ML20237G752
| ML20237G752 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/17/1987 |
| From: | Kowieski R Federal Emergency Management Agency |
| To: | Wilkerson R Federal Emergency Management Agency |
| References | |
| OL-5-I-FEMA-007, OL-5-I-FEMA-7, NUDOCS 8709020394 | |
| Download: ML20237G752 (8) | |
Text
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p.pqeimA-7 WH7 Federal Emergency Management Agency iW 8 Region II 26 Federal Plaza New York, New York 10378 M 25 ng:29 U
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', R,;f:t.C, MEMORANDUM FOR:
ROBERT S.
WILKERSON, CHIEF TECHNOLOGICAL HAZARDS DIVISION FROM:
ROGE B.
- KOWIESKI, P.E.
CHAIRMAN q
REGIONAL ASSISTANCE COMMITEE j
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SUBJECT:
GUIDANCE MEMORANDA GM-PR-1 AND GM-EV-2 l
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he State of New York has obtained copies of l
G M -P;< - 1 and GM-EV-2 through the utility and the National l
Emergency Management Association.
They have reviewed l
both documents and comments are attached.
Since GM-EV-2 could have a major impact on the Indian Point site, we suggest that you carefully analyze the comments received from the state and counties on this guidance document.
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STATE OF NEW YORK DEPARTMENT OF HEALTH CORNING TOWER e THE GOVERNOR N ELSON A. ROCKEFELLER EMPIRE ST ATE PLAZA e ALB ANY, N.Y.12237 O AVID AXELROD, M.D.
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January 17., 1986 i
l Mr. Roger B. Kowieski, P.E.
RAC Chairman Federal Emergency Management Agency 26 Federal Plaza New York, NY 10278
Dear Roger:
he have reviewed a copy of the FEMA draft Guidance Memorandum GM-PR-1 that was sent to Mr. DeVito, President, National Emergency Management Association.
For your information, the following comments were provided by REPG to Mr. DeVito and I am submitting the same to you for your information and any necessary action you deem appropriate.
1.
GM-PR-1 purportedly is being prepared to set forth policy and procedures for a set of periodic requirements that are part of NUREG-0654/ FEMA-REP 1 and 44CFR350.
I consider the procedures outlined in those documents to be sufficient and not in need of having more requirements placed upon states. To have states submit an " Annual Letter of Certification" places an additional burden for record j
l keeping and a requirement for a certificate seems to imply that FEMA is turning i
j over the monitoring of the program to the individual states. To expect states to l
l implement this program, if approved, by January 31, 1986 f( r calendar year 1985 is i
impractical.
i 2.
FEMA's Memorandum of Understanding with the Nuclear Regulatory Comission (NRC) which requires FEMA to furnish assessments, findings and determinations would have to depend upon the certificates submitted by the states.
I do not think that this was the intent of the NRC or the Executive Order that outlined the responsibilities of the NRC and FEMA.
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3.
In addition, I find that there are other areas of review that need further comment.
a.
Paragraphs 3, N.l.b Evaluation Criterion (page 2). states that it is a requirement for each state which has a nuclear power plant within its borders to fully exercise its plans and preparedness related to ingestion exposure pathway measures at least once every six years in conjunction with a plume exposure pathway exercised for sane site. This is all well and good if FEMA can provide guidance on the conduct of such exercises.
FEMA has not provided specific guidance on ingestion pathway criteria. The lack of this guidance pieces the states in the
" hold" position and will delay meeting the six year requirement.
FEMA must desig-nate the time of each exercise after guidance is published.
4.
.In addition, further request that GM-PR-1 not be published until all states have the opportunity to officially make comments on the provisions contained in the document.
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Mr. Roger B. Kowieski, P.E.
-2.
January 17, 1986 In further review of PR-1 additional comments on ingestion pathway exercise f
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criteria is warranted.
1.
The final NRC rulemaking on exercise frequency is explicit and clarifies vague language from the earlier draft published for public comment.
This rulemaking provides relief to the states.from overburdensome and too frequent drills and exercises. The NRC regulations require that the state exercise its ingestion pathway plans once during a cycle (5/6 years) at any of the sites for j
which it is located in the ingestion pathway EPZ.
PR-1, however, contradicts
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10 CFR Part 50 by requiring full or partial exercises for the state at each of the sites for which a state is within the ingestion pathway EPZ.
For New York State
- j PR-1 would require at least one full and nine partial ingestion pathway exercises during a six year exercise cycle.
2.
Any contaminating radiological event would involve Federal support. A
- -i prime example is Federal involvement at Three Mile Island. Any ingestion exercise 3
without Federal participation at least for assessment and decisionmaking is not
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worthwhile. It is doubtful that the Federal resources would allow for participation at each state within a six year period let alone the unreasonable frequency demands of PR-1.
3.
Ingestion is primarily a state function. PR-1 would require the same group of state people to exercise and re-exercise during the six year cycle.
Incidentally, these same state personnel are also involved in decision making, implementing protective actions, assessment, etc. during the plume exposure pathway exercises, d
I hope you will share our concerns with those drafting guidance memoranda.
PR-1, if impicmcnted, will put an undue burden on retources M d staff time and require substantial expenditure of funds.
Sincerely, i
Ja es D. Papile
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i Ac ing Director Rad ological Emergency i
t Pr paredness Group
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1 STATE OF NEW YORK DEPARTMENT OF HEALTH CORNING TOWER e THE GOVERNOR N ELSON A ROCKEFELLER EMPIRE STATE PLAZ A e ALB ANY, N.Y.12237 l
DAVIDAXELROD,M.D.
Commia a non er February 12, 1986 Mr. Roger B. Kowieski, P.E.
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RAC Chairman FEMA-Region II l
t Natural & Technological Hazards Division
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j 26 Federal Plaza New York, NY 10278 i
Dear Mr. Kowieski:
Since writing to you on January 28, 1986, reference Guidance Memoranda (GM), I received a copy of Draf t Guidance Memorandum EV-2,
" Evacuation and Early Dismissal Options for School Children." This is another case of the GM being sent to licensees by other agencies and we in the State and local governments not having prior knowledge of the document.
After receiving the Uraf t GM-EV-2, I sent a copy to each County invol.ed in cmargency planning fur nuclear power plants and regi ested their comment. Before summarizing their comments, I want to once again re-emphasize that we need your assistance to insure that the State and the counties be requested by FEMA Regional Offices to comment on any draft Guidance Memoranda before publication of the Memorandum.
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In reviewing the Guidance Memorandum EV-2, it is evident that the FEMA is not aware that school districts in New York are separate political entities and the planning for the school districts is not necessarily the responsibility of the local governments. Although the guidance addresres the local government responsibility for coordinating with school officialt,, there is no assurance that school officials will adopt recommended emergency procedures. The issuance of EV-2 guidance by FEMA indicates that the schools in New York, as part of the State School System, should be required by law to cooperate with local government officials.
In the past six years, local officials have worked closely with school officials and they have reached agreements on risk assessment.
The State of New York has no doubt that in the event of an energency, local and school officials will implement the protective action option most compatible with the protection of the school children and potential general population evacuation.
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Mr. Kowieski February 12, 1986 We have and will continue to include loc e school officials in
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our planning process but as previously stated there is no guarantee that the school officials have to abide by a FEMA Guidance Memorandum. The Departmsnt
- of Education at Federal and State levels have certain authorities. FEMA should explain what '.hese authorities are before putting out guidance. To attempt to mandate is not the solution. The hands of the Emergency Manager.at local and state levels are tied unless cooperation is guaranteed.
Attached are specific comments received from local governments.
Sincerely, NM, James'D. Pspile Directbr/
Radiological Emergency Preparedness Group JDP/sm Attachment cc: Mr. Brower Maj. Bates Mr. McGuire Mr. McBride l
REPG
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SPECIFIC COMMENTS RECEIVED FROM LOCAL GOVERNMENTS 1.
"The evacuation of school children under the continuous supervision of l
teachers and administrators from a school to a relocation center is a i
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valuable and reasonable approach when confronted with a radiological emergency."
The wording on this is weak and its meaning debatable.
It is imperative that the evacuated school children be under constant supervision and control. This applies for both the transportation phase and the reunification phase. The schools responsibility ends only when the school reception center has been closed and the children reunited with their parents, or transferred to a congregate care center.
2.
' School officials may select one of the three options for protecting their students including: e tc. "
While GM-EV-2 deals with evacuation and early dismissal options for school children, it is necesstry to maintain that school officials have four op,.i ons. The additional option in SHELTERING.
In order to maintain continuity when discussing the plan I strongly suggest that this paragraph be amended to include " sheltering".
3.
Early dismissal criteria should not be restrictive. Some Counties have agreements with school officials that all school options will be discussed at the alert stage,'early dismissal at this stage is a viable and
' r.cccssary al ternative. Other counties make provisions to release their children at early stages and send their students to other schools or I
sheltars outside the ten mile EPZ where they may be picked up by parents at a later time. The guidance must permit the local official in coordination with school officials and the State, if necessary, to determine the optimum choice for each individual case.
4.
" Evacuation Combined with Early Dismissal".
The combining of both options (Early Dismissal and Evacuation) can best be described as " Pandora's Box".
Besides adding responsibilities to school administrators the plan I
has pit falls. For example: A)
Improper communications with the schools and the E0C.
B) Children leaving school with friends and entering l
exposed areas.
This combined option should be stricken and the control and integrity of the entire school district maintained. The option of sheltering may be pre fe rred.
5.
It is not necessary for schools to be contacted by local government at l
specific times.
l County Executive should evaluate conditions within EPZ by receiving l
recommendations from the Emergency Operations staff and then conferring i
with the school superilitendent in regards to evacuation.
Evacuation could I
be earlier than Site Area Emergency depending on weather and road conditions, etc.
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'6.
The problem of evacuating all or part of the student population in the 10
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mile EPZ should be left to the local authorities. First, you have to remove the anxiety of the parents and school officials regarding the safety of the children with the proper education of parents (public) and school administrators.
EPZ residents would already know that their children would be loaded on to buses and taken to a predesignated school reception center outside the EPZ where they could be picked up and taken with them.
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