new fema interim findings report ( ifr ) for open items for the … · 2012. 12. 1. · october...

Bruce Musico

From:Sent:To:Cc:Subject:Attachments:

Dan BarssWednesday, December 24, 2008 9:07 AMBruce MusicoKevin WilliamsFW: Letter from Vanessa E. Quinn Ref: NAPS IFR Open Items12-23-08 Letter Williams NAPS IFR Open ltems.pdf; 12-23-08 Letter Williams NAPS IFROpen Items Enclosure.pdf

For your action.

From: Dowgwillo, Theresa [mailto:[email protected]]Sent: Tuesday, December 23, 2008 2:52 PMTo: Kevin WilliamsCc: Dan Barss; Hammons, DarrellSubject: Letter from Vanessa E. Quinn Ref: NAPS IFR Open Items

Dear Mr. Williams:

Please find attached a letter to your attention from Vanessa E. Quinn, Chief, Radiological EmergencyPreparedness Branch, FEMA. The original has been sent to you via normal USPS mail delivery.

Please let me know if I can be of any assistance.

Thankfyou,

T. Reni DowgwifloExecutive AssistantRadiological Emergency Preparedness BranchTechnological Hazards DivisionNational Preparedness DirectorateDHS/FEMA(202) 212-2301 OfficeTheresa.Dowgwillo(,dhs.gov

1

U.S. Department of Homeland Security500 C Street, SW'Washington, DC 20472

FEMA

December 23, 2008

Mr. Kevin WilliamsChief, Licensing and Inspection BranchDivision of Preparedness and ResponseNuclear Security and Incident ResponseU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001

Ref: Interim Findings Report (IFR) for Open Items for the North Anna Power Station (NAPS)Unit 3 Combined License (COL) Application

Dear Mr. Williams:

Please find enclosed the IFR for Open Items for the NAPS COL application submitted by theRadiological Emergency Preparedness (REP) Program staff from our Region III Office. Thisenclosure serves as the deliverable for the completion of FEMA's portion of Phase II of the NAPSCOL application process. The status of emergency preparedness for offsite response for the NAPSwas determined based on the review of the following plans:

* The Commonwealth of Virginia Radiological Emergency Response Plan (COVRERP),Volume III

* The Commonwealth of Virginia Emergency Operations Plan Peacetime Disasters, May 2007.* The Commonwealth of Virginia Department of Health/Division of Radiological Health and

Safety Regulations, Emergency Response Plan, 2007 (without Appendix 17 StandardOperating Procedures).

* The Louisa County Radiological Emergency Response Plan (RERP), October 2006.• The Caroline County Radiological Emergency Response Plan (RERP), October 2006." The Hanover County Radiological Emergency Response Plan (RERP), October 2006.* The Orange County Radiological Emergency Response Plan (RERP), October 2006.* The Spotsylvania County Radiological Emergency Response Plan (RERP), October 2006.

The review of the offsite emergency plans resulted in evaluation findings for all of the planningstandards and associated criteria contained in NUREG-0654/FEMA-REP-1, Rev. 1, as amended, thatare Offsite Response Organization responsibilities. After a review of information provided by thelicensee's response to Phase I of the Request for Additional Information, (ratings by criterion), theratings were modified as follows:

" Planning Standard A: Adequate --corrections must be made.* Planning Standard B: N/A* Planning Standard C: Adequate -corrections must be made.

www.fema.gov

Mr. Kevin WilliamsDecember 23, 20008Page 2

* Planning Standard D: Adequate." Planning Standard E: Adequate -corrections must be made." Planning Standard F: Adequate -corrections must be made." Planning Standard G: Adequate.* Planning Standard H: Adequate --corrections must be made." Planning Standard I: Adequate - corrections must be made." Planning Standard J: Adequate - corrections must be made." Planning Standard K: Adequate - corrections.must be made.* Planning Standard L: Adequate - corrections must be made.• Planning Standard M: Adequate -corrections must be made.* Planning Standard N: Adequate - corrections must be made." Planning Standard 0: Adequate.* Planning Standard P: Adequate - corrections must be made.

Should you or members of your staff have any questions regarding this matter, please contactMr. Nathaniel Yates at (202) 212-2125 or Ms. Bonnie Sheffield at (202) 212-2120.

Sincerely,

Vanessa E. Quinn

ChiefRadiological Emergency Preparedness Branch

Enclosure: As stated

cc: D. Barss, NRCD. Hammons, FEMA Region III

INTERIM FINDINGS REPORT FOR OPEN ITEMS

On the Adequacy of OffsiteRadiological Emergency Response Planning and Preparedness

For theProposed North Anna Power Station Unit 3

December 16, 2008

Prepared by theFederal Emergency Management Agency

Preparedness, Training, and Exercises DirectorateExercises Division

TABLE OF CONTENTS

A. EXECUTIVE SUMMARY ................................................................ 1

B. INTRODUCTION .................................. ...................................... 1

1. General Characteristics of the North Anna Power Plant ............... 12. Emergency Response Organization ................................................... 13. P lans .................................................................................. . . 2

C. BASIS FOR FINDINGS ................................................................. 3

D. EVALUATION FORMAT .............................................................. 3

E. INTERIM FINDINGS ...................................................................... 4

F. SCHEDULE OF PENDING ACTIONS .............................................. 5

G. TECHNICAL REVIEW COMPOSITE SUMMARY ............................... 6

H. OPEN ITEMS ............................................................................. 8

ii

A. EXECUTIVE SUMMARY

On November 27, 2007, Dominion Virginia Power (Dominion) submitted a CombinedLicense Application (COL) to the U.S. Nuclear Regulatory Commission to construct andoperate Unit 3 of the North Anna Power Station (NAPS) facility located in LouisaCounty, Virginia, approximately 40 miles north-northwest of Richmond. Part 5 of theCOL application contained the proposed North Anna Power Station Unit 3 CombinedLicense Application Emergency Plan.

The two existing reactors at NAPS have been on-line since 1978 and 1980. FEMAgranted formal approval of the initial offsite response jurisdiction's (ORO's) RadiologicalEmergency Response Plans (RERPs) in February 1983 under 44CFR350.8. A qualifyingexercise, under the requirements of 44CFR350.9, was conducted on September 18, 1983.On September 2, 1987, FEMA completed its review of the alert and notification systeminstalled around NAPS and determined that the system is adequate to provide promptalerting and notification to the public in the event of an emergency at the site. Thisreview is of the current ORO's plans.

B. INTRODUCTION

1. General Characteristics of the North Anna Power Station

The North Anna Power Station (NAPS), consisting of approximately 1,856 acres, islocated in Louisa County on the southern shore of Lake Anna in central Virginia, 40miles northwest of Richmond, 38 miles east of Charlottesville, and 24 miles southwest ofFredericksburg.

The 10-mile plume Emergency Planning Zone (EPZ) includes Louisa, Carolina, Hanover,Orange and Spotsylvania Counties. While the 50-mile Ingestion Pathway Zone (IPZ)includes all or parts of Louisa, Hanover, Orange, Spotsylvania, Albemarle, Amelia,Buckingham, Chesterfield, Culpeper, Cumberland, Essex, Fauquier, Fluvanna,Goochland, Greene, Henrico, King George, King and Queen, King William, Madison,New Kent, Page, Powhatan, Prince William, Rappahannock, Richmond, Stafford andWestmoreland Counties in the Commonwealth of Virginia and Charles County in theState of Maryland. NAPS is owned and operated by Dominion Generation.

2. Emergency Response Organization

In the Commonwealth of Virginia, the implementation of protective actions beyond thesite boundary but within the 10-mile plume exposure EPZ and within the 50-mile IPZ isthe primary responsibility of the elected officials of the local governments. As time maybe a critical factor in providing protection against plume exposure, initial response isbased on the implementation of preplanned actions. Follow-up action will be taken on theadvice of the Virginia Emergency Operations Center (EOC) personnel based on theresults of evaluation and assessment of the accident. Local directors of emergencyservices may take independent and preemptive action to implement protective actions

Interim Findings Report For Open Items (North Anna Power Station) -1I-

within their jurisdictions. Jurisdictions implementing preemptive local protective actionswill ensure that the Virginia EOC and surrounding jurisdictions are fully informed of allactions and decisions.

The Virginia Department of Emergency Management (VDEM) will activate andcoordinate implementation of the State plan, to include assistance to local governmentsand coordination of emergency response actions of Federal and State agencies.

The Virginia Department of Health (VDH) will implement procedures to determineactual off-site radiation distribution to refine the projected dose. Based on thisassessment,. VDH will recommend protective actions to be taken. VDH will evaluate theradiological situation on a continuing basis from the time of initial notification until theradiological emergency is over. It will provide technical guidance and assistance relativeto actions required, as indicated by the situation.

Radiation assessment and coordination of protective actions within the IPZ will be theprimary responsibility of the VDEM and VDH in cooperation with the VirginiaDepartment of Agriculture and Consumer Services and the Virginia Department ofEnvironmental Quality, Water Division.

In the State of Maryland, the implementation of protective actions within the 50-mile IPZis the primary responsibility of the Secretary of the Department of the Environment withassistance provided by other state agencies and the local governments.

3. Plans

The Commonwealth of Virginia Radiological Emergency Response Plan (COVRERP) isVolume III of the Commonwealth of Virginia Emergency Operations Plan PeacetimeDisasters. Volume III includes the basic plan as well as the organization concepts andpolicies and establishes the assignments of emergency responsibilities for radiologicalemergencies. The Appendices and Annexes in Volume III also include operationalconcepts and procedures for specific emergency responsibilities for State departments.

Louisa, Caroline, Hanover, Orange, and Spotsylvania Counties maintain separateRadiological Emergency Response Plans (RERPs). The individual plans contain thecounty's concept of operations and policies. Appendices assign specific emergencyresponsibilities to local government agencies.

The North Anna Power Station Development of Evacuation Time Estimates, October2007 (report prepared by KLD Associates, Inc.), was also used in the review of the plans.

One county in the State of Maryland, Charles County, is in the 50-mile ingestionplanning zone for NAPS. The State of Maryland plan was provided for review onOctober 30,2008. The COL application's supplemental information included theexisting RERPs from the Commonwealth of Virginia (dated May 2007), Louisa County,Caroline County, Hanover County, Orange County, and Spotsylvania County (all dated

Interim Findings Report For Open Items (North Anna Power Station) -2-

October 2006). It also included the Evacuation Time Estimate (ETE) report prepared byKLD Associates, Inc., dated October 2007. The Emergency Response Plan (ERP), and aseparate NUREG-0654 Cross Reference, for the Virgifnia Department of Health/Divisionof Radiological Health (VDH/DRH) was provided, along with the Standing OperatingProcedures (Appendix 17) of the plan, and the State of Maryland RERP which extends tothe 50-mile Ingestion Planning Zone.

The materials listed above were the basis for the review. NUREG-0654/FEMA-REP-1,Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency ResponsePlans and Preparedness in Support of Nuclear Power Plants," amended March 2002, andits Supplements, the Interim REP Program Manual, dated August 2002, current FEMAguidance documents, and established industry practices were considered in making thedetermination as to the plans' adequacy.

C. BASIS FOR FINDINGS

The status of emergency preparedness for offsite response to possible incidents resultingfrom an accident at the NAPS has been determined based on:

Review of the Commonwealth of Virginia Radiological Emergency Response Plan(COVRERP), Volume III, The Commonwealth of Virginia Emergency Operations PlanPeacetime Disasters, May 2007.

* Review of the Commonwealth of Virginia Department of Health/Division ofRadiological Health and Safety Regulations, Emergency Response Plan, 2007(without Appendix 17 Standard Operating Procedures).

" Review of the Louisa County Radiological Emergency Response Plan (RERP),October 2006.

" Review of the Caroline County Radiological Emergency Response Plan (RERP),October 2006.

" Review of the Hanover County Radiological Emergency Response Plan (RERP),October 2006.

* Review of the Orange County Radiological Emergency Response Plan (RERP),October 2006.

" Review of the Spotsylvania County Radiological Emergency Response Plan(RERP), October 2006.

D. EVALUATION FORMAT

In accordance with the FEMA/NRC Memorandum of Understanding dated June 17,1993, FEMA has agreed to furnish assessments, findings, and determinations as towhether State and local emergency plans and preparedness are adequate and capable ofimplementation.

Guidance for review and development of radiological emergency response. plans iscontained in the document NUREG 0654/FEMA7REP-1, Rev. 1, "Criteria for Preparationand Evaluation of Radiological Emergency Response Plans and Preparedness in Support

Interim Findings Report For Open Items (North Anna Power Station) - 3 -

of Nuclear Power Plants," amended March 2002. NUREG-0654/FEMA-REP-l and itsSupplements, the Interim REP Program Manual, dated August 2002, current FEMAguidance documents, and established industry practices are considered in making thedetermination as to a plan's adequacy.

E. INTERIM FINDINGS

The review of the offsite emergency plans resulted in evaluation findings for all of theplanning standards and associated criteria contained in NUREG-0654/FEMA-REP- 1,Rev. 1, as amended, that are ORO responsibilities. Each planning standard and criterionwas rated as follows:

* Adequate: Plans are adequate and there is reasonable assurance that they can beimplemented with only limited or no corrections needed.

* Adequate - corrections must be made: Plans are adequate but before adetermination can be made as to whether they can be implemented, correctionsmust be made to the plans or supporting measures must be demonstrated (e.g.adequacy and maintenance of procedure, training, resource, staffing levels andqualifications, and equipment).

* Inadequate: Plans are inadequate and cannot be implemented until they arerevised to corrected deficiencies noted in the Federal review.

" N/A: The planning standard or criterion is not applicable to this ORO.

The initial review resulted in the following interim evaluation findings (ratings bycriterion) as follows:

* Planning Standard A: Adequate - corrections must be made.* Planning Standard B: N/A* Planning Standard C: Adequate -,corrections must be made.* Planning Standard D: Adequate.* Planning Standard E: Adequate - corrections must be made.* Planning Standard F: Adequate - corrections must be made.* Planning Standard G: Adequate - corrections must be made.* Planning Standard H: Adequate - corrections must be made.* Planning Standard I: Adequate - corrections must be made.* Planning Standard J: Adequate - corrections must be made.* Planning Standard K: Adequate - corrections must be made.* Planning Standard L: Adequate - corrections must be made.* Planning Standard M: Adequate - corrections must be made.* Planning Standard N: Adequate - corrections must be made.* Planning Standard 0: Adequate - corrections must be made.* Planning Standard P: Adequate - corrections must be made.

After a review of information provided by the licensee's response to Phase I of theRequest for Additional Information, (ratings by criterion) have been modified as follows:


* Planning Standard A: Adequate -corrections must be made.* Planning Standard B: N/A* Planning Standard C: Adequate -corrections must be made.* Planning Standard D: Adequate.* Planning Standard E: Adequate -corrections must be made.* Planning Standard F: Adequate -corrections must be made.* Planning Standard G: Adequate.* Planning Standard H: Adequate -corrections must be made.* Planning Standard I: Adequate - corrections must be made.* Planning Standard J: Adequate - corrections must be made.* Planning Standard K: Adequate- corrections must be made.* Planning Standard L: Adequate - corrections must be made.

Planning Standard M: Adequate -corrections must be made.* Planning Standard N: Adequate - corrections must be made.* Planning Standard 0: Adequate.* Planning Standard P: Adequate - corrections must be made.

Adequacy of the NAPS COL Application Emergency Plan review for OROs is alsodependent on:

* Satisfactory resolution of the above evaluation results that are "adequate -corrections must be made."

" An adequate demonstration of the completion of the COL Application EmergencyPlanning Inspections, Tests, Analyses, and Acceptance Criteria as it relates toOROs.

* Satisfactory demonstration of plan implementation during a joint exercise with thelicensee and state and local governments, as described in 44CFR350.9, andutilizing NAPS Unit 3 facilities.

F. SCHEDULE OF PENDING ACTIONS

The Commonwealth of Virginia is awaiting the Qualifying Exercise of the offsite plansand procedures for the 2009 Surry Biennial Exercise scheduled for August 4, 2009. Atthat time, necessary plan changes will be incorporated and submitted for Open Itemsidentified in the Commonwealth of Virginia Plans. In addition, The Commonwealth ofVirginia is awaiting the Qualifying Exercise of the offsite plans and procedures for the2010 North Anna Biennial Exercise scheduled for July 20, 2010. At that time, necessaryplan changes will be incorporated and submitted for Open Items identified in theCommonwealth of Virginia Risk County Plans.

Interim Findings Report For Open Items (North Anna Power Station) -5 -

G. TECHNICAL REVIEW COMPOSITE SUMMARY

The following table and discussion present the results for each criterion based on reviewof information provided by the licensee's response to Phase I of the Request forAdditional Information (RAI's), supporting documents submitted electronically or hardcopy, or verified by means of a site visit from FEMA Region III to the Commonwealth ofVirginia and the licensee. Of the total 109 criteria, Sixty-Nine criteria are now classifiedas adequate, one criterion remains inadequate, and Thirty-Nine criteria remain asadequate - corrections must be made.


G. Technical Review Composite Summaryfor Virginia and Risk County REP Plans in Support of North Anna COL

Element

A .L b ...................A`lIxA.1.b-- - .---- --A.1.d

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RAI Number Open Item Description State/County 1/County 2

NA 001 A

NA 001 B

NA 001 C

NA 001 D

NA 001 E

NA 001 F

NUREG-0654 Evaluation Criterion A.3 and C.4COVRERP Volume IIl, Basic Plan, Attachment 1Written Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of

Agreement, etc.

NUREG-0654 Evaluation Criterion A.3 and C.4Louisa County RERP NUREG-0654 Cross Reference

Written Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of

Agreement, etc

NUREG-0654 Evaluation Criterion A.3 and C.4Caroline County RERP NUREG-0654 Cross

Reference-Written Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of

Agreement, etc

NUREG-0654 Evaluation Criterion A.3 and C.4Hanover County RERP NUREG-0654 Cross

ReferenceWritten Agreements are not Incorporated into thePlan by Reference nor Cataloged by Title, Type of

Agreement, etc

NUREG-0654 Evaluation Criterion A.3 and C.4Orange County RERP NUREG-0654 Cross


Agreement, etc

NUREG-0654 Evaluation Criterion A.3 and C.4Spotsylvania County RERP NUREG-0654 Cross


Agreement, etc

Commonwealth of Virginia

Louisa County

Caroline County

Hanover County

Orange County

Spotsylvania County

NA 003 A

NA 003 B

NUREG-0654 Evaluation Criteria E.2 and F.L.eLouisa County RERP, Appendix 2, ESF#2 -

Communications Procedures and Appendix 5, ESF5Emergency Management Procedure

The Procedure for Mobilizing Response Personnel foran ALERT Declaration are not Included in the RERP

NUREG-0654 Evaluation Criteria E.2 and F.l.eCaroline County RERP, Appendix 2, ESF#2 -


The Procedure forMobilizing Response Personnel foran ALERT Declaration are not Included in the RERP

Louisa County"

Caroline County


RAI Number Open Item Description State/County I/County 2

NA 003 C NUREG-0654 Evaluation Criteria E.2 and F.l.e HanoverHanover County RERP, Appendix 2, ESF#2 -



NA 003 D NUREG-0654 Evaluation Criteria E.2 and F.1.e OrangeOrange County RERP, Appendix 2, ESF#2 -



NA 003 E NUREG-0654 Evaluation Criteria E.2 and F. 1.e Spotsylvania CountySpotsylvania County RERP, Appendix 2, ESF#2 -


The Procedure for Mobilizing Response Personnel for anALERT Declaration are not Included in the RERP

NA 004 A.1

NA 004 A.2

NA 004 B. I

NA 004.B.2

NUREG-0654 Evaluation Criterion E.5 and J.10.cIdentification of, Notification of, and Information

Dissemination to Special PopulationsLouisa County RERP, Appendix 8, Public Health

ESF Procedure,Does not Include Procedures on the Identification of

Special Needs Populations who are notInstitutionalized

NUREG-0654 Evaluation Criterion E.5 and J.10.cLouisa County RERP, Section VII.A.4, Organization,

Dept. of Social Services States,The Department will Assist in Managing the

Emergency Needs of Special Needs Individuals.Section VII.A.5 Organization, Department of Mental

Health and Mental Retardation, States that theDepartment will Maintain a List of Mentally

Handicapped Persons who Would Require AssistanceDuring a Radiological Emergency. The Procedure forNotifying this Population during an Emergency is not

Included in the RERP

NUREG-0654 Evaluation Criterion E.5 and J. 10.cCaroline County RERP, Appendix 8, ESF #8 - Public

Health ProcedureDoes not Include Procedure in the RERP for

Identifying Special Needs Populations who are notInstitutionalized

NUREG-0654 Evaluation Criterion E.5 and J. 10.cCaroline County RERP, Section VII.A.4

Organization, Appendix 8, ESF #8The Procedure for Notifying Special Needs

Populations within the 10-Mile EPZ During anEmercencv are not Included in the RERP

Louisa County

Louisa County

Caroline County

Caroline County


RAI Number I Open Item Description I State/County I/County 2

NA 004 C. 1

NA 004 C.2

NA 004 D.1

NA 004 D.2

NA 004.E. I

NA 004.E.2

NUREG-0654 Evaluation Criterion E.5 and J.10.cHanover County RERP, Appendix 8, ESF #8, Public

Health ProcedureDoes not Include Procedure in the RERP for

Identifying Special Needs Populations who are notInstitutionalized

NUREG-0654 Evaluation Criterion.E.5 and J.10.cHanover County RERP, Section VII.A.4, Appendix 8,

ESF #8The Procedure for Notifying Special Needs

Populations within the 10-Mile EPZ During anEmergency are not Included in the RERP

NUREG-0654 Evaluation Criterion E.5 and J. 10.cOrange County RERP, Appendix 8

Does not Include Procedure in the RERP forIdentifying Special Needs Populations who are not

Institutionalized

NUREG-0654 Evaluation Criterion E.5 and J. I0.cHanover County RERP, Section VII.A.5

The Procedure for Notifying Special NeedsPopulations within the 10-Mile EPZ During an

Emergency are not Included in the RERP

NUREG-0654 Evaluation Criterion E.5 and J. I0.cSpotsylvania County RERP, Appendix 8, ESF #8

Does not Include Procedure in the RERP forIdentifying Special Needs Populations who are not

Institutionalized

NUREG-0654 Evaluation Criterion E.5 and J. I0.cSpotsylvania County RERP, Section VII.A.4,

Appendix 8, ESF #8The Procedure for Notifying Special Needs

Populations within the 10-Mile EPZ During anEmergency are not Included in the RERP

Hanover County

Hanover County

Orange County

Orange County

Spotsylvania County

SpotsylvaniaCounty

NA 006 A NUREG-0654 Evaluation Criterion E.7 and J. 10.cThe COVRERP, Appendix 8, Potassium Iodide (KI)Administration, states that protective action decisions

regarding KI will be transmitted to the localGovernment Emergency Operations Centers and

broadcast to the general public using the EmergencyAlert System (EAS). It further states that VDEM willcoordinate news releases with VDH about KI and thatthe PIO will issue news releases regarding the use of

KI. None of the pre-scripted messages (either EAS ornews releases) found in Annex M, Public

Information, address the use of or distribution of KI.The County RERPs do contain sample news releaseswith this information. Provide pre-scripted messages,

(both EAS and news release) in the COVERERPabout the use of and distribution of KI.




NA 011 A NUREG-0654 Evaluation Criterion H.4 Louisa CountyThe Louisa County RERP, Appendix 1, Emergency

Management ESF Procedures, states that uponopening an Evacuation Assembly Center (EAC), the

EOC is to notify all appropriate persons andorganizations. Appendix 3, Mass Care ESF.

Procedures, says that the EAC Supervisor is to notifyEAC staff. The notification procedures are not

specified, nor are the staffing organizations prior tothe required positions. Provide notification and

activation information for the EACs.

NA 011 B Same as RAI 011 A Caroline County

NA 011 C Same as RAI 011 A Hanover County

NA 011 D 'Same as RAI 011 A Orange County

NA 011 E Same as RAI 011 A Spotsylvania County

NA 013 A NUREG-0654 Evaluation Criterion H. 11 Commonwealth of VirginiaThe Commonwealth of Virginia RERP, Appendix 7,Tab E, Radiological Exposure Control, RadiologicalMonitoring Equipment Issued to Local Governments,lists the quantities of thermo luminescent dosimeters,

self-reading dosimeters, survey meters, and portalmonitors in each local jurisdiction. There is no

information about protective equipment,communications equipment, or emergency supplies.

Provide information on emergency equipment

NA 013 B Same As RAI 013 A Louisa County

NA 013 C Same As RAI 013 A Caroline County

NA 013 D Same As RAI 013 A Hanover County

NA 013 E Same As RAI 013 A Orange County

NA 013 F Same As RAI 013 A Spotsylvania CountyNA 014 A NUREG-0654 Evaluation Criterion 1.8 Commonwealth of Virginia

Field Monitoring TeamsThe Virginia Department of Health/Division of

Radiological ERP, Appendix 1, TaskProvide specific field monitoring procedures,including activation, notification means, field

team composition, transportation,communication, monitoring equipment and

estimated deployment times.

Interim Findings Report For Open Items (North Anna Power Station) -11 I-


NA 015 A NUREG-0654 Evaluation Criterion 1.9 Commonwealth of VirginiaAir Sampling Procedures

The COVRERP, Appendix 6, Accident Assessment,and Virginia Department of Health/Division of

Radiological Health (VDH/DRH) ERP, Appendix 5,Accident Assessment Provide specific field

monitoring procedures for air sampling that ensurethe capability to detect radioiodine at the required

levelNA 016 A NUREG-0654 Evaluation Criterion 1. 10 Commonwealth of Virginia

Dose AssessmentThe Virginia Department of Health/Division of

Radiological Health (VDH/DRH) ERP,Appendix 5, Accident Assessment

VDH/DRH personnel.No procedures for estimating integrated dose from the

projected and actual dose rates and for comparingthese estimates with the protective action guides were

provided for review. Provide procedures for doseassessment and EPA PAG comparisons

NA 017 A.1 NUREG-0654 Evaluation Criterion J.2 Commonwealth of VirginiaOnsite Personnel Evacuation AssistanceThe Commonwealth of Virginia RERP,

Appendix 5 Emergency ResponseProvide information on the

assistance that will be provided to NAPS duringan onsite evacuation

NA 017 A.2 NUREG-0654 Evaluation Criterion J.2 Commonwealth of VirginiaOnsite Personnel Evacuation Assistance

The Commonwealth of Virginia RERP,Appendix 5 Emergency Provide

information identifying the remote assemblycenters

NA 017 B. 1 NUREG-0654 Evaluation Criterion J.2 Louisa CountyProvide information on the assistance that will be

provided to NAPS during an onsiteevacuation

NA 017 B.2 NUREG-0654 Evaluation Criterion J.2 Louisa CountyProvide information identifying the remote

assembly centers

Interim Findings Report For Open Items (North Anna Power Station) - 12-


NA 018 A.1 NUREG-0654 Evaluation Criterion J.9 Commonwealth of VirginiaProtective Action Basis and Capability to Implement

The plans do not contain predetermined publicProtective Action Decisions (PADs) based on

Plant conditions. Provide information onpredetermined (PADs) based on plant

Conditions

NA 018 A.2 NUREG-0654 Evaluation Criterion J.9 Commonwealth of VirginiaProvide ingestion pathway decision-making

information including the title of theperson making decisions and what organization

will implement those decisions

NA 018 A.3 NUREG-0654 Evaluation Criterion J.9 Commonwealth of Virginia

COVRERP, Attachment 1, Supporting Plans,

Memoranda of Understanding; StandingOperating Procedures, and Public Affairs.

Publications, lists local governmentingestion pathway RERP plans as supporting

plans and directs the reader to Appendix 3,Tab E. There is no

Appendix 3, Tab E. Provide information prior tothe local government ingestion pathway

RERP plansNA 019 A.1 NUREG-0654 Evaluation Criterion J. 10.a Commonwealth of Virginia

The COVRERP, Appendix 5, Emergency Response,provides a map showing "Protective Action Zones"

(PAZs) around North Anna Power Station. However,the RERP does not include maps showing pre-

selected radiological sampling and monitoring points(including points for sampling water supplies), or thelocations of Evacuation Assembly Centers. Provide

maps showing pre-selected radiological sampling andmonitoring points (including points for. samplingwater supplies); and the locations of Evacuation

Assembly Centers

NA 019 A.2 NUREG-0654 Evaluation Criterion J. I0.a Commonwealth of VirginiaThe maps of evacuation routes and PAZs do not

clearly identify evacuation direction, roads, towns, orspecial facilities (such as schools). Provide

information that clearly identifies evacuationdirection, roads, towns, and special facilities on maps


RAI Number I Open Item Description { State/County I/County 2

NA 019 B.1

NA 019 C

NA 019 D

NA 019 E

NA 019 F

NUREG-0654 Evaluation Criterion J.10.aThe Louisa County RERP, Appendix 3, Mass CareESF Procedure, does not have the road names and

other details in the emergency public bus route mapslarge enough to be legible. Provide emergency

public bus route maps with road names and otherdetails that are large enough to be legible

NUREG-0654 Evaluation Criterion J.10.aThe Caroline County RERP does not include mapsspecifying the locations of Evacuation Assembly

Centers and does not clearly identify towns or specialfacilities. Provide maps specifying the locations of

Evacuation Assembly Centers and clearly identifyingtowns and special facilities

NUREG-0654 Evaluation Criterion J. 10.aThe Hanover County RERP does not include mapsspecifying the locations of Evacuation Assembly

Centers and does not clearly identify towns o'r specialfacilities. Provide maps specifying the locations of

EvacuationAssembly Centers and clearly identifyingtowns and special facilities

NUREG-0654 Evaluation Criterion J.10.aThe Orange County RERP does not include mapsspecifying the locations of Evacuation Assembly

Centers and does not clearly identify towns or specialfacilities. Provide maps specifying the locations of

Evacuation Assembly Centers and clearly identifyingtowns and special facilities

NUREG-0654 Evaluation Criterion J.10.aThe Spotsylvania County RERP does not include

maps specifying the locations of EvacuationAssembly Centers and does not clearly identify towns

or special facilities. Provide maps specifying thelocations of Evacuation Assembly Centers and clearly

identifying towns and special facilities

Louisa County

Caroline County

Hanover County

Orange County

Spotsylvania County

NA 023 A.1 NUREG-0654 Evaluation Criterion J. 10.fThe COVRERP, Appendix 8, Potassium Iodide (KI)

Administration, states that the State HealthCommissioner may recommend or advise KI to be

ingested by the general public and emergencyworkers when a dose assessment predicts a thyroid

exposure threshold of 5 rem or if an actualmeasurement of 5 rem is obtained offsite. In otherparts of the COVRERP, the threshold is incorrectly

listed as "25 rem CDE (thyroid)." Provide the correctthreshold (5 rem CDE, Thyroid) prior to therecommended ingestion of KI throughout the

COVRERP


Interim Findings Report For Open Items (North Anna Power Station) - 14-


NA 023 A.2 NUREG-0654 Evaluation Criterion J. I0 f Commonwealth of VirginiaThe Virginia Department of Health/Division of

Radiological Health ERP lists the administration ofKI dose limit for emergency workers as 5 rem CDE

thyroid in some locations and as 25 rem CDE thyroidin others. Provide the correct threshold (5 rem CDE,Thyroid) prior to the recommended ingestion of KI

throughout the plan

NA 023 B NUREG-0654 Evaluation Criterion J. I0.f Louisa CountyProvide the correct threshold

(5 rem CDE, Thyroid) prior to the recommendedingestion of KI throughout the plan

NA 023 C SAME AS RAI 023 B Caroline County

NA 023 D SAME AS RAI 023 B Hanover County

NA 023 E SAME AS RAI 023 B Orange County

NA 023 F SAME AS RAI 023 B Spotsylvania CountyNA 024 A N-UREG-0654 Evaluation Criterion J. I0.g Louisa County

"Means of Relocation"Provide information for determining the number ofpersons who may need assistance for each planning

area and provide updated information on thepermanent resident population data

NA 024 B SAME AS RAI 024 A Caroline County

NA 024 C SAME AS RAI 024 A Hanover County

NA 024 D SAME AS RAI 024 A Orange County

NA 024 E SAME AS RAI 024 A Spotsylvania CountyNA 025 B NUREG-0654 Evaluation Criterion J. I0.h Louisa County

Louisa County RERP, Section V.D, Situation,Protection Against the Hazard, Provide informationprior to the EAC address, capacity, and accessibility

NA 025 C NUREG-0654 Evaluation Criterion J.10.h Caroline CountyThe plan does not provide the addresses prior to theEACs, the capacities, and if they are accessible toindividuals with disabilities. Provide information

prior to the EAC address, capacities, and accessibility

NA 025 D NUREG-0654 Evaluation Criterion J. 10.h Hanover CountyThe plan does not provide the addresses prior to the

EACs, the capacities, and if they are accessible toindividuals with disabilities. Provide information

prior to the EAC address, capacities, and accessibility



NA 025 E. I NUREG-0654 Evaluation Criterion J.10.h Orange CountyThe plan does not provide the address prior to the

EAC, the capacity, and if it is accessible toindividuals with disabilities. Provide information

prior to the EAC address, capacity, and accessibility

NA 025 E.2 NUREG-0654 Evaluation Criterion J.10.h Orange CountyThis is not consistent with the State Plan which alsolists Orange County High School as an EAC prior to

the county and Patrick Henry High School in HanoverCounty as the host reception center for Louisa

County. Provide information identifying all EACsand host reception centers within the county

NA 025 F NUREG-0654 Evaluation Criterion J. 10.h Spotsylvania CountyThe plan does not provide the addresses prior to the

EACs, the capacities, and if they are accessibleindividuals with disabilities. Provide information

prior to the EACs addresses, capacities, andaccessibility

NA 026 A NUREG-0654 Evaluation Criterion J.10.i Commonwealth of Virginia"Evacuation Route Traffic Capacity"

Provide updated information in the plan toincorporate the revised ETE study and evaluatefactors that might limit the capability to effect a

timely, safe evacuation

NA 026 B NUREG-0654 Evaluation Criterion J. 10.i Louisa CountyProvide updated information in the plan to

incorporate the revised ETE study, including updatedcounty evacuation route maps, and evaluate factors

that might limit the capability to effect a timely, safeevacuation



NA 026 C NUREG-0654 Evaluation Criterion J. 10.i Caroline CountyProvide updated information in the plan to incorporate therevised ETE study, including updated county evacuation

route maps, and evaluate factors that might limit thecapability to effect a timely, safe evacuation

NA 026 D NUJREG-0654 Evaluation Criterion J.l0.i Hanover CountyProvide updated information in the plan to incorporate therevised ETE study, including updated county evacuation


NA 026 E NUREG-0654 Evaluation Criterion J. 10.i Orange CountyProvide updated information in the plan to incorporate therevised ETE study, including updated county evacuation


NA 026 F NUREG-0654 Evaluation Criterion J. 10.i Spotsylvania CountyProvide updated information in the plan to incorporate therevised ETE study, including updated county evacuation


NA 027 A NUREG-0654 Evaluation Criterion J.10.k Louisa County"Evacuation Route Impediments"

Provide information referencing the resources available tobe used in clearing impediments

NA 027 B SAME AS RAI 027A Caroline County

NA 027 C SAME AS RAI 027A Hanover County

NA 027 D SAME AS RAI 027A Orange County

NA 027 E SAME AS RAI 027A Spotsylvania County



NA 028 A NUREG-0654 Evaluation Criterion J.10.1 Commonwealth of Virginia"Evacuation Route Time Estimates"

Provide updated information incorporating the new ETEstudy including revised population data and separate time

estimates prior to the special population groups

NA 028 B SAME AS RAI 028 A Louisa County

NA 028 C SAME AS RAI 028 A Caroline County

SAME AS RAI 028 ANA 028 D Hanover County

NA 028 E SAME AS RAI 028 A Orange County

NA 028 F SAME AS RAI 028 A Spotsylvania CountyNA 029 A.1 NUREG-0654 Evaluation Criterion J. 11 Commonwealth of Virginia

"Ingestion Pathway Protective Measures"The COVRERP does not contain the following: the

criteria for putting animals on stored feed; theidentification and description of procedures for detecting

contamination, for estimating the dose commitmentconsequences from the ingestion pathway and for

imposing protective measures; and maps showing generalcrop information, farms, dairies, food processing plants,watershed, water supply intake and treatment plants and

reservoirsNA 030 A NIUREG-0654 Evaluation Criterion J. 12 Louisa County

"Evacuee Monitoring and Registration"Provide information showing the portal monitoring

operability check complies with the standard

NA 030 B Caroline CountySAME AS RAI 030 A



NA 030 E SAME AS RAI 030 A Spotsylvania County


AAI Number Open Item Description State/County 1/County 2

NA 031 A

NA 031 A.2

NA 031 B

NA 031 C

NA 031 D

NA 031 E

NA 031 F

NUREG-0654 Evaluation Criterion K.3.aThe Virginia Department of Health/Division of

Radiological Health (VDH/DRH) ERP, Appendix 6,Radiological Exposure Control, lists the correct

Emergency Worker Exposure Limits in step 2. 1, butthen refers to incorrect limits in step 2.4. The

VDH/DRH ERP lists the exposure control ratio asinitially 2

Provide revisions to all sections of the plans to ensurethat all instances of the administrative exposure limitsare correct and that the appropriate exposure or doseunits and exposure control ratios are used throughout

the plans

NUREG-0654 Evaluation Criterion K.3.aThe Commonwealth of Virginia RERP, Tab B2 to

Appendix 7, Radiological Exposure Control, lists thecorrect administrative exposure limits. Tab G to

Appendix 7 lists incorrect limits. In addition, Tab B2to Appendix 7 incorrectly lists the "EPA Protective-Action Guidelines, Emergency Worker Exposure

Limits." Provide revisions to all sections of the plansto ensure that all instances of the administrative

exposure limits are correct and that the appropriateexposure or dose units and exposure control ratios are

used throughout the plans

SAME AS RAI 031 A.2

SAME AS RAI 031 A.2

SAME AS RAI 031 A.2

SAME AS RAI 031 A.2

SAME AS RAI 031 A.2



Louisa County

Caroline County

Hanover County

Orange County

Spotsylvania CountyNA 032 A

NA 032 B.1

NA 032 C. I

NA 032 D. I

NA 032 E.1

NA 032 F.1

NUREG-0654 Evaluation Criterion K.4"'Emergency Worker Dose Authorization"

There are numerous inconsistencies throughout the plans inexposure limits, exposure control ratios, and radiation units

[exposure (R) and dose (Rem)] as detailed in CriterionK.3.a. Provide information about the procedure to

authorize high exposure limits to emergency workers

SAME AS RAI 032 A

SAME AS RAI 032 A

SAME AS RAI 032 A

SAME AS RAI 032 A

SAME AS RAI 032 A


Louisa County

Caroline County

Hanover County

Orange County

Spotsvlvania County



NA 033 A NUREG-0654 Evaluation Criterion K.5.a Louisa County"Decontamination Action Levels"

Provide information on monitoring the interior ofemergency vehicles




NA 033 E SAME AS RAI 033A Spotsylvania CountyNA 034 A.1 NUREG-0654 Evaluation Criterion K.5.b Louisa County

"Decontamination Material Control"Provide information on secured storage areas for

contaminated equipment

NA 034 A.2 NUREG-0654 Evaluation Criterion K.5.b Louisa CountyProvide information on the doffing of personal

protective clothing prior to the initial monitoring

NA 034 B. I SAME AS RAI 034 A. 1 Caroline County

NA 034 B.2 SAME AS RAI 034 A.2 Caroline County

NA 034 C. 1 SAME AS RAI 034 A. 1 Hanover County

NA 034 C.2 SAME AS RAI 034 A.2 Hanover County

NA 034 D.1 SAME AS RAI 034 A.lI Orange County

NA 034 D.2 SAME AS RAI 034 A.2 Orange County

NA 034 E.1 SAME AS RAI 034 A.2 Spotsylvania County

NA 034 E.2 SAME AS RAI 034 A.2 Spotsylvania CountyNA 035 B NUREG-0654 Evaluation Criterion L. 1 Louisa County

Provide information identifying the primary andback-up hospitals and support information

demonstrating that they have the capability forevaluation of radiation exposure and uptake,

including assurance that persons providing theseservices are adequately prepared to handle

contaminated individuals.


Interim Findings Report For Open Items (North Anna Power Station). - 20 -




NA 035 F SAME AS RAI 035 B Spotsylvania CountyNA 036 A NUREG-0654 Evaluation Criterion L.3 Commonwealth of Virginia

"Medical Services for Contaminated/InjuredPatients"

Provide relevant information prior to the list ofadditional hospitals including qualifications to handle

contaminated injured patients, equipment forradiological response capabilities, specific locations,and capacities for ambulatory and non-ambulatory

individuals.

NA 037 A NUREG-0654 Evaluation Criterion L.3 Louisa CountyProvide information about the transport of

contaminated injured members of the public.




NA 037 E SAME AS RAI 037 A Spotsylvania CountyNA 038 A.1 NUREG-0654 Evaluation Criterion M. 1 Commonwealth of Virginia

"Recovery and Reentry Procedures"Provide information for relocating persons that were

not evacuated but may be in contaminated areas.

NA 038 A.2 NUREG-0654 Evaluation Criterion M. I Commonwealth of VirginiaAppendix 11, Decontamination, Re-Entry, Return andRecovery, states the VDH dose levels for determiningthe need to relocate populations which is contrary toFederal guidance (EPA 400-R-92-001 states that the50 year committed dose includes the first and second

year whereas the stated dose in the COVRERPexcludes the first and second years). Provide correct

information on the dose levels for determining theneed to relocate populations.

NA 038 A.3 NUREG-0654 Evaluation Criterion M. 1 Commonwealth of VirginiaAppendix 11, Decontamination, Re-Entry, Return and

Recovery, states that the decision to allow re-entryand return of evacuated individuals rests with the

Director of Emergency Services of the localjurisdiction affected. However, there are no decision-making procedures identified in any county plan thataddress allowing evacuated persons or households to

permanently return to an evacuation area. Provideinformation addressing procedures for evacuated

persons to permanently return to an evacuated area.



NA 038 B NUREG-0654 Evaluation Criterion M. 1 Louisa CountyThe Louisa County RERP does not include anyinformation about reentry and return. Provide

information consistent with the COVRERP Appendix11, Decontamination, Re-Entry, Return and

Recovery, which states that the decision to allow re-entry and return of evacuated individuals rests with

the Director of Emergency Services of the localjurisdiction affected.


NA 038D SAME AS RAI 038 B Hanover County


NA 038 F SAME AS RAI 038 B Sp6tsylvania County

NA 039 A NUREG-0654 Evaluation Criterion M.3 Commonwealth of Virginia"Recovery Operations Notifications"

The COVRERP, Appendix 6, Accident Assessment,states that offsite emergency operations will becoordinated from the Virginia EOC. Provide

information specifying the means that will be used tokeep all involved response organizations informed of

the recovery phase activities or changes that mighttake place in the organizational structure.

NA 041 A.1 NUREG-0654 Evaluation Criterion N.2.a Commonwealth of Virginia"Communications Drills"

The Commonwealth of Virginia RERP, Appendix 13,Provide. information on which is the appropriate

frequency of communications drills.

NA 041 A.2 NUREG-0654 Evaluation Criterion N.2.a Commonwealth of VirginiaThe COVRERP does not specify a mechanism to

ensure that the content of the message is understood.Provide a mechanism to ensure that the content of themessage is understood during communications drills.

NA 041 B.1 NUREG-0654 Evaluation Criterion N.2.a Louisa CountyThe Louisa County RERP, Section XII, Training,

Drills, and Exercises, states that monthly drills willcheck the systems used for communications betweenState and local governments which is different thanthe daily drills specified in the Commonwealth of

Virginia RERP. Provide information on which is theappropriate frequency of communications drills.

NA 041 B.2 NUREG-0654 Evaluation Criterion N.2.a Louisa CountyThe Louisa County RERP does not specify a

mechanism to ensure that the content of the messageis understood, Provide a mechanism to ensure that

the content of the message is understood duringcommunications drills.



NA 041 C. 1 SAME AS RAI 041 BA I Caroline County

NA 041 C.2 SAME AS RAI 041 B.2 Caroline County

NA 041 D.I SAME AS RAI 041 B.1 Hanover County

NA 041 D.2 SAME AS RAI 041 B.2 Hanover County

NA 041 E.1 SAME AS RAI 041 B.1 Orange County

NA 041 E.2 SAME AS RAI 041 B.2 Orange County

NA 041 F. 1 SAME AS RAI 041 B. 1 Spotsylvania County

NA 041 F.2 SAME AS RAI 041 B.2 Spotsylvania CountyNA 042 A NUREG-0654 Evaluation Criterion N.2.c Louisa County

"Local Jurisdiction Participation in Medical EmergencyDrills"

The Louisa County RERP does not includinginformation on the conduct of medical emergency

drills and participation of local emergency responseorganizations for transport of contaminated injured

individuals (members of the public, not licenseeemployees). Provide information about the

participation of Louisa County medical transport

NA 042 B providers in the annual medical emergency drills Caroline County



NA 042 E SAME AS RAI 042 A Spotsylvania County

SAME AS RAI 042 A



NA 043 A NUREG-0654 Evaluation Criterion N.5 Commonwealth of Virginia"Implementing Corrective Actions Identified at Drills

and Exercises"The Commonwealth of Virginia RERP, Appendix 13,

Training and Exercises, states the recommendedcorrective actions from drills and exercises will be

implemented; however, the details of this process arenot given. Provide information on the managementcontrol that has been established to ensure corrective

actions are implemented.

NA 043 B SAME AS RAI 043 A Louisa County

NA 043 C SAME AS RAI 043 A Caroline County

NA 043 D SAME AS RAI 043 A Hanover County

NA 043 E SAME AS RAI 043 A Orange County

NA 043 F SAME AS RAI 043 A Spotsylvania CountyNA 046 A NUREG-0654 Evaluation Criterion P. 1 Commonwealth of Virginia

"Training Requirement for Individuals Responsiblefor the Planning Effort"

The COVRERP, Appendix 13, Section II.E.5,Training and Exercises, Operational Concepts and

Procedures, Training, states that "Key planners willbe sent to the Radiological Emergency Planning

Course at the Emergency Management Institute."Key planners within the State Agencies are notidentified. Provide information about the keyplanners within the State Agencies that will be

provided the appropriate training.



NA 046 B NUREG-0654 Evaluation Criterion P. 1 Commonwealth of VirginiaProvide information on the identification of the "keyplanner" and what training that person will receive

NA 046 C Same as RAI 046 B Commonwealth of Virginia

NA 046 D Same as RAI 046 B Commonwealth of Virginia

NA 046 E Same as RAI 046 B Commonwealth of Virginia

NA 046 F Same as RAI 046 B Commonwealth of VirginiaNA 047 B NUREG-0654 Evaluation Criterion P.4 Louisa County

Provide information on how identified issues areincorporated into the update of the plans.

NA 047 C Same as RAI 047 B Caroline County

NA 047 D Same as RAI 047 B Hanover County

NA 047 E Same as RAI 047 B Orange County

NA 047 F Same as RAI 047 B Spotsylvania CountyNA 050 B NUREG-0654 Evaluation Criterion P.7 Louisa County

The Louisa County RERP, Table of Contents andSection XIV, Appendices, provide a listing of

Appendices which contain implementing proceduresidentified by emergency support function. It is not acomplete list since some procedures have references

to additional procedures. The list does not include thesection(s) of the plan to be implemented by each

procedure. Provide information on which section(s)

of the plan are implemented by the procedures.




NA 050 F SAME AS RAI 050 B Spotsylvania County

NA 051 A.1 NUREG-0654 Evaluation Criterion P.8 Commonwealth of VirginiaThe Commonwealth of Virginia RERP contains both

a Table of Contents and a NUREG-0654 CrossReference. The Table of Contents is thorough and

accurate. The NUREG-0654 Cross Reference has areference for almost every applicable criterion;however, it does not provide specific reference

information to enable easy location of informationwithin the plan for some criteria (for example, A. .d,

A.2.b, and H.3 just reference "Basic Plan"). TheNUREG-0654 Cross Reference is riddled with errors(see report by criterion). Provide an accurate, specific

NUREG-0654 Cross Reference.

Interim.Findings Report For Open Items (North Anna Power Station) - 25 -


NA 051 B NUREG-0654 Evaluation Criterion P.8 Louisa CountyThe Louisa County RERP contains both a Table of

Contents and a NUREG-0654 Cross Reference. TheNUREG-0654 Cross Reference is riddled with errors(see report by criterion). Provide an accurate, specific

NUREG-0654 Cross Reference.




NA 051 F SAME AS RAI 051 B Spotsylvania CountyNA 052 A NUREG-0654 Evaluation Criterion P. 10 Commonwealth of Virginia

"Updating of Telephone Numbers, Call-Down Lists,and Maps"

The COVRERP, Section IX.B, Responsibilities,Attachment 1 There is no mention of updating call-

down lists or maps as required by GuidanceMemorandum PR-i, Policy on NUREG-0654/FEMA-

REP-i and 44 CFR 350 Periodic Requirements,October 1, 1985. Provide information on thequarterly update of call-down lists and maps.

NA 052 B NUREG-0654 Evaluation Criterion P. 10 Louisa CountyThe Louisa County RERP, Section X,

Responsibilities, states that the Coordinator ofEmergency Services is responsible for the quarterlyupdate of the telephone numbers in the procedures.There is no mention of updating call-down lists or

maps. Provide information on the quarterly updateof call-down lists and maps.




NA 052 F SAME AS RAI 052 B Spotsylvania County"


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