ML20028B779
| ML20028B779 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/02/1982 |
| From: | Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20028B663 | List: |
| References | |
| NUDOCS 8212030248 | |
| Download: ML20028B779 (11) | |
Text
.-
John D. O'Toole Vce Presdent 1 -
Consobdated Edison Corpany of New York. Inc.
4 trying Place. New York, NY 10003 '
Telephone (212) 460-2533 4
September 2,1982 Re:
Indian Point Unit Nos. 1&2 Docket Nos. 50-03 and 50-247 Mr. Ronald C. Haynes, Regional Administrator
~
Region I U.S. Nuclear ~ Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 1
Dear Mr. Haynes:
As you requested by your August 3rd, 1982 letter, enclosed as Attachment A is a description of the activities which are planned or underway to correct-the significant deficiencies identified by the Federal Emergency Management Agency (FEMA) to you in its " Interim Findings on the Adequacy of Radiological Emergency Response Preparedness of State and Local Governments at the Indian Point Nuclear Power Station".
i i
"'he se July 30th FEMA interim findings are related to the offsite emergency response preparedness of State and local governments in -the vicinity of Indian Point.
The activities to correct the deficiencies will, therefore, be a cooperative effort among the Licensee s and the government entities involved. As in the past, Licensees will continue to participate in and support the efforts of the State and counties to upgrade their radiological emergency preparedness capability.
Af ter discussions among the interested parties, the overall plan for correcting each of the significant deficiencies and for dealing with the minor deficiencies is comprised of the following basic elements:
1)
Development of a consensus as to what nust be accomplished in order to resolve significant deficiencies.
This phase has generally been completed for the significant deficiencies as a result' of consultations between New York State and FEMA in i
mid-August and at another working session among the State and Licensees.
Attachment A discusses the current status of the ef fo rt s to resolve the 1
significant deficiencies identified by FEMA as clarified by the referenced meetings.
i F
t
s
~
Wptember 2,1982 -
..Mr. Ronald C. Haynes 4 2)
Close licensee cooperation with New York State during the development and- -implementation of specific i
resolutions of the significant deficiencies will be i
accomplished during periodic work sessions among-theresponsible organizations.
Based on these
- meetings, some approaches may change as desirable alternatives become apparent.
While the principal av ivities will be conducted by State and local govet,ments, there are some measures necessary to-address significant deficiencies where the Licensees will be principal contributors. such as the alert and notification
- system, communication with. transient populations,. and brochure content and distribution.
We are advised that with -respect to the remaining deficiency
- items, the State of New York will accomplish the corrective measure s as set forth. in Attachment A.
3)
Bi-weekly status sessions among responsible parties at which progress in implementing adequate corrections of significant deficiencies will be discussed and agreed j
upon.
While your August 3rd letter related only to those deficiencies l
identified as significant in the interim
- findings, other. minor I
deficiencies were referred to in the interim findings report.. We will l
also be working with State and local governments to correct these deficiencies after activities to correct significant deficiencies are underway.
One planning requirement which may not be fully clarified during the period for corrective action despite FEMA's involvement relates to the alert and notification oystem, which is involved in - one category of significant deficiencies cl.ted in the interim findings.
The status of the alert and notification sywcom (ANS), is provided as follows.
A telephone survey conducted by the utilities subsequent to the March 3rd exercise indicated that a number of sirens had not been heard by residents living near those sirens.
Subsequent to the exercise, the utilities jointly conducted a complete re-test and performed necessary maintenance on each of the sirens in the ANS.
l As with.any new installation, there were problems uncovered that related to initial construction'and first time operation of a system after the construction test program was completed.
The problems were corrected prior to June 1, 1982 as noted in our June 9, 1982 letter to Mr. George Smith of your staff.
i Mr. Ronald C. Haynes September 2, 1982 4
Our subsequent investigation revealed that there was a generic problem with sirens wherein our 125dB rated sirens provided only 119dB.
On May
- 27, 2 982, in a telephone conversation with NRC staff ~ we noted this - 6dB deficiency and also requested some clarification. of certain of the acceptance criteria.
We are continuing with our testing and analysis so that we have the necessary background information to. respond rapidly should the FEMA acceptance criteria indicate a need to supplement the-system.
In addition to this work, consideration is being given to the ordering of hardware and methods of facilitating ' the local permit process so that we may act rapidly if needs are identified.
If this hardware were installed lwe anticipate some sound level and system enhancement.
Other methods of notification 1are also being explored.
For example on May 27th the utilities formally requested that New York State explore the une of fire and Civil Defense. sirens being sounded in unison with the utility installed ANS in order to enhance the system.
The state is-l currently exploring that option.
The utilities are also purchasing tone-activated radios for use.at all special facilities within the Eme rgency Planning Zone.
These radios would alert. the special facilities over the EBS network.
It is expected that these tone alert-radios will be distributed within ninety days.
I 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. acceptance test referred to in the interim findings is awaiting the development of FEMA criteria which will permit the FEMA evaluation of the ANS at our site.
Based upon our discussion with FEMA we understand that this might occur in late 1982 and a determination by FEMA of system acceptability cannot be made until that time.
As FEMA noted, the withdrawal of Rockland County from the coordinated emergency preparedness process was not within Licensee's control.
While i
Licensees believe that the Rockland County issue will be resolved to the satisfaction of NRC and FEMA, Rockland County's action cannot serve as a basis for findings adverse to the continued licensing of the Indian Point Nw York State has assumed the responsibility of periodically units.
e notifying FEMA of the status of compensatory planning f or Rockland County to the extent that the county's current planning and implementation capability may be de ficient. By law New York State will provide emergency i
l response when this is not performed by a local governmental uthority.
Attachment A provides some details on this matter.
As discussed above, since the issuance of the interim findings, the State of New York and FEMA have met to identify corrective measures which n
--e
-.---.-v-
- -,. ~ - -..
. -. - - ~
Mr. Ronald C. Haynes September 2,1982 are adequate to correct 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 discussions between New York State and FEMA, and is complete with respect to measures required.
2 Should you or your staff have any questions please call my office.
Very truly yours, My 8/
w John D. O'Toole Vice President Attachment CC:
Mr. Brian Grimes, Director Division of Emergency Preparedness U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. Ted Rebelowski, Senior Resident Inspector U. S. Nuclear Regulatory Commission Post Office Box 38 Buchanan, New York 10511
)
+
5
..w
.e
ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY 30, 1982. FEMA INTERIM REPORT f
Statement of Deficiency Proposed Corrective Actions E.
Notification (a) Siren system requires.further (a) Subsequent to the exercise, the utilities I
correction.
jointly conducted a complete retest performed necessary maintenance' on each of i
The Indian I
Point ANS system is now functional.
l Final resolution of the alert and notification system (ANS) issue cannot be accomplished until FEMA has developed acceptance criteria which will permit evaluation of the ANS.
Results of studies and tests (see cover letter) are being reviewed to determine the need for enhancement In parallel with this work, consideration is being given to ordering hardware and compensatory measures such as the use of existing fire and civil defense sirens is being investigated by the State. Tone activated radios are being :
purchased for use at all 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 will be included in the use of EBS messages.
EBS messages. A system will be developed to insure che content of all EBS messages and the prompt and accurate transfer of such messages to the EBS stations. News releases will include information given in the EBS messages.
i _.
ATTACHMENT A i
SIGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT Statement of Deficiency Proposed Corrective Actions E.
Notification (Con't)
~
(c) Procedures for PIO's should be (c) All revisions necessitated by the interim
~
revised to include.the findings will be incorporated or referenced specific items 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 emergency personnel and local improve initial call out methods for schools.
emergency personnel and local school notification.
1 (e) Procedures for establishing contact (e) The State Plan 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.
be trained on such procedures. See E (c) above.
(g) FEMA does not have the most (g) The Emergency Broadcast System procedures up-to-date EBS plan.
for the Hudson Valley and Catskill New York Operational area and plan will be sent to
?
FEMA.
(h) The specific details of EBS (h) The specific details of EBS activation for activation for the four county the four county area, not' reflected in the area are not in the EBS plan.
EBS plan (noted above) shall be detailed in each State and county Plan and provided to the lead EBS Station.
Meetings will be arranged with EBS station management to explain its importance and its operation as it relates to the emergency planning efforts.,
ATTACHMENT A SIGNIFICANT DEFICIEdCIES JULY 30, 1982 FEMA INTERIM REPORT.
Statement of Deficiency Proposed Corrective Actions G.
Public Education and Information (a) 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 implemented.
)
(b)
Inadequate distribution of the (b) Further clarification by the State from the brochure, " Indian Point Emergency FEMA Regional Assistance Committee (RAC) has Planning & You."
been requested.
Copies of the previously transmitted distribution methodology letters-were forwarded to FEMA. Brochure distribution methodology will be reviewed 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 NUREC 0654 criterion, the -
4 in language (s) other than English.
State, counties and utilities will investigate the need for publication of the brochure in language (s) other than English.
A survey will be done on the number of Non-English speaking residents in the 10 i
mile emergency planning zone.
(d)
Inadequate arrangements for dealing (d) The rumor control program used at the with rumor control August 11, 1982 FitzPatrick (JAF) Emergency.
Exercise and approved by all parties 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.
' 1 e
ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT Statement of Deficiency Proposed Corrective Actions G.
Public Education and Information (Con't)
(e) A more adequate description of the (e) An outline of the public information program, public information program, news new media briefings and notification of
. media briefings and notification of transients will be in the State and county transients should be in the State plans. Specific details of this program will and county plans.
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 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 the joint media facility. Further clarification has been requested by the State, from the RAC.
J.
Protective Response (a) Methods for notification of (a) Posters and telephone book insert information
~
transients must.be provided.
will be forwarded to FEMA upon completion.
See C (e) above.
(b). Maps which include population by (b) Maps with population distribution'by ERPA are ERPA should be displayed in EOCs.
available for use at State and county EOC's.
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 provide thyroid blocking agents dissemination of KI (Potassium Iodide) to emergency. workers.
to emergency workers and special populations. This policy will be included in the State Plan.
ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT Statenant of Deficiency Proporzd Corrxetive Acticna J.
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.
(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.
(Maps, 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 cree centers.
reception centers will be added to the plans.
Added capability includes equipment, training and manpower.
(g) Inadequate collection and trans-(g) Additional Standard Operating Procedures for~
mission of field data for consid-collection and transmission of field data eration of decision makers.
will be developed.
Utility, County and EOC staf fs will be trained on the additional procedures.
(h) Evacuation of non-institutionalized (h) Further clarification is needed an will be mobility imparied persons is not requested by the State from RAC to define addressed.
what is adequate to satisfy this element.
ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT' State = ent of Deficicncy Prepo nd Corrretivi Actions J.
Protective Response (Con't)
(i) No evacuation commitments from Bus (i) Compensating measures are being pursued.-
Operators, or locations and number of buses, bus radios and maps.
(j) Some relocation centers are Jocated (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 exercise, a lack of maps (k) Additional maps 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.
K.
Radiological Exposure Control (a) Absence of permanent dosimetry and (a) Permanent docimeters (TLDs) and self-reading 24-hour monitoring capability. More pocket dosimeters (0-5 R) with chargers have sensitive self-reading dosimeters are been ordered. The capability for 24-hour needed. No permanent record devices operation (i.e., shif t changer 4) 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
", i emergency personnel ~needed.'
reviewed and modified.
Personnel at 1'
appropriate locations will be trathed in'new methods and will be demonstrated at the next
/;
exercise.
f
?,
p
i
?
/
.\\
d j' s.
- r
[
4 ,
u
[a e '
4 yr as'
.i<-
-r:
j-
-1 ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT v
Statement of Deficiency
(..
Proposed Corrective Actions r
K.
Radiological Exposrue C'ntrol'(Con't) o J-
- ~
(c) Decontamination levels posted in (c) Levels will be displayed as needed.
d' c,rf wrong sequence (Putnam Plan only).
Personnel will be trained in application of 7
e requirements.
7 j
'f :
/
(d) Disposal of contaminated wastes is (d) The plan will describe the method for not adequately addressed in the disposing of solid wastes.
County Plans.
t e Westchester site chosen for r'
uecontamination will be changed.
o (e)
Inadequate calibration and main-(e) Equipment will be checked for proper tenance of monitoring equipment.'
-operation s'emi-annually, to assure functioning.
P.
Planning Responsibility (a) Rockland's non participation in the (a) Rockland County decision makers will be.
four county plan raises a question as trained on radiological emergency response to decision maker capability to respond necessities.
Compensating 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 is an inherent lack of provision will be included in the State plan capability to upaate such a plan.
for updating Rockland response requirements.
(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 Rockland response requirements current.
(d) Rockland's non participation in the (d)
In the absence of a Rockland County Plan, exercise and planning effort requires compensating measures will be included in compensating measures to be taken, the State plan to insure adequate emergency response in that county.