ML20023B421

Proposes Alternative Views to Questions Posed in Sj Chilk to FEMA Re Emergency Planning & Evacuation

ML20023B421
Person / Time
Site:	Indian Point
Issue date:	05/02/1983
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM)
References
ISSUANCES-SP, NUDOCS 8305050035
Download: ML20023B421 (3)

Text

V WEST BRANCH CONSERVATION ASSOCIATION MG BUENA VISTA ROAD q'.j'E*jED NEW CITY N Y 10956 May 2, 1983 Chairman Nunzio J. Palladino Commissioner V.ictor Gilinsky'53_". -4 A0 b4 Commissioner John F.' Ahearne Commissioner Thomas M. Roberts Commissioner James K. Asselstine Re; Dockets 504247-SP U. S. Nuc-lear Regulatory Commission 50-286-SP 4

1717 H Street N.W.

Washington, D.C. 20555 Dear Commissioner ki d " J We refer to Secretari Samuel'J. Chilk's letter to Richard W. Krimm of FEMA of April 26 and write you with great ur-gency to offer alterna.tive views to some of the questions.

j Sheltering has not been studied as we discover from question-ing many witnesses offered in the ASLB case. Houses are being built called " raised ranches" which are on a slab and which have the usual accoutrements of a basement on the ground level.

They avoid dampness but also offer no suitable shelter. We know from the 1970 census what number they are but the 1980 census did not inquire on that subject.

We questioned Mr. Keller and he averred that FEMA had made no study in the Indian Point EPZ of the number of houses with-out basements.

He also stated that sheltering would only be.useful for up to two hours.. Refer to transcript of March 29, among the first cross examination by Z. Fleisher.

Regarding the choice of sheltering v'ersus evacuating, in the same transcript you could find FEMA's view that the choice is up to the person in charge, i.e. the County Executive. He is not trained to know what sheltering offers and what it does not.- Most schools today are extravagant in the use of j

glass and even the hallways do not offer protection.

l The draft plan for Rockland County has no section in it on schools.- Although adopted by New York State there is no saying that there is any plan for schools to follow.

l Regarding'Dommissicher Roberts questions. #3 fails to note the large numbers of campers and hikers that are all year

'round vi-sitors in the Bear Moun-tain and Harriman parks.

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Varying figures have been entered in the'testi=ony de-pending on which park and what time of year. There can be 60,000 to 150,000 visitors in one day. The buses that bring l

them do not stay at the parks.

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Question 7 should be answered by the Rockland personnel who observed both.the 1982 and 1983 exercises and we could easil.,

the' State ambulance spell out the differences. At o'he point coordinator substitute announced he would have 100 ambulances

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in an hour. A hue and cry went up as no one believed him and he was questioned right then and there on the EOC floor.

4 Question 10, chlorine barge accidents.

Licensees witness on meteorology before the ASLB, claimed that low' level emissions would proceed down the river and be dissipated at High Tor and Hook mountains. If a chlorine barge release would not follow that scenario.

then-testimony of Jan Beyea should prevail.

But of course, this is only to comment on the question and does not represent ogr views of the subject.

~ Question 11.

100 people were evacuated from a fire scene,,that

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lived in a nearby trailer camp.

No sirens were used, the' people were offered shelter at nearby fba houses where it was Rockland later reported 20 went to one and 35 to another.

County fire and law enforcement p.ersonnel are very capable of managing an accident without any panic. What you need to know is the large number of volunteers needed for a small incident i

and then ask if an emergency such as an evacuation could ever be managed with existing personnel.

Again we would refer you to the ASLB transcript of interroga-The EPZ in Rockland ting the FEMA witness panel on March 30.

County is a larger geographic percentage of Rockland than the other three counties surrounding Indian Point. The population of Rockland in the EPZ equals abouta$ the total of Rockland whereas that of Westchester is more like 1/9.

The resources outside the EPZ which would be available to assist inside the EPZ ar'e far less in.Rockland than in Westchester in proportion.

We could answer each question but offer the above more obvious f

and simple replies.

We would be happy to have the opportunity to address the Commission on May 4th to fill in the gaps that persons who do not regularly live on the scene cannot know.

Sincerely yours, Mb Z.pporah S. Fleisher Secretary 914/634-2327

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Church Ibaders join bid *N to shut dowd Indian Pt.g *@9.b.O r..

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l Moore s ke at the' White Platris Librar before By GEOFF WALDEN a panel of ur members of Clergy, Relig[ous and I i

Stoll Writer I. alt Concerned about Indian Point, a group.of l Church and government leaders called for a. shutdown of I'ndian Point during, Tuesday

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' al ernat ve" h ring to rabe he moral

' counter ades" of nuclear' plants.

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hearings" to the Nuclear llegulatory Commission,s federal hearings on the safety of the nuclear power

• mlan also was among nearly 20 people who; spoke,l h Rockland Legislature Chairman IIerbert Rets-ko%f plant.

a6d he 'retterated the Legislature's two-year-old;

" Indian Point is d terr on,'said he Right Rev. call for an Indian Point shutdown.

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Paul Moore, bishop of 'the Episcopal Diocese of.

l-p New York,."and it's high time.wg tra,ded it in."

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i April 26, 1983 Richard W. Krimm Assistant Associate Director Office o' Natural and Technological-Hazards Federal ~'mergency Management Agency E

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Dear Mr. Krimm:

AspromisedintheApril20Commissionmeeting[weforward the following questions.

The first set relates to the Westchester County bu't driver problem and its effect on your assessment of preparedness at Indian Point; the second set relates to the implementation of the stat,e plan in Rockland County.

A.

Westchester County Under Planning Standard J as described in NUREG-V654/ FEMA-REP-1, Rev.

1, NRC and FEMA are to predict.whether a range of protective actions, reasonably could be impremented in the plume exposure pathway EPZ for emergency -worker.s and for the public.

In making its overall assessment of compliance with the planning standard (10 CFR 50.54 (q), see l'O. CFR

50. 47 (b) (10 ) ), the NRC must assess the significance of the bus driver situation as described by FEMA for Westchester County.

In doing so it would be useful to have supplemental information from FEMA concerning the above premise and the following matte,rs of fact:

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1.

Do you know how many people and what segment (or 4 -

segments) of the population (by age) would be dependent on buses in an emergency?

Is there any information available on this question?

2.

For purposes of your evaluation, how many people and what segment (s) of the population did you assume would be dependent on bus transportation in an emergency?

Do the number of people and the population segment (s) so depe'ndent in sny way affect your assessment as to whether this deficiency is significant in terms of 4

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preparedness?

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2 3.'

Does the plan to send children home t the. alert stage lessen the number of bus drivers needed in-an eme'rgency?

Did you consider this..factdr when you concluded that the failure to obtain a commitment from bus drivers in'Westchester County was a significant deficiengy?

4.

In making its conclusions about the. bus driver defi-ciency and its effect on compliance with Planning Sta6dard J, what percentage of bus drivers did FEMA 4

assume would.actually respond in an emergency?

Is thi's assumption based on actual responses in other emergencies?

5.,

At the April 20, 19 8 3 ' Commission briefing, ' Mr. Petrone of FEMA stated teat FEMA required letters of agreement with bus drivers who would respond during -an emergency.

a.

How many state and local plans have received FEMA approval to date?

s b.

Do all of the FEMA-approved plans have d.uch agreements with bus drivers?

If not, how many do?

Are they part of the state or local Epproved plans' 6.

Do you agree with the conclusion in NURE6CO396 that sheltering will b'e preferable to e'vacuation in all but the worst and rarest events?

Is it-yodr p'remise that preparedness is inadequate unless. evacuation is possible in all scenarios?

When you determined that' preparedness was inadequate, did you consider whether the bus driver deficiency should be viewed in light of the preferability of sheltering to evacuation in most

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scenarios?,

B.

Rockland County

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1.

In assessing the degree to which New York State involvement for Rockland County's n6n-participation should be weighed, the NRC'is understandably concerned about the interaction between Parts I.E and I.F. of NUREG-0654/ FEMA-REP-1, Rev.

1. Part I.E.

explains that local plans should include mutually supportive emergency planning and preparedness arrangements by several levels of government; Part I.F states that "although the guidance indicates the criteria are applicable to-6ne or more specific organisations, the e

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intention throughout has been to provide for an adequate state of emergency preparedness around the fadility."

Part I.F.

also explains that "if weaknesses in one organization are identified, but compensated for in another organization, the reviewers can_still find that an gdequate state of emergency. preparedness exists."

The rulemaking record is replete with references to the substitution of resources of one level or agency of government.for another.as part of

" alt'ernative compensating measures. " - To assist it in '

4 determining the ade.quacy of such measures under 10 CFR 50.54 (s), the NRC would appreciate FEMA's supplemental views on (a) the above statements, (b) whether aside from the failure of Rockland County personnel to participate in the exercise, there were significant deficiencies in implementing emergency measures by state personnel- (please be specific), and _(c) an indication of FEMA's views on Rockland's commitment to respond if there were an actual emergency and on Rockland's capability to respond adequately, assuming state supervision.

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2.

Section 2.5.7 of the r.eport states that due to the absence of detailed evacuation plans and procedures for Rockland County, the capability to implement actions to protect the public could not be measured,against a plan.

Why was the Rockland County Draft-Evacuation

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Plan, which w'as i'plemented by New York State (NYS),

m not evaluated for this planning standard?"

3.

At the April 20, 1983 Commission Neeting,'Mr. Petrone stated that if New York State intended to.take over all response in Rockland County, the NYS Compensatory Plan needed to be changed to reflect this and it would be i

necessary for the State to have the state employees who would impl'ement these beasures in Rockland County

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stationed there.'

l a.

Do any of the state employees who responded to the i

Rockland County EOC during the March 1983 exercise live or work in Rockland County?

If so, what is l

the proportion or number of those who. responded i

who do live or work there?

b.

Is it a FEMA requirement that county responders

'(in any county) live in that particular county or within a certain distance or travel time of their response location?

If so, what are your distance i

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or' time limits?

Are they appli d to all plans and locales uniformly?

c.

Was it your intent to indicate that NYS response to Rockland County in ninety minutes c less was a def4ciency?

If so, then was it a.sigqificant deficiency?

Is the same,true for Putnam County.?

3.

In the Indian Point Post Exercise Assessment Report, Roc % land and Westchester Counties are cited as signifi-4 cantly deficient regarding the public understanding as'

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to'their response to sirens or tone alerts.

Orange County was not, despite the conclusion that most people there did not understand the meaning of the sirens.

Report at.47-48, Was this deficiency in Westchester and Rockland pri6arily based on the failure to distribute brochures?

What criteria were -used?

In addition to the above questions, Commissioner Ahearne requested that we pass along to you the f,ollowing questions:

1.

Has FEMA reached the judgment that the bus d5ivers in Westchester County will not respond abseqt contractual i

commitments?

2.

Wh'atarethecontractualobligationsFENk_wouldwantin order to conclude that availability of bct drivers

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would not be 'a significant deficiency for,Westchester County?

a 3.

Such contracts would be between what part es?

4.

What is the-status of nego,tiating such contracts?

Thank you for your assistance in answering our_ questions.

We have also at'tached,Commi'ssione'r Roberts' questions.

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1.

On April 15, the regional director o.f FEMA, Frank T. Petrone, issued a press release in connection with the post-exercise assess-ment of th,e Indian Point Mar.ch _9 drill.

The. press ~. release stated:

According to Petrone, significant progress. bas been made'since the March 3, 1982 exercise.

"However, at,this time, I cannot

- assure that public health and safety cen be protected in the ten mile emergency planning zone around Indian Point," Petrone stated.

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In connection with any nuclear plant or emergency drill, has FEMA

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ever given. an assurance that the public health and safety' can be

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protected?

If so, cite the specific facility or drill assessment in which FEMA publicly stated its assurance that.publii: health and safety can be protected.

Why was it necessary for the regional director to issue a press release with that specific statement?

2.

Why is the June 1 date critical for distributin(the " brochures?

Are posters to notify transients reouired by Eny existing regulations?

3.

FEMA states tha't the deficiencies in 'Rockknd and Westchester

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County plans to notify transients such as_-those in motel rooms using methods such as posters, etc., leads to the conclusion that the Protective Response Planning Standard is not met.

As a practi-cal matter, aren't most of those persons within range of the sirens, radio or TV EBS messages?

Don't you think that motel operators will notify transients in their facili_ ties?

4.

On p. '35, in your conclusion you state that-your orocosed reculations "necessarily implies mutually support-ive emergency i

planning arrangements by several levels of government." That is a concept I do not disagree with; however, does this mean that each.

level of government must have its own plans which.confoms to the.

" guidance of NUREG-0654"? Or does this mean that somehow the level of offsite emergency preparedness must meet ~ the planning standards in the regulations and that " mutually supportive emergency plans" is th.e best way to get there?

5.

On p. 35 and elsewhere in your April 14 report, you. are critical of Nek York State for not requiring Rockland County' personnel to

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participate in the drill.

You find the State to be deficient in their compensating measures because their-written procedures were not followed to the letter.

Nowhere, however, do you comment on the substantive issue--that is, did the State personnel partici-pating in the drill demonstrate that they were capable of sub-stituting for the County personnel?

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To what extent is your deficient finding fo'r Now York State--

Rockland County -due to shortcomings in actual pefformance, and to

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whac extent is it due to the fact that procedures were not liter-ally followed?

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7.

In Section 2.5 you state, with regard to Rockland ' County,:

(a)

Energency operations facilities and resource _s. were acceptable (b).. Alerting and notifications of itaffs were "ac'ceptable (c)

Emergency operations management was good' (d)

Public alerting and notification were good (e)

Public and media relations need improvement but were not inadequate

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(f). Accident assessment was good (g)

Health, medical, and exposure measures were acce,ptable

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(h)

Recovery and reentry measures were good You then go on to say that in spite of the above acceptable fac-tors, actions to protect the public could not bejudged adequately because the State filled in for the county and eerried out some actions without"a plan and because bus drisers do not have radios.

It appears to me that you have documentedjow a State can indeed fill in fo'r a county.

• 8.

Are there any important safety functions which you feel could not be adequately performed around Indian Point based on your knowledge of the offsite preparedness there?

l 9.

Wouldn't yo0 say that it fs FEMA's collective experience that everyday emergency response capabilities, such as fire, policy, state and local disaster resources, has been.demcastrated rather well.at a large number of natural and man-made disasters, often with plans far less sophisticated and developed as those in New York?

10.

Is. it possible that adequate preparedness can exist without de-tailed plans?

For example, is there adequate preparedness in the area to protect the public from chlorine barge accidents?

11. ~ Are you aware tha.t Rockland County personnel partic.ipated in an actual evacuation -involving over 100 people earlier this month in a chemical factor accident and, thus, demonst~ rated a capability to publicly and adequately react in an emergency?

12.

What is the status of FEMA's regulations 44 CFR 350?

Are they final regulations ye.t?

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13.

In a real emergency, Rockland County says t' hat its resources would be available to the state.

Given this, how do yo6 justify criti-cizing the State's implementation of com6ensating~~ measures during the exercise based upon ungvailability of County resources?

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