ML20065G738
| ML20065G738 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/02/1982 |
| From: | Bayne J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20065G721 | List: |
| References | |
| IPN-82-63, NUDOCS 8210040213 | |
| Download: ML20065G738 (11) | |
Text
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POWER AUTHORITY OF THE ST* ATE OF NEW YORK to COLUMBUS CIRCLE NEW YORK. N. Y.10019 (212) 397.6200 LEROY S CLAIR TRUSTEES O'E * **'No OP
- ac a n W A L,T E R T.
CONSKI JOHN S DYSON e w no mi va rewa GEORGE L. ING ALLS or e.c o m JOSEPH R. SCHMIEDER
[,* 3,",,'[,' g, ",,,,
RICHARD M. PLYNN ROBERT !. MILLON11 FREDERICK R. CLARK
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& panw oaum=c a THOM AS R. FREY
& swa a6coum September 2, 1982 IPN-82-63 Mr. Ronald C. Haynes Regional Administrator Office of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
SUBJECT:
Indian Point 3 Nuclear Power Plant Docket No. 50-286 Planned Corrective Actions for Significant Deficiencies Identified in July 30, 1982 FEMA Interim Report
Dear Mr. Haynes:
As requested by your August 3rd, 1982 letter, please find herein a description of the activities which are planned or underway to correct the significant deficiencies listed 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".
These 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 between the licensees and the government entities involved.
We will provide support for the efforts of the State and counties.
8210040213 820927 PDR ADOCK 05000286 F
PDR p..n
r-r Mr. Ronald C. Haynes
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After discussions among the interested parties, the overall plan is comprised of the following basic elements:
I 1)
Development of a consensus as to what must be accomplished in order to resolve significant deficiencies.
This phase has generally been completed as a result of consultations between New York State and FEMA in mid-August and at another working session J
between the State and licensees.
The details are clarified by Attachment A and are the result of FEMA and New York State and utility efforts.
2)
Close licensee cooperation with New York State during the development and implementation of specific resolutions of the significant deficiencies will be accomplished during periodic work sessions between the responsible organizations.
Based on these meetings, some approaches may change as desirable alternatives become apparent.
While the principal activities will be conducted by State and local governments, there are some measures necessary where the licensees will be principal contributors, such as the Alert and Notification System (ANS) communication with transient populations, and brochure content and distribution.
3)
Bi-weekly status sessions among responsible parties at which progress in implementing adequate corrections will be discussed and agreed upon.
The status of the 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 maintenance on each of the sirens in the ANS.
As with any new installation, the re-test uncovered problems that related to initial construction and first time operation of a system after the construction test program was completed.
These problems were corrected prior to June 1, 1982 as noted in our June 9, 1982 letter to the NRC.
Our subsequent investigation revealed that there was a generic problem with sirens wherein our 125dB rated sirens provided only 119dB.
On May 27, 1982, in a telephone 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.
r Mr. Ronald C. Hayneo
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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, we anticipate some sound level and system enhancement.
Other methods of notification are also being explored.
For example, on May 27th the utilities formally requested that New York State explore the use of fire and Civil Defense sirens being sounded in unison with the utility-installed ANS in order to enhance the system.
The state is currently exploring that option.
The utilities are also purchasing tone activated radios for use at special facilities within the Emergency Planning Zone.
These radios would alert the special facilities on activation of the EBS network.
It is expected that distribution of these tone alert radios will begin within ninety days.
The Indian Point ANS is now functioning and the instances of incomplete functioning observed by FEMA during the March 3rd exercise have since been corrected.
The FEMA acceptance test referred to in the interim findings 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 a unilateral county action over which the licensees had no control.
While 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 units.
To allow it to do so would denigrate the Commerce Clause and the Supremacy Clause of the Constitution of the United States by subjecting Federal law to a county governmental veto.
Rockland County's action, therefore, would be contrary to congressionally established national policy.
New York State has assumed the responsibility of periodically notifying FEMA of the status of compensatory planning for Rockland County to the extent that the county's current planning and implementation capability may be deficient.
By law New York State will provide emergency response when and if this is not performed by a local governmental authority.
While your August 3rd letter related only to ihose deficiencies identified as significant in the interim findings, others were not put in the significant category in the interim findings report.
We will be working with State and local governments to correct these items as well, after activities to correct significant deficiencies are underway.
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Mr. Ronald C. Haynes Since the issuance of the interim findings, the State of New York and FEMA have met to identify corrective measures which 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.
Should you or your staff have any questions please call my office.
Very truly yours, r
\\
/
B ynI
.P xecutive Vice President Nuclear Generation cc: Mr. Brian Grimes, Director Division of Emergency Preparednesc U.S.
Nuclear Regulatory Commission Washington, D.
C.
20555 Resident Inspector's Office Indian Point 3 U.S. Nuclear Regulatory Commission P.O.
Box 39 Buchanan, New York 10511 Mr. Ron Barton United Engineers and Constructors, Inc.
30 S.
17th Street Philadelphia, PA 19101 i
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ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT Statement of Deficiency Propoced Corrective Actions E.
Notification (a)
Siren system requires further (a)
Subsequent to the exercise, the utilities correction.
jointly conducted a complete retest and maintenance program on each of the sirens in the ANS system.
The Indian Point ANS system is now functional.
Final resolution of the alert and notification system (ANS) issue can not be accomplished until FEMA has developed acceptance criteria which will permit evaluation of the ANS at each site.
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 crdering hardware and compensatory measures auch as the use of existing fire and civil.
defence sirens is being investigated by the State.
Tone activated radios are being purchased for use at special facilities within the 10 mile EPZ.
(b)
State and county plans lack (b)
All protective action orders and all actions specific criteria for content and affecting the public will be* included in the use of EBS messages.
EBS messages.
A system will be daveloped to insure the 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.
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ATTACHMENT A SIGNIFICANT DEiICIENCIES 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 Counti to l
emergency personnel and local improve initial call out methods for
- schools, emergency personnel and local school notification.
(e)
Procedures for establishing contact (e)
The State Plan will include the telephone with Federal agencies should include numbers of Federal' agency office numbers.
j office phone numbers.
These numbers are currently listed primarily in controlled copies at the State Warning 1
Point.
J (f)
PIO training is necessary on revised (f)
Upon the completion of the PIO procedure procedures.
revisions, all State and county PIO's will,
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be trained on such procedures.
See E (c) above.
1 1
(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 1_
Operational Area and Plan will be sent to FEMA.
I (h)
The speci fic details of EBS (h)
The specific details of DBS 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 4
j management to explain its importance and its operation as it relates to the emergency planning efforts.
i 1 1
ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY
'O, 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 brochuro (c)
Although not a NUREG-0654 criterion the 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 or some other foreign language program.
A survey will be done on the number of non-English speaking residents in the 10 mile emergency planning zone.
(d)
Inadequate arrangements for dealing (d)
The rumor control program used at the i
with rumor control Augus' 11, 1982 FitzPatrick (JAF) Emergency Exercist 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.
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ATTACHMENT A SIGNIFICAMT 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 news 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 or will described in detail in the plan.
reference other documents containing the floor plan, equipment and location information for the joint media facility.
Further clarification has been requested by the State, from the RAC.
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 G (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 EOCs.
REod wil) 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 Statement of Deficiency Proposed Corrective Actions J.
P1otective 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 care centers.
reception centers will be added to the plans.
l Added capability includes equipment, training and manpower.
i (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 staffs will be trained on the additional l
procedures.
6 (h)
Evacuation of non-institutionalized (h)
Further clarification is needed and will be mobility impaired persons is not requested by the State from RAC to define addressed.
what is adequate to satisfy this element.
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i ATTACHMENT A STGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT j
Statement of Deficiency Proposed Corrective Actions J.
Protective Response (Con't)
(i)
No evacuation commitments from Bus (i)
Compensatory measures are being pursued.
Operators, or locations and number of buses, bus radios and maps.
(j)
Some relocation centers are located (j)
The State has requested a list of the too close to the plume exposure EPZ.
specific centers from FEMA.
Appropriate revisions will be made.
(k)
During the exercise, a lack of maps (k)
Addit'ional maps are now available. The State wa'.
noted at the State and some has requested RAC to identify specific types county EOCs.
and locations where additional maps should be located.
I i
K.
Radiological Exposure Control (a)
Absence of permanent dosimetry and (a)
Permanent dosimeters (TLDs) and self-reading 24-hour monitoring capability. More pocket dosimoters (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.,
shift changes) will be (film badges or TLDs) were available demonstrated during the next exercise.
in the counties.
(b)
Demonstration of decontamination for (b)
Decontamination procedures are being emergency personnel needed.
reviewed and modified.
Personnel at appropriate locations will bg trained in new methods and will be demonstrated at the next exercise.
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ATTACHMENT A SIGNIFICANT DEFICIENCIES JULY 30, 1982 FEMA INTERIM REPORT Statement of Defic.icncy Proposed Corrective Actions K.
Radiological Exposure Control (Con't)
(c)
Decontamination levels posted in (c)
Levels will be displayed as needed.
wrong sequence (Putnam Plan only).
Personnel will be trained in application of requirements.
(d)
Disposal of contaminated wastes is (d)
The plan will describe the method for not adequately addressed in the disposing of solid wastes.
county plans.
The Westchester site chosen for decontamination will be changed.
j (e)
Inadequate calibration and main-(e)
Equipment wl..
- checked for proper I
tenance of monitoring equipment.
operation semi-annually, to assure I
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.
Compensatory measures will be in an emergency.
outlined in the State Plan.
(b)
In the absence of a Rockland County (b)
In the absence of a Rockland County Plan, I
Plan, there is an inherent lack of provision will be included in the State Plan capability to update such a plan.
for updating Rockland responge requirements.
1 (c)
In the absence of a Rockland County (c)
In the absence of a Rockland County Plan, l
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 compensatory measures will be included in compensating measures to be taken.
the State plan to insure adequate emergency response in that county. 1 l
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