ML20023A787

Advises That Serious Deficiencies in Emergency Preparedness Will Not Be Corrected Since State of Ny & FEMA Not Addressing Concerns of Local Officials by Involvement in Current Changes

ML20023A787
Person / Time
Site:	Indian Point
Issue date:	10/15/1982
From:	Fleisher Z, Holt J, Kessler J, Posner P, Scheiner C PARENTS CONCERNED ABOUT INDIAN POINT, PUBLIC INTEREST RESEARCH GROUP, NEW YORK, ROCKLAND CITIZENS FOR SAFE ENERGY, WEST BRANCH CONSERVATION ASSOCIATION, WESTCHESTER PEOPLES ACTION COALITION, INC.
To:	Ahearne J, Asselstine J, Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM)
References
NUDOCS 8210200019
Download: ML20023A787 (5)

Text

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l mew yonk pubhc ImREST RESEARCh Q ROUp,1NC.  !

NYPIRG 9 RAurrey St. e New York, N.Y.10007 (212) 349 4460 o,e s,%, % em e e= Lee ie==. se== Peas 'a= voa car. Mme== smw 00LKETED USNRC October 15, 1982

'82 OCT 18 A9:17 Chairman Nunzio Palladino Camtissioner John F. Ahearne Comnissioner Victor Gilinsky [-[y,. .- - hf ~

. 7$,73 Comitissioner 'Itanas M. Ibberts BRANCH Camtissioner James K. Asselstine United States Nuclear Fegulatory Omnission 1717 H Street Washington, D.C. 20555 Qh re: Camtission Meeting, October 21, 1982 Discussion of Staff Action on Dnergency Planning at Indian Point

Dear Camtissioners:

We have noted with interest the concern expressed by the Camtission about the involvement of local officials in the Indian Point Radiological Emergency Pesponse Plan revisions.

For example, on page 21 of the transcript of the Septerber 9 meetire of the Ccrmission, Camtissioner Ahearne asks, "Could you say a few words about the relationship between the state and the local goverments in the resolution of this? My inpression fran reading your report...is that many of the problems are at the county level, that is it (sic) county plans or country (sic) arrangements or county funding that has to be obtained."

We are writing to call your attention to the fact that serious deficiencies in energency preparedness will not be corrected precisely because New York State and FD4A are not directly addressing the concerns of local officials by involving them in current changes.

Village, town, ard county officials have said in the strorgest terms that the present plans cannot be implemented, and that no plans can be i implemented without a massive infusion of funds.  :

l Indeed, they have pointed out that sa:e problems on the local l level, such as the road systen and the refusal of emergency workers (and the l public) to co-operate, cannot be overcane with any amount of noney.

1 8210200 o,y g g The New York Pubhc interest Reneerch Group, Inc. (NYPIRG) is a not-for proht, nonpartean research and advocacy organi aan est .

directed and supported by New York State cohege end urwersey students. NYPIRG's staff of lawyers researchers scientists and orgeruzers works wrth students and otter cshzens, doweioping cs'izenship siuns and sheprig pubhc policy. Consumer protecton, begher education, energy, fiscal responsbhty, pohtical reform and coasi jushce are NYPIRG's principal stees of concem 1

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.x s letter to the Ccanissioners

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October 15, 1982 -

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Sonny Hall, Vice-President of Transport Workers Union Iccal 100, has said in pre-filed testinony that "'Ihis Union will not allow any member of our Union to be involved unless each and every detail has been discussed with

. us and then, of course, with our nunbers."

on May 25, 1982, New tork State United Teachers, Educational District #15, re-aumled that a resolution be adopted by locals to " notify government authorities charged with approval of this plan that it is con-sidered unrealistic, unworkable, and unacceptable to the membership of Westchester-Putnam NYSUr locals."

Frank C. Bohlander, Westchester County Ctmnissioner of Public Works, said in his pre-filed testinony, " Personnel participating frcm the Division of Road Maintenance have never been given adequate training by the consultant. 'Iheir response in an actual event remains questionable."

Sheriff Daniel P. Guido, Ctmmissioner of the Westchester County Department of Public Safety, included the following comnent in his pre-filed testinony: " ..there still may be scre question as to the reaction of emer-gency workers when faced with a choice of attending to the imnediate needs of their own families, who may live in an affected area, or fulfilling their assigned responsibilities under this plan..."

Ed Connelly, and Dtergency Medical Technician with the Ossining Volunteer Ambulance Corps, has subnitted pre-filed testinony in which he states, "I resent the inplication that I will give up all personal considera-tions to assist in an evacuation attempt."

At the very least we would expect close co-cperation between FDW, New York State, and local officials. Instead we find that bi-weekly meetings have been held between the State, licensees, FH4A, and NRC staff without local officials. Only one Task Force on revisions includes one county representative. It has oeen stated that "it would be a waste of their time" for local officials to attend the bi-weekly meetings.

s Tne attitude towards those who bear the burden of inplcrnenting these plans seems to be, " don't call us, we'll call you. Never mind telling us what you can do or need to do; we'll tell you what you must do." For exanple, when Rockland County officials detail a need for 12 nonitoring teams to track the amount and direction of a radiation release, the State Radiolog-ical D: urgency Planning Group refuses to consider nore than three.

Furthernere, the State insists that nonitoring equipnent pro-vided and maintained by the licensees is acceptable, while the counties, especially Rockland, have expressed a ccupletely justified reluctance to depend on equignent over which they have no control. In any cstergency re-sponse, of course, radiation monitoring is of the essence. All other actions flow frcm that.'information.

NRC and FH4A representatives have been disturbingly conplacent in their bi-weekly meetings with State and licensee officials. 7here is no evidence of probing questions about details of preparedness, especially re-garding ntrnbers and percentages. A correct evaluation of the plans must include w

Ietter to the Camissioners Oc Mbpr 15, 1982 Page 3 answers to the following basic questions: How many people and pieces of equip-ment are needed, how many are ready or on hand, what percentage does this rep-resent, and what percentage will be deemed " adequate?"

FDR is satisfied to accept false reassurances frm State representatives that the State can aM will take "capensatory measures" to correct local deficiencies. For exanple, all problems which flow frm RocklaM County's refusal to participate in the current planning effort will be solved, according to the revisers, by inserting a sentence at 16 places in the text of the plans, to the effect that "Where a county does not have a plan or is unable or unwilling to inpleent a plan, the Governor of New York will declare a state of emergency, field a State management team, and direct the use of State and local resources.

'Ihis is a prime exanple of the laughable but tragic disparity

'between planning and preparedness. What resources will the Governor direct?

'Ihe fact is that New York State does not have enough money, equirment, or trained personnel either. New York State is in a worse position than counties to cope with unfamiliar local roads. New abrk State will be dependent on the same ccmuunications systens that are inadequate for a county response. Notes of a meeting in Mt. Kisco, New York on Toril 19, 1982, include the following: "'Ibe telephone capany stated that any public order to evacuate or to prepare for evacuation would probably result in a traffic overload in central offices within the emergensy m planning zone."

Most inportant, according to a conclusion of iaw reached by the State of New York Department of Public Service in a Memorandtm dated July 9,1982, "The State cannot require a locality to participate in training, exercises, or other activities necessary to the developrent of a plan," but "In the event of a radiological erergency the State has the authority to require a locality to take specific actions."

After a radiological energency has begun will be far too late to reach an adequate level'of preparedness. Supplies, equipnent, trained workers, arxl back-up cmmunications systems must be in place, ready to roll at a narent's notice, if the 17 million people within 50 miles of Indian Point are to have any protection against a significant release of radiation.

New York State officials frm the Padiological Dnergency Planning Group are definitely nervous about what the Cmnission plans to do at the end of the 120 day clock. There is great hope, based on discussion with NRC staff, that all that will be required is an " update" or a " progress report." But treating the emergency plan as a " dynamic process" allows government officials to avoid their ultimate responsibility in protecting the health and safety of people affected by Indian Point. A " moving target" is created, and the intervenors and Interested States are prevented frm focusing on a " freeze frame" picture of the " status'and degree of conformity" of emergency planning efforts as required by Cmmission questions 3 and 4 in the order of January 8,1981. ,

A plan which is deemed " adequate" on paper may not stand up in actual practice. The frontline emergency workers have never been involved in the planning process. The average fire fighter, police officer, ambulance

Iatter to the Ctmmissioners October 15, 1982 Page 4 technician, bus driver, tow truck operator, teacher and parent has no more idea now that he or she had three months or three years ago of how to help the public escape fr m the consequences of nuclear emergency.

Whatever the plans say, a true picture regarding the following facts will not be revealed by referring to them:

• Off-site emergency workers have not been adequately trained.

• Reception centers are not adequately prepared for their role in an evacuation.

• Bus drivers have not negotiated a contract which includes the heroic task they are called upon to perform.

• The required number of buses cannot be timely mo-bilized to evacuate school children and the trans- i portation dependent population. 1

• 'Ihe road networks are not adequate to handle the bus, auto, and emergency vehicle traffic which will result frm an accident at Indian Point.

• Tow truck operators have not been identified for agree-ments to station themselves at pre-designated locations along evacuation routes.

• All the frail elderly, handicapped, and special needs populations have not been identified and provided for.

• The sizeable transient population cannot be adequately notified and provided for.

• Many parents, teachers, and emergency workers will not co-operate with the roles assigned them in the plans.

• Equipnent which will be needed by cmergency workers has not been provided and stored in easily accessible pre-designated locations.

• Even though the problem has long been identified and is easy to solve, an adequate number of proper dosimeters has not been distributed.

• There are not enough zeolite filters for the monitoring teams.

• The plans are based on outdated population figures.

• Money to finance radiological emergency preparednes has long been prmiced but has not been authorized or pro-2 vided by the State or by local governments.

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i Ietter to the Ccmnissioners Oc e r 15, 1982 Page 5 Intervenor and Interested State witnesses have pointed out these and many other major concerns which the FDa review process has translated into " minor" deficiencies. As far as the public is concerned, these defects are para mant. 'Ihe true standard of an adequate emergency plan should be co-operation and ccmnittment frtrn the affected populace.

'Ihe revision process is no rnore than an editorial job: words and phrases are added and deleted in a bulky document, and FE2M acts as senior editor, signing off on a final, " acceptable" version. Ibne of this has any relation to actual preparedness in the real world of snowsturms, flat tires, and hunun error. Confidence in official governnent infonration and orders will be further destroyed if practical details are igrcred planning process.

Ve truly yours, cc: Official Service List wU

'Ihe Hon. John T. Grant Holt'

'Ihe Hon. Sam Gdanski roject Director The Hon. Hugh Carey Jew York Public Interest House Sub-Ctmnittee on Posearch Group, Inc.

Energy, Conservation and Power j Mr. Ibger Kowieski 41 Mr. Ice Thcras Mr. Brian Grimes Pat Posner Mr. Frank Petrone Spokesperson Parents Concerned About Indian Point

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, hb, odh Z. S. Fleisher Secretary West Branch Conservation Association i

ef Q Judith Kessler Coordinator Rockland Citizens for Eafe Energy

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f N A Charles A. Scheiner Co-chairperson WESPAC