The equipment required for this function was set up and I operational as it would be during a full scale exercise.

Communications with the field team coordinator, located at the Clinton County Emergency Operations Center (CCEOC), were also established.

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function is located outside the plume emergency planning zone, dosimetry was not required.

Summary: There were no inadequacies observed that would require corrective action for this function. Objective Number 36 was fully demonstrated.

2.2 COUNTY OPERATIONS: e < . , - W 2.2.1 Clinton Cosnty Emercency ODerations Cen,ter (CCEOC) l Objective to be demonstrated: 36.

Objective Number 36, ability to carry out emergency response functions (i.e., activate EOC's mobilize staff that report to the EOC's, establish communications linkage and complete telephone call down) during an unannounced off-hours drill or exercise, was j not adequately demonstrated.  !

Clinton County was notified of the Alert emergency l classification level at 0948 by the Iowa Disaster Services  !

Division located in Des Moines, Iowa. Activation of the Clinton  !

l County Emergency Operations Center (CCEOC) and mobilization of I l

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- otaff b3gan nt 0950. Full staffing for the county level occurred f c . - at 1102. The State field team coordinator and; field teams f ' arrived at this location at 1232. .The CCEOC was fully activated- l with all' appropriate '

organizational staff reporting tol the . j facility. t.

The' ability to establish communications was not adequately..

demonstrated.- An area requiring. corrective action was identified-as the administrative conference line -(primary = communication-link)Kbetween.the SEOCi FCP, and County EOC's.was improperly used

- by Clinton and Scott Counties. This occurred because Clinton and Scott Counties utilized this line for a communication link.

However, this action prevented the SEOC from establishing the.ad-

- ministrative conference line between the State and local EOCs for-twenty-four minutes. The SEOC eventually ~ contacted the counties on a-separate line and instructed them to. stay off the line.until.

the conference line was established. Based on the above, the ap-propriate- training must be provided and_the activation of this system must be demonstrated during the next scheduled exercise.

With the exception of the' inadequacy identified with the-administrative. conference. line, all appropriate communication links were fully demonstrated. The Nuclear Accident Warning System (NARS) was demonstrated successfully to the county.

As the CCEOC is within the plume emergency planning zone, dosimetry was required for all emergency workers. All of the C county organizations who reported to the EOC were provided with the ' appropriate dosimetry. However, the Iowa State Highway Patrol officer who responded to this facility did notL have dosimetry. This concern is detailed-in Section 2.1.1. of this report. ,

Summarys . Objective Number 36 was not adequately demonstrated during this drill.

, Area Resuirina Corrective Action .,

s. The administrative conference line (primary communication link) was improperly used by Clinton and Scott Counties.

, This occurred because Clinton and. Scott Counties utilized this line for a communication'lin~k. However, 'this action prevented the SEOC from establishing- the administrative conference line between the aforementioned organizations for twenty-four minutes._ The SEOC eventually contacted the counties on a separate line and instructed them to stay off the line until the conference line was established. The appropriate training must be provided.and the activation of this- system must be demonstrated during the next scheduled exercise. (NUREG-0654, F.1.d.)

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2.2.2 Scott County Emeraency Operations Center (ECECCi -

Objective to be demonstrated: 36.

i objective Number 36, ability to carry out emergency response I functions (i.e., activate EOC's, mobilize staff that report to the EOC's, establish communications lirJ: age and complete i telephone call down) during an unannounced off-hours dr11.1 or '

exercise, was not adeque:ely demonstrated.

Scott County was notified of the Alert emergency classification level at 0947 by the Iowa ESD located' in Des Moines, Iowa. Activation of the Scott County Emergency Operations Center (SCEOC) and mobilization of stafi began immediately at 0948. All appropriate staff were- notified and mobilized with full staffing completed at 1103.

A planning inadequacy was identified with the Scott. County Plan concerning staffing. The Assistant to the Director assuned the role of the Director during the drill. Ecwever, the plan does not account for this contingency. Eue to- a malical emergency minutes prior to the initiation of the d=521, the Director was not available. Both of the alternates identified in the plan were out of town and unavailable. Therefore, the Assistant assumed the responsibility of the Director. Js the Scott County Plan does not provide for this cptico, the plan rust be amended to account for this contingency.

The ability to establish communications was net adequately demonstrated. An area requiring corrective act5sn was. idemtified as the administrative conference line between the SI:DC and the County EOC's was not established in a timely man':ter. The details of this inadequacy are contained in Section 2.2.L (Climtem County Emergency Operations Center) of this report. With the exception of the inadequacy identified with the administrative centference line, all appropriate communication links, includire the Euclear Accident Reporting System (NARS) , were fully demonstrated.

As the SCEOC is not located within the plume energency planning zone (EPZ), dosimetry was' not required for staff at this location. However, dosimetry kits were acallable to be distributed to emergency workers who may enter the EPE.

Area Reauirina Corrective Action

9. The Scott County Plan does not account fcr the Assistant to the Director assuming the role of the Trirector. The l appropriate plan change must be made to acce d for this l

contingency. (NUREG-0654,. A.2.a.)

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SUMMARY

OF AREAS REQUIRIN3 CORRECTIVE ACTICN IOWA STATE OPERATIONS State Emercency Operations Center (BEOC)

1. Due to technical complications, the Nuclear Accident Reporting System (NARS) failed to operate properly during this drill. The State Emergency Operations Center (SEOC) could not be contacted for notification of the Alert classification level utilizing this system. The NARS system never successfully contacted the SEOC during this exercise. Therefore, the technical correction must be made and this system demonstrated during the next scheduled exercise. (NUREG-0654, F.1.d.)

2. The Iowa Disaster Services Division (DSD) failed to notify the Forward Command Post (FCP) of the Alert classification level0938. in a timely manner. The Iowa DSD was notified of the Alert at However, the FCP was not subsequently notified until 1017 when the Iowa State Highway Patrol representative arrived at the SEOC.

This delay occurred in part because the State Plan fails to specify who is responsible for the initial notification to the FCP of emergency classification levels and to provide instructions to begin activation of the facility. The State Plan must be amended to reflect this responsibility. (NUREG-0654, C F.1.c.)

3. The Iowa State Highway Patrol representative who reported to the Clinton County Emergency Operations Center (CCEOC) did not have dosimetry. As the CCEOC is located in the plume emergency planning zone, dosimetry is required for all emergency workers who report to this facility. This must be demonstrated during the next scheduled exercise. (NUREG-0654, K.3.a.)

4. The State Plan is' inconsistent regarding what organizations will report to the SEOC. For example, page II-13 indicates that the Department of Commerce and Capitol Security will report to the SEOC. However, on page II-10, these organizations are not included. A similar problem exista with the Department of Corrections. The State notification procedures require this organization to report to the SEOC. However, the plan, in some cases, does not. The appropriate plan amendments must be made to correct the aforementioned concerns. (NUREG-0654, E.2.)

5. The State Plan does not indicate how dosimetry is distributed to the State Highway Patrol representatives who enter the EPZ.

Therefore, the State Plan must be amended to indicate where the dosimetry (self reading and permanent) is stored and how it is distributed to the Iowa State Highway Patrol. This amendment 13

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must also include all organizations assigned to the State FCP who. -

may enter the emergency planning zone. (NUREG-0654, K.3.a.)

State Forward Command Post (FCP)

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6. The Iowa Department of Natural Resources (DNR) representative did not report to the State FCP. The SEOC contacted this individual at 1052 with instructions to report to the FCP. However, as stated previously, the DNR representative failed to report.

Contributing to this inadequacy was the fact that this same individual was contacted by the Clinton County Emergency Operations Center (CCEOC) and instructed to report to his re. spec-tive department, per the Clinton County Plan. Thece inconsistent instructions may have contributed to the failure to report to the FCP. Based on the above, the inconsistency between the State and local plans must be resolved and the appropriate amendments made.

(NUREG-0654, E.2.) *

7. The State Forward Command ~ Post (FCP) staff was not aware of the procedures for establishing the administrative conference line between the SEOC, County EOC's, and FCP. As a result, the activation of this primary communication system was delayed for thirty-four minutes. The appropriate training must be provided and the activation of this system must be demonstrated during the next scheduled exercise. (NUREG-0654, F.1.d.)

COUNTY OPERATIONS

.Clinton County Emercency Operations Center (CCEOC)

8. The administrative conference line (primary communication link) was improperly used by Clinton and Scott Counties. This occurred because Clinton and Scott Counties utilized this line for a communication link. However, this action prevented the SEOC from I

establishing the administrative conference line between the aforementioned organizations for twenty-four minutes. The SEOC r eventually contacted the counties on a separate line and instructed them to stay off the line until the- conference line was established. The appropriateitraining must be provided and o

the activation of this system must be demonstrated during the

. next scheduled exercise. (NUREG-0654,. F.1.d. )

Scott County Emercency Operations Center (SCEOC)

9. The Scott County Plan does not account for the Assistant to the Director assuming the role of the Director. The appropriate plan change must be made to account for this contingency.

(NUREG-0654, A.2.a.)

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