ML20027D516

Updates Rockland County Info Re Sirens,Emergency Equipment, Population Estimates,Finances & Procedures.Info Should Have Been Forwarded to NRC by Fema.County Resolution 320 Encl

ML20027D516
Person / Time
Site:	Indian Point
Issue date:	10/29/1982
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM)
References
ISSUANCES-SP, NUDOCS 8211040424
Download: ML20027D516 (10)

Text

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'o WEST BRANCH CONSERVATION ASSOCIATION M3 BUENA VISTA ROAD

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NEW CITY N Y 10966 4

i October 29, 1982 DOCKETF0 l

USNRC Hon. Nunzio Palladino, Chairman l

Hon. Victor Gilinsky l'

Hon. John F. Ahearne 12 NOV -3 A10:01 Hon. Thomas Roberts j

Hon. James K. Asselstine j

U. S. Nuclear Regulatory Commission hy/ $h.

Washington, D.C.

20555 bnNCH T

Hon. Commissioners:

g Re: Dockets No. 50-247-SP and 50-286-SP Because the Legislature of Rockland County, in resolution #320 of 1982, copy enclosed, stated tha'c it did not care to spend any further money in time and effort 1

of Rockland employees, it has not been attending the meetings held bi-weekly by New York State, FEMA, NRC and' the licensees in above Special Proceedings.

However, as intervenors in the case and as interested citizens, we have been present on October 5 and 19.

j j

On October 19 two personnel from Rockland County were present as observer # but did not participate in the i

meeting.

Which is not the impression that FEMA has evi-dently given you on October 21.

If they signed the atten-dance sheet and may have answered a direct question which I

we did not hear, that does not mean participation.

Reso-I lution #320 attached has not been superceded and speaks for itself.

It need not be interpreted by New York State i

or FEMA to impress the Commission of any change.

b Rockland County is hardly any better off than it was on March 3, 1982, and you should find that out for yourselve4 as the FEMA and New York State people cannot be counted on to bring you the facts.

Below we have touched on a few obvious points to draw to your attention regarding finances, sirens, equip-i ment, population estimates and procedures in the review process for the 120 day clock.

If you cared to inquire of the Rockland County Chairman of the Legislature about the items listed, you would learn what you should have

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been told by FEMA.

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• on their own time, not the County's, j

8211040424 821029 i

PDR ADDCK 05000247 MO3 8

(WBCA to NRC - October 29, 1982) page 2 SIRENS No drill has been made of the sirens at full decibels since March 3 when they were inadequate. Growl tests have been conducted by the licensees only.

We should not have t-2 pend on them for our only verification when their license is at issue. Nothing short of a full test before the 120 day clock is out is acceptable to the people. If not, why not?

EQUIPMENT Emergency personnel have no equipment against radio-active fall-out. We have been promised dosimeters and re-ceived 150.

That is not 1/20th of what we need. How can FEMA or the NRC construe that as being prepared? Why didn't FEMA ask how many?

See finances below.

Silver zeolite filters are needed by the teams monitor-ing in the field. Rockland has had an on-going disagreement with the State about the number of teams needed and their equipment. The State avers there is no need for more than three teams, the County wants 12.

On a recent occasion Mr. Davidoff came up to four.

The teams are needed in the field to track for radiation. Our County personnel do not wish,to rely on automatic equipment mounted in some locations since they could be unreliable. There are no telephones to report data out in the countryside and no radio communica-tions or money to buy same.

Decontamination equipment is not in place. See finances below.

POPULATION ESTIMATES The study of population that went into licensee's plan relies on the 1970 census.

Acceptable at the time but not up-dated to suit the 1980 census long since available.

l Other cases before the NYState Public Service Commission, etc. are all using the 1980 census.

The Rockland L'unty Planning Board made a special study for the ASLB case on the population within the 10 mile EPZ checking the maps issued that show population block by block. The result was 17h% higher than 1970. We have repeatedly told FEMA and the State about it and the demographer testified before the ASLB to that effect on June 24. See transcript of testimony of George O' Lear.

17b% is not an inconsiderable factor.

(WBCA to NRC - Octobar 29, 1982) page 3 FINANCES New York State Executive Law now provides for the sum of $1,250,000 to be collected from the utilities operating nuclear facilities and presumable that has been collected.

We have been told by Mr. Davidoff, in public meetings, that the State will distribute $470,000 of that sum and keep the rest to pay for its expenses.

Rockland's share has been put at $30,000 for expenses of March 3 drill and $58,000 for any expenses Rockland wishes to make or reimburse. Our County Legislative Chairman, John Grant, has repeatedly pointed to the insufficiency of funds and asked for better methods of obtaining them.

Our State Legislature would have to pass a bill when it meets in next session, which only starts in January. We forsee resistance from up-state nuclear facility owners since their population density presents fewer problems.

That could hold up passage of a bill. In any event, the money needed is nowhere in sight. How then can FEMA certi-fy to you that any plan is implementable, if only on the 4

basis of lack of equipment?

PROCEDURES Under FEMA's proposed rules and regulations, 44 CFR-350,it is required for them to conduct a public hearing which they did. After it FEMA decides what are the defi-ciencies and there is no reiview of them by any other i

agency or governmental body excepting the NRC. If FEMA failed to note that the road network is THE achilles heel of all plans surrounding Indian Point site, we have no re-dress mechanism in which to point this out.

l Those persons in Rockland County such as chiefs of police, sheriff patrol, ambulance corps, bus drivers, teachers, etc. have offered testimony stating the plans wont work.

How then can the State move in to unknown areas with personnel not familiar with the roads and better effect an evacuation than those who know the area well?

You should have had some Rockland County representa-tives at your meeting to confront the myths of Mr. Kowieski et al.

Haven't you an obligation to check them out let alone to notice the objections being pointed out to you?

The whole State plan is a list of promises for the future.

Some are impossible to implement.

Sincerely yours, iht.b4 xc: JohnGrant, Gov. Carey W.

S.

Fleisher Congressmen Fish,Gilman, Secretary Peyser and Ottinger Legislators and intervenors

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WEST BRANCH CONSERVATION ASSOCIATION M3 BUENA VISTA ROAD NEW CITY N Y 10956 October 29, 1982 Re:

Attached reprints copied attached are from three pages of materials distributed by Mr. Donald Davidoff, Director of New York Stato Radiological Emergency Preparedness Group, at a meeting on October 5, and used also on October]9, as

" working Papers".

They had no title more than is shown and no sponsor printed anywhere.

The shorter page is one of 9 which referred to subsec-tions of NUREG-0654.

The longer page is a composite of pages 2 and 5 from 29 pages which were made up by FEMA from the comments at the July public meetings in Highland Falls and Cortlandt, New York, and submitted to the State REPG for comments.

Our critique follows:

Especially noteworthy are the qualitative and quanti-tative omissions.

K ( a) fails to detail how many dosimeters have been supplied. The Rockland Health Department states 150 have been received and 5,000 are needed. It is necessary that every emergency worker be able to monitor the dose being received by any plume or venting exposure.

The 150 would just about be enough for Fire personnel without caring for police, ambulance corps, bus drivers, etc.

K (b) We have plans for requiring exposed personr.el and evacuees to be routed through portable de-contamination facilities but no equipment to conduct decontamination.

1.

Re Park personnel.

The Palisades Interstate j

Park Managing Director has not been notified that he is expected to acccaplish the nottication described. He has no budgetary provision for accomplishing the notification. The Chief of the Park police states that he could not reach people walking or hiking in the Park.

These Park officials were asked about this item on October 19, 1982, by West Branch.

4.

Social Services personnel do not believe that the onus is on those who need assistance to "come forward to seek assistance" in many cases.

Z.

S.

Fleisher Secretary

Interim risulkevi ; - I nit i.iii I o i n t. It;u!;e.toq ir a l I.ri.es qency Prep.ireilnen::

141:PG-9/ 3 2/112 Itemed ia l Action Scheilu t e 1.ca <1 Cnmntetion Date/

S t a t i m. u t of Deficienq Prot >oncil tei nin n i t ion He noon _n i b i l i ty,

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Radiological Exposure Control (a) Absence of permanent (a) Permanent dopitnoters (TLDs)

(a) REPG (Distribution plan dosimetry and 24-hour and self-readinq pocket by 9/1) monito ioni capability.

dosimeters (0-5 H) with

• More sennitive self-reading chargers have been ordered.

COMPLETED

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h h g.4 p'f ((}j p 'o g,

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• [.l((6 f 8 cf'I dosimeters are ni c led. No The capability for 24-hour permanent recond devices operation (i.e.,

shift

• (f" AddU, d 4 L M U N C OIf'[N dN/

(f ilm bailges or TI.Ds) were changes) will be demonstrated L

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available in the counties.

during the next exercise.

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(b) Current decontamination (b) Decontamination procedures are (b) Radiological Review present / e/[g/

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f.

procedures for emergency being reviewed and modified.

Task Force procedures by 9/1.

personnel require revision.

Personnel at appropriate

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locations will be trained in Training commenced

.:t'g,,,1 new methods.

by 10/29 (c) Decontamination protocols (c) Levels will be displayed as (c) Radiological Define by 9/1

(::equences) out at order needed.

Personnel will be Task Force in Westchester Plan, trained in application of Plan changes by 10/15 satisfactory for Putnam and requirements.

Itockland Plans.

The decontaminalion me t 'iod s table is reissing in the Orange Plan ( K. '.,. b., !!U R EG 0(.51 and procediare 3, 3, Table 1, County ItCDPs)

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rns Raised and S;esker Page State / County Besponse Target FD1A Evaluation Eme W al te of M, equate Action r

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c P@lic l'atings Proposed reedial (A)

Ctmplete l

for State / County g

Inadequate (C) 2mpletier Fesponse (I)

Inexrplets ft (T) lc

!!!TICATIC*: FETHODS /d:D FROCELTRES J. In large parks, such as VESPAC Park personnel will provide all lt'ca riran, Bear Mountain, or Blee persons with appropriate instructiors

.":rtain, how vill hikers and campers for leaving the park areas.

p located to be given instructions?

Transient posters containing such i'. : ens:deratien been given to revise information are also displayed in

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each park site.

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ef.

f 4.

The Tres!dert of the Disabled Mrs.

128

[),1 <3 Tereors ir Fe:k ard stated that card Burger (2)

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'n-t to disabled persons was very ar Mr,ueus.

Arrarently peerle called t

bcr.x,o said they did net understand I !

what t'me card wa* f er.

Me f aaker also indicated that ltherearearpresitately16.000 s'

ncbility-frraired people in Rockland

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County. The speaker assu.ed that no v.are than 200 cards were returned to t!e au:f.orities.

Please advise what the popu-We have no firm data on g

lation c' rchility irraried-people non-institutionalized mobility l

Is in all four counties and indicate impaired people residing in the 4 i

tbc asurce of 3 car data. In addition.

counties. We will continue,to work l

6e recus vnd that you work with the with handicapped groups & county l

Ascociations of,isabled Persons officials, but a responsibility

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ta assure that all nobility-ir.pairec remains with individuals to come individua!s are ? der.tified.

forward to seek assistance.

5 na l

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9.C.I.o Referrol No. 6675 introduced by:

May 18,1982 Hon. Herbert Reismon Hon. Kenneth Ingenito Hon. Som Zalmon Gdanski Hon. Edward Gorman RESOLUTION NO. 320 OF 1982 PROHIBITING THE. XPENDITURE OF COUNTY FUNDS E

OR USE OF COUNTY EMPLOYEES FOR THE FEDERALLY MANDATED ROCKLAND COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR INDIAN POINT, BUCHANAN, NEW YORK.

Ingenito/ Reisman WHEREAS, Consolidated Edison of New York (hereinafter referred to os " Con Edison"), and the Power Authority of the State of New York (hereinafter referred to Indian Point, os "PASNY"), each operate nuclear electrical generating facilities at Buchonon, New York, and WHEREAS, there are substantial inherent risks in the operation of the nuclear electrical generating facilities which pose threats to the health, safety and welfare of the citizens of Rockland County, and WHEREIS, there have been numerous violations of safety requirements of the -

Nuclear Regulatory Commission at the Indian Point power facilities which pose substantial threats to the health, safety and welfare of the citizens of Rockland County, and WHEREAS, there are more people located within a ten-mile radius of the nuclear electrical generating facilities at Indian Point than within the ten-mile radius of any other nuclear electrical generating facility in the United States, and WHERAS, it has been publicly acknowledged' by the Nuclear Regufotory Commission members that present safety standards would prohibit the erection of nuclear generating facilities at or near the existing location of the Indian Point power plants, and WHEREAS, the Nuclear Regulatory Commission hos promulgated a regulation which requires the development and implementation of a Radiological Response Plan for all residents within on orbitrary ten-mile radius of each plant, and l

(continued on other side)

s 9.C.I.o Referrol No. 6675 May 18,1982 WHEREAS, Con Edison and PASNY have developed, through the use of independent contractors, with the State of New York, o Radiological Emergency Response Plan for the inhabitants of the four counties who reside within on orbitrary ten-mile radius of the Indian Point nuclear facilities, and WHEREAS, the aforesaid counties include the Counties of Rockland, Orange, Westchester and Putnam, and WHEREAS, the Radiological Ernergency Response Plan for Rockland County is unsatisfactory in that Rockland County has not. been provided with sufficient communication equipment to inform public officials of safety hozords; sufficienMorning devices to inform the general public of danger; and adequate training for the personnel required to implement the plan, and WHEREAS, the existing roadway system of Rocktond County is totally inadequate and would be unable to accommodate the safe and timely evacuation of the citizens of Rockland County within the offected area, and os officials of the Federal WHEREAS, Rockland County officials, os well Emergency Management Agency (hereinafter referred to os " FEMA"), have criticized the Radiological Emergency Response Plan for Rockland County, and WHERE S, the County of Rockland has made o good faith effort, expended '

funds, and used its employees in on attempt to develop the aforesaid Radiologico!

Emergency Response Plan for the inhabitants of Rockland County, and WHEREAS, the County's continued participation in the Radiologico! Emergency Response Plcn will require the continuous expenditure of County funds and personnel hours with little or no protective benefit to the citizens of the County of Rockland, and WHEREAS, the Executive Low of the State of New York outhorizes the County of Rockland to prepare o Disaster Prepardeness Plon, an.d the County of Rockland, through its Office of Emergency Services, has and will continue to develop such plcns as may be necessary to insure the health, safety and welfare of Rockland County citizens from all contingencies, and WHEREAS, the Multi Services Committee of this Legislature has met, considered and opproved this resolution, now, therefore, be it RESOLVED, that the Legislature of Rockland County hereby authorizes, empowers and directs the Office of Emergency Services to continue to develop, in cooperation with our volunteer services, school officials, Department of Social Services, Department of Health and such other County departments os may be requested, o Disaster Preparedness Plan for Rockland County, which program shall be funded by the County of Rockland, and be it further RESOLVED, that the Legislature of Rockland County further directs the County Office of Emergency Services to develop a plan in response to o potential nuclear. _ _ _.

9.C.I.o Referrol No. 6675 M y 18,1982 accident occurring of the Indian Point Facilities and to utilize all sources of information in preporing such plan for the maximum protection of the citizens of Rockland County, such plan to be presented to the Legislature of Rockland County by Deecmber 3i,1982, and be it further RESOLVED, that the Legislature of Rockland County hereby authorizes, empowers and directs the Office of Emergency Services, the Treasurer of Rockland County and/or the Chairman of the Legislature of Rockland County to pursue and accept all Federal and State monies, equipment and personnel training in connection with Rockland County's Disaster Preparedness Plan and the Rockland County Nuclear Evocuation and own Preparedness Plan for the purposes aforedescribed, and be it further RESOLVED, that the Legislature of Rockland County 'hereby prohibils'the use of Rockland County employees or the expenditure of Rockland County funds in any manner concerning the further development of the Federally mandated Radiological

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Emergency Respnnse Plan for the nuclear electrical generating facilities owned and operated by Con Edison and PASNY ot Indian Point, Buchanan, New York, and be it further RESOLVED, that the Legislature of Rockland County hereby directs the Chairman of the Rockland County Legislature not to assist FEMA, Con Edison and PASNY, their ogents, servants or employees, in any manner concerning the further development of the Federolly mandated Radiological Emergency Response Plan for the nuclear electrical generating facilities at Indian Point, Buchanan, New York, and be it further RESOLVED, that in the event of a nuclear occurrence at the Indian Pnint Facilities, the Legislature of Rockland County herely authorizes, empowers cod directs its Chairman, notwithstanding this resolution, to take any and all action in coordinating and cooperating with any and all Federal and State agencies to protect the lives and property of the citizens of Rockland County, and be it further RESOLVED, that the Legislature of Rockland County hereby requests the chief executive officers of the legislative bodies of the Counties of Orange, Westchester and Putnam to odopt similar resolutions prohibiting the use of their county employees or the expenditure of their respective county funds for the planning, development or implementation of Federally mandated nuclear Radiological Emergency Response Plans for the nuclear electrical generating facilities owned and operated by Con Edison and PASNY of Indian Point, Buchonon, New York and be it further (continued on other side)

I

' N N Referrol No. 6675 May 18,1982 RESOLVED, that the Clerk to the Legislature of Rockland County be and she hereby is directed to send o :opy of this resolution to Senators Alphonse D'Amato and Daniel Patrick Moynihon; Congressman Gilmon; the Majority and Minority Leaders of the United States Senate and House of Representatives; Hon. Hugh L. Corey, Governor of the State of New York; Hon. Linda Winikow and Hon. Richard Schermerhorn, New York State Senators; Hon. Thomas Morchon and Hon. Eugene Levy, New York State Assemblymen; the Majority and Minority Leaders of the New York State Senate and the New York State Assembly; the chief executive officers of the Counties of Westchester, Orange and Putnam; the officials of PASNY, FEMA,.NRC and Con _ Edison; and to such other persons os the Clerk, in her discrdtion, may feel proper in-order to effectuate the purpose of this resolution.