ML20214R109

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Ack Receipt of Encl FEMA & Findings for Offsite Emergency Preparedness Aspects of Facility Exercise Conducted on 860415.No Deficiencies Requiring Corrective Action,But Weakness Requiring State Action Noted
ML20214R109
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 09/22/1986
From: Shafer W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Edelman M
CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8609290080
Download: ML20214R109 (2)


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SEP 2 21986 Docket No. 50-440 Docket No. 50-441 The Cleveland Electric Illuminating Company ATTN: Mr. Murray R. Edelman Vice President Nuclear Group Post Office Box 5000 Cleveland, OH 44101 Gentlemen:

We have received the enclosed Federal Emergency Management Agency (FEMA)

I letter dated September 5, 1986, containing the findings for the offsite l emergency preparedness aspects of the Perry Nuclear Power Plant exercise conducted on April 15, 1986. Based on the performance of the offsite

, agencies during the exercise, FEMA identified no deficiencies requiring corrective action. However, one weakness was observed that does require corrective action by the State of Ohio, t

We fully recognize that any remedial actions to be implemented may involve other parties and political institutions which are not under your direct l control. Nonetheless, we would expect the subject of offsite preparedness for the area around the Perry Nuclear Power Plant to be addressed by you as well l

as others.

I In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosure will be placed in the NRC's Public Document i Room.

l Sincerely, 2 50riginnisignedbyWI.infor' g92googg6 4o p W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch

Enclosure:

As stated See Attached Distribution RI RIII /

oster/mj e1 l r

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f The Cleveland Electric Illuminating 2 SEP 221986 Company i

Distribution cc w/ enclosure:

F. R. Stead, Manager, Perry Plant Technical Department M. D. Lyster, Manager, Perry Plant Operations Department E. M. Buzzelli, General Supervising Engineer, Nuclear Licensing and Compliance Section DCS/RSB(RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Harold W. Kohn, Ohio EPA Terry J. Lodge, Esq.

James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of I!ealth cc w/o enclosure:

D. Matthews, EPB, OIE 4

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Federal Emergency Management Agency f Washington, D.C. 20472 o G SEP 5 1986 MEMORANDUM FOR: Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U ./ Nug r g latory Canmission FROM: 16el: % , ir M /A Assistant Assopiate Director Office of Natural and Technological Hazards Programs SUBJECr: Exercise Report of the April 15, 1986, Exercise of the Offsite Radiological Emergency Preparedness Plans for the Perry Nuclear Power Plant.

n is is to transmit a copy of the Exercise Report of the April 15, 1986, joint exercise of the offsite radiological emergency preparedness plans for the Perry Nuclear Power Plant, near North Perry, in Iake County, Ohio. This was a joint, full participation exercise for the Ashtabula, Geauga, and Iake Counties in Ohio. h is was a partial participation exercise for the State of Ohio. The three counties are inpacted by Perry's plume exposure 10-mile Emergency Planning Zone (EPZ). W e report, dated July 14, 1986, was prepared by the Federal Emergency Management Agency (FEMA) Region V.

In the April 15, 1986, exercise there were no Deficiencies observed, but there was an inadequacy observed as requiring a corrective action. We State of Ohio has received a copy of the exercise report and will re-spond to FEMA Region V with a schedule for the corrective action. After the Region has received the schedule, and consulted with appropriate members of the Regional Assistance Ccmnittee (RAC), it will forward an evaluated schedule for the corrective action to this office. H e schedule will be transmitted to NRC after FEMA review and analysis.

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

Attachment As Stated b C s9,-

f Perry Nuclear P. wor Plant Cleveland Electric Illuminating Conpany Joint Exercise i

1 f Facility Location: Located-in the State of Ohio, near the village of North Perry l

l Exercise Date: April 15, 1936 Date Of Report: July 14, 1986 t

Partidipants: State of Ohio (partial); Ashtabula County (full); Geauga County (full); Lake County (full) and the Cleveland Electric Illuminating Conpany.

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' - Federal Energency Managenent Agency -

Region V Natural And Technological llazards Division 300 South Wacker Drive, 24th Floor Chicago, Illinois 60606 i

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( A 99-

TABLE OF CONTENTS TABLE OF CONTENTS page 2-EXECtTTIVE SIM4ARY page 3

. State of Ohio page 3 Ashtabula County page 5 Ceauga County page 8 Lake County page 10 EXERCISE REPORT page 12 j_ Introduction page 12

1. Exercise Background page 12 '

2.. Participating and Non-Participating State and Local Governaents page 12

3. List of Evaluators. page 12
4. Evaluation Criteria page 13 '
5. Exercise Objectives page 14
6. Sunnary of Scenario page 19 4
7. State and Local Resources Planned To Be Used In The Exercise page 21
8. Exercise Findings In Past Exercises page 22
9. Exercise Objectives Still To Be Effectively-1 Achieved page 23 Narrative page 24

, 1. State of Ohio page 24

2. Ashtabula County page 31
3. Ceauga County page 38
4. Lake County page 44

SUMMARY

LISTING OF EXERCISE FINDINGS page 53 l State of Ohio _

page 54

1. Deficiencies Affecting Public Health and Safety page 54
2. Required Corrective Actions page 55
3. Reconnendations For Inprovenent page 56 4 Ashtabula County _ page 57 4
1. Deficiencies Affecting Public Health and Safety page 57

'2. Required Corrective Actions page 58

3. Reconnendations For Inprovenent page 59

, Geauga County .

page 60

1. Deficiencies Affecting Public Health and Safety page 60
2. Required Corrective Actions page 61
3. Reconnendations For Inprovenent page 62 Lake County page 63
1. Deficiencies Affecting Public Health and Safety page 63
2. Required Corrective Actions page 64
3. Reconnendations For Inprovenent page 65 2

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EXECUTIVE SUT1ARY STATE OF OHIO The State Fnergency Operations Center (EOC) at Worthington, Ohio has been evaluated during nunerous previous radiological energency preparedness exercises. This was a partial participation exercise for the State. The FDC staf f consisted of representatives f torn the Ohio Departnents of Health and tigriculture, the Ohio Environaental Protection Agency (OEPA), and the Ohio Disaster Services Agency (ODSA) . Additional State staff were prepositioned for the exercise at the County EOCs, EOF, JPIC, and at predesignated staging areas for the connonications van and field nonitoring team.

The State EOC staf f demonstrated the ability to nobilize staff, activate facilities and maintain staffing around the clock at the State EOC, the utility's EOF, the JPIC and field teams. This was acconplished through the use of current rosters of personnel of the energency response organizations, and the actual and sinolated call-up of energency response personnel of agencies represented in the EOC. The denonstration of around the clock (24-hour) staffing at the EOF by the State of Ohio corrects an area which required corrective action from the exercise of November 28, 1984.

i-The EOC staff denonstrated ability to nake decisions; to coordinate energency activities, and to connonicate with all appropriate locations, organizations, and field personnel. Connunications was via a five-way dedicated telephone between the utility, the State and the three (3)

Counties of Ashtabula, Geauga and Lake. A problem with the five-way dedicated telephones existed briefly during the early part of the exercise.

Extraneous noise was heard over the receiver of the telephone in the EOC, but v_ ; quickly corrected when it was discovered that two (2) lines were being used at tha licensee's EOF and control center simultaneously. To prevent future recurrence of the problem it is 'reconnended that the utility's control center cease nonitoring the line innediately after the EOF is activated and EOF personnel begin acnitoring the line. Connonications by use of the five-way dedicated lines was an area requiring corrective action during the Novenber 1984 exercise of the Perry Nuclear Power Plant.

However, the minor problem that occurred on the telephone line during the exercise did not warrant required corrective action but a need for the users

~ - to be aware of the potential problem.

The EOC staff was able to project dosage to the public via the plune exposure based on plant and field data. Appropriate protective measures, such as sheltering and evacuation, were also reconnended by the State assessnent team based on protective action guides. The State along with the Counties also denonstrated ability to inplenent reconcendations to shelter lactating farm aninals and place them on stored feed.

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The State field nonitoring team actively participated in the exercise. This included denonstration of radiological monitoring equipnent, connonications capabilities, field team exposure control, and collection of sanples.

However, sanpling site F1 is located in a heavily wooded area. Because the site is sheltered by a vegetative canopy it is not a representative site to accurately assess air deposition of radionuclides on soil and surface vegetation. The site needs to be relocated. At sanpling site F2 radio '

connonications could not be established with the connonications van using the prinary vehicular radio system. However, connunications was re-established at a distance away from the site by use of a secondary hand held walkie-talkie radio. The F2 sangling site also necds to be relocated.

The Field team consisted of OEPA personnel from Columbus and the Twinsburg, Ohio District Office. OEPA staff of the Colunbus office denonstrated a high level of proficiency, however, the Twinsburg staff was less familiar with personnel protection procedures and criteria and sanpling procedures. It is reconnended that additional training be provided to the Twinsburg staff.

Additional opportunities for the Twinsburg staff to exercise would be useful.

Calibration record keeping needs to be kept up to date. Calibration dates were missing on a calibration sheet for one instrunent and another instrunent lacked a calibration sticker. This appeared to be a record keeping problem instead of a calibration problem. Routine calibration record keeping shcald be inproved.

The State, Ashtabula, Geauga and Lake Counties denonstrated six (6) objectives at the Joint Public Infornation Center (JPIC) . They included the weakness (Area Requiring Corrective Action) identified in the exercise of Novenber 1984, for the State and Counties failure to release information contained in EBS nessages at the JPIC.

The initial activation of the JPIC began at 10:27 A.M., when the Lakeland Connonity College Police established security in the area designated for use as the JPIC. The State DSA staff arrived at 11:35 A.M., while the Ashtabula County spokesperson arrived at 12:40 P.M. The Counties initiated staffing of the JPIC in real tine. Twenty-four (24) hour staffing capability was shown by double staffing and presentation of a roster.

The auditorium of the Performing Arts Building 'at Lakeland Connonity College is used as the nodia briefing room. The ODSA and the Counties had a work room on the second floor of the building adjacent to the Cleveland Electric Illuminating Conpany's work room. Tables, chairs, and telephones were available for nedia use.

Each County had a dedicated telephone to their EOC and the State had a dedicated telephone to the EOF. There was hard-copy capability between the JPIC and the various EOCs. The ODSA also had a radio link to their nobile van. JPIC nedia briefings were held. The briefings were accurate and conplete. The various spokespersons were prepared and responded to questions. Printed releases directed citizens to listen to their Energency Broadcast Station (EBS) . However, none of the printed or oral releases contained the call letters or frequencies of the EBS stations. This is an area reconnended for inprovenent.

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The JPIC staf f received copies of the EBS reessages released by the counties. They provided the nessages to the nedia present at the JPIC.

This corrected the weakness (Area Requiring Corrective Action) frorn the previous exercise.

AS!! TABULA COUNTY There were twenty (20) exercise objectives to be evaluated during this exercise. The Federal evaluation concluded that all exercise objectives for Ashtabula County were fully denonstratsl. No deficiencies or areas r~guiring corrective actions were identified. Sone reconnendations for inprovenent are reflected below.

The PNPP initially inforned Ashtabula County of the Unusual Event at 7:35 A.M. via the five-way dedicated telephone system. Written call lists were used to alert and mobilize DOC and field staff at each accident classification level. the Ashtabula County EOC was staffed and operational by 9:25'A.M. All agencies listed in the plan were represented in the EOC.

Extended capability to continue operations was denonstrated through the use of a roster and double staffing of selected EOC positions. The EOC staff denonstrated that they were trained, capable, and' knowledgeable of their duties and responsibilities. Team work was evident in naking decisions and coordinating energency activities. Facilities staffed and activated during the exercise included the Ashtabula County EOC, one (1) energency worker monitoring /decontaniination center and one (1) care center. County representatives were dispatched to the utility's energency operations facility and the joint public infornation center. Appropriate displays were used to support energency operations.

The Federal evaluation team reconnends that: (1) The Ashtabula County DSA Executive Group hold periodic briefings in the operations room where each departnent/ agency representative reports action taken by their agency /departnent. (2) More care and attention needs to be given by staff to accurately reflect the neaning of tine noted in nessages and log entries.

Does the tine reflected nean the tine an event occurred, or the tine the utility declared an accident classification level, or protective action reconnendation; the tine the State concurred with a utility reconnendation or decided on a protective action order; the tine the County received a nessage, ccncurred with a nessage or the tine the County decided to take action? (3) The adoption and use of a " standard" type status board with columns and headings / captions. (4) Consider the use of color coded transparent overlays on the radiological plotting maps, particularily the ten (10) mile EPZ nap where pre-arranged combinations by sectors could be used to display the plune and protective actions taken by Ashtabula County.

The Ashtabula County (Sherif f's) Connonications Center is located in the EOC. Both prinary and back-up connonications systens are available. Hard-copy capability was available between the EOC and the JPIC. The five-way dedicated telephone system is the prinary conmunications system between Ashtabula County, the PNPP, the State of Ohio, and the Counties of Geauga and Lake. The five-way telephone system was nore reliable than denonstrated during the 1984 exercise, but it did have several false rings and sone static noise. The County dispatcher was able to work through this noise and continued to answer the telephone in spite of the nunerous false rings. The Federal evaluation team reconnends that effort be continued to correct the situation and inprove the system so that a clear and interference free level 5

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of perfornance is demonstrated in the next exercise. The three-way dedicated telephone system between the tri-counties of Ashtabula, Ceauga and Lake perforned well and with no observable problems by the Federal evaluation team. The Federal evaluation team would also like to conplinent the anateur radio energency services personnel who denonstrated their 1

capability at the EOC and the care center.

At 12:27 P.M. the PNPP reconnended sheltering 360 degrees 0-2 miles of the PNPP, and 2-5 miles in subareas 1,2, and 3. The State concurred and issued this reconnendation to Ashtabula County at 12:35 P.M. Ashtabula County coordinated with Lake County concerning the activation of the pronpt alert

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notification system and the EBS. Ashtabula County added to the shelter protective action reconnendation that lactating aninals out to ten (10) miles should be sheltered and put on stored feed. This infornation was put in the EBS nessage prepared by Lake County. Ashtabula County coupleted its coordination with Lake County by 12:40 P.M. and the sirens were activated at 12:47 P.M. The EBS announcenents were started at 12:50 P.M. and were re-broadcasted at fif teen (15) minute intervals for a one (1) hour period.

Given these tines the public was alerted and received an instructional nessage within twelve (12) minutes of the tine the State issued the shelter protective action reconnendation to Ashtabula County.

The Ashtabula County assistant public infornation officer (PIO) at the County EOC established contact with the Ashtabula County PIO at the JPIC and coordinated infornation and news nedia naterial between the County EOC and the JPIC. The County PIO at the JPIC briefed the nedia in a clear, accurate and tinely nenner. He coordinated his infornation with the other spokespersons to ensure the infornation was accurate and consistent.

Infornation. from the EOC was received via the two-way dedicated telephone and the facsimile nachine. Information contained in EBS nessages was released at the JPIC.

Runor control was established in the County EOC. The rumor control number was announced to the nedia for use by the public. Eight (8) telephone calls were received by the runor control staff. Responses were innediately provided or an answer was obtained from the proper departnent/ agency

, representative.

At 1:25 P.M. the State of Ohio concurred with the PNPP reconnendation to evacuate 360 degrees 0-2 miles around the PNPP, and 2-10 miles in subareas 1,2,3,4, and 5. Lactating aninals out to ten (10) miles were to be put in shelter and placed on stored feed. The County concurred with the reconnendation at 1:27 P.M. and coordinated with Lake County to have the -

sirens activated at 1:37 P.M. and EBS activated at 1:39 P.M.

Access control was established on a tinely basis. One (1) traffic control point was actually denonstrated at Interstate Route 90 and Highway 45. The renaining access control points were procedurally denonstrated in the EOC.

Sufficient resources are available to the County to deal with inpedinents to evacuation such as bad weather or traffic obstructions.

The EOC staf f was aware of the ~1ocation of nobility inpaired individuals and i their special needs. Written procedures are in place to provide necessary transportation.

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The Spencer Elenentary School evacuation was initiated by the Superintendent of the School System. Per FEMA procedures there was no actual novenent of students. The Geneva School District transportation supervisor actually dispatched two (2) drivers and buses to the Spencer Elenentary School.

Infornation on the school evacuation plan for Ashtabula County was provided to the Federal evaluator at the Spencer Elemntary School by the school principal and the two (2) bus drivers. Further interviews by the Federal evaluator with the school superintendent and the Geneva School District transportation supervisor indicated that these school officials and the bus drivers ur.derstood the school's evacuation plan and the inglenenting procedures.

Ashtabula County denonstrated the ability to continuously nonitor and control energency worker exposure. Proper dosinetry were worn by enercency field workers and they were familiar with recording and reporting procedures. Energency workers were instructed to report their readings to their respective supervisors or dispatcher (s) on an hourly basis. They were aware of the noximani dose allowed without authorization, and knew the location of the energency worker nonitoring/ decontamination center.

A reception / congregate care center was activated and staffed at the Rowe Junior High School in Conneaut, Ohio. The center was staffed by representatives from the Conneaut Fire and Police Departaents, the Anerican Red Cross, and the Conneaut Anateur Radio Drergency Systeni (CARES) .

Staffing capability for continuing extended operations was denonstrated via a roster, showing replacenent staff. Procedures were denonstrated for registration and nonitoring of evacuees. The center had four (4) nonitoring teaua (2 for wonen and 2 for nen) participating in. the denonstrations. All individuals entering the center were scanned by the nonitoring teams for potential radiological contamination. The decontamination process was adequately demonstrated with proper handling of contaminated individuals, clothing, and possessions. Additional centers are listed in the plan and were considered for potential activation by the EOC staff during the exercise. Foodstuffs already in the school's cafeteria and/or local purchases would be nade available for feeding evacuees. The Anerican Red Cross would provide cots, blankets and a nursing station.

The energency worker nonitoring/ decontamination center was located at the Saybrook Fire Station. The Saybrook Elenentary School is the actual facility identified for the decontamination center but was not available for this exercise. The center staff displayed knowledge of decontamination procedures. Measures were taken to control energency worker exposure and the spread of contamination. The Saybrook Elenentary School is adequate in

! terns of showering facilities and space. An adequate supply of dosinetry, survey equipnent and other necessary supplies were available. Deficiencies identified at the Saybrook Fire Station during the 1984 exercise have been corrected.

The denonstration of adequacy of hospital facilities and procedures for handling contaminated individuals consisted of a tour of the Ashtabula County Medical Center (ACIC) . The walk through of the hospital revealed 1

that the hospital has the necessary equipnent to adequately treat contaminated patients. ' The equipnent observed included equipnent nentioned as deficient during the 1984 exercise. This included waste water. collection 7

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i containers, faucet hoses, and a whole-body wash tray.. Other inprovenents to the facility, since the last exercise, include non-absorbent paint in the treatnent roorn, grounded faucets, grounded electrical outlets in the room, and increased lighting in the hallway leading to the treatuent room.

GEAUGA COUNTY Geauga County selected and successfully denonstrated twenty-one (21) objectives during this exercise. The County denonstrated their ability to nobilize their staff and activate facilities in a tinely nenner, in accordance with the County plan and current standard operating procedures.

Twenty-four (24) hour staffing was denonstrated by double staffing and/or presentation of personnel rosters for the various positions.

Decision naking and coordination with Ashtabula and Lake Counties was effectively acconplished. Routine decisions are nade by staff nembers with najor problems elevated to the executive staff for reconnendations and final decisions. The system is officient and effective.

The Geauga County EOC facilities contain all the anenities necessary for twenty-four (24) hour per day operations on a continuous basis. All required naps and charts are pernanently displayed in the EOC, with furniture and telephones in place. Energency electrical power was available. Each staff nenber brought his/her agency's current SOPS and reference noterial to the EOC in readiness for operation. According to County EOC officials the EOC operations will be noved to a new EOC location within the next few nonths.  ;

The EOC staff denonstrated capability to connonicate with appropriate locations using prinary and secondary systems.

Alerting the public is acconplished through coordination of the tri-counties. When protective actions are agreed upon personnel in the Lake County EOC are responsible for sounding the siren system. Geauga County has the ability to independently sound sirens for the tri-county area if required. Prescripted EBS nessages are used where possible. The nessages are agreed upon by the three (3) Counties and released to EBS stations by

-Lake County. Hard copies of the EBS releases are sent to Ashtabula and Geauga Counties, the JPIC and the State EOC, to give the widest dissemination of the released infornation. The alert and notification system was activated twice during the exercise. The initial activation was when sheltering was reconnended and the second activation was when evacuation was reconnended. On both occasions public alerting was acconplished within the fif teen (15) minute criteria of NUREG-0654.

In the EBS notification nessages the sector reconnendations are converted to subareas that are easily described, using familiar landnarks and geo-political boundaries. This corrects an area requiring corrective action from the 1984 exercise of the Perry Nuclear Power Plant.

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At the general energency when sheltering was reconnended the Sheriff's Departnent placed deputies at traf fic control points to assist people who might voluntarily evacuate the EPZ. '4nen evacuation was ordered deputies were-in place to control traffic until relieved by State Highway Patrol personnel. The County Highway Departuent sinulated the dispatch of nen and equiptent to assist evacuation and control access to evacuated areas.

Status _ boards in the EOC were narked to show road blocks and traffic control points. In addition to County resources available, the National Guard staged their resources to assist the County with evacuation, clearing of

. inpedinents, and military policenen to help control access to the evacuated area.

The Fire Departuent/Drergency Medical Services (EMS) representative had a printed list of those persons, within the ten (13) mile EPZ, in Geauga County who are noblilty inpaired. EMS personnel would use ambulances belonging to the fire departuent, private conpanies, and the National Guard for transportation of the nobility inpaired.

There is one (1) school within the ten (10) mile EPZ of the PNPP in Geauga County. One of the considerations node at the alert status was early dismissal of the schools, so that school buses would be free to assist persons without transportation if evacuation becane necessary.

a The County provide all energency workers in/or near the EPZ with dosinetry kits that contain low and mid range dosineters, TLDs, a record form and an instruction sheet. Energency workers at roadblocks, decontamination stations and traffic control points displayed broad understanding of how the dosinetry is used and what it indicated.

All inquiries node to the EOC for infornation were referred to the JPIC.

All briefings to the nedia were conducted at the JPIC. Infornation was coordinated on the three-way telephone between the Counties before it was i released to EBS or the JPIC. A dedicated telephone is used between the JPIC and Geauga County to coordinate infornation.

The County controlled runors from the EOC. The runor control officer receives infornation from the executive staff and the JPIC. Injected problens were used to test the runor control function which perforned well.

The reception and congregate care center was simulated to be activated at the site area energency notification during the exercise play. However, it was actually activated late in the evening on the exercise date and out of sequence with the regular exercise play, per pre-exercise agreenent between the ODSA and FEMA. The West Geauga High School is used as the prinary care facility. The Anerican Red Cross provides registration and support for shelter operations. The Geauga Anateur Radio Association provides back-up connonications to the EOC in the event connercial telephones are inoperable. The Chester Police Departnent provided security at the center, and the Chester Fire Departnent denonstrated that they were well versed in the use of radiological equipnent to nonitor evacuees and to provide decontamination as necessary. The Geauga County Health Departnent insures the adequacy of sanitation. The center provided child care, a nursing station, feeding area, and sleeping facilities.

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The denonstration of decontamination of energency workers, equipnent and vehicles was conducted at the lianbden Volunteer Fire Departnent. The facility is well staffed and workers are well trained. The station is equipped with a drive through bay for decontamination of vehicles. The appropriate nonitoring equipnent was available and the team had a thorough understanding of its use. In accordance with energency worker decontarnination SOPS, areas of the body found contaminated are narked on the registration sheet showing the area and anount of contamination. If contaminated the person (s) are taken to the appropriate facility (nale or fenale) for decontamination. After decontamination in accordance with the SOP, only those areas found contaminated are to be renonitored, instead of a conplete whole body renonitoring of individuals. It is reconnended this SOP be reviewed for accuracy and rewritten so that the whole body is renonitored.

Appropriate neasures were taken to control the spread of contamination.

Break-down procedures were denonstrated to show control of the spread of contaminants and the proper disposition of waste naterials.

During the decontamination of a vehicle a contaminated worker was simulated to have been injured. The EMS anbulance unit at the worker decontamination station was used to transport the victim to the Geauga Contronity liospital.

The appropriate steps were taken to isolate and protect the victim. The EMS anbulance is equipped with two-way radio for direct connunications with the hospital.

The energency room doorways, closet doors, and air ducts were sealed by energency room staff at the hospital in preparation for receiving the {

contaminated victim. Other areas were delienated using rope and/or warning tape. Floors were covered with plastic to contain contamination. The plastic was slippery on the floor and caused problems in noneuvering the hospital cart when attenoting to renove the victim from it. This is an area recontrended for inprovenent. The nurses, radiological nonitors, and physicians were properly dressed and wore nane labels to enable recognition of persons.

A beta button was used to sinulate contamination. The patient was surveyed.

for contamination and the beta button source was readily located by the energency room team. Decontamination procedures were inglenented while nedical treatnent was proceeding.

LAKE COUNTY The Lake County EOC housed a staf f that ef fectively nanaged the situation, nade tinely decisions, and had conprehensive knowledge and resources to efficiently carry out the radiological energency response plan.

Coordination and cooperation was evident internally as well as with the utility, State and other participating Counties. I 10

The connonications with the State, utility, other Counties, field nonitoring teaus and JPIC were denonstrated during the exercise and found to be effective. W o (2) Lake County field nonitoring teans were nobilized and deployed in a timely fashion. They denonstrated equipnent and procedures suitable for determining anbient radiation levels in the plune EPZ.

Appropriate equipnent and procedures were denonstrated for the neasurenent of radiciodine concentrations in air as low as 10-7 uCi/cc in the presence of noble gases. It is reconnended that the field teans equipnent include all appropriate naps for interpretation of connonications received from the I EOC.

The executive group was officient in performing their responsibility to alert the public and disseminate the initial instructional nessage within the fif teen (15) minutes as set forth in the guidelines. The organizational ability and resources to carry out an evacuation for part of the plune EPZ 1 was effectively acconplished during the course of the exercise. Personnel

at the evacuation referral point were well prepared and knew how to cope with the problens that would arise at their respective stations. Deviation froai the written plan appears to have created a slight problem on how nany people were sent to a care center. The plan as written should be followed, i.e. , " hand out one strip nap per person".

The traf fic and access control areas were nanned by capable officers who were knowledgeable of their tasks. They were able to naintain radio connonications with the County EOC and other traffic control points. The procedures for evacuation of the nobility inpaired was denonstrated at the EOC. The Madison School District has the necessary resources and organizational ability to ef fect an evacuation of schools within the plune EPZ.

The East Lake Fire Departnent denonstrated their ability to prepare and operate a decontamination center. They denonstrated the registration and total body scan by use of the CDV 700 geigher counter.

The anbulance crew knew what procedures they were to follow in transporting the contaminated injured person to the hospital. The hospital demonstrated their capability to handle an injured contaminated patient.

The Lake County PIO's assigned position is at the JPIC with a liaison PIO at the EOC. The connonications between the EOC and JPIC was by dedicated

telephone and facsimile. The news releases were coordinated through the executive group. The runor control was handled by a well trained EOC staff i person. The Ancrican Red Cross deaonstrated their ability to prepare, open and operate the reception and care center to full capacity. They successfully denonstrated their capability to work under adverse conditions.

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EXERCISE REPORT INTRODUCTION

1. EXERCISE BACKGROUND This was the second joint exercise for the Ohio Disaster Services Agency and the Counties of Ashtabula,.Geauga and Lake resulting from a simulated accident at.the Perry Nuclear Power Plant. The first joint exercise was on Novenber 28, 1984 and involved full scale participation by the State of Ohio and the aforenentioned Counties. This report addresses the most recent joint exercise for the Perry Nuclear Power Plant which was conducted on April 15, 1986.
2. PARTICIPATING AND NON-PARTICIPATING STATE AND LOCAL GOVERNMENTS The' ten (10) mile inhalation energency planning zone (EPZ) of the Perry Nuclear Power Plant inpacts on parts of Ashtabula, Geauga and Lake Counties, as well as Lake Erie, with the najor portion of the zone falling wi..in Lake County. The 1980 pernanent population within the ten (10) mile EPZ is estinated at 93,867. The influx of sunner vacationers increases the population considerably.

The fif ty (50) mile ingestion pathway zone enconpasses parts of eight (8)

Counties within the State of Ohio and three (3) Counties within the State of Pennsylvania. The renaining portion of the fif ty (50) mile ingestion pathway zone is located over Lake Erie. In addition to Ashtabula, Geauga and Lake Counties other Ohio Counties within the fifty (50) mile EPZ include Cuyahoga, Sunmit, Portage, Trunbull, and Mahoning. The Pennsylvania Counties are Erie, Crawford and Mercer. The foregoing Ohio and Pennsylvania Counties beyond the ten (10) mile EPZ did not denonstrate the procedures for inglenentation of ingestion EPZ protective actions as this activity was beyond the scope of the exercise. This exercise was conducted during nornal working hours.

3. LIST OF EVALUATORS For this exercise there was a total of twenty-one (21) federal evaluators observing off-site exercise activities. On-site exercise activities were evaluated by a separate team from the Nuclear Regulatory Conmission. The off-site evaluation teen included eight (8) evaluators from FEMA Region V, two (2) from the Environnental Protection Agency (EPA), one (1) from the U.S. Departnent of Transportation (DOT), one (1) from Health and Hunan Services (HHS) and nine (9) from the Argonne National Laboratory (ANL) . The evaluator assignnents were as follows:

OFF-SITE EXERCISE EVALUATION TEAM DIRECTOR Wallace J. Weaver, FEMA 12

STATE OF OllIO Woodie Curtis, Teatu Leader, FE%

- Don Jankowski, At:L Larry Jensen, EPA Pete Tedeschi, EPA Williani Knoetzer, ANL Patricia Buckley, FE%

Ray Kellogg, FE%~

ASitTABULA COUNTY Dan Benent, Teani Leador, FEMA Jerry Staroba, ANL Kenneth Rose, ANL Roxanne Izzo, ANL Patricia Buckley, FEMA

-Ray Kellogg, FEMA GEAUGA COUNTY Wiley liowell, Tearn Leader, FE%

Bob Neisius, ANL Walter O'Keefe, FEMA / ARC j Kent Jaffe,liHS j Roger Stokes, DOT Patricia Buckley, FEMA

! Ray Kellogg, FEMA LAKE COUNTY Ed Robinson, Teani Leader, FEMA Bill Charrbers, ANL Carolyn Ilirshberg, ANL Les Conley, ANL Walter O'Keefe, FEMA / ARC Kent Jaffee, HHS Patricia Buckley, FEMA Ray Kellogg, FEMA 1

4. EVALUATION CRITERIA The plans being evaluated by this exercise were developed by using the

" Criteria for Preparation and Evaluation of Radiological Energency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0654/ FEMA REP-1, Revision 1). Therefore, these criteria and the exercrit based on these criteria, " Modular Fortnat For Uniforniity of Radiological Energency Preparedness Exercise Observations and Evaluation", dated June 1983 were used for exercise evaluation.

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5. EX2RCISE OBJICTIVES Objectives for this exercise were selected from anong the thirty-five (35) standard objectives listed in Tab "M" of the " Modular Fornet For Uniformity of Radiological Energency Preparedness Exercise Observations and Evaluation", dated June 1983. The objective nunbers listed below correlate to Tab "M".

The State of Ohio selected the following eighteen (18) objectives, including those applicable to the Joint Public Infornation Center (JPIC) to be denonstrated during the exercise.

1. Denonstrate ability to nobilize staff and activate facilities pronptly.
2. Denonstrate ability to fully staff facilities and maintain staffing around the clock.
3. Denonstrate ability to nake decisions and to coordinate energency activities.
4. Denonstrate adequacy of facilities and displays to support energency operations.
5. Denonstrate ability to connonicate with all appropriate locations, organizations, and field personnel.
6. Denonstrate ability to nobilize and deploy field nonitoring teams in a tinely fashion.
7. Denonstrate appropriate aquipnent and procedures for determining anbient radiation levels.
8. Denonstrate appropriete equipnent and procedures for neasurenent of airborne radiciodine concentrations as low as 10-7 uCi/cc in the presence of noble gases.
9. Denonstrate appropriat? equipnent and procedures for collection, transport and analysis of sanples of soil, vegetation, snow, water, and milk.
10. Denonstrate ability to project dosage to the public via plune exposure, based on plant and field data, and to determine appropriate protective
neasures, based on PAG's, available shelter, evacuation tine estinates, and

- all other appropriate factors.

12. Denonstrate ability to inglenent protective actions for ingestion pathway hazards.
13. Denonstrate ability to alert the public within the ten (10) mile EPZ, and disseniinate an initial instructional nessage, within fif teen (15) minutes.

, 14. Denonstrate ability to fornulate and distribute appropriate instructions to the public, in a tinely fashion.

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15. Denonstrate the organizational ability and resources necessary to nanage an orderly evacuation of all or part of the plune EPZ.

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20. Denonstrate ability to continuously nonitor and control energency worker exposure.
24. Denonstrate ability to brief the nedia in a clear, accurate and tinely nenner.
25. Denonstrate ability to provide advance coordination of infornation released.
32. Denonstrate ability to identify need for, request, and obtain Federal assistance.

Ashtabula County selected the following twenty (20) exercise objectives, including those applicable to the JPIC, to be denonstrated during the exercise.

1. Denonstrate ability to nobilize staff and activate facilities pronptly.
2. Denonstrate ability to fully staf f facilities and naintain staffing around the clock.
3. Denonstrate ability to nake decisions and to coordinate energency activities.
4. Denonstrate adequacy of facilities and displays to support energency operations.
5. Denonstrate ability to connonicate with all appropriate locations, organizations, and field personnel.
13. . Denonstrate ability to alert the public within the ten (10) mile EPZ, and disserninate an initial instructional nessage, within fif teen (15) minutes.
14. Denonstrate ability to fort clate and distribute appropriate instructions to the public, in a tinely fashion.
15. Denonstrate the organizational ability and resources necessary to nanage an orderly evacuation of all or part of the plune EPZ.

16.- Denonstrate the organizational ability and resources necessary to deal with inpedinents to evacuation, as inclenent weather or traffic obstructions.

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17. Denonstrate the organizational ability and resources necessary to control access to an evacuated area.
18. Denonstrate the organizational ability and resources necessary to ef feet an orderly evacuation of nobility inpaired individuals within the plune EPZ.
19. Denonstrate the organizational ability and resources necessary to effect an orderly evacuation of schools within the plune EPZ.
20. Denonstrate ability to continuously nonitor and control energency worker exposure.

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24. Dencnstrate ability to brief the nodia in a clear, accurate and tinely nanner.
25. Denonstrate ability to provide advance coordination of infornation released.
26. Denonstrate ability to establish and operate runor control in a coordinated fashion.
27. Denonstrate adequacy of procedures for registration and radiological nonitoring of evacuees.-
28. Denonstrate adequacy of facilities for noss care of evacuees.
29. Denonstrate adequate equipnent and procedures for decontamination of energency workers, equipnent and vehicles.
31. Denonstrate adequacy of hospital facilities and procedures for handling I contaminated individuals.

Geauga County selected the following twenty-one (21) exercise objectives, including those applicable to the JPIC, to be denonstrated during .the exercise.

1. Denonstrate ability to nobilize-staff and activate facilities pronptly.

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2. Denonstrate ability to fully staff facilities and naintain staffing around the clock.
3. Denonstrate ability to make decisions and to coordinate energency activities.
4. Denonstrate adequacy of facilities and displays to support energency operations.
5. Denonstrate ability to connonicate with all appropriate locations, organizations, and field personnel.
13. Denonstrate ability to alert the public' within the ten (10) mile EPZ, and disseminate an initial instructional nessage, within fif teen (15) minutes.

- 14. Denonstrate ability to fornulate and distribute appropriate instructions to the public, in a tinely fashion.

I 15. Denonstrate the organizational ability and resources necessary to nanage an orderly evacuation of all or part of the plune EPZ.

16. Denonstrate the organizational ability and resources necessary to deal with inpedinents to evacuation, as inclenent weather or traf fic obstructions.
17. Denonstrate the organizational ability and resources necessary to control access to'an evacuated area.

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18. Deionstrate the organizational ability and resources necessary to
effect an orderly evacuation of nobility inpaired individuals within the pluae EPZ.

2 19. Denonstrate the organizational ability and resources necessary to effect an orderly evacuation of schools within the plune .EPZ.

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20.. Denonstrate ability to continuously nonitor and control energency worker exposure.

24. Ibnonstrate ability-to' brief the nedia in a clear accurate and tinely nanner.

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25. Denonstrate ability to provide advance coordination of infornation 1 released.

j 26. Denonstrate ability to establish and operate runor control in a coordinated fashion.

27. Denonstirate adequacy of procedures for registration and radiological nonitoring of evacuees.

,j 28. Denonstrate adequacy of facilities for nass care of evacuees, j 29. Denonstrate adequate equipnent and procedures for decontamination of i energency workers, equipnent and vehicles.- e i

! 30. Denonstrate adequacy of anbulance facilities and procedures for handling contaminated individuals.

j 31.- Denonstrate adequacy of hospital facilities and procedures for handling j

e contaminated individuals. ,

i Lake County selected the following twenty-four (24) exercise objectives, including those applicable to the JPIC, to be denonstrated during the exercise.

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! 1. Denonstrate ability to nobilize staff and activate facilities prenptly.

! 2. Denonstrate ability to fully staff facilities and maintain staffing l around the clock.

3. Denonstrate ability to nake decisions and to coordinate energency .

activities, i

j 4-. Denonstrate adequacy of facilities and displays to support energency

. operations.

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l 5. Denonstrate ability to contionicate with all appropriate locations, organizations, and field personnel, i 6. Denonstrate ability to nobilize and deploy field nonitoring teams in a tinely fashion.

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7. Denonstrate appropriate equipaent and procedures for deterniining anbient radiation levels.
8. Denonstrate appropriate equipnent and procedures for neasurenent of airborne radioiodine concentrations as low as 10-7 uCi/cc in the presence of noble gases.
13. Denonstrate ability to alert tdie public within the ten (10) niile EPZ, and disseniinate an initial instructional nessage, within fif teen (15) niinutes.
14. Denonstrate ability to fornolate and distribute appropriate instructions to the public, in a tinely fashion.
15. Denonstrate the organizational ability and resources necessary to nanage an orderly evacuation of all or. part of the plune EPZ.
16. Denonstrate the organizational ability and resources necessary to deal with inpedinents to evacuation, as inclenent weather or traffic obstructions.
17. Denonstrate the organizational ability and resources necessary to control access to an evacuated area.
18. Denonstrate the organizational ability and resources necessary to '

effect an orderly evacuation of nobility inpaired individuals within the plune EPZ.

19. Denonstrate the organizational ability and resources necessary to effect an orderly evacuation of schools 9ithin the plune EPZ.
20. Denonstrate ability to continuously nonitor and control energency worker exposure.
23. Denonstrate ability to effect an orderly evacuation of on-site personnel.

l 24. Denonstrate ability to brief the nodia in a clear, accurate and tinely nenner.

25. Denonstrate ability to provide advance coordination of infornation released.
26. Denonstrate ability to establish and operate runor control in a

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coordinated fashion.

27. Denonstrate adequacy of procedures for registration and radiological nonitoring of evacuees.
28. Denonstrate adequacy.of facilities for noss care of evacuees.
30. Denonstrate adequacy of anbulance facilities and procedures for handling contaniinated individuals.
31. Denonstrate adequacy of hospital facilities and procedures for handling contaniinated individuals.

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6.

SUMMARY

OF SCENARIO The Perry Nuclear Power Plant radiological energency preparedness scenario, j developed by writers from the utility and the State, took into consideration areas requiring corrective actions, identified in the first exercise of the

! PNPP site. This was done in order to develop a scenario that would allow denonstration of past required corrective actions as well as allow

! denonstration of exercise objectives selected by the State of Ohio, j .Ashtabula, Geauga and Lake Counties.

Representatives from the Perry Nuclear Power Plant, the State of Ohio, Ashtabula, Geauga, and Lake Counties and FEMA Region V net January 21, 1986 g

at the Lake County Energency Operations Center to select the exercise objectives and to discuss the scope of the exercise. Submission of the scenario to FEMA Region V was according to deadlines outlined in Nuclear Regulatory Contnission (NRC) and Federal Energency Managenent Agency (FEM) guidance. Westinghouse. Idaho Nuclear Conpany Incorporated reviewed the off-site portion of the scenario for FEMA and found the scenario adequate to j

exercise'the objectives selected. A sunnary of the scenario follows.

k The Perry Nuclear Power Plant has ' men operating continuously for tia last f seventeen (17) nonths, since the last refueling outage. The plant is currently operating at one hundred (100) percent power and is near the end

! of core life. Preparations are underway for a refueling outage, scheduled j to begin in four (4) weeks. Sone equipnent problems are ongoing, but all i have been addressed through surveillance activities.

Weather conditions renain constant, with the forecast indicating a high in the inid-forties with calm winds out of the northwest.

At 0710, A PNPP operator working at the Turbine Sanpling Panel receives an electrical shock and is knocked unconscious. He is injured and ,

contaminated. Health Physics support and a first aid team are dispatched to the area.

At 0715, the shif t supervisor requests that an anbulance be' dispatched to

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transport the contaminated injured person off-site. An Unusual Event is declared in accordance with EPI-Al, Section N.l.1, " Transportation of contaminated injured individuals from the site to off-site hospital."

  • From 0730 to 0800, the anbulance arrives, the victim is placed in the vehicle and the anbulance leaves the site.

I j At 0815, a resin spill occurs in the area of the Turbine Power Couplex and radiation levels in the area of the spill increases to one thousand (1000) i tines nornal. An Alert is declared per EPI-Al, Section E.II.1, "High radiation levels or airborne contamination which indicates a severe i degradation in the control of radioactive naterials." The Technical Support i Center (TSC) and Operations Support Center (OSC) are activated.

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The TSC and OSC are operational by 0845. At this tine, an oil fire is discovered in the area of the Turbine Building Chillers. The Control Room is notified, the fire brigade is dispatched and by 0915, the fire is out.

Off-site fire fighting support is provided by the Perry Township Fire Departnent.

A pipe rupture occurs in the circulating water system at 1015. The break occurs in the twelve (12) foot dianeter fiberglass, underground pipe.

section, flooding the plant yard. The noin condenser and auxiliary condenser vacuuns decrease rapidly, resulting in a turbine trip and reactor scram. The nain steam isolation valves isolate on low condenser vacuum, and reactor pressure increases. Attenpts to open safety relief valves fail as a result of solidified Safety Relief Valve (SRV) packing.

The Reactor Core Isolation Cooling system (RCIC) is nanually started at 1021.

At 1930, one (1) of the SRVs opens. As the reactor depressures, the SRV closes, resulting in increased reactor pressure. This SRV continues to cycle between 950 psi and 1300 psi. The water level renains constant.

At 1045, reactor coolant is released through a RCIC steam line crack at the weld just upstream of Outboard Isolation Valve E51-F064. Steam Tunnel

- ambient tenperature and ventilation differential tenperature monitors alarm, and the RCIC isolation tiner starts.

The RCIC isolation tiner shuts the Outboard Isolation Valve at 1055. A Site Area Energency is declared in accordance with EPI-Al, Section C.III.1,

" Steam line break outside containnent without isolation." The Energency Operations Facility (EOF) and Joint Public Infornation Center (JPIC) are activated.

The Plant conditions renain stable and reactor cooldown continues.

At 1215, the RCIC steam line crack increases and vessel level begins to decrease.

A General Drergency should be declared at 1230 in accordance with EPI-Al, Section A.IV.3," Snall or large LOCA with failure of EOCS to perform, leading to core degradation or nelt in minutes to hours. Loss of

. 'containnent integrity nay be intninent", or per Section A.IV.1, " Loss of two (2) fission product barriers with a potential loss of a third barrier." A I precautionary protective action reconnendation (shelter to two (2) miles,

- 360 degrees, and shelter five (5) miles downwind) should be node. The reactor continues to depressurize through the RCIC steam line crack.

At 1245, Auxiliary Building Exhaust Fan B fails due to seized bearings. The reactor level reaches one (1) Top Active Fuel (TAF) at 1255.

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At 1300, the reactor boils down to below TAF and fuel danage occurs. Area radiation nonitors alatm in the area of the suppression pool. The Turbine

- Building Vent low range nonitor indicates substantially increased levels of radiation. The release rate peaks at 1.23 Ci/Sec. This release results in a six hour projected thyroid dose of 52.7 Rem (unprotected) at 2.5 miles; the corresponding whole body dose is 0.3 Rem, therefore the thyroid dose will drive the protective actions. According to PNPP procedure, this accident should result in a mininum re onnendation of evacuation out to four (4) miles. The significant release lasts for approxinately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, ceasing at 1430. Meteorological conditions during the release are as:

follows:

Wind Speed 2.5 miles per hour Direction: from 310 degrees Tenperature: 45 degrees farenheit Pasquill Stability Class: D At 1445, inboard the RCIC valve closes and RHR B subsequently is cooling the core in shutdown cooling mode.

Winds of approxiaately twelve (12) miles per hour begin to disperse the plune at 1500, and by 1530, off-site radiation levels return to background.

The General Blergency is downgraded, and re-entry and recovery actions are initiated at 1530.

At 1700, the exercise is terminated.

The actual occurrence of events at the utility during the exercise were as follows:

The Unusual Event 7:35 A.M.

The Alert Declaration 8:30 A.M.

Site Area Energency Declaration 11:00 A.M.

The General Eaergency Declaration 1:27 P.M.

7. STATE AND LOCAL RESOURCES PLANNED TO BE USED IN THE EXERCISE l

During this exercise the State of Ohio planned to use the State EOC in Worthington, Ohio and the JPIC at the Lakeland Connonity College, Kirtland, Ohio. .The State of Ohio also planned to use the necessary connonications systens to conduct energency operations . The utility manned the EOF, which included representatives from the State and the three (3) Counties.

Ashtabula, Geauga and Lake Counties planned to denonstrate their EOC facilities, energency response staff and connonications systems capabilities and runor control. The three (3) Counties planned to have spokespersons at the JPIC to denonstrate their ability to coordinate public infornation.

Lake County denonstrated their ability to nobilize and deploy field nonitoring teaus in a tinely fashion. In addition, the three (3) Counties planned to denonstrate reception / congregate care and decontamination centers and the adequacy of ambulance and hospital facilities and procedures for handling contaminated individuals.

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8 .- EXERCISE FINDINGS IN FAST EXERCISES j There were four (4) weaknesses (areas requiring corrective actions)~ and five (5) recormendations identified for the State of Ohio during the evaluation of the Novenber 28, 1984 joint participation exercise for the Perry Nuclear Power Station. Corrective actions for the four (4) weaknesses (areas requiring corrective actions) for the State of Ohio have been denonstrated as a result of the April 15, 1986 exercise of the Perry Nuclear Power I Station.

There were five (5) weaknesses (areas requiring corrective actions) j identified for both Ashtabula and Lake Counties during the evaluation of the Novenber 28, 1984 joint participation exercise of the Perry Nuclear Power Plant. Corrective actions for all the areas requiring corrective action in both Ashtabula and Lake Counties have been denonstrated as a result of the April 15,1986 exercise of the Perry Nuclear Power Plant.

There were three. (3) weaknesses (areas requiring corrective actions)

identified for Geauga County during the evaluation of the Novenber 28, 1984 joint participation exercise of the PNPP. Corrective actions for the three (3) areas requiring corrective action have also been denonstrated as a result of the April 15, 1986 exercise of the PNPP.
9. EXERCISE OBJECTIVES STILL TO BE EFFECTIVELY ACHIEVED State of Ohio The State of Ohio did not conpletely denonstrate exercise objective #9 (Appropriate equipnent and procedures for collection, transport and analysis of sanples of soil, vegetation, snow, water and milk).

Appropriate action will be required to correct the inconpleted exercise objective. The objective nest be successfully denonstrated during the next biennial radiological energency preparedness exercise of the PNPP.

Ashtabula County All exercise objectives for Ashtabula County were denonstrated.

Ceauga County i All exercise objectives for Geauga County were denonstrated.

Lake County All exercise objectives for Lake County were denonstrated.

The fo!]owing list of exercise objectives were not selected for denonstration during this exercise. They should be denonstrated during a future exercise. The appropriate jurisdictions to denonstrate each objective are noted.

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11. Denonstrate ability to project dosage to the public via ingestion pathway exposure, based on field data, and to determine appropriate protective neasures, based on PAGs and other relevant factors. (State of Ohio).
12. Denonstrate ability to inglenent protective actions for ingestion pathway hazards. (Ashtabula, Geauga and Lake Counties) .
21. Denonstrate ability to nake the decision, based on predetermined criteria, whether to issue KI to energency workers and/or the general population. (State of Ohio, Ashtabula, Geauga and Lake Counties) .
22. Denonstrate the ability to supply and adniinister KI, once ti.e decision has been nade to do so. (State of Ohio, Ashtabula, Geauga and Lake Counties).
35. Denonstrate ability to determine and inglenent appropriate neasures for controlled recovery and reentry. (State of Ohio, Ashtabula, Geauga and Lake Counties).

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NARRATIVE

1. STATE OF OHIO ACTIVATION AND STAFFING The State of Ohio's participation in the exercise was in a partial node.

All State energency response personnel were pre-positioned with limited activity at the State Energency Operations Center per pre-exercise agreenent between the Ohio Disaster Services Agency (ODSA) and FENA.

The State staff assisted the Counties by staffing the Utility's Diergency Operations Facility (EOF), the Joint Public Infornation Center (JPIC) and the nobile contronications van, in addition to dispatching field nonitoring teams, and activation of the State EOC at Worthington, Ohio.

The State staff demonstrated ability to staff facilities and nointain staffing around the clock by double staffing at the JPIC and the dose assessnent team. The staff of the EOC, the field nonitoring team and the contronications team were double staffed and presented rosters of personnel for subscq2ent shif ts in case of an extended operation.

The State EOC is situated in the basenent of the Ohio National Guard Arnory. Contronications between the ODSA, the Perry Nuclear Power Plant (PNPP), and the three (3) Counties (Ashtabula, Geauga, and Lake) that are inpacted by the PNPP is via a five-way dedicated telephone system The lines are nonitored around the clock (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

Personnel of the utility's Technical Support Center (TSC) notified the State and the Counties of the Alert conditions at the utility at 8:40A.M.via the five-way dedicated telephone lines. The call from the Utility was verified at the EOC by telephone call-back to the TSC by the assessment room supervisor. Staff nobilization procedures were denonstrated through sinulation and by use of an up-to-date telephone call-up roster. Initial contact persons of respective agencies, that would nornally be represented in the EOC, were telephoned by EOC staff and inforned of the ' exercise beginning at approxinately 8:43 A.M., shortly after the Utility notified the State and County EOCs of the Alert Conditions at the PNPP. Staff notification and nobilization of personnel from the ODPH, OEPA, ODA and ODSA were conpleted at 8:52 A.M. and 9:05 A.M. respectively.

According to exercise participants the use of call-up rosters as utilized during the exercise is the system in place to receive calls directing activation and nobilization of staff at any hour of any day. The EOC, the EOF and the JPIC were fully staffed for the State's partial participation in the exercise as had been agreed between the State and FEMA.

EMERGENCY OPERATIONS MANAGD4ENT The Energency Response Coordinator was the individual effectively in charge of the EOC operations for the State's partial participation in the exercise.

Periodic briefings were held to update the staff on the situation at the utility and other locations participating in the exercise. The staff was actively involved in decisions and decisionnaking. Copies of the plan were available for reference and nost of the staff had checklists and/or excerpts of the plan that pertained to their respective responsibilities. Message logs were kept, nessage handling was efficient, and nessages were reproduced and distributed as appropriate.

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The EOC staff received telephone notification of the Unusual Event at the Perry Nuclear Power Plant at 7:40 A.M., via the five way dedicated telephone; the Alert Conditions at 8:40 A.M.; the Site Area Energency at 11:06 A.M. and the General Energency at 12:32. The foregoing events had been declared by the Utility at 7:35 A.M, 8:30 A.M, 11:00 A.M. and 12:27 P.M. respectively.

The ODSA was notified of the declaration of an Unusual Event at the PNPP by plant personnel at the utility's control center. .The ODSA Coordinator telephoned back to the utility's control center to verify the call and to deterniine the reasons for the unusual event conditions at the plant. ODSA was inforned that an injured worker required ambulance transportation from-the utility to the hospital for treatnent. ODSA inplenented their notifications per standard operations procedures (SOP), which included notification of the Adjutant General and the Governor's office. At 8:40 A.M. the ODSA was notified of the Alert Status at the PNPP, because of a resin spill in the turbine power conplex area, which had reportedly caused radiation levels to increase greatly. The call from personnel of the utility's control center was via the five-way dedicated telephone link and was again verified by a telephone call back to the control center. ODSA partially activated the State EOC to assist in the call-down process and in preparation for the departure of key staff to near-site positions and to support the fornation of the State assessnent team. The call-down process included notification of the Governor's office, key staff, Federal agencies, the Pennsylvania Energency Managenent Agency, and the office of the Ministry of the Solicitor General of Ontario, Canada by the Deputy Director, ODSA.

The EOC staff sinalated the fornation and dispatch of the State assessnent teans from the Ohio Departnent of Health (ODH) and the Ohio Environnental Protection Agency; State connonications personnel and equipnent; and the Ohio National Guard's helicopter transport of personnel assigned to the EOF the JPIC, and the supervisor for the radiological assessnent team.

EOC staff was notified at 11:06 A.M. of the Site Area Energency at the utility, because of a steamline break outside the containnent that was l

causing a minor release of gas. The call was again, verified by a telephone call back to the utility's control center, as were all subsequent 3 notifications from the PNPP. EOC staff notified the remainder of the EOC energency response organizations and sinulated instructing them to have their respective personnel respond to the EOC for full activation. The Governor's office was notified and at 11:15 A.M. the Governor declared a State of Energency due to the continuing problens at the Perry site. The Governor's Declaration authorized activation of the Ohio National Guard and other State agencies to assist County officials and augnent County resources. The EOC was sinulated to have been fully activated and staffed.

The Ohio Departnents of Health and Agriculture reconnended precautionary sheltering of lactating aninals within a two (2) mile radius of the power plant. Personnel of the PNPP inforned the State and County EOCs that the j U.S. Coast Guard had been notified of the plant conditions and the Coast I Guard was inglenenting a precautionary evacuation of the waterway within the ten (10) mile EPZ. The EOC staff sinulated contacting the Federal Aviation l Administration (FAA), the Norfolk and Western and Consolidated Railways (CONRAIL) to restrict air and rail traf fic in the 10 n ile EPZ.'

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Federal assistance was requested from the Federal Energency Managenent Agency (FEMA) and the Departnent of Energy (DOE) . The request to FEMA was for administrative assistance and logistic support for Federal response and disaster, nass care assistance, etc. 'Ihe request to DOE was for field nonitoring for noble gas and iodine, and field sanpling, including analysis to determine-particulate depositions.

The lIO i of the Adjutant General's Departaent established lines of connonications with the JPIC and coordinated infornation ~with the spokespersons for the State and Counties.

At 12:32 P M. the State EOC was notified of the General Energency which was declared by the Utility at 12:27 P.M. The Utility reconnended sheltering of people, within the 0-2 mile radius of the plant site and from 2-5 miles downwind, in sectors E-F-G. At 12:35 P.M. the State reconnended sheltering, in sub areas 1,2 and 3, to the Counties. The State Departnents of Health and Agriculture reconnended sheltering and feeding lactating aninals on stored feed within the ten (10) mile radius of the PNPP, as a precaution and the issuance of advisories on locally grown produce.

The Counties concurred with the State reconnendations and advised the State EOC that the-EBS and sirens would be activated at 12:47 P.M. The infornation and concurrence by the Counties was relayed to the State Liaisons at the EOF and the JPIC. At 12:50 P.M, the EOC was inforned by the respective Counties of their intent to activate all prinary care centers, as a precaution to escalation and/or spontaneous evacuation. The EOC and Counties were notified at 1:11 P.M. by the PNPP of increasing release rates of radioactive noterials at the plant. The Utility reconnended the evacuation of the 0-2 mile radius of the plant, sheltering within the 2-3 mile radius and downwind 3-5 miles in sectors E-F and G. The State's assessnent of the Protective Action Guide (PAG) from the utility was taken under advisenent. However, the State upgraded the PAG and at 1:25 P.M.

issued reconnendations to the Counties to evacuate sub areas 1-2-3 and 5, to which the Counties concurred. At 1:29 P.M the Counties advised the State EOC that the Drergency Broadcast Stations (EBS) and the siren system would be activated, at 1:35 P.M., with appropriate nessages for the public.

The State nonitoring teams were dispatched to pre-selected sites within the

plune exposure pathway and provided field radiological data to the State assessnent team through the ODSA connonications van. At 1
30 P.M. the EOC was advised by the PNPP of a change in their reconnendation of 1:11 P.M.

The change by the Utility in the prior reconnendation enconpassed the need to shelter people within the 2-4 mile radius of the plant, instead of the 2-3 mile radius, and the need to include the evacuation of children and wonen of child bearing years within the sheltered areas and downwind out to ten (10) miles in sectors E-F and G. Since the State had already upgraded the Utility's reconnendation, which included evacuation of the areas in question, no additional adjustnents in protective actions were necessary.

At 4:02 P.M. the PNPP advised the State EOC and Counties that the release of radiation had terminated. The EOC notified the appropriate agencies and officials per SOP and reconnended that protective actions renain in place j until further nonitoring was perforned and sanple results were returned.

The exercise was downgraded to an Alert Status at 4:05 P.M. by the PNPP and the State in concert with the Counties was notified at 4:07 P.M. The ctercise was terminated at 4:30 P.M.

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FACILITIES The State energency operations center is a nodern facility with sufficient furniture, space, lighting, telephones, television nonitors, caneras, electrical generators, cooking and eating facilities, showers, locker roons, etc. The EOC facility is in excess of 150 miles from the utility and can easily support extended operations indefinitely. During the exercise the operation was conducted within the radiological assessnent room and the adjacent connonications room, which are both a part of the EOC. A status board was available and was kept up to date on significant events by EOC staff assigned that responsibility. The status board was clearly visible-to the staff participating in the exercise. All required maps were posted in the EOC and were available in the assessnent room. The naps depicted the plune EPZ with sectors labeled; evacuation routes; relocation centers;

< access control points; radiological nonitoring points, and population by evacuation areas.

COMMUNICATIONS The five-way dedicated telephone linkup between the State EOC, the three (3)

County EOCs and the EOF was operational subsequent to the initial notification of the Unusual Event at the PNPP. The five-way telephone system was nonitored throughout the exercise. Extraneous noise was reported on the line at approxinately 9:00 A.M. The reason for the noise' as w discovered at the licensee, where the control center and the EOF were both nonitoring the line. The problem was resolved when the control center ceased nonitoring the line after the utility was inforned of the situation by the EOC assessnent room supervisor.

The staff of the EOC denonstrated prinary connonications links with the Governor's office by connercial telephone; the State of Pennsylvania by Civil Defense National Teletype; the JPIC by concercial telephone and facsimile machine, and the radiological nonitoring teans through the State

?

Connonications van.

Connonications links between the EOF /TSC, the State of Ohio, the JPIC and the Counties are prinarily by dedicated telephone lines as previously noted in this report. Back-up connonications rely on a nunber of connercial lines fed into the EOF. The hard-copy facsimile device was used extensively without any difficulty.

Both the State and utility were able to feed infornation from the EOF to the Counties and the JPIC via the dedicated lines. This is intended to provide personnel in the JPIC with two (2) sources of tinely infornation. The ODSA liaison in the EOF also used the five-way dedicated telephone line to present information to the Conmissioners in the Counties.

The State Connonications van was in continuous connonications with the State and County EOCs, EOF, JPIC, and the field nonitoring team. Additionally, the connonications van can connonic*te directly with the radio nets 'of Sheriff's Departnents, the Ohio National Guard and the State Police. The connonications van is capable of around the clock (24-hour) operations.

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r-- - - . . , , , - -- - - - - -

DOSE ASSESSMENT AND PROI'ECTIVE ACTION RECOMMENDATIONS Dose assessnent and protective action reconnendations were accouplished at the State EOC with assistance from the State liaison at the EOF. The State liaison at the EOF was constantly in touch with the utility staff concerning underlying reasons for the utility's decisions. Ibrsonnel of the, EOF calculated dose assessnent by conputers supplied with scenario data. The.

field nonitoring teans displayed adequate training and equipnent to relay

. data back to the EOF. The FliC used plant radiation levels, plant status infornation, etc., in presenting protective action suggestions to State and County officials.

The State assessnent group in the EOC used a microprocessor and appropriate software to project expected doses to the public. Calculations were based on sinalated data received directly from the plant via conputer and information radioed from the field by three (3) field nonitoring teans.

Hand calculations were also denonstrated. Findings at the State EOC were

! correlated with similar calculations done by the utility. Field nonitoring teans were directed to new locations by the OEPA Coordinator in order to track the plune. The OEPA Coordinator also received data from two (2) Lake County field nonitoring teans through the OEPA Liaison at the Lake County EOC. Updated data was displayed on a chart and a nap in the EOC.

PUBLIC ALERTING AND INSTRUCTIONS Activation of the siren system and EBS is a local responsibility in the State of Ohio. The State action under this objective is to support the Counties by confirming, through the EOC, the energency conditions necessitating sheltering in place and evacuation. Inglenentation of the protective action reconnendations is addressed in the Ashtabula, Geauga and Lake Counties portion of this report.

PROTECTIVE ACTIONS Evacuation activities such as the activation of reception centers, congregate care facilities, relocation of special needs individuals, and i access control are the responsibility of local governnent.

RADIOLOGICAL EXPOSURE CONTROL State personnel of the field nonitoring team, EOF, and other sites near the.

utility were issued low, nedium and self reading dosineters. The teans were equipped with dosineter chargers and record keeping cards for readings.

Appropriate instructions on the use of the equipnent were included.

I MEDIA RELATIONS The Joint Public Infornation Center (JPIC) is located in the Performing Arts Building at Lakeland Connonity College, Kirtland, Ohio. The auditorium is used for nedia briefings. The required naps and other briefing aids were available for the briefings and were used effectively. Tables, chairs, and telephones were available in the auditorium lobby area for use by the nodia. The Cleveland Electric Illuminating Conpany and ODSA personnel had adjacent work roons on the second floor of the building. The personnel from the Counties of Ashtabula, Geauga and Lake were co-located with ODSA.

Additional space is available for Federal response personnel. An area, renoved from the work roons, was used by the briefers to coordinate their i statenents and organize the briefings.

28 i

Connercial telephone was available to the ODSA and personnel from the Counties. Additionally, each County had a dedicated telephone link to their respective County EOCs. The ODSA staff had a dedicated telephone link to the EOF. There were fascimile nachines that connected the three (3)

Counties and the State EOC with the JPIC. The ODSA also had, and denonstrated, radio capability with the State's nobile connonications van.

Kits containing infornation about the Perry Nuclear Power Plant; the general operation of nuclear power plants; the local area, and radiation were available for the nedia.

Six (6) briefings were held with the first beginning shortly af ter 12:00 P.M. The PIOS exchanged infornation and coordinated their releases. The briefings seened to be accurate and couplete. Technical terns were adequately explained. The briefers were prepared for and responded to questions from the nedia. They were clearly abreast of events and understood their connonity's energency plan. Hard copies of releases were node available to the nodia. Printed releases directed citizens to listen to the EBS. The nodia briefers asked the nedia representatives to urge people to listen to the EBS. None of the news releases, written or oral, contained the call letters or frequencies of the EBS stations.

Area Reconnended For Ir..provenent: News releases and oral briefings should include the call letters and frequencies of the EBS stations.

The JPIC staff received copies of the EBS nessages released by the Counties and provided these nessages to the nedia present at the JPIC. The receipt and release of the County EBS nessages at the JPIC eliminates a required corrective action noted during the last exercise.

The JPIC staff released the runor control telephone numbers for the three (3) Counties and the 800 nunber at the State in briefings and printed copies.

FIELD MONI'IORING The Field Assessnent Team was prepositioned at the Ohio State Patrol Post (staging area), Chardon, Ohio per pre-exercise agreenent between the State and FEMA. The team was activated at 11:50 A.M. via radio connonications from the field connonications van (van 1), which relayed the call from the State EOC.

The field nonitoring team consisted of OEPA personnel from Colunbus and the District Office, at Twinsburg, Ohio. The nonitoring team was kept aware of utility and noteorological conditions by listening to radio transmissions from the controller in the connonications van, which was situated at the Ledgenont School near Thonpson, Ohio. Equipnent check procedures and division of responsibilities were known through prior training. The OEPA staff from Colunbus were well versed in personnel protection criteria and procedures. liowever, the OEPA staff from Twinsburg were not fully aware of personnel protection criteria as evidenced by failure to know action levels at which personal protection action should be initiated.

29

Area Reconnended For Inprovment: OEPA field nonitoring staff of the TWinsburg District Office needs additional training in field nonitoring.

W e field nonitoring teans were well prepared for the anticipated mergency. Air sanpling equipnent was adequate and functional. Soil, vegetation, and water sanpling equipnent was appropriate and adequate.

Calibration dates were noted on calibration sheets and the equipnent.

Calibrations had been perforned as recently as February 1986. However, in the case of one (1) rateneter and one (1) air sanpler, calibration dates were not noted on the calibration sheets nor were calibration stickers affixed to the instrunents. This appeared to be a lapse in record-keeping rather than an actual lack of calibration. The team had backup equipnent for the foregoing equipnent itens and indicated that the equipnent checked out with accuracy, during their equipnent check, prior to coming into the field.

Area Reconnended For Inprovenent: The field nonitoring teans should ensure that equipnent brought to the field is properly labeled and calibration dates are properly recorded.

Unit 13 of the three (3) field teans was the team evaluated. The team denonstrated activation and checking of their survey instrunents, although the team did not have a check source available. Wey explained that the equipnent had been checked with a check source prior to their departure to the field. The team nonitored for exte sanples during the transport.

We nonitoring team was familiar with the area assigned to them and found the nonitoring points easily. However, field sanpling site F1 is located in a wooded area. Because the F1 Site is heavily wooded it is not a representative site to accurately assess air deposition.

At sanpling site F2, the nonitoring teans van radio connonications to the State connonications van was tenporarily lost. A hand held portable radio, held outside the nonitoring teans van corrected the problem. The connonications problem appeared to be due to overhead electrical lines and/or the terrain. When the teans van was noved down the road a few tenths of a mile the problem disappeared.

Area Requiring Corrective Action: NUREG 0654, criteria item I.8 -

Radiological sanpling sites nest be re-evaluated for sanpling representativeness and radio connonications.

We Controller in the State connonications van (van 1) maintained contact with the field nonitoring team alnost throughout the exercise. However, the field - team's OEPA radio operator did not appear to have been adequately trained in the use of the portable radio. A team menber from Van 1 had to be dispatched to aid the OEPA radio operator in the operation of the radio.

We State Connonications van had a nultiplicity of radios with a variety of frequencies available. Were appeared to be good back-up connonications capabilities. When connonications was lost with the unit 13 field team connunications van,the teans hand held portable radio worked as the back-up neans of connonications.

30

The field teans have adequate quantities and types of protective clothing.

Menbers of the field nonitoring team wore permanent and self reading dosineters. The OEPA personnel from Colunbus were proficient in the use of dosinetry, dose assessnent and decontamination procedures. However, team nenbers of OEPA from the Twinsburg District Office were not very familiar with the use of dosinetry, dose assessnent, and decontamination procedures.

Area Reconnended For Inprovenent: Field nonitoring team nenbers of the OEPA's Twinsburg District Office need training in the use of dosinetry, dose assessnent, and decontamination procedures.

RECOVERY AND REENTRY Recovery and reentry was not an objective selected to be demonstrated during the exercise.

2. ASHTABULA COUNTY The five-way dedicated telephone link between Ashtabula County, PNPP, the State EOC and the Counties of Geauga and Lake is continuously nonitored twenty-four (24) hours per day, seven (7) days a week at the County Shorif f's conmunications center.

The utility initially inforned Ashtabula County of the Unusual Event at 7:35 A.M. The Alert, Site Area Energency, and the General Energency were announced at 8:48 A.M., 11:09 A.M. and 12:34 P.M. Written call lists were used to alert and nobilize the EOC staff. The County EOC staffing was conpleted and operational by 9:25 A.M. All agencies / organizations listed in the Ashtabula County plan for EOC staffing were represented in the EOC.

Extended capability to continue operations was denonstrated through the use of a roster and double staffing of sone EOC positions. The EOC staff denonstrated that they are trained and knowledgeable of their duties and responsibilities. The County liaison at the PNPP's energency operations facility was dispatched to the EOF at 12:33 P.M.

m ERGENCY OPERATIONS MANAGEMENT The Ashtabula County Disaster Services Agency coordinator, working with the executive group, was effectively in charge of County operations. Periodic updates on the situation were announced by the County coordinator via a public address (PA) system to the EOC staff. The DSA coordinator net individually with appropriate EOC staff to facilitate decisionmaking.

Area Reconnended For Inprovenent: The Federal evaluation team reconnends the DSA coordinator / executive group hold periodic briefings in the operations room where each departnent/ agency representative report actions taken by their respective agencies /departnents. The evaluation team feels this would enable the entire EOC staff to better know the County situation / posture and would further inprove inter-departnent awareness and coordination.

31

t All nessages coming into the central connonications center were' recorded on tape in the connonications center. There were nony connercial telephones strategically placed throughout the EOC. Anateur radios with operators, and the State radio system were assenbled in line on a wall utilizing sound control booths.

i 'Ihe three-way dedicated telephone link perforned well with no problems. The five-way dedicated telephone system was enployed and functioned, but with sone operational difficulties occurring at tines. A hard-copy device was centrally available, frequently used and reliable.

Area R_ econnended For Inprovenent: The five-way dedicated telephone link should be inproved and corrected to obtain a clear and interference free level of perfornance.

The County EOC staff fully denonstrated their ability to establish and naintain connonications with the necessary agencies, organizations, and personnel under energency conditions. All applicable objectives and

criteria for performance were net.

DOSE ASSESSMENT AND PROPECTIVE ACTION RECOMMENDATION Dose assessnent and protective action reconnendations are prinarily the responsibilities of the State of Ohio. Dose assessnent infornation and protective action reconnendations developed by the State are given to i Ashtabula County. The County inglenents the protective action reconnendations developed by the. State. The County in their decisions to

! inglenent protective action reconnendations considered EPA exposure guidelines, plant status, evacuation tines, and local weather conditions.

The protective action reconnendations were pronptly reviewed and updated as conditions changed.

PUBLIC ALERTING AND INSTRUCTION Lake County is the lead County for public alerting and instructions for the tri-county areas of Lake, Geauga and Ashtabula. Ashtabula County plays a support role in public alerting and instructions but could becone responsible for the lead role in the event that Lake and Geauga County could not perform this function. The Ashtabula County siren system control is located in the connonications center and activation is coordinated by the conniissioners from the three (3) Counties over the three-way dedicated i

- telephone lines.

i I The sirens and the EBS were activated on the notification to shelter and again upon notification to evacuate. The list of key tines is tabulated below in order to evaluate the requirenent that the public be alerted and inforned within a fif teen (15) minutes tine frane.

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SHELTER ORDER 12:27 P.M PNPP reconnended sheltering 12:35 P.M State reconnended sheltering 12:40 P.M . Ashtabula County coordinated with Lake County 12: 47 ' P.M Sirens were activated E

12:50 P.M EBS was activated A twelve (12) minutes tine differential between State reconnended action and the activation of sirens is reflected. The objective of not exceeding fif teen (15) minutes was net.

Public-alerting and instructions for the evacuation order was also conpleted in tWeleve (12) minutes as reflected below:

! V EVACUATION ORDER 1:25 P.M. State reconnended evacuation 1:27 P.M. Ashtabula County coordinated with Lake County 1:37 P.M. Sirens were activated 1:37 P.M EBS was activated Ashtabula County denonstrated, in a tinely fashion that the public could be notified and given instructional infornation in the event of an energency.

PROTECTIVE ACTION The activation of traffic control points were pronptly ordered by the executive group. The appropriate EOC staff indicated that resources are available to keep evacuation routes clear during bad weather or in the event j of stalled or wrecked cars. One traffic and access control point was

actually set-up and dertonstrated during the exercise. Other traffic and access control points were procedurally denonstrated through discussion and i nap displays within the County EOC. All roads were blocked, air traffic was re-routed, water and rail traffic were stopped. The EOC staff indicated that local resources are adequate to cover all traffic and access control points simultaneously. Receptions / congregate care centers were staffed and ordered to be activated in a tinely fashion.

The EOC staff were aware of the location of nobility-inpaired individuals and their special needs. The County Agricultural Extension Agent in the EOC had available his updated list of farners and their crops. He knew the locations of dairy farms and food processing plants. Trained staff is

! available to work individually with farners, food workers, etc., to inglenent protective actions.

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RADIOLOGICAL EXPOSURE CONTROL i

The Ashtabula County EOC is' located outside the ten (10) niile energency planning zone of the PNPP. Dosinetry equipnent was available at the EOC for the ' EOF liaison, the JPIC spokesperson, and the County Sheriff's deputies canning the traffic control point at Interstate 90 and highway 45.

Appropriate instructions were issued along with the dosineters. The County Radiological Officer and the energency workers in the field were aware of the naxinnn dose allowed without authorization. The radiological officer

was also aware of decontarnination procedures. The EOC staff actively l nonitored energency worker ex.posure. The energency workers reported their readings once an hour to their respective supervisors-or their radio dispatcher. This was done at 12:52 P.M., 1:49 P.M., and 2:51 P.M. during
the exercise.

MEDIA RELATIONS 4

The Ashtabula County EOC was a controlled access area which contained a conbined runor control and public infornation section within a portion of 4 the operations roorn in the EOC. This runor control /public infornation i section was activated at the Alert Notification stage of the exercise. At the Site Area Eaergency notification the Public Infornation Officer (PIO) i departed the EOC and went to the JPIC when notified that the JPIC had been activated.

A second floor room at the EOC had been designated as a possible nedia briefing roorn, in the unlikely event that nedia personnel attenpted to obtain infornation at this location.

i At 2:00 P.M. the assistant PIO received infornation that a photographer from the Ashtabula Star Beacon wanted to obtain photographs of the County EOC.

The assistant PIO net with the photographer in the second floor nedia briefing room and inforned the individual that his request was denied, f whereupon the individual departed the building.

Eight (8) runor inquiries were received by the runor control section and handled properly. Additionally, it was denonstrated that EOC personnel knew I that any inquiries by the nodia were to be referred to the JPIC.

j

The Assistant PIO/nodia representative established and naintained liaison

! with the Ashtabula County representative at the JPIC. A nunber of nessages and news releases were received at the EOC via the telecopier linked to the nedia center.

FIELD ACTIVITY i l The Ohio State Highway Patrol tranned the access control point at the

intersection of Interstate Route 90 and Ohio State Route 45.. The State

! Patrolnan arrived at his post at approxinately 12:15 P.M. The Patro1 nan was later followed by an energency worker from the County Transportation Departnent that had been requested by the Patrolnan, via patrol radio connonications, to transport barricades to the site. The Patrol Officer was knowledgeable of evacuation procedures, evacuation routes, and the locations of reception / care centers. He was in direct connonications with the Highway l Patrol Post, other State Patrol Personnel, and had radio connonications i 35 t

We State Highway Patrol Post had mpability with local Police Departnents. He the capability to connonicate directly with the Ashtabula County EOC. l received updates from the State Highway Patrol Post and was to report hourly via radio. We Patrolnan had an extensive resource listing of available tow trucks / wreckers, etc., that would be used for clearing road obstructions.

We Ohio State Patrolnan and the energency worker, from the County Transportation Departnent, wore mid and high range dosineters and TLDs.

%ey also had instructions and recording forns. Both individuals were familiar with the recording procedures and the maxinum dose restraints.

%ey were also aware of the locations for energency worker decontamination stations and referral points for evacuees.

We Spencer Elenentary School evacuation was initiated by the Superintendent of the School System. Per FEMA procedures there was no actual novenent of students. W e Geneva School District transportation supervisor actually dispatched two (2) drivers and buses to the Spencer Elenentary School. i Infornation on the school evacuation plan for Ashtabula County was provided f to the Federal evaluator at the Spencer Elenentary School by the school ,

principal and the two (2) bus drivers who denonstrated their procedures toF evacuate the students. ly school superintendent and the Geneva School District transportation supervisor indicated that these school officials and the bus drivers understood the school's evacuation plan and the inglenenting procedures.

We Ashtabula County plan calls for school evacuation to be by both, bus and parential picp p of students g udents that ordinarily _w7a toschoolwilp lHWU their parents pick them up. The renainder of the (eitheLwalk hone utstudents would be bused to the Ashtabula County Joint Vocational School.

We parents or guardians would then pick-up their children at the Ashtabula school. Students that are not picked up by parents and/or guardians at the Ashtabula school would later be transferred to the Edgewood Senior HighWe School, so that long term care (food, shelter, etc.) can be provided.

authorization to evacuate the schools would be given by the Superintendant of Schools via connercial telephone or two-way radio, if telephone capability is unavailable.

We two (2) bus drivers interviewed were equipped with dosineters and film badges and through questioning appeared to be aware of their proper use.

We drivers knew the naxinum dose and how often to check the dosineters.

We transportation supervisor inforned the drivers of the location We transportation of the is supervisor l

i mergency worker decontamination facility.

in constant contact with the drivers via two-way radio ecmnunications.

Based on the denonstrated activity and verbal descriptions it appears that the capabilities and resources are present to carry out the school evacuation according to plan. Both prinary and secondary connonications School Officials had systens (telephone and two-way radio) were adequate.

detailed written evacuation procedures readily available and were well No-way radio connonications with the buses were inforned of the content. Both in place and adequate. bus operators interviewed had their own copy of the evacuation route and were well inforned of the evacuation procedures.

i 36 l

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  • q- REw CATION / CONGREGATE CARE / DECONTAMINATION CENTER l

Ashtabula County energency response personnel of the Conneaut Fire and Police Departaents, Anerican Red Cross, and the Conneaut Anateur Radio Brergency System (CARES) operated the reception and congregate care center

' at the Rowe Junior High School. Staff present at the center was adequate in terns of nuabars, background and training to perform their energency functions. The staff displayed knowledge of their respective responsibilities and training in energency procedures. Around the clock (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) staffing capability was denonstrated by presentation of a roster and

. double staffing at the center.

The registration and nonitoring process was well defined and adequately denonstrated. Evacuees arriving at the reception / congregate care center would be nonitored for contamination and decontaminated, if needed. The evacuees would thereaf ter be registered by center staff from the Anerican Red Cross. They will be provided food, shelter, nedical attention, etc., as

necessary. The decontamination process was adequately denonstrated, with proper handling of contaminated individuals, clothing and possessions.

The Center was nanned by four (4) radiological nonitoring teans, which were Conneaut Fire Departnent Personnel. The nonitoring teans consisted of three 4 (3)nenbers for each team. Every individual entering the center would be scanned by a nonitoring team (2 for nales and 2 for fenales) for potential radiological contamination. If found to be contaminated evacuees would be

, decontaminated by use of the school's showering facilities. Clothing and i personal articles would be secured in plastic bags and tagged for i identification of the owner (s) . Contaminated persons would be asked to shower and would be scanned a second tine after showering. If readings of contamination persists the individual (s) would be transported to the hospital, by personnel of the Conneaut Fire Departaent, for further i

decontamination ' efforts. Menbers of the radiological nonitoring and

' decontamination team displayed thorough knowledge and training in their responsibilities.

The Rowe Junior High School Reception / Congregate Care Center is well outside

! the 10 mile EPZ of the Perry Nuclear Power Plant. The center could

acconodate an excess of 1700 persons for feeding, sleeping, showering, etc.

The facility is adequate for the extended care of evacuees. The Rowe School l Center serves as the central feeding point for the entire School District.

Existing supplies of foodstuffs in the center would be utilized for the energency feeding of evacuees. Additional supplies would be obtained as

> - - necessary through local purchasing. The center was staffed and is equipped.

to handle evacuees in wheelchairs. The school's regular and several pay station cormercial telephones are available for connonications. The i facility is equipped with a nursing station which was operated by the Anerican Red Cross; It is in close proximity to the Ashtabula Connonity I Hospital and the Conneaut Fire Departnent.

The energency worker decontamination facility was located at the Saybrook

- Township Fire Departnent for exercise denonstration. The Saybrook

) Elenentary School, per the County's plan, is the location for decontamination in the event of an energency requiring energency worker i decontamination. Since school was in session it was not available for the exercise. The Fire Departnent personnel nanning the facility displayed knowledge of procedures for determining the need for decontamination and the decontamination process. The staff denonstrated neasures to control

energency worker exposure and the spread of contamination.
37 i

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. , . , . _ . - - . . .,,,,.,-,__~._.-.y . _ - - . . . . - . . . _ , - _ , .m.--_._ _,m _.~.,_-- .__-..-_,,-..---.-,_m_.....-r..,--_--m-. .- . , - -

The facility at the Saybrook Elenentary School is adequate in terns of showering units and space. An adequate supply of dosinetry (CDV 730, 742, 4

TLDs), CDV 700 geigher counter type equipnent and reporting forns were

!' available. The recent installation of sewer lines in the Saybrook Fire Departnent energency worker decontamination station was in direct response to correct previous problens with the septic tank that was used in the past.

Procedures for radiological monitoring of evacuees /energency workers and procedures for handling radioactive wastes are standardized per the routine cited .for evacuees at the reception / congregate care center in Ashtabula County.

MEDICAL SUPPORT

'Ihe denonstration of adequacy of hospital facilities and procedures for handling contaminated individuals consisted of a tour of the Ashtabula County Medical Center (ACMC). The walk through of the hospital revealed that the hospital has the necessary equipnent to adequately treat contaminated patients. The equipnent observed included equipnent nentioned as deficient during the 1984 exercise. This included waste water collection containers, faucet hoses, and a whole-body wash tray. Other inprovenents to the facility since the last exercisa include non-absorbent paint in the treatnent room, grounded faucets, grounded electrical outlets in the room,

! and increased lighting in the hallway leading to the treatnent room.

I RECOVERY AND REENTRY l Recovery and reentry was not an objective selected to be denonstrated during the exercise.

3. GEAUGA COUNTY ACTIVATION AND STAFFING The Dispatch Center of the Geauga County Sheriff's Departnent received the initial telephone call of the Unusual Event Conditions at the Perry Nuclear Power plant, in concert with the State of Ohio, Ashtabula and Lake Counties, at 7:40 A.M., via the five-Way dedicated telephone line between the utility, the State of Ohio and the three Counties. The notification from the utility's Technical Support Center was verified by a telephone code word at the end of- the nessage. Sheriff's personnel in the dispatch center notified nenbers of the County Energency Response Organization from currently dated written call lists and/or at the direction of the DSA Director in accordance j with standard operations procedures. The Alert Notification was classified by the utility at 8:22 A.M., and was received by the County at 8:34 A.M. via the five-Way dedicated telephone. Personnel of the County Sheriff's Dispatch Center notified key energency response personnel in accordance with the plan, and the County EOC was partially activated. The rencinder of the EOC staff were activated at the Site Area Energency notification. The initial staffing was conpleted at 9:45 A.M. and the EOC was conpletely staffed at 11:40 A. M.

38 i

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The five-way dedicated telephone system to the County consists of two (2) telephones, one of which is located in the Dispatch Center of the County Sheriff's Departnent and the second. in the bergency Operations Center.

The Sherif f's Departnent personnel discontinues nonitoring the dedicated telephone line upon the arrival of the County DSA Director and the activation of the EOC.

Representatives of all agencies naking up the County's bergency Response Organization were present and effectively operational in the County EOC.

The EOC staf f denonstrated around the clock (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) staffing capability by i double staffing positions and presentation of a roster of personnel for additional shifts as necessary. In addition to the EOC staff the County

) assisted in the staffing of the Joint Public Infornation Center and activated and staffed a reception / congregate care center, a decontamination center, nanned access control points and coordinated with the support hospital's denonstration of treatnent for injured and contaminated workers. At 9:15 A. M. the three (3) Counties initiated activation of all prinary care centers as a precaution against escalation and/or spontaneous evacuation. The reception / congregate care center at the West Geauga fligh School was adequately staffed with personnel from the County Health Departnent, Chester Fire and Police Departnents, the Anerican Red Cross, and the school system. Agency representatives reportedly had been activated by their respective agencies by use of energency response call lists. The staff also had copies of the rosters of personnel of their respective agencies that were to be used in cases of extended operations and to denonstrate twenty-four (24) hour staffing capabilities.

1 EMERGENCY OPERATIONS MANAGEMENT The County Director, Disaster Services Agency effectively coordinated the activities within the EOC. Periodic briefings were held to update the staff on the situation at the plant, and other activities inpacting on the progress of the operation. The staff was involved in decision naking with najor decisions being nade by the executive group, which included the DSA Director, the County Conmissioners, the County Sheriff's representative, and the Public Infornation Officer liaison in the EOC. Copies of the plan were available for reference and staff had copies of procedures and/or checklists pertaining to their respective agencies. Message logs were kept and nessages were reproduced and distributed as appropriate. Access to the EOC was controlled by representatives of the County Sheriff's Departnent and by l use of a control roster and personal identification.

The County EOC in concert with the State, Ashtabula and Lake Counties were notified by the Perry Nuclear Power Plant of the Alert Conditions at the plant at 8:34 A.M.; the Site Area Energency Conditions at 11:08 A. M., and the General Energency at 12:32 P.M. Geauga, Ashtabula and Lake Counties were notified at 11:15 A. M. of the Governor's Declaration of a State of Energency due to the continuing problens at the Perry Nuclear Power Plant.

In conjunction with the Governor's Declaration, the Counties were inforned by the State of the activation of the National Guard and other State agencies to assist County officials and augnent County resources. At 12:32 P.M. the County in concert with the State, Lake and Ashtabula Counties were notified of the General Energency by the Utility, The Utility reconnended inplace sheltering of people within the 0-2 mile radius of the plant, and i 2-5 miles in the downwind sectors E-F-G . The State upgraded the protective actions and reconnended sheltering in sub areas 1-2-3. The State Departnents of Health and Agriculture reconnended sheltering and feeding all lactating aninals on stored feed within the 10-mile radius of the Perry Nuclear Power Plant, and the issuance of advisories on locally grown produce.

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FACILITIES The Geauga County EOC is located ir. the basenent level of the County Safety

- Center (13281 Ravenna Road, Chardon, Ohio). The County Disaster Services Agency operates in the EOC facility during nornal working hours. The DSA naintains the EOC and operate it during energencies, ensuring that it renains operational 24-hours a day throughout the energency period. 'Ihe EOC has sufficient lighting, furniture, telephones, and other anenities to support an extended operation. Energency classification levels were posted in the EOC. A status board was available and was kept up to date on ,

significant events. All required naps were posted, depicting the plune EPZ with sectors labelled, evacuation routes, relocation centers, access control points, radiological nonitoring points, and population by evacuation areas.

Other facilities denonstrated during the exercise are adequate for their

! intended purpose, including the Reception / Congregate Care Center at the West Geauga High School, and the Decontamination Center at the Hanbden Volunteer Fire Departnent.

COMMUNICATIONS The County denonstrated the prinary and backup neans of connonications with the State EOC, the Utility, other Counties, the JPIC and other centers that were activated during the exercise. The prinary neans of connonications between Geauga County, the Utility, the State of Ohio and the Counties of Lake and Ashtabula is via the five-Way dedicated telephone hook-up that provides several extensions at each location. Additional neans of connonications between Geauga County, the State and Counties is via radio and or regular telephone. A separate three-way dedicated. telephone system links the Geauga County EOC with the Lake and Ashtabula County Energency Operations Centers. Connonications between the County EOC and the JPIC is via a two-way dedicated telephone line between the two (2) locations. Local schools and the support hospitals are prinarily contacted by connercial

! telephone. During energencies hant-radio contact is established between the EOC, the schools and support hospitals as necessary. Fire / rescue anbulances i are contacted by radio through the County Sheriff's Dispatch Center, which is upstairs from the basenent level EOC, where connunications to the EOC is by concercial telephone and police radio. Additionally, the County EOC is equipped with twenty-two (22) connercial telephones, two-way radio equipnent, the Anateur Radio Association support, pagers, a high-speed facsimile nachine and a telephoto-copier. A nessage center is staffed by a nessage controller, a nessage logger, a status board plotter and nessengers. The center ensures nessage flow and naintains a record of all nessages being received or transmitted.

DOSE ASSESSMENT AND PROTECTIVE ACTION RECOMMENDATIONS i

Dose assessnent and protective action reconnendations are the responsibility of the State of Ohio.

l PUBLIC ALERTING AND INSTRUCTION 1

i The executive staff of the Geauga County EOC in joint consultation with EOC l staffa of Ashtabula and Lake Counties is responsible for alerting and

! Instructions to the public in the tri-county area.

40 i

Geauga County, in consultation with Lake and Ashtabula Counties, nade the decision to reconnend the early distuissal of schools within the ten (10) mile EPZ of the utility at 9:15 A.M., after being notified of the Alert Conditions at the plant by the Utility at 8:34 A.M. A telephone call was nade advising the principal of the one (1) school that is located in the ten (10) mile EPZ within Geauga County.

Public alerting and instructions were effected by the County beginning at 11:13 A.M., af ter the State Departnents of Health and Agriculture's reconnendation for precautionary sheltering of lactating aninals.

The County in consultation with Lake and Ashtabula Counties (through Lake County as the activation point) activated sirens and the energency broadcast system (EBS) at 12:47 P.M., after receiving notification of the General Ehergency Conditions at the plant from the Utility at 12:32 P.M. The activation of the siren system and the EBS was initiated a second tine at 1:25 P.M., when the Counties were instructed to evacuate, sub areas 1 through 5, by the State because of increasing release rates of radiological contaminating gas from the plant.

Energency public instructions are draf ted and released by the Lake County EOC, for the three (3) counties inpacted by the PNPP, af ter consultation between the three (3) counties. The Counties used prescripted nessages during the exercise. Protective action areas were described in terns of familiar boundaries and landnarks. The instructions to take shelter were fornulated and included guidance on sheltering nethods and instructions for transients without shelter.

PROTECTIVE ACTION The nanning and activation of traffic control points were initiated by the County following directions frorn the State. According to EOC staff of the County Sheriff's Departnent appropriate resources in terns of personnel and equipnent are available to keep evacuation routes clear during bad weather and/or in the event of stalled or wrecked cars. Anple resources were denonstrated by the Ohio State Police and Highway Conmission personnel for covering all routes and traffic control points that were the responsibility of Geauga County.

At 1:15 P.M. a two (2) nan County crew, operating a truck loaded with barricades, arrived at the access control point at the junction of State Routes 166 and 86 which was nenned by an Ohio State Trooper. The trooper was familiar with the evacuation routes, the location of reception / congregate care centers and procedures to request tow trucks and other equipnent to insure that roads and highways are kept clear of inpedinents to traffic. The County was advised that the State had contacted the responsible railway conpanies to reroute rail traffic and the Federal Aviation Administration (FAA) had been requested to reroute air traffic.

The Utility inforned the Counties and the State that the U.S. Coast Guard had been notified and was inglenenting a precautionary evacuation of the waterway within the ten (10) mile EPZ. The County had initiated activation of all prinary care centers at 9:15 A.M. as a precaution for escalation and/or spontaneous evacuation.

The County nointains a list of the nobility inpairod residents with addresses, telephone nunbers, and identification of special needs. The County sinulated arrangenents for the required nunber of buses and anbulances needed to acconodate the nobility inpaired individuals.

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i The Ledgenont High School is the only school within the ten (10) niile EPZ of the PNPP in Geauga County. According to the EOC staff there are enough buses and drivers available to cover the transport and evacuation of the school. The bus drivers are contacted by concercial telephone during non-duty hours. Atrangenents were nade by the three (3) Counties to preclude traf fic jans at the school by issuance of an EBS rressage. The cessage inforned parents that if their child (ren) were at a school located within

]. the evacuating area the school would safely nove the children to a receiving school located at least ten (10) railes away froni the PNPP. The parent (s) were instructed to neet their children at the receiving school.

RADIOLOGICAL EXPOSURE CONTROL The Geauga County EOC is located well outside the ten (10) niile EPZ of the Perry Nuclear Power Plant. Dosinetry equipnent was observed in the County EOC, traffic control points, the support hospital and the decontaniination station. The County's dosinetry kits contain low (0-200 niR) and niid range (0-20R) dosineters, TLDs, record keeping cards, chargers for the dosineters, and instructions to be issued along with the dosirreters. The County radiological officer and energency field workers queried on the use of the

dosinetry were aware of their use, record keeping and exposure controls.

i The workers and radiological officer were also aware of decontaniination procedures and where to go ~ for decontarnination.

j RELOCATION / CONGREGATE CARE CENTER The County operated a reception / congregate care center at the West Geauga liigh School. The school can acconodate approxinately 1200 individuals as a shelter and approxirrately 3000 for daily feo. ling. The facility has sufficient anenities for sleeping, feeding, recreation and care for evacuees for an extended period. The Anerican Red Cross by agreenent with the County 1

will provide cots, blankets, and other itens needed for sleeping evacuees at the care centers. The school food supply in addition to local purchases would be utilized for feeding purposes.

Staff of the reception / congregate care center denonstrated procedures for registration and radiological nonitoring of evacuees. Representatives frorn the Anotican Red Cross were responsible for the registration, nursing

station, feeding, and other evacuee health and cornfort needs. The Chester Fire Departnent denonstrated procedures for radiological nonitoring and i decontamination of evecuees and/or energency workers. The center was j

further staffed by the County Health Departnent, the Chester Anateur Radio Association and the Chester Police Departnent which was responsible for security. The staffing of the center was adequate in terns of nunbers, background and training to perform their emergency functions. Twenty-four i (24) hour staffing capability was denonstrated by double staffing positions and/or presentation of rosters of personnel designated as replacenents for the initial and subsequent staffing.

'Ihe four (4) radiological nonitoring teans of the Chester Fire Departuent denonstrated radiological nonitoring by use of CDV 700 geigher counters, and sinulated decontaniination, with the assistance of individuals role playing as evacuees.

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DECONTAMINATION The Hanbden Volunteer Fire Departnent Decontamination Facility has the capacity to nonitor and decontaminate approxinately 6-8 persons per hour and 2-3 vehicles per hour. Additional energency worker and equipnent decontamination centers are defined within the County plan. Radioactive waste is collected in plastic bags and/or drums and is disposed by the Ohio Departaent of Health. The personnel of the Hanbden Fire Departnent denonstrated exceptional knowledge, training and understanding of radiological nonitoring and decontamination procedures. However, the decontamination standard operations procedures (SOP) provides for personnel to be nonitored, areas contaminated noted and a decontamination shower. The SOP thereaf ter only requires renonitoring of thore areas noted to have been contaminated during the initial nonitoring for contamination. In the process of renoving clothing or while showering the contamination could be spread to other parts of the body. Therefore, after decontamination the entire body should be renonitored.

Area Reconcended For Inprovenent: The SOP for decontamination of energency workers should be reviewed and rewritten so that the whole body is renonitored.

MEDICAL SUPPORT Additionally, the County denonstrated the adequacy of anbulance facilities and procedures for handling contaminated individuals. This denonstration was in conjunction with the Hanbden Volunteer Fire Departnent's denonstration of the adequacy of equipnent and procedures for decontanii-nation of energency workers, equipnent, and vehicles, and the Geauga Connonity Hospital's denonstration of the adequacy of hospital facilities and procedures for handling contaminated individuals.

An energency worker that was sinalated to have been injured and radiologically contaniinated was transported to the Geauga Connonity Hospital by anbulance from the energency worker radiological nonitoring and decontamination station at the Hanbden Fire Departnent. The floor of the anbulance was covered with protective plastic and the energency nedical team (EMT) donned throw-away clothing, gloves, head and feet coverings, etc.,

prior to receipt of the patient for transport to the hospital. The anbulance crew was able to connonicate with the hospital while enroute by use of a two-way radio. The hospital's energency room staff accepted the patient, whereupon the anbulance EMT proceeded back to the Hanbden Fire Departnent Decontamination Center where the team, vehicle, and the energency equipnent used for the patient's transport and care would be nonitored for contamination and decontaminated.

The energency room staff of the Ceauga Connunity Hospital was proficient in the handling and treatnent of the injured and contaminated worker and the avoidance of the spread of contamination. A health physicist fron the utility was present. The hospital denonstrated the necessary equipnent for determining whether or not the patient was contaminated. The hospital staff also denonstrated decontamination procedures. It was noted that the energency room staff experienced difficulty in maneuvering the patient cart on the plastic floor covering that was used instead of a herculite tarp.

The plastic was slippery and kept noving underfoot and/or with the rolling cart wheels.

43

Area Reconnended For Inprovenent: It is recontrended that a herculite tarpaulin or other suitable noterial be used as a runway floor covering in the treatnent area for potentially contaminated patients.

MEDIA RELATIONS The County dispatched the County Public Infornation Officer (PIO) to the JPIC upon it's activation at 12:00 P.M. The County PIO liaison at the JPIC coordinated with the executive group of the EOC through the PIO liaison in the County EOC. All nedia inquiries were referred to the JPIC.

RECOVERY AND REENTRY Recovery and reentry was not an objective to be denonstrated during this exercise.

4. LAKE COUNTY 4

ACTIVATION AND STAFFING The Lake County EOC is a pernenent twenty-four (24) hours per day facility with around the clock conplenents of tele-connunicators (dispatchers) and advanced connunications equipnent, both fixed and portable, so that alnost innediate notification of key staff is assured. The EOC received notification from the PNPP at 8:46 A.M. and was fully staffed and activated by 9:50 A.M., with perhaps an approxinate twenty (20) minutes delay caused by the arrival of a substitute nedical officer as fill in for the unexpectedly out of town regular doctor. Initial notification of the Unusual Event was conpleted in nine (9) . minutes and additional notification for the Alert Status required twenty (20) minutes. The elected officials were all present and participated fully in all areas of their responsibility, including very effective decision-naking in their executive group. Every organization as depicted in the County plan was represented by double staffing or via roster, except the Ohio National Guard and the OEPA.

All organizations actively participated in their areas of responsibility.

Each staff nenber, when interviewed, indicated thorough knowledge of their f

responsibilities and reacted well throughout the exercise. Copies of the plan were available for reference. EOC staff had copies of procedures l and/or checklists that pertained to their respective responsibilities.

j Message logs were kept and nessages were reproduced and distributed as

{ appropriate. The handling of nessages were efficient. Access to the EOC

was controlled by use of personal identification, a roster and sign in/out log.

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-_..-- -_ ~-. . - - , . _ _ , . _- ,- - . _

EMERGENCY OPERATIONS MANAGD4ENT The Ehergency Managenent Director conducted the overall EOC operations with effective control by the EOC Operations Officer, guided by the efficient and tinely decisions from the elected executive group. Frequent briefings and status reports were conducted, serving to give each participant a good picture of the overall incident and response status. There was excellent intra-conmunications and coordination. Regular contacts were established and nade with other participating centers. The only negative connent would be that the quarters for the radiological assessnent team, within the EOC were rather constricting for the nany activities, and the noise level within the office was higher than it should have been.

The Lake County EOC staff was notified of the Alert status at the utility at 8:46 A.M. ; the Site Area Energency at 11:11 A.M., and the General Energency at 12:37 P.M. The notifications from the utility was verified by telephone calls back to the Perry Nuclear Power Plant.

Protective action orders to take shelter were issued at 12:41 P.M. for sub areas 1,2, and 3. Sirens and the EBS were activated at 12:50 P.M.

Protective action orders to evacuate were issued at 1:27 P.M. for sub areas 1,2,3,4, and 5. Tha sirens were sounded and EBS activated.

FACILITIES The Lake County EOC facility has the necessary furniture, anple space, lighting, telephones, and all other anenities to support operations of the EOC. There is a fully equipped kitchen; separate bunk areas for nen and wonen; showers in one area for workers, and showers near the front entrance, if needed for decontamination. There is energency power available and it was effectively denonstrated during the exercise. The energency classification levels were posted in several locations within the EOC.

There were two (2) status boards in the operations room which were kept up to date throughout the exercise. One (1) was for general infornation and one (1) for significant events. Exercise events were also typed so there would be a pernenent record of events. A third status board was located in the room with the executive group. All status boards were clearly visible to the participants. All necessary naps were posted and infornation on them was updated as necessary.

COMMUNICATIONS The prinary connonications with the utility, State, Ashtabula and Geauga Counties is a five-way dedicated telephone line, with connercial telephone and radio as Mck-up. During the early part of the exercise there was a slight problem with the five-way dedicated telehone line. However, the problem did not affect the operation. Upon identification of the problem the connonicators inacdiately switched to the back-up telephone and within five (5) minutes the five-way telephone was Mck in operation. There is also a three-way dedicated telephone line that is used by the three (3) counties that are inpacted by the PNPP. A dedicated telephone is also available for connunications with the JPIC and a facsimile nachine is used for hard-copy. All EBS nessages originating at the EOC were sent to the JPIC so they could be incorporated into the news releases.

45

Radio contact was established by both Lake County field nonitoring teans with the field team director at the Lake County EOC prior to their departure for their initial assignnents. Radio contact appeared to be naintained essentially throughout the exercise. According to field team nenbers in the past there had been difficulties with radio connonications, but the problens appeared to have been resolved with the installation of supplenentary radio equipnent in the area. The teans had vehicle nounted radios which had the additional capability of telephone connonications. In addition, the teams had hand-held portable radios which were denonstrated and used for a period of tine by each team.

DOSE ASSESSMENT AND PROTECTIVE ACTION RECOMMENDATION Dose assessaent and protective action reconnendation are prinarily the responsibility of the State of Ohio. The Counties received and inplenented protective actions based on reconnendations from the State EOC.

PUBLIC ALERTING AND INSTRUCTION The Executive Group has the responsibility for alerting the public according to the plan. Af ter receiving the nessage from the State EOC, via the five-way dedicated telephone line, the executive group proceeded in a very orderly and business-like nonner to alert the public. The initial call was received at 12:37 P.M., the sirens were activated at 12:47 P.M. and the EBS at 12:50 P.M. Prior to activation of the sirens the executive group contacted Geauga and Ashtabula Counties to coordinate the activation of the alert and notification system. As indicated in the plan, it is Lake County's responsibility to activate the system for the tri-counties of Lake, Ashtabula and Geauga. The sinalated activation of the alert and notification system was handled very efficiently. The sirens were activated a second tine at 1:37 P.M. The EBS nessage was re-broadcasted every fif teen (15) minutes for a period of one (1) hour. At 1:41 P.M. a new nessage was broadcast and it was also re-broadcasted every fif teen (15) minutes for one (1) hour. The EBS nessages were telephoned to the radio station but were not actually broadcasted.

PROTECTIVE ACTION l Protective actions were carried out by sindlated sheltering and evacuation of nost County areas, in coordination with efforts of the other two (2) counties. Traffic referral control points and access control points were quickly nonned, with tinely notice and instructions given to evacuees and host support facility personnel. The County Sheriff's police , fire departnent personnel, Ohio Highway Patrol and National Guard reacted pronptly to directives. The school systens, Anerican Red Cross, Hunan Services, and the Cooperative Extension Agency perforned well in their notifications and inglenentation. The entire ganut of protective actions were effectively carried out by staff at the Lake County EOC.

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1 4

RADIOLOGICAL EXPOSURE CONTROL

The Lake County EOC is located outside the ten (10) niile energency planning zone of the Perry Nuclear Power Plant. Dosinetry equipnent was available at the EOC for energency workers that nay have a need to travel into the EPZ.

Ehergency personnel of the County Sheriff's Police, fire departnent personnel and the Ohio State Patrol were issued dosinetery by their respective departnents as reflected in this report. Appropriate instructions were issued along with the dosineters. The County Radiological Officer and the energency workers in the field were aware of the noxinum dose allowed without authorization, and the location of the energency worker decontamination facilities.

i j MEDIA RELATIONS The Lake County PIO's assigned position is at the JPIC, with a liaison PIO at the EOC. No nedia representatives were present or evident, although their presence was expected at the EOC. Sinulated (controller inserted) nedia-type interruptions were snoothly handled and evidenced preparation and capacity for real visitations froninedia nenbers.

l FIELD ACTIVITY Lake County set-up an access control Point at State Route 84 and Park Road and traffic control points along State Route 20 at Perry Park Road, Center Road, Madison Road, and Parmley Road. The traffic control points were nonned at 11:56 A.M. and the access control point at 1:09 P.M. by police personnel of the Lake County Sheriff's Departnent. Two Sherriff's Departnent Policenen nanned the access control point and two each nanned the

three (3) traffic control points. All personnel had dosinetry equipnent, and vehicular and portable radio connonications with the Sheriff's connonication

,! center and their counterparts at road blocks and other locations. All.eight i (8) of the officers had been instructed on reading and recording of l

dosinetry infornation. Their instructions included how often to read dosineters and when to report readings to supervisors for relay to the County EOC. The Sheriff's personnel were familiar with the evacuation routes, the location of reception / care centers, and procedures for clearing traffic obstructions. According to the of ficers and Staff in the EOC there are sufficient persorrel and equipnent available to non traffic and access control poin' ani ~ evacuation routes clear of obstructions, even i during inclenent weu i Additionally, the County operated a Referral Point at the westbound rest area on Interstate Route 90. The six (6) person referral point team arrived

, at the rest area site at 11:33 A.M. They were later acconpanied by a truck,

carrying traffic cones for channeling traffic from the highway into the reception area. However, the site personnel and the truck driver discovered he had not delivered a sufficient nunber of traffic cones to properly l

i operate their planned traffic routing procedures. Signs intended to be used for notorist to identify the Referral Point location were poor. The workers 4

explained that hetter signs are being ordered by Lake County.

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-~. ~__ . _ _ _ _ _ _ _ _ _ _ _ _ ___ ___.. _ _ _ _ _ , _ , _ ____ _ _ . . _ . . _ _ _ _ . , . . _ _ . _ _ _ _ _ .

The County plan calls for controlling the nunber of people assigned to reception / care centers by the nunber of sheet naps distributed by the referral point personnel to individual evacuees and/or notorists. The sheet naps were pre-packed for each reception center in two (2) packs for each center. One (1) of the two packs of sheet naps represented a specific center at three-fourths (3/4) capacity The second pack included enough sheet naps for the renaining one-fourth (1/4) of the centers capacity.

Instructions for the handout of the sheet traps were intrepretated differently by referral point personnel. Sone personnel understood the instructions to nean that each individual evacuee was to receive a sheet nap. Others explained that each autoaobile carrying evacuees were to receive one (1) sheet nap with' no concern about the nunber of evacuees in each autonobile, thus the accountability of nunbers was lost and no substitute system was set-up.

Area Reconnended For Improvenent: The plan should be followed as written, i ie. , " hand out one (1) sheet nap per person".

All referral point personnel had high and low range disineters and TLDs.

They had record keeping logs and were prepared to turn in hourly readings to the radiological officer. Personnel seened nentally well prepared to deal with potential evacuee problena. They were aware of school evacuation procedures, locations and capacities of care centers, the agency and contact for keeping routes clear of wrecked or vehicular breakdowns. The operational schene for the referral point depended on a sorting of persons requesting and/or needing referral services froni the traffic on Interstate Route 90 as a result of an accident at the PNPP.

The referral point team had telephone contact with the EOC via use of the rest area telephone. The team was kept abreast of conditions at the PNPP by use of the sane telephone. 'No-way radio consnunications, in addition to the rest area telephone, would enhance the referral point team's connonications capability. A standby kit containing the following itens is reconnended for personnel: (1) reflective traffic vests, (2) suitable hats for seasons, either nun shield or warm caps, and (3) sturdy comfortable shoes.

Area Reconnended For Iniprovenent: Two-way radio connonications would enhance the referral team's connonications capability.

Reflective vests would distinguish official persons from others and increase c

safety in working between rows of noving traffic. People who work inside i of ten do not wear clothing suitable for extended periods of several hours outdoors A hat and suitable shoes would be valuable. The two (2) persons with open sandals and noderate high heels would have trouble fulfilling their duties on concrete, in traffic, and in the cold for an extended period of tine.

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l.

2 FIELD MONITORING

%e two (2) Lake County field nonitoring teans were nobilized from their places of enploynent at the General Health District Office in the County.

i Administration Building in Painesville. A telephone call from the Lake County EOC, advising of the Alert Status at the PNPP was received by the j County Health Conniissioner at 8:57 A.M. An energency response personnel 3 call-up roster was available but was not necessary since nenbers of the f field nonitoring teaus were already on duty in the County Health Departnent.

Team equipnent, packed for rapid deploynent, was tenporarily stored in the

! long terne storage area of the County Health Departnent's Laboratory in the 2 basenent of the building. Vehicles assigned to the field teans were located l in a parking lot adjacent to the County Administration Building. The director of the field nonitoring teans departed for the Lake County EOC,

)

after giving the teans instructions'to depart after conpleting their preparations. The teans departed the County Administration Building, a

little before 10
00 A.M., to two (2) assigned locations downwind of the

} - PNPP. We teans arrived at their assigned initial locations near the PNPP at l approxinately 10:11 A.M. and 10:23 A.M. respectively. The two (2) teans received briefings on noteorological conditions but a mininum of infornation about utility conditions, during radio checks with the Lake County EOC.

l Area Reconnended For Inprovenent: The County should insure that the field

) teans receive infornation on plant conditicas-in addition to the i noteorological infornation.

I Radio contact was established by both Lake County field nonitoring teans l

with the field team director at the Lake County EOC, prior to their-j departure for their initial assignnents. Radio contact appeared to be

naintained essentially throughout the exercise. According to field team

! nenbers, in the past there had been difficulties with radio connonications in the area, but the difficulties appeared to have been resolved with the

installation of supplenentary radio conmunications equipnent in the area.

We teans had vehicle nounted radios which had the additional capability of i telephone conmunications. In addition, the teans had hand held portable radios which were denonstrated and used for a period of tine by each team.

Team nenbers were supplied with disposable anti-contamination suits, plastic boots, gloves,etc. The teans had bottles of potassium iodide (KI) tablets

' with them. Each team nenber had a TLD and three (3) self reading dosineters (low range 0-200 nR; mid-range 0-20 R, and high-range 0-200 R) . The team 1

also had dosineter chargers in each vehicle, record keeping cards and noterials.. The dosineter readings were frequently transmi.tted by radio to _

the field team director at the Lake County EOC. Team nenbers knew how to l read and record their dosineters, and had infornation on dose limits and

! procedures. They were also aware of procedures for decontamination.

' The Lake County plan contains a list of equipnent in the field nonitoring equipnent kits and the list corresponds to what the team had available.

Each team had a checklist of equipnent , and they checked through the '.

equipnent carefully prior to departure. The teams were well equipped for neasuring anbient radiation levels in the plune. Each teans equipnent included an Eberline ESP-1 with three probes, and a Bicron scintillator counter, as well as two (2) civil defense survey neters. Additionally, each i team had an air sanpler which was powered by their vehicle's source of 49

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i a

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power; a supply of silver zeolite, and charcoal cartridges. All equipnent examined for calibration was narked as having been calibrated within the past four (4) nonths. The County teans were not specifically equipped for environnental sanpling. The team's vehicles were standard size station wagons, which were large enough for the teans and their equipnent, and appeared to be suitable for anticipated terrain and weather conditions. The teans had naps of the area, but designations used during the exercise to identify sub areas for evacuation and sheltering were not present on any naps in the possession of the nonitoring teans. This led to sone confusion and the need for radio requests for interpretation of where the evacuation and sheltering were occurring.

Area Reconnended For Inprovenent: The field team equipnent should include appropriate naps that correspond with location infornation being disseminated by the EOC.

Prior to departure for their assignnents the County field nonitoring teans set-up and checked out their equipnent carefully and systenatically with the supervision of the County Health District technical advisor. This included the installation of batteries, routine equipnent checks, and use of a barium radioactive source in setting-up sone of the instrunents. Written SOPS were used both in the set-up and operations of much of the equinent. Team nembers used their equipnent correctly. They had instrunents turned on with audio to continually nonitor the radiation level when appropriate. Plune traversal nonitoring was condxted with a probe extending outside the window of the vehicle, and neasurenents recorded at 0.1 mile intervals from the vehicle's hodoneters. All team nenbers were familiar with the region being nonitored, and they had no difficulties in following the naps and finding the nonitoring locations. Both teans collected air sanples for particulates and radio-iodines. Written procedures were followed and the procedures appeared to be adequate for detection of radio-iodine concentrations in air at the level of 10-7 uCi/cc. Cartridges from air sanpling by the two (2) teans were, af ter cessation of the release, transferred to one (1) vehicle and driven to the Lost Nation Airport, where they were delivered to the State field nonitoring team personnel for simulated transport by helicopter to a State laboratory for analysis. No additional environnental sanples were collected by the Lake County teans. Discussions with County and State personnel of the field nonitoring teans suggest that environnental sanpling was the province of the State field nonitoring team that was observed to collect water, soil and vegetation sanples.

RECEPTION / CONGREGATE CARE AND DECONTAMINATION At 11:15 A.M. the County Health Departnent activated a team to check the potential reception / congregate care centers for possible use. At approxinately 12:15 P.M. the enetgency response and support organizations, responsible for operation of the reception / congregate care and decontaminations centers in Lake County, were notified and placed on standby for the potential need to open and operate centers as a result of the incident at the PNPP. At approxinately 1:10 P.M. the Anerican Red Cross (ARC) shelter nanager and other ARC team nenbers were notified by counterparts in the County EOC to ready the North High School reception / congregate care center for receipt of evacuees. The center was fully staffed and ready for occupancy at approxinately 2:45 P.M. by personnel from ARC, the Lake County Health Departaent, Eastlake Fire Departnent, North High School staff, and the Eastlake Anateur Radio Club.

50

The North High School reception / congregate care center is located well i outside the ten (10) niile EPZ of the PNPP. The center will acconodate approxinately 1,600 evacuees. Additional care centers would be opened to acconodate evacuees as each preceding center reaches capacity.

The North High School reception / congregate care center is well equipped with facilities for cooking and feeding, showering, sleeping roars / areas, recreation, nursing station (s), and other anenities for the tenporary well-

. being of evacuees. The school supplies already in the cafeteria and the

! purchase of additional goods locally would be used to feed evacuees. The Ancrican Red Cross by preplanned agreenent would provide cot and blankets for the evacuees and nanagenent of the center (s) . Special roans would be set-up for the handicapped and staf fed by Red Cross nurses. The center used concercial telephone as the prinary neans of connonications with the EOC and other agencies / organizations. Ham radio operators were operational in the center and were able to connonicate with their counterparts in the EOCs and other centers operating during the exercise.

The Red Cross fully denonstrated the disaster plan which includes preparing, opening and operating a reception / congregate care center. The Red Cross spokesperson verbally described nass feeding and sheltering of evacuees.

Additionally, the reception / congregate care center staff denonstrated registration of evacuees at the center by use of two (2) volunteers role playing as evacuees.

The Eastlake Fire Departnent exhibited a thorough knowledge of procedures

, for radiological nonitoring and decontamination of evacuees and energency workers. They prepared the nonitoring and decontamination areas with professionalista. Two (2) volunteer evacuees arrived at the North High i School reception / congregate care center by privately owned autonobile. Both 4

Persons passing through the station wore beta buttons to enhance denonstration of the radiological nonitoring teans ability to properly nonitor and detect radiological contamination. The nonitoring team very capably located the beta buttons, by use of the CDV 700 geigher counter and satisfactorily recorded the dosages by use of a dose log for each of the volunteers. Decontamination procedures were inglenented.

1 1

MEDICAL SUPPORT Energency room staff of the Lake County Menorial Hospital East denonstrated the adequacy of hospital facilities and procedures for handling contaminated individuals. The hospital's energency room staff was contacted by PNPP personnel advising the hospital of the incident at the plant and that the patient would be enroute by anbulance. While enroute the anbulance, from j, the Perry Fire Departnent, connonicated with the hospital by two-way. radio installed in the anbulance. Connercial telephone in the nethod used by the hospital to connonicate with the utility, EOC, reception / congregate care

centers and other locations. A health physicist from the utility j acconpanied the anbulance crew fran the plant to the hospital. The hospital's energency roan staff, by use of the necessary equipnent, nonitored the patient for radiological contamination and denonstrated patient handling and decontamination procedures. The hospital is equipped with it's own nuclear nedicine departnent. The hospital's handling was satisfactory in denonstrating their ability to treat a contaminated patient.
51

The anbulance crew from the Perry Fire Departnent followed procedures for renoving the patient from the anbulance and transferring and assisting the hospital staf f in getting the patient into the treatuent room. The crew awaited the arrival of the second health physicist and departed the hospital after being nonitored for potential radiation contamination.

RECOVERY AND REENTRY Recovery and reentry was not an exercise objective to be den.onstrated during this exercise.

52

SUMMARY

LISTING OF EXERCISE FINDINGS 53

UTILITY: Perry Nuclear Power Plant Suntrary Listing of Exercise Findings ,

1. Deficiencies Ohio April 15, 1986 (State) (Date)

Ohio (Contronity)

NUREC Narrative Statenent Corrective Action Scheduled Actual Iteni of Deficiency Proposed Date Date NONE 54

)

UTILITY: Perry Nuclear Power Plant Sunnary Listing of Exercise Findings

2. Areas Requiring Corrective Action Ohio April 15 1986 (State) (Date)

Ohio (Conniunity)

NUREG Narrative Statenent Corrective Action Scheduled Actual Item of W'akness e Proposed Date Date I.8 Radiological sanpling sites nust be reevaluated for sanpling representativeness and radio connonications.

55

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

I i

i-I UTILITY: Perry Nuclear Power Plant Sunnary Listing of Exercise Findings

3. Areas Reconnended For Inprovenent 1

i Ohio April 15, 1986 (State) (Date)

I Ohio (Conciunity)

1. The Ohio Environnental Protection Agency (OEPA) field nonitoring staff of the Twinsburg District Office needs additional training in field nonitoring.
2. Field nonitoring team nonbers of the OEPA's Twinsburg District Office need training in the use of dosinetry, dose assessnent and decontamination j procedures.
3. The field nonitoring team should ensure that equipnent brought to the fleid is properly labeled and calibration dates are properly recorded.
4. News releases and oral briefings should include the call letters and frequencies of the EBS stations.

4 1

i l

1 1

j 56 I

1 J

UTILITY: Perry Nuclear Power Plant Sunnary Listing of Exercise Findings

1. Deficiencies Ohio April 15, 1986 (State) (Date)

Ashtabula County (Conmunity '

NUREG Narrative Statenent Corrective Action Scheduled Actual Item of Deficiency Proposed Date Date NONE 57

(TTILITY: Perry Nuclear Power Plant Sunnery Listing of Exercise Findings

2. Areas Requiring Corrective Action Ohio .

April 15, 1986 (Statc) (Date)

Ashtabula County Connonity)

NUREG Narrative Statenent Corrective Action Scheduled Actual Iteni of Weakness Proposed Date Date None 58

UTILITY: Perry Nuclear Power Plant Sunatary Listing of Exercise Findings

3. Areas Reconnended For Inprovenent Ohio April 15, 1986 (Sta te) (Date)

Ashtabula County (Connonity)

1. The DSA coordinator / executive group should hold periodic briefings in the operations room, where each departnent/ agency representative report

. actions taken by their respective agencies /departaents.

1. Events and conditions should be reflected with the proper occurrence and receipt tine from the utility, State, other Counties and/or other sources.

] The neaning of tine on County fortis need to be nore accurately reflected.

1 j 3. The adoption and use of a' " standard type" status board, with colunns and headings / captions would enhance EOC operations.

]

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4. Transparent overlays on the radiological plotting naps would be helpful for the ten (10) mile EPZ nap, where prearranged conbinations by sectors could be used to display the plune EP7 and protective actions taken by the j County.
5. The five-way dedicated telephone link should be inproved and corrected to obtain a clear and interference free level of perfornance.

i 4 59

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UTILITY: Perry Nuclear Pcuer Plant Sunt:ary Listing of Exercise Findings

1. Deficiencies Ohio April 15, 1986 (State) (Date)

Geauga County (Contronity)

NUREG Narrative Statenent Corrective Action Scheduled Actual Item of Deficiency Proposed Date Date NONE 60

UTILITY: Perry Nuclear Power Plant Sunnary Listing of Exercise Findings

2. Areas Requiring Corrective Actions Ohio April 15, 1986 (State) (Date)

Geauga County (Conniunity)

NUREG Narrative Statenent Corrective Tsction Scheduled Actual Item of Weakness Proposed Date Date NONE 4

\

61 i

UTILITY: Perry Nuclear Power Plant Sunnary Listing of Exercise Findings

3. Areas Reconnended For Inprovenent Ohio April 15, 1986 (State) (Date)

Ceauga County (Conniunity)

1. The SOP for decontainination of energency workers should be reviewed and rewritten so that the whole body is renonitored.
2. A herculite tarpaulin or other suitable naterial should be used as a runway floor covering in the treatnent area for potentially contaniinated patients.

62

UTILITY: Perry Nuclear Power Plant Sunnary Listing of Exercise Findings

1. Deficiencies Ohio April 15, 1986 (State) (Date)

Lake County i (Connonity)

NUREG Narrative Statenent Corrective Action Scheduled Actual Item of Deficiency Proposed Date Date NOME 1

63

UTILITY: Perry Nuclear Power Plant Sunnery Listing of Exercise Findings i

3. Areas Reconnended For Inprovenent I I

i Ohio April 15, 1986 (State) (Date)

Lake County (Connonity) l

1. The County should ensure that the field teans receive infornation on plant conditions, in addition to the neteorological infornation.

I

2. The field team equipaent should include appropriate naps that correspond with location infornation being disseminated by the EOC.
3. 'IVo-way radio connonications would enhance the referral point team's connonications capability.
4. .To ensure an accurate account of the nunber of persons being referred to reception / care centers, County staff assigned to the referral point'should follow the plan as written (i.e., " hand out one (1) sheet nap per person").

h 65

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