ML20116E548
| ML20116E548 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/15/1985 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20116E550 | List: |
| References | |
| NUDOCS 8504300324 | |
| Download: ML20116E548 (18) | |
Text
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.e l [ s{ Federal Emergency Management Agency
? Washington, D.C. 20472 q ,.
APR I 51985 MEMORANDUM FOR: Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission r #-
FROM:
! Assistant Associate Director Office of Natural and Technological Hazards Programs
SUBJECT:
Exercise Report and Schedule of Corrective Actions for the October 10-11, 1984 Exercise of the Offsite Radiological Emergency Preparedness (REP) Plans for the LaSalle Nuclear Power Plant (NPP)
Attached are two copies of the Exercise Report for the October 10-11, 1984, joint exercise of the offsite REP plans for the LaSalle NPP. This was a partial participation exercise for the State of Illinois, and a full participation exercise for LaSalle and Grundy Counties. The report dated November 26, 1984, was prepared by Region V, Federal Emergency Management Agency (FEMA). It was revised March 26, 1985, to reflect clarifications mentioned below. These clarifications surfaced after the original report was completed.
Originally, there were two category A deficiencies, i.e, those affecting the public health and safety, identified during the evaluation of the LaSalle exercise, one each for LaSalle and Grundy Counties. Both deficiencies were related to lack of timely EBS activation, although the underlying cause for the untineliness was different for each county. However, upon further examination of the exercise observer's notes, it has been decided that the Category A deficiency for LaSalle County should be reduced to a Category B deficiency. The attached exercise reports have been revised to reflect this change and the reasoning explained in the following paragraphs.
In LaSalle County, the directive to actfvate the prompt alert and notification system (PANS) was received from the State of Illinois at 9:00 p.m. The County E0C staff required seven (7) minutes for proper verification at 9:07 p.n. and an additional fifteen (15) ninutes for simulated siren activation at 9:22 p.m. The simulated EBS notification was
, given at 9:25 p.n. While the time required to initiate public alerting i appears to be excessive, there were several mitigating factors. The verification period was appropriate since the situation at the utility had just reached site area emergency. The E0C staff wanted verification that public alerting was necessary at this time. Further, several E0C staff members were engaged in a response to a real-life emergency situation which temporarily diverted their attention and lengthened the time required for verification.
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- Upon receipt of the verification, the county did simulate activation of the sirens within fifteen (15) minutes. Concurrent with the verification and activation process, E0C staff were preparing the EBS message and it was ready for broadcast prior to siren activation. In fact, an attempt was made at the time of siren activation to read the message to the radio station (simulated).
An actual telephone call was made to a person simulating the role of the radio station (Actually the caller was attempting to call a friend who was to simulate the role of the radio station). However, this first attempt at a call resulted in a busy signal. At this point, the E0C staff member could have read the EBS message into the telephone which would have represented timely activation. Instead a second telephone call was made a few minutes later; at that time, the EBS message was read to the person simulating the radio station. (It should be noted that a radio backup exists between the County E0C and the EBS radio station.)
After consideration of these mitigating factors, LaSalle County did demonstrate that it can provide timely public alerting and notification in the event of an emergency at the LaSalle Nuclear Power Station. However, because the total PANS required twenty-five (25) minutes for activation, a Category B deficiency exists. It is FEMA's opinion that this deficency is best corrected by training on the procedures for PANS activation. The certification test of December 4, 1984 provided LaSalle County with an opportunity to successfully demonstrate their implementation procedures. A combination of this test, and both an initial and a follow-up, formal training session conducted with LaSalle County emergency services personnel, is considered adequate corrective actions for this particular deficiency.
Grundy County was cited for a Category A deficiency (NUREG evaluation criterion E.5) becaust 30 minutes elapsed from the time the sirens were sounded (simulated) until the initial instructional message was forwarded to the EBS station. This deficiency involves the failure to provide timely notification via the EBS. The EBS notification was overlooked until the E0C staff were questioned on this point by the federal evaluator. This deficiency was directly attributable to the turnover of the Grundy County Emergency Services and Disaster Assistance Coordinator just prior to the exercise.
This individual has subsequently received training as to the duties and responsibilities of his position with respect to radiological emergency preparedness. Further, Grundy County successfully demonstrated the procedure for activation of the EBS notification during the Prompt Alert and Notification System (PANS) certification test of December 4,1984. (It is recognized that a PANS certification test does not test timeliness of EBS notification.)
Grundy County will be required to successfully demonstrate timely activation of the PANS during the Dresden exercise on April 23, 1985. Grundy County is fully participating in the Dresden exercise and timely public alerting and notification is an exercise objective. (Note too that Grundy County is scheduled to participate in the initial Braidwood exercise in November of this year.)
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a A final resolution of the Category A deficiency for Grundy County cannot
.be made until the Dresden exercise in April at which time the County will have as an objective successful demonstration of the public alerting and notification system. Following the exercise, FEMA Headquarters will make a determination regarding the overall adequacy of the corrective actions and the status of approval under FEMA Rule 44 CFR 350.
A copy of the State's schedule of corrective actions is also attached. Since the corrective actions for Grundy and LaSalle Counties are explained in detail in this memorandum, this memorandum and the Illinois proposed corrective -
action response dated December 20, 1984 are to be considered in conjunction ,
with each other.
If you have any questions, please contact Mr. Robert S. Wilkerson, Chief, Technological Hazards Division at 646-2861.
Attachments As Stated I
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Illinois Emergency Services and Disaster Agency 110 East Adams Street, Springfield, Illinois 62706 April 9.1985 Mr. Gordon Wenger Emergency Management Program Specialist Region V, Federal Emergency Management Agency Federal Center 74 North Washington Street Battle Creek, Michigan 49016
Dear Mr. Wenger:
This letter is in response to Mr. Wallace Weaver's January 14. 1985 letter to Charles Jones in which Mr. Weaver requests that the Illinois Emergency Services and Disaster Agency provide a training meeting for the LaSalle County officials.
During February and March, four meetings have been held with the LaSalle County ESDA Coordinator and one with LaSalle County Board Chair-man regarding the timely E55 activation. The resulting enhanced pro-ficiency and improved procedures will enable LaSalle County to demonstrate their t.apability during the next scheduled exercise.
Sincerely,
% 7 4 O 19 David L. Wise Chief Division of Radiological Emergency Planning OLW/1h
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March 23, 1985 Mr. Charles D. Jonea Director, Illinois Emergency ,
Services and Disaster Agency 110 rest Adame Street Springfield, Illinois 62706 Daar Mr. Jonest k I have received and reviewed your followup corrective actions dated March 11, 1985 relative to the LaSalle exercise deficiencies.
Following discussions with FEMA Usadquarters staff and upon further examination of the exercise observer's notes, it has been decided that based on the information discussed below the category A deficiency for taSalle County will be reduced to a category B deficiency. A copy of five page changes to the LaSalle exercise report reflecting this decision are enclosed with this letter'.
In LaSalle County, the directive to activate the fat!S was received from the State of Illinois at 9:00 p.m. The county EOC staff '
required seven (7) minutos for proper verification and an additinnat fifteen (15) minutes for simulated siren activation at 9:22 p.mi The simulated E3S notification was given at 9:25 p.m. While the time required to initiate public alertinr. appears to he excessive, there were several mitigating factors. The verification period was appropriate since the situation at the utility had only just reached site area emergency (8:27 p.m.). The ROC staff wanted s verification that public alerting was necessary at ,this time.
Further, several EOC staff members were engaped ith a reaponse to a real-life emergency situation which temporarily diverted their attention and lengthened the time required for verification. You will note that upon receipt of the verification, the county did simulate activation of the sirene within fifteen (15) minutes.
Concurrent with the verification and activation time, EOC staff were preparing the EES message and it was ready for broadcast prior to the simulated siren activation. In fact, an attempt was made at the time of the simulated airen activation to simulate reading the seenage to the radio station. An actual telephone call wee made to a person simulating the role of the radio station.
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However this first attempt at a call resulted in a busy signal. At this point the EOC staff member could have read the EUS messa2e into the telephone which would 1myc represented tir.ely activation. (
Instead a second telephone call was made a few ninutes later at which time the E3S message was read to the person simulating the radio ,
station. (It should be noted that a radio backup exists between the I county EOC af.d the E3S radio station.)
It is my opinion that af ter consideration of these mitigating factors, l LaSalle County did demonstrate that it can provide timely public alerting and notification in the event of an eccrgency at the LaSalle Nuclear Power Station. However, because the total PAMS required twenty-five (25) minutes for activation, a category 3 deficiency exists. But this deficiency is best corrected by training on the procedures for PAUS activation not by a demonstration of timeliness. ,
The PANS certification test of December 4,1934 provided LaSalle '
County with an opportunity to successfully demonstrate their implenentation procedures. This test combined with the initial and formal training conlucted with LaSalle County emergency services -
personnel and receipt of your report of the LaSalle County training I will constitute an adequate corrective action for this particular -
deficiency. f For Grundy County, final resolution of the category A deficiency cannot he determined until all of the corrective actions have been implemented. This includes a demonstration of successful public alerting and notification by Crundy County during the upcomin2 Dresden exercise.
I would like to clarify a statament I made in my January 14, 1995 letter to you. I mistakenly noted that during the Prompt Alert and Motification System (FAN 3) certification test of December 4,1934, both LaSalle and Crundy Counties " demonstrated the ability to activate the EBS in a timely manner." The PA?!S certification test demonstrates implementation procedures but does not test timeliness.
Thus, the requirement for Grundy County to demonstrate timelinees of the alert and notification system durink the Dresden exercise.
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1 Upon successful demonstration of public alerting and notification by Crundy County during the Dresden exercise, FEMA Ueadquarters will determine the adequacy of the corrective actions and issue a statement as to the status of approval unJer FEMA rule 44 CrF 350 As an interim measure I am providing a copy of your letter with my recommendation for acceptance of your corrective nettons to TE"A Headquarters. I will keep you informed as to their actions in this manner. If you have any questions please do not hesitate to contact me, sincerely, Vallace J. Veaver, Chsirman P.cgional Assistance Committee Enclosure I
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g 6-9 pp D 9.985 lilinois Emergency Services and Disaster Agency 110 East Adams Street, Springfield, Illinois 62706 March 11, 1985 Mr. Wallace J. Weaver, Chairman Regional Assistance Committee Federal Emergency Management Agency Region V 300 South Wacker, 24th Floor Chicago, IL 60606
Dear Mr. Weaver:
This letter responds to your letter dated January 14, 1985 relative to required corrective actions for the LaSalle exercise deficiencies.
9 I concur completely that the PANS certification test conducted on December 4, 1984 clearly demonstrated the capability of Grundy and LaSalle counties to activate the EBS in a timely manner in accordance with established procedures. I am certain that the Dresden PANS will be equally satisfactory and effectively demonstrate the capabilities of all three counties in the EPZ. Additionally, I feel confident that Grundy County will perforn in a highly satisfactory manner during the Dresden exercise scheduled fer April 1985. I appreciate your sharing our concern for this county that is burdened by being impacted by three nuclear power plants.
As you noted in discussing the LaSalle County deficiency, the PANS certification test certainly demonstrated their ability to activate the EBS system in a timely manner. Training sessions with the LaSalle County ESDA Coordinator have already been initiated. A formal training session will be conducted immediately after the Zion exercise and prior to April 1, 1985. A report of this formal training will be provided as requested.
Bulk distribution of the Public Information Booklets was made throughout the EPZ. A summary of this distribution will be provided by Commenwealth Edison and provided to you. Only Quad Cities uses the sophisticated computerized system. The others use a manual system.
Procedures and manpcwer are available to address deficiency cited under J.10.j. However, the procedures were not implemented nor was mutual aid or state resources requested. This will be demonstrated during the next exercise involving LaSalle County.
Your comment relative to conducting a media briefing for the federal evaluator is well taken. Grundy County will be advised to demonstrate this capability during the Dresden exercise in April, 1985.
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'Mr. Wallace Weaver 2 March 11, 1985 Your assistance in adding to the realism of an exercise by having the message traffic to FEMA acknowledged by the regional communications center is appreciated. We will be sending messages during future exercises with special emphasis on the annual full scale exercise.
Your comments have been constructive and have added to the completeness of our plans. I wish to express my appreciation for your understanding of the difficult burden that is placed on Grundy County. They have a fine new coordinator who will demonstrate a renewed degree of excellence during the forthcoming Dresden exercise in April.
Sincerely, n mA.,,3 Charles D. Jone.s Director N CDJaht y
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. 1 Federal Emergency Management Agency Region V 300 South Wacker,24th Floor, Chicago,IL 60606 (312) 353-1500 January 14, 1985 Mr. Charles D. Jones
, Acting Director Illinois Dmergency Services and Disaster Agency 110 East Adams Street Springfield, Illinois 62706
Dear Mr. Jones:
This letter is in response to your proposed corrective action dated December 20, 1984 and my conversation with David Wise of your staff concerning the deficiencies for the October 10-11, 1984, LaSalle radiological emergency preparedness exercise. As a result of the letter and conversation, I have amended the required corrective actions for the LaSalle exercise deficiencies. LaSalle County and Grundy County are no longer required to conduct a remedial exercise to correct their category A deficiencies to NUREG-0654 criteria elements E.6. and E.5. respectively.
This amendment to the required corrective action is based on two factors.
First, during the LaSalle prompt alert and notification system (PANS) certification test of December 4, 1984, both Counties demonstrated the ability to activate the EBS in a timely manner. Both Counties did so by preparing a " live" test message and broadcasting it through the EBS.
Further, Grundy County is scheduled to participate in the Dresden PANS certification test tentatively set for May 7, 1985.
The second factor concerns the nature of the deficiencies themselves.
During the LaSalle exercise the sirens were activated in a timely fashion.
The deficiencies involve timely activation of the EBS.
In the case of Grundy County, the deficiency is such that it should also be corrected under exercise conditions. I concur with your position that Grundy County will have adequate opportunity to demonstrate its capability during the Dresden exercise in April and the Braidwood exercise tentatively schedule for late 1985. A single issue remedial exercise for Grundy County would be counterproductive.
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In the case of LaSalle County, the deficiency is such that it can be
- corrected by the PANS certification test and a meeting with LaSalle County officials to provide training as to the importance of timely EBS activation.
David Wise indicated that such a training session would be scheduled with LaSalle County. Please advise me of the date for this training session by February 1, 1985. This meeting with LaSalle County should be held prior to April 1, 1985 and a report provided to me for the record within two weeks of the meeting.
With respect to the remainder of your proposed corrective actions, they are approved. Please note that there are still two outstanding deficiencies from the July 12, 1983 LaSalle exercise for which we are awaiting implemen-tation of your corrective actions. These deficiencies are discussed on
- pages 10 and 11 of the October 10-11, 1984 LaSalle exercise report. For NUREG-0654 criteria element G.2. (Illinois), we are awaiting submission of the computerized mailing list similar to that provided for Quad Cities.
For NUREG-0654 criteria element J.10.j. (LaSalle County), we are awaiting the plan update scheduled for later this year.
I would like to discuss two of your responses to the cited deficiencies in more detail. For Grundy County (G.3.a. and G.4.b.), you state that the
' reason these objectives were not demonstrated is because no media represen-i tatives were present in the County EOC. While this is true, I remind you that the objectives can still be demonstrated by utilizing the designated
' press facility and giving at least one media briefing with the federal evaluator serving as a media representative. Further, preparation of media briefings can be demonstrated in the EOC by the appropriate staff.
For the State of Illinois (C.1.a.), I concur with your position that the FEMA Regional Office has not always been responsive to your exercise messages in the past. However, I have taken steps to insure that your messages will be acknowledged in future exercises. This objective is best demonstrated j
by the State of Illinois at your annual full participation exercise.
Enclosed with this letter are the page changes to the LaSalle exercise report. These revisions are the result of comments from you and FEMA Headquarters. Please incorporate these page changes in your copy of the exercise report and in any additional copies you may have distributed.
! If you have any questions, please call me at (312) 886-9530. I am providing a copy of this letter to my Headquarters Office for transmittal of the exercise report and your schedule of corrective actions to the NRC.
Sincerely, e
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Wallace J. W er, Chairman Regional Assistance Committee Enclosure cc: David Wise i
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Illinois Emergency Services and Disaster Agency 110 East Adams Street, Springfield, Illinois 62706 December 20, 1984 Mr. Wallace Weaver .
Chief, Technical Hazards Branch Region V, Federal Emergency Management Agency 300 South Wacker Drive Chicago, Illinois 60606
Dear Mr. Weaver:
This letter is in response to your letter of November 26, 1984 and the accompanying Report of the LaSalle Nuclear Power Station exercise conducted on October 10-11, 1984 Attached is our Proposed Corrective Action Response which indicates the schedule for correcting the deficiencies, as you requested in your letter.
Sincerely,
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en rks c ate Director enci cc: Charles D. Jones Gordon Wenger '
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UTILITY: LaSalle Nuclear Power Station Summary Listing of Deficiencies Octobe r 10-11, 1984 1111 note (Dete)
(State) Deficiencies Affecting Public Health and Safety A.
Illinois (Community)
Corrective Action Scheduled Actual NUREG Narrative Statement Date Date I
Item of Deficiency Proposed i
None 1
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UTILITY: LaSalle Nuclear Power Station l
Summary Listing of Deficiencies Illinola October 10-11. 1984 (State) (Date)
B. Other Deficiencies Illinois (Community)
NUREC Narrative Statement Corrective Action Scheduled Actual l
l Item of Deficiency Proposed Date Date i
C.I.a. The State did not demonstrate the ability This capability will reluctantly be 4/86 l identify need for, request and obtain demonstrated during the next regularly i
federal assistance. scheduled exercise. It would add i
realism to the exercises if FEMA would l' respond to the messages or at least
. acknowledge them. It was because of this demonstrated lack of interest and i
participation on FEMA's part that no messages were sent.
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UTILITY: LaSalle Nuclear Power Station Summary Listing of Deficiencies 1111 note October 10-11, 1984 (State) (Dete)
A. Deficiencies Affecting Public Health and Safety LaSalle County (Comunanity)
NUREG Narrative Statement Corrective Action Scheduled Actual Item of Deficiency Proposed Date Date E.6. Activation of the Prompt Alert and The implementation of the procedures required Notification System was not accoglished to activate the system in the alloted time are within 15 minutes as atsted in easily demonstrated. A remedial drill would NUREG-0654, Appendix 3. be counterproductive to the REP program. Seven additional minutes are minimal. FEMA National is requested to adjudicate this ruling prior to our scheduling a remedial drill. The FEMA 43 demonstration on December 4,1984 showed PNS system capability better than an exercise. The disadvantages of a remedial drill far outweigh the advantages.
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UTILITY: LaSalle Nuclear Power Station Summary Listing of Deficiencies October 10-11, 19(
Illinois (Date)
(State) B. Other Deficiencies i
LaSalle County (Community)
Narrative Statement Corrective Action Scheduled Actual NUREG of Deficiency Proposed Date Date Itee D.3. Emergency classification placards were The placards are on hand and will be 4/86 not displayed in the Seneca EOC. (Seneca) displayed during the next regularly scheduled exercise.
J.10.f. Ki was distributed without authorization The DC0 noticed his error and retrieved from the State. (Ranson) the simulated KI tablets within twenty minutes.
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UT1b!TY: LaSalle Nuclear Power Station Summary Li: ting of Deficiencies Illinois October 10-11, 198 (State) (Bate)
A. Deficiencies Affecting Public Health sod Safety Crundy County (Community)
NUREC Narrative Statement Corrective Action Scheduled Actual Item of Deficiency Proposed Date Date 4
E.5. Thirty minutes elapsed from the time the Implementation of the procedure to strens sounded (simulated) untti the initial forward the message was stressed ,
instructional message was forwarded to the during County Executive Training.
EBS radio station. This capability has been demonstrated during several exercises. A remedial i drill would antagonize Grundy County unnecessarily. FEMA National is re-quested to rule on this requirement for a remedial drill. Grundy County is involved in three exercises (EPZ's) and three FEMA 43 demonstrations. Nothing will be gained from a remedial drill, on the contrary, much could be lost.
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i UTILITY: LaSalle Nuclear Power Station i
l Summary Listing of Deficiencies October 10-11. 1984 Illinois (Detd
- 5. Other Deficiencies
! Grundy County '
l (Community) .
Corrective Action Scheduled Actual NUREC Narrative Statement Date Date Proposed j Item of Deficiency i
! A.I.d. It was not readily apparent who was in The role of the Board Chairman, the charge of the total emergency response. ESDA Coordinator and the other key As a result, staff briefings were either officials will be stressed during not held or were ineffective. Individual the County Executive Training, as will staff members made decisions which offacted log and status board upkeep and message the total Eoc operation, e.g. message log, distribution. The new ESDA Coordinator status board and message distribution. will use assistants and formalize decision making process for future exercises.
i I A.4. Around-the-clock staffing capability was This capability will be demonstrated 4/86 1 not demonstrated. during the next regularly scheduled exercise,
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c.3.a. There were no press besefings held for the Press briefings are not held in E0C's C.4.b. media within the Grundy County EOC. anywhere. If press representatives j arrive at the Grundy County Court House j they are escorted to the Board Room which is the designated press center. No media
- representatives arrived, therefore there i, were no briefings.
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