ML20151U997
| ML20151U997 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/31/1986 |
| From: | Federal Emergency Management Agency |
| To: | |
| Shared Package | |
| ML20151U984 | List: |
| References | |
| CLI-85-06, CLI-85-6, NUDOCS 8602110170 | |
| Download: ML20151U997 (9) | |
Text
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Status Report Indian Point Special Proceeding Cecision (CLI-85-0s)
FEMA Region II New York, New York January 31, 1986 9602110170 060205 PDR ADOCK 05000003 F PDR
- 1. EMERGENCY RESPONSE SUPPORT AND RESOURCES - NUREG-0654 - PLANNING STANDARD C 10 C.F.R. 50.47 (b)(3)
ASLB's FINDINGS:
Record inconclusive as to the existence of letters of agreement with reception and congregate care facilities.
, Commission Coments:
Further', though various schools were designated as reception centers or congregate care facilities and were notified of their designa-tion, not all accepted the designations and letters of agreement are missing for most of them. Transcript at 11,919-23, page 47.
FEMA August 1985 Position:
Issue remains unresolved.
Progress Since-August 1985 Update:
Annual plan revisions have been submitted for three of the four counties involved in the Indian Point' plume exposure EPZ, Westchester, Rockland, and Putnam. No plan revisions have been received for the Orange County plan.
Rockland County
'The 10/85 revision of the Rockland County Plan designates the following seven (7) facilities as reception centers:
Nanuet Senior High School Pearl River High School Salvation Army Training Center Spring Valley Junior High School Spring Valley Senior High School Suffern High School Tappan Zee High School The Rockland County Plan lists (page_M-2) a letter of agreement between the Salvation Army and Rockland County. FEMA has not received a copy of this letter for review and therefore cannot judge the adequacy of this letter of agreement. With regard to the use of school facilities as recep-tion centers, the following is the New York State position as expressed in a December 27, 1985 letter:
Rockland County - the County Emergency Manage-ment Director contends that existing commit-ments between the County Chief. Executive and schools whose facilities are targeted as reception centers are sufficient to insure the use of these facilities. This is the same position that was articulated in our letter to you on August 6, 1985.
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Westchester County The 9/85 revision of the Westchester County Plan designates the following ten (10) facilities as reception centers:
Van Wyck Junior High School R. C. Ketcham High School John Jay High School Pawling High School White Plains High School Westchester Community College Port Chester Middle School Harrison High School Ardsley Miodle School Fox Lane High School The following is the New York State position as expressed in the December 27, 1985 letter:
Westchester County - You have received all appropriate letters of agreement for this county in our letter to you dated August 6, 1985.
The August 6, 1985 New York State letter enclosed acceptable letters of agreement for the Ardsley Middle School and the Harrison High School. In ad6ition, letters from the following schools or school districts were enclosed which indicate that the respective schools or school districts are participating in the " Indian Point Radiological Emergency Response Plan and Procedure for Westchester County, New York" without specifying what roles or resources were being committed:
North Salem Central School Solomon Schechter School of Westchester Port Chester-Rye Union Free School District Katonah-Lewisboro School District Saint Patrick's School Dobbs Ferry Union Free School District White Plains Public School District Rye City School District A letter was enclosed for the Fox Lane High School which listed the emergency coordinator's name and phone numbers, but did not commit the use of any school resources.
Putnam County .
The 9/85 revision of the Putnam County Plan designates the following three (3) facilities as reception centers:
Dutchess Mall Van Wyck Junior High School R. C. Ketcham High School 2
.The following is the position of New York State as expressed in the December 27, 1985 letter:
Putnam County - In FEMA's response to Commis-sion on Indian Point (dated May 8, 1985), you indicated "Putnam evacuees go to Dutchess County. There is a letter of agreement with Dutchess Mall as the primary center."
FEMA has not received a copy of the letter of agreement with the Dutchess Mall for review and therefore cannot judge the adequacy of this letter of agreement.
Orange County Since there have been no revisions submitted for 1985, the 10/84 revision of the Orange County Plan designates the following five (5) facilities as reception centers:
Newburgh Free School Temple Hill School Middletown High School South J High School Warwick Valley Middle School The following is the New York State position as expressed in the December 27, 1985 letter:
Orange County - You have received all appro-priate letters of agreement in for this county in our letter to you dated August 6, 1985.
Acceptable letters of agreement between Orange county and the following schools or school districts were enclosed with August 6, 1985 New State letter:
Orange - Ulster BOCES Monroe-Woodbury Central School District Enlarged City School District of Middletown Newbury City School District A letter of agreement with the Highland Falls / Fort Montgomery Central School District was also enclosed, however, this agreement was not signed by the County.
All Counties FEMA has not received, for review, all of the necessary letters of agree-ment with respect to the availability of facilities for use as Congregate Care Centers. It is understood that the American Red Cross generally ope-rates these facilities and that the letters of agreement would be between the facility owner and the Red Cross. In order to assure that the facili-ties designated as Congregate Care Centers in the respective County Plans are available, FEMA must be provided copies of the letters of agreement for the facility use.
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Evaluation The FEMA position stated in the August 20. 1985 Response to.the Commission Decision remains unchanged. FEMA has received some letters of agreement which were reviewed and found acceptable. New York State has advised FEMA in a January 29, 1986 letter, that they will pursue argessively the signing of the remaining letters of agreement. Until these documents are received, there is no reason to change the FEMA position which was:-
"In summary, FEMA concludes that letters of agreement are required with schools and othtr facilities designated as reception and con-gregate care centers in each of the four (4) counties.- Until letters of agreement are provided to FEMA, and found acceptable, this issue remains unresolved".
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- 2. NOTIFICATION METH00S AND PROCEDURES - NUREG-0654 - PLANNING STANDARD E ,
ASLB's Findings:
No significant deficiencies, but record inconclusive with respect to the existence of or;need for routine-alerting or other procedures for the event the siren system fails.
Commission's Comments:
A The existence of route alerting procedures remains an issue of
. fact for which there is no affirmative evidence'in the record. The
' Commission directed the NRC staff to confer with FEMA and report on the status of compliance with this requirement.
FEMA August 1985 position:
. FEMA' determined that standard route alerting procedures are necessary in all four counties as a back-up system to assure that public alerting can be accomplished within 45 minutes of the initial notification.
Progress Since August 1985 Update:
.The 10/85 revision of the Rockland County Plan states the
. following:
RCS-1, 5.3.8.10:
"If notified of a siren failure' utilize the patrol or local police to provide route alerting."
" NOTE: Route alerting maps and messages are available in police vehicle emergency kits."
RCS-2, 5.3.2:
l "If requested, route alerting for siren 3
failures should be performed utilizing maps and message cards contained in the vehicle kit."
- The 9/85 revision of the Westchester County Plan gives (page 2-93) a procedure for route alerting in the event of siren failure. ,
- The 9/85 revision of the Putnam County Plan gives (pages LE-43 to 47) a procedure for route alerting in the event of siren failure.
No 1985 revisions have been received for the Orange County Plan, however, in a New York State letter to FEMA dated January 29, 1986, a page is enclosed which gives the procedure for use in the event of siren failure.
It is assumed that this page will be inserted in the next plan revision of the Orange County Plan.
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Also enclosed in the December 27, 1985 New York State letter are maps of~
the individual routes for each siren in all four (4) counties.
Evaluation:
As discussed in the August 1985' update, a sampling of route alerting was evaluated in all four counties in the November. 28, 1985 Indian Point Exercise. The plan revisions in Rockland, Westchester,'and Putnam County Plans discussed above close this issue for these three (3) counties.
When the routine. alerting message is formally included in the Orange County Plan, this issue will be closed. Until the Orange County Plan has been revised this issue remains unresolved for Orange County.
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- 3. PROTECTIVE RESPONSE - NUREG-0654 - PLANNING STANDARD J 10 C.F.R. 50.47(b)(10)
ASLB's Findings:
No letters of agreement from.Westchester County bus drivers.
Commission's Comments:
No comments were made regarding this Planning Standard.
FEMA August 1985 Position:
Letters of agreement are required only with bus companies, but not individual bus drivers.
FEMA finds that the issue of letters of agreement remains unresolved until all necessary documentation establishing the existence of these contracts with bus companies is provided by the State including:
o- signatures of all parties involved; o a current contract with Liberty Bus Lines that includes information as to available bus resources including type of vehicle to be provided.
Progress Since August Update:
The 9/85 revision of the Westchester County Plan lists the same four (4) transportation companies as providers of buses as those reviewed in the August 1985 FEMA Update.
FEMA has received no additional material since development of the August 30,1985 Response to the Commission with regard to letters of agreement with bus companies in Westchester County.
Evaluation:
The FEMA position stated in the August 20, 1985 R onse to the Commission Decision remains unchanged. Since there has been ew information sub-mitted to FEMA, there is no reason to change the EMA position, which was:
"In conclusion, FEMA finds that the issue of letters of agreement remains unresolved until all necessary documentation establishing the existence of these contracts with bus companies is provided by the State including:
o signatures of all parties involved; o a current contract with Liberty Bus Lines that includes information as to available bus resources including type of vehicle to be provided."
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- 4. RADIOLOGICAL EXPOSURE CONTROL - NUREG-0654 - PLANNING SCHEDULE K 10 C.F.R. 50.47(b)(11)
A'SLB's Findings:
No significant deficiencies, but record inconclusive as to the adequacy of provisions for disposal of contaminated waste water.
-Commission's Comments:
-No comments were made regarding this Planning Standard. However, the Commission directed the NRC staff to confer with FEMA and provide them with recommandations.
FEMA August 1985 position:
FEPA has evaluated the State's response and found it acceptable for those situations in which the Governor declares a state disaster emergency. However, further classification is needed for those situations in which the county is in command and control (no state declaration).
Progress Since August 1985 Update:
A December 27, 1985 New York State letter to FEMA stated the
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following:
The procedures for disposal o# contaminated waste water when the county is in command and control remains an open issue until USEPA provides New York State a letter to confirm that the proposed method of disposal of contaminated waste water does not pose a significant environmental or public health threat.
Evaluation:
As discussed in the August 1985 Update, the FEMA concern involved cases where there is no Governor's declaration of a state disaster emergency.
FEMA understands it is the New York State position that such a declaration allows the Governor to temporarily suspend specific provisions of the New York State Environmental Conservation Law. The issue is not the USEPA position on waste water disposal. The issue is "How does the New York State Environmental Conservation Law apply to the counties?" The FEMA position as stated in the August Update remains unchanged: -
FEMA has evaluated the State's response and found it acceptable for those situa-tions in which the Governor declares a state disasgr emergency. However, further clahification is needed for those situations in which the county is in command and control (no state declara-tion).
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