IR 05000003/1974005
| ML20050C978 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/24/1974 |
| From: | Gallina C, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050C970 | List: |
| References | |
| 50-003-74-05, 50-247-74-08, 50-247-74-8, 50-286-74-08, 50-286-74-8, 50-3-74-5, NUDOCS 8204090463 | |
| Download: ML20050C978 (31) | |
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I U. S. ATO!:IC E:: RGY C0:0:ISSIO::
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DI!!ECIOR.JS OF REGUU$ TORY CP,ER.'T!O::S
PIGIO:: I
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50-3
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50-247 s
I 50-03/74-05 j
no Inspection Report ::c. :
30-2'7/74-OS & 30-2S6/74-OS Docket o.: 50-:S6
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D"h'??NE DPR-5*
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Consolidated Edisen Cc:pany of :;ew York (CE)
License No.:
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Licensec:
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4 Irvine Place Priority:
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New York. New York 10003 Category: Unit 1: C l
Unit 2 : 3
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Unit 3 : 3
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Indian Point Nuclear Generating Facility Units 1,263 (IP)
i Location:
Unit 1: PWA (35W) 290 M'.la Unit 2: PIR (W)
873 >Rie Type of Licensec: Unit 3: Pt.7. (U)
1050 M'.?c
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Routino. !.nnounced (CT.crgency Planning)
. Type of Inspection:
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DatesofInspI2ction:
Ahril 29 - May 3 and d'ay 13, 1974
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Dates of Previous I;tspection:
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.I Reporting Inspector:
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Date C. O. Gallina, Ph.D., Radiation Specialist
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Accompanying Inspectors:
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[P. Stohr, Senior Environmental Scientist
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, Other Accompanying Personnel:
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, Reviewed By:
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J.P./Stohr, Chief,Enviren..catalProtectionand Date
Special Programs Section
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0204090463 740624 PDR ADOCK 05000003 O
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4 SITf.i'.RY OF PIMDINGS
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Enforceo'nt Acticn
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The following itens were found'to be apparent violations of the Indian Point Unit No. 2 Technical Specifications, Section 6.11, "Eccrgency Plans"
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i and Section 5.6, Supple =ent 5 of the subject facility (IP-2) FSAR.
1.
Co:cunication Checks were not performed as required between the central control room and (a) the CE Energy Control Center and (b)
Emergency Survey vehicles.
(Report Details, Paragraph 4)
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Emergency Training exercises were not conducted on a semi-annual basis-as required.
(Report Details, Paragraph 7)
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Appropriate emergency training had not been administered to E=crgency Directors and general uatch foremen.
(Report Details, Paragraph 6)
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Licensee Action on Previous 1v Identified Enforcement Items (Emercenev Plannine)
Nonc identificd
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i Design Chances
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None Unusual Occurrences
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Other Sienificant Findings (Emergency Plannine)
A.
Current Findings Three apparent violations with respect to IP-2 Technical'Specifi-cations were identified during the inspection. -(Report Details, Paragraphs 4, 6 & 7)
B.
Unresolved Items None l
l Manacenent Interview A canagement =ceting was held in the of fice of the "anager of the Nuclear Power Generation Departnent at the Indian Point Nuclear Generating facility on Iby 3,19/4, fc11outnq the conclusion of the inspection at the site.
The following individuals were in attendance:
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Dr. C. G. Gallina, Radiatir:n Speciali t, /. C-RO:I Mi. U. Stein, ".m gar, '.u:12 : "ov.tr C: wration Departmant, CE Fr. R.' '?. Van'.!' ck, "anar;er, ::uciant Snvice., C7 Ir. S. G. Salay, Ch::: Operrtiens Eo:.iracr. CE Mr. A. S. Cho tie:te, 'irecter, Padi'<tir, Saf;ty, CE
".r. G. F. Lieb] er, :'.adialt ical Enti-cur, CE Mr. U. rcrreira, Quality. s;arance 6n';ineer, CE In addition, ":. U. J. Cahill, Jr., Vice President, Mr. P. Zarakas, Vice and Mr. R. U. Van'..jck, Mana;;cr of : uclear Services ware con-President, tactea by telephone on May 7, 8, and 9, 1974 to further clarify issues interview.
identified during the inspection and subsequent nanagement the Indian Point Nuclear An additional managonant meeting was held at Gcncratin;; facility on : ay 13, 1974 The following individuals were in attendance:
AEC-RO:I Dr..C. O. Gallina, Radiation Specialic.t, Mr. J. P. Stohr, Senior Environmcatal Scientist, AEC-RO:I CE Mr. U. J. Cahill, Jr., Vice President,
Mr. P. Zarakas, Vice President, CE CE Mr. U. Stein, Manager, Nuclear Power Generation Department, Dr. T. J. Doyle, Assistant Vice President-:ledical, CE CE Mr. 5. Dimassie, Medical Department, Mr. R. W. VaaWyck, Manager, Nuclear Services, CE S. G. Salay, Chief Operatins Engineer, CE Mr.
Mr. A. S. Cheifetz, Director, Radiation Safety, CE During the abeve referenced ccetings and telephone conversations the follouing itens were discussed:
A.
Emercency Innlementation Procedures Emergency Implenentation Procedures would be The licensee stated that reviewed and upgraded where applicable so as'to provide a specific predetermined criteria for utilization in the declaration of various In addition *, the licensee would provide speci-l classes of emergencies.
fic action to be follo: ed in response to potential energency situations l
at the IP site.
The licencee stated that the criteria would also be evaluated frem the standpoint of insuring that a smooth transition would be provided between escalating response icvels froa the " local" to the " general" emergency.
The licensee also stated that procedures would be developed to provide for the revice of the Emergency Plan and (Report I
associated implementation procedures on a routine basis.
l Details, Paragraph 3)
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The licensee stated.that an evaluatitn had been initiated in the area of communicaticas.in order to deteraine (a) the number of radios re-quired to fully implorant the IP Fmargency Plan and (b)- insure that the communications Jcvices procured would be adequate in tcrns,cf ranga
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and convenient utilizatien.
The liccr.sce stated that these additional
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units would be obtaineu as 'scon as the aforementioned evaluation was
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completed.
The inspector stated that in reviewing checks of communication sys-tems as required by Section 12.0.3 of the IP Emergency Plan, that a violation was identified in that required checks were not made on a i
ucekly basis between a licensed reactor operater and.the CE Energy Control Center.
In addition, the inspector stated that similar commun-ications checks between the control rcom and two emergency survey
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vehicles had not been performed.
The licensee stated that incr eased cmphasis would be placed on the performance of these communications-i checks in the future with appropriate documentation.
(Report Details, Paragraph 4)
C.
Emercency Alarms The licenscc stated that an evaluation was continuing following
recent changes ~in emergency alarms, to insure that alarms and asso-ciated messages broadcast over the public address system could be heard.
and understood by all personnel at the IP site.
The licensee stated further that required modifications and upgrading would be made'sub--
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sequent to the completion of this evaluation and that for the interin time period, procedures would be developed to insure-proper notification to all affected personnel.-
(Report Details, Paragraph 5)-
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Emercenev Training The inspector noted that a violation had been identified with respect
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to Section 12.0.2 of the IP Emergency Plan in that adequate training had not been given to those individucals acting as Emergency Directors i
under emergency conditions.
The inspector did note, however, that this l
violation was corrected on an interin basis during the course of the inspection by intensive training provided by the licensce to designated l.
Emergency Directors and general watch foremen who act as interi= Emer-gency Directors.
The licensee stated further that although this train-i ing was interin, that a detailed training program would be developed i
and implemented as soon as possible to insure all individuals received proper training with specified periodic retraining.
(Repor t De tails,
Paragraph 6)
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E~ errancy Trainin Exercise _
The inspector acted that a violation had bebn identified with respect to Section 12.0.1 cf the IP Eneracacy Plan in that internal practice exerciscs had not been perforned en a semi-annual basis as recuired.
The licersee stated that this natter would be revieued and corrected as soon as pessible.
The licen:ne also stated that procedures would be developed to cover the planning, execution, review and docu:entation of future drills and that a major training encrcise incorporating as many phases of the overall Energency Plan as applicable would be con-ducted at the IP site prior to the issuance of an operating license to IP Unit 3.
(Report Details, Paragraph 7)
F.
Medical Em.2rcencv Planning The inspector noted that deficiencies had been identified with respect to medical emergency planning at the IP site.
Specifically, the inspecter stated that the "edical E=ergency Plan developed in coordination with New York University "edical Center uas formulatcd in a tentative manner and as such, provided no direct course of action to be followed in the event of a radiation emergency.
The inspector stated further that training exercises had not been conductcd in this area and that = cans had not been provided for the transfer of contaninated patients fro the downtown (NYC) heliport to the treatment facility.
The licensee stated that the CE "edical Director had net with NYU personnel and that the Medical Energency Pirn would be modified as necessary to correct all deficiencies.
With respect to training exerciscs, the licensee stated that due to the cost of utilizing the helicopter transport cap-ability, routine drills in this aren were not feasible.
The licensce l
stated that a mock-up of the helicopter transport area would be con-structed and drills conducted at the site using this training aid.
Following adequate training, a full-scale drill would be conducted utilizing the actual helicopter and put on video tape for use during subsequent training sessions.
From the stahdpoint transfer from the New York City heliport, the licensee stated that procedures were in i
the final stages of development to p3 ovide for transportation to the medical treatment facility utilizing CE echicles located in the city.
The inspector stated further that although no deficiencies were ident-ified with respect to on-site medical treat cnt facilities, that pro-cedures had not been provided in this arca in order to cover medical c=crgency aspects prior to the arrival cf trained medical help. The licensee stated that these procedures would be provided as part of the overall revicw and upgrading of emergency planning at the IP site.
(Report Details, Paragraph 8)
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Er_rce,cy survm M !cle:
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The inspector stated that various deficiencies were identified with respect to energency surNy vehicles currently being utili:ed at the IP site.
Speciitacily, t:w inspector stated tnat vehicles were not identified to ailc-rapid egress frcn the site during an emergency
'and caly one vehicle *:as csuipmant with crer3ency survey equip :nt.
The inspector also questioncd the accountability of these vehicles since radios contained therein were not turned on uhen the vehicles Icft the site for routine surveillance operations.
The licensee stated that the two survey vehicles would be properly equipped with appropriate survey and analysing equipnent and that this equipment would bc =aintained in a condition so that it could be rapidly util-ized in the event of an emargency.
The licensee also stated that in addition to having the vehicles accountable at all times, that add-itional equipment would be placed inside the vehicle to further assist monitoring teams during energency operations.
The licensee stated further that both emergency vehicles would be equipped with a placard (removeable) stating "c:crgency vehicle".
(Report Details, Paragraph 9)
II. Alternate Enerrency Control Center The inspector stated that the current Alternate Emergency Control Center located at the Buchanan Substation would not be acceptable due to its proximity to the primary Energency Control Center both with respect to wind direction and distance.
The licensee stated that the Alternate Emergency Control Center would be trarsferred from t'he Buchanan Substation to a CE substation located in Peekskill, New York.
This new Alternate Emergency Control Center is located in a different down wind direction from the primary center, sufficient to allow its use during energency conditions when the primary center was untenable.
The licensee stated further that this new Alternate Emer-gency Control Center would be equipped with essentially the same c=crgency equipment at the prieary center thereby removing the need for transfer operations should the situation arise.
(Report Details, Paragraph 10)
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Accountine Procedures and Evacuation Plans The inspector stated that various deficiencies had been identified in the area of accounting of plant personnel and overall evacuation plans for the IP site.
The inspector stated specifically that the evacuation of personnel on foot was relatively ti=c consucing but that the pri-mary deficiency was related to the fact that planning had not been provided for the evacuated personnel once they arrived at the Escrgency Control Center.
The licensee stated that this natter would be reviewed and upgraded as soon as possible and that planning modifications would be provided in accordance with the results of this evaluation.
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-6-inary r.'.di'ications to accountin ' precedure-vere provided to the inspector prior to th: cerp!stien of the inspection.
(Report Details,
Paragraph 11)
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Emer" m The insp:c'.or noted that deficiencias aad been identified in the area of er.erpacy of f-sitc monitorir; in that sampling and analysis relatcd to this area vould be cenducted aleest enclusively using
"in-place" e,amplinn locations.
The inspector stated further that uhile it was acceptable to use these monitoring stations as the nuc-Icus for the energency off-site program, that additional stations would be necessary and should be preplanned and evaluated with respect to accescibility and significance. The inapector also noted that spc-cific procedures covering this area vere ninimal and that only one sur-The licea-vey vehicle was provided ':ith appropriate survey equipnent.
plans had been initiated to identify additional off-site see stated that curvey locations for use under emergency conditions and that both off-site emergency survey vehicles were in the process of being fully equipped to conduct all sampline and analysis in the field.
The licensee stated further that appropriate procedures would be provided with this equipment and that plans also had been initiated to augment this equipment uith additienal itens to aid off-site area conitoring teams.
(Report Details, Parascaph 12)
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Plant Vent Radioccm 'Snitor The inspector noted that a deficiency had been identified with respect to the IP Unit No. 1 radiogas nonitor, in that the monitor would be off-scale at concentrations at 'or above 1x10 -3 uCi/cc.
The inspector stated further that under these conditions, the monitor would be off-scale before the significance or extent of the emergency
l could be evaluated. The licenccc stated that this matter had been l
identified earlier and that an evaluation had been initiated in order t
to determine the best method of corrective action. The licensee stated further that the Unit No. 1 radicgas conitor would be modified in sc e manner in order to bring it at a minitun, up to the off-scale reading l
for the IP Unit No. 2 and Unit No. 3 radiogas conitor (0.1 uC1/ce).
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(Report Details, Paragraph 13)
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Area ' tans and Overlavs l
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The inspec or noted that deficicacies had been identified with respect to the area naps and overlays being utiliced at the IP site under c:er-gency conditions.
The inspector stated specifically that in the process l
of photoreduction, the area naps currently planned for use under crer-estimate l
gency cenditions lacked the detail required to provide the best The of radioactive diapernion and related doec rates in effected areas.
licensee stated these maps would be modified and incorporate use of the original topographical caps and that me:eorological overlays would be i
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similarly codified to be utilized in conjunction with these upgraded
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map's.
(Rcport Dutails, Paragraph 14)
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Enr' me.* Envirnmn'.e i "- d t 'rinc
~ The inspector stated that provisions should be available to enable
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the rapid collection and evaluation of all appropriate environmental j
sctpling statione utili cd'cn a routine basis during non-emergency i
conditicas.
The inspector stated that this sampling regime vould i
augment the collection and evaluation of samples taken to determine emission dispersion characteristics.
The licensee stated that the
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aforementioned procedures would be developed as part of_the overall upgrading of the IP E=ergency Plan.
(Report Details, Paragraph 15)
N.
Search and Rescue Procedures
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i The inspector noted that in conjunction with accounting procedures, provisions should be available to provide guidance in the search and rescue operations rhich may be required at the IP site.
The licensee
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stated that th_ afore=entioned search and rescue procedures would be
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developed in order to insure that an effective rescue could be imple-
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mented in the event that' unaccounted for or injured personnel had to f
be located within'.the IP units during an emergency. The licensee-stated further that this process would involve nodification and/or upgrading of current procedures being utilized in this area.
(Report Details, Paragraph 16)
O.
Decisional Aids The inspector discussed with the licensee various aspects of decisional aids which could be utilized during e=crgency conditions to facilitate
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imple=entation of the licensee emergency p]an. The licensee stated
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that these matters would. evaluated and that modifications would be i
provided as appropriate subsequent to this evaluation.
(Report Details, Paragraph 17)
P.
Emergencv Eculonent and Checkout I
l-The inspector noted that deficiencies were identified with respect to emergency equipcent from the standpoint of type, number and availability.
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The-licensee stated that c=ergency_ equipment inventories would be reviewed
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and upgraded where necessary and that specific procedures would be devel-oped to provide for periodic inventories and operational checks of all emergency equipment.
The inspector noted that this upgrading had been initiated prior to the completion of the inspection.
(Report Details, Paragraph 18)
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Lqttern of * ymat
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Thp inspecter eted t.9at in conjunctica witp Medical Ercrgency Planning and injury tr.r.Afor capabilitica, tht.t a lettcr of agree:cnt would be requirca :rer tLa Loltamter transfer organization.
The licensee stnece that "' dical Dir9ctet nad met with representatives of this
" that a draft letter had alreadv been prepared to o r r.:nic a t ion corrce: this deficiency. The inspecter was given a copy of this draft letter.
(Report Details, Paragraph 19)
R.
Waterfrent P L'nn ing The inspector stated that an area had been identified which would require further evaluation on the part of the licensec.
Specifically, the inspector stated that provisions should be included in the E=cr-gency Plan to prevent snall boats from apprcaching the IP site from the lludron River area.
The licensee stated that it was his belief that the Coast Guard and State Police could effectively control this area using helicopters and/or small craft but that this area would be eval-uated further and appropriate codifications taken as necessary.
(Report Details, Paragraph 20)
S.
Securftv Procedures The inspector stated that while the licensee's security plan had been included in the IP Emergency Plan, that specific procedures had not been provided for those actions perforced by security personnel under emergency conditions.
The licensec stated that the entire security plan was going to be rc=oved from the IP Enargency Plan but that specific procedures would be provided to cover emergency responsibil-ities of security personnel.
(Report Details, Paragraph 21)
T.
Eternency Docunentation
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The inspector noted that due to the complexity of the implementation of i
the IP Energency Plan that modifications would be required in the area l
c=crgency documentation.
The inspector stated further that the use of nornal operations logs would not be adequate due to the fact that ener-I gency actions are directed and coordinated from a site (Emergency Control Center) remote froa the central control room.
The licensee I
stated that subscquent to the revision and upgrading of the IP Emergency Plan, methods of emergency documentation such as detailed checklists, log books, etc., would be evaluated.
The licensee stated further that the final method of emergency documentation would be l
l selected following evaluation under c ergency drill conditions.
(Report Details, Paragraph 22)
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On-Site Eclaasa l',t3
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The inspector stared that precedures should.be provided as part of the overall emer;;ency planning pachage for the IP site to cover the contingenq. of purging reactor xntains mt due to hydregen build up.
The inspector staccd further that taa procedures should include variou.s in plant tenitored variables and correlare those variables with predicted off-site doses and air conecatrations.
The licensee stated that this containment ventilatica procedure vould be for=u-lated as part of the overall revice and upgrading process of the IP Emergency Plan.
(Report Details, Paragraph 23)
V.
Meteoroloev The inspector noted that meteorological data was currently being obtained from two sources namely, the 100 ft. and 400 ft. meteorology towers.
The licensee stated that both towers would be in operation
.until a correlation of data could be obtained, at ubich time the 100 ft.
tower uculd be discontinued.
The licensee stated further, however, that the 100 ft. tower would be utiliced until such a time as a telecctering system could be installed on the 400 ft. tower. The licensec stated that this information would ba utilized primarily in the combined Unit 1/2 control roon and could be relayed to the Unit 3 control room via radio or telephone co==unications as necessary.
(P port Details, Paragraph 24)
W.
Toxic Releases The inspector noted that a deficiency had been identified in the area of toxic releases.
Significant amounts of caustic and acid as well as water retreat =cnt chemicals were stored at the IP site and procedures were not availabic to personnel to provide guidance should an accident result in conjunction uith one of these systems.
The licensee stated that the systems themselves would discharge to safe arcas but stated that procedures would be provided in order to give guidance to personnel as to safety precautions and special equip =cnt usage during the implementa, tion of corrective action in these arcas.
(Report Details, Paragraph 25)
X.
Personnel Call List The inspector noted that although personnel call lists had been included in the IP Emergency Plan that they were limited primarily to supervisory personnel.
The licensee stated that supervisory personnel did possess telephena rosters of those individuals under their supervision and that phone logs and listings would be included as separate documents in E=cr-gency Control Centers and appropriate control rooms.
(Report Details, Paragraph 26)
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The ine:cetor stat.td that a &ficienc.e had b.een i.lentified in tiu
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DETATLS
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Perk.cn'.cl Contacted
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Mr. P. Zaraka;, '.' ice Prc e i hnt, CE Mr.
'.7 J. Cah111, Jr., Vice Praidcr.t, CE Mr. W. Stein, "w.cner, :~ucicar Pover Generation Department, CE Dr. T. J. Doyle, Assista.: Vice Presidcat-Medical, CE Mr.
S. Dimassie, "2 dical Departrent, CE Mr. R. W. '.'an'. fck, Manager, Nucleac Services, CE Mr. S. G. Salay, Chief Operations Engineer, CE Mr. A. S. Chelfetz, Director, Radiation Safety, CE Mr. U. Ferreira, Quality Assurance Engineer, CE Mr. F. G. Hertrich, Chief Construction inspector, CE Mr. G. H. Liebler, Radiological Engineer, CE Mr. J. P. Cullen, In-Plant Health Physics Director, CE
& Controls Repair Engineer, CE Mr. R. J. Bozek, Instrument Mr. J. Scarai, Instrument & Controls Supervisor, CE Mr. A. Ferraro, Engineer, CE Mr. E. D. Imbimbo, Unit naalth Physicist, CE Mr. J. J. Kelly, Director, Chemistry, CE Mr. R. E. Schacklinsky, Senior Nuclear Environment Technician, CE Mr. R. Warren, Security Supervisor, CE Ms. J. F. McLay, R.5., Medical-Clinical Representation, CE Dr. C. Marshall, Radiation Safety Officer, New York University Medical Center Mr. L. Czech, New York Health Department Mr. C. C. Robertson, New York State Department of Commerce Elsroth, New York State Police - Civil Defense Liaison Sgt. W.
Mr. J. E. Hayes, "cw York State Division of Military & Naval Affairs, Office of Disaster Preparedness E. Ford, New York State Police, Peekskill Barracks Sgt.
2.
General This inspection was a detailed review of the IP Energency Plan and associated Emergency Implement e lon Procedures in order to determine
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the overall adequacy of er i c; plannin:; for the T.P site. The E=er-gency Plan is set fcrth 1 octfrent prepared by Consolidated Edison a
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ted entitled " Indian Point Nuclear Company of New York,
'lan".
The Emergency Plan is also ref-Generating Facility-E c.
m crenced in the ESAR fuc Unit.6, 2 in Section 5.6, Supplement 5 and in Section 12.6 of the FSAR for Uni: No. 3.
In addition, the technical specifications for Indian Point Unit No. 2, Section 6.11 " Emergency Plan" states in part that a site E=crgency Plan shall be maintained throughout the life of the facility.
It should be noted that the Emer-as " Contingency Plan" gency Plan is referred to in various docu=erts asis for this inspection and although the two documents are similar the was taken as the " Emergency Plan", Revision 0, dated July 15, 197 ?
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-12-All deficiencies dis:c' ared :it: respect to the IP Emergency Plan
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nnd ascociated Inp? cu. :tica "r 'ceiures, ":ather f actual (bacea on complcted nvailnble erncedurcs) or conceptual (based on discussiens with the licensee)
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revie.eu in detail
- .th managenent personnel.
The apparent deficieacies rr n it<a ninar its 3 such as use of non-specific terra in de: inir : vara.u: action Icvc ls, to maior itens in/ol-ving the calccion ci si.7nif t;c.: pro edurcs or significant deficiencias in selected energency n]anning aren After discussions with the inspec-tor but prior to the conclusion of tne overall inspection effort the licensee initiated an overall review and upgrading program with respect to all deficiencies discovered in the Emergency Implementation Procedures and associated e=crgency planning areas.
Details of these deficiencies follou in paragraphs 3 through 27.
A site inspection was conducted as part of this inspection effort.
Areas covered included the control rooms of all three units with asso-ciated emergency equipment and instrumentation, Emergency Control Center cetmunications and emergency equipnent, evacuation routes, overall energency communications equipnent, general emergency equipment, and other various areas of the IP site.
In addition to the above revicu, meetinrs were held with the inspector with representatives of off-site agencies utilized by the licensee to implement tarious aspects of the IP Energency Plan.
Details of these meetings are summarized in paragraphs 27 and 28.
3.
Enernency Inolementation Procedures, The inspector reviewed the licensec Emergency Impicmentation Procedures which were contained as an integral part of the overall IP Emergency Plan.
Deficiencies noted due to the absence of specific procedures are detailed in subsequent paragraphs.
With respect to those procedures reviewed, the inspector noted that in several instances non-specific terms were utilized and that the use of these terms such as "significant",
"abnornal", and " unexpected" could lead to confusion and possible delay in the inplemantation of emergency p;ocedures.
The inspector also stated that as uritten, the procedures would be difficult to inplement under emergency conditions.
As an integral part of the Emergency Plan, significant ancunts of time would be required to retrieve those pro-cedures necessar:: under given emergency conuitions.
The licensee stated I
that the entire area of emergenc:. planning, specifically the Emargcncy Plan and Emergency Implementation Procedures would be reviewed as soon as possible in order to correct the defielencies noted. The licensee stated further that use of inde>: tabs would be considered in order to correct the problem of isolating pertinent procedure _..
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-13-The inspector : Iso notc ' ene cens otunl deficiency with respect to
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th; licenece't. N.argene;. J1an in chat the brenhdown of accident cate;;ories created a ci nifIcant 4ap betuc.26 the " local" and " site" c ergencies.
The inspector sta..
t!mt due to the fact that three operating ren: tors 'cauld h: Iccaeed :;tnin a sin:;1e site boundary the r cmcrgencies could occur r:,uirim the cvacuation of a single unit but not the entire site.
The inspecter noted that the criteria as written indicated no definitc intern.. response level between the local snall scala energency and the larger site energency which would require evacuation of all three units. The licensee stated that this matter would be reviewed and updated as soon as possible either by (a) expanding the scope of the local emergency or (b) adding a separate category for a " plant" or " unit" emergency.
The inspector noted that the IP Emergency Plan did provide for the routine review of emergency planning aspects including the overall plan and impicmentation procedures, but that specific precedures to cover this area had not been provided.
The licensee stated that these procedures would be provided in conjunction with the overall review and upgrading of the emergency planning package.
4.
Communicaticns The inspector noted that only three portable radios were available at the site and that these units were used only for containment entries as part of routine maintenance procedures.
Prior to the completion of the inspection, the licensee was able
to verify that communications equipment located in the control rooms of Units 1/2 and 3 were connected to the vital bus as was the public address system.
Recognizing the significance of this communications capability, the licensee provided five interim portable radio units for use under emergency conditions.
The licensee stated that these radios operated on the frequency of the station radio and Eastview service area so that relaying capabilitics had been provided. The licensee stated that these radios had been located in the energency vehicles (2), the Emergency Control Center (2) and in the Alternate Emer-gency Control Canter (1). The licensee stu;ed that detailed evaluation had been initiated in order to upgrade overall commun-ication systems and that subsequent to this evaluation the appro-priate number of hand-held units would be acquired in conjunction
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-14-r co :: incorpor,ted in the control roots with a seccui radio y, s
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to,bc operntui in conjunctica "ith the Ener-z Control Center. The licensac stated furthar.that the upgradad <,< tem would include base radie: in the E :rg_:ncy Control Center where che transmitter would bc located.
In reviewing legs cf te muaicatica checks from the control roon, the incpector noted that required cc:~cunication checks had not been naintainN between the control rcem personral and (a) Energy Control Center and (b) emergency survey vehicles.
The inspector stated that failure to perform these communication chechs was in violation of Section 12.0.3 of the IP Emerscncy Plan which required these checks to be parformed on a ueekly basis. The inspector stated specifically that checks with the Energy Centrol Center had been conducted only on an intermittent batis during 1973 and none had been conducted from January through April 11, of 1974.
The inspector noted further that checks with survey vehicles had not boca ccaducted durin; 1974.
The
. licensee stated that this natter would ba corrected inmediately and that added emphasis would be made on the corpletion of these connun-ication checks in the future.
The inspector verified that appropriate personnel were instructed to insure that these checks were perforced as required.
5.
Emercencv Alarns In reviewing the description of emergency alarms in the IP Emergency Plan the inspector noted that the alarms were of such short duration that they very easily could go unnoticed by licensee personnel.
This observation was further reinforced when the inspector was conducting the in-plant inspection of the controlled areas in IP Unit No. 1.
During this time a minor fire uas identified on the non-nuclear side of IP Unit No. 1 and the fire energency alarm sounded with appropriate announcement.
The alarm was not heard by the inspector, but a partica of the alarm was heard by the licensee representative accompanying the inspector.
The licensee representative could not identify the type of alarm (radiation energency, air raid, or fire) and had to travel to another area before the accompanying announcement could be under-stood.
The licensee stated that this problen had been identified during energency training exercises but only from the standpoint that the emergency alares were inaudible at various locations uithin the plant.
The licensee initiated an everall evaluation of this proble at the site in order to more carefully delineate those arcas exper-iencing audibility problems.
To further augment this corrective action until permanent modifications could be cc=pleted, the licensee instituted special procedures in order to innure that all personnel would be advised of any energency conditiona at the site. The
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-15-license 2 further modified variors energency alares both with respect to, tyre and-duratien.
The inspector was able to verify that these
modifications had cjparently' corrected those deficiencies identified.
The licensce stated that additional speah.crs would be added fer the purposc of provicing audibic instructions to personnel, and that a roof cauated site evacuatjen signal would' be installed in the near
' future.
The inspector verified that instructions to all personnel apprisin:; then of.the revised e=crgency alarms ucre posted in areas accesnible.to all personnel.
6.
Emergenev Training The inspector reviewed all training related to'the implementation of the IP Emergency Plan.
The inspector noted that although all'
shift personnel had been indoctrinated as to the general content of the Emergency Plan, no specific and detailed training had been provided in various aspects.
(NOTE: Various individuals had
. received some intensive training in emergency planning but only limited to those areas utilized during training exercises or directly related to personnel responsibilitics under non-energency conditions.)
The inspectar alao'noted that individuals designated as Emergency Directors and interim Emergency. Directors (general watch forc=en)
had not ree.ived any intensive. training in the area of-cmcrgency plan-ning or associated procedures.
The inspector noted further that in revicuing the documentation of recent emergency training exercises, that this deficiency had been noted by plant personnel ~.
The inspector stated that failure to provide adequate training in the area of emergency planning and associated implementation procedures was in violation of Section 12.0.2 of the IP Emergency Plan.'
The licensec stated that both the aforementioned deficiency and subsequent violation identified by the inspector had been recognized by licensec supervision and that an intensive training program had been initiated to correct both the deficiency and violation. The inspector. verified that with the exception of certain individuals, this training had been completed prior to the termination of the inspection. The licensec stated-further that although this intensive training was being provided on an interin basis, a more detailed and forcalized training program in the arca of emergency planning would be developed incorporating provisions for periodic retraining of all responsible-individuals.
7.
Emercency Trainine Encrcise In reviewing licensee documentation of past training exercises, the in-spector noted that past encrcisos encompassing the scope-as described in Section 12.0.2 of the IP E=crgency Plan had not been conducted in accordance with the frequency specified in Section 12.0.1 of the plan,-consequently constituting a violation with respect to the
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Specifically, training exercises
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-- had been conducted in April of 1973 and again in April of 1974, a
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period' greater than.the required semi-annual drill frequency.
The licensee stated that this matter would~be corrected as soon as
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possible and that an evaluatien had been initiated in order to determine the necessity of conducting large-scale drills on a semi-annual basis.
The licensec stated that consideration was being given to conducting large-scale drills on an annual basis, while conducting'an increased number of smaller scale drills on a semi-annual basis or more frequently should results in a partic-
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ular exercise indicate this need.
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With respect to the emergency training exercise, the inspector identified the need to.= ore carefully formalire procedural require-j ments in the planning, conducting, evaluation and documentation i
aspects of this form of training.
The_ licensee stated that this matter would be taken under consideration and appropriate procedures provided accordingly.
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8.
Medical Emercency Plcnning
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A detailed review was made of.all aspects of the licensee's i
medical emergency planning including medical emergency procedures, first aid training, and emergency treatment facilitics (on-site-and off-site). Although no deficiencies were identified with respect to the licensee's on-site medical. treatment facilities, several deficiencies were identified sith respect to medical emer-
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gency planning relative to off-site activitics.
j As part of the overall inspection e,ffort.in this area, a represent-ative of the New York University Medical Center was contacted (see also paragraph 29).
During discussions with this representative, the inspector noted that emergency training exercises had not been carried out for any aspects of medical emergency planning beyond the site boundary.
Specifically, the inspector noted that other than
drills with the Verplanck Rescue Squad, the licensee had not excr-
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cised (a) transfer of injured to New York University Medical Center
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(by ambulance or helicopter), (b) transfer of injured fro: New York City Heliport to NYU. facility or (c) acceptance and primary actions at the NYU facility.
Details of these deficiencies and other related areas are specified below:
I a.
Transfer of Contaminated Individuals
The inspector noted that the Verplanck First Aid Squad had been trained in accepting a contaminated injury from the IP site but that no " dry-runs" had been conducted by the licensee to determine the amount of time required to reach the NYU facility. The t
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-37-the primary method of transfer would licensee stated that frcn Islcnd Eclicopters, Inc. of Garden utiliza belicopters licensee stated, however, that no drills
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The City, Long Island.
had been eenducted to datc covering this aspect of emergency
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the desicaated The inspec:or noted f urtL:r thatfor the afore=2n:icned helicopte transfer.
landing site at the IP site ly occupied as described in the IP, h ergency Plan was current The by mobile trailers and other pieces of heavy equipment.an alte been designated and the criginal landing site would oe utilized licensee stated that could be relocated.
Prior as soon as trailers and equipment t d that to the completion of the inspection the licensee sta ethe lack of drill defi the tentative method to correct
" mock-up" would involve the construction by the licensee of a ifications of the helicopter transfer area built according to specThe licensee stated furth provided the helicopter manufacturer.that extensive training onnel in the transfer of contaminated or injured victimsto extensive tra Subsequent for this transfer.
would be conducted utilizing actual helicopterstraining films would b area.
During this exercise, The licensee stated that in this training sessions.
ld way the deficiency vould be corrected, adequate training wou subsequent be provided and the means for future training would be made available.
Transfer from Helinort_
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h The inspector noted that planning had not bee h
facility.
to the NYU medical treatment New York City heliportto discussions with the inspector, the licensee developed internal procedures utilizing Con Edison maintenance Subsequent d or vehicles located in New York Oity to transfer contaminate h
by injured personnel from the heliport to the NYU facility, t ereThe l correcting this specific deficiency.
(para-in conjunction with the tradsfer drill noted above,thi be that all decontamination graph S.a.) that licensee stated further, thatthe site whenever po exercised.
The activities would be conducted at specially prepared decontamina: ion kits would accompany f
any contaminated or injured personnel through all aspects o that the transfer operation.
kits accessibility and completeness of these decontaminationthe Emerge (3) located within the IP plant and at Center.
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M2 dical E erm.nm Plan
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In revievi:q the "edical Emergency Plan'provided by the ::YU Medical Centcr, tha r zptictar noted that the plan was presented nore as generai
- idance rat:.ar taan -;pecific actions to be perfor::cd und. : umergene conditions.
Yhe liccance stated that this deficiency h5d been recognized and that subsequent to meetings with..?U representatives, preliminary procedures had been prm ided encor,aucin:; greater detail as to specific actions required.
Tha licensee's Medical Director stated that in order to prevent disruption of nornal hospital operations, no full-scale drill would be conducted involving "YU medical personnel but that ncetings vould be conducted with physicians at !;YU in order to insure that adequacy of the aforementioned planning.
The :!cdical Director also stated that the medical plan is routinely updated in January of each year and that plans had been initiated to either (a) have the :!edical Director be a part of the committee previding this review or (b) have the medical director provide a separate review in February of each year immediately following the "YU review.
The licensee ststed that it was his belief that plans for the transportation, ad-mission, and treatment of radiation casualities as reviewed with menbers of the :?YU staf f prior to the completion of the inspection were adequate and consistent with the understanding currently existing betueen the licens2e and ::cu York University medicnl representatives.
The licensee stated further that an additional physician of the licensee's medical department was scheduled to receive specific training in the treat =ent of rad-intion injuries.
d.
Medical Emercency Procedures In reviewing medical caergency planning at the IP site the inspector noted that potential situations could arise where rapid tedical assessment on the part af plant personnel would be required.
These areas included tot enly decisions as to the transfer of injured personnel to medical facilitics but also decisions relating to the movement of contaminated personnel when such movement would be contraindicate by the injuries sustained.
d The licensee stated that this matter vould be evaluated and that appropriate procedures would be provided subsequent to discussions with licensee medical personnel.
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Firnt Aid Trainina
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The inspector rcviewed the status of first aid training at the
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IP site.
The inspector verified that plans had been initiated to provide first aid training to all personnel associated directly with health physics respanalbilities.
The licensee stated that at present ceven individuals qualifiad as first aid instructors and that approximately 50 individualc-will have received the required first aid training.
The licensee stated further that
individuals with these capabilities are normally listed on the-watch schedule utilized during plant operations so that their identity is known should their assistance be required.
9.
Emercencv Surver Vehicles In conjunction with. emergency off-site monitoring (see also Paragraph 12 belou) the licensee utilizes two vehicles designated as " emergency survey vehicles".
The inspector noted that these vehicles were equipped with.two-way radio communications enabling ' constant contact
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with the control room.
The inspector noted that in accordance with the IP Emergency Plan these vehicles would-be utili cd to recover off-site sampics for subsequent evaluation.
The licensce' stated that one vehicle contained required survey and accounting equipment and
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that the other vehicle could be rapidly provided with the required items.
The licensee noted that these vehicles'are used on a routine
. basis in and around the IP site, primarily for recovery of routine environmental samples.
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In inspecting the aforementioned emergency vehicles, the' inspector l
noted that although brovided with communications equipment,.the.
radios were not turned on as the vehicles were utilized off-site.
The inspector stated that should use of these vehicles be required during operations off-site, such contact would be impossible under current operating procedures.
In checking the survey equip-ment available in the one emergency vehicle, the inspector.noted that the equipment was improperly stored and maintained,Jrendering rapid utilization of this equipment difficult at best with question-abic reliability.
The inspectcr also noted that auxiliary equipment required by site monitoring teams such as protective clothing and respiratory protection, etc., had not been provided in these vehicles nor in cmergency kits located cisewhere on-site for this purpose.
Subsequent to discussions with the inspector, the licensee initiated corrective action with respect to these' deficiencies and the inspec-tor was able to verify prior to completion of the inspection that l
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The inspector'
noted that precedur:3 had been modified to provide for constant con-
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munications with th2 control ream during off-site operations and that frequent connunications checks had been initiated.
The inspector also obscrved that eculpment lochers had been installed in each vehicle not only maintaining th; equipment in proper-operating con-dition and rendering it easily accessible,-but also containing asso-ciated protective clothing and equipnent for monitoring personnel.
The inspector noted in reviewing documentation of emergency training exercises that on one occasion,-energency survey vehicles were pre-vented from leaving'the site due to the fact that_they were not identifiabic as energency vehicles.
The licensee stated that corrective action had been initiated in this area and that the-aforecentioned vehicles contained placards which would be utilized to identify then under escrgency conditions.
The inspector also reviewed with the licensee the desirability of having caergency vehicles for use on-site during emergency conditior.s.
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The licensee stated that although no emergency vehicles had been pro-vided specifically-for this activity, sevecal vehicles were available at the Emergency Control Center in conjunction with their utilization under non-cmergency conditions in the k'eschester Service area. The licensee stated further that use of these vehicles under emergency conditions would be evaluated and if necessary procedures provided to insure their availability under emergency conditions.
10. Alternate Emernencv Control Center The IP Emergency Plan designates th,e Service Center as the primary Emergency Contrcl Center. The Service Center is located adjacent to the site boundary just east of the facility.
The inspector noted that an alternate Emergency Centrol Center luul been designated and located at the Buchanan Substation. The inspector stated however, that due to the close proximity of the Service Center and Buchanan Substation, both uith respect to distance and relative wind direction, that the use of Buchanan Substation as the alternate Energency Control Center would be unacceptable. The inspector stated further that
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although the primary Emergency Control Center could potentially be utilized under the majority of accident conditions expected, that the potential did exist for this location to be untenable under e=crgency
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conditions. Subsequent to discussions uith the inspector, the licensee stated that an a1tcrnate Emergency Control Center would be chosen in a gencral wind direction different from that of the Service Center and at a distance which would preclude the simultaneous involvement
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-21-of both the prirnry and alternate centrol ecnters under emergency ccnditions.
Pr.. to th cor% etion of the inspection the inspector 1 ternate Emerp,ency Control Center had
was eble to veri f:- that an been selected utilizing the second floor of a licensee substation located in Pec: cill, ::e 4 i; r.
The licensee stated that this loca-tion tas being utiltned en un interim basis pendin; evaluation of other locctions
- ich the licc: ee believed uould be more suitable on a perranent tasis.
The,in pector was able to verify however, that the selected location at Pcekskill was suitable with respect to wind direction and distance facters.
The inspector vas also able to verify that all apprepriate emergency equipment had been located at this interim location.
The licensee stated that the primary location being considared as permanent alternate Emergency Control Center was the Custcmer Relations Building located within the Weschester service area.
11. Accountine Procedures and Evacuation Plans The inspector noted that due to the number of entrances to the plant site and the diversity of responsibilities assigned to plant per-sonnel, accountability under emergency conditions would be difficult at best and noted various deficiencies with respect to licensee planning in this area. The licensee stated that this problem had been identified and that corrective measures had been initiated in order to nore rapidly account for plant personnel.
The licencee stated further that procedures had bacn drafted in this area and submitted a copy of this draft to the inspector for review.
The inspector noted no significant deliciencies.
From the standpoint of evacuation of plant personnel, the inspector noted that the current IP Emergency Plan calls for the evacuation on foot of all plant personnel to the Service Center parking area. The inspector questioned the licensee as to how many people could be involved in such an evacuation.
The licensee stated that the number
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could range f rom 150 CE employees to a maxinum exceeding 1200 depend-i
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ing on the number of construction personnel at the site.
The inspector noted that this evacuation would not only be time consuming and ardu-j l
ous, but also that provisions had not*been made for evacuees once at l
the Service Center.
When questioned on this aspect, the licensee l
stated that it was planned to allow employees to return to their jobs as soon as the eme,;ency conditions had been corrected.
The inspector then stated the. certain enargency conditions conceivably could exist for days but more importantly, should the wind shift direction
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during the course of an emergency, these evacuees would be in poten-l tially high radiation areas. The inspector and licensee discussed l
various alternatives to this type of evacuation, including the use of car-pools to allow evacuees to leave the site after belnr sur-j
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Ih2 lice wee stated:that an evaluation
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The licenseeEstated further that during this interin period CJ utility trucks could,bc utilized for-the transfer cf evacuces nder energenty conditions should the situatica-uarrant.
12. Emere'ncy Off-sita "p hter'-:
With respect to enerperty;off-site monitoring, the inspector noted
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'that in a n?jority of cases the licensee was relying on-the retrie-val and analysis of senples being utilized as part of the routine environ = ental monitoring' program..The inspector stated that this-type of sanpling sheuld not necassarily be limited to these.locatiens especially since they were not available in all potential wind direc-tions.
The licensee stated that additional sampling locations would be selected in the near future following an evaluation of potential wind directions,. identifiability and accessibility of the sampling locations to be chosen.
The inspector noted that.the primary source of.information upon which New York health officials-nould base initial off-site protective actions vould be that infornation provided by the licensee. The'
licensce stated that every effort vould be cade to assure that ener-
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gency of f-site conitoring and adacciated activitics would be con-
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ducted ar effectively as.possible. The inspector.and the licensec'
discussed the desirability of taintaining a third backup conitoring team for use in off-site areas to handle-the contingency of changing wind direction when the two existing off-site teams were at signi-ficant distances dcunwind.
The licensec stated that an environmental monitoring kit would be assembled for this contingency but.that no
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specific site vehicle would be assigned this responsibility.
Should i
a change in wind direction occur under energency conditions, this l
emergency kit could bc utiliced by site personnel using a company or private vehicic to proceed dcwnuind in the new direction and take the required samples for subsequent evaluation.
I 13. Vent Monitor (Unit ':a. 1)
The inspector noted that the, initial indication of the amount of
radioactive material being released off-site would come from the l
plant vent radiogas coniters.
The inspecdor also noted, however, that the Unit No. 1 radiogas cenitor would be off-scale at.001 uCi/cc whereas the Unit Nos. 2 and 3 monitors are off-scale at 0.1 uCi/cc.
The licensee stated that this problem had been iden-
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T.e lic : see sta ti that tha range of Unit No. 1 radiegas
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e::t e r a c.: to bc at least cc:..patible eith these
Unit Scs. 2.aJ 3.
The licensee stated further that an evalua: ion
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I w consider the nonitoring of varicus of th4.s 7. rob:
types of c :dicac t i re mat, "f ais in order to rrovide a more real-istic appro:
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thi. aain plant c.:n t for UrIt So. 1.
14. Are: "m and OverInvr The inspector e:c.inined the area naps and meteorological overlays currently beine utiliced at the IP site.
The inspector neted that the convantionni USGS topegraphical maps had been reduced phote-graphically for tha purpose of convenience in utilication. The ihspector also noted, however, that in being reduced in this =anner much of the detail of the maps had been lost. The inspector noted further that with respect to the meteorological overlays prepared (same scale as reduced maps), that effort and time had been devoted to cbtaining accuracy on a micrometeorological level but that the added accuracy achicved by this detail was negated by the subse-quent less in detail of the area maps with which the overlays would be used.
The licensee stated that the site would return to the use of the original topographical maps and the inspector verified that these caps were being prepared prior to the completion of tha inspection.
The licensee stated further that the metcocological overlays would also be reconstructed based on the original scale of the caps and that when completed, four complete sets of caps and overlays would be available, one in each control room (Unit 1/2 combined and Unit 3), one in the primary E=crgency Control Center and one in the Alternate Energency Control Cc~nter.
When completed, the licensee stated that these caps would be covered with plastic i
and pernanently wall nounted; a compass rose would be super-l imposed on these naps to better aid in the alignment of the over-lays and that selected sampling locations would be delineated en
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l the map with approxinately three to four locations in each conpass sector (22'B).
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15. Enercenc. Environmental '!cnitoring
i The licensee stated that procedures would be prepared which would provide for the collection and analysis of all environmental con-itoring sa plus routinely collected on a non-crergency basis follcw-
l ing the ternination of the incident.
The licensee stated that the l
samples would be limited to those ce= pass sectors downwind frcm j
the site during the emergency with a boundary sector of 225 on
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-24-i either side of the affected sectors. The licensee stated further the pree. dure weald call for the sampics td be taken af ter (a)
t that
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a. " site emargency" to' insure that radioactive caterial had not been I
released to the environnent and (b) after a " general emergency" to l
core accurataly evaluate the ar.ount of radioactivity released to the
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environnant.
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16. Schrch and Rescue Proced-3s
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The licensca stated that accountability procedures would be used as the initial-step in assuring that all personnel had been located.
The inspector and licensee also discussed the need for. search and
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l rescue procedures in the event that all personnel could not be accounted for under emergency conditions. The licensee stated that
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this area would be evaluated and search and rescue procedures would be provided as needed.
The licensce stated that consideration.would be given to the inclusion of a third member in any scarch and rescue
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party to assist other nembers with equipment, timing periods-in high r'adiation areas, assistance in moving debris if necessary, and other rescue operations.
17. Decisional Aids The inspector and licensee discussed various decisional aids used in conjunction with emergency implementation procedures in order to more-offectively implement the IP E.acrgency Plan. The three major creas
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l discusse.d included (a) emergency tag board, (b) cuergency status board and (c) facility plot plan.
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to the discussions between the inspector and licensee, S ub sequent
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I the licensec stated that these decisional ~ aids would be evaluated and that some combination of these aids would be included in the The l
overall upgrading of emergency planning for the IP site.-
licensec stated ths it was uncertain at this ti=c if all methods would be utiliced but that those methods most appropriate to oper-
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ations at the IP site would be included as soon as feasible.
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18. Leerce: cs Eculpacnt and Checklist TIr inspector noted that while equipnent inventories were apparently ccm.,lete ac stated, significant deficiencies vere identified in T-tlat adequate equipment had not been provided in all locations.
l The problen.cas more significant in areas such as the Emergency Control Center and those dutics requiring off-site responsib-
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ilitics.
The licensee stated that a detailed evaluation would be made of all equipment needs associated with crergency plan-
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ning, cither on or off-site.
The inspector verified that a pre-liminary evaluation in*.o this area had been conpleted prior to
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the ternination of the inspection and that equipment inventories at all locations had been upgraded.accordingly. The inspector also
stated that' procedures should-be provided containing these iaventory
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lists of energency equipnent and insuring that the aforementioned equipnent was available, operable and calibrated where applicable on a. routine basis. The licensee stated that these procedures would
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-be prepared ens incorporated into the emergency implementation pro-
'cedures as part of the ov..'all upgrading program in this area.
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19.. Letters of /ereement
The inspector noted that only one letter.of agreement from an
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off-site supporting agency was apparently missing, that being l
from the Island Helicopter service in Garden City, Long Island,
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The licensec stated that a meeting had been held with this agency i
during the course of the inspection and the inspector was provided
with a draft letter covering the agreements discussed. The licen-
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see stated further that no difficulty was expected in receiving
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i this letter of agreement in final form.
In addition, the licensee stated that should it become evident during the upcoming review i
of the Emergency Plan that letters of agreement would be required from other off-site agencies, these letters would be requested as I
soon as possible.
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20, b'aterf ront Planning The inspector reviewed areas dealing with control of river tra$ffic-adjacert to the IP facility.
The licensee stated that the United j.
States Coast Guard had informed them that should conditions warrant,
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l river traffic could be stopped from passing in front of the facility.
The inspector inquired as to the facilitics availability to warn-i boaters apprcaching the facility of potential-emergency conditions.
L The licensee stated that the facility itself had no such provisions l
but that it had'been assured.by the State of !cw York that state police helicopters could be utilized with. loud-speakers to achieve l.
this objective.
The licensee stated further that the public address
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system utilized in the dock area had to be modified in order to respond to complaints from residents on the far side of the river.
Luc to this modification, therefore, warning messages could only be heard on the dock area and not to any significant extent out into j
the waterway itself.
The licensec stated further that it was his
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belief that additional Coast Guard assistance would be available
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in this area should conditions warrant.
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21. Security Precedures i
l The inspector noted that the Emergency Plan did not contain specific l
procedures for the u;e of security personnel under emergency condi-tions.
The licensec stated that specific security procedures would i
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22. Eter jgjbcurria r ien
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The invector revicted the arca of docunentation under emergency conditfuns and statcu :::e vs; of normal ep ratin ; logs and asnociated records could aot i t.r e lf
~evi:N adequate Gecuncutation of crergency actien.
The inspector no; d rh t the najority of emer;;ency cetions and decisions originate fren L:o Emergency Control Center and not from the control reon and therefore cust be documented at the point of origination.
The licensee stated that this matter would be taken under consideration and that subscquent to the review of the Ener-gency Plan and associated procedures, checklists wculd be provided for use under emergency conditions.
The licensee stated further that the particular acthod of documentation selected would be evaluated under actual conditions during the nent emergency training exercise and modifications made accordingly thereafter.
23. On-stte "cleaso Rato The inspector and licensee discussed the need for the Emergency Implementation Procedures to contain provisions for a detailed determination of the on-site release rate from the facility during emergency conditions when planned releases of activity might be required to purge the containrent vessel.
The licensee stated that the primary necessity of purging containment would be contin,2nt upon the buildup of hydrogen gas to explosive levels and the facility did contain the hydrogen recombiners for such a purpese.
The licensee stated further, however, that should these recombiners fall to operate norm 2lly under energency con-ditions hat procedures would be provided for these releases and incorporated into the overall upgrading of the energency planning package.
The licensee stated that an evaluation of this problem would be initiated and procedures provided on the basis of in-plant instrumentation and meteorological equipment.
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24. Meteorolonv The inspector reviewed the area of meteorology as it pertained to emergency planning at the IP site.
The inspector noted that two meteorology towers were currently being utiliced at the site, one tower being 100 feet in height and the other approxiaately 400 feet in height and somewhat south of the IP facility.
The inspector noted fur-ther that at present data fren the 100 foot tower van being conitored in the cc.nbined control room of L' nits No. 1 and 2, while the data frc:
the 400 foot tower was monitored only at the base of the tower. The
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-27-stated that both meteorolegicsi touers had beca in cperatier li cene ce in order to establish c rrel-concurrcntly f r appron.;atal) One ycar ation betreen the datc b. :.; received f ren, bath teuers in separate
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the emupletica of this correlation, the lican-lo'caticas.
Sub acquent to see stated thit the 100 foot terer vuld be phared out.
The licansce stated furtht: that untim the in"tullation of a telencterin ; evsten 200 fact torer that da:a fro the 100 fcct could be coupletud at t:
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the centrol rooms for e=crgency purpcses.
tower uculd be utilized i ?
The inspector noted that tue 100 foot tower did net correspend to tha 1.
The of cicvated rc2ense of the rain stack at Unit No.
point due to licensec stated that he was aware of this deficiency and that the topography o# the area measurements at the 280 foot level of the 400 foot cateorology tower would correspond to the stack height of the Unit No. 1 facilJ:v.
Once fully operational, data could be this level thereby providing a more accurate estinate recorded at of meteorology condition: at the height of expected release. The under emergency conditions licensee persernel inspector noted that could transmit data via radio from the base of the 400 foot tower.
The licensee stated that this matter vould be taken under further consideration and utilized if applicable under energency conditiens.
The licensee stated further that noteorological information would net be recorded in the Unit No. 3 control roc = but that any inforcation desired at that location could be obtained via radio or telephone from the combined Units No. 1/2 control room.
25. pptural Disasters and Tonic Releases The inspector reviewed the area of natural disasters and toxic the IP site and noted no deficiencies dealing with releases at The inspector did note, houever, that procedures natural disasters.
The licensee stated had not been provided to cover toxic releases.
the facility had been designed to minimica any environmental that impact from the inadvertent release of toxic chemicals such as chlorine.
The inspector stated, however, that significant anounts of chlorine as well as caustic and acid used for water treatment purposes were stored on-site and should releases occur from thesc guidance would be. required by licensee personnel l
storage facilitics, recuired as to safety precautions to be folleuad, protective equipment and general corrective actions applicable to the aforenantioned sit-I untions.
The licensee agreed and stated that this natter would be reviewed and appropriato procedures provided as required.
26. Personnel Call Lists The inspector reviewed the personnel call lists included within the deficiency with respect to the IP Emergency Plan and noted an apparent The licensee stated that all primary scope of the personnel listed.
cach superviser cen-and supervisory personnel had been listed and that tained a listing of the phone numbers of those individuals working under
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In ndditien, th-licensee stated that due to the change:vt r of persor;ca at the -ite it would not be feasible to
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include th_ phm ai" b ra c.nd addresses of all IP personnel. The licensec statcJ furta.;r taat company phone f;cohs and other telephene directories were wat c bie at th: site and >culd be included with emergener equipnmut at the :.:w: Je9ey Control Center and other locations where their use vauld h required.
27. Recoverv and Re-entrg The inspector and the licensec discussed the need of including recovery and re-entry procedures as part of the overall IP emer-gency planning package.
The inspector noted that some consider-ation had been given to this area in the Emergency Plan but that more specific detail uns required uith respect to licensec actions.
The licent.ee stated that this matter would be reviewed and pro-cedures modified accordingly.
The licensec stated further that an attempt would be made to provide more detailed guidance in the ar2a without speaking to specific accidents.
The licensec felt that procedures containing entensive specific details should be prepared prior to recovery and re-entry operations based on the nature and scope of the incident which had occurred.
28. Contact with "eu York l'niversi tv :fedical Cen ter The IP Emergency Plan utillacs the New York Unversity Medical Center (NYU) as its prinary medical treatment facility for injuries at the IP site.
Telephone contact was established with a representative of NYU on "ay 1, 1974.
This representative stated that contact had been initiated by the licensee and that,this contact was confirmed on a yearly basis by telephone.
The representative stated that the respon-sibility of NYU during an emergency had been made cicar to them as well as all notification procedures and asacciated criteria utilized to impicm:nt those procedures.
The NYU representative stated that it was his understanding that transfer from the site to the NYU facility would be made utilizing either helicopter or local ambulence service (local to IP site).
The NYU representative stated further, however,
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that NYU had no ambulance service of its oun and therefore all trans-for from the New York City heliport to the "YU facility must be arrnuged by CE.
NYU stated that a treatment room had been set aside for use in treating contaminated patients and in conjunction with equipment supplied by the licensee, patients could be effectively segregated with a ninimum of contamination to other areas of the hos-pital.
NYU stated that other auxiliary health physics equipment was provided jointly by CE and "YU and that emergency equipment available at NYU was used on a routine basis in the area of nuclear medicine and other radiation emarnencies not necessarily related to the IP site.
The representative of NYU stated that the hospital contained approx-imately 90d beds and several emergency treatment rooms which could handle
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no icross contamination. 'The repre-personnel provided that te2re rat
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sentative of :.TU sec ted furt: ce tie.
althcugh several physicians ucre asiallable whq.vare traind in c.uclear ned icine ahd radiotherapy, - that only one physici;.n hac been Specifinally trained to handle radiation
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NYU Ttated that the prinary method of notifi-conta=inatica injurlis.
cation of a radiolegical c=aracacy b;. the licencee would be by tclephone.
training in her.lth physics procedures hTU stated f ur.acr that althouga
- .YU staf f, no major drills had had been <;iver to several md:ers of.thNYU cxpressed desire to conduct or 11censec.
been held - to date with ti..
observe an attual-radiation emergency drill in conjunction with the IP site.
29. Meetine with Reeresentatives of the State of New York In order to review the arrangement betucen the licensee and the State the IP-' site with of New York, a meeting uns held on May 1,1974 at representatives of the Bureau of Radiological Health (BRH)lof the
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of Connerce (DC),-Division of State Health Department, the Dapartn n:
Military an'd Naval Affairs '(DMNA) and the New York State Police (NYSP).
The representative fren ERH stated that contact had been initiated'and -
maintained by the licensee and had been intensificd in recent conths-
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Representatives in connection with the licensing of IP Unit No.
from Ucw York State stated that all notification procedures and asso--
ciated criteria utilized to implement those procedures had'been re -
BRH did state, however, that some minor viewed with the licensec.
notification changes could be forthcoming involving two separate not-ifications of New York State officials.
BRH stated that emergency actions are coordinated from the Energency Operating Center (EOC) which is located in-the substructure of the Public Security Building, State Office Buildina Campsus, Albany, in conjunction with the Office of Disaster Prepared-New York.
Here, ness (ODP) of the DMNA and the NYSP, around-the-clock coverage is -
BRH stated that the EOC could maintained for required notifications.
actually be coaccived as six district offices, with the southern office Coordination for the IP site being located in Poughkeepsic, New York.
activitics therefore, while initiating in. Albany would be transferred office and weuld then function with the local to the southern district operations center for Moschester County located.in White Plains, New incidtnt progressed, action would ultimately be coordin-York.
As the
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ated out of Weschester County with supervisory direction provided from Poughkeepsie.
BRH stated that although the ultimate authority for large scale evacuation rested with the Governor, the principal responsibility for declaring such action could rest with the Commissioner of Health.
BRH stated further that local, small' scale evacuations could be Both BRH on the county IcVel should conditions warrant.
carried out and ODP persennel estimated an individual could be at the IP site
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-30-within 29 mir :tes of netif f :ation but th2t appro:: irately one hour woul' be reiu; red far t..e estab! shment of an oparations center during
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norail va n in' hour:.
W SP repruzentatives stated that a troeper sit ita'n two to three r 1:intes of notification.
cou2? bu e ::
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ERH ata ted t.u t beth 'i3P rn.i Ci'cil Defense conmunications networks utilized under ec2rgency conditions.
woulu eu BRl! stated that in '. Just 1973 a state-vide drill uas conducted in /dbanf invelvin~,a siruiated accident at the :line ::ile Point Nuclear %".erating 5;atien near Oswe;;o, ::cu York.
BRH stated that representatives of various state agencies which nornally would have been involved in an incident of this nature participated at the EOC in Albany.
From the standnoint of emergency of f-site monitoring, BRH stated that the State of New York uould be relying heavily on licensee monitoring functions during the initial stages of the energency.
BRH stated tha t although assistance would be requested from the Radiological Assistance Program (r.P) team at Srookhaven National Laboratories, that 3'2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> responsa tice vould regulred under normal con-
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ditions.
BRil stated, therefore, that the licensee might conceivably have to handle the initial phases of environmental monitoring for several hours.
BRil stated other groups and agencies within the state organization
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would be available as conditions warrant during the cmcrgency period.
The NYSP statcJ that although the Police Departmcat from the village of Buchanan would be involved with local actions, that the NYSP would be responsible for overall traf fic control and evacuation responsib-ilities.
- !YSP stated further that helicopters could be utilized to assist in evacuation or notification responsibilitics and that the nearcst helicopters were located in Newburg, New York.
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