ML20215B217
| ML20215B217 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/09/1986 |
| From: | Cumming W Federal Emergency Management Agency |
| To: | Mark Miller KIRKPATRICK & LOCKHART |
| References | |
| CON-#486-1844 OL-5, NUDOCS 8612120081 | |
| Download: ML20215B217 (29) | |
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igc i Washington, D.C. 20472 U1' t O O
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December 9, 19 $ ggg 7I pQ ,3p i Michael S. Miller, Esq.
Kirkpatrick & Lockhart h >
1900 H. Street, N.H.
. Washington, D.C.20036 Re: Shoreham Discovery ,
Dear Mr. Miller:
Enclosed under cover of this letter are various documents in response to your document discovery request of October 10, 1986. Several documents over which FEMA previously asserted privilege as attorney work-product are being
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released. Also, Radiological Emergency Data Forms (RECS Messages) are LILCO only documents and therefore are not subject to release by FEMA. I enclose a letter from Ed Tanzman dated November 21, 1986, which produced all Argonne :
documents in response to my second personal request to search for all documents not documented as duplicated by FEMA Regional or Headquarters files. The only documents not released to you include (1) those documents for which privilege is or has been asserted; (2) LILCO only documents (including certain documents being redacted by LILCO); (3) the two litigation cases files previously indexed; (4) an index to exercise testimony based on the transcript to-date (attorney work-product); and (5) other handwritten notes produced the day of the exercise. Hith respect to the latter, we have not turned up further handwritten notes but our survey of all evaluators, and observers from both NRC and FEMA is not yet complete. All documents over which privilege is claimed and not yet produced are in the nature of those previously produced in camera for the Board's inspection and consist of handwritten notes and annotated materials concerning draft versions of the PEA.
Once again, we recognize that the document production request and interrogatories are continuing and will supplement both as documents and information come to light Sincerely, .
7 William R. Cumming :
Counsel for FEMA
Enclosure:
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/E,eNDD1 Federal Emergency Management Agency VLf!
% g. Washington, D.C. 20472
. September DJ, 1986 ,
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. De Honorable Edward J. Markey Chairman, Subcairnittee on Energy l Conservation ard Power Ccmnittee on Energy and Ccmnerce U.S. House of Representatives Washington, D.C. 20515
Dear Mr. Markey:
Director Becton asked me to respond to your letter of September 15, 1986, relating to the Subecmnittee on Energy Conservation and Power's hearing on nuclear licensing issues relatirg to the Seabrook NJClear Power Plant.
%e hearing is scheduled for Monday, October 6,1986, at 10:30 a.m., at the Newburyport City Hall, Newburyport, Massachusetts. I he Subccanittee invited Sanuel W. Speck to represent' FEMA at the hearing.
Since Dr. Speck returned to private sector anployment earlier this month, the Director has asked me to represent FDtA. As requested, I will provide-25 copies of my prepared statenent to the Subccrunittee office no later than 5:00 p.m., October 2,1986. An alditional 100 copies will be available at the hearing roon.
In your letter of Septenber 15, 1986, you also asked FDiA to provide written answers to fifteen (15) questions. I an pleased to enclose FDtA's response to the questions posed by the Subecmnittee. In addition, as noted in several of our responses, we have also enclosed a number of attachnents includirg FDIA guidance documents, the FDiA-NRC Memorandum of Understanding and documents relating to the Chernobyl accident.
I look forward to meeting with you and the Subecmmittee at the hearirg on l
October 6,1986.
([pl c'r. ly W, L s.. Dave McImughlin
, Deputy Associate Director
! State and local Prograns
( and Support l
Enclosures l
l
4 FDR RESPONSES 'IO SEPTEMBER 15, 1986 QUESTIONS FIOM CONGRESSMAN EDWARD M' JCEY 4
- 1) At an August 2,1983 hearing before the House Subcomittee on Overs.;;ht and Investigations, Committee on Interior and Insular Affairs,
- David McLoughlin, Deputy Asswiate Director for State and local Programs and Support, FEMA, testified, "Both FEMA and the NRC have initiated a joint, concurrent review of NUREG-0654, FD%-REP-1, the major source of guidance to State and local governments in developing their plans and preparedness capabilities. Chanaes, if warranted, are anticipated beginning in fiscal year 1985."
a) The existing source of guidance to State and local governments
. remains Revision 1 of NUREG-0654/ FEMA-REP-1. What revisions have been made to the State and local government guidance criteria which are not reflected in NUREG-06547 FEMA and NRC completed concurrent reviews and assessments of NUREG-0654/ FEMA-REP-1. However, a joint review and subsequent revision of the doc ment per se has been deferred, on request of the NRC, until the source term issue is resolved and a determination of whether changes in the emergency preparedness regulations will be required. ne resolution of this issue is not expected until sometime in 1987.
In order to permit State and local governments more time in couplying with the requirement to test the major elements of their
! emergency plans and preparedness within a specified time frame, the five-year period indicated in N.I.b was changed to six years in a FEMA guidance memorandum, GM PR-1, effective October 4,1985.
This " interim revision".to the document was also designed to bring this recurring requirement in line with the change of exercise frequency from annually to biennially made in 44 CFR 350 published September 28, 1983. The change was coordinated with the NRC.
FEMA has issued a series of documents designated as Guidance Memoranda (GM) that are used: (1) to set forth FD% policies and l
procedures related to radiological emergency preparedness (REP) l regulations, or general Agency policies, (2) to provide clarification l
and interpretation of criteria contained in guidance documents such I
as NUREG-0654/ FEMA-REP-1, and (3) to prcuide information of a more technicai nature t,g support the implementation of the REP program through the transfer of technology. Copies of the operative GM's are attached.
l l b) What revisions have been made to the NRC/FDR formal review process since 1983?
l t No FEMA revisions have been made to the NRC/ FEMA formal review l
process since the publication of FEMA's final rule, 44 CFR 350, on
! September 28, 1983. . 'Ihe Comission amended its regulations in i July 1984 to relax the frequency of participation by State and f local govermental authorities in emergency preparedness exercises at nuclear power plant sites from annual to biennial.
.o c) Please provide a copy of the current Memorandum of Understanding between !GC an3 FD%. Is FD% considerirg any changes to the MOU?
A copy t the current ( April 18,1985) " Memorandum of Understandirn Iutweer
.:ral Dnergency Manajcment Agency and FAJelear Regulatory Comaission" is attached, as requested, nhile the provisions of this MJ raodify specific aspects of the franework of ccnperation between the NRC and FDM, it does not revise the NRC/FD% formal review process.
- 2) Officials for the Public Service Conpany of New Hampshire he/e stated that the Probabilistic Safety Assessment Update, which is currently being reviewed by the NRC, may provide the basis for a reduction in the size of the emergency plannity zone for Seabrook. PSNH has not yet filed a formal petition for such action with the NRC.
a) Has the applicant consulted with FD% about possible charges to the energency plannirg process at Seabrook or about the possibility of specifically reducity the size of the emergency plannirg zone?
The applicant has neither consulted with FD% concernirg charges to the emergency planning process at Seabrook, nor changes to the size of the 10 mile plume exposure energency plannirn zone (EPZ).
We note that the applicant has mentioned to FDR staff on several occasions that they were considerirg requestirg that NRC grant an exemption to reduce the size of the Seabrook EPZ. One such occasion was the March 27, 1986 meetirg mentioned in your list of questions. An attendance list and statement of the meeting's purpose were provided to the subconnittee on July 18, 1986. W inadvertently f ailed to mention, however, that sone remarks a': cut a reduced EPZ proposal by the utility were made. FDM's position was that it was a matter between NRC and the utility.
b) Has the NRC informed FD% of any discussions with the applicant concernirn possible changes to the emergency plannirg and preparedness process at Seabrook?
Yes, Edward Jordan of the NRC informed Robert Wilkerson of FD%
of a discussion about reducing the size of the emergency plannirg zone for Seabrook in a telephone conversation in August 1986.
As we,noted in cur response to you on Septenber 12, 1986, Mr. Wilkerjson'sisole input to the conversation was a recognition that this is wii.hin($RC's area of responsibility.
c) that is FD%'s initial response to the possibility of NRC i consideration of a petition to reduce the size of the energency planning zone at Seabrook?
FD% believes that any charges to the size of the energency planning zone for Scabrook should be reviewed by NRC. It is not FD%'s function to take a position on that review.
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- 3) Has the applicant consulted with FDM in connection with the developnent of a utility emergency response plan for Seabrook?
No, the utility has had no consultation with FDM concerning the development of a utility sinnsored unengency response plan. ney
. did infonn FDM Region I staf f menbers Edward Ramas and John Dolan, on August 22, 1986, that such a plan was being developed for the 4
Massachusetts ccynmunties within the plume exposure EPZ.
- 4) We Subconmittee staf f has reviewed the undated rmwrandum of Donas Dignan of Ropes ar.d Gray on behalf of the Seabrook applicants related to the so-called " misconceptions" about energency planning.
We menorandum was reviewed in a June 18, 1986 memorandum by Edward S. Christenbury, Director and Chief Hearing Counsel of the NRC. Ec review was requested by Edward Womas of FD% Region I.
a) Please explain the ciroamstances by which the Dignan memorandum cane into FDR's possession.
The "three misconceptions" nemorandum cane into FD%'s possession at one of FD% Region I's regularly scheduled Seabrook energency planning coordination meetirgs held on January 21, 1986. De memorandum was provided to meeting attendees by the utility, b) Please explain what pronpted Mr. Thanas to request the NRC review.
Fir. Damas, FDM Region I, -requested the review becaJse the Massachusetts State Civil Defense Director, Robert J. Boulay, requested that FDM ard the NRC review and conment on the menorandum. De FDW Region I request was directed to FD%'s of fice of General Counsel (OCC) with the request that the response be coordinated with NRC. Region I and OGC felt it was desira' ale for both agencies to review the memorandum in order to provide a thorough and coordinated response to Massachusetts.
i c) Was* the ,purpadum and the NRC response circulated to all interested partiesF*
ne nemorandom and response was circulated to FDM, NRC, New flapshire and Massachusetts. FD% Region I sent a copy to the utility.
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- 5) Please provide all documents FDM has received related to energency planning and preparedness activities at the Chernobyl
. nuclear power plant. These should include but not be limited to all internal staf f memoranda, analyses and reports concerning the response of Soviet officials to the emergency at Chern myl.
All of the docuwnts that FD4A has received related to emerger.cy planning and preparedness activities at the Chernobyl nuclear sower plan are attachcJ, t rW".sted.
- 6) Based on the informaion FDO has received about Chernobyl, what has the Agency learned c. bout the need for carefully coordinated of fsite planning and preparedness activities at U.S. nuclear power plants in aivance of an emergency?
At this timo, we are not in a position to address with any specificity lessons learned from Chernobyl applicable to offsite planning and preparedness activities at U.S. nuclear power plants. FD% has joined NRC and the Department of Energy, EPA and the nuclear industry in the preparation of a report on the Chernobyl accident. FD%
accepted the responsibility for the Chapter on Dnergency Response arti Preparedness (copy attached) . The report should be finished by early December 1986. De view this report as a necessary prerequisite for review of the U.S. Radiological Dnergency Preparedness progran, since it will be the most complete and accurate record that we can produce. It should also clearly identify lessons from the Chernobyl experience that can be used in reviewing the U.S.
progran.
- 7) Scrne analysts maintain that the Chernobyl accident was much less serious than the very worst case scenarios considered in the Probabilistic Risk Assessments for U.S. nuclear power plants.
Some analysts also have asserted that the accident was much less sericus than the warst case scenarios that have provided the basis for the 10-mile emergency planning zone (EPZ). However, Soviet officials deened it necessary to evacuate a 30 kiloneter ralius of the plant, an area more than three times the size of the EPZ for which apprcned energency plans are required in the United States.
a) In t $ke ol' tha.Chernobyl accident, is FDR considering any new policy statendats or rulenaking concerning energency planning and preparedness issues? Pleas *. explain in detail.
As stated in cur response to question 6, it is too early for us to answer this question.
6 With reqart tc coordinatirg an organize.ional ' esponse to ra$iolog: 71...oroancies, a review of the U.S. response to the Chernobyl ccideri is being co,menced to determine if we could
- have been .nore. ef fective in such functicas as in'orming the U.S.
public and in cooperatirn with appropriate international organizations. Ris review will also include a circumstance
- where an accident occurs cutside the U.S. but has a significant impact on the U.S. in contrast to the minimum irrpact of. the Chernobyl accident. %is review, which will include reco,menda-tions, is being done by the Federal Radiological Dnergency Preparedness Coordinating Cownittee, chaired by FD4A. Nr, of course, will provide this subconnittee the results of all these reviews flowirg fran the Chernobyl accident.
b) Is fem considerin] any proposals by staff or others related to energency plannirg? Please explain in detail and provide all related documents, includirg internal staff memoranda, analyses, ary3 reports, etc.
FDM has received two proposals (attached) for expandirg the
< size of emergency planning zones (EPZ) for the Maine Yankee and Pilgrim ruclear power plants. ne two proposals are fran 1 Mr. Robert Barter, Chairman of the Lincoln County, Maine Cornissioners concernim the Maine Yankee ruclear power plant and Mr. Willian Golden, Massachusetts State Senator, for the Pilgrim nuclear power plant. As reflected in our response to question 7a above, it is premature to make determinations on proposals such as these at this time as we need more time to i fully assess the implications of the Chernobyl accident and ongoirg studies in this country on the issue of source term values.
The size of EPZ's is determined prirr.arily by source term values, which is an NRC responsibility, for a range of postulated accidents at conmercial ruclear power plants. Further, under the FDM regulation, 44 CFR 351.21(e), it is the NRC's responsibility, in cooperation with other Federal aJencies, to determine appropriate planning bases for NRC licensed nuclear facilities. Planning bases refers to established energency planning paraneters including EPZ's, times associated with radiological releases and charhtteristics of potentially released ra$ioisotapes.
we c) Is FEMA considering any proposals related to establishing time limit requirenents for the evacuation of the energency piknnirg
- ones around nuclear power plants? Please explain in detail.
l I There are no maximum time limits for the evacuation of persons l
residing in plume emergency plannirn zones around nuclear power l plants. FE*.A is not consideriry establishing time limit requirenents l
for evacuation %e existing requirement for establishing evacuation l
time estimates (ETE) is set forth in element J.10.1 and Appendix 4 of NUREG-0654/FDM-RCP-1. Ris function is the responsibility of State aM local governnents, in consultation with licensees,
- FDR and the NRC, and the resulting CTE's are incorp3 rated into site-specific energency plans. Per agreenent with the NRC, FDR has developed a conpater model, DYNbV (Dynanic Evacuation), to
- assist State and local governnents in developing ETE's.
- 8) We Subco mittee has received a copy of an attendance list at a meeting on March 27, 1986 to discuss energency planning at Seabrook. Accordirg to FD%, the meeting attendees discussed "the complete FDM plan and exercise review arti the NRC hearing process, and how this would affect an integrated schedule for projected Seabrook planning, exercise, and Atmic Safety and Licensing Board (ASIB) events. (Sane schedule was sent to the State the followirra day.)" We attendees were Ed Jordan ark! Ed Cnristenbury of NRC,10 FDR of ficials, Edward Brcwn of New Hanpshire Yankee, Bruce McCarthy of BME Strategies, and Monas Dignan of Ropes and Gray.
a) Please prcnide all notes, or transcripts, of this meeting.
We notes Edward %cnas, FDR Region I, made at the meeting and which ware later typed by his secretary, Carol Roselli, are attached. We original handwritten notes are available if the conmittee desires then. A copy of the handwritten notes of Richard W. Krinn, FDR HeakI uarters, are also attached.
b) thre other parties to the Seabrook licensing proceedings including States, localities, and intervenors notified of this nectirg?
As f ar as we knx, the other parties to the licensing proceeding were not notified of the meeting.
- 9) that is the history of conpliance with the post-3ree Mile Island emergency planning regulations?
a) Pleave explairk FD%'s progran of monitoring conpliance with energency plannirvrend preparedness regulations.
The policy and procedures for monitorirg compliance with State and local government emergency planning and preparedness "are set forth in FDM regulations (44 CFR 350 and 44 CFR 351) and specific guidance memoranda (CM EX-1 and GM PR-1). Essentially, FEMA monitors and evaluates five major components of State and local governnent emergency planniry and preparedness. Dese conponents include: (1) emergency response plans; (2) exercises
performance; (3) public meetirgs; (4) alert and notification systen design aM operability; and, (5) ongoing periodic requirements such as drills and annual updatina of public information materials.
These activities are monitored and evaluated by FDR Regional personnel through FDM-chaired Regional Assistance Conmittees, with Hea$ quarters support and coordination.
Guidance has been established by FD% for evaluating problen areas in all of the five components identified above and includes the follcuing guidance memorandum (G4): m-16, GM-17, GM-18, GM EK-1 and GM PP.-l. . These Gi's are included in an attached listing of
" Operative Guidance Memoranda." BecaJse of the critical nature of exercise performance, FD% policy and procedures for evaluating such perfonnances is set forth below.
For problem areas identified in exercises, three categories and corresponding corrective procedures are established:
(1) Deficiencies - they are inMequacies that directly impact on an organizations capability to protect public health and safety and, therefore, nust be corrected within a time frame, not to exceed 120 days fran the date of the exercise; (2) Areas requiring corrective actions - they are inaiequacies that are serious enough to warrant correction but need not be corrected until the next biennial exercise; and, (3) Areas reemriended for improvement
! - problan areas which organizations are encouraged, but not required, to correct in order to enhance their emergency response capabilities.
Based on FD%'s evaluation of these five progran conponents, findings are maje for Fen's use in its "350 process" and are provided to the NRC for its use in its licensing process, b) If FDn identifies deficiencies in emergency preparedness at a i particular plant, what is the process by which the Agency informs the NRC so appropriate enforcement actions can be implemented?
FDM Gaidance Memorandum (GM) EX-1, Remedial Exercises, specifies the process and time francs by which the Agency informs the NRC of defici. ncles in energency preparedness. According to the CM, j
FD% willi notily tk NRC promptly of exercise insiequacies where the FDM Rejional Of fice has in31cated that there is a potential or need for renedial action. This discussion and consultation process between FDM and NRC Haa$ quarters of fices contirwes until such tine as the remedial action evaluation report is sent to NRC by FD%.
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c c) that deficiencies still exist in energency planning and preparedness
' around U.S. nuclear power plants, especially with regard to alert j
anj notification systens?
Seabrook Nuclear Power Station
- As the Subconmittee is adare, there were numerous deficiencies and areas requiring corrective action as a result of the February 1986
- Seabrook exercise of the New Hanpshire REP plan. In aridition, Massachusetts has not subnitted a plan to FDR.
Indian Point NJelear Power Station, Buchanan, New York In the June 4,1986 full-scale exercise at Indian Point, deficien-cies were identified in the follcuing areas:
- Appropriate information was not being transnitted by the Bergen County, New Jersey, liaison representative in the R):kland County Dnergency Operations Center (EOC). Wis i
limited the response capabilities of Bergen County, a host county for the 10-mile Dnergency Planning Zone for Indian Point.
- A lbstchester bus dispatcher did not demonstrate a$ equate knowledge of responsibilities. Wis could have impeded the protection of the public due to improper dispatch of buses.
- Plans and procedures for 2 nonpublic schools in Rockland County have not been developed.
' me Orange County ra$iological field monitoring tean did not demonstrate adequate monitoring capabilities.
- The operation of the Orange County receptiory' congregate care center was poorly managed.
- Administrators at same schools in Orange County were not aware of radiological emergency response procedures.
l On Septonbar 35, 1986, staff of FEMA Region II met with represent-l New Jersey and the utilities operating
' g atives Indian Point to dih buss a renedial exercise to address these dC.New' York,,
! deficiencies. On the basis of that meeting, the schedule for remedial drills /a:tions will be established. FD% has algo asked the State of N2w York to provide a schedule of other corrective actions.
In aridition to the above, NRC requested FD% to provide a specific findin; about wheth?r the of fsite radiological emrgency preparedness plans for Indian Point are a3 equate to protect the health and . safety
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of school children in the event of a ra$iological mergency at the site. On September 17, 1986, FDM delivered a negative finding on that specific issue. That finding was based in part on aspects of the June 4,1986 exercise performance as roted above. Ocher plan-related acpects which contributed to this assessnent were lack
- of the required letters of agreement for reception centers and
- . transportation resources, and the necessity for training in certain areas. FDM has indicated that we will provide a supplanental firding on this issue by February 1,1987, to take
- into consideration: 1) the results of the remedial exercise / actions aidressing problens related to the June 4,1986 full-scale exercise; and, 2) supplemental documents which have been submitted since the cutof f date for materials to be considered in the Septenber finding.
Shoreha, Nuclear Power Station, !!auppauce, Long Island, New York j Neither the State of New York nor Suffolk County, the local govern-l ment, are currently participating in the offsite emergency planning
- process for Shorehan. The utility, Iong Island Lighting Conpany
- (LILCO), has draf ted an offsite plan, which FDM has reviewed under the terms of a Memorandum of Understanding with the NRC.
A basic problem with the LIlf0 plan has been the question of whether j LIlf0 has the necessary legal a2thority to implenent it. This issue J
was not in FDWs jurisdiction to resolve. Therefore, FDM provided j p1an revie.as on a technical and operational level only. On that level, there currently remain 5 inadequacies in the plan j ( as of Rev. 6) .
An exercise of Revision 6 of the LIICO plan was conducted on February 13, 1986. Five deficiencies were identified. On
' April 18, 1986, FDM delivered the post-exercise assessnent to
- NRC. In the near future, Atomic Safety and Licensing Board hearings
, on the exercise are to begin.
Susquehanna Stean Electric Station Exercise Deficiencies Date Identified: 5/1/85
- 1. Fishing Creek Township did not participate in the exercise.
c I
i 2. Dion,receiWing the Governor's protective action decision from the PennsylvanM Dnergency Management Agency (PDR), Columbia
- County of ficials informed the risk municipalities of the time for siren and EBS activation, but failed to m3 vise them to evacu ate.
j St atus: These deticiencies renain uncorrected by the Canmonwealth of Pennsylvania - no remedial exercise has been conducted.
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%ree Mile Island Outstandirr) Planning Inadequacies ne following plan ina$equacies have been identified in 3ree Mile Island plan reviews:
- 1. W enty-Four llour Staffing Essentially, none of the municipal plans give reasonable assurance that they have sufficient personnel to respond to an energency round-the-clock, for an extended period. In sone cases, only a few additional backup positions need to be filled, while in others, sone primary staff positions renain unfilled. In most instances, the plans note that staff renbers will be responsible for notifying deputies and other em rgency forces. However, no nanes of the deputies are included in the plans.
- 2. Handicapped and Hearing-Impaired Individuals Many of the municipal RERPs state that lists of hearing-impaired and/or handicapped remain under developnent. It is noted in your April 23, 1985 letter that on April 12, 1985, as part of the T4I information brochure distribution, a special Needs Information Card was included to poll special assistance requirenents for the physically disabled, hearing-impaired and other special needs.
Until this information is incorporated into the TtI municipal plc.ns, the planning process must be considered incomplete. All plans, at a minimum, should include the numbers of handicapped and hearing-impaired individuals in the plan.
Status: Wese inadequacies were identified in Septenber 1985 and no corrective actions or schedule of corrective actions have been submitted.
Beaver valley - West Virginia Planning Inalcquacies - 23 ne fpilosing plan ina$equacies haie been identified in Beaver Valley plan revkws speciyc to the State of West Virginia:
- 1. All reference to the IRAP in the State and county plans should be updated to reflect the Federal Raiiological Dnergency Response Plan (FRERP) published on tevenber 8,1985. Under Federal responsibilities, EPA has been listed at number 9 and 11.
tbmber 9 is obsolete and should be deleted. (Ala)
- 2. we urst Virginia Office of Ehergency Services uses a duty of ficer systen for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage. De State plan should contain more detailed information and instructions on how the duty of ficer system functions. (Ald, Fla)
- 3. We State Department of Health has the responsibility for accident assessnent and protective action recormendations. It is understood that each element of response should list one primary responsible organization, however, in this case it may be clearer if a primary organization was included for each level of response as was done for Cormand and Control, since all levels will haie responsibilities when protective actions are initiated. (A2a) 1
- 4. We State plan should include Letters of Agreement with the CPCS-1 radio station for Hast Virginia and with the RACES organization. (A.3)
- 5. We Hancock County plan does not contain Istters of Agreement with School Districts who are to provide buses for transportation and schools to be used as mass care centers. All Intters of Agreement do not state specifically what service or assistance will be proiided. (A.3) ,
- 6. We State plan does not contain first and second shift personnel for each staff pasition. (A4)
- 7. It is reconmended that State personnel bringing additional dosimetry equipnent to Hancock County be dispatched to Hancock CoJnty at the alert staje. (C2a, H4)
- 8. PAGs lister 1 in the Hancock County plan on page F-2 are not consistent with EPA PAGs or those given on page 1-2 of the sane county plan. We use of the top of the range of the EPA PAGs does not allcw evacuation at the low end if deemed appropriate.
Evacuation should also be recormended based solely on plant conditions even if there is no projected dose and the plan l
should allow for this. (D4)
- 9. .Ihe Hancock CoJnty plan does not call for activation of the EOC until Gondral Dnergency. In order to aiequately respond to an
'energency*theMOC should be activated much earlier in an incident. (H4).
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- 10. Inventory lists contained in the plan as to what equipnent is included in ewrgency kits do not include dosimeters Of any kind, patassium iodide or conrunications equipnent. (H-ll)
- 11. Althou0h Annex 15 of the State plan includes an equipnent list that shcus the instruments needed to measure radioiodine concentrations are available, this specific capability has not been described. (19)
- 12. ranners within the 10 mile EP2 may insist on reentering the EPz to feed their livestock. If this occurs, procedures nust be
- developed to monitor and limit ra)iological exposure to this segment of the population. (J9)
. . 13. We plans indicate that there is not sufficient dosimetry available to provide each emergency worker aiequate do.simetry.
In addition, there are only encugh CW-742s to provide one per group. It is not acceptable to have any emergency worker unmonitored. At a minimum, each worker should be issued one TLO, on high range (0-200R) dosimeter and one mid-range (0-20R) .
No indication of the rumber of TI.Ds a/ailable to Hancock County has been included in the plans. (J9, K3a)
- 14. State anJ county pl anz f ' $ be censistent as to who will be aatharized ta w L u. O a p. tective action. Were is no statenent as to how much K1,o a>ailable, where it is stored, if it is pre-positioned in Ha- c xk County or who is responsible for delivering it to Hancock Cunty. (K3a)
- 15. Dnergency workers are to report an exposure of 1 ren to their supervisors. We ccunty plan indicates the a/ailability of CW 742s only. We CW 742 will not accurately measure 1 ren. (K3a)
- 16. We State plan states that there are 3000 CW-742 dosimeters stored in the State EOC. It is recenenended that some of these dosimeters be pre-positioned in Hancock County. (K3a)
- 17. Were is no link fran an emergency worker's supervisor to the County Radiological Of ficer for althorization to exceed the 1-5 ran and 5-25 ran exposure. Wis decision, as stated in the ccunty plan, should be made by the County Dnergency Managenent Coordinator in conjunction with the Radiological Officer. It should not be made by a supervisor unless he is trained and qualified to interpret dose readings. W e Emergency Warker Procedures, page R-10-21 of the County plan should include the link between the supervisors and the County Ra$iological officer. (K4)
- 18. Although there is no " correct" level at which decontanination ji,f individuals is required, the State an$ county plans should ajret, on what ,that level is. In addition, those levels sh.uld be at the lowe n level detectable on survey meters. (K5a)
- 20. Ingestion PAGs given in the Hancock County plan are not consistent with the latest EPA guidance. (J9)
. - _ . -..,-.w,..--__- _
- 21. Dif ferent symbols should be used on appropriate maps to depict traf fic orx1 access control points and monitoring points. (J10a)
- 22. We cwnty plan does not aidress hw traffic impediments
- (stalled vehicles, snowbound roads, etc.) will be cleared from
- evaajation routes. (J10k)
- 23. State ark! cwnty plans should be charged to State that the county will participate fully in an exercise with the utility, ,
Wst Virginia and other States and local goverrynents within the 10 mile EPZ of the Bewer Valley Power Station at least every two years. (Nia)
St atus: Wese plan inadequacies were identified in Jarvary 1986 and at this time hwe not been corrected. However, the State of mst Virginia is apparently working on corrective actions and plan revisions, which are expected soon.
Beaver valley - Pennsylvania Cutstanding Planning Inaiequacies The folicwing plan inajequacies hwe been identified in Bewer Valley plan reviews specific to the Ccrinonwealth of Pennsylvania:
- 1. We plans for Bewer County and 21 EPZ municipalities do not aiequately address the capability to establish full staffing of their respective ECCs on a 24-hour basis.
- 2. We Bewer County plan does not a$ dress protective actions for prisoners and staf f of the Bewer County Jail. We RERP for this f acility is still under developnent.
- 3. W e Beater County EOC is located within the 10-mile EP:t the plan does not provide protective measures for the staff of the EOC.
Status: Even though the plan inadequacies were identified in July 1985, they remain uncorrected. Pennsylvania advised j .,
in February 1986 that specific corrective actions and
., . senedule p' uld not be provided pendirg major plan
,revisiond.vs Susquehanna Stean Electric Station ,
Outstanding Plannirg Inaiequacies ne follcuing plan inajequacies hwe been identified in Susquehanna plan reviews:
- 1. Staffirn lists contained in both risk county plans f ail to provide assurance that either county has assigned staf f for at least two full shifts. We risk counties must establish the
- ~ . .. _ .- _ _ _ _.-- - - - _ _ . _ - _ - _ , _ _ _ . _ _ _ _ _ , . . ___ _ _ _ _ _ . _ _ . - - , . - _ _ _ _ _ _ . _
capability to perform all key functions continuously for a
- protracted period, aM staf firn lists in the plans should be aneMed to show this capability. (REF: A.4)
- 2. ne plans for 26 municipalities (all except Nescopeck Township)
' - do not include conplete EOC staf firg lists, denonstratirg that all positions can be manned for at least twa full shif ts. ne municipalities must recruit and train aiditional staf f members, as necessary, in order to establish the capability to perform all key functions continuously for a protracted period.
Staffirg lists in the plans should be amended to show this capability. (REF: A.4)
- 3. We State plan provides no assurance that all identified radiological expusure control needs hace been procured and distributed to State agencies as specified in the plans.
Additional radiological exposure control resources, as necessary, should be procared, and the plan should be amended to verify that quantities of low and high range dosimeters, TLDs, dosimeter chargers, survey meters, and KI tablets, suf ficient to meet the identified State agency needs, are in place at the distribution points. (REF: H.ll. , K.3.a. )
- 4. We plans are inadequate regardirn inventories of dosimetry and KI for use by both county ard municipal emergency workers.
De followirg specific problems are noted:
The risk county plans do not provide sufficient assurance that the identified risk county and municipal radiological exposure control requirenents he/e been procured and are in place at the county EOCs. Additional radiological exposure control itens should be obtained, as necessary, and the plans should be anended to verify that quantities of dosimeters, Tut, and KI tablets, suf ficient to meet the identified risk county and muncipal needs, are in place l at the distribution points.
l We ra31ological exposure control requirements identified by
' ten municipal plans exceed the correspondirn requirements it for thpse connunities as identified in the risk county
.. 151 ansf indicatirg a shortf all of over 400 dosimetry /KI kdts in th{ risk cwnty irwentories. Discrepancies exist between the Columbia County plan, and the plans for Beaver i
'Ibanship, Berwick Borcugh, Briar Creek Borcugh, Briar Creek Township, tbrth Centre '1bwnship, and South Centre 'Ibwnship.
Discrepancies exist between the Luzerne County plan, and the plans for ilunlock Township, Nescopeck Borough, New Colunbus Borough, and Sugarloaf Township.
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I
.O Wese discrepancies should be resolved, the appropriate plans should be anended accordirgly, and the counties' inventories should be increased, as necessary. (REF: H.ll., K.3.a.)
I
- 5. Four municipal plans are deficient in providirn m$ equate !
- assurance that the necessary lists identifying the nanes and
- locations of hearing-impaired residents have been conpiled.
We municipalities of Fishirg Creek Tcunship, Black Creek Township, Nescopeck Borough, and Slocum Township should prepare lists of hearing-impaired residents, and the plans should be ma$ified, as necessary to assure that their people will be alerted, ard that the lists will be kept up-to-date.
(REF: J.10.c.)
- 6. Three municipal plans do not provide adequate assurance that lists of mobility-impaired residents have been prepared. Lists identifying the nanes ard locations of mobility-impaired residents should be prepared for Fishing Creek hwnship, Nescopeck Borough, ard Slocum Township, and the p1ans for these nunicipalities should be modified, as necessry, to assure that these people will be evacuated, and that the lists will be kept up-to-date. (REF: J.10.d.)
- 7. We State plan is deficient in establishing an a$ equate procedure for distributiry dosimetry /KI kits to the specified State agencies, and then to the individual energency workers.
The plan provides only a vague and contradictory outline for supplying the agencies, and establishes no procedures for further distribution to the workers. Additional planning details are necessary to assure efficient and timely State-level distribution of dosimetry /KI. We State plan should be anended accordingly.
(REF: K . 3. a. )
- 8. Distribution of dosimetry to the two EPZ hospitals has not been aiequately a$ dressed by the plans for the municipalities in which they are located. We plans for Nanticoke City and Berwick Borough should be revised to include the necessary proiisions for redistributing the dosimeters, received frcm their respective county EOCs, to the hospitals. (REF: K.3.a.)
St at,us: State has not prcwided corrective actions or schedule of
.corrtictig action for these plan inadequacies.
Davis Besse Nuclear Power Station, Toledo Edison Co.,
Toledo, oino In Deconber 1985, FDM rejected the State of Ohio's proposal to
- redefine the 10-mile plune CP2. De State's proposal called for eliminating a portion of !.ucas County within the 10-mile EP2 and for eliminatinj that part of the City of Port Clinton (Ottawa County) praicusly included in the original planning effort.
Following consultations involving FDM, Ohio, NRC, arr3 the utility, the State has satisf actorily responded to the EF2 concerns raised by FDR and is currently working toward resolution of the remainirn issues. Af ter conpletion of necessary plan modifications, exercise
! activity and a public meeting, exercise activity and a public necting, it is anticipated that FD% Region V will hwe sufficient infornation to proceed with an evaluation of Ohio's plans under 4
44 CFR 350. FDM will provide the NRC with periodic status reports regarding the State and local governments' conpliance in carrying out their conmitments. Should the State and local goverrunents f ail to meet their ccrmitments according to the agreed time frames, FD%
will return the State's site-specific plans in accordance with hjency regulations and notify the NRC so that appropriate enforcement actions -
cculd be taken.
Prairie Island Nuclear Power Station, Prairie Island, Minnesota At this site there was a failure to meet the 15-minute time frame to alert and notify the public required for Goodhue County, Minnesota and Pierce County, Wisconsin. We counties were cited for a deficiency in the June 17, 1986, exercise. Wis issue is still cpen and FD% Region V is actively engaged in negotiating its resolution with the States of Minnesota and Wisconsin.
Trojan - Washinoton
' The serious outstanding deficiencies are: (1) In Cowlitz and Colu:nbia Counties emergency workers (EW) are not a$equately trained l in dose cammitznent and emergency worker kits were not distributed; (2) Washirrjton State and Cowlitz County (WA) hwe not agreed on the cpncept an) responsibility for the monitorinj of contaninated EW'st,(3L arrangements hwe not been made for a$ equate staf fing of evacuee qSsistance" centers; (4) decision making at the Washington State level was noCaiequate at the last Trojan or INP-2 exercises; (5) ingestion pathway decision makirg by the State of Oregon was inadequate; and (6) protective action implementation by tt)e State l of Oregon does not ajree with FD% criteria. thile sane of these
,' issues hwe been reportedly resolved by Oregon and Washington, none of these resolutions hwe been verified by FD% Region X.
However, Region' X is actively negotiating with the States to verify what issues hwe been resolved.
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I Alert and Notification Presently, there are 72 alert and notification systens nationwide l
- that Fe m anticipates will be reviewed. Dasigns for 69 of the 72 alert and notificatinn systen designs have alrea$y been forwarded to FDM for review. De preliminary ergineering review has been conpleted on 59 of the sites arri telephone surveys hwe been conducted at 56 sites. FD% has provided final findirns to NRC on 30 alert aM notification systens with the remainirn sites still in various stages of the review process in FDM. In scme cases the alert and notification systen is being redesigned or the procedures are beirg revised by the State and local goverrinents or licensee to meet FDM and NRC standards.
De following alert and notification systems have problems in one or more aspects of the FDM review process that FDM would consider a deficiency at this point time, thus, preventirn a finding of a3cquacy until corrected. In most instances where this is the case, however, the State and local goverrinents and/or licensee are attenpting to correct the problens identified by FD%.
- 1. Site: hNP-II - Richland, Washington: Washington Public Power Supply Systen Problems:
4 a) The alert and notification systen as presently designed does not provide an alert signal to individuals alorg the Columbia River within 0 to 5 miles of the nuclear power plant within 15 minutes as required by FD% and NRC.
i b) In an exercise conducted on Septenber 18, 1986, offsite l authorities f allei to denonstrate the c@ ability to conplete alertito along the Columbia River portion of the energency plannirn zone between 5 and 10 miles fran the l
site within the required 45 mirutest in addition they f ailed to demonstrate the capability to alert an off the real vehicle park alorg the Yakima River within 45 mirutes.
Resolutions:
l E) a The U4shirgton Public Power Supply Systen has cotinitted t'o insta1Eng 2 new sirens alorg the Colunbia River and to incorporate procedural charges in the plans. Wese corrective actions are scheduled for completion within the next three months and should correct this problet.
b) A renrxilal exercise will be required to dawnstrate correction of the deficiencies identified durirg the September exercise before the alert and notification system can be detennined to be ajequate. Accordiry to FDM guidance, this should tw accomplished within 120 days.
1 1
- 2. Site: Callaray - Rilton, Missouri: Union Electric Con;;any Problems
! bring the July 29-30, 1986 of fsite ra]iological energency
- preparedness exercise, the of fsite of ficials f ailed to complete alert and notification of boaters and transients along the Missouri River within the required 45 minutes. In addition, the ofIsite of ficials were unable to bromicast protective action reccnnendations via the Dnergency Broadcast System within 15 mirutes as required in the NRC regulations.
Resolution: A remedial exercise is scheduled for the end of Septenber during which the of fsite authorities will be required to demonstrate that these two deficiencies have been corrected.
Failure to denonstrate correction of the deficiencies cculd result in a negative finding to NRC.
- 3. Sites iblf Creek - Burlington, Kansas: Kansas Gas & Electric Problem ne alert and notification systen as originally desigwd did not provide sufficient alerting coverage in the John Redmond Reservoir area of the energency planning zone.
Resolution: Kansas Gas and Electric has agreed to install a new siren and upgrade two existing sirens and document this in a new design report to be submitted in October. It is anticipated that these systen enhancenents should correct the problen.
- 4. Site: Indian Point - Indian Point, New York: Consolidated D11 son Company Problems here are cutstanding plan ina$equacies in the Orange, Putnan, j
and tbstchester Counties' offsite radiological emergency preparedness plans that impact the alert and notification pysten and that nust be corrected before the system can be Appr**ped. t
+),
Pesolution l
The Coanties are currently incorporating the changes 'into
~
their plans and when the changes are received, reviewed, and determined to be a3 equate by FD4A, a finding on the systen can be made.
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aM Light Co.
Problem:
The of fsite auttorities f ailed to denonstrate the capability to conplete the alert and notification process within 15 minutes during the Jaruary 23, 1986 of fsite ra$iological energency preparedness exercise.
Ilesolution:
1 A renedial exercise is scheduled for Jaruary 1987 during which offsite aathorities will be required to demonstrate the c@ ability to complete the alert and notification process within the required 15 minutes. A successful demonstration of this capability should enable the systen to be approved.
- 6. Site: Cooper - Brownsville, Nebraska: Nebraska Public Power District Problem:
It has not been denonstrated that the alert and notification systen as presently designed provides Mequate system coverage for a state park, for a wildlife area, and for portions of the Missouri River within the 5 to 10 mile portion of the emergency planning zone.
DJring the Septenber 24-25, 1986 exercise, the demonstration of alert and notification systen procedures for these areas within the required 45 mirutes was not acconplished. In a$dition, Atchison County, Missouri officials failed to properly coordinate the activation of the alert and notification systen.
Resolution:
The mbraska Public Power District has submitted additional qata on alert and notification system procedures for the Misuri ,(iver and other areas. 'Ihe new data will be reviewed as soon as posdible.
- 7. Sites tbrth A$na - Mineral, Virginia: Virginia Power Conpany Problem .
The of fsite raliological energency preparedness plans hwe not been revised to incorporate revised alert and notification procedures sutxnitted in a technical aidendum to the original alert and notification system design report; in addition, route
alertinj pru.a 3s implenented durirn the last ralic icqie;al erurgency preparedness exercise did not coincide fully witn the reviseo Ort -v3 notification systen plans and procedures subnitted e r I w
. Resolution:
De Conmnwalth of VirtJinia has recently submitted technical data to FDtA in response to the above issue. % e data is currently under review by FDtA and if At is found to be aiequate it should rectify the problen.
- 8. site: Zion - Zion, Illinois: Commnwalth Edison Conpany Problem:
The teleptrano survey conducted on May 5,1986 as part of the alert and notification systen review may be invalidated due to the f allure of several of the sirens to activate durirg the survey.
Resolution:
Co,mnealth Edison investigated the cause of the siren f allures arri corrected the problem; however, the lorg term siren operability records will be closely reviewed by FDR to confinn that the required 90% operability standard is achieved before the systen is approved. A resurvey of the systen may be required.
- 9. Sites a) Peach Dotton - Peach Botton, Pennsylvania: Philadelphia Electric Co.
b) Duane Arnold - Palo, Iowa: Iowa Electric Light & Power Problen he licensees for both of these nuclear power plants he/e been
, 4cw in submittirn alert and notification systems to FDiA for revity evutt thyh both are operatirg nuclear powr plants.
Resolutionst a) The alert and notification systen for tuane Arnold is beirg redesigned by the utility and the new design is scheduled to be submitted in Spring 1987. Based on infonnation available to FD%, the revised system should be superior to the existing one.
,. \
l b) Latest indications to FD4A are that the Peach Botton alert aM notification system design will be subnitted to FDIA for review in mid-October. FEMA is adare that the Tvach Botton alert and notification systen has undergone same modifications which should improve the systen.
- 10. Site: Lacrosse - Genoa, Wisconsin: Dairyland Power Cooperation Problen:
Further documentation on alerting procedures for areas alorg the Mississippi River in Iowa must be provided before approval of the systen can be granted by FEMA.
Resolution:
We State of Iowa has been requested to provide the documente-tion requested.
Note: It is part of the normal review process for FEMA to identify problems anr3 data requirenents and correspond with the State and local goverrvnents and/or the licensees in an attenpt to resolve the problens or gain the additional clarifications needed. Wis of ten requires substantial processing and review time and cannot be construed as a deficiency in the system.
- 10) In its June 2,1986 Final Exercise Assessnent of the February 26, 1986, drill of the New Hanpshire emergency plans for Seabrook, FDM identified ,
112 deficiencies and areas requirity corrective actions.
a) Since the Final Exercise Assessnent, what actions have FD% and the State of New Hanpshire taken to correct the insiequacies of the New Hatpshire plan?
Since the issuance of the exercise evaluation resort of the February 26, 1986 exercise, the State of New Havpshire has developed a detained workplan for solving the deficiencies and areas requirirg corre4tiva N: tion ghserved during the exercise, as well as the plannirn TnaialuacQs identified in plan reviews by the Regional Assistance Cmunittee (RAC). We RAC conducted a detailed review of this workplan on June 23 and 24. Revisions to the New Hanpshire plans to protect the public in the event of an accident at; Seabrook were submitted to FD4A on Septenber 8,1986. ( A copy of these plans was provided to the subcatinittee on September 12.) FDM and the other msnburs of the RAC are nw reviewiry these plans. A ;
RAC meetirg to review anr1 discuss the plans is currently scheduled for October 8 and 9, 1986.
t
~ - - - _ -_ . - -- . .- . . - . - _ - . -
l i b) Has a remedial exercise been scheduled? If not, when does FDM expect to conduct one?
. Ma, as noted in the response to question 10a, New Hanpshire l sutnitted a emprehensive revision of the State's RERP to FDR
- Region I on Septenber 8,1986. De revised State RERP is expected '
! . to a1 dress the deficiencies ard areas requiring corrective action ;
identified in the exercise report. De revised plan has been
- distributed to the individual RAC menbers. A RAC meeting has ,
been scheduled for October 8 and 9,1986 to review and discuss i this plan. It is not, therefore, possible to make a decision at this time concernirg the adequacy of the State's plan.
1
! FD% does not believe a remedial exercise is warranted at this
. time for the followirg reasons: . (1) In order to conserve limited financial an1 staff resources, FDM helieves a remedial exercise i should be held in conjunction with an exercise of the Massachusetts I plan; (2) Planning within the plune EPZ is incmplete since Massa::husetts has not provided FDtA with a copy of the current !
l draf t plans. In addition, Governor Ibkakis announced on September 20, 1986 that he would not submit Massachusetts State or local plans; (3) Atmic Safety ard 1.icensing Board (ASIB) i hearirgs on the plans are in abeyance pending conpletion of the RAC review process for the recently sutnitted New Hagshire l Radiological Dnergency Response Plans (RERP): and, (4) Strictly
- speakin3, the time frane established by Gi EX-1 is designed to protect the public health and safety by providin,) for pragt correction of serious problems in the offsite preparedness around ,
operating nuclear power plants. In light of the other factors
- mentic + ' above and the f act that Seabrook is not yet operating, l we do a /iew as unreasonable the decision to delay the scheduling '
cf , renedial exercise for Seabrook. .
l i 11) We Ccrvmnwealth of Massachusetts did not participate in the Fe' < oary 26, 1986 drill. Please describe in detail the current st.a x of the Massachusetts emergency plans for Seabrook. '
l We Comonwealth of Massachusetts has not provided FD% with a copy of the arrent draf t plans. However, at the request of the Canmonwealth, FD% has provMed t%chrdpal assistance by informally reviewing draf t plans in the Of fice of t'w Secretary of Public Safety in February f 1986. FDM provided technical review connents on the draf t plans to l
the Massachusetts Civil Defense Agency (MCIM) and Of fice of energency !
l Preparedness (OCP) on March 28, 1986. Since the plans were not being l formally submitted to FDM for revies, the Commonwealth did not want l
the draf t plans removed fran the Office of the Secretary of Public i
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c) Please identify those cases and describe how they were resolved.
DIABLO CANYON / SAN OrOFRE
- $ At both sites, evacuation of beach population takes place at the ALERT level as a special precautionary measure. At Diablo Canyon, the beaches are within 2 miles of the plant. Alertirn is done at Diablo Canyon by a variety of methods, includirg alerting with ham-held m>japhones fron beach vehicles, and sirens. At San Onofre, sirens are the primary maans of alerting the beach population. *Ihe parks involved are controlled by either State or local goverrrnent agencies and at the ALERT level, the beaches can be closud to the public ark! the people there must leave.
FERMI II There were ASLR hearings held March 31- April 2,1982 on evaoJatiorv flooding issues related to Stony Point. Satisfactory resolution was reached by the Utility prwidirg for an enhancenent and improvement of the area rom $s, both to minimize the likely of flooding and to improve traffic flow.
TRO7AN/WP-2 The ability to alert the recreational areas alorg the Columbia River has been questioned, principally from the standpoint of alerting the river related transients. For more detailed infomation on WP-2 see answer to question 9c.
- 14) that guidance does FEMA provide to the States and local conmunities concerning the monitorirg of ra11ation exposure? Please provide a brief description.
GJidance is prwided by both FD4A and the NRC on the monitoring of 4 radiation exposure to State aM local goverrrnents in our joint docurnent, NUREG-06)4/ FEMA-REP-1. Specific guidance related to monitoring of ener-gency wocherg,is contained in plannirn standard K (Rs11ation Exposure
< 4 and 5.a.b. for State and local goverrments.
Control) in alenents Specific guidance 37'd to monitorirq of the general public is relat$
contained in I.7. and J.12. .
Instrumention guidance has been developed by the Dnergency Instrumentation Subconnittee of the Federal Radiological Preparedness Coordination Conmittee supported by FDM interajency agreenent with the Idaho National Ervjincerin] Laboratory, a tupartment of Energy 1aboratory.
1
o-Safety. Prior to this review, FDM provided the MCIR and OCP with a "FDR Technical Review of the Massachusetts State and Area I Plans for Seabrook" on August 16, 1985. Copies of the 1985 and 1986
' review were delivered to Ms. Linda Correia of your staff in September 12, 1986.
On Septenber 20, 1986, Covernor tukakis of Massachusetts anncunced at a press conference that he would not sutrnit state or local plans to protect the public in the event of an accident at Seabrook. FD%
has no infonnation on this matter beyond what has been reported in the media and that contained in the Governor's news release dated Septenber 20, 1986.
- 12) We six Massachusetts ccrnnunities within Seabrook's 10-mile emergency
- planning zone have resolved not to participate in the emergency i planning process. We Governor of Massachusetts has not yet submitted for FDR approval emergency plans for those ccrmunities. Please provide all internal nenoranda fran both the FC4A Region I office and the FD% Uashington Headquarters related to any contingency plans for i those connunities not participating and for the possibility that the Governor decides not to sutynit emergency plans.'
ue are unable to find any such memoranda in our files.
I
- 13) We Ccnmonwealth of Massachusetts has contended that the beach topulation cannot be a$equately protected in the event of an emergency at Seabrook, a) that, if any, proposals is FD% considering to ensure that the beach population is protected in the event of an emergency at Seabrook?
I ne Regional Assistance Ccznmittee is currently reviewing the State of New Hanpshire plans to protect the public in the event of an accident at Seabrook. Wese revised plans, submitted on Septenber 8,1986, j include special, consideration for the beach population.
- s.,
i ne FD% Region,, I qf,fice raised the issue of special planning for l the beach.popu1*atio,n, near Seabrook in the attached Decenber 31, 1985, menorandum to the Regional Assistance Committee members. Ris issue i
has not been resolved at the present time. .
b) Has the Agency encountered this issue in the past?
i Yes.
4
6
-2 5- ,
The followina .yluidance documents have been developed:
- 1. FtMA-RIP-2, Guidance on Of fsite Dncroency Raiiation M0Murenent Systems, Phase 1 - Airlorne Release, Septonber 1980
- 2. Supplenental Infonnation to FD'.A-RCP-2, Widance on Offsite E"crooney Radiation Measurement Systems, Phase 1 - Airborne Release, April 17, 1984.
- 3. Widance on Of fsite Dneraency Ra3iation Measurenent Systens, Phase 2 - The Milk Pathway, April 1984 (WIfCC)-1009)
- 4. Widance on Offsite Dnercency Radiation Measurenent Systens, Phase 3 - Liater and Non-Dairy Food Pathway, October 1984 (WIICO-1012)
- 5. Widance on Of fsite Dneroency Radiation Measurement Systems, Phase 1 - Airborne Release, FEfR-REP-2, Rev.1, Ikcember 1985 (LIIfCO-1029 )
- 6. Widance on Of fsite Dnergency Ra$iation Measurement Systens,
- The Milk Pathway, FE'n-REP-12, Septenber 1986
- 7. Widance on Offsite Dnergency Radiation Measurement Systems, (
- t!ater and Non-Dairy Food Pathway, FEMA-REP-13, Decenber 1986 Itens 1 through 4 were published and distributed to the FDiA Regions, and through the Regions, to the States for connents. Coments received were the primary basis for revised documents 5, 6 and 7.
Item 5 was distributed on April 7,1986, to the Regions for further distribJtion to the States. It replaces and updates itens # 1 and 2.
Item 6 is bein2 Published and will be distributed in the near future.
It replaces and updates iten # 3.
Iten 7 is projected for publication in Decenber 1986. It will replace
' and update i,te., 8: 4.
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-262 A brief description of the three REP publications follows:
FDM REP-2, Rev.1 (l2/85)
GUIo4xE ON OFFsIrF, DiFECTY RADIATION MEASURtMDir' SYSTEMS - AIRBORNE RELEASE We first of a series of guidance documents on offsite instrumentation prepared by the Federal Raiiological Preparedness Coordinatirn Ccmnittee, Subcon;nittee on Of fsite Dnergency Instrumentation. 2 1s report prcnides guidance on the selection and use of ra$iation instrumentation and methodologies that are currently aiailable to detect and measure radioactive ecmponents, with emphasis on the measurement and evaluation of the ra3ioiodines in airborne releases, in the event of a rwclear accident at a light water nuclear power plant. Many topics ancillary to the specific instrumentation requiratents are included to provide a basis for the specific reconnendations with respect to accident noti-fication, exposure rate verification, the definition of an emergency 7
worker, acceptable dosimetry systens, response teen manpower, etc.
FDR REP-12 (9/86)
GUIDATE ON OFFSITE DIEMETY RADIATION MEASURD4DTT SYSTEMS - THE MIIX PATHWAY he second of a series of guidance docuaents on offsite instrumentation prepared by the Federal Radiolcgical Preparedness Coordinating Ccmnittee, Subco:uaittee on Of fsite Dnergency Instrumentation. m is report provides guidance on the selection and use of radiation instrunentation and ruthodologies that are currently a/ailable to detect and measure radioactive contanination, in the event of a nuclear accident at a 2 light water ruclear power plant, with enphasis on the measurenent and evaluation of nuclides in the milk pathway to determine the dose covnitment to individuals. Protective action levels proposed by the Food and Drug Atninistration for milk are used as the basis for monitorirg
' requirenents. Ra3ioiodine plus cesium and strontien can contribute significantly to dose via the milk pathway. Were is no emergency field monitorirg instrumentation a/ailable for accurately measuring cesign and l
strontium, particularly in the presence of radiciodine. Rajioiodine can i
be a potential contanination problen in liquid milk, whereas rafiocesiun and radiostrontion can be a contanination problen in processed milk I products;; Manitority for the lorg half-life nuclides such as cesian d
i ani strontiu;f,requiressso which are only aiailab% in a phisticated laboratory. equipnent er chenistry proce ures i
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FDM REP-13 (12/86)
GUID4NCE ON OFFSITE DiENGDCY RADIATION MEASURDtENT SYSTD(S - WA*IER AND NON-D41RY FOOD PATWAY De third of a series of guidance documents on offsite instrumentation prepared by the Federal Ra iolcnical Preparedness Coordinating Connittee, Subconmittee on Of fsite Dncrgency Instrumentation. B is report provides guidance on the selection and use of ra$iation instrianentation and methodologies that are currently available to detect and measure radioactive contanination, in tha event of a nuclear accident at a light water ruclear power plant, with enphasis on the measurenent and evaluation of nuclides in potable water and non-dairy food to determine the dose ccm titment to irdividuals. De ra11onuclide concentrations warranting emergency actions for potable water and edible plants are derived fran the Food and Drug Administration protective action guides.
Protective actions and monitorirn requirements are discussed. Several alternatives for field monitority of foodstuffs and water are presented.
However, the reccmended procedure for monitoring foodstuffs is field sanpling in predetermined areas followed by laboratory analyses. De reccmended procedure for monitoring water is collection of sanples at water purification plants follcued by analyses performed by experienced l
technical personnel.
- 15) Please prcuide a summary of State policies regarding the use and distribution of potassiten iodide.
i State policies on the use and distribution of potassium iodide (KI) reflect the guidance contained in elenents J.10.e. and J.10.f. of NURED-0654/FD4A-REP-1. Under J.10.e., State and local goverrinents i are required to make provisions for the use of KI for emergency J
workers. Also, similar provisions should be made for institutionalized
- persons wherein ir
- inediate evacuation is not possible. Under J.10.f.,
State and local governments are given discretion in determining if provisions will be ma$e to provide KI to the general public. If they opt to prcnide KI to the public, then their energency plans should
' document the method by which decisions by the State Health Department for administering KI are to be made and the predetermined conditions under which KI may be used.
FDtA coordinated the development of a Federal policy statenent i
through# the Federp1 F.Miological Preparedness Coordination Counittee l
on the dist/ibution ofvKI arcund ruclear power plants. Wis policy was published in the Federal Register on July 25, 1985, and is attached.
i ne specific procedures for prcnidirg KI to energency workerd are set forth in all State and local goverrinent energency response plans.
l 4 only a few (5-7) States haic opted to make prcnisions for the use of j
KI for the general public.
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De New Harpshire and Massachusetts policies on the distribution of potassitr7 iodide are:
NEli RVtPsHIRE General Public--Potassitrn Iodide shall not be made a/ailable by the
' State to the general public. It is legally atallable to individuals
' who, based on their wn personal analysis, choose to he/e the drug innediately available.
D-ercency Workers--Potassium Iodide will td^madg a/ailable, in the event of a ra1iological emergency, to emergency workers. **7he Potassium Iodide shall be ingested by emergency workers only af ter instructions to do so fro 7 the New Harpshire Director of Public Health or designee.
Institutionalized Individuals--Potassium Iodide will be made a/ailable, in the event of a raliological energency, to institutionalized individuals. We Potassitra Iodide will be made e/ailable to be in]ested only af ter instruction to do so by the New Hapshire Director ,
of Public Health or designeo.
.vAssACHusETrs It is the decision of the Radiation ~ Control Progran of the Massachusetts Department of Public Health that Potassitrn Iodide (KI) not be stockpiled for distribution durirr; a ruclear power plant incident nor will aiministration of KI be recomended for the general population. At the discretion of the Conmissioner of Public Health, KI will be reccmended for use by emergency personnel only in extraordinary circumstances. In this case the utilities will provide the KI to be used by emergency workers.
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