ML17258B175
| ML17258B175 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/24/1981 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| NUDOCS 8107130019 | |
| Download: ML17258B175 (31) | |
Text
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Docket No. 50-244 Cenkgg L Ftl~d 24 APR t981 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA19406 Rochester Gas and Electric Corporation ATTN:
Mr. John E. Maier Vice President Electric and Steam Production 89 East, Avenue Rochester, New York 14649
Dear Mr. Maier:
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 Disaster Preparedness Commission dated April 6, 1981, which lists numerous deficiencies in th'e 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 orde'r 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
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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 unti 1 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 8107130019 810424 PDR ADOCK 05000244 F
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Rochester Gas and Electric Corporation 24 APR 1981 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
'rector
Enclosures:
As Stated cc w/encls:
B. A. Snow, Plant Superintendent J.
- Bodine, gC Engineer Harry H. Voigt, Esquire J.
T. St. Martin, Technical Assistant, Operations Assessment Engineer Honorable Hugh L. Carey, Governor of New York State of New York, Department of Health V. Forde, Acting Regional Director, FEMA L. Morin, Chief Executive, Monroe County Chief, Executive, Wayne County J. Dunkelberger, New York State Energy Office W.
C. Hennessy,
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FFD=RAL Ebi%iRGENCY MANAGEP/iEN I AGENCY Pegion ll 26 Federal Plaza Ne.v York, idew York $ 0278 April 6, 1981 i~fr. Qi3.liam C. Hennassy, Chairman Disaster Prepa edness Commission State of Naw York Public Security Building State Campus Albany, Naw York 12226
Dear Mr. Hennessy:
RE:.
Review of'ew York State Radiological Emergency Preparedness (REP) Plan The Regional'ssistance Committee (RAC), less the U.S. Department of Energy, has reviewed the draft State Radiological Emergency Preparedness (R~~) Plan, using the planning standards contained in FWA REP-1/NUREG-0654.
The detailed comments are attached.
HM1e we recogni e that.the December 1980 draft submission was prepared in accordance with the 'Cnterim" edition of ZZSA. REP-l, we evaluated the State Plan against the "Revision 1" edition or the planning standards, which cia i"ied several issues contained. in the interim edition.
Therefore, the RAC's detailed comments regarding the State Plan are based on the revised standards.
Noticeable progress has been made in the version of the State Plan furnished to tha RAC for review on December 17, 1980.
The August 1980 draft submission had no, county plans prapaxad in accordance with P~~A Rc~-1 standards.
The December 1980 draft contains a State level plan and seven county plans.
The steady pro-gress made is indicative 'of the comm=tment by the State and locaL govern=ants towards radiological emergency preparedness for commercial nuclea-power plant accidents.
- indeed, the Nuclear. Plann:ng Group should be commanded for the energ" as and attainmant of its goal in its t&ely fu~hing to the RAC a, draft of ~~
State and local plans for locations with operat'ng nuclear reactors.
Moreover', we expect that signi icant and substant'va improvements to the sub-mitted.
p~t have already been made.
However, the RAC found it very time consuming to perform the review dua to in'accurate cross-ref arencing and hasty ed" t'ng.
Consequently, the RAC expended a great deal of time trying to locate va ious portions of the plan. that address the specific plug criteria.
Tn summa~,
deficiencies in the plan fall into three broad categories:
'a. Ala wa recogn~ "a the State's ef orts to reconcile the conflux.ct bat~-aan State and county authorities and responsibi~~ties pertaining to radiological emergency preparedness, with proposed enactments such as the "Pink Bile.,"
this deficiency, nonetheless, pervades the'plan.
Until resolution to t'.'s undamental planning cons'de ation 's attained, the plan will remain de"ic'ent, even if a11 other planning standards are adequately addressed.
Hr. Qilliam C. Hennessy b.
he. Plan still lacks specificity in many cases.
Hethodologies and dec'sion-making processes fox.the fo3 owing planning standards require further articulation.
emergency response support, notificat'on methods
'nd proc dures, public education, accident assessmen, radiological exposure control, medical and health support, and recove~
and re-entry'perations.
Cross references should clearly identify elements of the plan as they relate to the planning standards.
c.
Certain planning criteria have not been addressed in the submission.
Letter agreements with Federal agencies and non-government organizations were missing Beans fox relocation have not yet been incorporated in the Plan.
Related'maps and charts are missing.
4 program for pexmanent
- xecoxd, devices has not been developed.
A11 planning criteria listed in FMh. RZP-ll HVREG-0654, should be addxessed in the plan.
The detailed comments that the MC has provided, coupled with a meeting you may request=to discuss these
- comments, should serve to identify the revisions necessary in the State Plan.
Qe ask. that, upon completion of these revisions, the Governor apply for formal review and approval of the State Plan, site specific to each reactor location in order of State priority.
Each submission should be prepared
'and farc~hed in accordance with Section 350.7, FEHk Proposed Rule 44 CFR 350.
Requests-for additional informal reviews will only delay the review process.
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Sincerely,
/n~en<Feed 8 cting. Regional Director Attachments
RAAhlii'1ENTS ON NEN YORK COUNTY RADIOLOGICAL EMEPGENCY
RESPONSE
PLAN DECEMBER 1980 LEGEND:
A - ADE(UATE N - INADEQUATE RATING A.
Assi nment of Res onsibilit Or anization Control)
A.1. a.
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 A.Z.a Key individuals by title are not always specified.
Table III-1 is missing except in Wayne and Monroe County pl ans.
A.2.b A.3.
Not present.
Once the roles of the State and the counties are clarified, these roles must be clearly specified in written agreements.
. ELB1ENT RATING (Con't)
A.3.
- Also, agreement s with 'on-pub 1 ic suppp ort organization, such as his companies and their unions, must be included.
A.4.
C.
Emer enc Res onse Su ort and Resources C.1.C A
Should be better references between plan and procedures.
C.2.a.
P q A
C.4 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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ELE>IEiNT RATING Notification Methods and Procedur es While. adequate, as is, Figure III-2 is missing.
E'.2.
Figure: III-2 missing.
E.5.
Heed better indication as to how information will be disseminated.
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.
A Sut figure III-2, is missing.
F.l.b.
A Same as above.
F.l.c.
Communications ties with Federal agencies must be specified; particularly the Coast Guard.
.. ElENENT RATING F.l.d.
Means for communicating with radiological monitoring teams in the field must be specified.
F.l,.e..
h A
8ut figure III-2 is missing F.2.
No provision for communications with mobile medical support facilities.
F.3.
A Public Education and Information G.l.
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 communications system and procedures necessary to achieve cooraination.
6.4.c.
This criteria is not listed in the cross-reference index and does not appear in sec.ions dealing with public information.
. LEMENT RATIiJG 8.5.
A H.
Emerqenc Facilities and E ui ment H.3.
A H.4.
A H.7.
See. comments for State Plan.
H.10.
No reference to this criterion was found.
H.ll.
Except for Wayne Co, where applicable appendix still under development.
H.12.
Accident Assessment I.7.
While plan states that resources.
are limited, it does not describe what resources and capabilities currently exist.. Also, se comments for State Plan.
I.S.
See comments for State Plan.
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EL'KYiENT RATliNG Protective Res onse J.2.
Not yet incorporated into Pl an.
See comnents for State Plan.
J.10.a.
Maps mi ssing or are incompl ete.
J.10.c.
Appendix G must be updated to reflect change in NUREG-0654 (notification time).
While Appendix 6 discuss"
- options, actual plans and procedures have. not'et been established.
J.10.d.
A'.10.e.
N Use of radioprotective drugs not'iscussed.
- Also, see comments for State. Pl an.
J.10. f.
Same as above.
J.10.g Agreements with private and public carriers and their
- unions must be obtained.
J.10.h.
A But still incomplete in some counties.
J.10. i; Still not complete.
ELPilE AT RATING O.
8 J.10.j.
J.10.k.
But'arious 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.
K.
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 Counties 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.
See coments for State Pl an.
K.5.b.
See comments for State Plan.
Medical and Public Health Su port
EL>MENT RATING L.l No list of hospitals was found, but Congregate Care Center informations 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 P1annin and Postaccident 0 er ations Specific procedures that address decisions to relax protective measures ar 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
ELEMENT RATIi'IG (Con't)
H.2. a.
A which have no specific procedures for exercises and dri 1 1 s.
N.2.c.
A Same as N.2.a.
N.2.d.
A Same as N.2.a.
N.3.a.
Not yet present.
N.3:.b.
Not yet present.
N Not yet present.
Not. yet present.
N.3.f.
Not yet present.
N.4-.
H.5.
0 Radiolo ica1 Emer enc Res onse Trainin A
ELEMENT RATING O.l.b.
Except for Putnam, Monroe and Wayne Counties which have no specific procedures for training.
0.4.a.-j.
N 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 Plannina Effort: Oevelo ment Periodic Review and Oistribution of Emer enc Plans P.l.
Section EI-B.5. not specific enough.
P.Z.
A P.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
ELEM~I'lT RATING
-ll-P.7.
A Same as P.4.
P.8.
Must list implementing procedur s in Table of Contents and improve page numbering system.
P.10.
This criterion was 'not listed in draft NUREG-06~4.
RAC CO~'"-NTS ON THE STATE OF NEM YOR~
RAOIOLOGICAL ENERGuNCY
RESPONSE
PLAN FOR YUCLE~~
POMER PLANTS (STATE LE'fEL PLANS)
OECEi+iSER 1980 LEGENO A - AOEqUATE N - INAOEqUATE RATING A.
Assionment 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 all 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 c rtain phone numbers are sensitive.
A.l.e.
A A.Z.a Each organizhtion shall specify a key individual by
ELEt1ENT RATING A.2.b.
N Legal issues yet to be resolved.
A.3.
No agreements or memorandums of understanding're 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 P
included.
C.1.c.
A)
Land lines appear to be the major comnunication system.
Are these dedicated phone lines with separate trunks?, If'ot, what are the alternatives if they are not available?
~: Eleihent (Con't)
C.l.c.
P,atinq
.0 8)
Unable to locate information concerning air fields, telecommunications, and radio frequencies available for use.
A reference to air fields available and their capabilities is mandated by the reliance on Federal Agencies for aerial assessmen".
Discussion of radio frequencies is essential to assess ability for inter-agency communication.
C.2.a..
C.3.
Any and all private. radiological labs, their capabilities and response times should be included.
Page.-III-36 lists only several agencies.
Is the State I
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, w'ill 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 OOH contacts the Coast Guard and to which Coast Guard Office he directs his notification.
El.ement
~Ratin
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(Con't)
C.4.
In addition, who will notify the Railroads7 0.
Emer enc Classification S stem 0.3.
A 0.4.
Notification Methods and Procedures E.1..
Specify title of person notifying and being notified.
within the agenices listed on pp. II.I 28-30-.
What are the means for verification of messages7 E.2.
E.5.
A E.G.
In. the event a accident occurred today, describe the administrative and physicaI
- 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.
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Emer enc~
Communications F.l.a.
A F.l.b.
A F.l.c.
Specific communication ties with federal agencies is needed.
F.l.d.
F.l.e.
F.2.
Can not locate any mention of a coordinated communication link for fixed and mobile medical support facilities.
Who is on the 00H emergency medical services?
F.3.
A G.
Public Education and information G.l.
What. are specific educational plans?
How will information be dissemiated?.
Mhat. state individual is responsible of th'e educational program?
Topics in G.I. are not addressed.
I
, E1amant (Cont ')
G.l.
~Rat in Hhat type of program is Parsons preparing for the uti 1 ities?
G.2.
Same as G.I.
6.3.a.
G.4.a.
A G.4.b.
A.
G.4.c.
G.G Plan must address an annual program for the news r
media.
Emeroenc Facilities and Equi ment H.3.
A H.4.
H.7.
During the first few hours of a release, the Stat and local organizations must perform any needed field monitoring without federal.assistance.
E.lement
.(Con't)
H.7.
Ratina 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, 00H states it will provide limited manpower capability with the appropri ate equipment."
How limited?
For how long?
With what equipment?
Will it be adequate?
H.10.
Inventory/quarter not mentioned.
H.11.
H.12.
A Accident Assessment I;7.
Oescribed on pages III 34-37.
However, 1arger equipment such as portable ganma spectrum analyzers, stationary field monitoring equipment, or mobile vans with monitoring equi pment may be available through state and local organizations and if so, should be identified by listing or reference to county plan.
Mill the Brookhaven FREAP team be able to assist soon enough in emergency?
What equipment is available for food, milk, and water monitoring?
Ratina a)
What arrangements have been made to notify field monitoring teams at hove?
How do the teams get to the site?
How do they obtain their equipment?
What are their-communication arrangements with the EOC?
What're.
their estimated deployment times?
b)
What 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 monitor ing 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 I ~
cape. with. both..the emergency.. aad the., fie1.cLmoaitoein.g.'5..
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?
Flan states New York does not have airborne I de-tection capability.
The State does not have its own procedure, but merely references Nureg 1.109 as the-method to be followed.
El ement (Con't)
I.10.
~Rater, The State must develop its cun procedures, patterned after 1.109, if so desired (a quick and easy method of assessment should be used in the heat of battle).
I.ll.
N "Arrangement being made", therefore, unacceptable at this time; Protective Res onse Has yet to be incorporated into the plan.
J.9 Determination of protection actions not possible without I.10.
Capability to conduct sampling (ground and/or aerial sur veillance) has not been established.
Who will do this?
What measures are being considered to ensure that the. response(s) is
( are) actually v.iable?
J.10. a.
Maps missing.
J.10.b.
A J.10.c.
In the event an accident occurred
- today, how will the population in the plume exposure pathway be notified?
J.10.d.
"Currently under development"..
Element Rat in a
J.10.e.
FOA has indicated that this is a State decision and any policy regarding this is at the discretion of the DOH.
J.10. f'.
N Same as J.10.e.
J.10.g.
Agreements with public and private carriers must be obtained.
J.10.h.
Being developed J.10.i N.
Being developed J.3.0. 3.
A J.10.k.
Being developed J.10.1 N
Information missing J.10.m.
N 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.
J.11.
Informati on mi ssing, J.IZ.
This is referenced as."Local Responsibility".
Is that the agreement between State and locals?
, 'lement (Con t)
J.12 Ratina 0
If so, there is a problem, because the county plans do not reference this element.
K.
Radiolo ical Ex osure Control K.3.a.
Mhere 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 procedures for this?
Do the TLO's exist?,
How are the appropriate personnel to obtain their equipment on a 24 hour/day basis?
K.3.b.
This..responsibility is assigned to each agency's radiological liaison or field supervisor?
Have these people been trained and assigned?
K.4.
The final decision maker is the State Comnissioner of Heal'th?
Mho are the other members of the decision chain?
K.5.a.
The specified action levels are unacceptabTe because they are too high.
K.5.b Where are the PNC's, where are central supplies stored
'nd how will they be stocked?
Medical and Public Health Support L.l.
The State plans still.does not descirbe arrangements for local and backup hospital services and the capability for evaluation of'adiation exposure.
The r
Hospital Association of Hew York State has requested a
list of hospitals and special. radiological capability.
?t "is forthcoming."
L.3.,
Same as L.1.
3.4.
Arrangements are stilT not indicated for transporting victims of radiological accidents to medical support facilities.
Agreements are needed.
M.
Recover and Reentr Plannin and Postaccident 0 er ati ons M.l.
Mhat: levels and procedures are used in the decision-making?
M.3.
Plan states the ODP will appoint a committee to make recovery decision.
~Ahat state agencies and representatives will be sitting on this comnittee?
Plan states that a long term oanitoring program will be established.
PI ase 1 aborate.
N Exercises and Orills
'A N.2.a.
N.2.d.
N.2.e.
'Semi-annua1 health physics drill not mentioned.
N.3.a.
N.3.b.
N.3.c.
A N.3.d N.3.e.
N.3.f.
A
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ET'nt R a't 'I ll0 N.5.
0.
Radiolo ical Emer enc
Response
Trainina This section is acceptable, however, specific titles of individuals to be trained should be listed.
P.
Res onsibi1it for the Plannin Effort:
Oevelo ment Periodic Review and Distribution of Emer enc Plans P.l.
Specific titles of individuals responsible for the.
\\
planning effort should be listed.
P.2.
A P.3.
Who in the GOH'?
P.4.
P.5.
A P.6.
A
Element Ratina "Q /
0 P.7.
P-.S.
P.10.
N Emergency telephone numbers must be updated quarter 1y.