ML20038C563
| ML20038C563 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, FitzPatrick  |
| Issue date: | 12/04/1981 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8112110226 | |
| Download: ML20038C563 (2) | |
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MEMORANDUM FOR: Brian Grimes Director g8C U
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Acting Assistant Associate Director yg Office of Natural and Technological Hazards
SUBJECT:
Response to Your Memo of November 5, 1981, Offsite Emergency Preparedness at Nine Mile Point and James A.
Fitzpatrick Nuclear Power Facilities On September 15, 1981, a joint exercise was held for the Nine Mile Point and James A. Fitzpatrick Nuclear Power Facilities. As a result of this exercise, Region II determined a major deficiency existed in the field radiological monitoring portion of the plan.
Therefore, it is questionable as to whether
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l or not the public in the area near both nuclear power facilities could be l
protected if an actual radiological emergency occurred. Specifically, the basis for the deficiency was the lack of training and qualification of the local firemen that were used as field radiological monitors.
In his memorandum of November 13, 1981.(copy attached), the Radiological Assistance Committee Chairman reports that prior to December 15, 1981, there will be agreements between the State, Nine Mile Point, and the James A.
Fitzpatrick Nuclear Power Facilities which will show full cooperation and support in the event of an accident at either facility. Also, prior to December 30, the States will train the local field radiological monitors and they will be minimally qualified; and, local staff will receive full training in contamination and exposure control measures. Therefore, the offsite radiological plans and preparedness will be adequate by December 30, 1981.
Also attached is an October 22, 1981, report from Donald B. Davidoff, Director, New York State Department of Health Radiological Emergency Preparedneus Group, which was in full response to the Region's comments on plans and exercise for Nine Mile Point. This report contains deadlines for remedying the deficiencies found by FEMA during that exercise. However, as indicated above, the new deadlines were established by memorandum of November 13, 1981.
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Joe Picela.T Chair an, Regional Assistance Cerrittee St.S;I C :
OctOcer 10,1961.'Metinc w:. r. S'iSJG - Redi lec:. cal E; ergency Freparedness Gr:cp.
J:e P.::lanc a :d Pcer Garel:.k et w= Ocnald Drt:.deff and h:.s staff 0 discuss.ne'foll:v:ng :arget fatas f0r correttive ac-:Ons en feficiencies free de Sectacter 15, 1981 exercise.
1.
Ac 30 - Cn de training of radiolccical. cnitors it was agreed snat the ccunty would cer::plete the mini:ul required trainim ' efere this date. Four tearts (15 eecple) will receive a full 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to Dec. 30.
Ancther 15 will receive 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of training by de same date.
Finally 8 hcurs of trainirs; fer an additienc1 15 individuals vill te c mpleted prior to the Dec 30 date. All individuals trained will te salaried Oswego Firenan.
FD% Regi0n II agreed dat tnis trainig w rald lead to a sues- '. $' i-~ ease in local acility ard v uld be censidered nin:. a1 Ir accmetec ey __emr 30 es scncduled.
2.
Cec 30 - ?.e Social Service Department of Oswego County will 9 rte corpleted tf the ateve date 'ull training for all its z u:e....~..... a " ~ ~ ~ - -~ - e accue ^ = - o '~ ~~ ".a::.cn and ex;csure con:r:1 eas.:res.
3.
Cec 15 - Fr:cr.c.nis date One State nas agreed to se::rnt letters fr:m teth utility cwners at the Nine. Mile ?cint Site indicating nat an agreement exists presently between the utilities and de State to fully st:;: pert eacn other in a major incident.
S.e State has wreed to sutmit a sumary letter to cer effice detailirx; cur 9:vencer 10 reeting. We also s; reed cc a date fer an exerciae for de Fitzpatricit Plant en de e Nine. Mile Point Site.
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s November 5, 1981 MEMORANDUM FOR: Richard Krimm, Acting Assistant Associate Director Office of Natural and Technological Hazards Programs FRC:
Brian K. Grimes, Director Division of Emergency Preparedness Office of Inspection and Enforcement
SUBJECT:
OFFSITE EMERGENCY PREPAREDNESS AT THE NINE MILE POINT AND JAMES A FITZPATRICK NUCLEAR POWER FACILITIES With respect to R. T. Jaske's October 20, 1981 memorandum to me on the status of offsite emergency preparedness at the Nine Mile Point Nuclear Power Station, we will need a more specific conclusion with respect to the significant deficiencies before we can decide whether to take action under our regulations. We need, in particular, a specification of which of the deficiencies indicated in the documents you forwarded must be removed in order to allow a FEMA finding of adequate offsite preparedness and whether the course of action and schedule proposed by offsite authorities to remedy such deficiencies is adequate. As you know, our regulations provide for a period of up to four months within which signiff. cant deficiencies are to be rectified once the regulations are invoked.
The schedule of actions which FEMA is planning to reassess offsite preparedness is also needed.
In this regard, the findings appear to affect the nearby James A. FitzPatrick plant, as noted in R. Jaske's October 23, 1981 memorandum to me, our consideration is sought of the adequacy of the use of an exercise on this plant to verify that offsite preparedness has been improved.
The statement in the transmittal report relating to the inadequacy of the scenario to demonstrate offsite response raises a question with respect to the application of Guidance Memorandu.n #17. The intent of this guidance, developed by the FEMA /NRC Steering Committee was to provide the basis for fully adequate scenarios.
Your consideration of the role of GM #17 in this case is requested.
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P Brian K. Grimes, Director Division of Emergency Preparedness Office of Inspection a.nd Enforcement cc:
R. Haynes, Region I G. Smith, Region I g k, S. Schwart.
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Washington, D.C. 20U2 7,,,,
OCT 2 01981 MEMORANDUM FOR:
Brian Grimes Director Division of Emergency Preparedness Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission FF.CM:
Robert T. Jaske Acting Chief Technological Hazards Division Office of Natural & Technological Hazards
SUBJECT:
Status of Off-site Preparedness for Nine Mile Point Nuclear Power Station (NMPNS)
This is in response to the NRC/ FEMA Memorandum of Understanding as documented in the third NRC/ FEMA Joint Monthly Report to Congress on Emergency Preparedness.
This joint report states that FEMA shall report on the status of off-site preparedness for the Nine Mile Point Nuclear Power Station by October 15, 1981.
IV The Region reports that in general, during the most recent exercise (9/.3S/81),
the State and local Emergency Operation Center (EOC) facilities and equipment, as well as the emergency management activities, exceeded minimum standards.
However, local activities to gather radiological information (monitoring),
as well as to implement notification and protective actions, were generally weak or not demonstrated.
As a result of these deficiencies, Region II currently finds that it is questionable as to whether or not the public in the area near the NMPNS could be protected if an actual emergency occurred.
(It is important to note that the State in this exercise did not fully activate to the " State Emergency" level because the scenario did not escalate to that status.) The a schedule for resolution Regional staff expects the State of New York to present of the deficiencies by October 20, 1981.
Attached is a draft of the Post Exercise Assessment that was cresented to the State of New York.
If you have further questions, please contact Kenneth Green, Project Officer for NMPNS, at 287-3839.
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FEMA Reading File, Mail Room k@f Act. Exec. Asst. 825 Donohoe Reading / Thomas, 705 Donohoe Regional Dir.e_ctor, Region II, New York THD Chren/ File / Green 613 Donohoe MTH:THD:GREN: maw 10/16/81 613 Donohoe 287-3839 Retyped 10/16/81 sat /287-0220 REWRITTEN: NTH:THD:GAUT: maw 10/19/81 613 Donohoe 287-3838
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DEPARTMENT OF HEAL.TH G 0FFICE OF_T,,PdBlilC:* HEALTH i.
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WILLI AM fr. LE AVY Director Deressor el Pukne Health October 22, 1981 Mr. Joseph Picciano Chairman, Regional Advisory Committee Federal Emergency Management Agency 26 Federal Plaza New York, NY 10007
Dear Mr. Picciano:
Enclosed please find responses to the RAC Plan and Exercise comments based on the Nine Mile Point Exercise.
We look forward to further refinement of any open items after you have had an opportunity to review this material.
The public 9.eeting for the Plan in Oswego is set for November 4, 1981.
It is our understanding that shortly thereafter you will make your final report to Washington headquarters.
We stand ready to assist with last minute l
issues that may arise.
Sincerely yours, a
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irect r Radiological Emergency Preparedness Group Encl.
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RESPONSE
r0 NINE HLLE POINT POST EXERCISE RECOMMENDATIONS I.
Emergency Operations Facilities and Resources 1.
Communications and liaison with U.S. Coast Guard and liaison with Ontario should be ef f ected in future operations or simulations.
RESPONSE: The issue of communicating with Federal agencies and foreign countries, as well as with other States, was raised with FEMA prior to the Exercise. Our letter of August 20, 1981, from the Of fice of Disaster Pre-paredness to FEMA Region II, expressed New York State's belief that such communication more appropriately falls to Federal agencies. At the Exercise, the State Warning Point had on file telephone numbers for con-tacting both the Coast Guard and the Province of Ontario. However, in the absence of a determination whether this should be a Federal or State action, such contacts were not made.
We continue to urge that FEMA assume coordination with other Federal agencies but, lacking such, we will insure appropriate notices are made.
2.
There is need within each EOC for displaying a map on the Operations Room wall showing the basic changing radiological situation, so that all staf f members can keep adequately iniormed.
RESPONSE: Agreed. We are now considering transferring overlays from the Assessment and Evaluation Team to the operations room, as a supplement to the briefings, and to other mapping techniques to enhance radiological updating.
3.
Improvements recommended for the District (State) E0C include:
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Display of maps that show the population distribution near the nuclear facility by evacuation areas (ERPAs),
e Uniform internal communications and recording procedures.
e Maintaining facsimile equipment in working condition.
RESPONSE
We concur with the recommended improvements to the State District ECC and will implement them.
4.
Steps should be taken to tighten up security arrangements, as indicated in comments above.
RESPONSE
EOC security controlled access to the State EOC; no special addition 2l security arrangements appear needed for individual portions of the State EOC.
The security desk at the County EOC will be moved down the hall so that the restrooms are included within the secured area.
5.
Improvements should be made in communications in the Oswego County EOC including some additional telephones for Social Services, Fire, and.Public Works; radio and TV equipment for monitoring news releases; and operational facsimile equipment.
RESPONSE
Oswego County recognizes the need for improving communications l
within the EOC.
Various suppliers of radio communications equipment are being consulted.
Radio (AM/FM) and television are available in the Director's office.
6.
More extensive use of wall display map overlays could be made, such as indication of effected ERPAs, location of the plume, etc.
Also a map showing population by each ERPA is needed.
RESPONSE: Agreed -- As information is received it will be displayed on l
display maps (see #2 above).
l l
. Post Exercise Responses
-J-9 II.
Alerting and Mobilization of Officials and Staf f 7.
A second Radiological Defense Officer should be designated and trained for the County EOC.
RESPONSE
The County has four additional aesignated volunteer radiological defense officers. The County will be recruiting a qualified individual from its own work force and will initiate the necessary train-ing of this person to serve as RDO.
III.
Emergency Operations Management 8.
Considerat'.on should be given to establishing a systematic reporting system from local governments to the State EOC to assure exchange of all operational status information. This system would be in addition to executive level telephonic communications, which should continue.
RESPONSE: Agreed -- We are developing a specific procedure to insure systematic reports on~ operational status between counties and the State.
The procedure will mandate specific periodic briefings.
Informal executive contacts will continue.
9.
Future exercises should include appropriate Federal agency operations participation (FEMA, NRC, DOE, IRAP, etc.).
Featured also should be play involving a State Declaration of Emergency and multi-county involvement.
RESPONSE
Future exercises will include a State Declaration of Emergency and multi-county involvement.
10.
Review should be made to assure that existing agreements with support agencies (such as the U.S. Coast Guard) are current and correct.
RESPONSE
Such coordination is a function of the FEMA mission statement.
We request that FEMA insure current notification information is available to the S ta te.
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l Post Exercise Responses -
11.
State and local agencies should effect necessary programs to assure adequate training of persons with support roles concerning provisions of existing plans and basic policy and essential radiological knowledge.
RESPONSE: Agree -- The State and local agencies are in the process of developing a training regimen for radiological emergency response.
Oswego County also recognizes tt.? need for training for both staff and field personnel. With financial assistance from the utilities, the County has obtained a person to work on its internal training needs.
An exposure control pamphlet for emergency workers will be available in 1982. This pamphlet will be disseminated to all workers, in all sectors.
New York State has an articulated policy on the use of KI.
(See REPP, Part I,Section III.) The Oswego County portion of the Plan will be revised to conform to Part I,Section III.
12.
The roles of State and local representatives should be enhanced to provide a two-way channel of information. This will require cooperation of the licensee, as well as clarification of the function of the EOF.
RESPONSE: Agreed -- The County intends to discuss the role of the NFLO with the licensee in the near future. The EOF functions will be clarified.
IV.
Public Alerting and Notification 13.
The importance of coordination with the U.S. Coast Guard and others to issue adequate notification to individuals on coastal areas affected by the plume should be emphasized in plans, preparations, and exercises.
RESPONSE
We agree. We also continue ta look to FEMA for coordination of Federal agency assistance and. involvement.
14.
As long as the interim system of route alerting is the only primary means for notification of the public, it should be demonstrated.
In future exercises, notification of the public should be demonstrated as fully as practicable, without risk of unduly alarming the public.
Post Exercise Respouses.
RESPONSE: Route alerting was accomplished and demonstrated. The roads that were to be used were used.
Alerting and notification of the public within the 10 mile EPZ will be accomplished by use of a system usin; sirens and tone alert radios.
The siren system as originally designed and submitted for approval should be fully installed prior to November 30, 1981.
If any deficiencies are found with the system, af ter installion and testing, corrections will be made as indicated. With this ystem in place, route alerting pro-cedures will only be ised as a back-up.
15.
Public notification procedures should be improved, including those for the use of EBS.
A protected code should be provided to allow the County PIO to access.EBS. Also, measuree for notifying transients and boaters must be improved.
Finally, ERPAs should be defined in terms that the public can understand.
RESPONSE
EBS procedures have been recently revised. All necessary sign-offs are being procured and identification codes for access have been indicated. The next revision to the EBS procedures will allow the PIO to access EBS.
The County will be meeting with the utilities to follow-up on previous discussions related to transient no tifica tions.
Transient notification will be improved by placing emergency notification signs in hotels, notels and recreational areas. Law enforcement officials will dispatch personnel to close areas and instruct the people to leave the area and what routes to take.
Boaters will be notified by use of the Sheriff's boat patrol and the Coast Guard.
All ERPAs are defined in detail in Appendix A of the County Plan. The boundaries are in terms of street locations which will be used in EBS messages for public instruction.
2
l Post Exercise Responses -
V.
Public and Media Relations 16.
The brochure should be completed and distributed to the public.
1
RESPONSE
Brochures were completed and mailed October 15.
l 17.
Equipment should be providcd to ensure that State and County E0C's and the EOF can receive hard copy of news releases and are able to monitor TV and radio releases.
RESPONSE: Agreed. Existing equipment will be reviewed for adequacy and any necessary additions or changes made.
Television and radio releases will be monitored at the State and County EOC's and News Centers.
18.
Steps should be taken to enhance the rumor control function by providing more publicity, additional telephones and staffing.
RESPONSE
NUREG 0654 does not specify how Rumor Control should be conducted.
Additional guidance from FEMA would be appreciated.
We have somewhat of a conflict in that State and County policy requests the public not use their telephones except for emergency use.
Emergency numbers are contained in the brochures and in the EBS news releases.
Increased staf fing will be available at each emergency r. umber.
Procedures are in place to relay these messages to the State and County Plos.
Please share with us demonstrated approaches from other states.
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l VI.
Accident Assessmetit 19.
Future exercises should include full play of dynamic development of environmental data transmitted to State EOC on a continuing basis throughout the simulated emergency.
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RESPONSE
Once hand-held radios are received, field monitoring data will l
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be transmitted in a more timely manner. The CR0 will coordinate with State ODP Radiological Section and develop a reporting system acceptable to all parties.
We agree that the flow of data between the EOF and State and County E0C's should be improved.
20.
The State should insure that all areas af fected by the plume are notified, particularly those areas not under the direct responsibility of the local j urisdic tion, e.g.,
Lake Ontario, which requires notification of the Coast Guard.
RESPONSE
Yes, please note our request for FEMA role on Federal agency assistance.
21.
Extensive training of radiological monitoring personnel for field teams is necessary..This should be followed by drills. The drills should involve guiding and directing the teams reporting along with actual monitoring and reporting procedures.
RESPONSE: We also view this as essential and a Statewide training, program must be designed and implemented. The County will be scheduling meetings with City of Oswego Fire Department and Alcan Volunteer Fire Departments to discuss the formation of additional radiological monitor-ing teams. The County expects to be able to field three additional teams.
Necessary training will be scheduled utilizing licensee, State and Federal assistance, and should be completed by Spring of 1982.
As noted in Response #11, the State and local agencies should try to identify all training areas. Emergency workers shall be the primary group for training.
The revised training programs will utilize drills and hands-on training. Monitoring teams will be trained in instruments use, exposure
Post Lectut=c gesponses.
control and roles within the emergency system.
Re-training will be incorporated into ongoing radiological courses.
22.
Adequate equipment shopld be. provided and conveniently stored in local facilities f ar prompt actual use or for periodic training and drills.
RESPONSE
Oswego County is compiling a list of required equipmen'_.
Upon completion, this will be forwarded to the State and licensee to i
obtain financial assistance.
23.
The CRO, through the county representative, should continually report the information received from the county monitoring teams to the EOF central data collecting point.
4 RESPONSE: Agreed.
VII.
Actions to-Protect the Public 24 Consider equipping and staffing each congregate care center with more nearly identical capabilities, especially the capability to decontaminate arrivals who were not decontaminated at ? reception center.
Red C'ross does not differentiate between centers, whichever they serve, they intend to equip and staff as a fully-competent " shelter." In this regard, the operations-level relationships between Red Cross and County Departments of Social Services should also be reexamined.
RESPONSE: An interesting concept.
It means in effect that " shelters" are developed for dual use and that traffic and use is interrelated.
Public Information and brochures show evacuation routes to designated j
reception centers.only. Our ' congregate care' centers thus become backup sites to reception centers, i.e.,
primary and secondary shelters.
We have no objection to this approach and will apply the principle in future exercises.
Post Exercise Responses.,
25.
Intensify both individual and team training.
RESPONSE
Yes, we intend to, as noted above.
26 Forms for processing evacuees should be standardized; this was not the case among the dif ferent reception centers observed.
RESPONSE
Standard forms for processing evacuees are appropriate and will be developed.
27.
Ensure full staf f capability to operate bath reception centers and congregate care centers 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day if required. This includes provision for feeding county staf f where the Red Cross is authorized (by its own regulations) to feed only Red Cross personnel and evae:ees.
RESPONSE
We agree 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> evacuation center staff capability would be a necessity.
4 28.
Arrange for standby emergency power for cooking at centers.
RESPONSE
Standby emergency power will be obtained.
VIII.
Health, Medical, and Fxposure Control Measures a
29. An actual demonstration of exposure control and decontamination measures should take place in a future exercise.
1
RESPONSE
Exposure cont,rol and decontamination measures will be 1
I demonstrated in future exercista. Monitoring and decontamination of State personnel and equipment ucs conducted during the exercise.
30.
Consideration should be given to. providing further training for State EOC staff an existing State policy on the use of KI in radiological emergencies.
RESPONSE
Yes.
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.eust txercise Responses '
IX.
Recovery and Reentry Operations 31.
Implementation of reentry actions by field elements should be demonstrated in future exercises.
RESPONSE: Agreed. Actual demonstrations for reentry will be programmed within future exercises.
X.
Relevance of the Exercise Exper7. nce 32.
A f uture exercise should be conducrtd with a scenario that will more fully test the off-site response capability, as well as involve Federal agencies.
Such an exercise might be scheduled to be held on a Saturday in order to more fully activate local response organizations that depend upon volunteers for much of the staffing.
RESPONSE
The State and County agree that both State and local responses should be fully tested, as appropriate.
The feasibility of weekend exercises will be explored, and pros and cons documented.
33.
Follow-up action should be programmed to profit from lessons learned in this Exercise.
RESPONSE: Absolutely and that is our intent.
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RESPONL TO RAC STATE PLAN Ci-:1MENTS Assignment of Responsibility A.l.a.
A review of the state and local portions of the Plan which deal with the assignment of responsibility is in progress.
Necessary revisions will be made.
Article 2-B of the Executive Law, as amended by Chapter 708 of the Laws of 1981, is set forth in the Plan, and is, in fact, the basis for the Plan.
Revisions will, of necessity, conform with the statute and will be completed by January 1, 1982.
A.l.c.
All diagrams will be revised as part of the review of state and local responsibilities.
A.l.d.
This RAC comment has been resolved. This element is now acceptable.
(Information on private telephone numbers was not included in the RAC review copies for security purposes.)
A.2.a.
All necessary memoranda of understanding, once received, will be listed in the State Plan. We would wish to avoid placing all memoranda of understanding in the Plan to avoid creation of an overwhelming document.
(Note discussion on May 27, 1981 - RAC/REPG meeting in New York City.)
The United States Department of Agriculture's role is recognized.
However, we would prefer not adding the descriptive material to the Plan as noted above.
The protocol will be available to EOC staffers.
Part I,Section III, Page III Chart is correct.
Part II,Section I, NMP/JAF - Page 15, Figure 6 delete " Transportation" from Department of Transportation - add " Transportation" to ODP.
Part II,Section I, NMP/JAF - Page 16 is correct.
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l A.3.
We concur in USDA contact procedure.
I
" State Plan Responses Emergency Response Supp;
( and Resources Col.c.
We are addressing the communications issue in our January 1, 1982 report to the Governor and the Legislature. Additional information is also P
being developed by a State Division of the Budget communications task force.
Federal agencies will be asked to specify the resources needed to support their response activities.
The State will designate a liaison person, by title, who will have available updated listings of the facilities and resources required to support the Federal agencies response activities.
a) The Division of the Budget communications task force will consider what each agency has available for communications. As soon as this task force completes its work, all frequency charts etc., will be revamped to show existing capability of communications.
b) The Shoreham Nuclear Power Station will be added to page B-1 as indicated by its development status.
c) Procedures B & H will be deleted from the NUREG-0654 cross reference lists.
C.3.
Correction to page H-8 concerning the State Laboratory equipment and staff capabilities reference will be made.
This item was clarified to the RAC members during the October 7th meeting.
It will be resolved by rewording the quoted paragraph to read as follows:
"...These data are normally delayed from several hours to a few days depending upon the radionuclides present, contam-ination levels and sampling media involved. This cannot be used in..."
1 This will be resolved as discussed in C.1.c. above.
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Memoranda of Understanding will be listed where appropriate.
The agreements mentioned in page H-5, Part III,Section I, refer to agreements among the various NFOs and are not agreements with the State. Thus, we would not propose to include them in the State Plan.
Responses to the questionnaire have been received from 35 hospitals.
A tabulation listing those which indicate a capability to handle 4
accident victims will 'e incorporated in the Plan.
The Memoranda of b
Understanding between Nine Mile Point and Oswego Hospital and Upstate Medical Center (both listed in the Plan) do exist.
As these are agreements between the NFO and the hospital *. hey are listed in the NFO site Plan rather than the State Plan.
Letters of Agreement with the 3rd and 9th Coast Guard Districts have been obtained and will be listed in the Plan.
(Reference, A.3, above).
Notification Methods and Procedures E.1.
New York State has formally requested clarification of FEMA's role in coordinating notification to and requests for assistance from appropriate Federal agencies.
In the interim, the State will direct requests for specific assistance to the appropriate Federal agencies that are included in the Plan.
We propose that FEMA be viewed as responsible for notification and coordination of general Federal response and that USDOE coordinate off-site radiological nonitoring and sampling assistance from Federal agencies.
E.6.
Route alerting was demonstrat'ed. There was apparently a mix-up between the FEMA observers and the personnel involved in the route alerting (Sheriff's patrol, highway department).
The roads that were to be used were indeed used.
State Pian huspenses 6 Alerting and notification of the publ.
sithin the 10 mile EPZ will be accomplished by use of a system usn.; sirens and tone alert radios.
The system as originally designed and submitted for approval should be fully installed prior to November 30, 1981.
After installation and testing, additional sirens and tone alert radios will be installed to correct any deficiencies. With such system in place, route alerting procedures should become a backup.
E.7.
Draft messages are included in the section referenced by your review.
Public Information Pamphlet has been submitted to FEMA.
Sample messages in Part III,Section I will include the requested information in the next revision.
We have a concern with the recommendation that evacuees leave a signal indicating they have left their homes.
It is generally seen as an invitation to loot. We will explore with the Counties alternate methods which may be used for this purpose.
Emergency Communications F.1.c.
Notification telephone numbers for both the 3rd and 9th Coast Guard Districts are on file with the Office of Disaster Preparedness Communications section.
It is our belief that Plan inclusion is not necessary.
F.1.d.
Part III,Section I, Procedure B is the correct reference for State-County-NFO communications. Attachment 4 of this reference specifically illustrates the Radiological Emergency Communications System (RECS) for the Nine Mile Point / James A. Fitzpatrick reactors. The adequacy of RECS was demonstrated during the Nine Mile Point Exercise.
The NFO and County communicated with their respective field monitoring teams by appropriate
state riaa hesponses..,
radios. AII field monitorin lata is suvedinated at the EOF.
F.3.
Awaiting information of FEHA's role, reference E.1. above.
Public Education and Information G.l.
Cross reference changes to Part I,Section II, 9, 10 and 11 will be made. Procedure E describes a coordinated educational progrem. The educational activities and materials listed are being formulated as an effort of the New York State Radiological Emergency Preparedness Group, each County and the utilities. We intend that the program be "up and running" in 1982.
It is policy, however, that additional specifics, samples and schedules should not be plan material and not included in the Plan but rather be made available in the Training Program Plan. We ask your concurrence in this approach. We would request that USDA forward a copy of their Disaster Handbook for potential use in our Plan.
We also request additional information on FEMA's current Public Information Program.
G.2.
Cross reference correction will be made.
Appendix C has been deleted in County Plan.
It is now Appendix A.
Cite Appendix A, paragraph I, page A-3.
G.5.
At the October 7, 1981, RAC meeting, this item was found to be acceptable.
Cross reference Part III,Section I, Procedure C (242).
should be Part III,Section I, Procedure E, paragraph 3.3.
Emergency Facilities and Equipment H.7.
a.
The State lacks iodine detection capability. As a result, the statement in the Plan is correct.
(Page H-8, Part III,Section I).
State Plan Responses However, this capability does exist through the NFO equipment and staff.
b.
The detailed in* formation requested is incorporated in the NF0's site plan which is subject to review and approval by the NRC.
We would hope et avoid adding such information to the State Plan, as it increases the bulk of that document without adding to our response capabilities.
However, it would seem appropriate, as discussed in the RAC meeting, that the NRC discuss the results of its reviews of such capabilities with other interested RAC
- members, c.
New York State requests Federal guidance as to the number of monitoring teams considered sufficient. Meanwhile, the RAC comment will be discussed with the utilities.
d.
The communication equipment for NMP/JAF is specified in the NFO's plan.
The County EOC has radio communication capability with NMP monitoring teams in the field. The State does not have such a capability.
However, we feel our communication link to the County is sufficient.
Field data will be transmitted to the State and the County through the EOF.
l Field monitors from other utilities will utilize vehicles l
belonging to the affected licensee that are equipped with radios, and thus can communicate' direct.y with the EOF.
e.
The items listed on Page 4, Part III,Section II, are those 4
belonging to NYS Department of Environmenta; Jo:.servation. This t
i equipment is located in Albany, N.Y. unless otherwise specified.
i A statement to this effect will be incorporated.
l
- m State Plan Responses i-
. o, f.
The July 1981 Plan does not include these references in its NUREG-0654 Cross Reference, nor did we intend to.
g.
This item was found acceptable upon explanation during the October 7, 1984 meeting with the RAC members. Thus no further resolution appears indicated.
H.ll.
At the October 7, 1981 RAC meeting, it was agreed that the following changes will resolve the issues of this element.
The DEC equipment is kept in the Department Offices in Albany unless otherwise specified.
Wording will be added to the listing stating such. Numerical frequencies and related items will be included after completion of the survey being prepared by the New York State Division of Budget, Communications Task Force.
ODP equipment inventory and distribution is statewide.
Inventory listings are available at ODP offices in Albany, N.Y.
An example of such tabulations is given on Page 20, Part III,Section II.
We feel that including all tabulations in the Plan will grea'tly add to its volume with minimal improvement in our response capability We will add a statement to Page 17 of Part III,Section II stating that instrument maintenance is performed according to the manual RDAM 6-1 and is reviewed and accepted by FEMA.
Accident Assessment I.7.
The Plan states that the NFO has responsibility for off-site monitoring of the plume and.for providing monitoring data to the State and County EOCs. The NFO's capabilities and procedures are detailed in the NFO's Plan and we would not wish to duplicate this information in the State Plan.
Information on these capabilities will e
y.
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. State ilan hesponses ?
be forwarded to EPA for review as agreed during the October 7, 1981 meeting with the RAC members.
State personnel will be deployed according to availability and need as determined by the situation at the time.
Thus, we do not feel specifics need be incluced in the Plan.
I.B.
The information asked for in the comments relating to field monitoring activities is detailed in the NFO's site plan.
As discussed in responses to comments H.7. and I.7. above, these will be resolved by submitting such information to EPA for review and through discussions of these issues between EPA and NRC RAC members.
The issue of specitying facilities and resources allocated for support of Federal resources, will, we believe, be resolved by designating a state liaison person as discussed in item C.l.c. above.
I.9.
The statement that the State does not have capability for measurement of iodine concentrations under field conditions is correct.
Th'e State depends upon the NFO to supply such measurement.
J.9.
(Reference cited is in County Plan and not State Plan.)
Reference to Pages H-23 and H-24 will be corrected to read "Part III,Section I, Procedure H, Attachment 4."
The reference to Part I,Section I, Page 1-9 will be deleted from the 0654 cross reference index.
J.10.e. The RAC members agreed during the October 7, 1961 meeting that the documentation for the State policy decision does not belong in the Plan, and thus it will not be included.
The last portion of the comment applies to the County Plan and will be responded to undey the comments for that portion of the Plan.
' State Plan Responses.'
J.10.f. Same as J.10.e.
J.10.1. Traffic capacities will be provided as requested once they are received f rom the traffic plannin<, consultant.
J.10.1. The Plan provides the required :.nformation by ERPAs in lieu of sectors.
This approach was found acceptable by the RAC at the October 7, 1981 meeting.
J.10.m. See J.9. above and general comments on A.l.a.
J.11.
(1) Procedures for detecting contamination are discussed in Part III,Section I, Page H-8, 9 and 10.
0654 cross reference will be corrected to show this.
(2) Maps showing water supplies have been prepared and are available at the New York State Department of Health.
The Plan wording will be amended to reflect this fact.
(3) As indicated on Page 2 of Part III,Section II, the required lists are available at the N.Y.S. Department of Agriculture and Markets and at the New York State Department of Health.
The authority for decision making as relates to the ingestion pathway is stated on Page 111-39, Part I,Section III,as:
" Directing implementation of protective actions for the ingestion pathway will be accomplished jointly by the State Commissioners of Health and Agriculture and Markets."
This will be clarified by amending it to read "by the State Commissioner of Health.
Implementation of the protective action so ordered will be the responsibility of the State Commissioner of Agriculture and Markets."
Recommendation for protective actions to prevent potential consumption
. State Plan Responses.'
of contaminated food stuffs will be made prior to obtaining sampling results as stated on Pages H-14 and H-15, Part III,Section I.
Provisions for dealing with contaminated foodstuffs are discussed in the Plan on Pages III-45 through 111-48 of Part I,Section III.
J.12.
a) The phrase "if necessary" refers to such cases as the evacuation being carried cuc prior to initiation of a release, in which case monitoring of evacuees will not be needed. The wording will be modified in the Plan to clarify this statement. -
b) Found adequate by the RAC.
c) As agreed during the RAC October 7, 1981 meeting, the State will submit for RAC review a generic procedure on minimum facilities and equipment necessary to establish a decontamination center.
This procedure will be used as a guide for establishing such centers by the State and local agencies.
Radiological Exposure Control s
K.3.a.
(a, b, and g)
The State will make available for review by the RAC members, procedures for distribution of permanent record and self-reading dosimeters to be used during an emergency.
As agreed by the RAC members during the October 7, 1981 meeting, State agencies not using dosimetry on a day-to-day basis need procedures.
These procedures do not require inclusion in the Plan.
c) The State is in the process of acquiring bids for TLDs and 0-5 R self-reading dosimeters and dosimeter chargers.
These are expected to be available prior to the end of 1981.
In the interim, sufficient O
. State Plan nesponses.'
numbers of 0-200R self-reading dosimeters and chargers are available through our State ODP.
d) It was agreed during the October 7, 1981 RAC meeting that the Plan will not be amended to respond to this question.
Designation of radiological liaison personnel by the State agencies will be ascertained by the RAC members during exercises.
e) Sites that can be used as PMCs are predetermined. Which of 1
these will be activated will depend upon the situation and the emergency workers will be advised as to the selected locations as needed.
The incorporation of the lists of sites in the Plan might lead to confusion.
f) This is a comment on the County Plan. We are advised by the RAC members that the counties will clarify the issue in their plans.
K.3.b.
The Plan will be amended to require that copies of all personnel monitoring records relating to the emergency will be submitted to the N.Y. State Department of Health for review and permanent storage.
K.S.a.
After discussions with RAC at the October 7, 1981 meeting, this element was found to be acceptable.
The second comment was withdrawn.
K.5.b.
The following were agreed upon at the October 7, 1981 RAC meeting:
Comment "a" is covered in the response to K.3.a. above.
Paragraphs 4.0 and 5.5.3. of Procedure 6 will be added to the cross reference index to satisfy comment "b".
Comment "c" was withdrawn.
Comment "d" is a suggestion from internal EPA guidance and is not
. ute t%a acupunac o
required by this element.
Medical and Health Support L.1 A list of hospitals capable of handling radiation contaminated
,& L.3.
personnel will be included in the Plan.
L.4.
The information will be included when available.
Recovery and Reentry M.l.
During the October 7, 1981 meeting, RAC concerred in the State's position that monitoring programs initiated during the response phase will continue during recovery until acceptable levels are reached.
Part I,Section IV of the Plan will be revised to include this statement.
M.4.
During the October 7, 1981 meeting, present wording in the Plan was found acceptable for this criterion.
Proper referencing will be made.
Exercise and Drills N.2.d.
The State does not agree with the RAC comment requiring "shall" instead of "may" in this regard.
Personnel who normally collect water or milk samples as an ongoing activity should not have to collect samples during an annual drill.
Personnel required to collect emergency samples who normally do not collect samples, shall participate in periodic drills.
All State samples will be analyzed by the Department of Health's Radiological Sciences Institute (RSI). The RSI continually analyzes sample media including milk, air, water and vegetation.
Its expertise is nationally recognized and routine testing of lab during an annual drill seems unnecessary.
9 a
St, ate Plan Responses N.3.e.
Paragraph 4.2. of Appendix F will be amended to state that:
Each exercise will attempt to conduct as many actual (hands-on) activities as possible and within the resources available for the exercise.
Included will be deployment of monitoring personnel and exercising of assessment and evaluation in order to recommend protective response options to the authorities.
Law enforcement and fire personnel will be exercised on Control Point procedures, route alert (when required) and security matters.
Exercises will include public information activities to demonstrate the coordinated effort of State, local and licensee in keeping the public informed.
N.3.f.
Paragraph 4.2. of Appendix F will be further amended: Observers will be qualified individuals and will be provided additional training if required. All observers will be briefed prior to
- he exercise.
Observer rating sheets and a detailed list of the activities that are to be observed will be provided.
Ccmpleted observation reports will be returned to the Exercise Director or his representative no later than one week af ter the completion of the Exercise.
Observation sheets will be changed for exercises as required.
N.4.
Reference E.1. above.
N.5.
Upon completicn of an exercise, the evaluator and observer comments.
will be reviewed and included in an after-action report. A portion of the after-action report will highlight the lessons learned.
Plan revision, arising from lessons learned, will be executed as appropriate.
Appropriate corrective actions will be administered by the Radiological Emergency Preparedness Group.
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1 State Plan Responses Radiological Training 0.4 As noted in responses 11 and 21 to FEMA exercise assessment, the State and local agencies are re-evaluating and identifying all the areas that need training improvement.
Radiological Emergency a
Preparedness Group is responsible to evaluate the effectiveness of training.
Training programs will be modified accordingly.
The training programs will require ' hands-on' training. Text lectures must be supplemented in order to afford the individual and team personnel the optimum opportunity to visualize and experience how the system works.
Monitoring teams will be trained in use of instruments, exposure control and their role in the emergency system.
Re-training will be incorporated with ongoing training courses, s
We feel scheduling is inappropriate material for inclusion in, the Plan. Training schedules will be provided on a periodic basis.
0.5 Part III,Section I, Procedure F.3.3. page F-3 will be amended to read "... annual refresher training."
IO RAC OSWEGO COUNTY PLAN CONMENTS Assignment of Responsibility A.l.a.
A review of the State and local portions of the Plan which deal with the assignment of responsibility is in progress.
Necessary revisions will be made.
However, Article 2-B of the Executive Law, as amended by Chapter 708 of the Laws of 1981, is specifi-cally set forth in the Plan, and is in fact the basis'for the Plan.
Revisions will be made with the law.in mind, and will be completed by January 1, 1982.
A.l.b.
It.should not be assumed that the State takes the lead role unless a State declaration of disaster is made.
State re-i sources, including equipment _and personnel, can be provided without a State disaster declaration.
A.l.c.
. Diagrams will be revised as part of the review of' State and local responsibilities.
1A.2.a.
See comments to A.l.a.,
above.
A.3.
a.
The, Chairman of the Legislature will no t sign off on the County Radiological Emer'gency Response Plan (CRERP) until after the public meeting.
Oswego County wi*.h New York S ta te will work on agreements with nonpublic organizations and existing agreements will be referenced in the CRERP.
The subject paragraph in Section I.A.,
Authority, will be re-vised so that it agrees with Section III.C. and Table III-1.
b.
The CRERP Section I.A. will be revised to reference local statutes for agreements with the Cities of Oswego ~and Fulton.
Letters of. agreement with Oswego Hospital and b
Upstate Medical Center will be sought and referenced, c.
Reference to EPA as secondary support for accident assess-ment will,be deleted.
l
d.
When necessary, Memorandum'of Understanding will be sought with-local authorities or existing mutual-aid programs or statutes will be referenced.
l i
e.
The responsibility for coordinatio,n of the 50-mile inges-tion pathway is the responsibility of New York State and' is contained in the State Plan.
Emergency Response Support and Resources
~ C.l.c.
The. State of.New York is responsible for identifying facilities and resources (including airports, command posts and communications).
The State will designate a liaison person by title,-who will have available updated listings of facilities.
and resources required to support the Federal agencies.
Appendix E
contains a verbal description of county agency communications.
Table E-1 is merely a listing of existing county radio frequencies and call signs.
Frequencies have been controlled to retain confidentiality owever, they are available for RAC inspection.
A flow chart is' neither necessary nor required.
However, she development of such a chart will be considered.
C.4.
Reference A.3.
above, letters of agreement with Oswego Hospital and Upstate Medical Center will be sought Notification Methods and Procedures E.1.
The New York State Radiological Emergency Communications Sys. tem (RECS), a dedicated Hotline system,1s described in 2
Procedure No. 11, Attachment 7,
pages DE7-1 and DE7-2.
RECS j
r-provides automatic verification.
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-J-E.5.
The reference on page III-22 states that a "new plan" is being developed.
The regional plan still exis:s and is described in detail in Appendix F, Pages F-13 through F-23.
The new EBS Plan for Oswego County has been completed and upon approval of appropriate officials will be incorporated into the CRERP.
E.6.
Route altert,the interim notification system, is contained in Law Enforcement Procedures and was used during the recently completed exercise.
In the future, notification of the public within the 10 mile plume EPZ will be accomplished by use of siren and the alert radio systems.
The systems are scheduled for full installation prior to November 30, 1981.
E.7.
The name of the State and the County w'ill be included in sample messages when the Plan is updated.
In addition, messages will include advice to listeners to stay tuned to the station (s).
Messages will be broadcast as.often as deemed necessary and will state who declares state of emergency.
Messages will begin by stating that this is an important bulletin.'
Oswego County will coordinate rumor control phone numbers with New York State.
(See response to RAC State Plan comments.)
A message will be prepared, which includes information from the public information brochure pertaining to the evacuation of school children.
l Oswego County as well as the S t' ate of New York takes exception l
to this item since such a signal would constitute an invita-tion to vandals and l o o t.e r s.
Verification of evacuation will 1
4 be made by law enforcement officials as described in j
Evacuation Prosedures - Procedure No.
2.
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F.1.,c.
.The notification (and telephone numbers) of the Coast Guard 1
. e and CONRAIL is the responsibility of New York State and are not required in the CRERP.
(See Comment E.1.,
Comments to the State Plan.)
Public Education and Information G.I.
The public information program is still under development '
and will be available for review by the RAC.
The educational activities and materials are being formulated between State,,
County and Licensee.
It is State policy thatche samples and i
i schedules are not Plan material but will be made a ailable in a Public Information Program.
t In Oswego County the Commissioner of Health, using the Sheriff's Department and the Fire Coordinator has county re-sponsibility for notification of farmers.
The USDA county extension agent will also notify farmers 4
in coordination with State Department of Agriculture and Markets.
l G.2.
Same as G.I.
above.
G.4.c.
Rumor control is discussed in E.7.
above.
Responsibility for alerting EBS at the ALERT stage will be included in Volume II, Part I,
Section 4.0.
Emergency Facilities and Equipment l
l l
H.7.
a.
The equipment presently available for county use is listed in Procedure No.
1,.
'This list will be continually updated.
Arrangments for distribut on to l
l emergency workers will be explained more expl}citly.
Cross c
reference index will be changed.
Reference to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis for distribution will be included in the Plan update.
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'ri b.
County personnel are currently being trained.
The present i
maximum strength is:
Monitoring teams 15 people Decontamination. teams people Radiological transportation - 120 people Detection equipment for county teams will be identified per paragraph a, above.
a c.
Correct cross reference is III.c.14; III. G ; Ap p en' dix J.
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Procedure 1 - Attachment 8.
l H.ll.
Agree with comments in paragraphs a,b,d and e and information will be included in the Plan.
Para c:
Refer to H.7.
above.
Staff responsibility for maintenance and acccasibility are given in Procedure 13.
Accident Assessment I.7.
Agree with comments in paragraphs a and b and information will be included in the Plan. Paragraph c:
County personnel will not accompany NFO Nuclear Environmental Monitoring Teams and any reference thereto will be deleted from the Plan.
I.8.
a.
It.is anticipated that there will be 15 county personnel available for radiological monitoring in the near future.
These individuals are currently being trained.
The detail's l
will be included in the updated Plan.
b.
Civil Defense equipment is maintained through periodic checks of calibrat-ion, working order and batteries;- ' Refer to Procedure No. 13.
Instrumentation sensitivities and ranges will be specified.
Re s p o n s ibil it y fot repair and replacement is discussed in Procedure No. 13.
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c.
Hand hold portablo radio 2 nits with local govarnmant frequencies will be available for county radiological field monitors as of the week of 10/12/81.
d.
Until the new Fire Base Station is installed the old Fire Base Station will be used.
e.
The referenced cross reference will be corrected.
f.
Reference C.l.c.
above.
Protective Response J.9.
a.
Please refer to procedures 1 through 9 for the establish-ment of capabilities for implementing all protective ac-
- tions, b.
Beforehand information of location of handicapped individuals-is known by Fire Control and the Health Department.
More information o f this type will be gained through the public information program which will use return postcards that are contained in the public information brochures. Once locations are known, police / fire agencies will b'e used to notify these individuals.
J.10.
New York State has not recommended the use of radioprotective e.&f.
drugs for the public or emergency workers primarily because, to date, experts cannot agree on the effectiveness of the drugs for radiological emergencies involving nuclear power plants.
To be consistent with the State Plan, the CRERP will delete all references to the use of radioprotective drugs.
~s J.10.1.
This information is missing because it is quite voluminous and is being submitted under s'9.rnte cover - Appendix 14 contains Evacuation Time Estimates Within the Plume Expr are Pathway Emergency Planning Zone.
[,1u.1.
a...
1.
- above, ine lactes are contained in netu.
.o
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Radiological Exposure Control K.3.a.
Please refer to Procedure No. 3 sections 4.0, 5.0 and 6.0 and attachment 11 for details on dosimeter distribution, use of dosimeters and recordkeeping.
More details will be provided in the next update of the CRERP.
All emergency workers will be properly trained on recording techniques
- and limitations.of dosimeters.
This training is currently ongoing.
K.3.b.
This will be done at the County Emergency Operations Center and the location will be included in the next update.
K.S.a.
Minimum levels for personnel and equipment decontamination are 100 cpm above background (procedure 3 attachment 13).
Action guides for foodstuffs are in Tables III-4 and III-5.
n (Pages III 51 and III 52 respectively).
K.5.b.
The County PMC is located at th'e County EOC.
Department of Social Services personnel are being trained in these. activities.
More details will be provided.
Refer to paragraph A.3.
above.
The availability and location of emergency first aid field i
kits will be coordinated with New York State and the NFOs.
l Medical and Public Health Support l
L.1.
As indicated in Appendix E, Oswego Hospital is the only i
facility within the county that will be utilized for this 1
~
purpose.
Refer to Procedure 8 Paragraphs 5.4.9 and 6.4'.9.
i L.4.
This activity is the responsibility of Oswego County Le
'ncy for other emergenciYs.
Refer Medical Services, the same as to Procedure No.
8, above.
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,4 Recovery and Reentry Planning and Postaccident Operations M.l. to procedures 1,2,4,5,7,8,9 also address this subject.
More details will be provided.
Exerciset and Drills t
N.2.c.
Refer to Procedure 11, Paragraph 3.3.3.
N.2.d.
(1)
Drill procedures.will include record keeping and analysis of sample aedia.
(2)
Refer to Procedure 11, Section 2.0 and 3.0, Paragraph 3.2 and Procedure 10, Paragraph 3.5.4.
N.4.
This will be corrected to include attachments 3 and 4 and paragraphs 3.2.4 and 3.2.5 of Procedure 11.
Radiological Emergency Response Training 0.4.
Cross reference index gave insufficient references, add a.d.
f.g.
Procedure 12,-Attachments 3 and 6.
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