ML090860789
| ML090860789 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/16/2009 |
| From: | Burnside C US Dept of Homeland Security, Federal Emergency Management Agency |
| To: | Quinn V Office of Nuclear Security and Incident Response, US Dept of Homeland Security, Federal Emergency Management Agency |
| References | |
| Download: ML090860789 (5) | |
Text
MCM917 M1Y Department of ilomelanid Secui Region IV FEB 0 6 2009 3003 Chamblee-Tucker R*oad Atlanta, Georgia 30341 January 16, 2009 Memorandum For: Vanessa E. Quinn, Chief Radiological Emergene yreparedness From:
Technol gical Hazards Branch
Subject:
Request For Assistance For Design Interpretation Of Alert And Notification System At Joseph M. Farley Nuclear Power Plant With Regard To The Tone Alert Radio Program The Nuclear Regulatory Commission requested FEMA's assistance in reviewing material related to their investigation of the Farley Tone Alert Radio Program, which is the primary means to alert the population within the State of Georgia of an event at the Farley Nuclear Power Plant. The Design requirements for the Farley Nuclear Plant were established in March, 1989.
The results and interpretation of this inquiry are based upon the final FEMA approved Design Report (DR), dated March, 1989.
NRC posed 7 questions to FEMA we will restate the questions and provide our answers below.
- 1. Was Farley requiredto notify the State of Georgiato institute compensatory alerting methodologies upon discovery that households requiringTARs had not received them?
Yes. FEMA REP 10, November, 1985, Section E.6.1 (Areas of Review), paragraph 3 states:
'Accordingly, a coordinatedprogramof alert and notificationsystem development, implementation and routine testing is encouraged.' The Farley Site-Specific Emergency Preparedness Alert and Notification System Quality Assurance Verification (QAV) report, dated June, 1991 confirmed that the Farley ANS program met the provisions of FEMA43, based on the plan presented as part of the Prompt Notification System (PNS) Design Report dated March, 1989.
The March, 1989 Farley (PNS) Design Report, Section 2.2.1.2 states: 'In the event of an emergency at Farley NuclearPlant,the Alabama Power Company Directorwill notify the State of Georgia andState of Alabama Authorities in accordance with PlantEmergency Implementation Procedures.
Sufficient Information is provided to Statepersonnel so that the Alabama Department ofPublic Health and the GeorgiaDepartmentof NaturalResources can evaluate the radiologicalhazard associatedwith an emergency and decide on the need to initiateprotective action measures, including but not limited to, activation of the NotificationSystem.' 6 (Early County, GA Notification and Warning REP Excerpt), Section A (Prompt Notification System) details the installation of a notification system throughout the 10m EPZ, its' compliance with regulatory specifications and that it will be used to advise the EPZ populace of problems that exist at the plant. Section B, (Supplementary Notification System), states 'As a back-up system, the population of the ten mile EPZ will be notified of an emergency situation by means of thefollowing local resources:' It further lists and describes the resources.
Compensatory alerting is the responsibility and authority of the states to implement and requires notification of the states by the utility if a condition existed that would warrant its' employment. The system operates on an interdepency of the utility, the states of Georgia and Alabama and affected counties to receive and disseminate timely, accurate information to adequately notify residents within the EPZ. So, upon discovery by the utility that households in Georgia requiring TARs had not received them, the utility should have notified the State of Georgia.
- 2. Is Farley requiredto maintain an accuratelisting of addresses where TARs were needed?
Yes. FEMA REP-10, E.6.2.3 (Tone Alert Radios), states: 1) 'If Tone Alert Radios areproposedas part or all of a nuclearpowerplant's alertand notification system, the rationalefor their use should be included in the Design Report.
The Farley Site-Specific Emergency Preparedness Alert and Notification System (QAV) report, dated June, 1991, conveyed in it's analysis that specific FEMA-43 Guidelines should be followed to maintain an effective and continual alert and notification program utilizing Tone Alert Radio receivers. The adequacy of the program included the plans and procedures for distribution, maintenance and record keeping that would identify residents needing TARs and the process for ensuring they were received.
- 2) 'A recordsystem (register)containingan accuratelist of addresses (names are optional) must be maintainedfor those geographicalareas using the tone alertradios.'
The Farley Design Report, Section 2.2.2.2 (NOAA Tone Alert Radios) adopted these criteria.
Section B (Distribution and Maintenance), paragraph 2, item 1 specifies 'thatrecords are maintainedof all residencesand businesses in which TARs are needed.' Attachment 7 (Management Procedure No. 401-003),Section II.C.4, states 'The CorporateCommunications Departmentwill establish a program to distributeradiosto eligible residents, obtain radiosfrom residents moving out of the lOim EPZ and exchange malfunctioningunits.' Section D provides for a program for timely identification of new residents in the 1Oin EPZ. Section F (PNS Records),
provides for preparation of issued and exchanged radios to residents, and for those records to be computerized. The process is further defined in Attachment 13, Section 4.7.
- 3. Is FarleyResponsiblefor ensuringthe accuracyand the maintenanceof the local utilities records, such that households requiringTARs areproperly identified?
Yes. NUREG 0654 and FEMA-REP- 10 Evaluation Criterion. E.6 provide that 'Each organization shallestablish administrativeandphysicalmeans, and the time requiredfornotifying and providingprompt instructionsto the public within the plume EPZ. It shall be the licensee's responsibilityto demonstrate that such means exist, regardlessof who implements this requirement' The Farley Design Report establishes the responsibility to be that of the Licensee. Attachment 13 (GO-EIP-136, NOAA Weather Alert Radio Distribution and Maintenance), Section 4.0, (Procedure),
lays out the means by which the electric cooperatives, Georgia Power and Alabama Power Co. will provide the Farley Visitors Center (FVC) with monthly reports of resident and business connects and disconnects, by which they will use to identify those needing TARs. Section 4.0 also addresses distribution, malfunction, repair and recording information regarding TARs. Section 4.7 (Records Management) further specifies 'The FVC staff is responsiblefor keeping a thorough, timely, records managementprogramfor weather alert radio distributionand repair.' It also specifies forms to be prepared, information to be gathered, input procedures and maintenance media, such as computers that the FVC is responsible for managing.
- 4. Is Farleyrequiredto annually re-contactand re-offer TARS to those households who initially refused them? Also, is Farley requiredto maintain documentation of offers providedto individuals who initially refused TARs?
Yes. FEMA REP-10 E.6.2.3, paragraph 2, subparagraph 1, states 'Tone alert radiosshould be offered to the public in geographicalareas (where needed) and a "best effort" attempt must be made to place the radios.' 'The addresses of residents refusing tone alert radiosshould also be noted.' The (QAV) report Section 2, paragraph 1, subparagraph 1 offers an identical statement. The March 1989 Farley Design report, Section 2.2.2.2.B (Distribution and Maintenance), Section B, paragraph 2, item 2 states 'when new residentsare identified,they are offered a radio.' Item 3 follows with, 'Any residents who have declineda radio are re-contactedannuallyand again offered a radio.'
- 5. Are churches requiredto be included in the TAR distributionprogram?
No. NUREG-0654/FEMA-REP-10, Appendix 3 states, 'the minimum acceptabledesign objectives for coverage by the system are: a) Capabilityfor providing both an alertsignal andan informationalor instructionalmessage to the population on an area wide basis throughoutthe 10 mile EPZ, within 15 minutes; b) The initialnotification system will assure directcoverage of essentially 100% of the population within 5 miles of the site; and c) Special arrangementswill be made to assure 100% coverage within 45 minutes of the population who may not have receivedthe initialnotification within the entireplume exposure EPZ.'
No such distribution plan was established that included issue of TARs to Churches in the EPZ in the FEMA approved Design Report of 1989. Section 2.2.2.2.B of the Design Report states; 'The initial distributionof TARs was to residences and businesses.'
The Farley public alert and notification system (PNS) consists of 3 sirens and TARs. However, since the time of the approval of the DR in 1991, the interpretation of NUREG 0654 and FEMA REP- 10 has come to include the expectation that places of worship, not within range of the sirens, like other businesses, facilities and unique institutions within the EPZ would be issued TARs.
- 6. Was Farley requiredto submit any or all of the threesignificantchanges to the Alert Radio Distributionand Maintenanceprocedure included in the FarleyNuclear PlantAlert and Notification System Design Report, March 1989 to FEMA for review and approvalpriorto implementation asper 44 CFR 350.14?
Yes, all changes shouldhave been submittedfor review andapproval 44 CFR 350.14 (Amendments to State Plans), allows and requires that '(a)'- '...a state must amend its plan in orderto extend the coverage of the plan to any new nuclearpowerfacility which becomes operationalafter a FEMA approvalor in case of any other significantchange.'
(b) 'A significantchange is defined as one which involves the evaluation and assessment of a planningstandardor which involves a matter which if presentedwith the plan, would need to have been consideredby the Associate Directorin making a decision that State or localplans and preparednessare; 1) adequate to protect the health andsafety of thepublic living in the vicinity of the nuclearpowerfacility by providingreasonableassurancethat appropriateprotective measures can be taken offsite in the event of a radiologicalemergency; and 2) are capable of being implemented.'
(c) '...The existing FEMA approvalshall remain in effect while any significantchanges are under review.'
(d) 'Changes,such as a change in a telephone number, that are not significantas defined in paragraph(b) and (c) of this section (350.14), but are necessary to maintain currency of the plan, should beforwarded to the Regional Director.'
Each of the revisions made by the utility to the Alert Radio Distribution and Maintenance Program are material changes. Each affects the ability to provide the most accurate and timely information that ensures timely notification and protection of the public. The changes are provisions under which the Design report was based and approved and any change to them would warrant reconsideration of those changes to adequately meet the conditions of NUREG 0654, FEMA-REP 10 and FEMA-43, They clearly meet the definition of 'Significant Changes' and should have been forwarded to FEMA for approval.
- 7. Were the actions taken by Farley to implement their TAR program acceptable in meeting the FEMA approvedANS design reportand supportingFEMA approvalletter.
No. As evidenced in the NRC letter and in the statements above, Farley took actions over time that diminished the effectiveness of the prompt alert and notification system and brought the system out of compliance with the submitted and approved alert and notification system design report.
Revisions to the procedures provided in the original design report were made without providing them for review and proper checks were not in place to assure proper maintenance and record keeping for the Tone Alert Radios. When Farley was initially notified of the potential problems with the Tone Alert Radio system, response was delayed and official notification to State governments was not made.
Should you have questions, please contact Lawrence Robertson at 770/220-5466.
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