ML20054E748
| ML20054E748 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/07/1982 |
| From: | Brons J, Lomonaco L, Quinn D POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | |
| Shared Package | |
| ML20054E727 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8206140134 | |
| Download: ML20054E748 (41) | |
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.tELtTED COh.mWRZC2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1 ATOMIC SAFETY AND LICENSING BOARD Before A6.ninistrative Judges:-
Louis J. Carter, Chairman Frederick J. Shon Dr. Oscar H. Paris -
x In the Matter of ) -Docket Nos.
CONSOLIDATED EDISON COMPANY OF NEW YORK, ) 50-247 SP INC. (Indian Point, Unit No. 2) 50-286 SP
)
POWER AUTHORITY OF THE STATE OF NEW YORK June 7, 1982 (Indian Point, Unit No. 3) )
x POWER AUTHORITY'S TESTIMONY OF JOHN C. BRONS, LINDA LOMONhCO AND DENNIS OUINN ATTORNEY FILING THIS DOCUMENT:
Charles Morgan, Jr.
MORGAN ASSOCIATES, CHARTERED 1899 L Street, N.W.
Washington, D.C. 20036 (202) 466-7000
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8206140134 820607 PDR ADOCK 05000247 ~
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I TABLE OF CONTENTS
. Page I. INTRODUCTION ................................. 1 II. MISCONCEPTIONS ABOUT THE INDIAN POINT EMERGENCY PLAN ............................. 7
. III. THE SITE PLAN'S EFFECTIVENESS ................ 11 1
- IV. CAPABILITIES OF PERSONNEL, FACILITIES, l AND EQUIPMENT TO RESPOND TO AN j EMERGENCY .................................. 16 i V. PLAN MAINTENANCE MEETS ALL APPLICABLE l REGULATIONS AND PROVIDES ADEQUATE PROTECTION FOR THE PLANT AND PUBLIC ........ 32 ;
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SUMMARY
...................................... 34 VII. CONCLUSION ................................... 35 il i li u
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. TESTIMONY d
WITNESSES: John C. Brons Linda Lomonaco
- ll Dennis Quinn I. INTRODUCTION Purpose of Testimony This panel consists of individuals employed at the Indian Point 3 Nuclear Power Plant owned and operated by licensee
' Power Authority of the State of New York (the " Power Authority").
The purpose of the panel's testimony is to:
(A) address certain popular misconceptions about the Indian Point emergency plan and about radiological emergency planning in general; l
(B) explain and demonstrate the effectiveness of the on-site emergency response plan for Indian Point 3; (C) describe generally the capabilities of personnel, facilities, and equipment for responding to an emergency; and (D) demonstrate that plan maintenance meets all applicable regulations and provides adequate I
protection for the plant and public.
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I Personal Qualifications John C. Brons:
'2 I have been, since January, 1981, the Resident Manager at Indian Point 3. As such, I am under normal condi-tions and most accident scenarios the Authority's chief operating officer at the plant site. Pursuant to the Indian Point 3 emer-gency plan, I would become the Emergency Director for the plant during a Site Area Emergency or a General Emergency.
I received my B.b. in Engineering from the U.S.
Naval Academy in 1959 and an M.S. in Management from Rensselaer Polytechnic Institute in 1971. I also received specialized training in nuclear power in 1962 when I originally qualified I served in the Navy's as a watch officer on a nuclear submarine.
nuclear propulsion program for 18 years, rising to the rank of Commander. During my naval service I served as: .
o Chief Engineer of a nuclear submarine. I was responsible for the assembly, testing and operation of the nuclear power plant during the ship's construction and first year at sea.
o Executive Officer of the Navy Nuclear Power where I was responsible for Training Unit at West Milton, N.Y.,
the initial practical nuclear training of Navy plant operators and watch officers.
l o Commanding Officer of a nuclear submarine during construction, testing and its initial two years of operation.
,. 2 o Deputy Commander of a submarine squadron where I was responsible for the training and readiness of 12 operating and new construction ships. In addition, I acted as the on scene commander for submarine reactor plant emergency preparedness in the Norfolk, Virginia area.
o Senior member of the Nuclear Propulsion Examining Board where I was responsible for the conduct of Operational Reac-tor Safeguards Examinations on all types of navy nuclear ships and nuclear maintenance facilities. In addition, I served as senior I
member on the evaluation of emergency preparedness exercises in l New London, Connecticut and Charleston, South Carolina.
Upon my retirement from the Navy in 1980, I accepted l
my current position as Resident Manager at Indian Point 3. Dur-
!ing my tenure at Indian Point, I have supervised all facets of plant operations including training, maintenance, reactor opera-tion, emergency planning, finance and personnel.
As Resident Manager at Indian Point 3, I have placed particular emphasis on emergency preparedness and internal and l- external communications. I received much of my training in the Navy nuclear submarine program. I know the meaning and importance J u
of emergency preparedness. I commanded a nuclear submarine, which must be prepared for all kinds of contingencies, including the threSt of submerged operations, the possibility of attack and the potential of a problem developing with the nuclear plant while milca from home. I apply the same scrutiny I did in the Navy to supervision of plant operations and emergency preparedness at Indian Point 3.
Linda Lomonaco:
I am currently the Assistant to the Radiological and Environmental Services Superintendent at Indian Point 3.
I received my B.S. in Meteorology from the State University of New York, College at Oswego in 1975. Prior to accepting a position with the Power Authority I worked as an
! Assessment Meteorologist for the Lawrence Livermore Laboratory (1977-79) working with the Atmospheric Release Advisory Capability
(" ARAC") project. The ARAC program is established as an emergency planning program to respond to emergency conditions on the dose assessment level. As the Assessment Meteorologist, I responded with other dose assessment team members to a variety of hazardous atmospheric releases both nuclear and chemical.
My previous experience was with the University of Wyoming as a Cloud Physics Research Assistant (1976-1977).
t As the assistant to the Radiological and Environ-mental Services Superintendent, I am the Indian Point 3 site Emergency Planning Coordinator. Almost all of my time is occu-As such, pied by my duties as the Emergency Planning Coordinator.
my responsibilities include maintaining the site emergency plan; amending the plan in accordance with revised regulations or ope-rating experience; ensuring and providing training to all site personnel in accordance with the plan; supervising inspection and maintenance of emergency preparedness equipment required by the site plan; and assisting in coordinating on-site and off-site responses. I authored the bulk of the Indian Point 3 site plan, and therefore am personally familiar with the details.
Dennis Quinn:
I am a radiological engineer employed in the Radiological and Environmental Services Department at Indian Point 3.
I received my B.S. degree in Marine Engineering 1
I in 1972 from the United States Merchant Marine Academy, and my M.S. in environmental engineering / radiological health in j
1974 from Rensselaer Polytechnic Institute. My credentials in-clude American Board of Health Physics Comprehensive Certifica-l tion in Health Physics in 1978 and American Board of Health l I
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. . n Physics Certification in Power Reactor Health Physics in 1980.
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- Upon completion of courses at Rensselaer, I com-menced employment with the Electric Boat Division of General Dynamics (" Electric Boat") in Groton, Connecticut as a radiolog-ical engineer. I was principally engaged in environmental moni-toring and maintaining a radiologically safe work environment in the shipyard and aboard nuclear submarines ui.iergoing construc-tion, repair, and refueling at Electric Boat. I also provided technical assistance to the development and implementation of the shipyard's radiological emergency plan. I received extensive additional training and experience while employed at Electric Boat. Specific training included a one-week course at the Harvard School of Public Health on " Environmental Surveillance for Nuclear Power" and a two-week course at Rockwell International ,
I on " Health Physics."
In 1977, after four years at Electric Boat, I -
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! accepted employment at Indian Point 3. Since that time, I have l l
been a radiological engineer with the following principal res-ponsibilities: ,
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. (a) supervision of a program to reduce radiation
- exposures to plant workers; l
) (b) supervision of the programs for radiation i safety training and respiratory protection;
- (c) review of the off-site environmental monitor-j ing program;
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e (d) provision of technical expertise in the areas of radioactive waste disposal, personnel radiation dosimetry, instrument calibration,
' and emergency planning.
, II. " MISCONCEPTIONS ABOUT THE INDIAN POINT EMERGENCY PLAN At the outset, we will address certain popular
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misconceptions about the Indian Point emergency plan and about radiological emergency planning in general.
Misconception Number One Many people believe that radiological emergency planning is a new concept. This is a significant misconcep-tion. The Indian Point plants have always had an emergency plan in effect, since the day Indian Point 1 opened in 1962.
New York State was one of only twelve states which had a Nuclear Regulatory Commission concurred-in off-site emergency plan in effect prior to the Three Mile Island accident in 1979. We have always had regular emergency drills at the plant. The Power l
Authority has consistently notified the appropriate off-site authorities whenever unusual events have taken place at the l
plant. Indian Point 3 has never experienced an action level more serious than a " notification of unusual event."
l Misconception Number Two This may be called the " final plan misconception."
Some people mistakenly believe that the " plan" is a final l
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document which either will work or won't work, and cannot be adjusted or corrected. Actually, however, emergency planning is a -dyhamic process. Innovations are constantly being made, new technology becomes available, new individuals become participants with fresh ideas, and lessons are learned through drills and exercises. Experience shows that this process of planning, pre-paration, revision and adaptation is essential to all aspects of human endeavor. We regularly update portions of the site emer-gency plan, and, of course, educate the appropriate people about the changes. We performed our own critique of the March 3, 1982 full-scale exercise, and are actively considering adjustments to the site plan in accordance with our critique, as well as the cri-tique we have received from the Commission.
The Commission critique of the exercise found that "the team leader concluded that within the scope and limitations of the scenario, licensee's actions were found to be adequate to pro-tect the health and safety of the public. Such actions were con-sistent with their emergency plans and emergency implementing procedures."
As far as the Power Authority is concerned, there will never be a " final" emergency plan, because our constant scrutiny results in continuous changes and adjustments, t
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Misconception Number Three l
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Some' people suffer from the misconception that l
the emergency " plan" is a single document; some think this t
supposed " document" was prepared by Con Edison or by the Power
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Authority; some think it was prepared by tne Commission; some think it was prepared by state or local governments.
There is, in fact, no single " plan" document nor l
should there be one. Rather, there is a set of plans which may be broadly divided among four categories:
l (A) The site plans. Separate plans were prepared individually by Con Edison and the Power Authority for the ;
Indian Point 2 and Indian Point 3 plants, respectively. These are l
the only plans actually writien by and for the licensees and over which the licensees have control. Our testimony herein is there-fore directed toward the Indian Point 3 site plan.
(B) The State plan. This plan was prepared by and for the State of New York, and covers all commercial nuclear plants within the State.
(C) The County plans. These were prepared by consultants for the use of the four counties surrounding Indian l
1 Point. The development and maintenance of the county and State n
. t plans is a governmental obligation.
(D) Contiguous state plans. These are plans prepared
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- by and for contiguous states within a 50-mile radius of Indian Point.
Thus, the only component of the overall plan for which the Power Authority has jurisdiction is the Indian Point 3 site plan.
Misconception Number 4 People frequently refer to an " evacuation plan" l for Indian Point, as if the primary response to nuclear power plant incidents would be the evacuation of a large radius around l lthe plant, and as if the emergency plan were almost exclusively l l devoted to evacuation. This notion is given further impetus by the emergency exercise which is required to test the most extreme circumstances of the plan.
i In fact, however, a general evacuation is the least likely response to the spectrum of accidents possible at the plant, and evacuation is only one of the many components of the f overall plan. Even if a general evacuation were ordered, it would only involve sectors known as Emergency Response Planning Areas
("ERPA's") within close proximity to the plant, not an entire ten- l l'
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mile radius. In almost all radiological incidents, including those, designated " emergencies" like the recent accident at the Ginna plant near Rochester, the emergency response would occur solely within the plant boundaries; no public reaction would be necessary or called for.
This last point is very important, because it demon-strates that the critical component of the overall emergency plan is the site plan. If the site plan and operating procedures are properly followed, the need for any off-site response at all would ltus extremely remote. Therefore, the key to protection of the plant, workers, and the public is proper on-site preparedness and ,
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ilIII. THE SITE PLAN'S EFFECTIVENESS i l Introduction to the Plan and Procedures l l
Underlying the effectiveness of site emergency pre-paredness is the methodology and scope of emergency response at l
. Indian Point 3. The Indian Point 3 Nuclear Power Plant emergency I
planning program consists of two separate but coordinated docu-ments. The first document, the Emergency Plan, establishes the i
. format and organization of particular appropriate emergency responses. The Plan document defines specific requirements, l
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'* commitments, and agreements that, when implemented, afford Indian Point 3 a streamlined, efficient response to an emergency. The l
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e second document, the Emergency Planning Implementation Procedures Document, provides detailed information and procedures that will
,. 2 be necessary in order to efficiently implement the Indian Point 3 Emergency Plan. The Emergency Plan Procedures Document is a
" working" source of emergency classification and subsequent-instructions and procedures to be followed by plant emergency response personnel. This document is very dynamic and specific, containing, among other items, forms, flow charts, methodology, names, phone numbers and initiating conditions for the various emergency action levels.
The plan and procedures are based on four " emergency action levels," as recommended by NUREG-0654, Appendix 1. In order of increasing seriousness, they are as follows:
(A) Notification of Unusual Event: events are in process or have occurred which indicate a potential degradation of the level of safety of the plant; (B) Alert: events are in process or have occurred which involve an actual or potential substan-tial degradation of the level of safety of the plant; (C) Site Area Emergency: events are in process or have occurred which involve actual or likely 1
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major failures of plant functions needed for protection of the public;
,- '2 General Emergency: events are in process or (D) have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity.
Site Response and Emergency Organization The Shift Supervisor or most senior licensed reactor operator of the Watch Organization holds the responsibility for classifying and declaring an emergency. Based on the specific initiating conditions the emergency would be classed as a Noti-fication of Unusual Event, Alert, Site Area or General Emergency and the remainder of the response would be governed by that classification. It is important to note that the Emergency Classification may be changed during the course of the emergency, either upgraded or downgraded as plant conditions and their impact change. The Shift Supervisor would remain the Emergency Director until responsibility was assumed by the Resident Manager or other such trained individual, according to the hierarchy specified in the plan.
Indian Point has an added advantage as one of the few sites with moltiple nuclear power plants operated by different Having an independent licensee next-door at Indian licensees.
Point 2 makes available additional sources of support in the event of an emergency. A Memorandum of Understanding (MOU-28) betwebn the licensees (a copy of which is annexed to the site Emergency Plan) reflects this close cooperat' ion and mutual aid agreement. ,
After the declaration of an emergency, the Emergency Director is to ensure that prompt notifications are made to on-and off-site authorities. The Control Room would be the initial location where communication links would be established.
Staffing and primary and alternate communication paths are present twenty-four hours per day. The site emergency plan (Section 6.0) contains a list of the authorities who will be notified of emergency conditions at Indian Point, and those ithat may be notified dependent on the specific emergency conditions. Off-site authorities are apprised in accordance
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with procedure and alerted when any change in emergency classi-fication is made.
The initial notification of these authorities i
j is made within 15 minutes of the declaration of the emergency over the Radiological Emergency Communications System (" RECS"),
a dedicated hot-line linking eighteen parties, including six --
the State, the City of Peekskill, and the four surrounding counties -- which are notified initially. Once the State is notified, the obligation to notify parties who did not pick up o
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their phones passes to the State. This avoids " tying up" plant operators on the telephone. The initial message consists of idenilfication of the plant, the nature of the event, the circumstances, whether there has been a release, and whether there is an immediate need for protective action. Follow-up to the initial information is to be given approximately every 30 minutes.
Contingent on the type of emergency classifica- l tion, various emergency response facilities would be activated and manned. The Emergency Director would ensure that emergency response staffing is consistent with approved procedures.
Provisions have been made during norra: working hours and off hours to accomplish emergency response staffing. During normal
! work hours, the necessary personnel are available on-site and
.are contacted by the public address system or telephones; lduringoff-hours,personnelcanbecontactedattheirhomesor l
l located by the use of beepers. Facility activation and staffing I are described in Section 6.0 of the Emergency Plan.
l An organizational chart has been established for :
- I use during emergencies, and these trained individuals have been assigned positions in that emergency response organi-I- '
l zation. Hierarchies have been developed for key positions.
The various emergency response facilities, and their staff-ing and roles, are detailed in Section 7.1 of the site
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l IV. CAPABILITIES OF PERSONNEL, FACILITIES, AND EQUIPMENT TO RESPOND TO AN EMERGENCY Personnel A. Training Personnel active in the On-site Emergency Organiza-tion are trained as to their responsibilities, the estab-lished procedures, and the responsibilities of their support-ing staff. To accomplish functional assignment of emergency response personnel, employees are selected for emergency planning duties similar to their normal work functions.
Employees are trained in their proper responses to emergency situations at Indian Point 3.
The purpose of emergency planning training is to develop and maintain the proficiency of the emergency plan personnel. The training program is established to accomplish the following:
- 1. familiarize personnel with the Emergency Plan and Procedures;
- 2. train key personnel in specific duties relevant to their roles;
- 3. inform, or re-train if necessary, personnel re-garding significant changes in the Plan or Pro-cedures;
- 4. satisfy emergency response performance objectives; and
- 5. correct inadequate drill or exercise performance.
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O Demonstrated competence is required.
, . T; Training for reactor operators includes intensive training in plant systems; simulator training for normal and abnormal plant conditions; and how to recognize and mitigate core da~ mage. In addition, formal training is given in the emergency plan and how to perform the proper notification and assessment.
Further details regarding emergency plan training are contained in Section 8.0 of the emergency plan.
B. Staffing on-site staffing is extremely important. Even the most sophisticated equipment would be of less than optimal use if adequate personnel are not available for monitoring and response.
Based on the above instructional proceditres, the staff is well-trained to perform tasks required in an emergency.
As noted, the people chosen and trained for tasks during emergencies would be doing similar tasks during routine opera-tions. For example, the Emergency Director would normally be a shift supervisor or resident manager, individuals who normally direct operations at the plant. Our normal complement of personnel on shift is adequate to meet the staffing requirements of Table B-1 of NUREG-0654.
1 v Emergency Response Facilities 1
A. Emergency Operations Facility (" EOF")
. ~c A primary and alternate EOF have been established.
The principal location of the primary EOF is the main building of'the Indian Point Service Center Complex located o.1 Broadway l 1
in Buchanan, just south of the Bleakley Avenue intersection. i Center Complex facilities include gasoline service, vehicle repair equipment, Indian Point No. 2 Storeroom, Indian Point Medical Facility, toilet, shower, lockers, and office space, in addition to field monitoring and sampling equipment. The EOF includes dose assessment tools, communications equipment, status charts, radiological monitoring equipment and radiation dosimetry. The EOF houses the MIDAS and ARAC systems, described ,
below, used to obtain meteorological data, to project plume path, and to assess dose. There are two levels to the EOF. The first floor is designed for coordination of the response by the Emergency Director. The second floor is specifically for l
county, State, NRC and FEMA personnel. The alternate location is established at the Con Edison Eastview Service Center, on Saw Mill River Road, outside the plume emergency planning zone.
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. B.. Technical Support Center ("TSC")
At the TSC, engineering and operations personnel will evalQate plant operating and accident conditions in support of watch force operations. The Technical Support Manager will exercise control over TSC activities and maintain contact .
with the Control Room. The Shift Technical Advisor in the Control Room will be the TSC liaison with the Control Room.
'rechnical Services personnel are assigned to the TSC during emergency conditions.
Plant parameters can be continuously monitored on a television screen that is linked with the plant computer.
The TSC is adjacent to the Document Control Department, and thus has access to drawings and records that describe the i
as-built conditions and layout of structures, systems, and components of the Indian Point 3 Plant.
I C. Operations Support Center ("OSC")
The Operations Support Center is the central point l
from which personnel are assigned and scheduled to accomplish a variety of emergency tasks. Personnel assigned to the OSC may include Maintenance, Instrument & Controls, Operations,
- Health Physics and Chemistry personnel.
D. Special News Center In the event of an emergency which warrants the use of a near-site facility for disseminating clear, accurate information directly to the press, the Verplanck Fire Pro-tection Association has agreed to allow use of its headquar'ters for the Special News Center. The Special News Center Director will manage the Center, as the principal contact with the news media. The Director will act under the direction and support of the Vice President of Public Relations and the Power Authority Headquarters staff. Among other means of coordinating emergency communications and information flow, an electronic message rumor control unit has been provided at the Special News Center. The unit's telephone numbers will be announced to the public in the event of an emergency. Communication channels also exist for Power Authority, State, county and news media o .
representatives.
l Equipment A. Radiction Detection Equipment
- 1. On-site Radiation Detection Equipment A broad range of equipment is available to detect the presence of radiation. At the plant site, the following items are among those available, together with personnel trained in their use:
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- a. Survey instruments - used.to detect and quantify alpha, beta, gamma and neutron radiation levels in plant areas (e.g., ion chambers, Geiger-Muller detectors).
- b. Laboratory instruments - used to measure and identify radioactivity in air or on surfaces in plant areas (e.g., proportional counters, scintillation detectors).
- c. Personnel dosimetr" - used to measure the amount of radiation exposure for each indivi-dual inside radiation areas in the plant (e.g., pocket ion chambers (dosimeters),
thermoluminescent dosimetry, film badge).
- d. Area monitors - fixed radiation detectors in various areas in the plant to monitor radia-tion levels; readouts are in the control room.
- e. Process radiation monitors - detectors that monitor radioactivity levels in air and fluids in the plant and at release points; readouts are in the control room.
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- 2. Off-site radiation detection equipment In keeping with the Power Authority's obligations to'the public both as a nuclear power plant operator and as a public agency, we have also installed equipment and established procedures for monitoring off-site releaset.
These include the following:
o Off-site monitoring, during an emergency with potential or actual off-site consequences, is conducted using two mobile survey vehicles.
These vehicles are equipped with 2-way radios, for communications with the Emergency Director and the Assessment Team, air samplers, portable survey meters, as well as personnel dosimetry, protective clothing and respirators. Portable survey equipment includes ionization chambers and low-level radioiodine detection equipment.
o A Reuter Stokes Sentri 1011 Environmental Radiation Monitoring System presently exists in the Indian Point immediate vicinity.
Sixteen monitors within a 2-mile radius surrounding Indian Point telemeter radiation level readings to a dedicated central processor which relays its information into MIDAS computer system in the EOF. Instantaneous or integrated dose readings can be obtained.
o Approximately 25 locations within the four county area have Ludlum area radiation monitors situated in 24-hour a day manned posts.
- Digital readout measures gamma fields.
a o The Consolidated Edison Nuclear Environmental Monitoring Group conducts a continuous off-site radiological monitoring program for the entire site. This program includes collection
,_ 2 and analysis of TLD's, continuous air particu-late and radioiodine samples, water, milk and seasonal aquatic and land vegetation samples.
These same pre-established sampling locations can be used during an emergency by the off-site monitoring teams for immediate sample analysis, or following an emergency for post accident environmental monitoring.
B. Plume Prediction
- 1. Meteorological monitoring - on-site A primary 122 meter meteorological tower is located on the Indian Point site to provide real-time meteoro-logical parameters. Instruments are located at the 10m, 60m, and 122m levels. The tower electrical service is wired into a redundant diesel generator power supply, with an automatic power transfer switch. There is an equipment trailer located adjacent to the meteorological tower which has local read-outs. Meteorological readouts of wind speed, wind direction and Pasquill Stability Category are available in the Control Room. Remote access to these meteorological parameters is -
available via telephone communication using an ASCII termi-nal. This data is averaged and sent to the MIDAS and ARAC systems (described below) in the EOF.
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i A 10-meter backup tower, with a backup power supply, is near the Con Edison Service Center Building.
,- c Real time data, consisting of wind speed and direction, are continuously recorded. An estimator of atmospheric stability (sigma theta) is derived from the wind direction fluctua- l tions. Readout for the tower is located in the EOF and can be accessed remotely via telephone communication with an
. ASCII terminal. Both meteorological measurement systems relay their data to the EOF MIDAS syctem.
- 2. Meteorological Monitoring - off-site I
Indian Point 3 has sophisticated, redundant methods !
for predicting and tracking the path of a radioactive release I Predictions are made by assessing the beyond the plant boundary.
nature and extent of release in the context of real time and pro-jected meteorological conditions. Confirmation can be obtained and plume moi;ement further traced by use of off-site detection equipment.
Prediction is principally accomplished by utilizing meteorological data in conjunction with the plume overlays, as described below. The MIDAS and ARAC systems provide sophisti-cated support, as well as confirmation and redundancy.
l Off-site meteorological information can be obtained from various National Weather Service stations; a 100-meter
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. i meteorological tower, located at the Orange and Rockland Utilities Bowline plant in Haverstraw, N.Y.; and windsets, capable of moni-to_ ring and recording wind direction and speed which are deployed with each of the 16 Reuter Stokes instruments. Additionally, a f
weather service is under contract to provide hourly wind speed, wind direction, atmospheric stability and precipitation fore' casts l
for the Indian Point area.
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- 3. Plume Overlays 1-
! Transparent overlays are available which depict "the relative dispersion surrounding Indian Point. These overlays are placed over a site and area map to show where a j i
plume would be expected to travel. These overlays have been developed using real meteorological data from the Indian Point
.I l! area,consideringtheeffectofwinddirection, atmospheric .
h stability, and terrain.
- 4. MIDAS 1 Meteorological Information Dose Assessment System t
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!(" MIDAS") is a computer system which by the use of meteoro-I logical and plant parameter inputs and atmospheric diffusion computer codes offers the capability to predict plume move-ment and offers dose assessment predictions for plume-covered territory. Using graphics displays and data listings, MIDAS i
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offers representations of the plume for two specific types of computer models. The first is a straight line gaussian model (class "A") and the second a modified potential flow model-(class "B") incorporating terrain and' segmented plume representing plume stay times. This model can make predictions ,
for both the plume and ingestion exposure pathway EPZ's. The system can also utilize output from site meteorological systems and data from Reuter Stokes instruments.
County EOC's have been provided at the licensees' expense with Apple computers upon which they can gain access to the meteorological and Class "B" model information output from MIDAS. This affords the counties an independent and visual means for dose assessment emergency response.
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- 5. ARAC To complement the MIDAS system, the ARAC (Atmos-pheric Release Advisory Capability) system is also available on l
an experimental basis to use for dose assessment and plume prediction by the assessment staff of the EOF. ARAC parallels
! MIDAS in its role of using meteorology and plant parameters l
together in predicting plume movement and dose assessment.
1 ARAC depicts a three dimensional wind field of the surrounding territory using on-site and off-site meteorology and graphically represents plume movement and concentration.
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The State of New York has the ARAC capability and as such can access site meteorology and plume and dose predic- -
tionirfor the Indian Point area.
C. Communication Equipment Communications are critical in ensuring an adequate I I
on-site and, if necessary, off-site response. Indian Point 3 has an extensive communications system, designed to ensure direct, efficient communication among all control points and all emergency personnel responsible for mitigating actions and/or directions. The system provides reliability through a variety of internal and external alternatives: particularly crucial telephone lines are duplicated; several modes of f communication are available; the Control Room has a dual ,
I power supply, in the event one system fails; equipment is
' allotted to particular systems to avoid swamping; and several systems are used routinely, assuring detection of system failures. Communication equipment not normally used is checked 1
monthly. Immediacy and efficiency are facilitated by prompt i i
notification, pre-established lines of communication, and pre-determined allocation of authority and responsibility, as well as personnel training and familiarity with emergency responses. Communication links are manned on a 24-hour-a-day basis during emergency conditions.
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I, In this testimony, communications equipment is divided into two sections, internal on-site communications and communi-
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- cations between on- and off-site organizations.
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- 1. On-site Communication The internal on-site communication system includes:
(A) A public address system with two subsystems: ,
(1) plant party paging which links portions of the plant through a network of phone stations and loudspeakers; and l
(2) site public address system which allows i paging at the Indian Point 3 site.
(B) Four distinct alarms to warn, respectively, i of fire; air raid; site assembly; and I containment evacuation. l (C) Direct extension lines to Indian Point 2.
l (D) Radio communication, including link to New l York State Police.
(E) Radio paging system beepers to call in emergency plant personnel if needed.
(F) Standard internal telephones and intercoms.
l l, 2. Off-site Communication Systems i l Communications links with off-site organizations include:
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(A) The NRC Emergency Notification System.
Mandated by Commission regulatiens, this is a direct hotline to 1
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Commission headquarters in Bethesda. It includes a party line connecting the control room, shift supervisor, technical suppdyt center, and resident NRC inspector.
(B) Authority Standard Dial Telephones. The control room has direct dial capability. The Emergency Response Network is programmed in.
(C) Radio Communication. The Con Edison Emergency Plan Radio Frequency permits communication between the EOF, alternate EOF, the Unit 2 and 3 control rooms, and off-site moni-toring vehicles and Con Edison security. The Power Authority's l Security Radio Frequency monitors site security and has direct
.. communication with the New York State Police. .
(D) Hotline Telephone Network. Although not required by federal regulations, the licensees have purchased i
and installed this multi-point conferencing circuit connecting the Unit 2 and 3 control rooms with the EOF, alternate EOF, l
the county EOC's, the City of Peekskill EOC, and the New York State EOC.
(E) To be installed is a radio system (non-land ;
line) allowing all of the aforementioned hotline links to communicate via non-land line radio.
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(F) National Warning System ("NAWAS") Line.
This is a dedicated national party line between control room I
and county / State warning points and the City of Peekskill.
. I (G) Health Physics Network Line. This line j connects all nuclear power plants, the NRC Regional Office in King of Prussia, Pennsylvania and NRC Operations in Bethesda, MaryEgnd. It allows transmittal of radiological information by government employees.
These systems provide numerous levels of redundancy,.
and exceed the basic Commission guidelines. We are confident that they provide more than adequate assurance that proper communica-tions can be effected during a radiological emergency.
D. Additional Plant Instrumentation i
Additional plant instrumentation related to emergency preparedness is described in Section 7.0 of the emergency plan. Such instrumentation includes:
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- l. two high range radiation monitors in !
containment installed to assist in determining the amount of radioactivity released to the containment building;
- 2. a high range plant vent monitoring system to assist in quantification of any potential release from the plant vent;
- 3. systems to enable plant chemistry personnel to sample reactor coolant, containment air, and the plant vent air for radioactivity;
- 4. fire detection equipment;
- 5. seismic monitoring equipment; and
- 6. instrumentation for detection of inadequate core cooling.
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E. Maintenance of Emergency Supplies On-site emergency supplies are located in designated s - J emergency lockers. Inventoried and operationally checked monthly are the Control Room, TSC, EOF, AEOF, OSC and Security lockers. Health Physics equipment lockers and control point and warehouse stock are available during normal or emergency
., conditions.
Locker inventory includes dosimetry and film badges, respirators, self-contained breathing apparatus, protective clothing, and ample doses of potassium iodide. Area radiation monitoring equipment is found in most lockers.
Dose Assessment During alerts with potential radiological consequences and during Site Area and General Emergencies, radiological l
assessment actions are initiated. Included in radiological l assessment actions are assessment of the magnitude of the l
problem and the potential for a release; radiological projection; on-site and off-site radiological monitoring; radiological l
l assessment based on plant parameters; plume prediction based on meteorological data; calculations for dose projection; and on-site and off-site radiological monitoring for verification.
All radiological assessments are designed towards mapping the r l 1
. I radiological conditions of the Indian Point Site and its i
environs during emergency conditions, and making protective j i
actioh recommendations based on evaluation of radiological
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i data, both calculated and real time.
l County and state radiological assessment personnel are located in the EOF, and can therefore perform the assess-ment concurrently. The EOF communicates dose assessment and recommended protective actions information to the State and county EOC's on a regular basis. l Decontamination !
I Many persons mistakenly believe that any radioactive f decontamination entails lengthy, complicated treatment with
! l lspecial equipment in special facilities. In most situations, ;
i lhowever, this is far from the case. Indeed, all that is normally needed is a soap and water shower; even a spraying with a garden hose could suffice.
Decontamination procedures are described in Section 6.0 of the emergency plan.
V. PLAN MAINTENANCE MEETS ALL APPLICABLE REGULATIONS AND 1
PROVIDES ADEQUATE PROTECTION FOR THE PLANT AND PUBLIC By exercising our emergency plan and preparedness, l
We develop various ways to maintain the Indian Point 3 site !
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emergency plan consistent witn current regulatory requirements and-ipdustry site practices. By the very nature of exercises and drill experiences, the emergency plan is scrutinized and tested to assure compliance with regulations and to assure that emergency preparedness is at a high and workable level.
Utility and Commission critiques compare regulations with practices to assure this compliance. Critiques also provide an opportunity for participants to comment and recommend changes and methods to improve site emergency preparedness. Drill reports are issued and a method of documenting filing and scheduling improvement items are implemented in the system called EPCARS (Emergency Plan Corrective Action Reports).
The entire drill experience reinforces the training i jprocess and identifies areas to emphasize and fine-tune in the re-training sessions. In this framework, this constant l
I i upgrading of personnel knowledge and experience assures adequate I emergency response for the site and the public.
Not only are plans, procedures, practices and training constantly reviewed and upgraded, but equipment and facilities are maintained by conducting inventories, operability i
checks and calibrations.
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In addition to all other forms of maintaining the emergency preparedness of the site, a yearly plan and pro-cedure review is performed by the site Plant Operating Review Committee and the Corporate Safety Review Committee. A yearly independent review of the entire emergency preparedness program is also accomplished.
VI.
SUMMARY
By reason of the foregoing provisions and the depth of the entire emergency plan and procedures, we believe that the plant and public are adequately protected. This conclusion is supported by two recent and very positive experiences with the site emergency plan. On March 3, 1982, we held a
] full-scaleemergencyplanningexerciseatIndianPoint3, lI Based upon our own yincluding on-site and off-site response.
h detailed critique, we consider the exercise a success. The most positive feature of the exercise was its demonstration that the emergency organizations of the power plant and off-site authorities are in place, and can function very effect-ively and harmoniously.
l The exercise, like any drill, was designed to un-cover potential problems. While the overall exercise was very i successful, we did note some need for changes which are now l
l . being implemented.
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i A second demonstration of the efficacy of the emergency plan took place on March 24, 1982, when an " unusual eventy was declared following a minor leak in a steam generator.
As a result of the " trained-in attitude" we 'have promoted, the plant operators immediately knew how to respond, took all appropriate actions and brought the plant to a safe shutdown condition. Appropriate notification was made, and there were no adverse consequences to the public.
These experiences demonstrate that Indian Point 3 has exceptional equipment, procedures, personnel, training, and supervision to plan for and respond to any abnormal
- occurrence.
II ii The Power Authority is committed to correcting any l
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i'deficiencies noted as a result of the March 3, 1982 exercise. l
!lIndeed, this process is already underway.
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IVII. CONCLUSION The site plan and procedures are more than adequate l i
.to protect the integrity of the plant and the health and I -
I safety of the plant and the public. Emergency planning is {
a dynamic process, and the Power Authority is committed to making any reasonable future changes to further safety. -
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Louis J. Carter, Chairman Frederick J. Shon Dr. Oscar H. Paris
)
In the Matter of ) Docket Nos.
. )
CONSOLIDATED EDISON COMPANY OF NEW YORK, ) 50-247 SP INC. (Indian Point, Unit No. 2) ) 50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK )
(Indian Point, Unit No. 3) ) June 7, 1982
)
CERTIFICATE OF SERVICE I hereby certify that copies of LICENSEES' TESTIMONY OF DR. RUSSELL DYNES, LICENSEES' TESTIMONY OF SIDNEY LECKER, M.D., LICENSEES' TESTIMONY OF PARSONS BRINCKERHOFF QUADE &
DOUGLAS, INC., and POWER AUTHORITY'S TESTIMONY OF JOHN C. BRONS, LINDA LOMONACO AND DENNIS QUINN in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 7th day of June, 1982.
j Docketing and Service Branch Ellyn R. Weiss, Esq.
Office of the Secretary William S. Jordan, III, Esq.
U. S. Nuclear Regulatory Harmon & Weiss Commission 1725 I Strect, N.W., Suite 506 Washington, D.C. 20555 Washington, D.C. 20006 Louis J. Carter, Esq., Chairman Joan Ho.t, Project Director Administrative Judge Indian Point Project Atomic Safety and Licensing New York Public Interest Board Research Group l 7300 City Line Avenue 9 Murray Street
! Philadelphia, Pennsylvania 19151 New York, N.Y. 10007 1
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Dr. Oscar H. Paris John Gilroy, Westchester Administrative Judge Coordinator Atomic Safety and Licensing Indian Point Project U.S. Nuclear Regulatory New York Public Interest Commission Research Group Washington, D.C. 20555 240 Central Avenue White Plains, New York 10606 Mr. Frederick J. Shon Janice Moore, Esq.
Administrative Judge Counsel for NRC Staff Atomic Safety and Licensing Office of the Executive Board Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Jeffrey M. Blum, Esq. Brent L. Brandenburg, Esq.
New York University Law Assistant General Counsel School Consolidated Edison Co.
423 Vanderbilt Hall of New York, Inc.
40 Washington Square South 4 Irving Place New York, N.Y. 10012 New York, N.Y. 10003 Marc L. Parris, Esq. Charles J. Maikish, Esq.
Eric Thorson, Esq. Litigation Division County Attorney The Port Authority of County of Rockland New York and New Jersey 11 New Hemstead Road One World Trade Center New City, N.Y. 10956 New York, N.Y. 10048 Ezra I. Bialik, Esq.
Joan Miles Steve Leipsiz, Esq.
Indian Point Coordinator Enviromental Protection Bureau New York City Audubon Society New York State Attorney 71 West 23rd Street, Suite 1828 General's Office New York, N.Y. 10010 Two World Trade Center New York, N.Y. 10047 Greater New York Council on Alfred B. Del Bello Energy Westchester County Executive c/o Dean R. Corren, Westchester County Director 148 Martine Avenue New York University White Plains, N.Y. 10601 26 Stuyvesant Street ,
New York, N.Y. 10003 I
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Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Andrew S. Roffe, Esq. Honorable Richard L. Brodsky New York State Assembly Member of the County Albany, N.Y. 12248 Legislature Westchester County County Office Building White Plains, N.Y. 10601 Renee Schwartz, Esq. Pat Posner, Spokesperson Paul Chessin, Esq. Parents Concerned About Laurens R. Schwartz, Esq. Indian Point Margaret Oppel, Esq. P.O. Box 125 Botein, Hays, Sklar & Herzberg Croton-on-Hudson, N.Y. 10520 200 Park Avenue New York, N.Y. 10166 Stanley B. Klimberg Charles A. Scheiner, Co-General Counsel Chairperson New York State Energy Office Westchester People's Action 2 Rockefeller State Plaza Coalition, Inc.
Albany, New York 12223 P.O. Box 438 White Plains, N.Y. 10602 Honorable Ruth Messinger Alan Latman, Esq.
Member of the Council of the 44 Sunset Drive i
City of New York Croton-on-Hudson, N.Y. 10520 District No. 4 City Hall New York, New York 10007
- Richard M. Hartzman, Esq. Zipporah S. Fleisher Lorna Salzman West Branch Conservation Friends of the Earth, Inc. Association 208 West 13th Street 443 Buena Vista Road New York, N.Y. 10011 New City, N.Y. 10956 l
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t Mayor George V. Begany Judith Kessler, Coordinator Village of Buchanan Rockland Citizens for Safe 236 Tate Avenue Energy Buchanan, N.Y. 10511 300 New Hempstead Road New City, N.Y. 10956 Ms. Amanda Potterfield, Esq. Ruthanne G. Miller, Esq.
P.O. Box 384 Atomic Safety and Licensing Village Station Board Panel New York, New York 10014 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 David H. Pfkus l
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