ML20041C205
| ML20041C205 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/20/1981 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Grier B NRC |
| Shared Package | |
| ML20041C201 | List: |
| References | |
| FRN-46FR61132, RULE-PR-50 NUDOCS 8202260333 | |
| Download: ML20041C205 (1) | |
Text
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NUCLEAR REGULATORY cot *f51SSION
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Note to Boyce Grier Here is the FEMA letter on the New York plants.
Please draft letters to the New York utilities enclosing the FE.R letter and saying this resolves A
your earlier April 22 letter.
Do not send the letters until we have reviewed them as Vic has not decided whether the Commission should see them first.
Brian K. Grimes' Director Division of Emergency Preparedness i
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P.EMOMNDU!i FOR:
Brian K. Grimas, Director Division of Exersancy Preparedness FROM:'
Boyce H. Grier, Directer Region I SL'BJECT:
FEl'.A 1.E1TER CATED AUGUST 19, 1981 In your facsimile transmission dated August 2D,1931, you asked for a draft latter to the New York Utilities transmitting the FE%You statad that the t letter dated August 19, 1981 to them.
letter should say that, "this resolves your earlier April 22 (sic) r letter.
The FEMA letter may be an adr.,utte basis for not rs:;uiring reactor shutdown and for not taking enforcement action at this.tims,..b.ut _..._ _ _. _.
I believe that it is far frco resolving the concarns in our April 24 letter and the attachments thereto'.
Enclosed is a draft letter which places things in their proper perspective.
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/ Boyt'e H. Grier l
Director Inclosure:
Draf t letter dated 8/21/81 cc w/ enclosure:
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(Liernsee) e By letter d'ated April 24, 1981, I transmitted to you a copy of a letter from-the Federal Emergency Managament Agency (FEMA) dated Apri 23, 1981 and its attached letter from FD% to the New York State Disaster Preparedness Ccmission dated April 6, k981.
The attachments to the
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April 6, letter listed numerous deficiencias in the New York State and ~ ~
local er.:ergency response plans for ~the area around your reactor site.
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The enciesed letter from FEPA dated August 19, 1981, refers to the deficiencies in the aforementioned April 6,1931 letter.
FD% expresses their belief that pending the evaluation of exarcise rasults, present State i
Based on actual T rogr:ess.
and local emergency planning is adequate.
correcting daficiencias and your apparent good faith efforts to centinue to do so, no enforcement action is intended at this time.
Nonetheless, the NRC cannot judge 'em6 gen ~cy jireparedness as' being adequaEs at your facility until: the Emergency Plan Implementation Appraisal has been ccepleted; facility, l
State and local emergency plans have been reviewed; a fu1Nscale usrcts?----
has been conducted; and deficiencies which have been identifieh in each of
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these areas have been corrected.
.s Sincerely.
Boyce H. Grier Director
Enclosure:
As stated l
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August 24, 1981 Gentlemen:
By letter dated April 24, 19 81, I transmitted to you a copy of a letter from the Federal Emergency Management Agency (FEMA) dated
. April 23, 1981 and its attached letter from FEMA to the New York State Disaster Preparedness Comm'ission dsted April 6, 1981.
The attach-men L to the April 6, 1981 letter listed numerous deficiencies in tne New York State and local emergency response plans for the area around your reactor site.
The enclosed letter from FEMA dated August 19, 1981, refers to the def.ciencies in the aforementioned April 6, 1981 letter.
FEMA concludes that "the present state of planning is generally adequate to carry out the responsibilities of,the State and 2.ocal government in the case of an accident at these sites".
We thersfore concit.de '
that rhis issue has been resolved satisfactorily.
Sincerely, original signed by:
Boyce H.
Grier Director
Enclosure:
As Stated Addressees:
Pewer Aut.hority of the State of New York Rochester Gas anti tiectric Corp. (Gimna)
Jame,. A. ritzrstrick Nuclear Power Plant /
ATTN:
Mr. John E. Maier Indian Point 3 Nucleat Power Plant
% ice President ATTH:
Mr. George T. norry Electric and Steam Production President and Chief Operating of ficer 89 East Avenue 10 co1vabus Circle Rochester. New York 14649 New York. New York 10019 Niacara Mohawk Power Corp. (Nina Mile Point)
Consolidated Edison Company of New York, Inc.
ATTb Mr. T. E. Lumpges Indian Point 2 Vice Prealdent ATTNs Mr. John D. O'Toole Nuclear Generation Vice President - tauclear 330 crie Doulevard west Engineering and Quality Assurance Byra;use. New York 13:02 4 Irving P2 ace New York, New York 10003
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v.s September 29, 1981 Mr. William C. Hennessy,. Cnairman Disaster Preparedness Co==ission State of New York Public Security Building State Ca= pus Albany, New York 12226
Dear Mr. Hennessy:
Attached to this letter, please find the Post-Exercise Assessment for your September 1.
1981 Nine-Mile Point Exercise, and the Regional Assistance Co=mittee's (RAC) review cor=ents for the Radiological E=ergency Preparedness (REP) Plan for Nine-Mile Point.
It should be noted that the RAC co= cents were made prior to the Septe=ber 15th exercise. Theref ore, many co=ments have been addressed during the exercise and the REP Plan should be altered accordingly.
Concurre'ntly, new defici-encies were apparent or more pronounced during the exercise and will require i
careful review and correction by New York State.
Although the RIP Plan has been improved since the sub=ission of the draf t document this year, and co==ents and deficiencies listed in our letters.to your of fice dated April 6,1981 and Fay 1,1981 have been addressed, it is stjll the deter =ination of the RAC thrcugh their review that a nu=ber of criteria are still inadequate according to FEMA REP-1/::VREG-0654.
In sun =ary, deficiencies in the plan fall in the following areas:
(a)
Assignment of Responsibility The State and Oswego County Plans still do not reflect the latest 1egislation on authorities.
It is our understanding that your office is presently makingethese changes.
It was also noted that during the exercise assignment of responsibility was successfully seconstrated at the State ae.J county level.
(b)
Training Within the Plan, there are several instances where it is evident that personnel require extensive training.
Yet, no time ce==itments for training are indicated. A specific deadline for ce=pletion of-initial training should be included in each plan. A deadline should also be indicated for acquisition of monitoring instrumentation and co=munications equipment where these are not yet in place.
The exercise demonstrated that training must be enhanced at the local level. This was supported by a number of observations by Federal observers.
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ik. William C. Hennessy September 29, 1981 (c) Accident Assessment NRC and EPA believe more detailed information is required in this se ion to assure the State and county's ability to co:plete an ac.. dent assessment.
Observations made during the exercise support the need for clarificatien in the accident assessment portions of the plan.
There was ainost no field monitoring capability de=enstra-4 ted.
In cases where there was,the lack of sufficient training was evident.
(d) The format of the Stafe and county Plan has been improved over that of previcus submissions.
however, under emergency conditions, it vill be difficult to 1 ple:ent because of its bulk and conplex referencing.
The detailed co==ents that the RAC has provided, coupled with a meeting you r.ay request to discuss these comments, should serve to identify the revisions necessary in the REP Plan.
The Post-Exercise assessment report is furnished for y'our information, guidance and appropriate action. Your attention is invited to Page 5, Remedial Action Procedures.
Please provide this office, within twenty calendar days of this letter, your schedule of recedial actions for correct-ing deficiencies on the f ormal recommendations contained' in the report and the deficiencies listed by the RAC on the REP Plan itself.
Sincerely, Jti?
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Vincent Forde
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Acting Eegional Director Enclosures
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ETECL'THE, SUmRY The concensus of the 24-member Federal Observer Team indicated that the objectives of the exercise were generally achieved, which were to assess the State and local r ',onsa capability to protect the public in the event of a radiological emergency at the Nine Mile Point Nuclear Station (NMPNS) in accordance with the New York and Oswego County Radiological Em:rgency Response plans. However, because o f the slender magnitude and short duration of the radiological release, the scenario did not require or result in a full demonstration of the of fsite response capability.
'The exercise focused on thb State and local of fsite response as well as the ensite response by the N}TNS.
The !CPNS provided appropriate interface with the State and County both by issuing notifications of the simulated e:sergency event classes and releases and through the operation of its Emergency Operations Facility (EOF).
The onsite response is not covered,in this evaluation with the exception of the State-lo' cal coordination and interface functions at the NMPNS EOF.
The exercise demon ~strated a mixed of fsite capability to protect the public in the event of a radiological emergency at the NMPNS.
In some observable areas, the demonstrated capability ranged from acceptable to above ninicum standards, while in other areas, the capability was weak and/or not' demonstrated.
In general, the State and local Emergency Operation Center (EOC) facilities and equipment, as well as the emergency management activities (e.g., direction and control and decision taking) exceeded minimum standards.
However, activities to gather. radiological information (monitoring), as well as to implement notification and protectivo actions were generaily weak or not demonstrated.
As a result of 'these deficiencies, it is questionable.as to whether or not the public in the area near the NMPNS could be protected if an actual emergency occurred.
Highlights of the observations follow:
Positive observations include:
Professionalism and dedication by the officials and staff e
participating at the State and local levels.
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Sincere effort by most of those local emergency personnel (many'of
, re volunteers) who did report and participate.
whom a
ell designed and equipped State and County EOC facilities.
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An excellent Media Center that provided good facilities for the press and media.
Generally ef fective emergency management operations within' the e
State and County EOCs.
Areas of deficiencies not ed by observers include:
Lack of training on the part of most of the local emergency response e
personnel.
e Poor or lack of de=onstration of radiological monitoring, exposure cont rol, decentaminat ion, and access cont rol measures.
Failure to adequately r.aobilize response s esources because of the e
extensive involven.cnt of volunteers having other normal workday cor.mittments, ostensibly because this was an exercise and not a real emergency.
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FEMA News Rel se on Status of Off-Site Planning in New York StW h
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08 56 c3 ldman gion 1 Radiation Representative i
Ihtr Husar RAC Chairman Tha attached news release arrived recuntly as a routine mailing f.w.n
- g 4 C3 Tha conclusions stated in the FEMA memo to NRC (August 19, 1981) ai s
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confirmed by the most recently submitted versions of the State / local T
cmergency plans which we have receives.
1 In a conference call on July 27, 1981 involving EPA and FEMA Regiona.1 staff members'the continued conflict in direction and control (evident tha prior drafts of the FYS/ local government plans) present in the forr...
' submission:of the NYS/Oswe,'o plan was discussed at length. At that tim.'
it was agreed that the deficiency in this area had not been resolved.
.In cdditional conversations during that week, the major problem of the i
county's inability to perform the indicated assignments due to the present I,
lack of equipment and trained radiological emergency personnel was also rccognized.
j A cursory examination of the plans sutmittad for Ginna and Indian ? sinc.
indicates that these major deficiencies are present, in varying de wsc.:,
-in all three plans.
If a more.recent formal ~ submission to FEMA has-corrected all the pre dc..st idsntified inadequacies, please forward a copy to this office so that >c )
may review'the appropriate version.
As was discussed by telephone and confirmed by our subsequent formal tw.....
commants (August 26, 1981), the " inconsistencies in direction and con m (
wars only one of the major inadequacies of the plan.
If no new versie.s % 6...,
submitted, I would appreciate an explanation of the justificht. ions le et.c findine by FEMA that "the present state of planning is generally ade/g 1e.
f to carry out the responsibilities of the State and local governme.at a casa of an accident..."
i cc: Jan Geiselman Harry Calley/ Ken Travis Ron Bernacki Tom Elsasser' Leroy Martin
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Atttchment 5
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- T5 view of Int im Critique of Exercise at Nine-Mile Point c __ -
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Jy dman ional Radiation Representative To:
Ihcr W. Husar RAC Chairman 1
We have reviewed the FEMA critique of the exercise at Nine-Mile Point Nuclear Generating Station, September 15, 1981.
The additional comments presented below are prompted by the recognition that many aspects of the exercise, while subtle, were not evaluated in the form used by FEMA.
The basic question of whether an emergency could be adequately handled has not been answered in this case for two reasons:
(1) the scenario was not designed to provide en appropriate test of the plan, and (2) too many participants reacted as l'f they had extensive knowledge of the planned scenario.
Specific comments' follow.
I.
Emergency OperationsJacilities and Resources.
II.
Alerting and Mobilization of Officials and Staff.
No additional comments on I and II.
III.. Emergency' Operations' Management State -
Monitoring teams do not report to the State, but to the County. Therefore, the comment, "more play between all monitoring teams and State EOC appears to be~needed" should be revised to read that inore evidence of monitoring ' activity should be established through appropriate reporting channels.
County -
Imp 3amentation of protective actions was apparently premature; W ever, once the decision was made it was carried out very efficiently.
There were no monitoring activities per-formed by local response organizations due to the structure of scenario.
Monitoring teams were on standby two hours before the scripted release, but were inadequately trained for their rolas and unfamiliar with their radiological
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instruments.
IV.
Public Alerting and Notification.
No additional comments on IV.
V.
Public and Media Relations EOF -
It is probably preferable to have stock press releases on hand to be filled in with the appropriate data rather than try to create them during an emergency.
VI.
Accident Assessment EOF -
The NFO liaison officer at the County EOC provided excellent coordination on accident assessment and protective action decision making.
The plan does not call for the State to participate in field monitoring unless the Governor declares that an emergency state exists.
There was no field data to be obtained by the county monitoring teams to be passed on B
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to the EOF due to the inadecuacy of the scenario in this '
area.
However, the field team (s) which did report scant -
data did not do so in a timely manner. Even data reports indicating background readings are important in planning for evacuation or sheltering.
VII. Actions to Protect the'Public.
VIII.. Health, Medical and' Exposure Control' Measures.
The lead responsibility for these areas lies with the County.
However, State EOC observations revealed that State personnel were providing good support for County decisionmaking.
County -
There was not a " token demonstration of access control measures."
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observers were shown the facilities that might be used at the County EOC for decontamination purposes.
The arrangement observed was inadequate at the present time.
IX.
Recovery and Reentry Operations.
County -
Activity within the EOC was excellents however, the simulation did not extend to notifyir.; field teams of actions being y
taken.
X.
Relevance of the Exercise Experience - Additional ^ Comment.
Based on the results of this exercise, it has not been established that at this time the capabilicy for dealing with a radiological emergency is.present.
cc:
Ken Travis/ Harry Calley RAC Members -
Ron Bernacki Tom Elsasser e
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