ML19346A136
| ML19346A136 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/24/1981 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Pollock M LONG ISLAND LIGHTING CO. |
| Shared Package | |
| ML19346A135 | List: |
| References | |
| NUDOCS 8106050232 | |
| Download: ML19346A136 (31) | |
Text
.
8
'o UNITED STATES kJ ' g(
g NUCLEAR REGULATORY COMMISSION t
j REGION l 8
631 PARK AVENUE 4
,o KING OF PRUSSIA, PENNSYLVANIA 19436 Docket No. 50-322 2 4 APR 1981 Long Island Lighting Company ATTN: Mr. M. S. Pollock Vice President - Nuclear 175 East Old Country Road Hicksville, New York 11801 Gentlemen:
Enclosed for your information is the text of a letter and attachments that were mailed to all operating power reactor licensees in the State of New York.
This is transmitted to you for information only.
Sincerely,
'8 Boy H. Grier Director
Enclosures:
As Stated cc (w/encis):
J. P. Novarro Project Manager E. M. Barrett, Esquire E. J. Walsh, Esquire T. F. Gerecke, Manager, QA Department l-819605023 2
Dear :
We have received the attached Federal Emergency Management Agency (FEMA) letter dated April 23, 1981, and the attached letter from CEMA to the New York State Disaster 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 reacter shall be shut down until such deficiencias 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 pericd allowed for correcting the deficiencies.
You are requested to submit a written statement to this office within 30 da/s of the date of this letter, describing plans for correcting each of the 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 observations of the annual joint exercise, and onsite inspections of your emergency preparedness.
4 Sincerely, l
Boyce H. Grier Director
Enclosures:
As Stated
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I Y
FEDERAL EMERGENCY MANAGEMENT AGENCY l
\\j' Region !!
25 Federal Plaza New York, New York 10278 m
April 6, 1981 Mr. W4114== C. Hannassy, Ch=4 - ="
Disaster Preparedness Commission Staca of New York Public Securiev En41A4ng Stata Campus Albany, New York 12226 RE:
Review of New York State Radiological
Dear Mr. Hennessy:
Emergency Preparedness (REP) Plan The Regional Assistance Commit'taa (RAC), less the U.S. Department of Energy, has revie ed the draft State Radiological Emergency Preparedness (REP) Plan, using the planning standards contained in FEMA REP-1/NUREG-0634.
The detailed comments are attached.
While we recognize that.the December 1980 draft submission was prepared in accordance with the ' Interim" edition of FEMA REP-1, we evaluated the State Plan against cha."Ravi:.icn 1" edition of the planning standards, which clarified several issues contained.in the incarim edition.
Therefore, the RAC's detailed comments regarding the Stata Plan are based on the revised standards.
1 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=ission had no county plans prepared in accordance with FEMA REP-1 standards.
The December 1980 draft contains a State level plan and seven county plans.
The steady pro-grass made is 4"d4"tive 'of the commitment by the Sta:e and local govern =ents towards radiological emergency preparedness for commercial nuclear power plant eccidents.
Indeed, the Nuclear Planning Group should be commanded for the cnargias and atta1= ment of its goal in its timely furnishing to the RAC a draf: of all Stata and local plans for locations with operating nuclear reactors.
Moreover, we expect that significant and substantive improvenants to the sub-mitted. plan have already been made.
However, the RAC found iJ very time consuming to perform the review due to in~ accurate cross-refarencing and hasty editing.
Consequently, the RAC expended a great deal of ci.ne trying to locate various portions of the plan that address the, specific planning critaria.
In sunmary, deficiencias in the plan fall into three broad categories.
a.
Whila we recogni=a the State's efforts to reconcile the confflict between Stata and county authorities and responsibilities pertain 1=g to radiological emergency preparedness, with proposed enac::mants such as the " Fink Bill,"
thir deficiency, nonetheless, parvades the' plan.
Un'til resolution to this fundamental planning consideration is attained, the plan will remain deficient, even if all other pT=aning standards are adequately addressed.
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/ A7 2-Mr. William C. Hennessy b.
The Plan still lacks specificity in many cases.
Methodologies and decision-making processes for the following planning standards require further articulation:
emergency response support, notification methods and proceduras, public education, accident assessment, radiological i
exposure control, medical and health support, and recovery and re-entry operations.
Cross references should clearly identify alaments of the plac as they relate to the p1=an4ag standards.
c.
Certain planning critaria have not been addressed in the submission.
Letter agreements with Faderal agencies and non-government organizations were missing.
Means for relocation have not yet been inecrporated in the Plan.
Related maps and charts are missing.
A program for permanent record devices has not been, developed., All planning criteria listed' in FEMA REP-1/
NUREG-0654, should be addressed in the plan.
The detailed comments that the RAC has provided, coupled with a meeting you may raquest:to discuss these comments, should serve to identify the revisions nocessary in the State Plan.
W2 ask that, upon completion of these revis' ions, the Governor apply for formal review and approval of the State Plan, site specific to each reactor location in order of Stata priority.
Each submission should be prepared 'and furnished in accordance with Section 350.7, FDfA Proposed Rule 44 CFR 350.
Requests.,for additional informal reviews will only delay the review process.
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j, Vincent ' Forda 7.<
Acting.Ragional Director 3
l Artachments
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'. 4 RAC CD.SNENTS ON NEW YORK COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN DECEMSER 1980 LEGEND:
A - ADEQUATE N - INADEQUATE ELEMENT RATING 1
A.
Assignment of Responsibility (Organization Control)
A.l.a.
N The relationships between the State and the Counties have yet to be resolved.
A.l.b.
N Same comment as above.
A.l.c.
N Block diagram not present.
A.l.d.
N Same comment as A.l.a.
A.l.e.
A A.2.a N
Key individuals by title are not always specified.
Table III-l is missing except in Wayne and Monroe County plans.
A.2.b A
A.3.
N 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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RATDIG ELEMENT (Con't)
A.3.
N Also, agreements with non-public suppport organization, such as his companies and their unions, must be included.
A.4.
A C.
Emergency Response Support and Resources C.I.C A
Should be better references between ple:: and procedures.
C.2. a.
A C.4 N
Letters of agreement not present, particularly with respect to non-public support organizations O.
Emergency Classification System 0.3.
A D.4-A 9
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3-ELEENT RATING E.
Notification Methods and Procedures E.1.
A While adequate, as is, Figure III-2 is missing.
E.2.
A Figure III-2 missing.
E.5.
N Need better indication as to how information will be disseminated.
E.6 N
A more complete set of prepared messages are needed which would insure that news annou.ncements for various sets of conditions are readily available.
E.7.
N Same comment as above.
F.
Emergency Communications F.1. a.
A But figure III-2 is missing.
l F.1.b.
A Same as above.
l F.1.c.
N Communications ties with Federal agencies must be specified, particularly the Coast Guard.
e
e O
'. ELEMENT RATING 1
F.1.d.
N Means for communicating with radiological monitoring teams in the field must be specified.
F.1.e.
A But figure III-2 is missing F.2.
h No provision for communications with mobile medical support facilities.
F.3.
A G.
Public Education and Information G.I.
N See corresponding comment for State Plan.
G.2.
N Same comment as above.
G.3. a.
A G.4.a.
A G.4,b.
N Must be more specific on communications system and procedures necessary to achieve coorcination.
G.4.c.
N This criteria is not listed in the cross-reference index and does not appear in sections dealing with public information.
t l
n
O V..
ELEMENT RATING G.5.
A H.
Emergency Facilities and Ecuicment H.3.
A 4
H.4.
A H.7.
N See coments for State Plan.
H.10.
N No refeyence to this criterion was found.
H.11.
A Except for Wayne Co, where applicable appendix still under development.
H.12.
A I
Accident Assessment I.7.
N While plan states that resources are limited, it does not describe what resources and capabilities currently exist.
Also, see coments for State Plan.
I.8.
N See coments for State Plan.
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l ElkMENT RATING J.
Protective Resoonse J.2.
N Not yet incorporated ~ into Plan.
J.9.
N See connents for State Plan.
J.10. a.
N Maps missing or are incomplete.
J.10.c.
N Appendix G must be updated to reflect change in NUREG-06S4 (notification time). While Appendix G discuss options, actual plans and proce'dures have not yet been established.
J.10.d.
A J.10.e.
N Use of radioprotective drugs not' discussed.
Also, see comments for State flan.
J.10.f.
N Same as above.
J.10.g N
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.
N Still not complete.
t O
l Q
Q 7-ELEMENT RATING J.10.j.
A J.10.k.
A But various attachments in implementing procedures in some county plans must be completed.
J.10.1.
A For all county plans except for Monroe and Wayne.
J.12.
N No provision for registering and monitoring evacuees.
K.
Radiological Exposure Control K.3. a.
N See comments for State Plan.
4
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K.3.b.
N See connents for State Plan.
K.4.
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.
N See comments for State Plan.
K.5.b.
N See connents for State Plan.
L Medical and Public Health Succort e
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ELEMENT RATING J
L.1 N
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.
N - Guidelines for Treatment and Transportation of Potentially Contaminated Injured People is blank.
Also, formal agreements are needed with carriers and their unions.
M.
Recovery and Reentry Planning and Postaccident Operations M.l.
N Specific procedures that address decisions to relax protective measures are missing.
N.
Exercises and Dril's N.l.a.
A N.l.b.
N No provision for exercise once every six years between 6:00 pn and midnight and midnight and 6:00 am.
N.2. a.
A Except for Putnam, Oswego, Monroe and Wayne Counties, m
ELEMENT RATING (Con't)
N.2.a.
A which have no specific procedures for exercises and drills.
I N.2.c.
A Same as N.2.a.
N.2.d.
A Same as N.2.a.
N.3. a.
N Not yet present.
,N.3.b.
N Not yet present.
N.3.c.
N Not yet present.
N.3.d.
N Not yet present.
N.3.f.
N Not yet present.
N.4.
A N.S.
A O
Radiological Emergency Resoonse Training 0.1.
A
Elb4ENT RATING U
U 0.1.b.
A Except for Putnam, Monroe and Wayne Counties which have no specific procedures for training.
0.4. a. -j.
N Plans and procedures r.ot specif1c 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.
Responsibility For The Planning Effort: Development2 Periodic Review and Distribution of Emergency Plar.s P.l.
N Section II-8.5. not specific enough.
P.2.
A P.3.
A l
l 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
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- ELIMENT RATING P.7.
A Same as P.4.
P.8.
N Must list implementing procedure; in Table of Contents and improve page numbering system.
P.10.
N This criterion was not listed in draft NUREG -0654.
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RAC C0FRENTS ON TriE STATE OF NEW YORK RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR NUCLEAR POWER PLANTS (STATE LEVEL PLANS)
DECEMBER 198d LEGEND:
A - ADEQUATE N - INADEQUATE ELEMENT' RATING s
A.
Assianment of Responsibility (Orcanization Control)
A.l. a.
N The relationships between the State and the Counties have yet to be resolved.
A.l.b.
N Identify all private sector organizations to be used for back-up support i
A.l.c.
A A.l.d.
N Phone numbers and titles of individuals in charge and backups should be included.
This may be incorporated l
into a separate booklet, since certain phene numbers are sensitive.
A.l.e.
A A.2.a N
Each organiz& tion shall specify a key individual by title.
o e
7 j
ELEMENT 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.
Emergency Response Support and Resources C.l. a.
N 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 Rad'ological Emergency Preparedness i
and Response Plan for commercial nuclear power plant accidents (Master Plan - 12/23/80 in Federal Register).
Also, who. in the DOH will notify FR&AP?
C.1.b.
N Federal resources times of arrival should be included.
C.l.c.
N A)
Land lines appear to be the major communication system.
Are these dedicated phone lines with separate trunks?
If not, what are the alternatives if they are not available?
Element Ratina (Con't)
C.1.c.
N B)
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 en Federal Agencies for aerial assessment.
Discussion of radio frequencies is essential to assess ability for inter-agency connunication.
+
C.2. a.
N
, C.3.
N Any and all private radiological labs, their capabilities and response times should be included.
Page-III-36 lists only several agencies.
Is the State lab the only facility in stite other than Feds?
C.4 N
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.
e
Elemenc Rating (Con't)
C.4.
N In addition, who will notify the Railroads?
D.
Emergency Classification System D.3.
A l
l D.4.
A E.
Notification Methods and Procedures E.1.
N Specify title of person notifying and being notified within the agenices listed on pp. III 28-30.
What are the means for verification of messages?
E.2.
A E.5.
A E.6.
N In the event a accident occurred today, describe the administrative and physical means, ang the time required for notifying and providing prompt instructions to the public within the plume exposure pathway.
E.7 N
Does not include respiratory protection.
U V
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" Elcment Rating F.
Emergency Cor::tunications F.1. a.
A F.1.b.
A F.1.c.
N Specific comunication ties with federal agencies is needed.
F.1.d.
A F.1.e.
A F.2.
N 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.I.
N What are specific educational plans? How will information be dissemiated? What state individual is responsible of the educational program? Topics in G.I. are not addressed.
u
R
/
' Element Rating (Cent')
I G.l.
N What type of program is Parsons preparing for the utilities?
G.2.
N Same as G.I.
G.3.a.
A G.4. a.
A G.4.b.
A.
'G.4.c.
A G.5 N
Plan must address an annual program for the news media.
H.
Emergency Facilities and Ecuioment H.3.
A H.4.
A H.7.
N During the first few hours of a release, the State and local organizations must perform any needed field monitoring without federal. assistance.
ETement Ratina
-(Con't)
H.7.
N The pian must discuss the adequacy of calibrations, security from damage, accessibility to monitoring teams, or ability to measure potential principle exposure pathways.
In addition, DOH states it w'ill provide "_ __ __ limited manpower capability with the appropriate equipment." How limited?. For how long?
With what equipment? Will it be adequate?
H.10.
N Inventory / quarter not~ mentioned.
H.ll.
A H.12.
A I
Accident Assessment I.7.
N Described on pages III 34-37.
However, larger equipment such as portable gama spectrum analyzers, stationary field monitoring equipment, or mobile vans with monitoring equipment may be available through l
state and local organizations and if so, should be identified by listing or reference to county plan.
Will the Brookhaven FR&AP team De able to assist soon l
l enough in emergency? What equipment is available for food, milk, and water monitoring?
l l
l
El'em!nt Ratina I.8.
N a)
What arrangements have been made to notify field monitoring teams at 'home?
How do the teams get to the site?
How do they obtain their equipment? What are their connunication arrangements with the EOC7 What are 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 monitoring teams or just the Indian Point NGS?
If just IP, what arrangements have been made at the other NFO's? ~ Will the NFO's have sufficient personnel to cope.with, bath. the_ emergency. and. tha. fteld_maattoring1.
Are off-shift personnel to be used?
If so, how are they notified?
I c)
What, if any, fixed monitoring stations are available? Have monitoring locations been site-selected?
I.9.
N Flan states New York oces not have airborne I de-tection capability.
I.10.
N The State does not have its own procedure, but merely references Nureg 1.109 as the method to be followed.
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Elem:nt Rating (Con't)
I.10.
N The State must develop its cwn 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.
J.
Protective Response J.2.
N Has yet to be incorporated into the plan.
J.9 N
Determination 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 viable?
J.10. a.
N Maps missing.
l 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?
J.10.d.
N
" Currently under development".-
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Element 3&i,n3 J.10.e.
N FDA 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.
N Agreements with public and private carriers must be obtained.
J.10.h.
N.
Being developed J.10.1 N.
Being developed J.10.j.
-A J.10.k.
N Being developed J.10.1 N
Information missing J.10.m.
N Flow chart is good, however, it is not clear how the criticai decisions at 4 and 6 are to be made, i.e.
shelter vs. evacuate.
J.ll.
N Information missing J.12.
N This is referenced as."Lccal Responsibility".
Is that the agreement between State and locals?
O
- Element Ratino
( Co.n ' t )
J.12 N
If so, there is a problem, because the county plans do not reference this element.
K.
Radiological Excosure Control K.3. a.
N Where is the program for permanent record devices (i.e., film badges, TLD)? Appendix G, 3-2 assigns each agency's radiological liaison to obtain and prepare records. Are there' procedures for this? Do the TLD's exist? How are the appropriate personnel to obtain their equipment on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day basis?
K.3.b.
N This responsibility is assigned to each agency's radiological liaison or field supervisor? Have these people been trained and assigned?,
K.4.
N The final decision maker is the State Comissioner of Health? Who are the other members of the decision chain?
K.S.a.
N The specified action levels are unacceptable because they are too high.
K.S.b N
Where are the PMC's, where are central supplies stored and how will they be stocked?
ctement xatina L'
Medical and Public Health Supoort L.l.
N The State plans still.does not descirbe arrangements for local and backup hospital services and the capability for evaluatien' of radiation exposure.
The Hospital Association of New York State has rr. quested a list of hospitals and special radiological capability.
It "is forthcoming."
L.3.
N Same as L.l.
1 L.4.
N Arrangements are still not indicated for transporting,
victims of radiological accidents to medical support facilities.
Agreements are needed.
M.
Recovery and Reentry Planning and Postaccident Operations M.l.
N What levels and precedures are used in the decision-l making?
I
(
M.3..
N Plan states the 00P will appoint a committee to make recovery decision.
What state agencies and represen'tatives will be sitting en this committee?
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.. : rement n e. my MA.
N Plan states that a long term monitoring program will be established.
Please elaborate.
N Exercises and Drills N.l.a.
A N.I.b.
' A N.2. a.
A N.2.d.
A
~
N.2.e.
N Semi-annual health physics drill not menticned.
N.3. a.
A I
N.3.b.
A i
i N.3.c.
A i
9 N.3.d A
1 l
l N.3. e.
A N.3.f.
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N.S.
A O.
Radiological Emergency Resoonse Training This section is acceptabie, however, specific titles of individuals to be trained should be listed.
P.
Responsibility for the Planning Effort:
Development, Periodic Review and Distribution of Emergency Plans P.l.
N Specific titles of individuals responsible f6r the planning effort should be listed.
P.2.
A P.3.
N Who in the DOH?
F.4.
A P.5.
A P.6.
A 1
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'. Element Ratinc P.7.
A P.8.
A P.10.
N Emergency telephone numbers must be updated quarterly.
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wx FEDERAL EMERGENCY MANAGEMENT AGENCY
'Ns Washington O.C. 2047?
April 23,198i M H0HAN00H FOM:
Brian Grime gula [ C US Nuclear inaion FRON:
Jonn E. Dicke' o
Director. Radio 1, cal mergency Preparednese Division
's f
SueJECT:
Federet Emergency Management Agency (FEMA) Support for Indian Point Nuclear Power Station i
Reference is made to my menorednum of Apett 2.1981, subject as above.
In accordance with your discuselon with my staff on Apell 22. 1981, and your request, attached is a copy of the Regional Assistance Committee (RAC) from FEMA Region II review of the ' draft New York State Radiological Emergency-Preparedness (REP) Plan including the "destchester County plan.
In summary.
the deficioneles in the Plan fall into three broad categories se listed in the RAC review memorandum of April 6.1981.
Our conclusione stated in my April 2.1981 memorandum still stand.
Unless there is some unforeseen development. I do not expect to provide you any further information on Hey.15.
Attachment as stated
-.