View source for CLI-85-08, Forwards FEMA Status Rept on Special Proceeding Decision CLI-85-08,containing Schedule of Unresolved Emergency Preparedness Deficiencies.Resolution of Issues in Cooperation W/State & Local Govts Requested

{{Adams
| number = ML20137Z907
| issue date = 03/07/1986
| title = Forwards FEMA Status Rept on Special Proceeding Decision CLI-85-08,containing Schedule of Unresolved Emergency Preparedness Deficiencies.Resolution of Issues in Cooperation W/State & Local Govts Requested
| author name = Harpster T
| author affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| addressee name = Selman M
| addressee affiliation = CONSOLIDATED EDISON CO. OF NEW YORK, INC.
| docket = 05000247
| license number = 
| contact person = 
| document report number = CLI-85-08, CLI-85-8, NUDOCS 8603130234
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 2
}}

=Text=
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* MAR 0 71986 Docket No. 50-247
    ' Consolidated Edison Company of New York, Inc.
ATTN: Mr. Murray Selman Vice President Indian Point Station                                                                l Broadway and Bleakley Avenue Buchanan, New York 10511 Gentlemen:
The enclosed FEMA Region II status report on the Indian Point Special Proceeding Decision (CLI-85-08) contains a schedule of offsite emergency preparedness deficiencies which remain unresolved.       We ask that you continue to work with the State and local governments in the resolution of these unresolved items.
If you have questions concerning this matter, please contact Mr. David Vito.
(215) 337-5142, of my staff.
Sincerely, cri r --1 C '"" ' "'
Terry L. Harpster. Chief Emergency Preparedness Section Division of Radiation Safety and Safeguards

==Enclosure:==
As stated cc w/ encl:
J. D. O'Toole, Vice President, Nuclear Engineering, Quality Assurance and Reliability M. Blatt, Director, Regulatory Affairs F. Matra, Resident Construction Manager R. L. Spring, Nuclear Licensing Engineer Brent L. Brandenburg, Assistant General Counsel P. Kokolakis, Director, Nuclear Licensing FEMA Region II Public Document Roon (PDR)
Local Public Docunent Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York 0603130         $    p             0FFICIAL RECORD COPY                             r
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Consolidated Edison Company of            2 New York, Inc.
bec w/ encl:
Region I Docket Room (with concurrences)
DRP Section Chief I:  SS V                   Harpster 3/ /86              3/]/86 0FFICIAL RECORD COPY

Federal Emergency Management Agency Washington, D.C. 20472 FEB    5 586 MEMORANDEM EUR: Edward L. Jordan Director, Division of Ehergency Preparedness and Engineering Besponse Office of Inspection and Enforconent Nuc ear       la ty Ccmnission
                                                      ^
Flot:                    a   W. Kr Assistant Asmciate Director Of fice of Natural and Technological Hazards Pro] rams SUEUECT:            Indian Ibint Special Proceeding Decision (CLI-85-06)
         'Ihis is in response to your memorandun of Deconber 6,1985, requestirr; a status report on certain itens mentioned in the Ccmnission decision on the special proceediry on the Indian Ibint Nuclear Dower Plant (CLI-85-06). 'Ihe following items remined unresolved at the time of our August 30, 1985 memorandtrn:
: 1) letters of agreenent for reception centers and congregate care centers in all four counties in the Indian Ibint 10-mile Dnergency Planning Zone (EPZ),
: 2) letters of agreement with bus conpanies in W3stchester County,
: 3) Procedures for route alerting in all four counties, arx!
: 4) Procedures for disgosal of contaminated waste water when the county (rather than the State) is in connand and control.
Attached is a status report prepared by Region II of the Federal Ehergency Management Agency (FEMA). Since August 1985, annual plan revisions have been received by Region II for three of the four counties involvoi in the Indian Ibint 10-tnile EP2, i.e., Wastchester, Ibcklarx1 arx1 Putnan Counties. No revisions have been received for the Orange County plan.
: 1) FEMA has received some letters of aqreonent and found t1x5n to be acceptable. However, plan revisions sutznitted since Aurpast 1985 for Wastchester, Ibckland and Putnan Counties contain no tvu letters of agreement regarding reception centers. No 1985 plan revisic; was sutxnitted for Orarvje County. To date, FENA has not received all of the necessary letters of agreement with respect to the availability of facilities for use as congregate care centers. As a result, FENA's position on this itan, as stated in our August 30, 1985, nvinorandtsn, ranains unchanged.
FEMA concludes that letters of agressnent are still required with schools and other facilities designated as reception arvi conqrerlate care centers in each of the four counties. Until letters of agree-ment are submitted to FEMA ary! fourvj acceptable, this issue runains unrenolved.
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!                                                 2) FEMA has received no additional material since the August 30, 1985 report with regard to letters of agreement with bus coreanies in Westchester County. As we said then, the issue of letters of agreement with these comanies remains unresolved until all necessary docurnentation establishing the existence of these contracts with bus cormanies is provided by the State.
: 3) A sanple of route alertirv) was evaluated in all four counties
!           in the Novent>er 28, 1985 Indian Point exercise. In addition, the plan revisions in the Wstchester, Rockland and Putnan County
;          plans are adequate and close the issue of route alerting for these l           three counties. Wen the route alertinr; nessage is formally inserted in the Orange County plan, this issue will be closed.
l          Until the Orarge County plan has been revised, this issue will l
remin unresolved tor Orarne County.
i l       4) FEMA's position remains unchanged on procedures for the disposal of contaminated waste water when the county is in connand and j          control. The New York State procedure is acceptable for l
situations when the Governor declarus a state of emergency.
However, further clarification is needed for situations when the county is in convend and control (i.e., no State declaration).
FEMA's Region II is continuing to work with the State of New York on i   these outstandirry items. Ilowever, due to the fact that the State rmst
!   work with the Counties to obtain the remaining mterial repired to l   close out the open issues, it is not possible to mke a firm estimte of the time required for conpletiry; the necessary corrective actions.
At the present time, New York is actively noving towards a resolution of all open issues mentioned above. W hope this information is useful to you. If you have any more questions, please feel free to call rm at i   646-2871 or Ibbert S. Wilkerson at 646-2861.
Attachment As Stated

.           Federal Emergency Management Agency Region II   26 Federal Plaza      New York, New York 10278 Febnnry 3,1986 Memorandum Fort   Richard W. Krimm Assistant Associate Director Of            Natural &      hnological Hazards r
From:             Phi      M. cI t r     C ie Natural & Technological llazards Division

==Subject:==
Status Report on Indian Point Special Proceeding Decision (CLI-86-06)
Enclosed please find the status report on the of fsite preparedness for the Indian Point site. Although New York State has made progress since our August 20, 1985 status report, additional work needs to be done before all outstanding issues can be closed. Due to the fact that the state must work through the counties to obtain the remaining material required to close out the opened issues, a firm estimate of the time required for completing these remaining corrective actions cannot be made. At the present time, New York State is actively moving towards a resolution of all open issues.
If you have any questions, please call me at (212) 264-8385.
Encl.

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1 Status Report l
Indian Point Special Progeoding Decision (CLI-85-06) l I
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l FEMA Region 11 New York, New York January 31, 1986 l
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. 1. EMERGENCY RESPONSE SUPPORT ANO RESOURCES - NUREG-06E4 - PLANNING STANDARD C 10 C.F.R. 50.47 (b)(3)
ASLB's FIN 0!NGS:
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 {{letter dated|date=December 27, 1985|text=December 27, 1985 letter}}:
Rockland County - the County Emergency Manage-ment Director contends that existing conunit-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 desigriaces 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 {{letter dated|date=December 27, 1985|text=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 addition, 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 i
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 come.it the use of any school resources.
Putnam County                                                           ,
The 9/85 revision of the Putnam County Plan designates the following three 1
(3) facilities as reception centers:
1 i                    Dutchess Mall Van W'ck Junior High School R. C. Ketcham High School I
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    . The following is the position of New York State as expressed in the {{letter dated|date=December 27, 1985|text=December 27, 1985 letter}}:
Putnam County - In FEMA's response to Cosmis-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 {{letter dated|date=December 27, 1985|text=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 Olstrict 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 rr.ceived, for review, all of the necessary letters of agree-ment with re'.pect to the availability of facilities for use as Congregate Care Center 4. 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 {{letter dated|date=January 29, 1986|text=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 other 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 METH00$ AND PROCEDURES - NUREG-0654 - PLANNING STANDARD E 10 C.F.R. 50.47(b)(5)
ASL8's Findinos:
No significant deficiencies, but record inconclusive with respect to the existence of or need for routine-alerting or otner procedures for the event the siren system fails.
Comunission's Comments:
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:
                                                                      "If requested, route alerting for siren 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 stren failure.
No 1985 revisions have been received fo- 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 stren 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)
ASL8's Findines:
No letters of agreement from Westchester County bus drivers.
Commission's Comunents:                                                                  -
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 estabitshing 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)                           i 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 M 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 Consnission Decision remains unchanged. Since there has been            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 Filp050RE CONTROL - NUREG-0654 - PLANNING SCHEDULE K       ,
10 C.F.R. 50.47(b)(11)
ASLB's Findinas:                                                   r No significant deficiencies, but record inconclusive as to the    '
adequacy of provisions for disposal of contaminated waste water.
Commission's Comments:
                                                                                                                                         ?
No connents were made regarding this Planning Standard. However, the Commission directed the NRC staff to confer with FEMA and provide them with recommendations.
fem Aunust 1985 position:
FEMA has evaluated the State's response and found it acceptable for those situations in which the Governor declares a state disaster        f emergency. However, further classification is needed for those situations in which the county is in command and control (no state declaration),        l progress Since August 1985 Uodate:
A December 27, 1985 New York State letter to FEMA stated the following:
The procedures for disposal of contaminated waste water when the county is in connand and                ,
control remains an open issue until USEPA                   l provides New York State a letter to confirm                 ;
that the proposed method of disposal of                     '
contaminated waste water does not pose a                    i 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  L allows the Governor to temporarily suspend specific provisions of the New   }
York State Environmental Conservation Law. The issue is not the USEPA       j position on waste water disposal. The issue is "How does the New York       p 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-              l tions in which the Governor declares a                i state disastgr emergency. However.                    :
further c1 6 1fication is needed for those situations in which the county is               ,
in command and control (no state declara-             !
tion).                                                ;
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       !m        \                            UMTE3 STATES
     !                            NUCLEAR REGULATORY COMMISSION f                                     WASHiteG700s, O. C, 20004 February 25, 1986 k*....
I MEMORANDUM FOR: Thomas T. Martin, Ofrector Division of Radiation Safety and Safejuards
;                           Region !
FROM:              David 8. Matthews, Chief l
Emergency Preparedness Branch Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement                                             !
i i

==SUBJECT:==
FEMA STATUS REPORT ON INDIAN POINT SPECIAL PROCLEDINGDECISION(CLI-85-08) ITEMS 1
The subject report is enclosed.           You are requested to forward the report to the two Itcensees and encourage them to continue to work with state and                          j local governments in the resolution of the remaining unresolved items.
cNP                  /                  rb David 8. Matthews. Ch!ef Emergency Preparedness Branch Division of Emergency Preparedness                I and Engineering Response                       j Office of Inspection and Enforcement              :
i

==Enclosure:==
                                                   , e .. , ,
FEMA Report dtd. 2/5/86 RE: CLI-85-06 Status
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