ML20027B755
| ML20027B755 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/28/1982 |
| From: | Hassell D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Gleason J, Paris O, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8209300069 | |
| Download: ML20027B755 (23) | |
Text
DESIGNATEDORIGIX&Il(
Certified By 2-L6Wf L
'JDY James P. Gleason, Esq., Chairman Dr. Oscar H. Paris Administrative Judge Administrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Frederick J. Shon Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission September 28, 1982 Washington, D.C. 20555 In the Matter of Consolidated Edison Company ofNewYork(IndianPoint, Unit 2)
Power Authority of the State of New York (Indian Point, Unit 3)
Docket Nos. 50_247_SP and 50-286 SP
Dear Administrative Judges:
Enclosed are copies of letters from the Power Authority of the State of New York and Consolidated Edison Company of New York, Inc.
concerning the activities which are planned or underway to correct the significant deficiencies for offsite emergency preparedness, which were identified by the Federal Emergency Management Agency in its " Interim Findings Report" of July 30, 1982. These letters are provided for the information of the Licensing Board and parties.
Sincerely, Donald F. Hassell Counsel for NRC Staff DHassel FRowsome JMoore JHannon JMcCurren Christenbury/Scinto ABarbagallo Murray
Enclosures:
SATreby ELD FF #2 as stated MKarman DMS-PDR-LPDR Dross Chron cc w/ encl: Service List X-2
^
, 0FC :0EL
)
- 0E
(____:__
q__:____________:____________:.___________:____________:___________
NAME :DHassell/eb SAT DATE :09/28/82
- 09/ W 82 8209300069 820928 PDR ADOCK 05000247 C
s.
POWER AUTHORITY OF THE STATE OF NEW YORK lo COLUMaus CincLE New YomK. N. Y.10019 t212) 397 6200 Lamov w. stacLAsw
.'s T2yBTEES e en a a
e son
. or. ore,
W A LT E N T M..ICl 88 SM S gg
.... r......
S aa = 'a TJ.:.~/.''.'.*,,..
C EQ AGE L. #Nda6L5
./
5 tiG E Gmas.ams JCC$
R SC M EDER
...C s..,. + n.v ~
s
~.,; a ; - - -
cc:
T. T. Martin
'**".".'.*/"".
. c o r,c x. c'"
G. H. Smith (4 cys)
Ur.*/.'" ~.*l. - "
R. W. Starostocki v. u.....,
9/3/82-RCH 1*.~.'A Tl.".".".* :
September 2, 1982 IPN-82-63 Mr. Ronald C. Haynes Regional Administrator of fice of Inspection and Enforcement Rogion I U.S. Nuclear Regulatory Commission 631 Par): Avenue King of Prussia, Pennsylvania 19406
SUBJECT:
Indian Point 3 Nuclear Power Plant Dock 6t No. 50-286 Planned Corrective Actions'for Significant Deficiencies Identified in July 30, 1982 FEMA Interim Report
Dear Mr. Haynes:
As requested by your August 3rd, 1982 letter, please find harein a description of the activities which are planned or unden ay to correct the significant deficiencies listed by the Federal Emergency Managemont Agency (FEMA) to you in its
" Interim Findings on the Adequacy of Radiological Emergency l
Response Preparedness of State and Local Governmente at the l
Indian Point Nuclear Power Station".
These July 30th PEMA interim find,ings are related to the offsite emergency re:sponse preparedness of State and local ~
governments in the vicinity of Indian Point.
The activities to correct the deficiencies will, therefore, be a cooperative effort between the licensees and the government entities involved.
We will provide support for the efforts of the State and counties.
6 4
^
Ronald C. Haynec
.2 -
V After discussions among the interested parties, the overall plan is comprised of the following basic elements:
1)
Development of a, consensus.as to what must be acco6p,iished ih order to resolve significant deficiencies.
This phase has generally been conpleted as a result of consultations between New York State and FEMA in mid-August and at another wo,rking semaion betwoon the State and licensees.
The details are claritiod by Attachment A and are the result of FF.MA
'and New York State and utility ef forts.
2)
Close licensee cooperation with New York Stata during the development and implementation of specific resolutions of the significant deficiencies Will be accomplished during periodic work sessions between the responsible organizations.
Based on these meetings, go=c approaches may change as, desirable alternatives become apparent.
While the principal activities will be conducted by State and local governments, there are sore neasures necessary where the licensees will be principal contributors, such as the Alert and Notification System (ANS) communication with transient populations, and brochure content and distribution.
3) ni-weekly status sessione among responsible parties at which progress in implementing adequate corrections will be discussed and agroed upon.
The status of the ANS is provided as follows.
A telephone survey conducted by the utilities subsequent to the March 3rd exorcise indicated that a number of sirens had not been heard by residents living near those sirens.
Subsequane to the exorciso, the utilition jointly conducted a complete re-test and maintenance on each of the sirens in the ANS.
As with any new installation, the re-test uncovered problanc that related to initial construction and first time operatien of a system af ter the construction test program was cc pleted.
These problems were corrected prior to June 1, 1982 as noted in our June 9, 1982 letter to the NRC.
Our subsequent investigation revealed that there was a generic problem with sirens wherein our 125dB rated sirens provided only 119dB.
On May 27, 1982, in a telephone convorcation with NRC staff we noted this GdB deficiency and also requested some clarification of certain of the acceptance criteria.
We are continuing with our testing and analysis no that we have the necessary background information to respond rapidly should the FEMA acceptance criteria indicate a need to supplement the system.
l l
3
). 5cacid C. Haynes
'3 -
I
.In addit $ ion to this work, consideration is being given to the ordering of hardware and methods of f acilitating the local permit process so that we may act rapidly if needs are identified.
If,this hardware were installed, we anticipate co=o cound level and system enhancement.
Other methods of notification are also being d:plored.
Por exampl'e, on May 27th the utilities formally requested that New York State explore the use of fire and Civil Defense sirens boing sounded in unison with the utility ~inatalled ANS in order to enhance tho system.
The state is currently exploring that option.
The utilities are also purchasing, tone activated redios for use at special facilities within the Emergency Planning Zone.
These radios would alert the special facilities on activation of the EDS network.
It la expected that distribution of these tone alert radios will begin within ninety days.
The Indian Point ANS is now functioning and the instances of incomplete functioning observed by FEMA during the March 3rd exercise have since been corrected.
The FEMA acceptance test referred to in the interim findings la awaiting the development of PEMA criteria which will perm t the FEMA evaluation of the MS at our site.
Based upon our d scussion with FEMA we understand that this might occur in late 1982 and a deternination by FEMA of system acceptability cannot be made until that tine.
As FEMA noted, the withdrawal of Rockland County from the coordinated emergency preparedness process was a unilateral county action over which the licensees had no control.
While licensees believe that the Rockland County issue will be resolved to the natisfaction of NRC and FEMA, Rockland County's action cannot serve as a basis for findings adverse to the continued licenalng of ths Indian Point units.
To allow it to do so would denigrate the Commerce Clause and the Supremacy Clause of the constitution of the United States by subjecting Federal law to a county governmental veto.
Rockland County's action, therefore, would be contrary to congressionally established naticeal policy.
New York Sta'te has assumed the responsibility of pariodically notifying FEMA of, the status of compensatory planning for Rocxland County to the extent that the county's current planning and implementation capability may be
/
deficient.
Dy law New York Ftate will provide emergency response whoo and if this is not performed by a local governnental authority.
While your August 3rd letter related only to those c
deficiencies identified as al gni fi ca nt in the interim findings, others wore not put in the significant category in the interim findings report.
We will be working with State and local ' -
governments to correct these itema as well, after activities to correct algnificant deficiencies are underway.
~_;.T:.._J Mr. Ronald C. Haynes k Since the issuance of the interim findings, the State of New York And FEMA bave met to identify corrective monaures which are adqquate to' c6 erect significant deficiencies identified in the findings.
We have been advised by New York State that what appears in Attachment A as New York State
~,
responsibilities represents the results of disct2ssions between Now York State and FEMA, and is complete with respect to measures required.
Should you or your staff have any questione please cal.1 my office.
Very truly yours,
\\
yne recutive vice President Nuclear Generation cc: Mr. Brian Grimes, Director Division of Emergency Preparedness
~
U.S. Nur-lear Regulatory Commission Washington, D.
C.
20555 Resident Inspector's Office Indian Point 3 U.S. Nuclear Regulatory Commission P.O.
Dox 38 Buchanan, New York 10511 Mr. Ron Barton United Engineers and constructors, Inc.
30 S. 17th Street Philadelphia, PA 19101 S
e O
O 9
8
ATTACHMENT A SIGNIFICAt3T DEFICIENCIES JULY 30, 1902 FEHA It4TERIM REPORT totenent of De ficiency Proposed Corrective Actions Notification o
(a)
Siren system requiren further (a)
Subsequent to the exercieo, the utilities correction.
jointly conducted a conplete retest and 4
paintenance program on each of the sirens in the ANS system.
The Indian Point ANS system i
is now functional.
Final resolution of the alert and notification system (ANS) issue can not be accomplished until FEMA has developed acceptance criteria which will permi.t evaluation of the ANs at each site.
Results of studies and tests (see cover, letter) are being reviewed to dotermine the need for enhancenent In parallel with this work, consideration is being given to ordering hardware and coopensatory peneures such as the use of existing tire and civil defense sirens la being investigated by the State.
Tone activated radios are being purchased for use at special facilities within the 10 mile EPZ.
(b)
State and county plans ' lack (b)
All protective-action orders and all actions specific criteria for content and affecting the public wi].1 be included in the use of EBS messages.
EDS messages.
A system will be developed to insure the content of all EBS messages and the prompt and accurate transfer of such neonages to the EDS stations.
News releases will include information given in the EBS messages.
O e.
ATTACIIHENT A SIGNIFICANT DEFICIENCIES JULY 30, 1902 FEMA INTERIM REPORT 5tatecent of Deficiency Proposed Corrective Actions flotification (Con't)
(c)
Procedures for PIO's should be (c)
All revisiono necessitated by the interim revised to include the findings will be incorporated orsreferenced specific itema listed.in
.in the State and county PIO procedures.
E.
(b), (h),
G.
(d), (e), (f).
(d)
Inadequate notification of Rockland (d)
The State will work with Rockland County to energency personnel and local improve initial call out methods for schools.
emergency personnel and local school l
notification.
(e)
Procedures for establishing contact le)
The State Pian will include the telephone with Federal agencies should include numbers of Federal agency office numbers.
office phone numbers.
These numbers are currently listed primarily
.in controlled copies at the State Warning Point.
(f)
PIO training is necessary on revised (f)
Upon the completion of the PIO procedure procedures, revisions, all State and county PIO's will above.
See B (c) be trained on such procedures.
(g)
FEMA does not have the most (g)
The Energency Broadcast System procedures up-to-date EDS plan.
for the Hudson Valley and Catskill New York Operational Area and Plan will be sent to FEMA.
Ih)
The specific details of EB3 (h)
The specific' details of Ens activation for activation for the four. county the four county area, not reflected in 'the area are not ir the EBS plan.
EDS plan (noted above) shall be detailed in each State and county plan and provided to the lead EBS. Station.
Meetingn'will be arranged with EDS station management to explain its importance and its operation as it relates to the emergency planning efforts.
-2
u.-
ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY 30 1902 FEMA INTERIM REPORT La temen t of Deficiency Propoced Corrective Actione Public Education and Information (o)
The public appears to be uninformed (a)
The public education program which is being about the Radiological Emergency developed by the State, counties and Preparedness Plan.
' utilities will be luplemented.
(b)
Inadequate distribution of the (b)
Further clarification by the State from the brochure, " Indian Point Emergency Planning & You."
FEMA Regional Assistance Committee (RAC) has been requested.
Copies of the previously transmitted distribution methodology letters i
were forwarded to. FEMA.
Brochur~e distribution methodology will be reviewed i
on an ongoing basis in an effort to assure that all those within the 10 mile EPZ receive the appropriate brochure during the planned annual distribution.
(c)
Need for publication of the brochure (c)
Although not a NUREG-0G54 criterion the in language (s) other than English.
State, counties, and utilities will investigate the need for publication i
l of the brochuro in language (s) other
=
than English or same.other. foreign language program.
A survey will be done on the number of non-English speaking residents in the 10 mile emergency planning zone.
i j
(d)
Inadequate arrangements for desling (d)
The rumor control program used at the i
with rumor control August 11, 1982 PitrPatrick (JAF) Emergency Exercise and approved by all' parties will serve as a basis for the rumor control program at Indian' Point.
This program wl,ll be tailored and then added to each State and county plan.
e w
7 ATTACIIMEtrP A SIGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT
~
Latement of Deficiency Proposed Corrective Actions Public Education and Information (Con't)
(c)
A-more adequate description of the (e)
An outline of the public information program, public information program, news news media briefings and notification of media briefings and notification of transients will be in the State,a.,d county transients should be in the State and county plans.
plans.
Specific detaiJs of this progren will be forwarded to FEMA upon completion (i.e.,
pamphlets, posters, telephone book inserts etc.)
(f)
Arrangements and procedures for the (f)
Although not a NUREG-0654 cri'?rl'on. State joint media facility need to be and county plans will describ or will described in detail in the plan.
reference other documents containing the floor plan, equipment and location information for the joint media facility.
Further clarification has been requested by the State, from the RAC.
Protective Response (a)
Methods for notification of (a)
Posters and telephone book insert info [ nation transients must be provided.
will be forwarded-to FEMA upon completion.
See G (e) aSove.
(b)
Haps which include population by (b)
Maps with population distribution by E PA are ERPA should be displayed in EOCs.
available fer use at State and county EOCs.
REPG will provide population information on EOC maps to RAC.
(c)
The State has decided not to (c)
State policy now calls for the provision and i
provide thyroid blocking agents dissemination of KI (Potassium Iodide) to emergency workers.
to energency workers and special populations.
This policy will be included in the State Plan.
I
-4
=
8 6 B 0 0thUCLUGWU U /Ah SIGt4}PICAt4T DEFICIENCIES JULY 7,7902 FEMA ItiTERIF1 REPORT T
Statement of De ficiency Proposed Correctiva Actiona T.
Protective Response (Con't)
(d)
The plans provide insufficient site-(d)
Further details of the means for clearing specific means for dealing with evacuation routes will be included or-impediments to evacuation.
referenced in State and County plans.
(c)
Describe more adegustely in the State
[e)
Further clarification has been requested plan, the measures for protection of by the State from the RAC in order that the ingestion pathway.
(Mape, lists appropriate detail is more adequately of food processors, identification of described in the State Plan.
reservoirs, etc., must be provided or material adequately referenced.)
(f)
Procedures should be developed,to (f)
The capability for monitoring of evacueen at provide monitoring capability at congregate care centers as well as at i
congregate care centers.
reception centers will be added to the plans.
4 Added capability includse equipment, training and manpower.
(g)
Inadequate collection and trans-(g)
Additional Standard Operating Procedures for mission of field data for consic-collection and transmission of field data eration of decision makers.
will be developed.
Utility, county and EOC 4
I staffs will be trained on the additional procedures.
(h)
Evacuation of non-institutionalized (h)
Further~ ciarification is needed and will be mobility impaired persons is not requested by the State from RAC to define addressed.
what la adequate to satisfy this element.
e I
l
a ATTAC11 MENT A SIGNIFICANT DEFICIENCIES JULY 30, 1902 FErfA INTERIM REFoRT
.atement of Deficiency Proposed Correct!.ve Actione I
Protective Rooponse (Con't)
(1)
No evacuation conmitmento from Bus (1)
Compennatory measu.res are being pursuod.
j Operators, or locations and nurber of buses, bus radios and maps.
(j)
Some relocation centers are located (j)
The State has requested a-list of the too close to the plume exposure EPZ.
specific centers from FEMA.
Appropriate revisions will be made.
(k)
During the exerciso, a lack of maps (k)
Additional naps are now available. The State was noted at' the State and some has requested RAC to identify specific types county EOCs.
and locations where additional maps should be located.
Radiological Exposure Control (a)
Absence of _ permanent dosimetry and (a)
Permanent dosimeters (TLDs) and self-reading 24-hour monitoring capability. More pocket dosimeters (0-5 R) with chargers have sensitive self-reading docimeters are been ordered.
The capability for 24-hour needed.
tio permanent record devices operation (i.e., shift changes) will be (film badges or TLDs) were available demonstrated during the next exercise.
in the counties.
(b)
Demonstration of decontamination for (b)
Decontamination procedures are being eoergency personnel needed.
reviewed and modified.
Personnel at appropriate locations will be trained in new methoda and will be denonstrated at the next exercise.
j i
i 8
i l
-G-
i Al"l'ACllt1EtlT A SIGIIIFICANT DCFICIE23CIES
.lOLY 30,7902 FCIM IliTEltIM ItEPORT tatement of Deficiency Proposed Corrective Actione 3.
Radiological Exposure Control (Con't)
(c)
Decontamination levels posted in (c)
Levels will be dioplayed so needed.
wrong sequence (Putnan Plan only).
Person 7el will be trainod in applicotfon of requirements.
(d)
Disposal of contaminated wastee le (d)
The plan will describe the method for not adequately addressed.in the disposing of solid wastes, county plana.
The Westchester oite chosen for decontanination will be changed.
l l
(e)
Inadequcte calibration and main-(e)
Equipment will be checked for proper l
tenance of monitoring equipment.
operation semi-annually, t'o assure functioning.
Planning Responsibility P
(a)
Rockland's non-participation in the (a)
Rockland County decision makers will bo four county plan raises a question as trained on radiological emergency response to decision maker capability to respond necessities.
Compensatory measures will be in an emergency.
outlined in the State Plan.
(b)
In the absence of a Rockland County (b)
In the absence of a Rockland County Plan, Plan, there le an inherent lack of provision will be included in the State Plan capability to update such a plan.
for updating Rockland response requiresents.
(c)
In the absence of a Rockland County (c)
In the absence of a Rockland County Plan, Plan, there is an inherent liability provision will be included in the State Plan to keep the plan current.
for keeping Rocklund response requirements current.
(d)
Rockland's non-participation in the (d)
In the absence of a Rockland County Plan, exbrcise and planning effort requires compensatory measures will be included in compensating measures to be taken.
the State plan to insure adequatg emergency response in that county..
John D. O'Toole i
We P'epcem s.
g; l
C n'.cimted kcc.on Ccmpany of Naru Y(nb. piq.
4 liv.og Pit.M. New Ytuk. NY 100ej l
Te!epw stri 4G0 2L23 1
j 1
September 2, 1982 l
Re:
Indian Point Unit Nos. 1. & 2 Docket Nos. 50-03 and 50-247 Mr. Ronald C. Haynes, Regional Adtninistrator
~
(
Region I U.S. Nuc1 car Regulatory Cor. mission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. haynes:
j(
l As you requested by your Aurust 3r.d,
1982 2ceter, enclosed as description of the activities which are planned or Attachment A in a underway to entreet the significant deficiencies identified by the Fed ersi F.mergency Management Agency (FDIA) to. you in its
" Interim the Adequacy of Radiological Emergency hesponse Preparedness 1
Findinga on of State and Local Governmentr, at the Inlian Point ?!uclear Power Station".
1
'ffsite f
These July 30th YEMA interim findiras are related to the o
cuergency responen preparedness of State end local governments in the vicinity of Indian Point.
The activities to correct the daffetencies irill, therefore, be a cooperative effort among the Licensees and the
. j government enticles involved.
As.in the past, Licensees vill continue to
~
participete in and support the efforts of the State and counties to f-l upgrade their radiological emergency preparedness capability.
-I Af ter discussinns among the interested partf eg, the overall plan for sf nfficant deficiencies and for dealing with the i
enrrecting each of thn E
minor deficiencies is comprised of the fn13nwing basic elements:
i l
1)
Develop:2ent of a
consensus as to what must be accomplished in o rder to resolve significant l
deficiencies.
"Ihis phase has ganara13y haan co:1picted i
l for the significant deficiencica an a
result of
.1 l
consultations between New York State and FEMA in
$l mid-August and at another. worki.sg session among the l'
State and Liceneces.
Attachment' A discusses
,the l
current status of the e f f o rt s to resolve the j
i significant deficiencies identified by PDiA as clarified by the referenced meetings.
I
-)
l 4 j 1
l
'i 1
h 1
f tV
. s t
i
- September 2. 1982 Nr. Ronald C. Ilsynes n.
cooperatinn with New York State during 2)
Close licensee the development end impicnentation of specific resolutions of the signiticant deficiencies will be i.
[
acco:tpJ ished during periodic work nessions
- smony, i
therceponsiblo organirations.
Based on these
- meetings, some approaches may change as desirable j
alternativen become apparent.
While the principal i
activities will be conducted by State and loca) thern are some weasurca necessary to -
l governments, address significant deficiencies where the Licensees vill be principal contributnru, such en,the alert and l}
notification
- system, con.munication with' transient
[
populations, and brochure content and distribution, p
Ve arc advised that with renpect to the remaining l
deficiency
- items, the State of New York vill acccaplish the corrective measures nu set forth in Attechment A.
Bi-wenk.ly status cessions among responsible parties et 3) which progress in -implementing adequate corrections of significant deficiencies wi31 be discussed and agreed upon.
While your August 3rd letter reinted only to those deficiencies identified as significant in the interim
- findings, other minor We vill defi ciencies were referred to in the interim findings report' miso be work.ing. wi th Stat,e and local governments to correct-these deficiencies after activitien to correct significant deficiencies are underway.
One planning requirement which may not be fully clarified during the period for corrective action despite FDiA's involvement relates to the and notification system, which is involved in one category of The status of the alers significant deficiencies cited in the interim findings.
f A telephone and notification system ( ANS), is provided as follows.
I survey conducted by the utilities subsequent to the March 3rd exercise alert a otnnber of sirens had not been heard by residents living indicated that to the exercise. the utilitica jointly naar those sirens.
Subsequentand performed necessary maintenance on each conducted a complete re-test of the sirens in the ANS.
As with any new installation. there were problems uncovered that related to initial construction and ffrat time operation of a system after The problems were corrected the constructfon test program was completed.
prior to June 1, 1982 am noted in our June 9, 1982 letter to Mr. George Smith of your staff.
4.
e 0
e
W"'"w'...
1 Septenbor 2,1982 Mr. Ronald C. Itsynes 1i h
investigstion revealed that there was e seneric problem with sirens wherein uur 125dB rated sirenn provided only 119da.
On May j
our subsequent 27, 1982, in a telephone conversation with NRC staff we noted this 6dB j
deficiency and slao rerguested some clarification of ce rtain of the 1
continuing with our tenting and analysis no i
neceptance criteria.
We are that vn have the necessary background inf ormation to respond rapidly a need to supplement the criteria Indicato should the FPiA acceptsnce 1
l sy stem.
j In addition to this work, consideration is hei.ng given' to the ordering i
of hardware and methods of f acilitating the local permit procesa so that ve may ar rapidly if needs are identifind.
If this hardware were installed we anticipate nome sound level-and system enhancement.
For exsuple on-
{
~
Other methods of notification are also being explored.
that New York State explore the May 27th the utilities formally requested une of fire and Civil Defanse s$rens being sounded in unison with the utility insts11ed ANS in o rder to enhance the system.
The state is currently exploring that option.
The utilitics are also purchasing tone activated radios for uso at all special facilities within the Emergency q
rianning Zone.
Thnse radios would alert the special facilities over th'e' EBS network.
It ia expected that these tone alert radios will be
{
distributed within ninoty days.
The Indian Point ANS is now functioning and the instances of incomplete functioning observed by FEMA during the March 3rd exercise have since been corrected.
However, the FEMA neceptance test referred to in the interim findings is avaiting the development' of FEMA criteria which will permit the FDIA evaluation of the ANS at our site.
Based upon our this night occur in late 1982 and discussion with FaiA vn understand that a determination by FEMA of system acceptability cannot be made until that l
time.
l As TDfA uoted, thn withdrawal of Rockland County frots the coordinated l
within Licensee's control.
Whil'e emergency preparedness process was not Licensees believe that the Rockland County issue vill be remolved to the l
County's action cannot serve== a satisf action of NRC and FriA. Rockland basis for findings adverse to the continued licensing of the Indian Point has assumed the renponsibility of periodically State unita.
New York the status of co=pennatory planning for Rockland County notifying FEMA of to the extent that the county's current planning and implementation capability may be dsficient.
By. Jaw New York State will provide emergency response when this is not performed by a local governmental uthority.
Attach =snt A provides some details on this matter.
l As discussed above, since the inauance of the interim findings, the State of New York and FEMA have net to identify corrective measures which l
J
I N.
o
~
,3 i
d Mr. Ronald C. lisyne s September 2,1982 l
t I
se adequate to currect siF,ni ficant deficiencies identified in the i
ficdings.
We have been advised by New York State that what appears in Attachment A as l'ev York Statei responsibilities represents the resultu of i
discumulons between New York State and FEMA, and is complete with respect to measures required.
i Should you or your staff have any questions please call ny office.
,{-
Very truly yours, dw d
s/ 0/
e John D. O'Toole Vice Pronident
'l Attachment CC:
Mr. Brian Grimes, Director j,
Division of Emergency Preparedness j;
4' U. S. Nuclear RcEulatory Commiunion I
Washington, D. C.
20555 Mr. Ted Rebelowski, Senior Resident Inspector U. S. Nuclear Regulatory Commission Post Office Box 38 Buchanan, New York 10511 e
i I
I l
i i
l i
I a - or
l @E M Zl@Q[U2 N CIE F.RIE C 30 82 TENATINTERD1 REPORT
'r O
Statement of Deficiency Proposed Corrective Actions E.
Notification
'i (a) Siren system requires further (a) Subsequent to the exercise, the utilities correction.
jointly conducted a complete retest performed necessary maintenance on each of the sirens in the ARS systen.
The Indian Fotut ANS system is now functional.
Final resolution of the alert and notification systen (ANS) issue cannot be accomplished until FEMA has developed acceptance criteria which will permit evaluation of the ANS.
Results of studies and tests (ace cover 1etter) are being reviewed to determine the need for enhancement.
In parallel with this work, consideration is bging given to ordering hardware and compensatory measures such as the use of existing. fire and civil defense sirens le being investigated by the State. Tone activated radios are being purchased for use at all special facilities within the 10 mile BPZ.
(b) State and county Plans lack (b) All protective action orders and all actions specific criteria for content and affecting the public will be included in the use of EBS messages.
EBS messages.
A system vill be developed to insure'the content of all.EBS messages and
~
the prompt and accurate transfer of such messages to the EBS stations.
tieve rolesses vill include information given in the EBS messages.
_1-f; 5
-~
v I
St,.3 tenent of Deficiency Propored Corrective Action 1 E.
Notification (Con't) 2; (c) Procedures for PIO's should be (c) All revisions necessitated by the interim revised to. include the findings will be incorporated or referenced g
specific '.tema listed in in the State and county PLO procedures.
1 E. (b), (h), G. (d), (e), (f).
(d) Inadequate notification of Rockland (d) The' State vill work with Rockland County $o emergency personnel and local improve initial call out methods for schools.
energency personoel and local school notification.
(e)
Procedures for establishing contact (e)
Ihe State Plan vill include the telephone with federal agencies should include numbera, of Federsi agency office numbers.
office phone numbers.
These numbers are currently listed primarily in controlled copies at the State Warning Point.
(f) PIO traluing is necessary on revised (f) Upon the completion of the PIO, procedure procedures.
revisions, all State nod county P10's will be trained on suchsprocedures.
See E (c) above.
(g) FEMA does not have the most (g) The Imergency Broadcast System procedurco up-to-date EBS plan.
for the Budson Valley and Catskill New York Operational area and pla'n will be sent to TEMA.
{h) The specific deteils of EBS (h) The apecific details of EBS activatic, for not. reflected it the activation for the four county the four county areas area are not in the EBS plan.
EBS plan (noted above) shall be detailed in each State sad county Plan and provided to the lead EBS Station.
Meetings will be arranged with RBS station nanagement to explain its importance and its operation as it' relates to the emergency planning efforts.
'S.
6 d
r7'.
1 Stctement af D ficiency Proposed Corrective Actiono PS4 G.
Public Education and Information
~
(a) The public appears to be unicf ormed (a) The public education progrem which is being about the Radiological Emergency developed by the State, counties and Preparedness Plan.
utilities will be implemented.
l (b) Inadequate distribution of the (b)
Further clarification by the State from the j
brochure, " Indian Point'0mergency FEMA Regional Assistance Comnittee (RAC) has l
Planning & You.'
been requested.. Copies of the previously transmitted distribution methodology letters were forvnrded to FEMA. Brochure distribution methodology will be reviewed' l
on an ongoing basis in an effort to assure i
that all those within the 10 mile EPZ receive i
che appropriate brochure during the planned l
annust distributloo.
l l
(c) Need 'for publication of the brochuro (c) Although not a NUREG 0654 criterion, the-in language (s) other than EngIlsh.
State, counties and utilities will investigate the need for publication of the brochure in languake(s) other than English.
A survey will be done on the number of I
Non-English speaking residents la the 10 mile energency planning zone.
(d) Inadequate arrangements for dealing (d) The rumor control program used at the with rumor control August 11,1982,FitzPatrick (JAT) Emergency Exercise and approved by all partias will serve as a basis for the rumor control program at Indian Point.' This program will be tailored and then added to each State and county plan.
i e
n vw-
~. - si a
u r.:xT-
" i._. ~
- ~ ~ ^ ^
^
mm m &',e
y-i Statement of Deficiency Proroecd Corrective Actions G.
Public Education and Information (Con't)
(e) A tsore adequate description of the (c) An outline of the public information progran, public information program, news new media brief.ings and notification of I
media briefings and notification of transtents v111 be in the State and county transients should be in the State plans. Specific details of this program vill and county plans.
be forwarded to FDfA upon completion (i.e.,
pamphlets, posters, telephone book inserts etc.)
(f) Arrangements and procedures for the (f) Although not a NUREG-0654 criterion, State joint media facility need to be and county plans will describe the floor described in detail in the plan.
plan, equipment and location information for 1
the joint stedia f acility.
Further clarification has been requested by the State, from the RAC.
J.
Protective Response (a) tiethods for notification of (a)
Posters and telephone book insert infornation transients must be provided.
will be forwarded'to TEMA opon coupletion.
See G (e) above.
(b) 1 Caps which include population by (b) Maps with population distribution by ERPA are ERfA should be displayed in EOCs.
available for use at State and county EOC's.
REPC will provide population luformation on EOC inaps to liAC.
(c) The State has decided not to (c) State policy now calle for the provision and provide thyroid blocking agents diesestination of KI (Potassium Iodide) to emergency verkers.
to emergency workers and special populations. This policy will be included in the State Plan.
(
4
.--t_
_ - ~ _
- -7 FTMid Corr:cthva IMtRono J.
Protectivo Reepance (Con't)
(d) The plans ' provide losufficient site-(d) Parther details of the means for c1 caring i
specific means for dealing with evacuation routes vill be included or impedluents to evacuation.
referenced In State and County plans.
(e) Describe more adequately in the State (e)
Further clarification has been requested plan, the measures for protection of by the State from the RAC in order that the ingestion pathway.
(Kaps, lists appropriate detail is more adequately of food processors, identification of described in the State Plan.
reservoirs, etc., must be provided or material adequately referenced.)
(f) Procedures should be developed to (f) The capability for monitoring of evacuees at provide monitoring capability at congregate care centers as well as at congregate care centers, reception centers will be added to the plans Added capability includes equipment, traloing and manpover.
(g)
Inadequate collection and trans-(g) Additional Standard Operating Fr' ocedures for
~
mission of field data for consid-collection and transmission of field dats eration of decision makers.
will be developed. Utility, County and EOC ataffs will be trained on the additional procedures.
(h) Evacuation of non-institutional 1 zed (h) Further clarification 'is needed,an will be mobility inparted persons Is not requested by the State from RAC to defice' s
addressed.
what is adequate to satisfy this element. ;
l W uur - -
CEE.__
A&
_=
7 7'-
r g 7'
v--
Stctement of Deficiency Proponid Corrective Actiena
[t J.
Protective Response (Con't) l (1) No evacuation commitments from Bus (1) Compensating measures are being pursued.
Operators, or locations and number I
of buses, bus. radios and maps.
(j) Some relocation centers are located (j) The State has requested a list of the too close to the plume exposure EPZ.
specific centers from PEMA. Appropriate revisions will be unde.
(k) During the exercise, a Isch of maps (k) Additional caps are now avalleble. The State was noted at the State and some has requested RAC to identify specific types j
county EOCs.
God locations where additional maps should be located.
K.
Radiological Exposure Control (a) Absence of permanent dosimetry and (a)
Pernanent dosimeters (ILDs) and self-reading 24-hour monitoring capability. More pocket dosimeters (0-5'R) with Shargers have sensitive self-reading dosimeters are been ordered.
The espability for 24-hour needed.
No permanent record devices operation (i.e., shif t changes) will bc (film badges or TLDs) were available demonstrated during the next exercise.
l in the counties.
(b) Demonstration of decontamination for (b) Decontamination procedures are being emergency personnel needed.
reviewed and nodified.
Personnel at appropriate locations will be trained in new nethods and will be demonstrated at the next exe rcis e.
-6~
I 9
g 7
m
~
Statement of Deficiency Frepored Corrective Actiens K.
Radiological Exposrue Control (Cop' t)
, I (c) Decontamination levels posted in (c) Levels will be displayed as needed.
wrong asquence (Putnam Fisu only).
Personnel will-be trained in application of requirements.
(d) Disposal of contaminated wastes is (d) The plan will describe the method for not adequately addressed ir. the disposing of solid wastes.
County Pinos.
The Westchester site chosen for l
decontamination will be changed.
i (e) Inadequate calibration and main-(e) Equipnent will be checi.ed 'for proper tenance.of monitoring equipuent.
operation semi-annually, to assure f unctioning.
P.
Planning Responsibility (e) Rockland's non participation in the (a) Rockland County. decision ma'kers will be
~
four county plan raises a question as.
trained on radlological emergency response to decision maker capability to respond necessities.
Compensating measures vill be outlined in the State Plan.
in en emergency.
(b)
In the absence of a Rockland County (b)
In the absence of a Rockland County pino, plan, there is an inberent lack of provision will be included in the State plan capability te update such a plan.
for updating Rock 1sud response requirements.
a (c) In the stsence of a Rockland County (c) In the absence of a Rockland County Plan, Plan, there is an inherent liability provision vill be included in the State Plan to keep the plan current.
for keeping Rockleod response requirements current.
(d) Rockland's non participation in the (d) In the absence of a Rockiand County Plan, exercise nod planning effort requires compensating measuras will be included in componesting measures to be taken.
the Stats plan to insure adequate emergency response in that county.
m,, -
r