ML20023D559

Requests Time to Speak on 830526.State of Ny Claims Unsubstantiated.Nrc Should Adopt Policy of Communicating W/Public

ML20023D559
Person / Time
Site:	Indian Point
Issue date:	05/16/1983
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM)
References
ISSUANCES-SP, NUDOCS 8305200605
Download: ML20023D559 (12)

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WEST BRANCH CONSERVATION ASSOCIATION -

43 BUENA VISTA ROAD NEW CITY N Y 10956 Masl36Ph 9s3 F2 20 Commissioner Nunzio Palladine, Chairman Commissioner Victor Gilinsky Commissioner John F. Ahearne Commissioner Thomas M. Roberts Commissioner James K. Asselstine

Dear Commissioner:

We submit the attached paper for the May 20 date and hope you would allow some of us a few minutes on May 26.

I am a member of the Rockland County Citizens Advisory Committee For A New Evacuation Plan and also participated in the ASLB hearings with as good an attendance record as any.

We did not participate in those hearings without a great deal of personal devotion and organization funds. It is a serious commitment.

We are troubled that you will not have any adversarial testimony before you. The New York State people are making claims and promises that we believe to be bloated. We were unable to bring to the hearings two important witnesses because they have State jobs. One is the administrator of ,

Letchworth Village and the other is the administrator of Helen Hayes Hospital. These two institutions do not have the

preparation claimed for them and you should have an oppor-

'tunity to be told how many witnesses were unable to, or un-willing to travel,to White Plains from Rockland County and where the holes remain in the record.

We would hope that by now the NRC would adopt a policy of communicating with the public.

Sincerely yours, Z S. Fleisher Secretary 8305200605 830516 PDR ADOCK 05000247 0 PDR g

NRC PUTS LICENSEE'S RESPONSIBILITY ONTO THE LOCAL PEOPLE The licensees! Emergency Response Plan was rejected by the personnel in Rockland County who were responsible for its implementation. The NRC is now saying that Rockland must come up with a plan before Rockland is ready, by June 9.

It took the licensees years to develop a poor plan.

Now, instead of shutting down the plants for the safety of the people, #3 having been down for 14 months, the NRC is pressing Rockla,nd to be ready by June 9 It is the licensees who have not provided equipment and training and who substan-tiallydidnothjnguntilthegunwasplacedattheirheads.

Rockland's Citizens Advisory Committee has been meet-ing regularly. The departments that would be involved in any plan have surveyed their needs. We can't make a plan over-night, nor will we offer one that isn't implementable, like that offered to us in 1981. The pressure being put on Rock-

~: 'kandwithoffersofNationalGuardorWestPointcadetassis-tance are bending the evacuation regulations of the NRC.

• Now that the regulations can't be met in May, 1983, we are hearing that as long as there is planning it shows good intentions and that is reason to permit the plants to be open (or rather one to reopen.) There is an old addage about

the roa'd to Hell being paved with good intentions and the very point is that right now there is no plan.

Two 120 day periods have come and gone while the NRC

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is doing nothing to protect the safety of the people surrounding Indian Point. The NRC is derelict.

In referring to risk analysis the licensees are sending up a smoke screen. The regulations of the NRC under 10 CFR 50:47 state that there shall be an-implementable evacuation plan. There isn't one by the NRC's own standards and in an area where today no such station would be built due to the density of the surrounding population.

By comparison Rockland has more of its population within the 10 mile EPZ than the other three counties. It is 2/5ths of the total in Rockland whereas no other has more -

than 1/7th. [

ROCKLAND COUNTY IS UNIQUE The EPZ in Rockland County is geographically about one half the County. Some boundaries of Rockland are no more than 15 miles from Indian Point whereas Westchester's

' extends to 25 miles and Orange to 45 miles. Rockland has

.i .f fewer resources Uoutside its EPZ in proportion to the need for as,sitance than any of the other counties, and perhaps than of any county in the United States. The resources in Westchester outside the EPZ are far larger in proportion and are far better supplied with County owned trasportation, emergency personnel and equipment.

By choice Rockland County does not have a County Executive. The head of the government is the Chairman of the County fegislature, with most power vested in the full

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body, not in the Chairman. He, and the legislators are all part-time officials. Changes to provide a County Executive have been voted down by the citizens some nine times. A county-vide police force has been rejected by the voters. There is no county department of public works. There are very few buses owned by the county. Neither the County nor the local hospitals own ambulances. By comparison with Westchester it can be said Rockland has far less resources to provide trans-portation and road maintenance to an endangered EPZ in a time of crisis.

All the firemen in Rockland are volunteers and are not available during their working hours if they work outside the county. Rockland has a large group of New York City fire-men and polico living in it. The same is true of the ambulance corps with the exception of a few commercial ambulance vehicles.

Above are some of the reasons why Rockland has more

} fifficulty preparing an implementable evacuation plan. Addi-tionally, Rockla,nd's geography makes it almost the same as an island, with the Hudson on the east and mountains surrounding it on the other compass points.

SCHOOL GO-HOME-EARLY PLAN IS AN EVASION OF RESPONSIBILITY There is no saying there will be timo to notify pa-rents or their surrogates in the event of a nuclear accident.

There's no saying there will be enough telephone lines on which .

to notify parents as many schools have only two or three out-side lines.

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Supposedly responsible officials such as Mr. Donald Davido'ff the the New York State Radiological Emergency Response Group have compared snow day cancellations of school to one of a radiological emergency. The scale is not the same as a broken boiler or a snow storm, nor is the need as pressing for quick action.

The New York State compensating plan for Rockland County had zero plan for school children, at the time of the March 9 drill. In fact, a school in Rockland that had been closed for two years was reported to have been evacuated by noon ! The State's plan is a patchwork of nothing. It is playing roulette with peoples' lives.

The Go-Rome-Early suggestion is an evasion of respon-sibility; a subterfuge in order to get around a problem that so far has no good solution.

THERE ARE NO SATISFACTORY PLANS TO MOVE THE DISABLED

, Rockland County has a large population of institu-

'kionalized persons needing special care. As an example, the Helen Hayes Hospital For Rehabilitation, which has a fine record *for helping the handicapped to become useful, has no more plans than that of a regular fire drill. There are no shelters sufficient to care for the number of stretcher and wheelchair patients.

. "Lthe c worth Village with some 1,300 patients would have to depend on buses coming from afar and has no base-ment shelters dry enough, or ventilated enough to use.

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8 SECTION 504 IS VIOLATED BY THE LICENSEES' PLAN Equal protection is not available to the handicapped in Helen Hayes Hospital, Letchworth Village, Camp Jawonio and several schools within Rockland's EPZ. The plan offered in 1981 practised triage by failing to care for the handicapped.

Rockland's Health Complex houses many invalids who need special care. There.are nursing homes with no facilities to unload all their patients at once.

SHELTERING IS NOT A FEASIBLE CHOICE The lic,ensees (Coned and PASNY) answered an NRC Staff interrogatory in the ASLB hearings just held stating "The shelteringshie}dingfactorsarebasedupontheassumptionthat persons with access to basements (90 percent of the popula-tion) would take shelter in them." Laws have been passed by Towns in Rockland requiring homes to be built 3 feet above the water table resulting in " raised ranches" which are built on slabs and which have no basements. No surveys were made

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[ "byeitherNewYorkState, the licensees or FEMA to show that r,

there were basements in Rockland County for sheltering. Yet the alternative to evacuation by sheltering is offered.

Many of the schools are new and built with glass walls including the corridors. They offer no shelters.

FALSE COMPARISONS OF ROCKLAND PERSONNEL

"' In the questions attached to Mr. Chilk's letter to Richard Krimm of FEMA of April 26 several comparisons are -

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are made to events that are not comparable.

The recent fire in Mt. Ivy during the evening in no way compares to a nuclear emergency. Only 100 persons in a downwind trailer park were told to move. They caused no traffic congestion going a mere two miles to two local fire houses for a few hours. No sirens were used, no congestion on the phone lines. The night time hour assured that many volunteers were available and that most families were together that moved. An event involving 1/1,000th of the possible EPZ population hardly compares and should not be offered. It reduces the credibility of the NR0 because the local citiz(ns understand how different it is from a large more threatening emergency.

A chlorine barge that someway was damaged as it moved on the Hudson River would be swapped by all of us for a radiological emergency, gladly.

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NRC AND FEMA ATTEMPT TO PUT THE BURDEN ON ROCKLAND CITIZENS 1 [

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The tone of the FEMA and NRC communications tend to place some blame on the Rockland citizens involved in making a new plan. There are no shortcomings in the Rockland people.

The volunteers may be equalled but not surpassed. The people of Rockland gladly place their safety in the hands of the ,

firemen, police and ambulance corps of Rockland County.

Any shortcomings are due to the. lack of a useful plan concoted by the licensees who are the ones that

wasted years dragging their feet and offered a poor quality plan. It is not stubborn anti-nukes, as Commissioner Dyson suggested, that have held back development of a plan. It is the attempt of the licensees and the rest of the " establish-ment" such as FEMA and the NRC that have tried to force on Rockland County an unworkable plan threatening the safety of all citizens. The persons who would have to effect the useless plan objected to it. The NRC errs and loses credibility by implying that Rockland personnel are anything but the best. ,

The Chiefs of Police in Rockland County's EPZ have testified that they have insufficient personnel to attend the intersections ndeding traffic control. If they even have barriers, there are no trucks to cart them to intersections in a mass effort.

It is not Rockland who offered a brochure which failed

. to invite sufficient response from the impaired by the paltry

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~7 number of cards returned. It is.not Rockland personnel who failed to post public notices, who didn't account for the possibility of thousands of persons in the parks with no remaining buses to move them out.

The failures of the licensees' plan are too numer-ous to list here.

FEMA'FKTLED TO IDENTI?Y DEFICIENCIES REVEALED TO THEM Repeatedly Rockland has pointed to deficiencies which '

FEMA has omitted. The most important deficiency is the-road 7-e

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networ,k. The location and small number of tow trucks to be ready to remove road blocks, the failure of the brochure to effect its purpose in several ways; the lack of shelters, the lack of training, the turn-over problem in preparing elected officials for emergency response, and many more.

The combined establishment personnel turned out a new brochure, and FEMA has not objected, which, on page 20, sug-gested that the licensees' nuclear station saved the use of 20 million barrels of oil when in truth last year, with IP #3 down fourteen months, only 10 million could have been saved, if indeed, that figure is correct. Sined the brochure f

is supposed to 6e printed annually, one would expect the s

" Facts about Indian Point" to be just that. What it is in-stead is advertising for the licensees and is no part of an evacuation brochure which FEMA should'so note.

A glaring deficiency is in communications. The tele-

7 . phone system is not capable.of handling the pressure that

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would be applied.. Other radio contact in many levels is completely missing. Radio contact in Rockland is primitive and would hinder an evacuation during a nuclear emergency.

THE NRC IS NOT ENFORCING ITS OWN RULES AND REGULATIONS The most glaring fault, far exceeding the lack on the part of any other entity, is that of the NRC's failure

' t'o come to grips with the present issue. Equating the density of the population with superesafety supposedly existing at Indian Point is the most incredible fantasy l

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of many being passed around.

There is no plan in Rockland right now. There have been several delays offered and they have not produced a plan of this'date. The rules and regulations intent is to protect the safety of the people in the 10 mile EPZ. The deviations and legal obfuscations are maneuvers to avoid taking the bull by the horns which is what the NRC appears to fail to do.

The fact that Rockland County is investigating the feasibility of making an evacuation plan does not mean it has one. All the S_ tate's compensatory plans do not fulfill NUREG 0654 nor 10 CFR 50:47 and Appendix E. Rockland might go en trying to make g plan for months or years. What is there about the present thaU allows the rules and regs to be bent?

Indian Point #3 has been down for fourteen months and no dire effects have been felt that anyone has heard. Coned has ample capacity to permit #2 to be up and ,down during this

, time without brown-outs or calls for less consumption. The a

~7 economic consequences may be debatable but surely we cre not expecting the NRC to protect some investors as against the lives df 280,000 persons living within 10 miles of the station.

It is the fault of the licensees that a no good plan was pro-vided at great cost to their rate payers. They should bear the onus, not the people of Rockland.

~'It is TMI, Salem 1 and unresolved A-17 issues that suggest a more responsible response on the part of the NRC.

The people of Rockland will be' happy when such signs appear.

Dialogue with responsible citizens on the CAC and interve-nors in.the ASLB case and the NRC Commissioners is needed.

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o facility - which recently got the go-g ahead from the NRC to restart its .

number one reactor after two circult- N 79 . g gs; g

breaker malfunctions in late February forced the unit to be shut down.

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emergency personnel took part in the on .ue l

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a daylong drill which was designed to *y"

' test a disaster response plan kno vn as e '

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C UNDER THE WATCHFUL gue of several observers from FEMA, various Among the major problems cited in

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e inadequate placement of radiation i

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rie of d on tr t o s n a field monitoring equipment.

i - .,- s - - County and neighboring Cumberland e Inadequate training of Salem l . Y..ymmeI# County. . County emergency personnel in the.

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use of dossimeters to determine con-of'"significant deficiencies" in the uu'

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including lack of ade- rn ove the size and opera-quate personnel, under tramed per- tion of the Salem County Emergency onnel, and a general sense of hianagement Office.

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4 "There are still some problems at tion of Congregate Care Centers- the Z this point" said Roger Garelik, com- first stop in the event of a full h 5

[ munity planner tor FEMNs region Il (Continued on Page A8, Col.1)

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Salein's nuclear emergency plan failec . during which "significant deficien-5 % From A1 l

.acuation, t the e tion logistics in the f d -

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contamination center. the lodian Point pirnt, whileithe y  %

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Cumberland County and in the city v --- - .different types of animals," said.' "kIN"i#-

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r-istrated," Garelik said. "It caused us . When FEMA completes its analysis me problems." .; -

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• submitted to the NRC, which will IIE SAID THAT the intent of the evaluate it and the drill report.

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port is to get. state and county .. .. > t. :.. . . . ~

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tuorities t3 take corrective actions. .. ."BOTH HAVE TO be acceptable" . . 4. . .i .4 ef

)w will they do that will be judged Garelik said. "It's up to the NRC as to

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Some stat 2 officials, however, have State'e" merge'nc' y " officials, wh15e s. C un issua with some of the criticistps. . somewhat critical of the FEMA report) nled by FEMA in the report. L. pre confident.that they can make the E '

4' 4'*/ 'S yM 'n#v hhn Tatum. acting chief .of the proper adjustments in time for this 'il "Y' 'DE'%. ' ..'i V WW '

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nratiInal Planning Bureau of the year's test. , .

tw Jus 2y Office of Emergency s Si- - "

anagem;nt, called the state's emer- ' "'lliere's no question that every drill ,~ t .-

, , .--e ncy plan for nuclear accidents "one ~ is to make operations better," said Jon 4 Mdh, W ~E g. 'tfrH tha most detailed types of protec. Christiansen, pfincipal planner in the n plans I've ever seen."

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'The state has demonstrated that it "Some things Seed improvement at - - *'

• a protect the public against disas. Salem. , ,  ;

." ha said. "I don't think we agree Whatever is la that report,I will sit A Salem nuclear plant employee poses with one of, tF th, FEMA on the major deficien- down with other people and say "How faulty circuit breakers at the plant lost month.

The " Artificial Island Plan".- so -

med because the Salem nuclear Christiansen was quick to point out ,

int sits en a man-made island in the that despite FEMA's concerns,"I don't tt.ere were problems with the exer- ONE AREA THAT needs atten lawara River - was developed by think theofpublic was inproblems jeopardy.,th -g;3,, is the attitude of the various to te, ccunty and local authorities One the biggest wi teers who take part;in the dr

-ty in 1980. last October's exercise, Christiansen "There may have been confusion'" Christiansensaid, adding that"it w the; St.:le Office of Emergency said, was that it was held during the lot of circumstances that piled he said.

nagement,which is part of the New day when many volunteers were sey Division of State Police,is the unable to participate. The point is, now to correct the w tich led to the failure of var ergency personnel to a ar d agincy in such matters and acts He said that; FEMA failed to take deficiencies as soon as possible, parti emThe upshot of the last Sa m ccnjuncti:n with er6ergency man. that factor into account in its report. culary in light of the Indian Point that there needs to be greater par l rmint offices in Salem and Cumber , The federal agency is now considering decision, he said.

patian by local respondents and I.

.d Ccunties. . whether to conduct this year's d, rill "The NRC is heralding to us that elected officials," he said. "We nee during the evening hours. they consider off-site aspects as impor impress upon people that they nee

N THE WAKE cf the 1979 acci-nt at Three Mile Island, the Nuclear tant as onsite aspects" he said. *The improve their skills.

gulatory Commission and FEMA "TO,, CRITICIZE local ~P' ple is state should be concerned but not "It's OK to make a mistake in a d a, as hg as ymn conut it after" irred changes in all emergency ay t y' d nt respond a e' dismayed."

ponse plans to achieve a more .

quate nd rdized approach, Tatum ex. ggor than 800 emergency workers

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the Salem plan is still being evaluat- from Salem and Cumberland Counties were scheduled t( take part in the t,y FEMA to determine its feasibili-

' and could receive approval in. .. drill, he said.

Tral' months. Christiansen also said that many of

tate and federal officials do not the 20 or so FEMA observers at the .

icipata that the Salem emergency drill may not have been totally famil-

, apsedness plan will run into the tar with the local preparedness plan.

l na difficulties that the lndian Point, "We did have some disagreements Y., plan did. with FEMA in the way they observed

'arlier this week the NRC threat- the exercise," he said. "It may have ad to shut down the two nuclear been that the FEMA observers were a mer plants on the Hudson River by little uninformed with the procedures le 9 unless there were " compelling down there."

i sons to , keep them in operation." But Christiansen admitted that l

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