ML20054E718
| ML20054E718 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/08/1982 |
| From: | Hartzman R, Scheiner C FRIENDS OF THE EARTH, NEW YORK CITY AUDUBON SOCIETY, WESTCHESTER PEOPLES ACTION COALITION, INC. |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-SP, NUDOCS 8206140103 | |
| Download: ML20054E718 (20) | |
Text
e' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSIONERS
'{20 Nunzio J.
Palladino, Chairman
,_3 Victor Gilinsky J
, 20 1
John F. Ahearne Thomas M.
Roberts James Asselstine and BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Louis J. Carter, Chairman Oscar H. Paris Frederick J. Shon x
In the Matter of x
x Docket Nos.
CONSOLIDATED EDISON COMPANY OF NEW YORK x
(Indian Point Unit 2) x 50-247 SP x
50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK x (Indian Point Uni-3) x June 8, 1982 x
FOE /AUDUBON AND WESPAC'S RESPONSE IN SUPPORT OF UCS/NYPIRG MOTION FOR RE-CONSIDERATION OF COMMISSION RULING ALLOWING INTERIM OPERATION AND FOR ISSUANCE OF A SHOW CAUSE ORDER AGAINST LICENSEE'S, AND FOE /AUDUBON AND WESPAC'S PRESENTATION OF ADDITIONAL NEW EVIDENCE 1.
On Sane 4, 1982, the Union of Concerned Scientists (UCS) and the New York Public Interest Research Group (NYPIRG) moved for reconsideration of the Commission's ruling permitting interim operation of Indian Point Units 2 and 3 pending-the outcome of the Atomic Safety and Licensing Board investigation, and for issuance of a show cause order against the Licensee's, prior to commencement of the evidentiary portion of the inves-tigation.
In their submission, UCS/NYPIRG presented new evidence of deficiencies in emergency planning for the Indian Point nuclear power plants.
Friends of the Earth, Inc. (FOE), the A$0h 8206140103 820608 PDR ADOCK 05000247 V
G PDR
New York City Audubon Society (Audubon), and Westchester Peoples Action Coalition (WESPAC) are filing this response in support of UCS/NYPIRG's motion.
In addition, FOE /Audubon and WESPAC present further new evidence of emergency plan deficiencies which have come to light since filing of the UCS/NYPIRG motion.
2.
The Nuclear Regulatory Commission (Commission) in its order of January 8, 1981, which set the. course for this proceeding and permitted interim operation of the Indian Point nuclear power plants, declared that when new evidence warranted interim relief, a different course of action in this proceeding could be ordered.
Order of January 8, 1981 at p.3.
' FOE /Audubon and WESPAC are in agreement with UCS/
NYPIRG that the new evidence submitted by the latter parties demonstrates a woeful lack of emergency preparedness at Indian Point.
The serious deficiencies in the Indian Point emergency plans described by the Regional Assistance Committee (RAC) of the Federal Emergency Management Agency (FEMA) in April and December of 1981 lead to the inescapable conclusion that there is no assurance that appropriate protective measures can and will be taken in the event of a radiological emergency at Indian Point.
Furthermore, local emergency plans are clearly inadequate and incapable of implementation, as emphasized by the formal rejection on May 18, 1982 of the R0ckland County Radiological Emergency Response Plan (CRERP) by the Rockland County Legislature.
3.-
3.
The evidence presented by UCS/NYPIRG would in
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itself be more than sufficient to warrant interim shutdown of the Indian Point nuclear power plants and issuance of a show cause order.
But new information just made available portrays a situation far more grave than previously. apparent.
On March 3, 1982, a joint exercise of the emergency prepared-ness plans for Indian Point was held.
Participating in the exercise were the Power Authority of the State of New York, owner of Indian Point Unit 3, and officials and agencies of the State of New York, and the Counties of Westchester, Rock-land, Orange, Putnam and Dutchess.
Findings were reported to FEMA which, on June 4, 1982 released its " Post Exercise Assessment," dated May 27, 1982.
The Assessment reported that "Amont the four counties, nine functional areas were evaluated as weak."
Post Exercise Assessment, at p.9-10.
(a copy of the Executive Summary of the Assessment is annexed hereto as Appendix A)
These substantial and significant deficiencies underscore the fundamental and overwhelming degree of inade-quacy of the emergency plans atad the broad failure to meet the mandatory standards of 10 C.F.R.850.47.
l Among the deficiencies reported by FEMA are:
weakness in the means of alerting the public to a serious radiological emergency, in non-conformity with 10 C.F.R.950.47 (b) (6).
Sirens did not sound or were inaudible to residents.
The backup system of notification by sound trucks was not even tested. There was a lack of public understanding of the mean-ing of the sirens, and a lack of notification of transients.
weakness in the public education program in non-conformity with 10 C.F.R.950.47 (b) (7).
Public education pamphlets were
' ineffective.
The public as a whole 1qcked knowledge of radiological emergency preparedness, and, in particular were uninformed about protective actions and ERPA zones.
Awareness of the emergency procedures by the non-English speaking population was not demonstrated.
the minimal extent of participation by Rockland County's police, fire and volunteer ambulance corps demonstrates the lack of success of the exercise in assessing the capability of the second largest county to meet the standards set forth in 10 C.F.R.550.47 (b).
weakness in recovery and reentry procedures for Orange County in non-conformity with 10 C.F.R.850.47 (b) (13).
weakness of Westchester County's health, medical and exposure control capabilities in non-conformity with 10 C.F.R. 250. 47 (b) (12).
weakness in accident assessment capabilities for Rockland County and deficiencies elsewhere, in non-conformity with 10 C.F. R. 550. 4 7 (b) (9).
inadequate backup for two key people in Putnam County, the CD Director and radiological defense (RADEF) officer, in non-conformity with 10 C.F.R. 550.47 (b) (1).
weakness in emergency operations facilities and capacity for alerting and mobilizing staff in Rockland County in non-conform-ity with 10 C.F.R.550.47 (b) (5) and (8).
weakness in 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capability to determine exposure of emergency workers in Westchester County in non-conformity with 10 C.F. R. 950. 4 7 (b) (11).
1
serious deficiencies in communications capabilities among
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state and local emergency response facilities in non-conform-ity with 10 C.F.R.550.47 (b) (6)
These observations are just a sample of the range of serious deficiencies that exist in emergency preparedness as revealed by the FEMA Post Exercise Assessment.
But they do demonstrate that the emergency plans are basically inadequate and incapable of implementation.
These are not deficiencies which can be corrected through remedial action procedures.
If effective emergency preparedness is at all possible, at a minimum, fundamental revision of the plan itself is a stark necessity.
4.
The information contained in the letter of June 2, 1982 from Alfred Del Bello, Westchester County Executive, to Commission Chairman Palladino, and in the departmental comments attached to his letter, provide further evidence that major i
l d
iciencies in emergency preparedness exist in Westchester County.
County Executive Del Bello stated that his trans-portation professionals are of the opinion that evacuation plans will not work as currently drafted.
Letter, p.2.
The County Executive also indicated that funding for radiological j
equipment, training, and communications systems needed to make the potentially workable aspects of the plan implementable in fact, is " grossly inadequate."
These are only two major deficiencies among those reported in these ma.terials.
5.
The sum of this new evidence and that presented to the Commission by UCS/NYPIRG patently warrant a changed course of action in this proceeding.
Continuation of the evidentiary l
hearing without a show cause order wil1 be redundant and wasteful, and will unnecessarily delay a definitive decision by the Commission.
While it is our contention that no feasible emergency measures can protect against the long term consequences of a serious accident at Indian Point, it is now crystal clear that the responsible parties have repeatedly failed to meet their obligations under existing emergency regulations to develop effective plans to deal with the immediate exigencies of an accident at Indian Point.
Further
" preliminary" investigative hearings are unnecessary to demon-strate the inadequacies and dangers at Indian Point.
The known facts compel issuance of a show cause order and interim suspension of operations at the power plants.
6.
Nor can the triggering of the 120 day clock be expected to remedy the lack of emergency preparedness.
This mechanism was used once without any results, as borne out by the December 31, 1981 RAC Review, the May 27, 1982 FEMA Post Exercise Assessment, the rejection of emergency plans by Rockland County, and the submissions of Westchester County Executivd Alfred Del Bello.
This evidence irrefutably demon-strates that the August 24, 1981 NRC conclusion that deficiencies in Indian Point emergency plans had been " resolved satisfactorily,"
was mistaken and misguided.
To try the 120 day clock a second time in the face of centinuing deficiencies which render the emergency plans fundamentally inadequate and incapable of implementation, would be to disregard the long delayed and immediate need for providing for the safety of those living and
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working in the vicinity of Indian Point.
This situation can only be remedied through a show cause" order and interim shutdown of the Indian Point nuclear power plants:.
WHEREFORE, FOE /Audubon and WESPAC request, in support of the UCS/NYPIRG motion, and upon the basis of the additional new evidence presented herein, that the Commission issue an order to show cause why the licenses for Indian Point Units 2 and 3 should not be revoked, and directing the interim suspension of the operation of said nuclear power plants.
Respectfully submitted,
/
[<
n RICHARD M.
HARTZMAM Esq.
Counsel for FOE /Audubon Friends of the Earth, Inc.
208 West 13th Street New York, New York 10011
{
s /h 0.CA fSAf//
CHARLES A.
SCHEINER Co-Chairperson Westchester People's Action Coalition, Inc.
P.O.
Box 488 White Plains, New York 10602 l
Dated:
June 8, 1982 I
APPEAIDIR A
,_ _ &_ _s_ _,_,
i POST EXERCISE i e
e ASSESSMENT sssssssssssssssssssssssssssssssss Exercise of the New York State and Westchester, Putnam, Roc (land and Orange Counties Radiological Emergency Plans for INDIAN POINT NUCLEAR GENERATIN3 S"ATION M AY 2 7,19 8 2 Federal Emergency Management Agency Region 2 FRANK P. PETRONE 26 FEDER AL PLAZ A Regional Director New Yo rk, N.Y.10 278
I 6
TABLE OF CONTENTS i
~
db Page
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1.
INTRODUCTION.
l 1.
FEMA Responsibilities 1
2.
Exercise Event.
2 3.
Exercise Objective.
2 4.
Participating State and Local Organizations.
4 t
5.
Exercise Critique 6
6.
RAC Evaluation Objectives 6
7.
Federal Observer Team.
6 8.
Evaluation Criteria.
8.
9.
Remedial Action Procedures.
8 10.
Review and Approval' Procedures...
9 II.
EXECUTIVE
SUMMARY
10 1.
Overview.
10 2.
Summary: State Ac tivities.
11 3.
Summary:
Indian Point Emergency Operating Facility...
12 4
Summary: Westchester County.
13 5.
Summary: Rockland County.
14 6.
Summary: Orange County.
15 7.
Summary: Putnam County.
17 III.
EXERCISE SCENARIO.
20 IV.
EVALUATIONS AND RECOHMENDATIONS.
21 1.
State.
21 2.
Emergency Operating Facility.
24 3.
Westchester County.
27 4.
Rockland County.
39 5.
Orange County.
48 6.
Putnam County.
56-7.
Du t c he s s Coun t y.
67 V.
CORRECTIVE ACTION FOR DEFICIENCIES 68 1.
Scheddle for Correcting Significant De ficiencies.
68 l
L 4
4 y
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10 II.
EXECUTIVE
SUMMARY
c A joint exercise of the emergency pr epa red ne s s plans fo r the Indian Point site was held on March 3, 1982.
The of f-site exercise was observed by a team of 50 federal cbservers, who re po r ted their find ing s to the Federal Emergency Management Agency (FEMA).
Pa r t ic ipa t ing in the exercise were the owner of Indian Point Unit 3, Power Authority of the State of New York (PASNY), of ficials and agencies of the State of New York, and the counties o~
Westchester, Rockland, Orange, Putnam, and Dutchess.
' Emergency response facilities observed by FEMA included:
the Indian Point Emergency Operations Facility (EOF);
e the state Emergency Operations Center (FOC) in Albany; e
the state EOC in the Of fice of Disaster Preparedness, e
Southern District; the Westchester County EOC; e
the Rockland County EOC; e
the Orange County EOC; e
the Putnam County EOC; e
e, the Dutchess County EOC; and the Emergency News Center in Verplanck.
e The Dutchess County EOC also chose to participate in the exercise, although it is not within the 10-mile emergency planning zone.
Evaluators also observed procedures at pe r sonnel monitoring centers, at reception / congregate care centers, and at hospitals where simulated acci-dent victims were treated.
Over 50 state, local, and private agencies and departments participated in the exercise.
1.
Overview Dur ing the review of the exercise, each of the ten functional areas d esc ribed in section I.6 were evaluated fo r the state operations and each of l
the four mun ic ipal counties' operations (except Dutchess).
At the state level, all observed functions were carried out well; only minor deficiencies were noted.
Among the four counties, nine functional areas were evaluated
11' I
14 w ak.
Th e se de fic ienc ie s, po s i t ive areas of pe r fo rma nc e, and c o r r,ec-t ive reconmendations are detailed in the s umma r ie s prov id ed below and in the following pages.
Several concerns were ident i fied during the exercise that in flue nc ed the evaluation of that element.
Some of these concerns are identified below, The primary means for alerting the populace to a serious e
radiological emergency will be a system of sirens.
This system is now being installed and is to be tested by the l'ic en s e e s. The existing sirens were activated during the exercise, but some of the units did not sound or were inaudible to local residents. The backup system of noti-fication by sound trucks (pol. ice / fire crucks equipped with public address systems) was not used.
Rockland County's police, fire and volunteer ambulance e
corps initially chose not to participate in the exercise, claiming that inadequate training had been provided. During the exercise these groups participated, but to a minimal extent, thereby reducing the training benefit of the exercise and the ability to fully evaluate the county's preparedness.
The ef fectiveness of the existing radiological public educa-e tion program should be strengthened. Currently, public education on radiological emergency procedures relies on distribution of pamphlets to residents.
Concern reuains as to the level of public awareness.ind response. The se concerns include the public's understanding of the concept and geographical boundaries of planning zones. Also, the level of awareness of the non English-speaking residents living in the area should be analyzed.
2.
Summary: State Activities Emergency Operations Facilities and Resources.
Fac il it ie s and resources in 'the state EOCs in Albany and Poughkeepsie we r e good.
Dis pl ays were well placed ' and promptly upd a t ed.
Some additional plotting of dose calculations is recommended.
The c ommun ic a t ions between state and local ac c id en t a s se s sment te ams we re we a k.
Internal commun ic a t ions and public in fo rma t ion arrangement s were good.
Alerting and Mobilization of Officials and Staf f.
All mob il iza t io n ac t iv it ie s functioned well.
J
g}
t Emergency Operat ions Management.
Ma n.ag em e n t of the response organiza-
'i e
I t ion was well denonstrated.
Increased flow o f in fo rmation in both directions between agencies and decision-maker s would be beneficial.
Public and Media Relations.
At the state EOC in Albany, press f ac il i-t ies ind med ia briefings were good.
At the Joint Media Center, the state PIO staf f demonstrated good capability.
Accident Assessment.
Ac c id ent a s se s sment capabilities were good.
However, the state did not demonstrate their own i nd e pend ent field monitoring capability. Some additional computational aids would be of value.
Recovery and Reentry.
Short-te'rm and long-t e rm recovery and reentry proced,ures appeared to be good.
[ Relevance of the Exercise.
Participants felt that the exercise was beneticial for training and experience.
Use of simulated meteorology and the rapid, pace of scenario events detracted somewhat from the realism of the exercise.
s 3.
Summary:
Indian Point Emergency Operating Facility (EOF)
$ Emergency Operations Facilities and Resources.
The EOF in Buchanan had acceptable capabilities; however, space was l imited and inconveniently arranged.
Internal and external commun ic at ion systems could be improv ed.
Alerting and Mobilization of Of ficials and Staf f.
Staffing and notifi-cation was acceptable.
Additional feedback from the state and counties to the EOF would be o f bene fit.
Emergegev Operations Management.
Manag ement of the res ponse was good for state representatives and acceptable for the county representatives.
Mo re
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involvement of the state and county in decision making is recommended.
L Accident Assessment.
Ca pab il it ie s in this area were acceptable.
Computing capability for rapid response is rec,ommended.
Improvement is needed in use of monitoring data.
o' 9
Relevance of the Experience.
The exerc ise wa s felt to be beneficial to the participants.
l l
l l
L
1 ]*
le.
Summary:
Westchester County r
e Emergency Operations Factlities and Resources.
Th e fac ilit ies at the We s t c he s t e r County EOC were good overall.
The working space was sma l l l
l but adequate because of the layout.
Commun ic a t ion, internal
,a nd external, was good.
Backup RACES communication capability was demonstrated.
Displays and mJps were well crganized and security was good.
Alerting and Mobilization of Of ficials and Staf f.
Westchester County demonstrated a good capability for alerting and mobilizing officials aad staff in a timely manner.
This resulted from good communications and from adequate procedures and backup personnel.
Th e capability for 24-hour alerting and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day operation was good.
The re is some concern over the avail-ability of enough personnel to adequately staff the reception centers if an actual emergency started on a weekend.
Emergency Operations Management.
Emergency o pe rat ions management, headed by the County Executive, was very good, and demonstrated well-defined leadership at several levels.
The staff was kept well in formed through periodic briefings by the leaders.
Public Alerting and Notification.
Public alerting and notification actions were weak, due primarily to the unsatisfactory pe r fo rmance of the siren system, l.ack of understanding by some of the populace of the meaning of the sirens; lack o f knowledge of the emergency response planning areas (ERPA);,
and lack of adequate notification of transients were observed. The procedures for broadcasting EBS messages were very good; EBS messages were well written and timely.
Activation of EBS station and issuance of first EBS message were
\\
excellent.
4 Public and Media Relations.
The public and media relation actions were acceptable, however, public education programs and rumor control procedures need im p r ov em e n t.
Public education pamphlets were mailed and received by rate payers, but apparently we re not e f fec t ive, because the public as a whole seemed to have a general lack of knowledge of radiological emergency prepared-ness.
People who do not pay utility bills directly, such as some tenant s, may not have received the pamphl e t s.
Emergency in format ion. wa s not po s t ed, nor was it printed in the telephone book.
Accident Assessment.
Ac c id ent assessment c a pab il it ie s were evaluated as acceptable but some de fic ienc ie s are noted.
Th e radiological assessment e
~
16 instrumentation was good, except that the instrument used for measuring e
=
r ad io iod ine should be equipped with a silver-containing air filter.
Pro-cedures for quickly measuring contamination in liquid samples are needed.
Projected dose calculations were good,. and field monitoring teams were well trained and capable. We ability to recommend protective actions based on the protective action guidelines was well demonstrated.
Actions to Protect the Public. Overall, the Westchester County person-nel demonstrated an acceptable capability to protect the public by implement-ing protec t iv e meas ure s.
Improvements are needed in the details o f the procedures for relocating residents who do not have pr iv ate vehicles, in protecting mobility-impaired persons, and in dealing with po tent ial imped i-ments:to evacuation.
Health, Medical, and Exposure Control.
Mo st of the health, medical, and exposure control capabilities were we x.
Th e 24-hour capability to d e termine exposures of emergency workers was weak because of instrtsnentation problems, while decontamination procedures were weak primarily because of a lack of adequate vaste d i s po sal, especially for liquid wastes.
Control of access to evacuated areas was good, and maintenance of dose records was good.~ Action levels that require decontamination procedures were well estabkished.
.. Recovery and Reentry Operations.
Simulated reentry operations made it appear that the capability to recover and reenter exists.
' Relevance of the Exercise Experience.
Participants felt that the exercise was a good learning experience.
i l
A j
5.
Summarv:
Rockland County i
" Emergency Operations Facilities and Resources.
We facilities at the Rockla'nd County EOC vere weak.
Significant d e fic ienc ie s were noted relating to external and internal commun ic a t ion s, leadership in the EOC, and space l
a l lo t ttien t.
?
l Alerting and Mobilization of Of ficials and Staf f.
We c apab ilit y for alerting and mobilization of staff from the EOC was weak.
De fic ienc ie s were noted related to the lack of telephone lines and staf f to perform initial c a l l ing.
Backup staff was also lacking.
Overall improvement in commun ic a-tions is needed.
l i
I l
L
o I
15 Emergency Operations Management.
Or s;an i za t ional control, leadership, and deciaion making were acceptable.
However, e f fec tive management of the EOC by one individual was not demonstrated.
Mo re familiarity is needed with response procedures.
Public Alerting and Notification.
Initial notification of the pub lic was weak, primarily because of siren system malfunction.
Activation of the EBS station and issuance of the first EBS message were well coo rd inated.
EBS messages were professionally coordinated, cleared, and issued.
Public and Media Relations.
Media c apab il it ie s were acceptable, f
However, public awareness of a pub lic education brochure was low.
Rumor control needs to be strengthened.
There may be a need to translate the brochure in order to reach non-English speaking individuals.
Accident Assessment. Ac c id ent assessment capabilities were weak. Poor communication systems contributed to problems in this area.
Field monitoring teams need more training with their instruments.
he role of the county repre.sentative at the EOF needs to be better defined.
Actions to Protect the Public.
Ca pab ilit ie s for protection of the public were good.
Evacuation and decontamin at ion were well demonstrated.
Health, Medical, and Exposure Control Measures.
The se ac tiv it ie s were well demonstrated.
Facilities were good and well staf fed.
Recovery and Reentry Operations.
he capability of the EOC for recov-ery and reentry was good, as demonstrated by simulation.
Ac t iv it ie s ir. the field were not observed, due to the shortness of the scenario.
Relevance of the Experience.
Lack of involvement by some local agen-cies reduced the ef fectiveness of the exercise.
The inclusion of a simulated winj shift in the scenario was good, but the county's computer analysis system was not used during the exercise.
Th e exercise id en t i f ied areas that would benefit from additional training and better equipnent.
6.
Summarv: Orange County Emergenev Operations Facilities and Resources.
The facilities at the Orange County Emergency Operating Center (EOC) were evaluated as acceptable.
16 I
t' Some de fic ienc ie s were noted, particularly gith the commun ic a t ion sy' stem l
linking Orange County with the other counties.
Internal commt iic a t ion s systems could also be improved.
Maps and displays were generally good.
Accept able security wa s provided.
u Alerting and Mobilizatien of Of ficials and Staff.
The overall capa-bility fo r alerting and mob il iza t ion was evaluated as we a k, based upo n a deficiency in the ke y element of 24-hour shift change c a pab ilit y.
Backup personnel did not demons t rate suf fic ient knowl ed ge in all essential areas.
The rema in ing elements in this category we re in general adequately demon-strated, although poor communications be twe en agenc ie s i's the EOC led to difficulties in establishing access control points.
Emergency Operations Management.
Organizational control, lead ership,
decision making and support by officials we re acce ptab le.
Pe r fo rmance was a f fec ted by internal commun ic at ions in the EOC, which d epend ed upo n hand-carrying messages between rooms in the facility.
Br ie fing of agencies was sporadic and written updates were not always available.
Recept ion centers, congregate care facilities, and the decontamination center were well sta f fed and organized.
Public Alerting and Notification.
Pub lic alerting and no t i fic a t ion we re weak, due primarily to the unsatis f ac tory per formance of the siren system.
The EBS was activated in a timely manner.
The first EBS message was coordinated with the siren sounding. Procedures for issuing EBS messages were
- good, hblic and Media Relations.
The c a pab il it y for dealing with the g8od.
Rumor control needs to be strengthened.
Pub lic educ at ion media was programs also should be strengthened.
Accident Assessment.
Ca pab il it ie s fo r ac c id en t assessment we re rated as acceptable.
De fic ienc ie s noted inc lud ed the failure of the field monitoring teams to carry full instrumentation.
Actions to Protect the Public.
Means fo r sheltering or evacuating the public were evaluated as good. All observed facilities were well staf fed.
Lack o f data on rad io iod ine levels in the field we re believed to af fect d ec i s ions for public protec tion.
4
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17 Health, Medical. and Exposure Control Measures.
Procedures for med ital treatment and exposure control were evaluated as acceptable.
De fic ienc ie s noted inc l ud ed the lack of provision fo r d i s po sa l of contaminated wastes.
Hospital personnel need additional training.
Permanent dose recording instru-ments were not available for emergency workers.
Recoverv and Reentry.
Recovery and reentry procedures were evaluated a s we a k.
Be significant deficiency related to the lack o f full simulation by partic ipants.
Relevance of the Experience.
Th e exercise seemed to pr ov id e an acceptable level of experience.
One ' d rawb ack noted was that some response teams were not fully tested, while others were tested on skills that we re considered routine.
7.
Summary: Putnam County Emergency Operations Facilities and Resources.
The working space in the Putnam County EOC was cramped, which resulted in some minor discomfort to the staff.
Re overall functioning of the EOC was good in spite of the small size, because the management wa s good.
Commun ic a t ion systems were good, and had good backup.
Alerting and Mobilization of O f ficials and Staff.
Putnam County d emons t r a ted an acceptable capability for alerting and mobilizing officials and staff.
The procedures used would have been ef fective at any time during the day or night, and resulted in a prompt and timely activation of the EOC and field monitoring teams.
A capability for continuous operations 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day was well demonstrated by executing a shift change and by exhibiting 1ists of backup personnel.
- Th i s shift change revealed that two key people, the CD Director and the radiological defense (RADEF) o f fic er, do not have adequate backup.
An emergency generator was not available in the event of power failure.
/
Emergenev Operations Management.
The management of the Pu tn ara Coun t y EOC was very good and was well supported by elected o f fic ial s.
Many specific organizations had well-defined roles and demonstrated good pe r fo rmanc e.
l.eidership was excellent and support by the RACES organization was excellent.
a a
e L8 Publix Alertsat and Notification.
Pub l i.c alerting and no t i f ic at ion e
were weak, due primarily to the un sa t is f ac tory per formance o f the stren systee.
Ac t iv a t ion of the ES$ station and issuance of first EBS message were good.
Other ESS messates we re cleared and issued on a t imely basis.
Some route alerting by police and fire vehicles was simulated but no PA announcements were made. Deficiencies were noted in the ability to notify the transient po pul a t ion.
public and Media Relations.
The capability for public and media relations in putnam County was acceptable overall. Public education brochures we re mailed to the pub lic, and public training courses were given by the fire department and RACES personnel. Nevertheless, there appears to be a need for additional education to help the public understand protective actions and ERFA sones. The p10 of ficer had good access to all information, and prepared t imely and appropriate releases.
There was no evid ence of a coordinated e f fort to identify and control rumors.
Accident Assessment.
Accident a s se s sment capabilities were evaluated as acceptable; however, some deficiencies were noted.
Initial projections of radiological exposure were made independertly in a timely manner and confirmed the utility projections. Field monitoring temas were promptly deployed, and were very competent. The instrumentation for Wole body genea ray was good.
However, there was no capability for measuring rad ic iod ine.
Silve r-load ed filters are needed to provide capability for measuring radioiodine.
Actions to Protect the Public.
Put n am Coun ty d ason st r a ted a good capability to protect the pub lic. Roadblocks were set up promptly. Orders were given in a timely manner for the actions to simulate sheltering and then evacuation. 'A bus load of students was evacuated (in actuality) to the congregate care center in Dutchess County.
his was well done.
The congre-gate care centers were wil located, well staf fed, and well equipped. he ir procedures were good; however, the radiation monitoring personnel could benefit frors aJditional training.
f Health, Medical, and Ewoosure control.
Overall, the Nealth, med ic al,
and esposure control actions were acceptable, with the exception of the procedures for ultimate d i s po s al of contaminated liquid s.
Direct r ead ing l
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do4imeters suppl ied to emergency workers had approprtate ranges and sengi-ttvities.
Readings were made and recorded frequently, and the results
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r e po r t ed by radio to the EOC.
No pe nnanent-r ec o rd dosimeters were provided.
l Procedures for approval of exposure 'of emergency workers in excess of protec-I tion action guid es need to be clarified.
Ac t ion levels for decontamination -
f procedures were known.
Recovery and Reentry Operations.
Reentry operations were denonstrated by simulation only. An acceptable capability for reentry and recovery appears to exist.
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Relevance of the Exercise Experience.
The re was un an imous ag reement very beneficial to the participants, all of whom took that the exercise was as if the powe r plant accident.
the exercise very seriously and pe r fo rmed actually occurred.
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r UNITED STATES T AMERICA NUCLEAR REXJIAIORY COPMISSION W
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BENRE 'DE ATOMIC SAFETY AND MCENSING DOARD
'I I26 b;
. :c...
1 In the Matter of
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Docket Nos. 50-247 SP 00NSOLIDNIED EDISON COMPANY T NEW YORK
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50-286 SP (Indian Point Unit 2)
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POWER AUrf0RITY T U{E STATE & NEN. YORK
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(Indian Point Unit 3)
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Certificate of Service I hereby certify that copies of:
FOE /AUDUBON AND WESPAC'S RESPONSE IN SUPPORT OF UCS/NYPIRG MOTION FOR RE-CONSIDERATION OF COMMISSION RULING ALLOWING INTERIM OPERATION AND FOR ISSUANCE OF A SHOW CAUSE ORDER AGAINST LICENSEE'S, AND FOE /AUDUBON AND WESPAC'S PRESENTATION OF ADDITIONAL NEW EVIDENCE luvebeenservedontheofficialminimumservicelistfortheadve captioned proceeding by depositing in the United States mail, first class, this 8Tii day of JUNE, 1982.
I 4&c
<A RICIIARD M.
HARTZMAN" Friends ofithe Earth, Inc.
208 West 13th Street New York, New York 10011 (212) 675-5911