ML20010E563
| ML20010E563 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/30/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML100540437 | List: |
| References | |
| NUDOCS 8109040269 | |
| Download: ML20010E563 (40) | |
Text
l l
i APPENDIX C I
1 EMERGENCY PREPAREDNESS EVALUATION REPORT BY THE i
DIVISION OF EMERGENCY PREPAREDNESS i
0FFICE OF INSPECTION AND ENFORCEMENT U. S. NUCLEAR REGULATORY COMMISSION l
IN THE MATTER OF I
INDIAN POINT STATION 4
l UNITS 1 & 2 l
DOCKET NOS. 50-3, 50-247 JUNE 1981 i
i i
i Appendix C l
consists of I
40 Pages t
8109040269 810821
- " ^*" ""
9
INTRODUCTION The Consolidated Edison Company of New York (hereinafter referred to as the licensee or Con Edison) filed with the Nuclear Regulatory Com-i mission revisions c6 the Indian Point 1 & 2 Emergency Plan dated December 30, 1980, February 26, 1981, and June 1, 1981.
The plan was reviewed against the sixteen planning standards in r
Section 30.47 of 10 CFR Part 50, the_ requirements of Appendix E to 10 CFR Part 50, and the criteria of NUREG-0654/ FEMA-REP-1, Revision 1 entitled " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.
This evaluation report fcilows the format of Part II of NUREG-0654 in that each of the Planning Standards is listed and fo' lowed by a summary.
of the applicable portions of the plan and the deficiencies that relate to that specific standard. The final section of this report'provides our conclusions.
A separate report will.be issued describing the findings and. determinations of the Federal Emergency Management Agency on'the State and local emergency response plans.
f h
y-EVALUATION A.
ASSIGNMENT OF RESPONSIBILITY (0RGANIZATION CONTROL)
Planning Standard Primary responsibilities for emergency response by th. nuclear facility licensee, and L, State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on 1 continuous basis.
Emergency Plan:
o The Feceral, State, and local and private sector organizations that are intended to be part of the overall response organization for Emergency Planning Zones are identified. The principal State agency responsible for radiation accident emergency planning and response is the New York State Department of Health. The plan notes that' specific tasks and responsib.lities assigned to various departments and agencies of the State are delineated in the New York State Radio-logical Emergency Preparedness Plan, which has been submitted to NRC and FEMA. The responsibilities of the four New York counties, Westchester, Rockland, Orange, and Putnam, are briefly described and reference is made to the four County Radiological Emergency Response Plans which have been submitted to NRC and FEMA. Federal support from 00E'and the U.S. Coast Guard is described. Private sector services which are available are indicated, such as a private laboratory and
A.
ASSIGNMENT OF RESPONSIBILITY (0RGANIZATION CCNTROL) the NSSS supplier (Westinghouse), as well as the Power Authority of the State of New York which operates Unit No. 3 at Indian Point.
o A concept of operations and its relationship to the total effort is specified. The interrelationships are illustrated in Figure 5.2.2 of the onsite emergency plan.
o The Recovery Manager is identified as the person who will assume over-all direction and control if the Corporate Emergency Response Plan is activated. The Plant Operation Manager and the Emergency Director are in charge of the operational and radiological aspects, respectively.
o 24-hour per day emergency response, inc~.uding 24-hour per day manning of communication links, is provided.
o Written agreements from Federal, State and local agencies and other support organizations having an emergency response role within the EPZ's are included in the plan.
The plan describes the role of each of the agencies with which there are agreements in relation to the role of the plant and this concept of operations is reflected in the content of the letters of agreement.
o The Office in Charge of Power Generation, who takes the title of Recovery Manager for emergency response operations, will assure the continuity of resources (technical, administrative, and logistics) to
A.
ASSIGNMENT OF RESPONSIBILITY (0RGANIZATION CONTROL) (Cont.)
support the emergency response.
It is stated that Con Edison is capable of continuous (2a hour) operations for a protracted period.
Deficiencieg 1.
In a recent revision to the indian Point 2 emergency plan, the Officer in Charge of Power Generation (Recovery Manager) has been eliminated from the figure which depicts the interrelationships of the station management and operations staff'. The figure should be revised to include this position as well as the interface with the station watch organization.
B. ONSITE EMERGENCY ORGANIZATION Planning Standard On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the inter-faces among various response activities and offsite support and response activities are specified.
Emergency Plan:
o The onsite emercency organiz0 tion of plant personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement are specified. Plant staff emergency assignments are described.
o The Con Edison positions of Emergency Director and Plant Operations Manager correspond to the position title specified in NUREG-0654 as Emergency Coordinator. The plan states that the Watch Supervisor has the authority to initiate emergency actions until relieved. such duties by the Plant Operations Manager and the Emergency Director.
The Emergency Director is specified as having the responsibility and authority to provide protective action recommendations to offsite autho"ities.
8.
ONSITE EMERGENCY ORGANIZATION (Cont.)
i o The line ci succession for the Plant Operations Manager (the General Manager, Nuclear Power Generation) is identified as the Plant manager and then the General Manager, Administrative Services. The Plant Operations Manager also assumes the role of Recovery Manager except in the event of a Site Area or General Emergency.
If the Corporate Emergency Response Plan is activated, the Officer in Charge of Power J
}
Generation or his designee becomes the Recovery Manager and assumes overall direction and control.
o The functional responsibilities assigned to the Plant Operations f% ager i
and the Emergency Director are specified.
It is stated that the Emergency Director may not delegate the responsibility for making protectiva action recommendations to offsite authorities.
[
o The positions or title and major tasks to be performed by the persons j
to be assigned to the functional areas of emergency activity are i
specified. The plan indicates that minimum on-shift staffing levels can be augmented within 60 minutes to levels specified in Table B-1 of NUREG-0654.
1 o The interfar.es between and among the onsite functional areas of emergency activity and the offsite emergency organization made up of corporate support, local services support, and State and local govern-ment response organizations are specified. A block diagram is provided l
in Figure 5.2-2 of the plan.
i l
m
B.
Ot4 SITE EfiERGENCY ORGANIZATION (Cont.)
o The corporate management, administrative, and technical support personnel who will augment the plant staff as specified in Table B-1 of NURLG-0654 and also in the areas of logistical and technical support are indicated.
o The contractor and private organizations who may be requested to provide technical assistance to and augmentation of the emergency respuase organization are specified, o The services to be provided by local agencies for handling emergencies, including police, ambulance, medical hospital, and fire-fighting organ-izations are specified.
Copies of letters of agreement with these organizations as well as letters of agreement with Westinghouse Electric Corporation (the :455S supplier) and with Teledyne Isotopes are appended to the plan.
Deficiences:
1.
The plan shculd explicitly provide for an individual who shall always have authority and responsibility for overall direction and control of the emergency response effort.
It appears that this is ambiguous between the time the watch supervisor is relieved of these duties in part by either the Plant Operations Manager or the Emergency Director and the arrival of the Recovery Manager for Site Area and General
B.
ONSITE EMERGENCY ORGANIZATION (Cont.)
Emergencies.
It is also misleading that th's role is never fulfilled by the Emergency Director.
It is recommended that the titles of the key individuals be changed to more clearly coincide with their func-tional responsibilities during emergencies.
- 2. The line of succession should be more explicitly defined for the Emergency Director. Since any number of persons can assume this role, including those specifically designated for the Plant Operations Manager position, it appears that the current arrangement could result in considerable confusion under c;iergency conditions. The plan is not clear as to whether or not the same individual may simultaneously fulfill the roles of the Emergency Director and the Plant Operations Manager.
- 3. Since the decision to notify and to recommend protective actions to authcrities rerponsible for offsite emergency measures may not be delegated by the responsible individual, it is questionable that this function has been vested in the Emergency Director who at no time has I
authority and responsibility for directing the overall emergency re-r sponse effort. This function should be assigned to the positions having
(
the overall direction and control of the integrated emergency response
(
effort, commencing with the watch supervisor and continuing through his successors.
i I
r l
B. ONSITE EMERGENCY ORGANIZATION (Cont.)
4.
The plan should provide a commitment that the minimum staffing requirements including the times for augmentation from offsite personnel will be as specified in Table B-1 of NUREG-0654, Rev. 1 by July 1, 1982, 5.
The near-site Emergency Operations Facility required by Appendix E to 10 CFR Part 50 is currently being provided by two separate tacilities, namely the Con Edison Emergency Control Center and the Recovery Center.
Although this arrangement appears satisfactory for the interim, final acceptance will be based upon our review and evaluation with respect to NUREG-0696.
6.
The letter of agreement with the ambulance service should state the willingness and capability to transport contaminated patients. The letter of agreement with the Buchanan Fire Department requires a signature by the person authorizing the agreement. The Memorandum of Understandir.g with PASNY should be reviewed and updated since the current MOU is dated 1/23/78. Provide a copy or schedule for the agreement with the Northern Westchester Hospital Center.
l t
f l
m a
C. EMERGENCY RESPONSE SUPPORT aND RESOURCES Planning Standard Arrangements for requesting and effectively using assist'ance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.
o The Fmergency Director is specified as the person authorized to request Federal assistance under the Radiological Assistance Plan.
o The Emergency Director is designated to receive responding representa-tives from cffsite emergency agencies and assist ir) their information and communication needs.
o The Emergency Director will send one of his staff to the Principal Emergency Omrations Center to perform liaison duties during Site j
Area and General En<ergencies.
o An offsite vendor's laboratory is identified and its general cap-abilities and availability to provide radiological monitoring and analyses services are specified in a written agreement.
C. EMERGENCY RESP 0f1SE $!PPORT AND RESOURCES (Cont.)
o fluclear and other facilities, organizations or individuals which can be relied upon in an emergency to provide assistance, including, medical, and radiation management capabilities are identified.
Letters of agreement are appended.
Deficiencies:
1.
The plan states that Federal Response in the form of RAP /IRAP is not anticipated; therefore, no arrangements have been made. Since some accidents may require the assistance provided by DOE through the Federal Radiological Monitcring and Assessment Plan (formerly RAP /IRAP) and since such activities may require courdination and integration with licensee efforts, the plan should provide for such arrangements.
2.
The plan should specify the principal offs'te Emergency Operations Center to which the Emergency Director would dispatch a company representative.
- 0. PLANNING STANDARD A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information'provided by facility licensees for determinations of minimum initial offsite response measures.
Emergency Plan:
o The licensee has established an emergency classification and emergency action level scheme compatible with the scheme set forth in Appendix 1, NUREG-0654, Rev. 1.
i o
Specific instruments, parameters or equipment status for each emergency class is established in the emergency procedures and in the plan.
o Postulated accidents (Section 14 of the FSAR) and the example initiating conditions in Appendix 1, NUREG-0654, Rev. 1 are covered in Table 4-1 of the plan.
1 Deficiencies:
1.
Emergency Action Levels should be established for the initiating-conditions 13.b under Site Area Emergency and 1.b under General
D. PLANNING STANDARD (Cont.)
Emergency as specified in Appendix 1 to NUREG-0654. These EALs should be based on in-plant parameters such as containment activity and pressure.
E. NOTIFICATION METHODS AND PROCEDURES Planning Standard Procedures have been established for notification, by the licensee of State and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and followup messages to response organizations and the public has been estab-lished; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.
Emergency Plan:
o Procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classifica-tion and action level s,. heme, including neans for confirmation, are established.
o Procedures for alerting, notifying and mobilizing emergency response personnel are established, including means of notifying on-site staff and off-shift personnel as needed for minimum emergency staffing levels.
o The contents of the initial emergency message to be sent from the plant are established.
E.NOTIFICATIONMETHODSANDPROCEDURES(Cont.1 o
The contents of followup messages to provide appropriate information to offsite authorities are established, o
The population-at-risk in the plume exposure EPZ will be notified by State and/or local agencies. County plans containing information on offsite protective actions have been submitted to NRC and FEMA.
o The licensee will provide supporting information to offsite authorities for use in messages to the public giving instructions with regard to specific protective actions to be taken by occupants of affected areas.
Deficiencies:
- 1. The contents of the initial emergency message to be sent from the plant should include the potentially affected population and areas.
2.
The plan should provide a detailed description of the administrative and. physical system to be used for the prompt alerting and notifica-tion of the public in the event of a serious emergency. The descrip-tion should include the schedule through operational readiness of the system.
3.
The plan states that supporting information for public messages will be provided to offsite authorities. Since the plan does not include sample formats of such messages, it is not possible to ascertain
E. NOTIFICATION METHODS AND PROCEDURES (Cont.)
whether or not they are consistent with the emergency classification scheme. Final evaluation will include the FEMA finding on this matter.
i i
l
F. EMERGENCY COMMUNICATION Planning Standard Provisions exist for prompt comunications among principal response organiza-tions to emergency personnel and to the public.
Emergency Plan:
o Primary and backup means of communication for operators, local, and State response organizations are provided by National Warning System phone loops and commercial telephone.
o The Emergency Director and the Comunicator are established as providing communications from the plant.
o 24-hour notification to and activation of the State / local emergency response network are provided, o
Communications with contiguous State / local governments within the EPZ are provided, o
Communications with Federal emergency response organizations are provided.
F. EMERGENCY COMMUNICATIONS (Cont.)
o Communications between the nuclear facility Control Hoom, the Emergency Control Center, State and local E0C's and monitoring teams are addressed.
o Means to alert or activate emergency personnel are provided.
o Communications by the licensee with NRC headquarters, the NRC Regional Office, and the Emergency Control Center are addressed, o
A telephone link between the plant and the hospital, and a radio link between the hospital and the ambulance are provided.
o Monthly tests of the communication links between the Control Room, Emergency Control Center and the State and four county warning points and E0C's are specified. Tests of the communication links with the NRC are specified.
Deficiencies:
1.
Information on the communication links is scattered throughout the plan and should be presented in at least one place with greater clarity in a diagram caoicting the links, titles, alternates, and the primary and backup means of communication.
F. EMERGENCY COMMUNICATIONS (Cont.)
2.
A schedule should be provided for the hot line system to be installed between the site and the State and local organizations.
3.
A diverse means of communication, such as a radio system, should be available between the site and the primary offsite response agencies.
G. PUBLIC EDUCATION AND INFORMATION Planning Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the ne*!s media for dis-semination c' informat: 'n during.am emergency (including the physical location or locations) are established in advance, and orecedures for coordinated dissemination of information to the public are established.
~
Emergency Plan:
o Annual dissemination of information to the public regarding how they will be notified and what their actions should be in an emergency is i
to be prepared and disseminated on an annual ba:is, beginning in the Spring of 1981. The initial brochure is to contain the appropriate information.
o Advertisements containing useful emergency information which can be placed ir, the phone book and used for posting in public places are to be prepared.
... -. -. -, ~ _.., -... -. - - -, - _ - -.. -.
4 G. PUBLIC OUCATION AND INFORMATION (Cott_._)
o A Public Information Duty Officer will provide a point of contact for the news media Juring Notification of Unusual Events or Alerts. The position of Emergency News Center Dire'. tor is provided to manage the Emergency News Center and act as official Company Spokesperson for events classed higher than an Alert. A near-site Emergency News Center will be set up in the headquarters of the Verplanck Fire Protection Association.
o Access to all necessary information is to be provided to the Emergency News Director as the official spokesperson, and to the j
Public Information Duty Officer.
J Provision of accurate and timely information to the p blic through o
the news media and coordination with Federal, State end local public relations officials will be the responsibility of the Emergency News Center Director.
Coordination to deal with rumors is to be provided through exchanges.
o among licensee, Federal, State and local media representatives at.the Emergency News Center.
Programs will be conducted on an annual basis by Con Edison, in o
cooperation with appropriate Power Authority, State, and county officials to acquaint news media oersonnel with the emergency plans, information concerning radiation and points of contact for release of public information in an emergency.
.~ -
G.
PUBLIC EDUCATION AND INFORMATION (Cont.)
Deficiencies:
1.
The Plan should contain a sample copy of the emergency preparedness informatic, which will be provided for both the resident and transient population around the site.
2.
The arrangements for dealing with rumors should include some way in which the public could confirm information it has received such as a rumor control line or place to call for further information.
I
- - ' - - ~ ~-
H. EMERGENCY _ FACILITIES AND EQUIPMENT Planning Standard Adequate emergency facilities and equipment to support the emergency-response are provided and maintained.
Emergency Plan:
o The licensee has established a Technical Support Center, Emergency Control Center, Recovery Center, and an Operations Support (Assembly)
Center and can activatt them in a timely manner.
t o
Onsite and offtite monitoring and analysis systems and equipment have been established and are identified in the plan.
i o
Routine i;1spection, inventory, calibration, and maintenance of emergency eqcipment and identification of emergency kits are addressed as well as the location for receipt and analysis of field monitoring data and coordination of sample media.
i j
Deficiencies:
i 1.
The plan should provide a commitment and schedule for the permanent Emergency Response Facilities in accordance with NUREG-0696.
H. EMERGENCY FACILITIES AND EQUIPMENT 2.
The supplies and equipment available in the Operations Support Center should include those items listed in Section H.9 of NUREG-0654.
I. ACCIDENT' ASSESSMENT i
Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
Emergency Plan:
o The plan identifies plant system and effluent parameter values characteristic of a spectrum of off-normal condi'. ions and accidents.
1 o
Onsite capability and resources are provided for initial and con-4 tinuing assessment during an accident including instrumentation 7
for detection of inadequate core cooling, in-plant iodine instru-j mentation, and post-accident samplirg capability.
I o
The plan describes the methodology for determining the source term, magnitude of releases, and the relationship between effluent monitor readings and projected offsite doses. Plots of contain-ment radiation readings versus time have been developed for various fission product inventories within containment in order to aid in assessing core damage.
i L
i k
o
I. ACCIDENT ASSESSMENT (Cont.)
o Provisions have been made for determining release rates and projected doses in the event that the plant vent monitor is offscale or inoperable, o
Resources are provided for prompt field monitoring within the environs including field detection and monitoring of radiciodine concentrations as low as 10-7 uCi/cc.
Deficiencies:
1.
A description and schedule should be provided for upgrading the post-accident sampling capability as identified in the plan.
2.
.The plan should explicitly identify the means for relating various measured parameters in the field to dose rates for the key isotopes listed in Table 3 of NUREG-0654.
J. PROTECTIVE RESPONSE Planning Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consictent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
Emergency Plan:
o The licensee has established the means to warn, advise, account for, radiologically monitor and evacuate onsite personnel.
o Individuals remaining onsite will be furnished with protective l
clothing, respiratory equipment and issued radioprotective drugs
(
if necessary.
l o
The plan identifies the mechanism for nromptly recommending pro-1 tective actions to appropriate state and local authorities, and l
l provides time estimates for evacuation within the plume exposure i
EPZ.
l l
J. PROTECTIVE RESPONSE (Cont.)
o The plan contains maps showing preselectet' sampling points and population distribution around the plant site and discusses the basis for recommended protective actions from the plume exposure pathway.
Defi:.iencies:
1.
Although the plan discusses notification of onsite personnel in general, it should also address employees having emergency assign-ments, visitors, contractor / construction personnel and individuals who may be in the exclusion area but outside the protected area.
2.
The plan should discuss the bases for the choice of recommended protective actions for the plume exposure pathway during emergency conditions including the expected local protection afforded by residential or other structures for protection against direct and inhalation exposure.
K. RADIOLOGICAL EXPOSURE CONTROL Planning Standard Means for controlling radiological exposures, in en emergency, are established for emergency workers. The means for controlling radio-logical exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.
Emergency Plan:
o The licensee has established onsite exposure guidelines consistent with EPA standards, has provided an onsite radiation protection program and identified individuals by position who can authorize exposures in excess of 10 CFR 20 limits.
o The plan provides for 24-hour a day capability to determine the radiation dose received by emergency workers; distribution of dosimeters and maintenance of dose records; decontamination of personnel, supplies, instrurents and equipment and onsite con-tamination control.
Deficiencies:
1.
The plan should identify the action levels for determining the need for decontamination.
i l
i;. RADIOLOGICAL EXPOSURE CONTROL (cont.)
2.
The plan should address the means for decontamination of wounds and disposal of contaminated waste.
3.
The plan should specify the criteria for returning contaminated items and areas to normal use.
4.
The plan should discuss the availability of special decontaminants for relocated onsite personnel F,aving radiciodine contamination.
i l
-~
L. MEDICAL AND PUBLIC HEALTH SUPPORT Planning Standard Arrangements are made for medical services for contaminated injured individuals.
Emergency Plan:
o Arrangements have been made with a local and backup hospital for the treatment of individuals involved in a radiological accident.
o Onsite first aid capability is provided, including an individual onsite at a',1 times who is trained in first aid techniaues.
o Arrangements have been made for the transportation of victims of radiological accidents to the medical support facilities.
M. REC 0VERY AND REENTRY PLANNING AND POST-ACCIDENT OPERATIONS Planning Standard General plans for recovery and reentry ara developed.
Emergency Plan:
General plans and procedures for reentry and recovery have been o
developed, and the means by which decisions are made to relax pro-tective measures are addressed.
The title, authority and responsibilities of individuals filling o
key positions in the facility recovery organization are specified.
The emergency Director '.s responsible for maintaining contact with o
State and local govern.nents and keeping them apprised of plant and radiological conditions through the recovery operations.
o A method ir periodically estimating total population exposure has been established.
N. EXERCISES AMD DRILLS Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maincain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
Emergency Plan:
o An emergency preparedness exercise will be conducted as set forth in the NRC rule.
o A joint exercise involving the mobilization of State and local personnel and resources is provided.
o The scenarios of the exercises will be varied from year to year such that all major elements of the emergency response plan and its procedures are evaluated every five years. Additionally, exercises will be scheduled so as to be conducted at differirg times of day, and if possible under adverse weather conditions.
Some will be unannounced.
o The plan provides for a critique of the annual exercise by Federal, State, and local officials.
N. EXERCISES AND hlILLS (Cont.)
o Communicaticns with State and local governments within the plume
. exposure pathway EPZ will be tested monthly and communications with NRC will be tested quarterly, o
Quarterly iire drills will be conducted.
o Annual medical emergency drills will be conducted.
o Annual radiological monitoring drills will be conducted.
o Semi-annual health physicals drills involving airborne and liquid samples and direct radiation measurements in the environment will be conducted, and annual health physics drills involving analysis of in-plant liquid samples with elevated radiation levels will be conducted, o
The scenarios to be used in the exercises and drills will include:
(1) basic objectives of the exercise or drill including evaluation criteria; (2) date, time period, and participating agencies; (3) events to be simulated; (4) approximate time schedule of real and simulated events; (5) a narrative summary description of the exercise or drill; and (6) arrangements made for qualified observers.
w
N. EXERCISES AND DRILLS (Cont.)
o Provisions are made for a critique following each drill or exercise.
o An Emergency Plan Corrective Action Report will be written for each item requiring followup.
Deficiencies:
1.
The plan should.specify that each drill will be supervised and evaluated by a qualified drill instructor.
2.
Communications with the NRC shall be tested monthly in accordance with paragraph E.9.d of Appendix E to 10 CFR 50; commu ations with the Federal response organizations (e.g. U. S. C..'. Guard, DOE), and states within the ingestion pathway should be tested quarterly.
3.
The plan should identify the management controls which have been established to ensure that corrective actions stemming from drills l
and exercises are implemented.
l l
l f
4
- 0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING Radiological emergency response training is provided to those who may be called on to assist in an emergency.
The plan provides for the initial training and retraining of company and offsite personnel who will respond to an accident or emergency.
o Training will include classroom as well as practical drills to ensure that personnel are cognizant of and acquainted with their duties and responsibilities.
Deficiencies:
1.
The plan should include training made available to local and/or State police.
2.
The plan should address the training provided for those personnel responsible for the transmission of emergency information and instruc-tions (see Table B-1, NUREG-0654, " Notification / Communication',').
P. RESPONSIBILITY FOR THE PLANNING EFFORT Planning Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.
Emergency Plan:
o Training of individuals responsible for the planning effort is t'
assured by the Officer in Charge of Power Generation.
o The Officer in Charge of Power Generation has the overall authority and responsibility for radiological emergency response planning, o
An Emergency Planning Director has been appointed, and given the responsibilities of updating emergency plans and coordinating these plans with other response organizations.
i o
Updated plans will take into account changes identified in drills and exercises and be certified on an annual basis to be current.
o Controlled copies shall be used to keep the emergency organization cognizant of changes to the Plan and the Emergency Procedures Document.
l a
1
-re
,w
-,e
-i.--,m-r.w.9-,%.,
.,,..-,,,r.,
e,..,,,,,. -
-s.-.-,,,,.,w
..e<,,v,,,,
,.,..-w.
,,.,,,.m,,,,,,,.-,,er.,,
,,,,,,.,ww,w.w%-m,
P. RESPONSIBILITY FOR THE PLANNING EFFORT (Cont.)
i o
A listing of the procedures required to implement the plan and thesectionoftheplantobeimplementedbyeachisprohided as part of the emergency plan.
o An audit of the emergency preparedness program is performed by the Consolidated Edison Quality Assurance Organization under the cognizance of the Nuclear Facilities Safety Committee at least once a year.
f o
The Quality Assurance Program provides the management controls for I
documenting,reportingandretainingauditresultsandforehaluat-ing and correcting audit findings.
l o
The updating of telephone numbers in the Emergency Procedures i
j Document shall oe verified on a quarterly basis.
Deficiencies:
1.
The plan should contain a detailed listing of all supporting plans l
and their source.
i f
I l
gNCLUSION Based on our review, we conclude that the Indian Point Units 1 & 2 Emergency Plan, upon satisfactory correction of the previously identi-fied deficiencies, will meet the planning standards set forth in NUREG-0654, Revision 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.
The NRC evaluation on the overall state of emergency preparedness for the the Indian Point site will be made following review of the findings and determinations made by FEMA on the State and local emergency response plans, and the revit of the joint exercise held to demonstrate the capability to impl'.1ent the onsite and offsite plans.
-