ML18101A458

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Forwards from R Meyninger of Fema,Notifying CA Williams,State Director of New Jersey Ofc of Emergency Mgt of FEMA Identified Deficiency for State of New Jersey During 940524 Plant Exercise
ML18101A458
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 01/03/1995
From: Joyner J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Eliason L
Public Service Enterprise Group
References
NUDOCS 9501110158
Download: ML18101A458 (6)


Text

Mr. Leon R. Eliason Chief Nuclear Officer & President Nuclear Business Unit Public Service Electric and Gas Company PO Box 236 Hancocks Bridge, NJ 08038 January 3, 1995

SUBJECT:

UPDATE REGARDING THE FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA)

IDENTIFIED DEFICIENCY FOR THE STATE OF NEW JERSEY DURING THE MAY 24, 1994 HOPE CREEK EXERCISE

Dear Mr. Eliason:

Enclosed is a letter from Dr: Rita Meyninger, Regional Director, FEMA Region II, dated December 6, 1994, notifying Colonel Carl A. Williams, State Director of the Office of Emergency Management, that following further review a Deficiency and a Plan issue are still warranted for the May 24, 1994 exercise performance.

The Deficiency was originally cited under Radiological Emergency Preparedness (REP) Objective 7, Plume Dose Projection, against the New Jersey Bureau of Nuclear Engineering (NJBNE).

However, after further review, it was decided to withdraw the Deficiency against NJBNE and to issue the Deficiency under REP Objective 9, Protective Action Decision Making, against the New Jersey Office of Emergency Management and NJBNE.

Please provide assistance to offsite officials to address and resolve the identified Deficiency on a timely basis. The 120-day time limit for correction of the deficiency by New Jersey has been res~t to begin December 6, 1994, the date of the FEMA letter.

If you or your staff have any questions concerning the enclosure, please contact me at (610) 337-5370.

Enclosure:

As Stated Docket Nos. 50-272 50-311 50-354 9501110158 950103 PDR ADOCK 05000272 F

PDR Sincerely, Original Signed By:

J:Jmes H. Joyner James H. Joyner, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards

Mr. L. R. Eliason 2

cc w/encl:

J. J. Hagan, Vice President-Operations/General Manager-Salem Operations S. LaBruna, Vice President - Engineering and Plant Betterment C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co.

R. Hovey, General Manager - Hope Creek Operations F. Thomson, Manager, Licensing and Regulation J. Robb, Director, Joint Owner Affairs A. Tapert, Program Administrator A. Giardino, Acting Manager, Quality Assurance B. Hall, Acting Manager, Nuclear Safety Review R. Fryling, Jr., Esquire M. Wetterhahn, Esquire P. J. Curham, Manager, Joint Generation Department, Atlantic Electric Company Consumer Advocate, Office of Consumer Advocate William Conklin, Public Safety Consultant, Lower Alloways Creek Township Public Service Commission of Maryland State of New Jersey State of Delaware

Mr. L. R. Eliason 3

Distribution w/encl:

Region I Docket Room (with concurrences)

Kay Gallagher, DRP D. Screnci, PAO (2)

PUBLIC Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Distribution w/encl: (Via E-Mail)

L. 01 sh an, NRR D. Moran, Project Manager, NRR W. Dean, OEDO J. Stolz, PDI-2, NRR M. Shannon, ILPB M. Callahan, OCA DOCUMENT NAME:

G:\\FRSSB.GRP\\NJDEF.UPD To receive a copy of this document, Indicate In the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI:DRSS 1c-RI : DRSS //' I /JI RI:DRSS 1,.1 I

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DATE 12/.'.)1 /94 12/

/94 12/30 /94 v OFFICIAL RECORD COPY I

Federal Emergency Management Agency Region II 26 Federal Pl37.3. Room 1337 New York, NY 10278-0002 Colonel Carl A. Williams, State Director Off ice of Emergency Management State of New Jersey Department of Law and Public Safety Division of State Police P.O. Box 7068 West Trenton, New Jersey 08628-0068

Dear Colonel Williams:

DEC - 6 1994 This letter responds to the concerns which have been raised relative to the Deficiency identified under Objective 7, Plume Dose Projection, Emergency Operations Facility (EOF), during the May 24, 1994, Artificial Island Radiological Emergency Preparedness (REP)"

exercise.

Specifically, the Federal Emergency Management Agency (FEMA) has considered the letter and enclosed material, dated June 28, 1994, received from Dr. Gerald P. Nicholls, Director, New Jersey Department of Environmental Protection and Energy, your letter dated July 6, 1994, regarding revision to the Radiological Emergency Response Plan, and a draft letter from Dr. Nicholls, dated August 9, 1994, containing additional supporting information.

FEMA has also discussed the exercise events surrounding the assessment of this Deficiency with the FEMA evaluators who were at the EOF and the State Emergency Operations Center ( SEOC), and thoroughly reviewed the documents generated during the exercise.

In addition, FEMA ha~ had two meetings with its technical consultants and the U.S. Nuclear Regulatory Commission to discuss this Deficiency.

As a

result of this re-analysis, we have concluded that a Deficiency and a Plan Issue *are still warranted.

FEMA also concluded that discussions in our previous letters of June 10, 1994, and July 20, 1994, may not have been clear.

The untimely State decision to evacuate is the basis for FEMA's finding of a Deficiency..

The problem lies in the process that led to an untimely decision to evacuate and the responsibility to correct that process lies with the New Jersey Office of Emergency Management and New Jersey Bureau of Nuclear Engineering (NJBNE).

It is the opinion of FEMA that the untimeliness of the decision making process with respect to evacuation resulted in the potential for endangerment of the public health and safety due to unnecessary radiation exposure.

The Deficiency will be placed in the Post Exercise Assessment under Section 2.1.1, State of New Jersey, State Emergency Operations Center, under Objective 9, Protective Action Decision Making.

The* previous Def.icien.cy assessed to. the NJBNE staff under. Object.iv~

.. 7,. Plume. Dose P:i;oj*ection,.. is :.~ithdrawn.*

Presented below is an overview of the basic exercise facts regarding the timeliness of the decision-making process during this exercise.

The times reflected below were taken from FEMA' s timeline of exercise events, as recorded by the exercise evaluators at the EOF and the SEOC.

1.

A General Emergency (GE) was declared at 2000, indicating that plant conditions were degrading and, that if a release of radioactivity did occur, the Protective Action Guidelines (FAG) would likely be exceeded.

2.

Protective Action Recommendations (PAR) from the Utility were issued at 2007 and again at 2045 calling for evacuation.

3.

At 2027, the NJBNE issued a PAR to shelter all sectors in the emergency planning zone (EPZ), zero to five miles.

At 2045, the State (SEOC) decision to shelter was made.

4.

The release began at 2045. *

5.

By 2100, the source term was significant enough to result in a projected dose at five miles of 1.2 rem Total Effective Dose Equivalent.

The projected dose was more than the PAG of 1 rem, warranting evacuation.

6.

At 2141, the NJBNE issued a PAR calling for the evacuation of all sectors in the EPZ, zero to five miles.

By this time, the plume had reached the inhabited portions of the EPZ.

7.

At 2150, the SEOC issued a Protective Action Decision (PAD) to evacuate.

The basis for adequate emergency reponse is to make PADs, if possible, before exposures to the population can occur. Even after the State was aware of the release to the environment, no evacuation decision was made for over an hour.

The delay in the State's decision to evacuate would have resulted in exposure to the population which could have been reduced or avoided.

Regarding Dr. Nicholls letter of June 28, 1994, we agree that the EOF team considered the Utility's PAR in its PAR development process. Also, it is quite correct that the New Jersey Department of Environmental Protection and Energy should perform its own assessments of the emergency conditions of the nuclear power plant and form its own independent dose projections.

This is not an issue nor is it to be jeopardized.

FEMA did not mean to imply that Utility PARs are to be followed blindly, or that Utility PARs should override State PARs, or that Utility PARs are more accurate and important than State PARs.

However, when the Utility recommends evacuation and then confirms and extends its PAR, this should bring a sense of urgency to the

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protective action decision making proceedings.

This should be interpreted to mean that there is a significant potential for the major release of radionuclides into the environment.

Please respond to Stanley Mcintosh, Regional Assistance Committee (RAC) Chairperson, at (212) 225-7204 with the date and time of the pertinent remedial actions and the involved State and county participants within 45 days from the date of this letter. Because of the potential impact of a Deficiency on the protection of the public health and safety, it should be corrected within 120 days from the date of this letter.

FEMA, if requested and with assistance from K.L.

Travis Associates, will be pleased to work w~th you and your staff on the necessary remediations.

If there are any questions regarding FEMA's decision relative to this Deficiency and Plan Issue or the proposed corrective actions, please contact Stanley Mcintosh, RAC Chairperson, at (212) 225-7204.

Sincerely,

~

.R@~/!f}!jp~f1 Regional Director 3