ML17053C731
| ML17053C731 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/24/1981 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Lempges T NIAGARA MOHAWK POWER CORP. |
| References | |
| NUDOCS 8107130020 | |
| Download: ML17053C731 (60) | |
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Oocket No. 50-220 UNITEDSTATES NUCLEAR REGULATORY COMMISSION REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA19406 24 APR 1981 Niagara Mohawk Power Corporation ATTN:
Mr. T.
E.
Lempges Vice President Nuclear Generation 300 Erie Boulevard West
- Syracuse, New York 13202 Oear Mr. Lempges:
We have received the attached Federal Emergency Management Agency (FEMA) letter dated April 23,
- 1981, and the attached letter from FEMA to the New York State Oisaster Preparedness Commission dated April 6, 1981, which lists numerous deficiencies in the New York State and local emergency response plans for the area around your reactor site.
Although we have not completed our review and assessment of the overall state of emergency preparedness we are of the view that many of these deficiencies identified by FEMA must be removed in order for us to conclude that appropriate protective measures can and will be taken in the event of a radiological emergency at your facility.
We have concluded that assurance of both onsite and offsite preparedness is needed to protect the health and safety of the public.
This is to notify you that should the deficiencies not be corrected within 120 days of the date of this letter, the Nuclear Regulatory Commission will determine whether your reactor shall be shut down until such deficiencies are remedied or whether other enforcement action is appropriate.
We are concerned that the availability and allocation of resources necessary to address the FEMA deficiencies are not clearly defined.
We also fully recognize that the deficiencies to be corrected may involve actions by other parties and political institutions which are not under your direct control.
Nonetheless, we would expect this subject to be addressed by you as well as others.
We understand that New York State believes that State legislation is required to fully resolve the offsite planning problems and that resolution of the legislative issues involved can be achieved within the period allowed for correcting the deficiencies.
You are requested to submit a written statement to this office within 30 days of the date of this letter, describing plans for correcting each of the deficiencies identified in the April 6, 1981 letter.
This request affects f'i07i30020 Bi0424 I
PDR ADOCK 05000220 F
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Niagara Mohawk Power Corporation 24 APR 198$
fewer than ten (10) licensees and therefore, is not subject to the Paperwork Reduction Act of 1980 (PL 96-511).
If any unusual problems develop we are available to work with you and the State and local authorities along with FEMA to. resolve the problem.
Additional notifications of this type may be issued as our emergency preparedness review continues through observation of the annual joint exercise, and onsite inspections of your emergency preparedness.
Sincerely, yce H. Grier ector
Enclosures:
As Stated cc w/encls:
T. Perkins, General Superintendent, Nuclear Generation T.
Roman, Station Superintendent R. Abbott, Operations Supervisor E.
B. Thomas, Jr.,
Esquire Honorable Hugh L. Carey, Governor of New York State of New York, Department of Health V. Forde, Acting Regional Director, FEMA Chief Executive, Oswego County J.
Dunkelberger, New York State Energy Office M.
C. Hennessey,
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FFD=RAL ElRGENCY MANAGrMENPAGENCY Pegion Il 26 F deral Plaza New York, New York 10278 April 6, 1981 Mr. MI1iam C. Hennessy, Chairman Disaster Prepa edness Commission State of New Yorl-Public Security Building State Campus Albany, New York 12226
Dear Mr. Hennessy:
RE:.
" Review oZ New York State Radiological Emergency Preparedness (REP) Plan The RegionaZ.'Assistance Committee (RAC), less the U.S. Department of Energy, has reviewed the draft State Radiological Emergency'reparedness (R~) Plan, using the planning standards contained in~ REP-1/NUREG-0654.
The detailed commenm are attached.
Wkfke we racogni e that.the December 1980 draft submission was prepared in accordance with the "Interim" edition of FEB. REP-l, we evaluated the State Plan aga"nst the "Revision 1" edition of the planning standards, which cia-ified several issues contained. in the interim edition.
Therefore, the RAC's detailed comments regarding t'e State Plan are based on the revised standards.
Noticeable progress has been made in the version of the State Plan furnished to the RAC for review on December 17, 1980.
The August 1980 draft sub'sion had no,county plans prepared in accordance with FK4 ~~-1 standards.
The December 1980 draft contains a State level plan and seven county plans.
The steady pro-gress made is indicative of tha comm" tment by the Stat:e and local gove~ants towards radiologica3. emergency preparedness for commercial nuclear power plant accidents.
- Indeed, tha Nuclear. Planning Group should be commended for tha energ"as and attainment of its goal in its timely furnishi".g to the RAC a draft of M~
State and. local plans for locations with operat ng nuclear reactors.
Moreover; we e~ect that signi""icant and substantive improvements to tha sub-mitted. plan have a?ready been made.
However, the RAC found it very time consuming to perform the review dua to in'accurate cross-referencing and hasty edit'ng.
Consequently, the RAC expended a great deal of tlute trying to locate various portions of the plan that address the specific plug criteria.
In summa~, deficiencies in the, plan fall into three broad categories:
'a.
~A."~a we racogn~-a the State's efforts to reconcile the conflict bet-een State and county authorities and respansibi~~ties perm~ming to radiological emergency preparedness, with proposed enactments such as the "Fink Bill,"
this deficiency, nonetheless, pervades the 'plan.
Until resolution to this fundamental planning consideration 's attained, the plan will remain defic eat, even if a13. other planning standards are adequately addressed.
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Hr. Qi11iam C. Hennessy b.
he Plan still lacks specificity in many cases.
Hethodologias and decision-making
'processes for the foLowing planning standards require urther articulation.
emergency response support, notification methods
'nd proc dures, public education, accident assessment, radiological exposure control, medical and health support, and recovery and re-entry'perations.
Cross references should clearly identify elements of the plan as they'elate to the planning standards.
c.
Certain planning criteria have not bean addressed in the submission.
Letter agreements with Federal agencies and non-government organizations were missing Heans for relocation have not yet bean incorporated in the Plan.
Related maps and charts are missing.
A program for permanent record devices has not bean developed.
All planning criteria listed in FMh, RZP-1/
NUREG-06S4, should be addressed in the plan.
The detailed cnnanents that the RAC has provided, coupled with a meeting you may request=to discuss these
- comments, should serve to-identify tha revisions necessary in the State Plan.
Ve ask. that, upon completion of these revisions, the Governor apply for formal review and approva1 'of the State Plan, site specific to each reactor location in order of State priority.
Each submission should be prepared
'and furzdahed in accordance with Section 350.7, FZHA Proposed Rule 44 CFR 3SO.
Requests-for additional informa1 reviews will only delay the review process.
'incerely, Vincent Peed'e Acting.Regional Director Attachments
RAC NNENTS ON NEW YORK COUNTY RADIOLOGICAL ENEPGENCY
RESPONSE
PLAN DECENSER 1980 LEGEND A - ADEQUATE N - INADEQUATE RATING A.
Assi nment of Res onsibilit Or anization Control)
A.l.a.
N The relationships between the State and the Counties have yet to be resolved.
A.l.b Same comment as above.
,A.l.c.
Block diagram not present.
A.l.d.
Same comment as A.l.a.
A.l.e.
A.2.a Key individuals by title are not always specified.
Table III-l is missing except in Wayne and Nonroe County pl ans.
A.2.b A
A.3.
Not present.
Once the roles of the State and the counties are clarified, these roles must be clearly specified in written agreements.
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ELEMENT (Con't)
A.3.
RATING N
- Also, agreements with non-public suppport organization, such as his companies and their unions, must be included.
A.4.
A C.
Emer enc Res onse Su ort and Resources C.l.C'hould be better references between plan and procedures.
C.2.a.
A C.4 i
Letters of agreement not present, particularly with respect-to non-public support organizations 0.
Emer enc Classification S stem 0.3.
0.4.
A
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GLGIIENT RATING
.0 Notificati on Methods and Procedures E.l.
A While adequate, as is, Figure III-2 is missing.
E.2.
Figure: III-2 missing.
E.G.
Need better indication as to how information will be disseminated.
E.6.
A-more complete set: of prepared messages are needed which would insure that news announcements for various sets of conditions are readily available.
E.7.
Same comment as above.
F.
Emer enc Communications F.l.a.
But figure III-2 is missing.
F.l.b.
Same as above.
F.l.c.
N Communications ties with Federal agencies must be specified, particularly the Coast Guard.
F.l.d.
Means for communicating with radiological monitoring teams in the field must be specified.
F.l.e.
A Sut figure III-2 is missing F.2.
N No provision for communications with mobile medical support facilities.
F.3.
Public Education and Information G.1.
See corresponding comment for State Plan.
G.Z.
Same comnent as above.
G.3.a; A
G.4.a.,
A G.4.b.
Must be more specific on coomunications system and procedures necessary to achieve cooraination.
G.4.c.
This criteria is not listed in the cross-reference index and does not appear in. sections dealing with public information.
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~ a ELEMENT RAT ING G.5.
A H.
Emeroenc Facilities and.
E ui ment H.3.
H.4.
A H.7.
See. comments for State. Plan.
H.10.
No reference to this criterion was found.
H.11.
Except for Wayne Co, where applicable appendix still under development.
H.12.
Accident Assessment r.7.
While plan states that resources are limited,. it does not describe what resources and capabilities currently exist.. Also, se comments for State Plan.
See comments for State Plan.
1
RATING Protective Res onse J.2.
Not yet incorporated into P 1 an.
See comments for State 'Plan.
Maps missing or're incomplete.
Appendix G must be updated to reflect change in NUREG-0654. (notification time).
While Appendix G
discuss'ptions, actual plans and procedures have. not'et. been established.
Use of radioprotective drugs not discussed.
- Also, see comments for State Plan.
Same.
as above.
J.10.g Agreements with private and public carriers and their
- unions must be obtained.
A 8ut still incomplete in some counties.
Still not complete.
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EL MEihi Q
RATING 0 J.10.j.
A J.10.k.
A But various attachments in implementing procedures in some county plans must be completed.
J.10.1.
For all county plans except for Monroe and Wayne.
J.12.
No provision for registering and monitoring evacuees.
Radiolo ical Ex osure Control K.3. a.
See comments for State Plan.
K.3.b.
See comments for State Plan.
N Until respective roles of State and Coun.ties are
- resolved, there would be a potential conflict between orders given by State Commissioner of Health and responsible person designated in county plans.
K.5.a.
Se coments for State Pl an.
K.S.b.
See comnents for State Plan.
Medical and Public Health Su ort
1
RATING L.l No list of hospitals v:as found, but Congregate Care Center informati ons provided.
While the centers are to care for contaminated
- persons, the minimum criteria are. lacking and County Health Department input is lacking.
L.4.
Attachment 8 - Guidelines for Treatment and Transportation of Potentially Contaminated Injured People is blank.
Also, formal agreements are needed with carriers and their unions.
Recover and Reentr Plannin and Postaccident 0 er ations M.1.
Specific procedures that address decisions to relax protective measures are missing.
Exercises and Drills N.l.a.
A N.l.b.
No provision for exercise once every six years between 6:00 pm and midnight and midnight and 6:00 am.
N.2.a.
A Except for Putnam,
- Oswego, Monroe and Wayne Counties
'LEi4EHT RATIi'IG (Con't)
H.2. a.
A which have no specific procedures for exercises and dri 1 1's.
N.2.c.
Same as N.2.a.
N.2.d.
A Same as N.2.a.
N.3.a.
N Not-yet present.
N.3:.b.
Not yet present.
Not yet present.
Not. yet present.
N.3.f.
Not yet present.
N.4.
A N.5.
0 Radiolo ical Emet enc
Response
Trainin A
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Except for Putnam, Monroe and Wayne Counties which have no specific procedures for training.
0.4.a.-j.
Plans and procedures not specific enough.
They do not list specific type of training needed, as in criteria.
Also "should be trained" must be changed to "shall be trained".
0.5.
A P.,
Res onsibilit For The Plannino Effort: Oevelo ment Periodic Revie~
and Oistribution of Emer enc Plans P.1.
Section II-B.5. not specific enough.
P.Z.
A'.3.
A P.4.
A..
Except for Putnam, Monroe and Wayne Counties which have no procedures for document control and revision.
P.5.
A Same as P.4.
P.6.
A
'LEMENT RATING P.7.
A Same as P.4.
P.S.
Must list implementing procedures in Table of Contents and improve page numbering system.
P.10.
N This criterion was not listed in draft NUREG-0654.
ELENENT RAC C
"HTS OH TrlE STATE OF NEW YO RAOIOLOGICAL ENERGENCY
RESPONSE
PLAN FOR NUCLE~, POMK PLANTS (STATE LE'/EL PLANS)
OECEY(BER 1980 LEGENO A - AOEQUATE N - IHAOEQUATE RATING A.
Assi nment of Res onsibilit Or anization Control A.l.a.
The relationships between the State and the Counties have yet to be resolved.
~ A.l.b.
Identify a11 private sector organizations to be used for back-up support A.l.c.
A.l.d.
Phone numbers and titles of individuals in charge and backups should be included.
This may be incorporated into a separate
- booklet, since certain phone number s are sensitive.
A.l.e.
A A.Z.a Each or ganizhtion shall specify a key individual by
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EL'Eb/ENT RATING A.2.b.
N Legal issues yet to be resolved.
A.3.
N No agreements or memorandums of understanding are included in the plan.
A.4..
A C.
Emer enc Res onse Su ort and Resources C'.1.a.
Assistance.
is now requested through the Federal Radiological and Assessment Plan.
Reference to RAP/
IRAP should be deleted.
Furthermore, IRAP is replaced by the National Radiological Emergency Preparedness and Response Plan for commercial nuclear power plant accidents (Master Plan - 12/23/80. in Federal Register).
Also, who. in the DOH will notify FRUMP?
C.1.b.
Federal resources times of arrival should be included.
C.l.c.
A)
Land lines appear to be the major coomunication system.
Are these dedicated phone lines with separate trunks?
If not, what are the alternatives if they are not available?
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Riltlllg (Con't)
C.l.c.
8)
Unable to locate information concerning air fields, telecommunications, and radio frequencies availabl.e for use.
A reference to air fields available, and their capabilities is mandated by the I
reliance on Federal Agencies for aerial assessment.
Discussion of radio frequencies is essential
.to assess ability for inter-agency comnunication.
C.2.a.
C.3.
Any and all private radiological labs,, their capabilities and r esponse times should be included.
Page,-III-36 lists only several agencies.
Is the State lab the only facility in state other than Feds?
C.4 No letters of agreement with federal agencies and non-governmental organizations.
The recognition that the Coast: Guard, which as a part of its statutory duties, will be involved in any nuclear accident near a
navigable waterway, must be addressed in the New York State. Plan, as the nuclear plants are all adjacent to
~ navigable waters.
An agreement with the Coast Guard is necessary
- and, in particular, the plan must identify who in the DOH contacts the Coast Guard and to which Coast Guard Office he directs his notification.
Eiement
( Con '
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C.4.
~Ret in N
In addition, who will notify the Railroads?
0.
Emer enc Classification S stem 0.3.
A 0.4.
Notification Methods and Procedures E.l.
Specify title of person notifying and being notified within the agenices listed on pp. III 28-30.
Mhat are the means for verification of messages?
E.Z.
E.5.
E.6.
In the event a accident occurred today, describe the administrative and physical
- means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway.
E.7.
Ooes not include respiratory protection'.
El'ev..ent Retina F.
Emer enc Communications F'.l.,a.
A F'.1.b.
A,'.l.c.
Specific comnunication ties with federal agencies is needed.
F.l..d..
F.l.e.
F.2.
N Can not locate any mention of a coordinated communication link for fixed and mobile medical support facilities.
Who is on the OOH emergency medical services?
F.3.
A G.
Public Education and information 6.1.
What. are specific educational plans?
How will information be dissemiated?.
What. state individual is responsible of th'e educational program?
Topics in G.I. are not addressed.
4
El emerita (Cont ')
G.l.
~Ratin e
What type of program is Parsons preparing for the uti 1 ities?
6.2.
N 'ame as G.I.
G.3.a.
A" G.4.a.
A 6.4.b.
A.
6.4.c.
6.5 Plan must address an annual program for the news r
media.
H.
Emer enc Facilities and Equi ment H.3.
A H.4.
A H.7.
During the first few hours of a release, the Stat and local organizations must perform any needed field "monitoring without federal.assistance.
Elehent'atina (Con't)
H.7.
The plan must discuss the adequacy of calibrations, security from damage, accessibility to monitoring teams,. or ability to measure potential principle exposure pathways.
In addition, OOH states it will provide limited manpower capability with the appropriate equipment."
How limited'?
For how long?
Mith what equipment?
Mill it be adequate?
H.10.
Inventor y/quarter not'entioned.
H.ll,.
H.12.
Accident Assessment I.;7.
Described on pages III 34-37.
However,. larger equipment such as portable ganma spectrum analyzers, stationary field monitoring equipment, or mobile vans with monitoring equipment may be avail able. through state and local organizations and if so, should be identified by listing or reference to county plan.
Mill the Brookhaven FRAAP team be able to assist soon enough in emergency?
Mhat equipment is available for food, milk, and water monitoring?
. Element
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I.8.
~Rat in e
a)
Mhat arrangements have b en made to notify ield monitoring teams at'home?
How do the teams get to the site?
How do they obtain their equipment?
What are their communication arrangements with the EOC?
Mhat are. their estimated deployment times?
b)
Mhat. is the composition of the NFO field teams?
Is the NFO aware that its field monitoring teams will be used to provide information to the State?
Have all the NFO's in the State agreed to provide field monitoring teams or just the Indian Point NGS? If just IP,. what arrangements have been made at the other NFO's?
Mill the NFO's have sufficient personnel to cope arith. ba.ttL,ttu* em'.gene@.. ancL ttu fie.ld mon.iturin.g.'L,,
r Are off-shift personnel to be used?
If so, how are they notified?
c)
What, if any, fixed monitoring stations are avail abl e?
Have monitoring locations been site-selected?
Plan states New York does not have airborne I de-tection capability.
'.10.
The State does not have its own'procedure, but merely references Nureg 1.109
~s the method to be followed.
~Ietqent (Con't)
I.10.
~Rat in The State must develop its own procedures, patterned after 1.109, if'o desired (a quick and easy method of assessment should be used in the heat of battle).
I.11.
"Arrangement being made", therefore, unacceptable at this time.
Protective Res onse Has, yet to be incorporated. into the plan.
Oetermination of protection actions not possible without I.10.
Capability to conduct sampling (ground and/or aerial surveillance) has not been established.
Who will do this?
What measures are being considered to ensure that the response(s) is (are) actually vi able?'.10.a.
Maps missing.
J.10.b.
A J.10.c.
N In the event an accident occurred
- today, how will the population in the plume exposure pathway be notified?
II J.10.d.
"Cur 'ntly under developm nt".
E.l ement '
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~Rai: in J.3.0.e.
FDA has indicated that this is a State decision and any policy regarding this is at the discretion of the DOH.
3.10.f.
Same as 0.10.e..
J.10.g.
N Agreements with public and private carriers must be obtained.
0.10.h.
N:.
Being developed J.10.i N.
Being developed J.10.3.
0.10.k.
Being developed D.10.1 N
Informati on mi ssing J.10.m.
Flow chart is good, however, it is not clear how the critical decisions at 4 and 6 are to be made, i.e.
shelter vs. evacuate.
D.ll.
N Informati on mi ssing, J.12.
N This is referenced as."Local Responsibility".
Is that the agreement between State and locals?
ement.
Ratina (Con t)
J.3.2 If so, there is a problem, because the county plans do not reference this element.
K.
Radiolo ical Ex osure Control K.3.a.
Where is the program for permanent record devices (i.e., film badges, TLO)?
Appendix G, 3-2 assigns each agency's radiological liaison to obtain and prepare records.
Are there procedur es for this?
Oo the-TLD's exist?.
How are the appropriate personnel to obtai'n their equipment on a 24 hour/day basis?
K.3.b.
This..responsibility is assigned to each agency's
'I radiological liaison or-field supervisor?
Have these peopTe been trained and assigned?
K.4.
The final decision maker is the State Comnissioner of HeaTth?
Who are the other members of the decision chain?'.5.a.
The specified action levels are unacceptabTe because they are too high.'.5.b Where are the PMC's, where are central supplies stored and how will they be stocked?
~r
erne l(aTI n 9 Medical and Public Health Su ort L.1.
The State plans still.does not descirbe arrangements for local and backup hospital services and the capability for evaluation of radiation exposure.
The Hospital Association of New York State has requested a
list of hospitals and special. radiological capability.
It "is forthcoming."
L.3.
Same as L.1.
3.4.
Arrangements are stil'T not indicated for transporting victims of radiological accidents to medical support-facilities.
Agreements are needed.
N.
Recover and R entr Plannin and Postaccident Ooer ations N.l.
What. levels and.procedures are used in the decision-making?
N.3.-
Plan states the ODP will appoint a conmittee to make recovery decision.
Mhat state agencies and representatives will be sitting on this comittee?
c remenr.
P1an states that a 1ong term monitoring program will be estab1i shed.
P1ease 1 aborate.
N Exercises and Orills N.l.a.
N.Z.a.
~ N.2.d.
N.2.e.
Semi-annual health physics drill not mentioned.
N.3.a.
N.3.b.
A N.3.c.
N.3.d A
N.3.e.
A N.3.f.
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0.
Radiolo ical Emer enc Res onse Trainin This section is acceptable, however, specific titles of individuals to be trained should be listed.
Res onsibilit for the Pl annin Effort:
Oeve'lo ment Periodic Review and Oistribution of EEE PI P.l.
Specific titles of individuals responsible for the planning effort should be listed.
P.2.
A P.3.
N Who in the OGHAM P.4.
P.5.
A
f 4
O Element Q "/
Ratina P.7.
P.S.
A P.10.
N Emergency telephone numbers must be updated quarter 1y.
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