ML12335A582

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Official Exhibit - CLE00012C-00-BD01 - Michael R. Edelstein, Ph.D., Environmental Justice Impacts from the Proposed Relicensing of the Indian Point Nuclear Power Complex: a Focus on Sing Sing Prison (October 5, 2011) Part 3
ML12335A582
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 10/05/2011
From:
Hudson River Sloop Clearwater
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21641, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR
Download: ML12335A582 (18)
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Text

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3)

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ASLBP #: 07-858-03-LR-BD01 Exhibit CLE00012c

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Docket #: 05000247 l 05000286 Exhibit #: CLE00012C-00-BD01

',, ! Admitted: 10/15/2012 O~

Identified: 10/15/2012 Withdrawn:

Submitted 12/22/11 lIfo.* * .-

~ Rejected: Stricken:

Other:

Movmg a hIgh secunty gnson gogu a JOn IS groblematic An evacuation of Sing Sing would entail significant problems beyond the scope of the evacuation of the general population. Inmates from Sing Sing would only be moved under controlled and secure conditions. Buses and guards would be required. Encounter of congestion and delay would be viewed as a security issue and security in route would be viewed as a paramount concem. And destination(s) would have to be carefully arranged, avoiding the many pitfalls found with the evacuation of OPP inmates, creating complications of last minute planning and dispersal of inmates to different facilities.

In that case, what kinds of impact would prisoners expect during the resulting transitions? Again, the Katrina case described above is enlightening as to the general issues. Suggested is that it would take emergency persOJUlel beyond officers on hand to mobilize and move so large a cohort of high security prisoners. The Witt report suggests that State Police from New York and New Jersey would be involved. These forces would have to be pulled off other duties at a time of crises and sent into a presumable danger zone. The inmates interviewed indicated that they would likely have to be chained and secured to be moved, a time consuming and clumsy operation to calTY out under duress. Sufficient vehicles, catalogued by Witt, would have to be dedicated for the evacuation, which means they would have to be withheld from other emergency services. Drivers would be required even though Witt acknowledges that they might be in short supply.

Then there is uncertainty for the reassigned evacuees about being the new inmate "in town." Witt reports a vague plan to reassign inmates at the point that their relocation from Sing Sing becomes necessary. Assuming that such an analysis of beds and prisoner characteristics for matching to an appropriate placement were possible on short notice under crisis conditions, implied is that Sing Sing prisoners would have to be sorted by destination, either before leaving Sing Sing or at an intermediary evacuation point that is apparently not pre-designated. The integration of inmates into new settings may go smoother than at Katrina if, in fact, computer matching is carried out and if there is not a wholesale dumping of prisoners into another location overwhelmed by the same crisis, as occurred in Louisiana. Such a process might prevent racial or other problems with the integration into a new setting. There may be conflictive issues, however, stemming from gang or other allegiances that might not be anticipated in the computer matching process. On the other hand, they will have the added burden of environmental stigma. Sing Sing prisoners might be stigmatized as radioactive beyond any other stigma issues that might arise.

Summary for Evacuation Without diminishing the challenges faced by others attempting to evacuate under conditions that Witt predicts to be difficult and ineffective, it can be concluded that evacuation during a radiological event at Indian Point represents the potential for a large number of significant adverse impacts to the EJ prisoner population that are different from and disproportionately more severe than those faced by others. Prisoners will potentially remain longest in an environment perceived as radioactive and possibly truly so. They are totally dependent on others to move 39

them and to decide the timing, destination and route. And, absent a plan for such an evacuation,

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the unique challenges of moving a high security inmate population, evacuation can hardly be seen as an adequate mitigative strategy to protect this EJ population.

5. Proposals to strengthen mitigation Given the above analysis, are there meaningful things that can be said about mitigation that would assure the protection of the inmate population at Sing Sing during an Indian Point emergency?

Improving the Protectiveness of Shelter-in-place In order to justify employing the strategy of shelter-in-place, a complete energy and infiltration audit must be made of the entire prison complex. Using this audit, corrections and modifications must be made to assure that entry points are controlled. Even a tight building can have technical systems overcome by human behavior. Superb training standards are required to assure that systems are operated properly and not defeated by mistakes, such as allowing windows to remain ajar.

Due consideration must be given to whether and for how long Sing Sing can operate without fresh makeup air. Will it be known if the shell is breached during an emergency? How uninhabitable will Sing Sing become under no-ventilation conditions and how fast? What might be done to maintain habitability so as to keep prisoners from challenging conditions? These and other questions must be addressed, ideally with the participation of inmates.

Improving the Protectiveness of Evacuation Given the lack of any intention to evacuate Sing Sing il1l1lates, it may be odd to ask for a plan to do so. Nevertheless, should conditions deteriorate sufficiently due either to excessive release of radioactive air or because shelteroin-place cannot be sustained, the eventuality of evacuating Sing Sing may arise.

Plan Evacuation Even if evacuation is not the first choice, better evacuation planning is required if Sing Sing inmates are not to be placed at risk and subjected to undue stress in a manner parallel to that seen at OPP in New Orleans. The "plan" to figure out transport and where individual Sing Sing prisoners might ideally be transferred to in the midst of a radiological emergency is imprudent.

Instead, a serious designation should be made for an evacuation site for Sing Sing inmates that would be able to take all the prisoners on short notice in order to remove them from ham1's way.

The pl an should include suitable quarters, supply and control in order to avoid the transitional problems seen in Louisiana. Once at the temporary site, there is time to plan and an'ange appropri ate transfers to a pennanent location.

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CatTY Out a Test Evacuation Given its unique vulnerability, Sing Sing should be included in emergency response preparedness exercises and this should be a condition of any Entergy pem1it.

Robbins writing of a survey evaluation of emergency response plans for prisons, stresses the requirement that actual evacuations be conducted.lxxxiv It is not until a real evacuation is conducted that prison administrators can discover problems with plans that otherwise exist only on paper. While the safety risks are undoubtedly significant in high-security areas, these risks can be abated by using extra staff or engaging in additional planning.

A test evacuation of Sing Sing for a radiological event would demonstrate whether or not it was feasible and allow for correction. The practice effect would be helpful for guards and prisoners alike with regard to preparing for an actual event. Of course a test evacuation of just Sing Sing would miss the complications predicted by Witt associated with a general large scale evacuation.

Other Forms of Mitigation Having identified potential impacts, other mitigations come to mind that may assuage potential harm?

Improve Emergency Response A mitigation checklist proposed by ACLU in its analysis of Katrina is relevant here. I have appended this list (Appendix I), modifying flood related questions to anticipate a nuclear event at Indian Point. Using a checklist such as this as the basis for independent monitoring of emergency response preparation would offer some additional protection to prisoners. lxxxv Better Inform and Involve Inmates and Reassure Them Realistically As was noted during my conversation with Sing Sing prisoners, if the population is informed of the threat and how the prison plans to deal with an emergency, there is a greater likelihood prisoners will cooperate if the worst occurs. Of course, informing the population invites worry.

But building a reservoir of trust will help if demanded under crisis. Ifprisoners, for example, know that there is KI on hand and what procedures will be used to dispense it, it will help avoid a divisive issue later on. Also, as seen from the brief conversation with prisoners, those inside Sing Sing know the prison well, including its assets and its vulnerabilities. Engaging interested members of the community may lead to insights that will make it more protective.

Add Vulnerable Person Coordinators 41

Hoffman advocates for the creation of independent "VPC"s (vulnerable person coordinators)

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represent an independent group concemed only with the wellbeing of prisoners in instances of high vulnerability.lmvi The vulnerable populations for which VPCs are responsible should inelude prisoners. The VPCs should oversee efforts to develop plans for the efficient and safe evacuation ofprisons andjails, ensuring that prison authorities conduct disaster drills, coordinate across departmental lines, and have designated facilities that can receive evacuees who are inmates.

With a VPC managing the implementation of emergency response, some potential problems with evacuation might be avoided.

Close Sing Sing One option would be to close Sing Sing, a move that a small group of residents of Ossining are reported to favor. However, despite a current effort to reduce the number of prison beds, Sing Sing fulfills an important role as a maximum security facility. It is also one of the few state prisons close to the New York Metropolitan area, where many prisoner's families live.lxxxvii And, there would be numerous impacts associated with the closing to be examined.

Improve Disaster Preparedness Although the Witt report implied that large stockpiles of food were on hand at Sing Sing, there is a need to review how the prison would fare were a prolonged shelter-in-place be required. Are non-perishable foods stored in sufficient quantities should resupply be inten'upted? Likewise, bottled water and other consumables need to be kept on hand in large quantity without becoming out-of-date. Fomler Westchester County Executive Al DelBello's staff predicted that Ossining, and thus Sing Sing, would face severe water restrictions during an Indian Point event. This potential increases the chance that prisoners will face privation during their shelter-in-place experience.lxx",iii There needs to be a clear description of how Sing Sing would maintain its readiness to feed inmates and guests on hand during a worst case scenario event. As noted, OPP made assumptions about the adequacy of their food platUling that failed in practice during the emergency.

Provide Dosimetry During an emergency at Indian Point, on site monitoring of dose is important as a check to the conventional approach of sampling and modeling during a disaster. There is a clear need for radiation detectors combined with staff training in how to use them. During an emergency, officers and inmates will both want infonnation as to their exposure and to understand where 42

contamination has occurred within the complex. It will be necessary to give reassurances.

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possible and inmates need to be trained to use the equipment, replicating results during a disaster. Such feedback may allow for additional protective steps, signal when iodine pills should be distributed and alert officers that an evacuation is necessary.

Communications The Katrina debacle illustrates the dangers of failing to maintain adequate communication and information sharing with the inmate popUlation. At Sing Sing, a dedicated staff member for each shift should be assigned to become expert on the issues of an Indian Point emergency and attend all meetings and exercises, developing relationships with key sources. During an emergency, these connections can be used to stay informed. Infonnation should be shared directly with patients in order to establish trust and to reduce the effect of rumors spreading.

Another communications issue is that, given the demographic connection of the Sing Sing inmate popUlation to New York City, it should be expected that many imnates will be deeply concerned about the fate of people on the outside. During Katrina, OPP inmates were cut off from their families as phone service failed. This isolation proved to be a special source of stress for the inmate popUlation. Special means should be developed to allow imnates to stay in touch with loved ones during an Indian Point emergency.

Training There should be a dedicated training program for Sing Sing staff and inmates in order to prepare them for roles to be played during an Indian Point emergency. Such training will diminish the risk of misunderstandings during an event and increase the effectiveness of meeting innlate needs.

Conclusion to Mitigation Review It is useful to return to the meaning of mitigation. Writing after the Bhopal accident, a social scientist named Bogard profoundly discussed the distorted sense of security offered by the concept of mitigation l xxxix It is easy to see the mitigation as removing the threat it is meant to address. But in reality, the mitigation is merely a restatement of that impact. Should the mitigation fail or not be in place, then the impact occurs. And mitigations also have impacts themselves. A band aid is only as effective as the tape that holds it on. And if it is on too tight, it hurts to pull it off.

We see this problem with the concepts proposed here, but also with the broader reliance on an emergency response plan where the presumption that shelter in place and evacuation will be protective in the wake of a disaster at Indian Point becomes the basis for approving a facility with known and considerable disaster potential. From the perspectives of mitigation, neither 43

shelter nor evacuation can be counted upon to be protective of Sing Sing prisoners; both

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No Action Should no action be taken and the licenses not be renewed , it may be the case that significant potential for radioactive release will remain on the Indian Point site so long as the reactors have not been fully decommissioned and so long as radioactive wastes are stored on site. However, the likelihood of such events will exist whether or not the license is granted. The continued operations of the plant will add to the risk-life for Sing Sing prisoners by keeping the plant open another twenty years and generating additional high level nuclear wastes for which there is no anticipated off-site storage available. Thus, no action offers a greater likelihood of avoiding the impacts discussed in this report.

Conclusion It is highly likely that prisoners at Sing Sing will be disproportionately impacted should a radioactive release occur at Indian Point for two main reasons. First, the prison will not be evacuated at the same time as the general population, if at all. Second, the impacts will likely be above and beyond the effects of whatever exposure of prisoners to radioactivity occurs. The very acts of shelter and evacuation will cause significant adverse effects for Sing Sing inmates.

These impacts are different and potentially more severe than those suffered by others. Given that the illlilate population of Sing Sing meets EJ criteria, it is my opinion that there is a significant potential for differential adverse effect on an EJ popUlation from the relicensing of Indian Point that needs to be analyzed and mitigated to the degree possible. Under the definitions employed by the federal government, such adverse impacts would constitute an envirol1l11ental injustice.

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Appendix I:

Mitigations Proposed by ACLU in Response to its Analysis of OPP during the Katrina Disaster ACLU generated a checklist for the ERP to test its mitigatory potential. This list has been modified for applicability to IP by this author.

EMERGENCY GENERA TORS

  • Is there an emergency generator?
  • Is the emergency generator adequate to run critical areas of the institution and critical equipment safely for 24 hrs?
  • Are staff trained to know which systems will be run on emergency power and which will be inoperable during a main power outage?
  • Do all emergency generators have sufficient fuel to run for a minimum of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> continuously?
  • If the emergency generators must be started manually in the event of a main power outage, are there staff on duty on a 24-hour basis who are trained to start and operate those generators?
  • Is there a means of supplying fresh makeup air without drawing on external sources that are potentially contaminated?

OFFSlTE EY ACUATrONS

  • Is there an offsite evacuation plan?

If yes, does the offsite evacuation plan include the following:

  • Potential destinations?
  • Specific dedicated transportation alternatives?
  • Security procedures during evacuation?
  • Which inmate records must be moved with inmates?
  • Procedures for providing medical services during and after the evacuation?
  • Provisions for coordinating with local and state police during the evacuation?
  • Arrangements for meal services at the new location?

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  • Arrangements for irunate identification and count at the new location?
  • Arrangements for housing and security at the new location?
  • Predetemlined evacuation routes?
  • Procedures for protection or destruction of confidential records that calmot be evacuated?

MEDICAL SERVICES

  • Is there a comprehensive medical plan for an institutional emergency?
  • Does the plan include mass casualti es/triage?
  • Are staff trained in blood-borne pathogen precautions?
  • Is a location other than the infimlary identified for mass casualties/triage?
  • Does the institution have an emergency-equipped medical crash cali?
  • Are there adequate numbers of gurneys?
  • Are backup medical resources for emergencies identified in the community?
  • Are iodine pills and any other medical needs relevant to addressing radioactive exposure available and up-to-date?
  • Are protective clothing and breathing apparatus available for staff and the inmate population if needed?
  • Are shower facilities and other decontamination measures available even during a nuclear emergency where water supplies and power might be disrupted and is there an organization plan to deploy them?
  • Is appropriate dosimetry avai lable so that exposure in the institution can be measured individually and environmentally (in air, water and food)?

GENERAL CONSIDERATIONS

  • Does the institution have policies in place specific to nuclear disaster planning, response, and recovery operations?
  • Does the institution conduct routine training in nuclear disaster response, including drills and exercises?

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  • Does the institution have current mutual aid agreements with outside agencies to coordinate r"e's"'p"'

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=lIvl!Ies auring a nucl-e-ardrs'aster?'- - - - - - - - - - - - - - - - - - - - - - - - - -

  • Does the institution have emergency response plans and checklists specific to nuclear disaster response?
  • Has the institution identified supplies and equipment that may be needed in a nuclear disaster (water, tents, portable toilets, portable lighting, blankets, etc.)?
  • Does the institution have evacuation and relocation plans, alternative sites selected, and arrangements and agreements for natural disasters?
  • Does the institution have a plan to operate the institution with reduced staffing levels should a nuclear disaster make that necessary?
  • Does the institution have an emergency staff services (ESS) program to respond to staff and staff family needs in the event ofa nuclear disaster?
  • Has the institution planned for 'desert island operations' (operating for an extended period without contaclor assistance from outside) in the event of a nuclear disaster?
  • Is the institution prepared to maintain security and essential services, in the event ofloss of power or other utilities, for as long as 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />?
  • Does the institution have a 3-day supply of potable water onsite or an alternate water supply system?
  • Does the institution have a 3-day supply of food that would not need cooking and that would not spoi l?
  • Does the institution have a 3-day supply of medications for inmates onsite?
  • Do staff and illli1ates participate in nuclear event disaster drills?

NUCLEAR DISASTERS (note this is an added section).

  • Has the institution conducted a thorough risk assessment of vulnerable areas and equipment in the event of a nuclear accident?
  • Does the institution have detailed plans for a complete offsite evacuation in the event of a nuclear accident?
  • Have those offsite evacuation plans been reviewed carefully within the past 12 months?
  • Has the institution practiced or drilled with a nuclear disaster offsite evacuation scenario within the past 24 months, at the level of table-top exercise or above?

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  • Is Sing Sing's nuclear accident response plan developed in stages, so it could be enacted in

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  • Do Sing Sing's nuclear accident response plans include an analysis of which access and egress routes would be rendered unusable at various points in a nuclear accident where the entire metropolitan population might be mobile?
  • Is there a plan for managing the inmate population during a nuclear event either locked down in place or in transit during evacuation and after reaching a destination?
  • Have staff received any training specifically on preparing for and responding to a range of possible nuclear disaster scenarios within the last 24 months?
  • Do the institution's nuclear accident response plans include an assessment of potential for isolating a sheltered inmate population and staff from radionuclides entering tlu'ough open or broken windows and doors or drawn in through the HV AC system or entering in some other manner?
  • Do the institution's nuclear accident response plans include an assessment of the vulnerability of various utilities?
  • Do the institution's nuclear accident response plans include an assessment of potential for isolating a sheltered imnate population and staff from radioactive smoke resulting from a fire at the Indian Point complex? xc 48

Appendix 2:

Health Department IP3.0 xc i : Sheltering-in-Place Guidelines

  • The Sheltering-in-place Option gives the County the capability to implement an effective protective action for the general public in the event of a puff-type radiological release incident at the Indian Point Energy Center (IPEC) In addition, for those situations requiring evacuation and where evacuation cannot be implemented because of time constraints and/or impediments to highway movement, Sheltering-in-place may be implemented in lieu of evacuation.

If Sheltering-in-place is implemented, the general public ad special facility administrators should be informed of the following:

I. Remain indoors and close all windows and doors.

2. Turn off all fans, air conditioning equipment and other sources of outside air.
3. Close blinds and drapes.
4. Extinguish fires in fireplaces and close flues.
5. Keep listening to the TV and radio. For heightened awareness of a radiological emergency and for possible protective actions announced via the Emergency Alert System.

Sheltering-in-place maybe preferable to evacuation as a protective action in some situations.

Because of the higher risk associated with evacuation of some special groups in the population (e.g., those who are not readily mobile), sheltering-in-place may be the preferred alternative for such groups as a protective action at projected doses up to 5 rem. In addition, under unusually hazardous environmental conditions use of sheltering-in-place at projected doses up to 5 rem to the general population (and up to 10 rem to special groups) may become justified. Sheltering-in-place may also provide protection equal to or greater than evacuation due to the nature of the source term and/or the presence of temporal or other site-specific conditions. Illustrative examples of situations or groups for which evacuation may not be appropriate at 1 rem include:

a) the presence of severe weather, b) competing disasters, c) institutionalized persons who are not readily mobile, and d) local physical factors which impede evacuation.

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References:

National Environmental Policy Act of 1969, 42 U.S.c. § 4321 et seq.
Bullard, Robeli. 2000. Dumping ill Dixie
Race, Class, and Environmental Quality. Boulder

Westview, GAO. 1983. "Siting of Hazardous Waste Landfills and Their COlTelation with Racial and Economic Status of Surrounding Communities." http://www.gao.gov/, Commission for Racial Justice. 1987. "Toxic Wastes and Race in the United States: A National Report on the Racial and Socio-Economic Characteristics of Communities with Hazardous Waste Sites."

Cleveland: United Church of Christ.

Edelstein, Michael R. 2004. Contaminated Communities
Coping with residential Toxic Exposure, Second Edition. Boulder, Co. Westview Press.
v 62642 Federal Register I Vol. 68, No. 2141 Wednesday, November 5, 20031 Notices.

Retrieved from http://edocket.access.gpo.govI2003/pdf/03-27805.pdf.

VNuclear Regulatory Commission. Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Action. http://www.lU.c.gov/reading-rm/doc-collections/commissionlpolicyl69fr52040.pdf v; 62642 Federal Register 1 Vol. 68, No. 2141 Wednesday, November 5, 2003 I Noticeslretrieved from http://edocket.access.gpo.gov/2003/pdfl03-27805.pdf; also 69 Fed. Reg. 52,040, 52,044 (August 24, 2004).

v;; Clearwater clearly summarized the NRC's Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions, issued August 24,2004, the Commission acknowledged its "obligation to consider and assess disproportionately high and adverse impacts on low-income or minority populations" pursuant to NEPA. 69 Fed.

Reg. 52,040, 52,044 (August 24,2004). The policy first requires the assessment of impacts peculiar to those communities and then mandates the identification of disparate impacts. 69 Fed.

Reg. 52,048.

v;;; Hudson River Sloop Clearwater Inc. 2007. Petition to Intervene and Request for Hearing Before the Atomic Safety and Licensing Board in the Matter of Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3). December 10,2007, p. 31.

X CLI-98-3, 47, NRC 77, 100 (1998).

x Atomic Safety and Licensing Board. Memorandum and Order in the Matter of Entergy Nuclear Operations, Inc., (Indian Point Nuclear Generating Units 2 and 3), July 6,2011, pp. 52-60.

XI NRC. 2010. NUREG-1437, Supplement 38, December 2010,3-13.

x;; NRC. 2010. NUREG-1437, Supplement 38, December 2010 4-49-4-55.

x;;; Council of Envirol1l11ental Quality. 1997. "Envirorunental Justice: Guidance under the National Enviroll111ental Policy Act."

x;v NRC. 2010. NUREG-1437, Supplement 38, December 2010 4-49-4-55.

xv NRC. 2010. NUREG-1437, Supplement 38, December 2010 5.1-5.4.

50

Hl1dson-River--sloop-GleaFWatef-IA(T.-2()-I-I~Motion-Eor_Leav
e

_ _ _ _ _-"x'v"-- To AmencLAndu.J..E"'x"'te""l"ld'---_ _ _ _ _ _ __

Contention Ec-3 Regarding Environmental Justice And Petition To Do So. February 3, 2011, p.

14.

xv;; Atomic Safety and Licensing Board, Nuclear Regulatory Commission. 2011. "In The Matter Of Entergy Nuclear Operations, Inc. (Indian Point Nuclear Generating Units 2 and 3). Ruling on Pending Motions for Leave to File New and Amended Contentions." CW-EC-3A. July 6, 2011.

xv;;; NRC. 2010. NUREG-1437, Supplement 38, December 20104-49,4-50.

x;x Council of Environmental Quality. 1997. "Environmental Justice: Guidance under the National Environmental Policy Act."

xx Bogard, William. 1989. The Bhopal Tragedy: Language, Logic, and Politics in the Production ofa Hazard. Boulder: Westview.

xx; ACLU National Prison Project, Abandoned and Abused: Orleans Parish Prisoners in the Wake of Hurricane Katrina (Aug. 2006) available at http://

www.aclu.org/pdfs/prison/oppreport20060809.pdf.

xx;; ibid, p. 10.

xx ;;; I'b'd I , P 52 .

xx;v I'b I'd , P53 .

xxv I'b'd I , P67 .

xxv; ACLU National Prison Project, Abandoned and Abused: Orleans Parish Prisoners in the Wake of Hurricane Katrina (Aug. 2006) available at http ://

www.aclu.org/pdfs/prison/oppreport20060809.pdf. p.12.

xxv;; Bernstein, Dan. "HUB System: Profile ofInmate Population Under Custody on January I, 2008." State of New York Department of Correctional Services. March 2008. Derived from Table 3, p. 8.

xxv;;; New York Times. 20 I O. "Mapping America: Every City, Every Block." Based upon the Census Bureau American Community Survey 2005-9. Downloaded from http://projects.nyti mesocom/census/20 I 0/exp lorer?re f=us XX; x NRC. 2010. NUREG-1437, Supplement 38, December 2010 4-49-4-55.

xxx ibid, derived from Table 4, p. 10 for region of commitment, for reading level Table 7, p. 47, and for high school attainment Table 18, p 51.

xxx ; NRC. 2010. NUREG-1437, Supplement 38, December 2010 4-49-4-55 .

xxx ;; ibid, derived from Table 4, p. 10 for region of commitment, for reading level Table 7, p. 47, and for high school attainment Table 18, p 51.

xxx ;;; ibid, Table IIA p28.

xxx;v Goffman, Erving. 1961. Asylums: essays all the social situation of mental patients and other inmates. N.Y.: Anchor Books; Erving Goffman. 1957. "On the Characteristics of Total Institutions," paper presented April 1957 at the Symposium on Preventive and Social Psychiatry.

Walter Reed Institute, Bethesda, Md.

xxxv Hoffman, Sharona. "Preparing for Disaster: Protecting the Most Vulnerable in Emergencies" case Western Reserve University School of Law. Case working paper 08-27. September 2008 (revised July 2009). 1490-1547.

51

xx~xv"i_:H0ffman,-.ShaF011a~Fl'epaFiHg-f{)r-flisasteE-FF0teeting-the-M0st-¥ulneFable-tll-EmeFgeneiese'-"-----

case Westem Reserve University School of Law. Case working paper 08-27. September 2008 (revised July 2009), p1504, citing Robbins, p. 73,74.

xxxvii xxxvii Robbins, Ira P. "Lessons from Hunicane Katrina: Prison Emergency Preparedness as a Constitutional Imperative." American University Washington College of Law Research paper No. 2008-68. Downloaded from http://ssm.com/abstract= 1300971. Vol. 42; 1,2008,68-9.

xxxviii Westchester County Radiological Emergency Plan for the Indian Point Energy Center, September 2008.IPECOOI99997, Attachment 2 Shelter in Place for Hospitals, p. 29.

xxxix James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, p.5.

xl James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003.1201 F Street NW, Suite 850, Washington, DC 20004, p. 19.

xli USNRC Office of Public Affairs. "Emergency Preparedness at Nuclear Power Plants." Fact Sheet. USNRC, p.2. Retrieved from http://www.nrc.gov/reading-nnldoc-collections/fact-sheets/fs-emerg-plan-prep-nuc-power.pdf xlii USNRC Office of Public Affairs. "Emergency Preparedness at Nuclear Power Plants." Fact Sheet. USNRC, p.2. Retrieved from http://www.nrc.gov/reading-nn/doc-collections/fact-sheets/fs-emerg-plan-prep-nuc-power.pdf xliii USNRC Office of Public Affairs. "Emergency Preparedness at Nuclear Power Plants." Fact Sheet. USNRC, p.2. Retrieved from http://www.nrc.gov/reading-nnldoc-collections/fact-sheets/fs-emerg-plan-prep-nuc-power.pdf xliv Edelstein, Michael R. 2004. Contaminated Communities: Coping with residential Toxic Exposure, Second Edition. Boulder, Co. Westview Press. See also Slovic, Paul, Baruch Fischhoff, and Sarah Lichtenstein. 1982. "Psychological Aspects of Risk Perception." In David Sills, C. P. Wolf, and Vivian Shelanski, eds., Accident at Three Mile Island, pp. 11-42. Boulder:

Westview.

xlv Edelstein, Michael R. and William Makofske. Radon's Deadly Daughters: Science, Environmental Policy and the Politics of Risk, Rowman and Littlefield, 1998.

xlvi Rittel, Horst and Melvin Webber. 1973. "Dilemmas in a General Theory of Planning." Policy Sciences 4,155-169.

xlvii Mid-Hudson News (MHN) "Westchester emergency officials question 10 mile IP emergency area." April 4, 2011.

xlviii James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, p.

57. Note Witt cites NUREG-0654, Rev. I.

xlix Envirorunental Protection Agency. Manual of Protective Action Guides and Protective Actions for Nuclear Incidents. EPA-400-R-92-001.

I James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, pp. 57-58.

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_ _ _ _- "li-James-tee-Witt--Associates,b-b&(~()(}-3}--Review-of--gme~genC¥-EreparednesS-aUndiru anlLLP"'OILL*n"t-_ _ _ _ __

and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, p. 87.

Iii James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003.1201 F Street NW, Suite 850, Washington, DC 20004, p.17. 24, 32.

liii James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, p.87.

liv Westchester County Radiological Emergency Plan for the Indian Point Energy Center, September 2008.IPECOOI99997, p.33 .

Iv Environmental Protection Agency 400-R-92-001, page 4-5 cited in James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, p. 58.

Ivi Westchester County Radiological Emergency Plan for the Indian Point Energy Center, September 2008.IPECOOI99997. Health Department IP 3.0 Attachment 6, Sheltering in Place Guidelines.

Ivii Charles Bates, Westchester County Commissioner of Social Services, letter to County Executive Al DelBello on February 4, 1981.

Iviii For example, Slovic, Paul, Baruch Fischhoff, and Sarah Lichtenstein. 1982. "Psychological Aspects of Risk Perception." In David Sills, C. P. Wolf, and Vivian Shelanski, eds., Accident at Three Mile Island, pp. 11-42. Boulder: Westview.

lix Harris, Gardiner. (2011). "Dangers of Leaving No Resident Behind." New York Tilll es, March 21.

Ix Jeffrey A. Schwatiz and David Webb. 2006. Hurrican es Katrina and Rita and the Louisiana Dept. of Public Safety and Corrections: A Chronicle and Critical Incident Review. NrC Teclmical Assistance RepOli, Technical Assistance No. 06Pl035 (May 10, 2006).

Ixi Jeffrey A. Schwartz and David Webb. 2006. Hurricanes Katrina and Rita and the Louisiana Dept. of Public Safety and Corrections: A Chronicle and Critical In cident Review. NrC Teclmical Assistance Report, Teclmical Assistance No. 06P 1035 (May 10, 2006).

Ixii My wann thanks to Julio Medina and his Spring 2010 masters class from New York Theological Seminary for welcoming me.

Ixiii Westchester County Radiological Emergency Plan for the Indian Point Energy Center, September 2008.IPECOOI99997. Health Department's IP3.0 Attachment 6, Sheltering-in-place Guideline.

Ixi v USNRC Office of Public Affairs. "Emergency Preparedness at Nuclear Power Plants." Fact Sheet. USNRC, p.3. Retrieved from http://www.nrc.gov/reading-rmldoc-collections/fact-sheets/fs-emerg-plan-prep-nuc-power.pdf Ixv Westchester County Radiological Emergency Plan for the Indian Point Energy Center, September 2008.IPECOOI99997. Health Department's IP3.0 Attachment 6, Sheltering-in-place Guideline.

53

Weste-hesteF-Geunty-RaGielegie-3I-EmeFgene-y-Plan-fer-the-lndian-Peint-EneFg-y-Genter,;-,- - - -- -- -

_ __ _ _...::Ix:::.v'---'/i September 2008.IPECOOI99997. Health Department's IP3.0 Attachment 6, Sheltering-in-place Guideline.

Ixv ii James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indi an Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, pp.

214-215.

Ixviii Westchester County Radiological Emergency Plan for the Indian Point Energy Center, September 2008. IPECOOI99997, Attachment 2 Shelter in Place for Hospitals.

Ixi x James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, R* 58 .

xx James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, pp.93-94.

Ixx i Stoffle, Richard, et al. 1991. "Risk Perception Mapping: Using Ethnography to Define the Locally Affected Population for a Low-Level Radioactive Waste Storage Facility in Michigan."

American Anthropologist 93, 3: 611 - 635.

Ixxii James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, p.

68.

Ixx iii James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, p.

68.

Ixx iv Warren et.al. v. Keane et.al. 937 F.Supp. 301 (1996) No. 93 Civ. 6018 (JES). United States District COUli, S.D. New York. September 10, 1996.

Ixxv Warren et.al. v. Keane et.al. (Docket No. 98-2997, United States Court of Appeals, Second Circuit, November 16, 1999).

Ixxvi Galmett News Service._ "Sing Sing fire forces relocation of 700 inmates." Poughkeepsie Journal, April 18, 2011.

Ixxvii Rayman, Graham. "Sing Sing Prison Fire: Inmate Letters Claim Chaos, Panic, Respiratory Problems." Village Voice blog, May 52011 @ 7:30am. Downloaded May 7, 2011 from httJ,l:/Iblogs. villagevoice.com/runninscared/20 11 /05/sing sing priso.php ?print=true.

Ixxvlii Edelstein, Michael. R. Contaminated Communities: Coping with Residential Toxic Exposure (2nd Edition), Westiew Press, 2004.

Ixxix Harris, Gardiner. (2011). "Dangers of Leaving No Resident Behind." New York Tim es, March 21.

Ixxx James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, p.

68.

Ixxxi James Lee Witt Associates, LLC. (2003). "Review of Emergency Preparedness at Indian Point and Millstone." March 7, 2003. 1201 F Street NW, Suite 850, Washington, DC 20004, pp.

259-61,264-69.

54

regularly congested even without a disaster.

Ixxx iii Onishi, Norimitsu and Martin Fackler. (20 II). "In Nuclear Clisis, Crippling Mistrust."

New York Times. June 12. Retrieved July 6,2011 from http://www.nytimes.coml2011 /06113/worldiasialI3japan.html?scp= I &sg=%22In+Nuclear+Crisi s%2C+Crippling+Mistrust. %22&st=nyt.

Ixxx iv Robbins, Ira P. "Lessons from Hunicane Katr:na: Prison Emergency Preparedness as a Constitutional Imperative." American University Washington College of Law Research paper No. 200S-6S. Downloaded from http://ssrn.comlabstract=1300971. Vol. 42;1, 200S, pp. 150-1.

Ixxxv ACLU with page for emergency list in appendix Ixxxvi Hoffman, Sharona. "Preparing for Disaster: Protecting the Most Vulnerable in Emergencies" case Western Reserve University School of Law. Case working paper OS-27.

September 200S (revised July 2009), P. 1544.

Ixxxvii Berger, Joseph. "In Sing Sing's Hometown, Many Dream of Day 'the Big House' Closes."

April 24, 2011 retrieved from http://www.nytimes.coml2011l04/25/nvregion/in-sing-sings-hometown-dreams-o f-inmates-Ieavin g-for- good. html? scp= I &sg=sing%20sing&st=cse 5/10120 II.

Ixxxviii Westchester Health Department, Bureau of Environmental Quality Control. 19SI.

"Comments Regarding The Responsibilities Of The Westchester County Department Of Health Set Forth In The Westchester County Radiological Emergency Response Plan." February 25, p.9.

Ixxxix Bogard, William. 19S9. The Bhopal Tragedy: Language, Logic, and Politics in the Production of a Hazard. Boulder: Westview.

xexexexe ACLU National Prison Project, Abandoned and Abused: Orleans Parish Prisoners in the Wake of Hurricane Katrina (Aug. 2006) available at http://

www.aclu.org/pdfs/prison/oppreport20060S09.pdf.pp 19-21.

xci Westchester County Radiological Emergency Plan for the Indian Point Energy Center, September 200S.IPECOOI99997. Health Department's IP3 .0 Attachment 6, Sheltering-in-place Guideline.

55

This report is based on a review of documents listed in the bibliography, my personal observation and knowledge and my expertise. It is true and correct to a reasonable degree of scientific certainty.

Submitted in final form November 6, 2011 by the author Uiky!/!ijL Michael R. Edelstein, Ph.D.

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