ML20058B792
| ML20058B792 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Indian Point |
| Issue date: | 03/15/1982 |
| From: | Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20058A345 | List: |
| References | |
| FOIA-82-236 EA-82-035, EA-82-35, IPN-82-24, NUDOCS 8207260148 | |
| Download: ML20058B792 (4) | |
Text
-
fa f.Wl'W
,. *(..*
Le f
D POWER AUTHORITY OF THE STATE OF NEW YORK 10 CotuM us CincLE NEW Yonx. N. Y.10010 (212) 397 62oo GEC",$E,,T(,",E,"fe,,,,
opanarine o,rican J3MN s. OYSON s
vsyes e
sounts cuaam asase e M GE L INGA M JOSEPH R. SCHMIEDER vics cwasaneam suscutiva vics Pea.ssesNT & CMIsF sas 8 mesa CICHAMO M. FLYNN oc::ERT 3. MILLON28 "S*IENcNamosa' March 15, 1982 r:EcEnicic R. cLAnic IPN-82-24 Ir*Ic'e'a""^~
THOM AS R. FREY I'."$".'E'cA'[='.E'**
Mr. Richard C. De Young, Director
(( N,,h, q f Office of Inspection and Enforcement
'~
U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Subj ect:
Indian Point 3 Nuclear Power Plant Docket No. 50-286 Reply to Notice of Violation EA-82-35
Dear Sir:
The Power Authority of the State of New York (Authority), in reply to the subject Notice of Violation dated February 12, 1982, asserts the
, following:
4 1.
The Authority denies the alleged violation.
.2.
The Authority completed installation of an alert and notification system ( ANS) in the four counties within the plume exposure pathway EPZ of Indian Point prior to February 1,1982, a project undertaken and carried out in cooperation with the Consolidated Edison Company of New York, Inc. (Con I
Ediso n).
By so doing, the Authority respectfully subnits that it satisfied the requirements of 10 CFR {50.54(s) and Appendix E to 10 CFR Part 50 (46 Fed. Reg. 63032) for initial installation by that date and for a demonstration that administrative and physical means had been established for alerting and providing prompt instructions to the public.
3.
Installation of an encoder in Rockland County on January 31, 1982 effected completion of initial installation of the ANS in compliance with Appendix E,Section IV.D.3, to 10 CFR Part 50.
The Authority submits that so long as installation of the ANS was completed by February 1,1982, any deficiency that might have existed on that date is covered by the 120-day period for correction of deficiencies provided by Appendix E,Section IV.D.3, to 10 CFR Part 50.
4.
Initial. testing of the operability of Orange and Westchester Counties' ANSs was completed early in January 1982.
This testing involved l
- 1) local testing of each siren by manually depressing pushbuttons located in the control box on the siren's pole, and 2) testing of the county wide system by sending a radio signal from the encoder in each county's Emergency I
Operations Center and thereafter verifying activation of the sirens by b
8207260148 820617 N
7#
/
SHOLLY82-236 PDR
sa J
checking each siren's electrical circuitry in the control box on the siren's pole.
(Note that a few individual sirens' control boxes were inaccessible fcr checking during th'.s initial test and were therefore considered' deficient.
See paragraph "7" below. )
5.
Initial testing of the operability of the Putnam County system by the same two-step process used in Orange and Westchestar Counties was -
undertaken in mid-January.
This' test uncovered a1ounty-wide deficiency.
The deficiency was repaired by February 1,1982 and retesting of the Putnam l
County ANS was completed on February 5,1982.
I 6.
As of February 1,1982, local testing of the Rockland County cirens, on an individual basis, had been completed.
A test involving the sending of a radio signal from the County's ancoder had not been carried out.
The Authority (on behalf of both Con Edison and the Authority) advised t he Cmmi ssion staff by telephone on February 1,1982 that initial testing, cc distinct from initial installation, could not be completed in Rockland County by February 1,1982 because the County had temporarily lost its Faderal Communications Commission (KC) radio license for the transmitter
'being used f or the ANS.
i Concerted efforts by the Authority, con Edison, and Rockland County l
achieved an expedited reinstatement of Rockland* County's MC license, with modification permitting use of the frequency for the pS, on January 29, 1982.
I'nitial testiny of the operability of the Rockland County system, including ttsp two of the process described in paragraph "4," was completed by Fabruary 3,1982, except for those sirens identified in the note at the end of paragraph "4."
7.
Initial system testing for operability in all four counties was ccxnpleted by February 5,1982, the date by which retesting of the Putnam County ANS was completed.
Access to control boxes on the poles of eight sirens to verify their response to the radio signal was delayed because of their inaccessibility due primarily to winter weather conditions.* This was resolved by February 19, 1982.
1 8.
The Authority and Con Edison informed the NRC Staff of the status of initial siren installation and initial testing by letters dated July 24, 1981, October 30, 1981, December 31,1981, January 29, 1982 and February 26, 1982.
9.
The Authority and Con Edison advised the Commission in a telephone l
call on January 29, 1982 that completion of initial installation and initial tuting of the Rockland County ANS had been delayed by the FCC's rejection of Rockland County's application for renewal of its radio transmitter license, that every possible effort was continuing to achieve reinstatement of the license, and that reinstatement was expected imminently.
In f act,
- Four of the eight sirens that were te=porarily inaccessible are located in a large state park and are included in the ANS primarily to insure alerting summer camp and seasonal transient populations.
-~-
w.
a.
that license renewal was granted on the same day and, as the NPC Staff was subsequently informed, installation of Rockland County's encoder was completed by February 1,1982.
10.
In addition to the telephone call indentified in paragre.ph "9,"
the Authority and Con Edison made frequent telephone calls to the twenission during the week of February 1,1982 to advise the NBC Staff of the progress being made with initial testing, the problems remaining, and deficiencies identified.
11.
The Authority and Con Edison advised the NRC Staff by letter dated February 26, 1982 that initial testing, in addition to initial installation, had been completed.
12.
As described in paragraph "9" above, on January 29, 1982, the Authority and Con Edison notified the NRC Staff of the possibility that installation of the ANS might not be completed by February 1,1982.
l However, installation was completed by that date.
Since administrative and other physical means (including provision for telephone communications and emergency broadcast system activation) had already been established for activating emergency public notification plans, the Authority respectfully subnits, as set forth in paragraphs "2" and "3" above, that the completion of installation by February 1,1982 satisfied the requirement of Appendix E,Section IV.D.3, to 10 CFR Part 50.
13.
Even if the Commission were to conclude Mhat completion of initial
_ installation of the ANS throughout the plume exposure pathway EPZ by February 1, 1982 did not satisfy the Indian Point licensees' obligations under the regulatory provisions set forth in the Notice of Violation, no penalty would be appropriate. By the terms of the Commission's letter of February 12, 1982 which accompanied the Notice of violation, no civil penalty should be imposed because initial testing, as well as initial
- installation, was completed before March 1, 1982.
Very truly yours, e00n s
, c.-m.m-r :
R J P Bayne h,, i*
7 Se or Vice President g
iM-
. ' *e,.,.,
Nuclear Generation C#'!' i'0;.'
l Comm W [,h'y*jj;a2."O. WJ 3 I
State of New York County of New York Subscribed and sworn to before me this /[ day of /kty(
1982.
gp N6tary Publi r' j
f
y(;
- 4 e-cca Director of Nuclear Reactor Regulation U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 W. H. Baunack Acting Chief, Indian Point:
U. S. Nuclear Regulatory Commission P. O. Box 38 Buchanan, N. Y.
10501 T. J. Kenny Resident Inspector, Indian Point U. S. Nuclear Regulatory Commission P. O. Box 38 Buchanan, New York 10501 Mr. Ron Barton United Engineers & Constructors, Inc.
30 S. 17th Street Philadelphia, PA 19101 1
l I
I