ML20054H739
| ML20054H739 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/21/1982 |
| From: | Morgan C MORGAN ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8206240379 | |
| Download: ML20054H739 (75) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION , , , o g o. ,c ,,;-)
3 Before the COMMISSIONERS:
Nunzio J. Palladino, Chairman Victor Gilinsky John F. Ahearne Thomas M. Roberts James K. Asselstine and Before the ATOMIC SAFETY AND LICENSING BOARD:
Louis J. Carter, Chairman Dr. Oscar H. Paris Frederick J. Shon
)
In the Matter of )
)
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. ) Docket Nos.
(Indian Point, Unit No. 2) ) 50-247 SP
) 50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK )
(Indian Point, Unit No. 3) ) June 21, 1982
)
POWER AUTHORITY'S OPPOSITION TO UCS/NYPIRG MOTION FOR RECONSIDERATION OF COMMISSION RULING ALLOWING INTERIM OPERATION AND FOR ISSUANCE OF A SHOW CAUSE ORDER AGAINST THE LICENSEES PRIOR TO COMMENCEMENT OF THE EVIDENTIARY HEARING ON THE SAFETY OF THE INDIAN POINT NUCLEAR POWER PLANTS ATTORNEY FILING THIS DOCUMENT:
Charles Morgan, Jr.
MORGAN ASSOCIATES, CHARTERED 1899 L Street, :' , W .
Washington, D.C. 20036 (202) 466-7000 82g%O O C
)
TABLE OF CONTENTS Page I. INTRODUCTION . . . . . . . . . . . . . . . . .- . . . . 1 II. UCS/NYPIRG'S EVIDENCE DOES NOT WARRANT THIS LAST MINUTE MOTION . . . . . .. . .;. . . . , . . . . . . .
3
-III. THE ROCKLAND COUNTY RESOLUTION FAILS TO SUPPORT RECON-SIDERATION OR THE ISSUANCE OF A SHOW CAUSE ORDER . . . -7 IV. CONCLUSION . . . . . . . . . . . . . . . . . . . . . . 9 e
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I. INTRODUCTION Claiming that it has "new evidence of deficiencies in emergency planning for the Indian Point nuclear power plants,"1 Union of Concerned Scientists /New York Public Interest Research Group (UCS/NYPIRG) has filed an eleventh-hour motion seeking reconsideration of the Commission's January 8, 1981 order, and issuance of a show-cause order against the Power Authority of the State of New York (Power Authority). However, the present motion is yet another in a j long series of attempts by UCS/NYPIRG to close two licensed, operational plants which save licensees' consumers hundreds of millions of dollars annually.2 After failing in a least
- 1. UCS/NYPIRG Motion for Reconsideration of Commission Ruling Allowing Interim Operation and-for Issuance of a Show Cause Order Against the Licensees Prior to Commencement of the Evidentiary Hearing on the Safety of the Indian Point Nuclear Power Plants at 1 (June 4, 1982) (emphasis'added)-
(Motion).
- 2. UCS and NYPIRG,E along' with other intervenors here-in, have been lobbying for years in the communities ~sur-rounding Indian Point and in the media for the ' closing of the plants. Their first entry into the legal arena was the filing of a petition with the Commission in September,1979 to close Indian Point Units 2 and 3 and to decommission -Unit
- 1. The Commission denied the immediate shutdown request and instead, inter alia, directed that the present investigatory hearings be held and that a Staff Task Force examine the interim operation of the plants. Order at 3, 5-6 (May 30, 1980). After thorough study, the Task Force concluded that the "overall risk of the Indian Point reactor is about the same as a typical. reactor on a typical site." Task Force Report On Interim Operation of Indian Point 40 (NUREG-0715)
(1980). . Based upon this report, the Commission decided "that the risk posed by the operation of the Indian Point facilities did not warrant the suspension of the operating ,
licenses during the adjudicatory proceedings," Order at 3
. _ _ _ _ _ _ . _ J
l 2-seven previous attempts to close the plants, UCS/NYPIRG now seeks to circumvent the primary purposes of this proceeding
-- the level of safety posed by the Indian Point plants.
Intervenors Friends of the Earth /New York Audubon Society
( FOE / Aud ubon) , Westchester People's Action Coalition (WESPAC), and West Branch Conservation Association (WBCA) support the UCS/NYPIRG motion. Because intervenors' "new l evidence" is more than six months cid and because inter--
venors have grossly misrepresented the present state of emergency planning, this motion, filed on the eve of the (Jan. 8, 1981), thus once again rejecting UCS/NYPIRG's efforts to close the plants. .
NYPIRG followed that decision with a letter to the Staff dated April 1, 1981, which again sought to close the plants, this time for purported failure to comply with emer-gency planning regulations. The Staff denied the request pursuant to 10 C.F.R. S 2.206 (1981), also noting that the Commission itself reaffirmed its interim operation order on
. April 7. 46 Fed. Reg. 28,261 (1981).
NYPIRG forwarded a letter to the Commission dated July 24, 1981, again requesting that the plants be closed for alleged emergency planning inadequacies. Letter from Joan Holt to Commissioners at 1 (July 24, 1981). This request was also denied, as confirmed by letter of the Commission's General Counsel dated December 11, 1981.
In October, 1981, UCS/NYPIRG attempted to circumvent this proceeding by filing a petition in the United States
, Court of Appeals for the Second Circuit seeking extra-i ordinary relief including continuing appellate court jurisdiction over emergency planning at Indian Point, com-prehensive revision of the Commission's emergency planning i
rules and procedures, and a possible shutdown of the plants. UCS/NYPIRG argued, as it does herein, that the Commission's so-called "120-day clock", see 10 C.F.R.
S 50.54(S)(2) (1981), for resolving emergency planning deficiencies was ineffective. By Order dated December 15, 1981, the court dismissed UCS/NYPIRG's petition (after first having ruled against UCS/NYPIRG from the bench) .
}
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hearing designed to investigate these very issues, should be denied.1 II. UCS/NYPIRG'S EVIDENCE DOES NOT WARRANT THIS LAST MINUTE MOTION UCS/NYPIRG's first piece of "new evidence" is the deficiencies in the Indian Point emergency plans as recorded by the Federal Emergency Management Agency's ( FEMA's)
Regional Assistance Committee (RAC) in April 1981. Motion at 3.2 UCS/NYPIRG, however, neglects to mention that on August 24, 1981, the Nuclear Regulatory Commission (NRC)
" conclude [d] that this issue has been resolved satisfactor--
ily." Letter from Boyce H. Grier, Director, NRC Region 1, to George T.
- Berry, Power Authority President and Chief
, Operating Officer (Aug. 24, 1981) (emphasis added) (Attach-ment B). Thus, the April 1981 comments of FEMA's RAC are hardly a legitimate ground for a motion purportly based on new evidence.
- 1. UCS/NYPIRG has also erred in filing this motion for a show cause order with the Commission and with the Board.
10 C.F.R. S 2.206(a) expressly provides that a request to institute a proceeding to modify, suspend, or revoke a license must first be made to and considered by the Staff, not the Commission or a licensing board.
- 2. Presumably this is a reference to the April 6, 1981 letter from Vincent Forde, Acting Regional Director, FEMA, to William C. Hennessy, Chairman, New York State Disaster Preparedness Commission. See Attachment A.
UCS/NYPIRG's second piece of "new evidence" dates from December 1981 and consists of further comments made by FEMA's RAC. Such evidence is also hardly "new" in the con-text of this hearing, in which the Commission's suggested deadline requires such a rigorous hearing schedule.1 UCS/NYPIRG's months-long delay in filing this motion illustrates that its "new" information is not urgent. Its "new evidence" merely confirms that FEMA's evaluations are part of the ongoing process of developing emergency- plans for nuclear power plants. FEMA's comments, therefore, do not raise the " substantial health or safety issues" necessary for the issuance of a show cause order under 10 c
C.F.R. S 2.202. In re Consolidated Edison Co. (Indian Point Units 1, 2, and 3), 2 N.R.C. 173, 177 (1975) (" parties must be prevented from using 10 CFR 2.206 (show cause] procedures as a vehicle for reconsideration of issues previously decided"); accord In re Northern Indiana Public Service Co.
(Bailly Generating Station, Nuclear 1), 7 N.R.C. 429, 433-34 (1978), aff'd, 606 F.2d 1363 (D.C.Cir. 1979).
- 1. Although UCS/NYPIRG claims that it does not seek to delay the evidentiary hearings scheduled to begin on June 22, 1982, see Motion at 5, this motion cannot help but delay the proceeding designed to address the very issues raised by Intervenors.
The support for UCS/NYPIRG's motion by FOE /Audubon and WESPAC is similarly inadequate.1 FOE /Audubon and WESPAC claim that FEMA's Post Exercise Assessment, issued May 27, 1982, is additional new information in support of UCS/
NYPIRG's motion. See Response in Support-at 3. To the contrary, the FEMA Assessment supports the Power Authority's argument that emergency planning is a dynamic process and that reasonable assurance presently exists that the public can and will be protected in the event of a radiological emergency.
This document details FEMA's comments on the radiolog-ical emergency exercise conducted on March 3, 1982. FOE /
Audubon and WESPAC are less than candid when they append only the 10-page executive summary of the 68-page assessment to their document,2 and when they claim that the evaluation of nine functional areas as " weak" constitutes " substantial
- 1. See FOE /Audubon and WESPAC's Response in Support of UCS/NYPIRG Motion for Reconsideration of Commission Ruling Allowing Interim Operation and for Issuance of a Show Cause Order Against Licensee's [ sic], and FOE /Audubon and WESPAC's Presentation of Additional New Evidence (June 8, 1982)
(Response in Support).
FOE /Audubon and WESPAC's support for UCS/NYPIRG's motion is undercut by their admission that "no feasible emergency measures can protect against the long term con-sequences of a serious accident at Indian Point." Response in Support at 6. Because FOE /Audubon and WESPAC claim that no plan will be effective, then the purpose of their criti-cisms of the current plan can only be to make their claim a self-fulfilling prophecy.
- 2. The Power Authority has appended the entire document to this memorandum as Attachment C.
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and significant de ficiencies." Id_. In fact, the exercise participants also received 19 " good" ratings'in 9 functional areas, and 23 " acceptable" ratings in 10 functional areas.
See generally Attachment C, FEMA, Post Exercise Assessment (May 27, 1982) ( Assessment) . Intervenors obscure the fact that the very purpose of an exercise and critique is to identify as many deficiencies as possible 's o that correc-tions can be made.
Indeed, the FEMA Assessment of the most important areas of emergency response was highly f avorable: (1) "[al t the state level, all observed functions were carried out well,"
Assessment at 10; (2) at the Indian Point 3 Emergency Operations Facility, all tested areas were rated from
" acceptable" to " good ," Assessment at 12; and (3) even in Rockland County, upon which intervenors have focused- their criticism, "[clapabilities for protection of the public were good" and "[el vacuation and decontamination were .well demonstrated." Assessment at 15.
The high marks given the State of New York are partic-ularly noteworthy since, pursuant to N.Y. Exec. Law, Art.
2-B (Consol. 1981), the State maintains primary responsibil-ity for radiological emergency planning and, in the event of a general emergency, the State would commit its extensive resources and coordination and management capabilities.
Finally, the direct testimony filed by the Commission Staff and FEMA in the Indian Point investigatory proceeding A
-- which contains an overall review of emergency planning beyond simply the exercise -- contains few negative comments about the state of preparedness. Indeed, Staff witness Thomas Urbanik, II suggests that the evacuation time esti-mates contained in the emergency plan are even more reliable than the FEMA estimates, which enjoy a rebuttable presump-tion of validity in the proceeding. Testimony of Dr. Thomas Urbanik, II Concerning the Evacuation Time Estimates Studies for Indian Point, Units 2 and 3 (June 4, 1982).
"After a decision has been rendered, a dissatisfied litigant who seeks to persuade us--or any tribunal for that matter--to reopen a record and reconsider 'because some new circumstance has arisen, some new trend has been observed, or some new fact discovered,' has a difficult burden to bear." In re Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), 4 N.R.C. 619, 620 (1976), guoting ICC v. Jersey City, 322 U.S. 503, 514 (1944). UCS/NYPIRG and FOE /Audubon f ail to satisfy this "dif ficult burden."
III. THE ROCKLAND COUNTY RESOLUTION FAILS TO SUPPORT RECON-SIDERATION OR THE ISSUANCE OF A SHOW CAUSE ORDER UCS/NYPIRG also does not satisfy its burden when it j contends that Rockland County's resolution calling for "the Of fice of Emergency Services to continue to develop . . . a l
Disaster Preparedness Plan for Rockland County" makes the i
emergency plan for Indian Point unworkaole. See Motion at
4; Attachment A to Motion at 2. UCS/NYPIRG conspicuously falls to note that the !:esoldtion also provides:
RESOLVED, that in the event of a nuclear occurrence at the Indian Point Facilities, the Legislature of Rockland County hereby authorizes, empowers and directs its Chairman, notwithstanding this retolution, 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.
Attachment A to Motion at 3 (emphasis added).
- Rockland County's reiteration of its intention to abide by the federal and state plans in case of an emergency, while continuing to develop its own plan, hardly creates what UCS/NYPIRG calls an " emergency preparedness vacuum."
Motion at 4.
Thus, the Resolution, obviously a political gesture, would have no practical effect on Rockland County's response to a radiological emergency. The planning for such an emergency is also substantially unaffected, since the State maintains primary responsibility for radiological emergency planning and for the maintenance of the written State and county plan documents. ( A thorough two-volume radiolc gical emergency plan exclusively tailored for Rockland County is annexed to the State plan.) In a letter prepared subsequent to the Resolution, Rockland County reaf firmed its commitment
.to partii c pate in the State's planning process. See Attachment D, Letter from Donald B. Davidoff, Director, J
Radiolegical Emergency Preparedness Group, to John T. Grant, Chairman, County Legislature, at 1 (June 9,1982) .1 IV. CONCLUSION For the reasons stated herein, the Power Authority of the State of New York hereby requests that the UCS/NYPIRG
! Motion for Reconsideration of Commission Ruling Allowing Interim Operation and for Issuance of a Show Cause Order Against the Licensees Prior to Commencement of the Evidentiary Hearing on the Safety of the Indian Point Nuclear Power Plants be denied.
- 1. FEMA has noted that isolated instances of uncooper-ativeness by state or local governments would not seriously affect overall radiological emergency preparedness. See, e .g. , NYPIRG's Legislative Memorandum re : S-7122 at 5 (July T8, 1981), attached to Governor's Bill Jacket for S-7122
("[tlhe number of these (isolated instancesi does not . . .
l seriously affect the progress of preparedness development at this time").
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Respectfully submitted,
/
Charles Morgan,[qc.
Paul Colarulli V A/ Y_/
/f Joseph J. Levin, Jr.
MORGAN ASSOCIATES, CHARTERED 1899 L Street, N.W.
Washington, D.C. 20036 (202) 466-7000 Thomas R. Frey General Counsel Charles M. Pratt Assistant General Counsel POWER AUTHORITY OF THE STATE OF NEW YORK Licensee of Indian Point Unit 3 10 Columbus Circle New York, New York 10019 Bernard D. Fischman Michael Curley Richard F. Czaja David H. Pikus SHEA & GOULD 330 Madison Avenue New York, New York 10017 (212) 370-8000 Dated: June 21, 1982
I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the COMMISSIONERS:
Nunzio J. Palladino, Chairman victor Gilinsky John F. Ahearne Thomas M. Roberts James K. Asselstine i
and Before the ATOMIC SAFETY AND LICENSING BOARD:
Louis J. Carter, Chairman Dr. Oscar H. Paris Frederick J. Shon
)
In the Matter of )
)
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. ) Docket Nos.
(Indian Point, Unit No. 2) ) 50-247 SP
) 50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK )
(Indian Point, Unit No. 3) ) June 21, 1982
)
CERTIFIC ATE OF SERVICE I hereby certify that on the 21st day of June, 1982, I i caused a copy of the Power Authority's Opposition to UCS/NYPIRG l
Motion for Reconsideration of Commission Ruling Allowing Interim Operation and for Issuance of a Show Cause Order Against the Licensees Prior to Commencement of the Evidentiary Hearing on the Safety of the Indian Point Nuclear Power Plants to be served by first class mail, postage prepaid on:
Louis J. Carter, Esq., Chairman Charles M. Pratt, Esq.
Administrative Judge Thomas R. Frey, Esq.
Atomic Safety and Licensing Board Power Authority of the 7300 City Line Avenue State of New York Philadelphia, Pennsylvania 19151 10 Columbus Circle New York, New York 10019
- Mr. Frederick J. Shon Administrative Judge Janice Moore, Esq.
Atomic Safety and Licensing Board Counsel for NRC Staff U.S. Nuclear Regulatory Commission Office of the Executive Washington, D.C. 20555 Legal Director U.S. Nuclear Regulatory Commission Dr. Oscar H. Paris Washington, D.C. 20555 Administrative Judge -
Atomic Safety and Licensing Board Brent L. Brandenburg, Esq.
U.S. Nuclear Regulatory Commission Assistant General Counsel Washington, D.C. 20555 Consolidated Edison Company of New York, Inc.
Docketing and Service Brarch 4 Irving Place Office of the Secretary New York, New York 10003 U.S. Nuclear Regulatory Commission Washing ton , D.C. 20555 Ellyn R. Weiss, Esq.
William S. Jordan, III, Esq.
Joan Holt, Project Director Harmon and Weiss Indian Point Project 1725 I Street, N.W., Suite 506 New York Public Interest Research Washington, D.C. 20006 Group 9 Murray Street Charles A. Scheiner, Co-Chairperson New York, New York 10007 Westchester People's Action Coalition, Inc.
John Gilroy P.O. Box 488 Westchester Coordinator White Plains, New York 10602 Indian Pcint Project New York Public Interest Research Alan Latman, Esq.
Group 44 Sunset Drive 240 Central Avenue Croton-On-Hudson, New York 10520 White Plains, New York 10606 Ezra I. Bialik, Esq.
Jeffrey M. Blum, Esq. Steve Leipzig, Esq.
New York University Law School Environmental Protection Bureau 423 Vanderbilt Hall New York State Attorney 40 Washington Square South General's Office i
New York, New York 10012 Two World Trade Center New York, New York 10047 Charles J. Maikish, Esq.
Litigation Division Alfred B. Del Bello The Port Authority of New York Westchester County Executive and New Jersey Westchester County One World Trade Center 148 Martine Avenue New York, New York 10048 White Plains, New York 10601 Andrew S. Roffe, Esq.
New York State Assembly Albany, New York 12248
Marc L. Parris, Esq. Stanley B. Klimberg, Esq.
Eric Thorsen, Esq. General Counsel County Attorney Now York State Energy Office County of Rockland 2 Rockefeller State Plaza 11 New Hempstead Road Albany, New York 12223 New City, New York 10956 Atomic Safety and Licensing Pat Posner, Spokesperson Board Panel Parents Concerned About Indian U.S. Nuclear Regulatory Commission Point Washing ton, D.C. 20555 P.O. Box 125 Croton-on-Hudson, New York 10520 Atomic Safety and Licensing Appeal Board Panel Renee Schwartz, Esq. U.S. Nuclear Regulatory Commission Paul _Chessin, Esq. Washington, D.C. 20555 Laurens R. Schwartz, Esq.
Margaret Oppel, Esq. Honorable Richard L. Brodsky Botein, Hays, Sklar and Hertzberg Member of the County Legislature 200 Park Avenue Westchester County New York, New York 10166 County Office Building White Plains, New York 10601 Honorable Ruth W. Messinger Member of the Council of the Zipporah S. Fleisher City of New York West Branch Conservation District $4 Association City Hall 443 Buena Vista Road New York, New York 10007 New City, New York 10956 Greater New York Council Mayor George V. Begany on Energy Village of Buchanan c/o Dean R. Corren, Director 236 Tate Avenue New York University Buchanan, New York 10511 26 Stuyvesant Street New York, New York 10003 Judith Kessler, Coordinator.
Rockland Citizens for Safe Energy Geoffrey Cobb Ryan 300 New Hemstead Road Conservation Committee Chairman New City, New York 10956 Director, New York City Audubon Society David H. Pikus, Esq.
71 West 23rd Street, Suite 1828 Richard F. Czaja, Esq.
New York, New York 10010 330 Madison Avenue New York, New York 10017 Lorna Salzman -
Mid-Atlantic Representative Amanda Potterfield, Esq.
Friends of the Earth, Inc. P.O. Box 384 208 West 13th Street Village Station-New York, New York 10011 New York, New York 10014 f
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a e *e 4-3- i Ruthanne'G. Miller, Esq.
j; . Atomic Safety and Licensing Board i Panel U.S. Nuclear Regulatory Commission i.
Washington, D.C. 20555 4
I Mr. Donald Davidof f i Director, Radiological Emergency Preparedness Group r Empire State Plaza l Tower Building, RM 1750 Albany, New York 12237 d
Paul F. Colarc '.
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!e POST EXERCISE le iw ASSESSMENT !e S99999999999999999999999999999996 Mfd @{'lf>
E ixercise o" the New Yori State and h
Wes"cles"er, Jutnam, Roc ( anc anc Orange Coun"les Racio ogica Emergency llans "or l = 'ND AN 37N" N.C. EAR '3ENERATIF3 5"A" CN M AY 2 7,19 8 2 l '
Federal Emergency Management Agency Region 2 FRANK P. PETRON E 26 FEDER AL PLAZA Regional Director New Yo rk, N.Y.10 27 3
()
TA3LE OF CONTENTS
?sge I. INTRODUCTION . . . .. . . . . . . . . . . . . . . . . . . . I
- 1. FEMA Re sponsibilities . . . . . . . . . . . . . . . . . . . 1
- 4. :xercise ever.t. . . . . . . . . . . . . . . . . . . . . . . .
- 3. Exercise Cbjective. . . . . . . . . . . . . . . . . . . . . 2 4 Participating State and Local Organizations . . . . . . . . 4
- 5. Exercise critique . . . . . . . . . . . . . . . . . . . . . 6
- 6. RAC Evaluation Objectives . . . . . . . . . . . . . . . . . 6
. 7. Federal Observer Team . . . . . . . . . . . . . . . . . . . 6
- 3. Evaluation Criteria . . . . . . . . . . . . . . . . . . . . 8
- 9. Remedial Action Procedures. . . . . . . . . . . . . . . . . 8
- 10. Raview and Approval Procedures. . . . . . . . . . . . . . . 9 II. EXECUTIVE
SUMMARY
. . . . . . . . . . . . . . . . . . . . . . . . 10
- 1. Ov e rview. . . . . . . . . . . . . . . . . . . . . . . . . . 10
- 2. Summary: State Ac tivitie s. . . . . . . . . . . . . . . . . 11
- 3. Summary: Indian Point Emergency Operating Facility . . . . 12 4 Summary: '*estchester
- County. . . . . . . . . . . . . . . . 13
- 5. Summary: Rockland County . . . . . . . . . . . . . . . . . 14
- 6. Summary: Orange County . . . . . . . . . . . . . . . . . . 15
- 7. Sum =ary: Futnam County . . . . . . . . . . . . . . . .. . 17 III. EXERCISE SCENARIO. . . . . . . . . . . . . . . . . . . . . . . . 20 IV. EVALUATIONS AND RECCKMENDATIONS. .. . . . . . . . . . . . . . . 21
- 1. State . . .. . . . . . . . . . , . . . . . . . . . . . . . 21
- 2. Emergency Operating Facility. . . . . . . . . . . . . . . . 24
- 3. ~4estchester County. . . . . . . . . . . . . . . . . . . . . 27 4 Rockland County . .. . . . . . . . . . . . . . . . . . . . 39
- 5. Orange County . . . . . . . . . . . . . . . . . .. . . . . 48
- 6. Putnam County . . . . . . . . . . . . . . . . . . . . . . . 56
- 7. Du t che s s Co un t y . .. . . . . . . . . . . . . .. . . . . . 67 V. CCRRECTIVE ACTION FOR CEFICLENCIES . . . . . . . . . .. . . . . 68 L. Schedule for Correcting Significant De ficiencies. . . .. . 68
9 L
I. INTRODUCTION
- l. FEMA Resconsibilities On Dec embe r 7, 1979, the ?r e s id ent directed the Federal Emergency Management Agency (FEMA) to a s s um e lead responsibility for all of f-site nuclear planning and response.
FEMA's immed iate basic re s ponsib ilit ie s in Fixed Nuclear Fac ilit y Radiological Emergency Planning include:
- 1. Taking the lead in off-site emergency planning and review and evaluation of state and local government emergency plans for adequacy.
- 2. Determining whether the plans can be bmpleuented, based upon observacion and evaluacion of exercises conducted in these jurisdictions.
- 3. Coordinating the ac:{vicies of other involved Federal and volunteer agencies:
- Nuclear Regulatory Commission (NRC)
- Environmental Protection Agency (IPA)
- Department of Energy (DOE)
- Department of Health and Human Services (HHS)
- Department of Transportation (DOT)
- Department of Agriculture (USDA)
- National Oceanic and Atmospheric Administration (NOAA)
- Food and Drug Administration (FDA)
Re pre sen ta t iv e s of these agencies se rve as members of the Regional Assistance Ccomittee (RAC), which is chaired by FEMA.
Fermal submi s s ion of e=ergency plans to the RAC by the sta:es and involved local jurisdictions is, in each case, followed closely by evalua: ion of : hose plans and an ex erc ise and cri:ique. A public meeting is held to acquaint the citizenry with the conten:s o f the plans, answer questions about : hem, and receive suggestions on the plans.
This report is an evaluation of the first joint exercise at the Indian .
Point site, which involved parcicipa:Lon by sca:e, local, and Ind ian Po int Uni: 3 personnel to determine whe:her the radiologi:al energency plans can be is ol em en t e d .
2 9
- 2. Ixercise Even:
A r ad io log ic al emergency exercise was conducted on March 3, 1982, between the hour s o f 6: 00 a.m. (IST) and approxima:ely 5:00 p.m. , :o assess the ad equacy of radiological emergency r e s ponse plans for New York State, We s cche s:e r County, Ro ckl and Co un : y , Orange Coun:y, and Putnam Coun:y, and to :est the s: ace and local capabilicies :o protec: the pub lic in the even: of a rad iological emergency involving :he Indian Po in t Nuclear Powe r Station (I?N?S), operated by the Power Authori:y of the State of New York (PASNY) and located near Suchanan, New York.
- 3. Exercise objee:ive The o f f-s ite exercise obj ec t iv e was :o demonstrate :he re s pon se and capability of :he state and local governmen:s ac cord ing to exis:ing plans, and to demonstrate the emergency response c apab il it ie s that wo uld be brought into play in :he even: of a r ad iolog ic al emergency at :he !?NPS-3 : hat a f fec:ed of f-si:e areas.
The ke y state and local suppor: c apab ili:ie s , as presented in the radiological emergency response plans that were :o be tested, include: '
e The adequacy and capabili:y of implementation of the New York Sca:e, k'estchester, Rockland, Orange, and Putnam coun:ies and the Indian Point radiological emergency plans.
e The capability of the state, counties, and Indian Point
- o no:ify and activate emergency response personnel.
e ~he capability of the counties and the state to aler and notify the af fected permanent and transient po pul a-
- ion wi:hin :he plu:ne exposure emergency planning :ene (EF ) of an incident at the Indian Poin: site and to provide follow-up info:na: ion as required via sirens and the e=ergency b roadcast system (E35).
e *he capabili:y of the normal and back up emergency com-munications among k*e s:che ster, Rockland, Orange, and Pu: nam counties, the state, and Indian Point, includ ing the radiological emergency ccumunica: ions sys:em (RICS) ho: line, e The adequacy o f the s:sf fing and ac:ivation, as appro-pria:e, of emergency response facili:ies, and :he adequacy of space and habitabilley for management of radiologic al emergency 2:: ,
I '.
3
- ndian Poin: 3 Control Room (CR)
Indian Poin: 3 Technical Suppor: Cen:er (TSC)
Indian ?oin: 3 opera:ional Suppor: Cen:er (CSC)
Indian Poin: Emergency Operations Tacility (ICF) 3:ste E=ergency Operations Center (ICC)
ODP Southern District IOC We stchester County EOC Rockland Coun:y ICC Orange County ICC Putnam County ICC Emergency News Center e The adequacy and compe:ency o f the s: ate, We stche ster, Rockland, Orange, and Putnam counties, and Indian Point 3 staf f to operate the emergency response facili ies, e The ability of key emergency personnel at Indian Point and at all levels of governmen; to ini:iate and coordinate timely and effec:ive decisions with respect to a radio-logical emergency.
e The ability of Indian Poin: 3 staf f :o activate the spe-cial news center in conjunc: ion with sta:e and coun:y agencies and :s provide for periodic release of public information and for runer control, e The counties' ability to deploy radiological field moni-tors and to receive and assess meteorological and radio-logical da:a from both county and utility field :eams, in accordance wi:h their respective radiological emergency plans.
e The abili:y of Indian Point 3 and the state to calculate dose projee: ions, compare projections to pro:ective ac: ion guides (PACS) and recommend appropriate protective actions.
e The capability of the emergency response organizations fo r the state and Westchester, Rockland , Orange, and Putnam coun:ies to make decisions and to hsplement appropriate protective action options. These options include sheltering, (simula:ed) evacuation of on-site and of f-site areas, informing the public on the development of the accident, identification of and provision for special populations, activation of reception and congregate care facilities, and control of ingestion exposure.
e The capability of of f-si:e emergency response personnel to Empl emen: access con:rol procedures.
e The abili:y of Indian Poin: and Wes:chester, Ro ckl and ,
Orange, and Putnam counties to coordina:e, con:rol, and deploy radiological monitoring :eams via :he respective ,
field ca:munications systems.
e Methods for radiation exposure control, including dis-
- ribu: ion of dosime:ers and maintenance of individual wo rker expo sure records.
.. .- -~ _ _
6 s
e Ability to use decontamination facili:ies and to lbsit exposure of emergency workers.
e Capability for providing medical suppor: to radia: ion casualties.
- Capability for bnplemen:ing procedures for (simulated) reentry, d amage asse s sment, and recovery.
4 Particisating State and Local Facili:ies and Organi:ations The principal operating area fo r the exercise was the plane expo sur e emergency planning zone around :he Indian Point si:e, approximately a 10 =ile radius around the power plant. Organiza:Lons and f acilities that were desig-nated to participa:e in the exercise are listed below; during the exercise some of the organizations may have had minimal involvement.
New York State Facilities .
ECCs Albany, New York Of fice of Disaster Preparedness Southern District Poughkeepsie, New York Personnel Monitoring Hawchorne, New York
. enters .
Monroe, New York Coun:v Facilities ECCs Westchester County, White Plains, New York Rockland County, Pomona, New York Crange Coun:y, Coshen, New York
?utnam County, Carmel, New York Dutchess County,* Poughkeepsie, New York Reception / Congregate We stchester County Care Centers Rockland County Orange County Dutchess County Hospitals We stchester County o Peekskill Hospital Crange County o Cornwall Hospi:al o Middle:cwn Hospi:al -
'Outchess Coun:y ICC was ac:iva:ed to prov id e suppo rt :o :he plane exposure EPC coun:ies, such as reception /congrega:e care centers, monitoring and decon:amina:Lon of " evacuees," and :raf fic control.
-e ,
3 Indian Point Facili:ies Indian Point ICF Suchanan, New York Emergency News Cen:er Verplanck, New Yo rk New York State Disas er Preparedness Commission Department of Heal:h DMNA/Of fice of Disaster Preparedness Department of Transpor:acion Division of State Police Departmen: of Agriculture Marke:s Department of Environmental Conservation State Energy Office Department of Social Services Depar:sent of State, Fire Prevention and Control Department o f Education Of fice of General Services Department o f Labor Department of Parks, Recreation and Historic Preservation
- Departmen: o f Men:al Health Department of Correction Department of Criminal Jus: ice Thruway Authori:y Counties
'a'e s tche s t er, Rockland , Orange , and Putnam County Executive Civil Defense Director Commissioner of Public Safety ,
Commissioner of Health Commissioner of Hospi:als Commi s s ioner o f Pub lic 'Jo rks Director, Department o f Transportation Commissioner of Social Services Fire Coordina:or Public Infor=ation Of ficer Radiological Health Specialist Sheriff Volunteer Ambulance Disas:er Coordinator Superin:enden: of Highways Private Agencies and Volunteers A=erican Red Cross RACES (Radio Amateur Civil E=ergency Service)
Conrail MTA (Metropoli:an Transit Au:hority)
Amtrak .
Sus Companies 4
6
- 5. Exercise Cri:icue A prelisinary oral cri:ique of the March 3 exer:ise was conducted at 11:00 4.s., March 6, 1932, a: Cor: land Civic Cen:er, New York.
- 6. RAC Evaluation Objectives General obj ective s of the Regional Assistance Commi::ee (RAC) for the ope ra t ional chase of :he plans were :o ob s e rve and evalua:e the exercise, focu s ing on :he :en func:ional areas lis:ed and briefly described below.
These :en funct ional areas include approxima:ely 75 specific cri:eria :aken direc:ly fersSection II o f NUREC-0634-FEMA REP-1, Rev. 1, which is the basic planning document on which the sea e and local plans, and also :he cri:eria for observing and evaluating the exercise, are based.
Func:ional areas:
e Emergency Operations Facili:ies and Resources.
e Aler:ing and Mobili:ation of Of ficials and 5:aff.
e E=ergency Operations Management, e Public Alerting and Notification.
e Public and Media Relations.
- Acciden: Assess =ent.
- Actions to Protect the Public.
e Realth, Medical, and Exposure Control Measures.
e Recovery and Reentry Opera: ions, o Relevance of the Exercise Experience.
- 7. Federal Cbserver Team A 50-= ember of f-si:e Federal Observer Team was es:ablished by :he FEMA Region II RAC Cr. airman for observing the response a: Indian Point. Ob s e rve rt included:
\
l 1
7 l l
l Cb se rver Agency Loca: ion /Func: ion F. Petrone FEMA (Regional Direc:or) Oversigh: Re s po ns ib ility R. Kovieski FEMA (RAC Chairman) Oversigh: Re s ponsibili:y S. McIn:osh FEMA State ICC/ Team Leader N. Steinlauf FEMA Sta:e ECC J. Feldman IPA State ECC/Acciden: As se s smen:
M. Adler DOE State ECC/P.I.O.
J. Johnson TEMA S. Distric: ICC/ Team Leader W. Pierson FEMA Indian Point ICF/ Team Leader
- 3. 3 ores NRC Indian Point ECF J. Harrison NCAA Indian Point EOF M. Jackson FEMA News Med ia Center /P. I.O.
L. Dillon FEMA News Media Center /P.I.O. l S. Glass FIMA Westchester ICC/ Advisor G. Connolly TEMA Westchester ECC/ Team Leader R. Bernacki )
7DA Westchester ECC/ Accident Assessmen.
J. Kelly FEMA Westchester ECC/Com=unications K. Lawrence FEMA We stchester ECC/P. I.O.
D. Tin sman DOT,USCO Westchester Co./Evacua: ion J. 3ravo FEMA We stchester Co./ Evacuation F. Fishman FEMA Westchester Co./ Evacuation C. Rod rigue: FEMA Westchester Co./ Congregate Care W. Casper ANL' Westchester Co./ Radiological Moni:oring J. Keller INE L** Westchester Co./ Radiological Monttoring R. Jones FEMA Westchester Co./ Medical P. McIntire FEMA Putnam ECC/ Advisor T. Maynard FD'.A Putnam ECC/ Team Leader K. Gant DOE Putnam ECC/ Accident Assessnent H. Rand FEMA Putnam ECC/P. I.O.
T. Hollid ay FEMA Putnam ECC/ Communications J. O'Sullivan FEMA Putnam Co ./ Evacuation M. Kaplan ANL* Pu: nam Co./ Evacuation C. Nichols INEL** Putnam Co./ Radiological Monitoring J. 3 atis ANL' Putnam Co./ Radiological Moni:oring J. Picciano FEMA Rockland ECC/ Team Leader i
M. Goodkind ANL* Rockland ECC/ Accident As sessment R. Garclik FEMA Rockland EOC/Coc=unications G. Se id en fe ld FEMA Rockland ECC/P. I.O.
P. Lucc DOT,USCG Rockland Co./ Evacuation R. Hellriegel FEMA Rockland Co./ Evacuation C. Malin a US DA Rockland Co./ Congregate Care /PMC R. Skinner INEL** Rockland Co./ Radiological Moni:oring J. Tatar ANL* Orange Co./ Radiological Monitoring R. Re ynold s FEMA Orange Co./ Team Leader E. Levine ANL' Orange Co./ Accident As sessment .
A. Davis FEMA Crange Co./Com=unications C. Cart:on FEMA Crange Co./P.I.O.
H. Fish DCE Crange Co./ Evacuation
o .
O Ob se rv er Ag ency Loca:icn/ Func:Lon P. '.*e b e r g FEMA CranZe Co./Evacua: ion L. Ho f fman INEL** Crange Co./ Radiological Moni:oring L. Lewis ANL* Orange Co./ Radiological Moni:oring
- Argonne National Labora:ory (under contrac: to FEMA)
- 1daho National Engineering Labora:ory (under contrac: :o FEMA)
In addi: ion :o :he Federal Ob server Team, utili:y's con:ractor personnel and visitors observed the exercise.
- 3. Evaluation Cri:eria Major fune: ions witnessed by federal observers were evalua:ed in accordance with :he following scheme:
e Capabili:y outstanding: no deficiencies noted, no improvement s necessary, e Capabili:y good: only sinor deficiencies no:ed.
. Capability acceotable: deficiencies no:ed that lini:
ef fective performances.
e Capability weak: significant deficiencies noted.
e Capability lacking: response called for but not d emon s:r ated .
- 9. Remedial Action Procedures Provided under Part IV of this report are evalua: ions and re c t==e nd a-
- ions for remedial ac: ions. The se evaluations and recommendations are based on the applicable pl anning standards ( fr om which the sca:e and lccal plans were developed) and evaluation criteria set forth in See: ion II of NUREG-0654 FEMA RIP-1, Rev . 1. Other recemmendations are suggested that are not keyed to NURIC-0654, but which could improve opera: ions.
In this report, reccenendations are presented and are ke yed to the state and local jurisdictions. S a:e and local jurisdic: ions should subsi: to FEMA 4 description of the corrective measures they have taken and a schedule for the ones to be cad er:ake n. If r e=ed ial actions cannot be insti:u:ed i==e d i a t e l y , then a de: ailed schedule for i=pl emen t ing remed ial ac: ions sus:
be provided :o FEdA, including dates for cr=pletion.
9 The Regional Director of TEMA is responsible for cer:ifying to :he TEMA Associate Direc:or, State and '_ocal ?;o g emns and Su p po r t , *4a shing :o n , D.C., ,
tha: the deficiencies noted in :he exercise have been correc:ed and :ha: such correc: ions have been incorporated in:o the plan.
- 10. Review and Amoroval ?rocedures A sta:e :ha: seeks review and approval by FEMA o f i:s plan and annexes submits an application for review and approval :o :he FEMA Regional Director of the region in which :he state is loca:ed. The application, in the form of a letter from the Governor, or such other sta:e of ficial as :he Governor =ay designate, is to contain one copy of the completed s: ate plan wi:h an indica-tion that deficiencies have been correc:ed.
Upon receipt of a state plan, :he Regional Direc:or initiates the review process as described in 44 CFR Part 350, Federal Register, volume 45, Number 123, Tue sd ay , June 24, 1980 (Review and Approval of Sta:e and Lo cal Radiological Emergency Plans and Preparedness). Af:er the Regional Assistance Commit:ee (RAC) and the FEMA Regional staff have completed : heir r ev iew ,
,inc lud ing the evaluation of the supporting exercise and the pub lic meeting required in proposed 44 CFR Par: 350, the FEdA Regional Director will issue a r e po r: to FEMA Headquarters regarding the state and local government pl an s ,
procedures, and preparedness capabilities. This r e po r will consist of a sis: mary of the overall find ing s and de te rminations in respect to the pro-cedures, training, resources, staffing levels, qualifications, and equipment availabili:y. The FEMA As sociate Director is to conduct such review of this re por: as deemed necessary prior to its being forwarded :o :he appropriate NRC licensing bodie's.
l .
4
10 II. EXECUTIVE SO'. MARY A join: exercise of the e=ergency preparedness
- plans fo r :he Indian Po in t si:e was held on March 3,1982. The o ff-si:e exercise was observed by a team of 50 federal observers, who re po rted their finding s to :he Fed er al Emergency Management Agency (FEMA). Participating in the exercise were the owner of Indian Point Uni: 3, Power Authority of the State of New York
(?ASNY), of ficials and agencies of the State of New York, and the countias o f
'Je s tc he s t e r , Rockland, Orange, Putnam, and Dutchess.
Emergency response facilities observed by TE'.A inc lud ed :
e the Indian Poin: Emergency Operations Tacility (EOF);
e the sta:e Emergency Operations Center (ECC) i:f Albany; e the state IOC in :he Of fice of Disaster Preparedness, Southern District; e the ~4es:chester County ECC; e :he Rockland County ECC; e the Crange County ECC; e the Putnam County ECC; e the Dutchess County IOC; and e :he Emergency News Center in Verplanck.
The Dutchess County ECC also chose to participate in the exercise, although i: is not within the 10-mile emergency planning zone.
Evaluators also observed procedures at pe r sonnel =onitoring centers, a: rec ept ion / cong reg at e care centers, and at hospitals -here simulated acci-den: victiss were treated.
Over 50 sea:e, local, and private agencias and depar:sents participated in the exercise.
- 1. Overviev During the review of the ex e rc is e , each of :he ten func:ional areas d e sc rib ed in sec:Lon I.6 were evalua:ed fo r the state operations and each of the four mun ic ipal counties' operations (except Dutchess). At the sta:e level, all observed fune: ions were carried out well; only sinor deficiencies were noted. A=ong the four counties, nine functional areas we re ev alua ted v -,
11 as vesk. The se deficiencies, positive areas of perfor=ance, and corree-
- iv e reces=endations are detailed in the su=maries provided belev and in the following pages.
Several concerns were id en:ified during :he exercise :ha: in flue nc ed the evaluation of that el emen: . Some of :hese concerns are iden:ified belev.
e The pr!=ary means for aler:ing the populace to a serious radiological e=ergency will be a sys:em of sirens. This sys:em is now being installed and is :o be :ested by :he licensees. The existing sirens were ac:ivated during the exercise, but some of the units did not sound or were inaudible :o local residents. The backup system of no:i-fication by sound trucks (police / fire : ucks equipped with public address systems) was not used, e Rockland Coun:y's police, fire and volunteer ambulance corps initially chose not to par:icipate in :he exercise, claiming : hat inadequa:e training had been provided. Dur ing the exercise these groups participated, but to a minimal extent. :hereby reducing :he training benefit of :he exercise and the ability :o fully evaluate :he county's preparedness.
e The effec:iveness of the exis:ing radiological public educa-tion program should be strengthened. Currently, public education on radiological e=ergency procedures relies on distribution of pamphlets to residents. Concerm remains as to the level of public awareness and response. The se concerns include :he public's understanding of the concept and geographical boundaries of planning zones. Also, the level of awareness o f the non English-speaking residents living in :he area should be analyzed.
- 2. Su=marv: State Activities Emergenev Osera: ions Facilities and Resources. Fa c il it ie s and resources in the state ECCs in Albany and Poughkeepsie were good. Di s pl ays were wil placed and promptly upd a t ed . Scme additional plo::ing of dose calculations is recommended. The cocmunica: ions be:veen s:a:e and local ac c id en: assess =en: :eams we re we ak . In:ernal commun ic at ions and ;ublic in fo r:stion arrange =ent s were good.
Alertin: and Mobilica: ion of Of ficials and Staf f. All mobilization ,
ac :iv i:ie s func:Loned well.
12
!sergenev Ceera: ions Manage =ent. Manag ement of the response organica-
- ion was well demonstrated. increased flow of informa: ion in both directions between agencies and decision-makers would be beneficial. ,
Public and Media Rela: ions. At :he sca:e ECC in Albany, press facili-ties and =edia briefings were good. At the Join Media Cen:er, the state ?!O staf f demonstra:ed good capability.
Accident Assessment. Acciden as se s sment c apab ilit ie s were good.
' dove v e r , :he sta:e did not demonstrace : heir own independent field moni:oring capabill:y. Some additional cemputational aids would be of value.
Recoverv and Reenerv. Sho r t- t e rs and long-:ers recovery and reentry procedures appeared to be good.
Relevance of :he Exercise. Par:icipants felt that the exercise was b ene fic ial for training and experience. Use of simulated seteorology and the rapif pace of scenario events detrac:ed somewhat from :he realism of the exer:ise.
- 3. Su=marv: Indian Point E=ergenev oeerating Faciliev (EOF)
Emergenev Ooerations Facilities and Resources. The EOF in 3uchanan had acceptable capabilities; however, space was limited and inconv eniently .
arranged. in:ernal and external commun icat ion systems could be impr ov ed .
Alerting and Mobilization of Of ficials and Staf f. Staffing and notifi-cation was acceptable. Addi:ional feedback from the state and counties to the EOF would be of benefit.
Emergency Ooerations Management. Manag ement of the res po nse wa s good for state representatives and acceptable for the county representatives. Mo re involvement of :he state and county in decision saking is recem= ended.
Accident Assessment. Ca pab il it ie s in this area were acceptable.
Compu:ing capability for rapid response is recec= ended. 1sprov ement is needed in use of sonitoring data.
Relevance of the Exoerience. The exercise was fel: :o be beneficial :s
- he participan:s.
13 4 Su :=arv: Ves:chester Counev
!=ergenev 0:erations Tacili:ies and Resources. The facili:ies a:
the Wes:ches:er Coun:y ICC vere good overall. Se wo rking space was small bu: adequate because of the l a yo ut . Co==un ic a t io n , in:ernal and ex:ernal, was good. 3ackup RACIS ce==unica: ion capabili:7 was de=onstrated. Displays and =aps' were veil organi:ed and security was good.
Alerting and Mobilization of Of ficials and Staf f. We stches:er- County de=onstra:ed a good capabili:y for aler:ing and =obilicing of ficials and staf f in a :i=ely =anner. This resul:ed fro = good co==unications and fec= adequa:e procedures and backup personnel. Be capability for 24-hour alerting and 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> a day operation was good. Sere is so=e concern over :he av a il-abili:y of enough personnel to adequately s:aff :he reception centers if an ac:ual emergency s:arted on a weekend.
E=cegenev Oeera: ions Manage =ent. E=ergency operations management, headed by :he County Execu:ive, was very good, and demons:ra:ed well-defined leadership a: several levels. ~h e staff was kep: vell in fo rmed through periodic brie fings by the leaders.
Public Alerting .and Notification. Public alerting and notification ac: ions were weak, due primarily to the unsa:isfae:ory per fo rmanc e of the siren system. Lack of understanding by so=e of the populace of the meaning of
- he sirens; lack of knowledge of the e.ergency response planning areas (ERFA);
and lack of adequa:e notification of transients were observed. De procedures for broadcasting E35 =essages were very' good; E3S messages were well vri::en and ti=ely. Activation of E3S station and issuance of first ESS message vere excellen:.
Public and Media Relations. De public and =edia relation actions were a c c e p t ab l e , however, pub lic education progra=s and r .:= c con:rol procedures i
need i= p r ov e= e n t . Public educa: ion pa=phlets were = ailed and received by race payers, but apparen:1y were not effec:ive, because the public as a whole seemed to have a general lack of kncvledge of radiological e=ergency prepared-ness. People who do not pay utility bills directly, such as sc=e tenants, may ,
not hav e rec eiv ed the pa=phle:s. !=ergency informa: ion was not po s t ed , nor was i: printed in :he :elephone book.
Acciden: Assess =ent. Ac cid ent assessmen: c apab ilit ie s were ev alua ted as acceptable but so=e deficiencies are no:ed. Be rad iolog ic al assesscen:
i l.
o ,
la
. i t
ins: umen:a: ion was good, except t h.a : the ins:rumen: used for measuring r adiciodine should be equipped vi:h a silver-con:aining air fil:er. ?ro-cedures for quickly measuring con:ssination in licuid samples are needed.
?rojec:ed dose :alcula:Lons were good, and field moni:oring :eams were vell
- rained and casable. *he abili:y to recommend protec:ive ac: ions based on :he l peatec:ive ac: ion guidelines was well demonstrated.
- Actions to protect the Public. Overall, the '4e s:chester County person-nel demonstrated an accepcable capability to protect the public by i=plemen:-
ing protec:ive measures. Improvementa are needed in the details of the procedures for reloca:ing residen:s Wo do not have pr iv ate vehicles, in protec:ing mob ility-impair ed persons, and in dealing vi:h po:en:ial imped i-ments :o evacuation.
Health. Medical. and Exoosure Control. Mo st of :he health, medical, and exposure control capabili:les were weak. Th e 24-hour capability to determine exposures of emergency workers was weak because of inscrtscentation problems, vnile decon amination procedures were weak primarily because of a l ack of adequate vaste dis po sal , especially for liquid vastes. Control of access to evacua:ed areas was good, and maintenance of dose records was good. Action levels that require decen: amination procedures were vell established.
Recoverv and Reenerv Oserations. Simulated reentry operations made it appear :ha: the capability to recover and reenter exists.
Relevance of the Exercise Exoerience. Participants felt that the exer:ise was a good learning experience.
i
- 5. Su==sev: Rockland Coun:v Emergenev Oeerations Facilities and Resources. The facilities at :he Rockland County EOC vere weak. Significan: deficiencies were no:ed ' rela:ing to ex:ernal and internal cemmun ic a: Lons , leadership in- the ECC, and space al'ot: men:.
Aler: int and Mobilization of Officials and Staff. Th e c apab ilit y for ' alerting and mobilication of s:af f frem the IOC vas weak. Oe fic ienc ie s were no:ed related to :he lack of telephone lines and staf f :o perform ini:ial c al l in g . Backup staff was also lacking. Cv e r a *. i i=provement in cecmunic a-
- ions is needed.
i b
t
.o ,'
13 Emercenev ceerations Manarement. Organi:a:ional :en:rol, leadership, and decislan making vere acceptable. F.o vev e r , e f f ec:ive management of :he EOC by one individual was no: demonstra:ed. Mo re f amiliari:y is needed vi:h response procedures.
Public Alerting and Notification. Initial notifi:ation of :he pub lic was weak, primarily because of siren sys:em malfune: ion. Ac tiv ation o f :he E33 station and issuance of the first E3S message were well coordinated.
E35 messages were professionally coordina:ed, cleared, and issued.
Public snd Media Relations. Media capabilities were acceptable, ,
However, pub lic awareness of a pub lic education brochure was lov. Rumor con:rol needs to be streng:hened. There may be a need to translate the brochure in order to reach non-English speaking individuals.
Acciden: Assessment. Ac c id ent assessment capabilities were weak. Poor communication systems contributed to problems in this area. Field monitortng teams need more : raining with their in s t et:ne n t s . The role of the codn e y representative at the ECF needs to be better def ned.
Ae: ions to Protect the Public. Ca pab ilit ie s for protection of the public were good. Ev acua t ion and decontaminat. ion were well , demonstrated .
Health. Medic al, and Excosure Control Me. tures. These ac t ivit ie s were well demonstrated. Facilities were good and well staf fed.
s
+
Recoverv and Reentev Ooerations. The capability *,o f the ECC for recov- ,
ery and reentry was good, as demons: rated by simulation. Ac :iv it ie s in the field were not observed, due to the shortness of the scenario.
~
Relevance of the Excerience. Iack of involvemen: by some local agen-cies reduced the ef fectiveness of the exercise. The inclusion of a simulated vind shift in the scenario was good, but the county's cceputer analys'is sya'.em I
was not used during the exercise.
^
Th e exercise id en t i f ied areas tha: vould benefi: from additional training and be::er equi; ment. /
- 6. Summarv: Orance Countv ,
E=errenev 0:erations Tacill:ies and Resources. ~he f a:ilit ie s a: the Orange County Emergency Opera:ing Cen:er (ECC) were ev aluat ed as ac c e pt ab le .
O i
f p- ;1
, /
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) . ,
16 Some d e fic ienc ie s were noted, par:icularly wi:h :ne e cc=un ic a: ion sys:em
, linking Orange County wi:5 the other coun:les. In:ernal communica:Lons
, sys: ems could also be im p r ov ed . Maps and displays were generally good.
Acceptable securi:y was provided.
Alerting and Mcbilica: ion of Of ficials and Staf f. The overall capa-bili:y for slerting and sob iliza t ion wa s evalua:ed as .e ak , based upo n a deficiency in :he key element of 24-hour shift change capabili:y. 3ackup personnel did no: demons:ra:e suf fic ient knowledge in all essential areas.
The remain ing elements in this category were in general adequately d eson-strated, although poor commun ic a: ions between ag enc ie s in :he ECC led to dif ficulties in es:ablishing access control points.
Emergenev Ooerations Management. Org anica tional con:rol, lead er ship ,
decision saking and suppo rt by officials were acceptable. Pe r fo rmanc e was a f fec:ed by internal commun ic a t ions in the ECC, which depended upon hand-carrying messages between rocas in the facility. 3r ie fing of agencies was s poradic and wri::en updates were not always available.
Reception cen:ers, congregate care f ac ilit ie s , and :he decon:amina: ion cen:er were well staf fed and organized.
Public Alerting and No:ification. Pub lic al er t ing and no:ification
- we re weak, dve primarily to the unsa
- is f ae:o ry per fo rmance o f the siren system. The E3S was activated in a timely manner. Tae first E3S message was coordinated wi:h :he siren sound ing. Procedures for issuing E35 sessages were
. good.
- Public and Media Relations. The c a pab il it y fo r d eali.sg wi:h :he sedia was good. Rumor con:rol need s :o be streng:hened. Pub lic educ a:ic a programs also should be strengthened.
l, Accident Assessment. Ca pab ilit ie s fo r ac c id en t assessment were r ated as acceptable. De fic ienc ie s no:ed inc lud ed :he failure of the field
(
moni:oring :eams to carry f ull inscri.:sen:ation.
i Actions to Protect :he Public. Means for sheltering or evacuating ,
- he public were evaluated as good. All observed facili:ies were well staf fed.
j; '
'.a ck o f d at a on r adiciod ine levels in :he field were believed :o affect E
l decisions for public protec: ion.
I -
l l
17 Mealth. Medi:al, and Exoosure Control Measures. Procedures for medi:al trea: men: and exposure con:rol were evalua:ed as acceptable. Oe fic iencie s noted includ ed :he lack of provision for d is po sal of con:amina:ed was:es.
Mospital personnel need addi:ianal : raining. Permanen: dose recording ins:ru-ments vere ac: available for emergency wekers.
Recoverv and Reen:rv. Recovery and reen:ry procedures were evaluated as weak. ~he significan: deficiency related :o :he lack of full simulation by par:i:ipants.
Relevance of :he Exoerience. De exercise seemed to provide an ac:eptable level of experience. One drawb ack noted was tha: some r e s ponse teams were not fully :ested, wh ile others were :ested on skills that were considered rou:ine.
- 7. Summary: Pu: nam County E=ergenev Ooerations Facilities and Resour:es. We working space in the ?u:nm County ECC was cramped, which resulted in some minor discemfort to
- he s:aff. Se overall func:ioning of :he ECC was good in spi:e of the small si:e, because the managemen: was good. Communication systems were good, and had good backup.
Alertina and Mobilization of O f ficials and Staff. Putnam County deons::a:ed an acceptable capability for alerting and mobilizing officials and staff. ne procedures used would have been ef fective at any time during the day or night, and resul:ed in a pr mpt and timely ac:ivation of :he ECC 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 exhibi:ing lis:s of backup personnel. Bis shif: change revealed : hat two key people,
- he CD Direc:or and the radiological defense (RACET) o f ficer, do not have adequa:e backup. An emergency generator was not available in the event of power f ailure.
E=errenev Oseracions Manaremen:. De managemen: of the Putan County EOC was very good and was well supported by elec:ed officials. Many specifi: -
or.canizations had veil-defined roles and demonstra:ed good performance.
ieadership was ex: ellen: and suppor: by :he RACES organizacion was excellen:.
13 Public Alertine and Notifica: ion. Public alerting and notification were weak, due pr imarily :o :he un sa tis f ac to ry pe r fo rmance o f the siren sys:em. A::iv a: ion of :he E35 s:2: ion and issuance of firs: ISS =essage were good. C:her I3S =essages were cleared and issued on a :imely basis.
Some route aler:ing by police and fire vehicles was simulated but no PA announce=ent s we re made. De ficiencies were noted in :he ability :o no:ify :he
- ransien: population.
Public and Media Relations. *he c apab il i:y for pub lic and =edia rela: ions in Putnas County was acceptable overall. Public education brochures were = ailed :o :he pub lic , and pub li: : raining courses were given by :he fire depar:=ent and RACES personnel. Nevertheless, :here appears to be a need for addi:ional educa: ion :o help the public understand protec:ive actions and IRPA :ones. The PIO o f ficer had good access to all infor=ation, and prepared
- i=ely and appropriate releases. There was no evidence of a coord ina ted e f fo rt :o identify and control umors.
Acciden: Assess =ent. Ac c id en t as se s sment capabilities were ev alua ted as acceptable; however, some deficiencies were noted. Ini:ial proj ec tions o f radiological exposure were made independently in a :5ely manner and confirmed the utili:y projec: ions. Field moni:oring :eams were peceptly deployed , and were very competent. The ins trument atio n fo r who le body g amma ray wa s g ood .
However, there was no capab ill:y for =easuring rad ic iodine. Silver-load ed filters are needed to provide capability for =casuring radioiodine.
Actions to Protec: the Public. Putnam County d emons tr a:ed a good capability to protec: the pub lic . Ro adblocks we re se: up pe cesp ely . Orders were given in a ti=ely =anner for the a:: ions to simula:e sheltering and : hen evacua: ion. A bus lead of stud ents was evacuated (in ac tuali:y) :o the congrega:e care center in Dutche s s Coun:y. *h i s wa s we ll done . ~he c o cg re-
' ga:e care cen:ers were well located , well staffed, and well equipped. Th e ir procedures were good; however, the radia: ion =onitoring personnel could b ene fi: from addi:ional training.
Meal:h, Medical, and Excesure Control. Overall, the health, =ed ic al , ,
and exposure con:rol actions were ac:eptable, wi:h :he exception o f :he proc edur e s fo r ultisa:e d is po sal of co n:a=in a t ed liquids. Direct reading l
l
=
19 dosize:ers supplied to emerg ency workers had appropria:e ranges and sensi-
- ivities. Re ad in g s were made and recorded frequen:1y, and the resul:s r e po rt ed by radio :o :he ICC. No permanent-record dosineters e re provided.
Procedures for approval of exposure of emergency workers in excess of protec-tion action guides need :o be clarified. Action levels for decontasination peacedures were known.
Recoverv and Reeneri 0:erations. Reen:ry opera: ions were desonstrated by simula:Lon only. An acceptable capabili:y for reentry and recovery appears to exist.
Relevance of the Exercise Exoerience. The re was un an i.sous ag reesen:
- hat :he exercise was very beneficial to :he partictpants, all of wttom took
- he exercise very seriously and per fo rmed as if the powe r plant ac c id en:
actually occurred.
1 4
9
- --a.- , . . . . , , = - . . . ,. - - -
20
- . EXERCISE SCENARIO The scenario provided a simul a:ed series of events on-si:e :ha:
resul:ed in .all four classes of emergency condi: ions being declared. In : urn,
- hese condi: ions :riggered of f-si:e response cc ions (or simula: ions).
An overv iew of the sequence of emerg ency cond it io ns , maj or ev en:s ,
and : heir approximate. :imes of occurrence is sunmariced below.
EVENT TI}'E (EST)
Notification of unusual event 735 Notification of aler: 3 15 District Of fice begins staf fing 330 Notifica: ion of site-area emergency 906 counties ac:ivate all emergency workers 9 15 Activa:e emergency news center 920 No: ice to 3rewster congregate care cen:er 1002 Sirens activated 1012 ESS message aired 10 15 General emergency declared 1025 Reac:or shuts down aut:matically 1030 3rewster congregate care center fune:ional 1030 Sheltering of selec:ed ER?AS ordered 1055 Sta:e emergency declared 1134 ISS message of general emergency 1150 Evacuation ordered for ERPA 16,13 1153 Evacuation ordered for ERPA 1, 2, 7, 3 & 44 1200 Wind shift 1215 Sheltering ordered for ER?A 24, 26, 45, 46 1215 Downgrade to site area emergency 1509 Simulate elapse of 3 days Implemen: recovery procedures 1553 Exercise terminated 1615 The :imetable of exercise events was for the most part withheld from j o f f-si:e participants. However, the exercise date and the general time of :he first exercise event was known, since demons t ra t ions of response func tions using volun:eers require some advance adminis tr at iv e pr epar a t io ns , such as t ime o f f f rcc wo rk, e tc .
l r .
I ,,, - -. _ . . . - - _ -- _
21 IV. EVAI.UA!!CNS AND RECOMMENOA!!ONS
- 1. 5:ste E=ergenev 0 erations Facilities and Resources ICC facilities a: Albany and at the Southern Dis:ri:: in Poughkeepsie were good , vich c aly =ino r de ficiencie s . Displays were well placed and frequently updated; however, additional maps are needed in :he Albany ICC to show data such as populations in emergency response planning areas (IRPAs) and the location of county field sampling poin:s.
Th e commun ic a tions between state and local acciden: as se s sment teams were weak. Internal communications were good. Pub lic in fo rma: ion arrange-ments were also good.
Re commend a: ion s :
o Communications systems be:veen :he state ECCs and other EOCs should be improved. (Re ference Ni! REC-06fe, II. F.)
e Additional maps for displaying populations within ERFAs ,
and field sampling locations should be provided in the Albany EOC. (Re ference NUREC-06f 4, J.10.a)
Alerting and Mobilization of O f ficials and S:af f The procedures and actions for alerting and mobilization of of ficials and staff were goed. State ECCs were promptly staffed, and 24-hour response capability was de=enstra:ed. RACES operators in Albany were well prepared for providing assistance in notifying emergency personnel. A: the Southern District, computerized calling of emergency workers was a good fea:ure.
Emertenev Oeerations Manage =ent Organization, leadership, and decision making vere good at the ECCs.
Procedures and authority for requesting federal assistance were also good.
However, it appeared tha: there was not enough feedback to agency representa- .
t iv e s from the decision sakers.
22 Re c o= mend a: ion:
e State suppor: agencies should be given more involvement in the exer:ise.
Publi: Alerting and Notification These func: ions were not observed a: :he s: ace ECCs.
Public and Media Relations At the Albany ECC press f acilities, media briefings, and news releases were good. The media spokesperson performed very well; however, some press questions regarding dose rates were not answered immed iately . At Joint Media Cen:er, sta:e PICS and staf f demons:rs:ed a high level of ability. B e sea:e is commit:ed to coord,inating a joint num b er system for suppor: o f rumor con:rol during an actual emergency. A review of county E3S messages and news releases ind i:a:e s that in a limited number of instances information in news releases = ore properly should have been contained in E3S messages. Bis occurrence could adversely ef fect overall PIO opera: ions.
Recommenda: ions:
e In conjunction with county FIOs , criteria should be developed :o determine what type of information will be issued via I3S and what type via news releases.
e Procedures for quickly activating rumor-control
- elephone nt:nbers and procedures should be formalized.
Accident Assessment Ac c id ent as se s sment procedures vere good overall. Mo r e plotting and display of dose calculations and field data vould be beneficial for decision making pur po se s . The state did not de=onstra:e their own independent field
=oni:oring capabili:y. Be field data repor:ed by the coun:y were not suf-ficient for ccnfirmation of dose projec: ions, t.ack o f compu:ing capability slowed dose calculations; however, procedures for calcula:ing doses were ,
adequate.
23 Rec:mmenda: ion:
e Additional calculating equipsen: should be considered to expedi:e dose calculations.
e The sta:e may wish :o consider i:s own field mon::oring capabili:7 which would allov :he state to make an inde-penden: accident a s s e s smen: .
Ac: ions to Protect :he Public Shel:ering and evacuation procedures were not ob se rved at the sca e -
EOC4.
Health, Medical. and Exoosure Con:rol Measures 1 These activi:ies were not observed at the state EOCs.
~
Recoverv and Reenerv l Shor:-range recovery and reentry procedures appeared to be adequate.
I: was more dif ficul: to assess the value o f :he longer-range planning descri-bed by :he state. . Consideration has been giv en :o long-:erm env ironmental e f fects. .
Relevance of the Exercise Exoerience .
Participants fel: tha: the exercise was beneficial for training and for gaining mor+,f amiliari:y vi h :he emergency plan. The use o f simulated meteorology reduced the realism of :he exercise. Some participants also fel:
- he rapid pace o f events in the scenario was not realistic. It was also noted cha: vin:er-time exercises greatly reduced the role of agricultural agencies.
24
- 2. E=ergency Ooerating Facility (EOF)
Emergencv Ooerations Facili:v and Resources The E=ergency Opera:ing Facili:y (EOF) in Buchanan, New York, was evaluated as acceptable, with de fic ienc ie s no:ed : hat wuld li=i: e f fec tiv e perfo:mance.
Space allotted to :he EOF was considered insuf fic ien t , and the evo-level structure was inconvenient. The communicaticas systes in the ICF also needed improvemen:. Backup telephone lines are needed fo r the sta:e and coun:ies. Th e aud ib le intercom sys:em was fel: :o be detri= ental to opera-tions. Internal communications need to be improved to reduce reliance on hand-wri::en messages. Although :he RIC line :o the ECCs allowed good con-tact, little feedback was observed frem the ECCs to the EOF.
Displays and status upd a:e s we re adequa:e bu: li :le information was displayed on sta:e and coun:y ac: ions.
Re com=end at ions :
e More space is needed for ef fective display of infor=ation in the EOF, and a single-floor area would ease communications.
e The cce=unic ations system need s improvement, and backup telepnone lines should br available (Re ference NtlREO-0654, II.F)
Alertine and Mobilization of Of ficials and Staf f Staffing, 24-hour res po nse capability, and alerting capability were evaluated as acceptable, wi:h deficiencies listed below tha: limi:ed ef fec:ive pe r fo rmanc e.
The sca:e and county responses were acceptable.
Feedback of in fo rma tion f cm the state and counties :o the EOF was insuf ficien:. Information on :he s:a:e's evacua: ion ef forts in response to the utili:y rec. senda: ions was delayed. ,
3ackup staf f capabili:7 was adequa:ely demonstra:ed.
25 Recommenda: ion:
e Emprovemen: is needed in :he flow o f information back
- o :he ECF from sta:e and local response organi:a: ions.
(Re ference NLTEC-0654, II.F)
Emergenev Coerations Management The organization, leadership, and d ec ision-making capab ili:ie s were evalua:ed as good for the sta:e wi:h some minor deficiencies, and acceptable for the coun:ies, wi:h deficiencies noted that li=i:ed ef fec:ive performance.
More defini: ion of the county representatives' roles-a: the EOF was needed.
Good brie fing s were held by the utility director. Ut ilit y functions we re per formed very smoothly.
Closer contac: was needed be:veen engineering s:aff at the EOF and at
- he technic al support center to ensure timely and accura:e in fo rmation ex- ,
change. Also, s:ste and county representatives should have been made aware o f
- he basis for REOs messages.
Reccomendations:
e The role of coun:y representa:ives a: the EOF needs better definition. (Re ference NUREG-0654, II.3.6) 1 Public Alerting and Notification These ac:ivities were not observed at the EOF.
Public and Media Rela: ions these ac:ivi:ies were not ob s erved at the EOF other than that the utility public informa: ion of ficer functioned well in providing informa: ion to
- he media center.
Accident Assess =ent Ac cid ent a s se s sment c apab ilit ie s were evaluated as acceptable, wi:h ,
deficiencies no:ed that limited ef fective perfor=ance.
Com=unica:Lon of field moni:oring data :o :he EOF was erratic.
25 3:a:e r e pr esenta:iv e s 4: the EOF communi:sted their dose calculations well :o the sca:e ECCs; however, integrated dose es:ima:es were performed by the utill:y anly. l Recommenda: ion:
e Response :Lse for analy:ing changes in dose calcula: ion parameters should be shortened. (Re ference NUREG-0654, l!.I.8)
Actions to Protect the Public These ac:ivities were not observed at the ICF.
Health. Medical, and Excosure Control Measures These activi:ies were not observed at the ECF.
Recoverv and Reen:rv Ooerations These activi:ies were not observed at the ECF.
Relevance of the Exercise Experience The exercise was felt to be of benefi: to the participan:s.
27
- 3. ~4estchester Coun:v Emergency 0: era: ions Overall, :he f ac ilit ie s , r e so ur:e s , space, in:ernal ccm=un ic a: ion s ,
d is pl ays , and security were good, and only minor deficiencies were noted.
Be 'Jestches:er County emergency operating center (ECC) is located in the Coun:y of fice Build ing , 148 Mar:ine Avenue, '4hi:e Plains, New York. The location in :he sub-basement area provides excellen: protection and security for :he emergency workers.
We small working space in the ECC was adequate because it wa s d iv id ed into four wo rk areas. Se parate rooms are provided for radio cocununications, for the accident as se s sment fune: ion, and for management personnel. The four:h room was the large outer room. This con:ained work : ables for the many agency par:icipants and provides wall space :o display maps, s:atus boards, etc. Some o f the observers considered this outer main room to be too crowded.
One thought :ha: the noise level was too high. All four of these rooms were well lighted and well ventilated.
ne overall per fo rmanc e of the several communications systems was good. A dedica:ed executive hot line was used between state and local govern-ments, vich the exception of Orange Coun:y. The Orange County executive hot line was no: functioning because of equipment problems. Backups for the sys:ec were a radio network, the commercial telephone, and the RACES sys: ems.
Th e bulk of the commun ic a tions from the EOC was sent. by commercial
- elepnone (notification, transsiccing orders to county workers, etc.). Excess coemercial telephone line capacity was demonstrated to be av a ilab le. Backup for these calls relied heavily on :he RACES sys:em. The RACES organization provided a superb ccm=unications support.
1 Com=unications with federal ager.cies was adequate.
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23 A need fo r be::er cce=un ic a: ions between :he nuclear facility and Ves:chester EOC was identified. The plan: data on release races, seceorole-gical cond it ion s , etc., were not always cecple:e. Sece data bypassed :he coun:y representa:ive a: the ECF.
In:ernal commun ic a c io n s wi:hin :he EOC vere good. Fo r example, messages were promptly logged and d i s :r ib u t ed :o :he proper personnel; plant s:a:us, release data, and monitoring data vere displayed and updated on a sca:us board; and periodic briefings ke pt the entire .staf f well in fo rmed .
Displays and maps in :he ECC vere well organized in general; however,
- he po pulation d is tribut ion sap was av ail ab le at :he ICF ins t e ad of in :he ICC. Some clarification is needed on who has :he responsibility for posting infor=a: ion on the displays.
Th e securi:y was very good because :vo policemen were sca:ioned at :he only entrance :o the ECC. The location of :he security check poin:
caused some inconvenience, since adequa:e toile: facili:ies were not available inside the secured area.
Recommendations:
e The arrangemen: of : ables and :he locations for each emergency worker in the IOC should be reviewed in order to sinimize the Espact of the s=all space on :he operation of the EOC.
(Re ference NUREC-0654, II.H.3) e A dedicated line between :he EOF and the ECC should be installed to Laprove communications. (Re ference NUREG-0654, II.F.1.d) e Orange Coun:y ECC executive hot line should be made opera-tional so that all the coun:y ECCs can communica:e with each other read ily (e.g . , Orange with We stche ster) . (Re ferenc e NUREC-0654 II.F.1.d) e A population distribution map should be displayed in the ICC.
(Re ference NUREG-0654, II.J.10.b) e 3ackup cec =unications systems and procedures should be reviewed to reduce dependence on the causercial telephone system, since this may be overloaded in a real emergency.
(Re ference NUREC-0654, II.F.1.e) e It is recce= ended that workers in the ECC vear iden:ification badges tha: give : heir names, the ir organi:acions ( e.g. , Red Cross, e:c.) and : heir func t io n s , in order to expedi:e the flew o f messages and orders. (Re ference NUREG-0654, II.H.3)
29 A le r t in g and Mobiliza: ion Ves:ches:er County demonstrated a very good capability for aler:ing emergency workers, wi:h only =inor deficiencies noted. Mos: of :he ECC s:sf f had :wo-way adios :o receive the e=ergency calls. Telephone lis:s of backup personnel vere available. Manning of :he ECC was very pr:mpt, and :he arrival of each staf f member was recorded on a special display board.
A county representa:ive was alerted and dispa:ched :o the u:ili:y's ICT in a timely manner. The field radiological moni:oring :eams were alerted and-dispa:ched by . rad io from :he police department headquar:ers. Th e y we r e deployed pec=pely.
Th e several procedures for aler:ing and mobili:ing :he emergency workers were ef fectively demons: rated. These procedures would have functioned a: any :ime during the day or night because of the backup methods of communi-cation. A detailed wr it e-up of these alerting and mobilization procedures should be included in the emergency plan docunent.
A good capability for staf fing the ECC 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day was demonstrated by performing a shif t change at the ,ECC. This was accomplished very, smoothly.
A 21-hour capability for staffing the field monitoring teams was not d emon-s::a:ed; however, each field team knew its , backup personnel.
Th e Social Se rvic e s staff at the ECC noted a potential shortage of personnel for staffing all of the reception centers to the level required in an actual emergency, should :he emergency star: on a weekend.
Recommendations:
e More detailed alerting and mobiliza: ion procedures should be included in the vricten plan. (Re ference NCREG-0554, II.E.2, H.4)
E=ergenev Ooerations Management Emergency operations management a the We s t c he s t e r ECC was very good, with only minor deficiancies noted. The organi:a:icn, con:rol, leader- -
ship, and suppor: by elec:ed officials was good.
I: vas qui:e ev id en: that many specific organizations had been given roles in the overall emergency response. ! hey knev : heir roles and respon-sibill:ies and participated ef fectively in :he exercise.
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30 Leadership was well defined at several levels. Th e Coun:y Executive took sn ac:ive role, and was clearly in charge of :he IOC. Ind iv id ua l orgsni:2: ions (e.g., Real:h, Red Cross) each had their own re pr esen:a:ive in charge of tha: func: ion. Accident a s se s smen: was well staf fed and strongly led.
The staf f was kept up :o da:e by periodic briefings by :he Co un ty Execu:ive and by periodic repor:s by the leaders o f each par:icipating o rg an iza: ion. The ECC used :he emergency classifica: ions used by the utility.
Public Aler: and No ification Some of the actions taken fo r pub lic alerting and notification were acceptable. Those that were weak and in need of subs:ancial imp rovement include pe r fo rmanc e of :he siren sys:em and the abili:7 :o no:ify :he
- ransien: po pul a t io n.
The Ve s:che s ter EOC received the notice of a si:e area emergency and verified i:. A message for the E3S was prepared by the Ves:ches:er PLO in the Jo in t Media Center, and was coordina:ed with the other coun:y and state PI0s in :he EOC. The siren system was then activated. Some observers heard the sirens very well, some heard them to be weak, and some did not hear them at all. No rou:e-alerting activity was reported.
The E3S message folleved the sirens by :hree minutes and was pecmptly broadcas: by the r ad io stations. The E3S messages listed by number the Emergency Re sponse Planning Areas (ERFA) tha: vere af fected by the simulated emergency. Sample checks by observers indicated a lack of public unders:and-ing o f the ERPA zones.
A check of :he schools ind ic a:ed that the majority of them had been notified. However, Lakeland School District was notified but d id not con-tac: :he school distric:s they were assigned to in f o rm . *here was no means established :s verify whether school distrie:s were con:ac:ed.
Mo s: of :he residen:s had re c e iv ed pamphlets d i s t r ib u t ed by the utili:y. Ihree o f the motels and one nursing home visited by an observer t;ere not aware o f the pamphle:s, while others had re c e iv ed : hem. Th e re wa s a lack o f *.:. owl e d g e of procedures for notifying :he ::ansients, especially those in busines s e s:ablish=en:s .
31 A review o f county E35 mese ages and news releases indica:ed that in a limi:ed number of cases in f o rm a:io n in news releases more properly should have been con:ained in E3S messages. All o f ficial emergency pub lic in fo r=a: ion per:aining to public sa fe:y should be broadcas: on I3S. The pub lic has been advised tha: E35 is :he sole source for o f fic ial emergency public informa: ion.
Recommendations :
a Tes: seasuremen:s of sound levels should be made throughou:
the 10-mile EPZ. Modification and/or additions should then be made until the system meets :he notifica: ion requirements.
(Re ference NUREG-0654, II.E.6, J.LO.F) e Rou:e-alerting procedures and messages should be developed to supplemen: the siren sys:em, especially in those areas of low siren-sound levels. (Re ference NUREG-0634, II.E.6, J.10.c) e Intense ef forts should be made :o make the public aware of the meaning of :he siren signals. (Re ference NURIG-0634, II.G.1) e A very complete educational campaign regarding ERPAs should be implemented that includes distribution of de: ailed maps showing these areas. (Re ference NUREG-0654, II.J.10.a, G.1) e Cri:eria should be developed, in conjunction with :he state and the other counties, to determine :he type of information to be issued via E35 and the type to be issued via news releases.
Public and Media Relations Overall, pub lic and =edia relations we re acceptable, with some defi-ciencies no:ed. Public education programs need improvement.
Public in fo rm a:io n pamphlets were mailed to residents recently.
Questions asked the pub lic by FEMA ob se rver s dur ing the exercise confirmed
- a general lack o f unders:anding of evacua: ion cones.
The Ves:chester County public infor=ation o f ficer had access :o all of the info mation available at :he ECC and :he EOF. The informa: ion released was
- i=ely and concise. -e s:ches:er Coun:y was responsible for coordina:ing all
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E33 messages from :he o:her counties.
'h e Jo in t Media Facili:y (JMF) was :he poin: of contac: wi:h the press. D.e JMF d id no:'have adequa:e space or equipcent, including maps and
32
- har:s. It s loca: ion, abou: one site S 5W o f :he plan:, is of sose concern, since under certain vind conditions i: sight be in a con:amina:ed :ene poten-Lally requiring evacuation. *he alterna:ive 'MF location is in Whi:e Plains, and sight not be convenien:ly reached under cer:ain condi: ions, for similar reasons.
3riefings in :he sedia center were not always announced, and no:
all impor:an: briefings were attended by the ?I0s. Fo r ex ampl e , when PASNY announced the si:e area emergency a: 9:20 a.s., only :he utility was present, and at the 11:26 a.s. briefing only ?ASNY and Wes: hester County were present.
A coll-free information nusber was listed in :he PASNY b rochure fo r ru=or control. Two phone numbers were also availab le in Westchester County for referring runor inquiries to appropria:e personnel.
Recessendations:
e Additional public ducation is needed so that the public will unders:and :he locations o f :he areas that are to take protec:ive actions, and vill know how :o carry ou: the protec:ive actions. Consideration should be given :o ascertain whether a significant nunber of people did not receive the pamphlets. If this is the case, ad'ditional dis:ribution should be made. (Re ference NUREG-0634, II.J.10.a. G.1) e A new loca: ion for the JMF, with adequate space and equip-sent, that is outside :he 10-site E?Z, should be es:ablished.
(Re ference NUREG-0634, II.G.3.4) e Coun:y ?!Os should at:end all sajor media briefings.
Accident Assessment Ac cid ent assessmen: capabilities were evaluated as acceptable, vi:h some deficiencies noted. Me: hods for seasuring radiciodine need to be f
improved, and procedures for quickly determining contamination l evels in liquid samples need to be addressed.
Release rates and seteorological data seasured at the plant were l
l used by :he Westchester County accident a s se s sment personnel :o make initial projec::ons o f the r ad iolog ic al exposures expected. *he We s:ches:er ECC had l excellen: =aps and an extensive se: o f ::ansparen: overlays :o help de: ermine l
l these projec: ions. ~he abili:y to calcula:e proj ec ted doses rapidly was de= ens::a:ed.
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33 yield moni:oring :eams were dispatched peceptly by the RADEF o f ficer, wi:h cmmunica: ion provided by :he po lic e rad io . Data frem the field :eams were ::ansmi::ed :o the ECC by radio in a timely =anner.
Le field sonitoring equipment fo r seasuring whole-body g amma-ray exposure ra:es was excellen:, and covered a wide range of potential exposure races. Mo ni:o ring equipmen: for seasuring rad ic iod ine was inadequate, due to :he use of a charcoal filter sedium in the air sampling equipment, which limi:ed its fune:ional utili:y. This fil:er collec:s :he noble gases as well as iod ine. The re fo re , the read ing s do not meet the requirements of NUREG-0 656 The use of a silver ceolice fil:er instead of charcoal greatly reduces :he collection of the noble gases.
The number of read ing s tha: the field teams could make was limi:ed primarily by travel time from one sample po int to another. Nevertheless, if the sampling teams were very e f ficiently deployed, it appears : hat data could be obtained in a shor: c ise , so : hat the ICC could sake an early independent assessmen:.
The acc id en: as se s sment roce in :he ECC was :he central collection po int for field s am pl e s . Sample media were bagged, labeled, and re:urned to the EOC when :he field teams repo rted back near the end of the ex e rc ise .
The acciden: as se s sment per sonnel in the EOC d emonstrated that they could calculate gamsa dose rates and doses from iodine frcm the data :rans-si::ed frem the field : cams. They also demons:r ated an ability to recommend pro t ec :iv e actions based on the protective action guides. These recommended ac tions verified :he s: ate recom=endations.
Recec=end ations :
e Silver ceolite fil:ers should be used in the air sampling equipment that is used for measuring radiciodine. NOTE:
Charcoal fil:ers =ay be used during drills and exercises, but :he silver ceoli:e filters mus: be in the in s:rument kits ready for use in an actual emergency. (Re ference NUREG-0534, II.I.9) e Be sequence of sa=ple poin:s used (rou:es driven by :he
=eni:oring teams) should be carefully chosen to give the saxi=um a=oun: of da:a for use in making the early in-d e pe nd en: assess =ent. (Reference NUREG-0654, II.I.3)
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l e ~he aucher of samples needed for an independent early ass e s sm en:, and :he possible hinderances :o fas: deploymen:
of the field =oni:oring teams, should be reviewed to assess
- he possible need for additional field soni:oring :eams.
(Re ference NU12C-0654, II.I.3) e Procedures should be developed for obtaining the field data measured by the utili:y's field moni:oring :eam in a :i=ely sanner. (Re ference NURIG-06f4, II.I.3)
Accions to Protect the Public Overall, the We sche s t er County personnel demonstrated an ac cept ab le capability to protect :he pub lic by implementing protectire measures. Secte deficiencies were noted : hat limi:ed ef fective performance. Isprove=ents are needed in the areas of relocating the po pul ac e , protecting :he mobili:y-impaired, and dealing with potential impediments :o evacuation.
Police personnel s:affed all but one of :he ::affic control po ints called fo r in the exercise. Traffic control po int "F" wa s s:sffed by ci:y police approxima:ely 40 minutes after the sirens were sounded. Traffic control poin: "I" was staf fed by the State Police 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 30 minutes af ter the sirens were sounded. Traffic control point "C" was no: s:af fed during :ha time tha: :he observer vai:ed a: the location. No explanat ion for these delays was discovered. Police personnel indicated that there say be a lack of enough trained police to staff all of the traf fic control points in addition
- o other duties. Capabili:ie s that were not demonstrated, nor called for by the scenario, but which may be associated wi:h general vehicular evacuation, include capabilities to handle auto accidents, breakdowns, severe road condi-tions, and supply of gasoline.
Bus transpor:ation is extensive in Westches:er County, and is an impor: ant par: of :he evacuation plan, especially for school children and for people without pr iv a te aute=ob ile s . Six bus companies participa:ed in the drill. Five of these had radios in their buses while one depeeded on periodic telephone calls :o :he dispatcher. A :otal of six evacuation rou:es were run vi:5 the buses.
Several problems sur f a c ed during the evacuation tes:s. 3et:er maps and/or instructions would exped ite the evacuation by bus to the recep: ion centers. ~h e use of fix ed s:aps and unc er t ain :i=e s :o pi:k up passengers should be reevalua:ed, especially for those rou:es :ha: use narrow, hilly i
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35 roads. The lack of radio dispatch on some buses say delay :he use of : hose buses once evacua: ion has been ordered. There is a need for sore sub stan:ial pl an s for bus sup po r: -- i.e. , =emoranda o f understanding wi:h bus ccupanies.
Iv acua: ion capabilities for :he sob il i:y-impa ir ed , e s pec ially those instutionally confined, were no: ad equa:ely demons:ra:ed. One bus had a pl a: fo rm for loading a wneel chair, but :he rela:ively long load time and the lack of a radio rescrie:ed i:s usefulness.
Reception centers were located well ou: side of :he 10 mile I?Z.
At the John Jay High School reception center, the facili:ies were good;
- he proc edur es were good; the supplies and equipment "we re good; the staffing sas good; and a capability for 24-hour operacion was simulated by identifying backup personnel. The radiation sonitoring and decon: amination personnel had acceptable instrumentation, but questioning indicated that addi:ional training is needed. v.oni:oring and decontaminat ion actions would be exped ited by additional training in the charac: eristics of radiation, in methods of measur-ing rad ia t io n , in procedures for surveying , and in ac tion levels that require decontamination procedures.
One bus was, routed to the Harrison High School, which was not desig-nated as a reception center fo r this exercise. Ques:ioning of the school scaf f revealed that they were not aware tha: their school had been designated as a reception cen:er in the coun:y plan.
The School Superintenden:'s Office at Peekskill and a: Croton demon-strated an ability to protect the school children by impl ement ing eme rgency procedures in a timely manner.
Recocmend ations :
e Procedures for staf fing traf fic con:rol points in a timely manner need to be reviewed and strengthened. (Re fe rence NUREG-0654, II.J.10.j) e Procedures for dealing wi:h impediments to evacuation need to be developed and exercised. These impedimen:s include au:o accidents , auto breakdowns , severe road conditions, and the unavailabill:y of gasoline when needed. (Re ference NUREG- .
0654, II.J.10.k)
36 e All buses used for evacuation should be equipped with radios for dispa:ching. (Re ference NURIG-0634, II.J.10.g) e 3uses used for evacuation should be supplied better =aps and instrue: ions concerning the routes and :he loca: ion of the reception cen:ers. (Re ference NURIG-0634, II.J.10.a J.10.g) e ?rocedures and equipment for the evacua: ion of the mobility-impaired need to be improved. (Re ference NURIG-0654, II.J.10.d) e Additional ::aining is needed for the reception center per-sonnel who do radia: ion surveying and decontamination.
(Re farence NURIG-0654, II.J.12)
Health. Medical, and Excesure Control Mos: of the measures for health, medical, and exposure control were weak, and significant deficiencies were noted. The 24-hour capability for detersining exposures of emergency workers was weak because of instrumentation -
prob l ems . Th e decontamination procedures were also we a k , primarily because o f a lack of adequa:e waste disposal, especially for liquid wastes.
The policy of the Department of Health of the state of New York is that no potassius iodide will be distributed.
The control of access to evacuated areas was good. Simulated road-blocks were manned in a timely manner by personnel who understood their function.
Exposure of emergency workers was sonitored by self-reading dosise:ers.
Most of these instruments had a range o f 0-200 Rem, and were not suf fic iently sensitive for accurately measuring the allowable exposures. Exposure of 1 Rem is required :o be re po r:ed :o :he IOC. No per=anent-record devices (e.g.,
film badge, TLD) were provided .
Emergency workers were provided wi:h a dose-record card on which
! they recorded dosise:er readings frequently. In addition, field survey i
l workers were required to repo r: their dosimeter readings pericdically to the ICC by radio.
1 Ac: ion levels that require decon:amina: ion procedures were well es:ablished and were po sted. The ac: ion level was 0.1 =Re=/hr.
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37 T r an s po r t a : ion of a r ad io log ic al acciden: vic:is from the plan:
- o a hospi:a1 was well demonstrated. Th e transport was : isely and :he procedures vere designed to lisi: :he spread of contamination and :o make :he decontamina: ion o f equipmen: easier :o accomplish. On arr iv al , :he hospital s:sff demons::a:ed good procedures for caring for the patient.
Decon:amina: ion procedures at the State Po lic e Troop K Headquar:ers were ad e qua t e. However, the liquid contaminated wastes generated by the decontamina: ion were no: properly disposed of. The solid contaminated was:es (e.g. , clothing) were collec:ed for ultimate disposal. Some o f :he soni:oring equipment was in need of recalibration.
Re com=end a: ions :
e More sensitive self-reading dosimeters (e.g. , 0-200 mRec, 0-20 Rem) should be provided to emergency workers.
(Re ferenee NL' REG-0654, II.K.3.a) e Permanent record dosiseters ( e.g. , fil= badge, *!,Ds) should be provided to emergency workers. (Re ference NL~dEG-0654, II.K.3.a) e Methods for permanently disposing of con:aminated liquid and solid wastes need :o be developed for the iecontamina-tion *cen:ers. (Re ferences NUREG-0554, II.K.5.o) e Monitoring equipment should be recalibra:ed periodically
- according to :he schedules set forth in the plan (Re ference NUREG-0654, II.H.10)
Recovery and Reentry Ooerations Reen:ry opera: ions were demonstrated in simulation only, but i:
appeared that the capability to recover and reenter exists.
The county radiation soni:oring teams were kep: in :he field until the simulated radiation levels diminished to near background. Th e acciden:
assessment ceas reviewed the exposure data before recommend ing the beginning of reentry.
Reentry processes were facilitated by the simulated reversal of nu=erous pro:ective and mobilization ac: ions.
Th e congregate-care cen:er had a good und er s t and ing of plans to assist in the reentry.
38 Receccenda: ion:
e Tucure exercise scenarios should provide more time for a detailed reentry activity. (Re ference N'JREG-0654, II.M.1)
Relevance of the Exercise Exeerience Participants fel: :he exercise encouraged : hem to become more familiar.
wi:h :he plan, helped point out deficiencies (which wi[1 lead to resolution of identified problems), was a good learning experience, and provided training for their primary and backup teams. The scenario was considered very :Lnely and of benefi: to most participants.
f
39 4 Rockland County Emergenev Oeera: ions Tacili:ies and Resource The facili:ies of the Ro ckl and County ICC vere evaluated as weak; significan: deficiencies were no:ed, as described in the following paragraphs.
Th e Rockl and County Emergency Operating Center (IOC) is loca:ed in the Fire Training Center in Pomona, New York. Space provided for :he center was adequa:e for accomoda:ing all par:icipa:ing organizations. However, the space allot:ed for the accid ent aesessmen: rocm was cramped, which severely limi:ed the number o f people who could participate in these ac:ivities.
The arrangements for maps and for display of in fo rmat ion were also adequa:e, although upda:ing of some displays of information on the sta:us of the situation was not frequent enough.
External communications we re the weakest aspect of the EOC. Ac t iv-ities in the acciden: a s se s smen: rocm were hampered by a lack of telephones, a poorly-f unctioning RECS line system, and insufficient suppor: staff. A conference telephone in the command room provided an impo r: ant commun ic at io n
- 1 ink, but it d id no t include the utility or the EOF. Contact between the EOF and :he Rockland ECC was established through an open :elephone line, l eav ing only one other telephone in the acciden: assessmen: room for receipt of in fo r=a:io n. This telephone was needed :o receive information that could not be received over the RECS line speaker phone. The State Police field cem= uni-ca: ion was also not effec:ive for transmi::al of messages be:veen the base and
- he units.
Initial internal commun ic ation be:veen :he co==and rocm , the ac cid ent a s se s smen: rocm , and the general operating roce was weak, but improvement was noted as the fay progressed. The of ficial message board was not updated with sufficient frequency.
Good security measures were used at the entrance to the ECC, but :he slom ess in get:ing :he system set up caused :he roem :o re=ain closed until af:er 9:00 a.m., more :han half an hour after :he site area emergency. Some -
security problems d ev eloped vi:hin the ECC during the day due :o the large j nc=5er of press and media representatives allowed in :he roem; however, fed.A I believes :ha: :his wuld no: be allowed in an ac:ual inciden:.
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40 Rockl and Co un:y demons::ated a good capability :o con:ac: federal response organi:2: ions; however, i: was noted : hat the Coast Guard and rail-road were contacted independen:ly by all four coun:ies and :he utili:y, resulting in confused sessages.
Recommend ations :
e Sub stan:ial improve =en: is needed in equipc:ent and pro-cedures for external communica: ion. ":he RECS line sys:em needs :o be made more reliable. Staff suppor: is needed
- o relieve principals frem phoning : asks. (Re ference NL2EG-0654, II.F.1.5) e Considera: ion should be given to allot:ing sore space :o :he acciden: assessment rocm. (Re ference NL2EO-0654 II.E.3) e A procedure is needed for keeping the operations-room staf f better informed. It is suggested :ha: the opera: ion leg be updated frequently and circulated :o provide a chrono-logical record of ac:ivi:ies.
e The plan should be revised to coordinate contact between the counties, the Coas Cuard, the railroad, and other agencies .ttere multiple contacting =ay also occur.
(Re ference Nt3EC-0654, II F.1.c).
Alerting and Mobilization of Of ficials and Staff The capability for alerting and mobiliza: ion of staff from the ECC was evaluated as we ak. Significant deficiencies were noted, as described in :he following paragraphs. .
Ac t iv at ion of the EOC was rather slow, and there was confusion in se::ing up security. Wh il e :he initial re s po n s e was adequate, 24-hour c apab ilit y was not demonstrated for mos: func t io ns . Fo r the rad iolegic al assessment officer, backup wo uld need to be provid ed by the state dis:rict
( o f fice.
l Insufficien: staff was av ailab le for aler:ing and mobilization of l
emergency response personnel. There were weaknesses in ecmmunications due to insufficien: :elephone lines and pe r sonnel to staff them. The po lic e we r e i
i only able :o com=unicate vi:hin : heir evn coun:y, resul:ing in lack of coordi-na: ion vi:h other coun:les.
I Dispatch of a represen:ative to :he IOF was achieved in a timely
=anner.
l l
I l
L
41 Rec ommend ations :
e Addi:ional considers: ion should be given :o staffing of critical positions by backup personnel. (Re ference E" REG-0654, II.A.I.e).
e More ef fective me: hods are needed for inicial call-ou: :o-emergency personnel. (Re ference ETEG-0654, II.E.2).
E=ergenev Ocerations Management Organizational control, leadership, sup po r: by officials, and decision making were evaluated as acceptable, with deficiencies noted that limited e f fective performance, as noted below.
Command and con:rol capabilities were lacking. Ef fective =anagement of the emergency response by one individual was not demonstrated. In some situations, key par:icipants were not no:ified of changes in the statas of the si:ua: ion. In the main operating room, verification of even:s came well af ter
- he cocmand roce received i:s information. Briefing sessions were infrequent.
However, when held they were very good, and their use became more effective as
- he day progressed.
Participants in the exercise had adequate written procedures, but training in their use appeared limited. Prompting by state controllers occurred on a number o f occasions, list:ing the abili:7 o f observers to evaluate personnel capabilities.
The County Executive was involved in the decision process. There was,
- however, some dispute over decision making, e.g., between
- he sherif f and the State Police. Some local officials initially declined to participate in the exercise, citing a lack of previous training, but did par:icipate to a limited degree.
In the field, polic e , the Sheriff, Fire Department personnel, and bus d rivers were ef fee:ively managed. The State Police se: up one road bicek only. 1"h e bus company personnel were well ::ained, but should have radios.
I Re comme nd at ions :
- More ef fective management of the ECC is needed :o ensure efficien: opera: ion. (Re ference E3EG-0654 II.A.l.d) e E=ergency staff would benefi: from more familiarity with l
- he response procedures. (Re ference E" REG-0650, II.A.l.5) l l
l
42 Public Alerting and Notificacion Means for pub lic notification .e r e evaluated as weak. Significant deficiencies were noted, as desc'ribed below.
The E3S system was used effectively. E3S messages we r e concise and t ime l y . However, other aspects o f aler:ing and no:ifica: ion were weak.
Problems noted were as follows:
- a. The siren system was not fully functional, and no backup notification system was evident other than :elephone contac: to facilities such as nursing homes.
- 5. Members of the public calling some o f the emergency center telephone nesbers were told that no infor=ation was av ail ab le,
- c. A check of six local schools indica:d that none had been called by emergency personnel.
- d. Although a brochure had- been distributed to those living within 10 miles o f the plant, members o f the public who were in:erviewed were unaware of any inscrue:Lons. The brochure may also be ineffective for informing the numerous Hispanic residents living within the EP2.
- e. A review of county E3S messages and news releases indicated tha' in a limited number of instances informa: ion in news releases more properly should have b*een contained in EBS messages. - All of ficial public inforna: ion pertaining to public safety should be broadcast on E35. The public had been advis'ed that ESS is the sole source for official emergency public information.
Recom=end a: ions :
e The ef fec:iveness of the inicial public no:ification system needs to be tested to determine whether the siren system will be sufficient or whether a backup notifica:Lon system is needed. (Re ference NUREG-0654, II.E.6.)
e Rumor control method; need to be strengthened. ( Re fe rence NUREG-0 654, II.G.2.c.).
e The public education program should be reviewed to determine whe:her ef for:s are needed to improve i:s e f fectiveness.
(Re ference NUKEG-065a, II.G.2. )
e Criteria should b= developed in conjune: ion wi:h :he s: ate ,
and other counties to de:er=ine what types of informa: ion will be broadcas: over I3S and what :ype will be issued in
- news releases.
43 Public and Media Relacions Med ia capaoilities were evaluated as acceptable. Oe ficiencie s that would li.nc ef fec:ive performance are noted below.
Be public in formation ac:ivitie s were well coordina:ed between :he county ICC and the Media Center. I: should be noted that W sechester County was re s po ns ib le for coordina:ing all ISS messages from the other c oun ti'e s .
Although an infomation brochure had been dis:ributed to the public cuo weeks before the exercise, awareness of it was low. No provisions were made for non English-speaking residents in the area.
Be Rockland County pubtle information of ficer had access to all of the information available at the, EOC and the ECT. Be information released was timely and concise. - 3 ,
^
The Jo int Media Facility (JMT) was the po in t of contact with,the e' press. I:s location, about one mile SS*J of the pl an c , is of some concern, ,
since under certain vind conditions it might be in a contaminated zone.
Be alternative JMF location in '4hite Plains might not be conveniently reached under certain conditions, for similar reasons. Bere was not adequate space or equipment, including maps and charts.
3et e was no evid enc e of coord inate t arrangements to iden:ify and ' ' I control runors. /
Recommend at ions :
)
e Addi:ional public education is needed so that $he public will understand the boundaries o f the areas that are to ,
take protective actions, and know how :o carry ou: the protective actions. (Re ference Nt*RIC-0654, II.J.10.a, G.1) e A new location for the JMF, with adequate space and equip-ment, that is outside the 10-mile EFZ, should be established.
(Re ferenc e NL* REG-0 654, II.G. 3.4) e Procedures should be developed for identifying ;mors and for dealing with them. (Re ference NL' REG-0654, II.G.d.c)
Accident Assessment Acciden: assessmen: capabilities were evalua:ed as weak. Significan:
deficiencies were noted, as described below.
The poor communications system in :he acciden: assessmen: room con:ri-bu:ed :o problems in :his area. One field moni:oring :eam was unable :o communi:4:e by radio. The field data were :elephoned to the EOC, which relayed the data to the ICF. Due to inappropria:e equipment, :he IOF had to call :he ICCs individually :o repeat eLECs line messages. A consisten: dose a s s es sme n: me:hodology had been previously established between s ate and county assessmen :eams; however, slowness in :he com=unica: ion system lessened :he ef fec:iveness of dose estima:e comparisons.
Moni:oring equipment for measuring radiciodine was inadequa:e due to the use of a charcoal filter medium in the sampling equipment, which limited its functional utill:y. This filter collects the noble gases as well as iodine, and therefore the readings do not mee: :he requirements of NURIG-0654 The use of silver zeolite filter instead of charcoal grea:ly 7
reduces the collection of the noble gases.
The field personnel did not demonstrace adequate familiari:y wi:h the field instrumentation. Communica: ion wi:h the central data collection point was dif ficult. Reports of radiation measurements a: ters or background were some:imes not passed on to the other assessment centers. One monitoring team remained 4: one sampling poin: all morning and a: a second point all af:er-noon, so that their plume-tracking ability was not well demonstrated. Moni-l- coring teams ef fectively measured and recorded their individual exposures; however, use of T:.Ds for dose recording would have been easier.
The role of the county representative at the ECF was not well defined.
Informa: ion he received from the county was not passed on to the EOF. Also, che coun:y representative was bypassed by information flowing from the utility i
hotline.
I Reccomendations:
t
! e Silver zeoli:e filters should be used in :he air sampling
( equipment that is used for measuring radiciodine. NOTE:
' Charcoal fil:ers may be used during drills and exercises, but the silver zeolite filters mus: be in :he ins:rumen:
kits ready for use in an ac:ual emergency. ( Re fe renc e .
WRIG-0 651, II.I.9) e An improved coemunications system is needed to suport I assessmen: ac:ivicies and :i=ely use of field da:2.
l ( Re f e r e nc e WRIG-06 5!. , II . F.1.d )
I
45
. Additional training of field teams vould be beneficial to increase their familiarity with equipment and pro-cedures. Responsibilities for field radiciodine esasurements should be clearly defined. ( Re ference NURIC-0654, II.I.3,9) e The duties of the county representative at the ICF should be more clearly defined. (Re ference NURIG-0654, II.C.2.a)
Actions to Protect the Public Ca pab ilities in the ECC for protection of the public were evaluated as good. Only minor deficiencies were noted.
Actions to protect the public we re generally very good. Evacuation planning and execution were demonstrated without any major problems. Co ng r e-gate-care centers per formed in an excellent manner. Be Rockland County Psychiatric Center was well staf fed, large, and an excellent facility for mass care. However, the staf f would bene fit from on-the-job training.
The pe rso nnel monitoring centers we re we ll staf fed, and enployees followed established guidelines. However, workers who were monitoring for rad ioac t ive contamination need better training to prevent the spread of contamination to clean areas.
3us drivers in the evacuation routes vere well briefed, but should be equipped with radios so that they could request additional help if necessary and ebcain updates on plant status. Bus dispatchers had good communication links to the IOC. Backup personnel were available. Ambulance and helicopter evacuation were well demonstrated.
Re c ommend ations :
e Although actions to protect the public were well demon-strated, participation in regular exercises or drills is reccamended to further improve task performance.
(Re ference NURIG-0654, II.N) e All buses used for evacuation should be equipped with radios for dispatching. (Re ference NURIG-0654, II.J.10.g)
Health, Medical, and Excesure Control Measures Health and medical measures were evalua t ed as good; only minor defi-ciencies were noted.
16 The Rockland County Psychiatric Cen:er pr ov id ed ex cellent f ac ill: te s ,
supplies, and equi pmen: . Additional training could i= prove operation o f :he cen:er.
Exposure of emergency workers was monitored by self-reading dosimeters.
Field workers were trained in their use and recorded dosimeter readings at 15-minu:e in:erials. However, no permanen:-record devices ( e.g. , film badge, TLD) were provided. Procedures for obtaining appropria:e authority for emergency exposure of workers were well demonstrated. Cecontamination level guidelines were well displayed. Good decon:anination facilities were avail-able. Food con:rsination =enitoring was carried out at :he ICC.
Scace polic e simulated con:rol of evacuated areas by set:ing up one, roadblock, a less extensive response :han called for in :he scenario.
l Re commend ations :
l l e Cn-the-job training would make procedures ficw more snoothly a: :he congrega:e care centers.
e Use of TLDs or film badges should be bsplenen:ed for recording of doses. (Re ference NUREC-0634, II.3.a.)
f Recoverv and Reentrv Coerations The capability of the EOC for recovery and rentry operations was eval-ua:ed as good; only minor deficiencies were noted.
Simulation of recovery and reentry was we ll carried out a: :he ICC.
Each agency was g iv en specific re s po nsib ili:ie s. No field simulations we re observed, due partly to the shor: duration of the exercise.
Relevance of the Exercise Exoerience The exercise was felt to be of benefit :o county participants. Limited involvement by the local police, fire deparrsen:s, and ambulance teams reduced
- he effectiveness of the ex e rc is e . Re pre sen:a t iv e s fr om these d epar tment s were presen: a: the ICC and gained some experience wi:h emergency operations.
The local police repor:ed : hat : raining and involvemen: of :he police prior to
- he drill had been inadequa:e to allow ef fective participa:Lon.
47 The scenaris's use of a vind shift contributed to the exercise by allowing more ex:ensive decision making. However, the coun:y's computer analysis system was no: used during the exercise to analyze meteorological da:a.
~he exercise demonstra:ed tha: bet:er communication systems are needed in the ICC and that there is a need for bet:er integra: ion and training of local igencies.
Dur ing the exercise, prompting occurred by state ob server s and con-trollers to a degree : hat affected :he ability of federal observers :o make ev alua:lo ns . In most cases it appeared that the prompting was probably superfluous to completion of the activity.
A: the congregate care : enters and in evacuation areas the exercise waa fel: to be of benefit in training.
Re commend ations :
e Future exercises should include more extensive par:ici-pacion by police, sherif f, fire, and ambulance services.
Training needs in these areas should be identified.
(Re ference NUSEG-0654, II. B.9)
~
e Use of actual meteorological data should be considered for at least a portion of the exercise to allow more realistic response frem the accident assessment tearns and to provide additional training benefit.
e 1,ocal agencies need more training and greater involvement in the emergency plan to ensure effee:ive response (Reference NT.*RIC-0 6 54, II.C.4).
e Nonparticipants must be ins:ructed to refrain fece parti-cipa:ing in exercise activities.
j
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t
- .8
- 5. Orange Coun:v Emergenev Ooerations Facili:ies and Resources ne facilities of the Orange County emergency operating center (ECC) were evalua:ed as acceptable overall, at: hough some deficiencies were noted.
ne most significant deficiency occured in' :he area o f communica: ions. his and other deficiencias are further described below.
The Or ang e Coun:y ECC is located in the County Covernment Center, Coshen, New York. Bis facility was somewhat cramped, but provided adequate working space for accommodating all participating organizations. Be facili:7 was parti: toned to reduce internal ::af fic flow. Separate races were used for ac cid en t assessment and for decision making by the county executive.
Incoming communica: ions we r e dispersed be:veen :he commun ic ations room, County Executive's room, and the acciden: assessment rocm. On occasion the limi:ed number of telephone lines and radio facili:ies hampered opera-tions. A breakdown occurred in the executive hot-line which links the counties, temporarily isolating Orange County from the other counties. Field measurement data were r ec eived in the commun ic at ions room because o f radia-tion shielding of :he accident assessment room. Participating field workers, including bus drivers, policemen, and ambulance drivers, had separate radios, ne RACES personnel participated in the exercise, but were not ob se rv ed .
In:ernal communications were accomplished informally, as needed by the various re pr e sentat iv e s . Communication relay depended upon hand-carrying of messages between rooms. Periodic situation repor:s were not prepared. Be principal si:uation board was not always current and occasionally showed conflicting infornacion, and message logs were no: widely available.
Maps and displays were av ailable and well laid out, however, some personnel were not familiar with the annotation used on :he maps. Rad iation dose maps we re cen: rally located on the :able in the dose a s se s sment room.
l Sampling poin:s and relocation centers were well marked on maps.
Securi:y was ad equa t e , provided by Sherif f's Deputies in and outside of the IOC. A personnel checklist was utilized and identification was i checked.
l I
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49 Reccamenda: ions:
e The Orange County ICC should make the executive ho: line opera:ional to facili:2:e the information flov be: ween .
coun:le s .
e Addi:ional :elephone lines or equivalent systems should be provided in the ICC to serve as an additional backup for dedicated phones. (Re ference NURIG-0654, II.F.1.b) e The plan for internal communications and dissemination of information wi:his :he IOC should be i= proved to increase ef ficiency and coordination. Radiological field monitoring data should be transmi::ed directly in:o the accident assessment room.
e IOC workers should be familiarized wi:h disp' lays.
Alerting and Mobilization of Of ficials and Staf f The overall capabill:y for continuous 24-hour emergency res po nse o pe rat ions was evaluated as we ak because of inad equa te training of relief personnel.
All personnel were contacted and mobilized promptly. Each responding organization po s se s sed ad equate staff and quickly established operational r ead ine s s . Backup capabilities we re simulated or demonstrated. However, a serious concern is the proficiency of the relief personnel. An example of
- his was noted with the backup county RADEF o f ficer, who was not fully trained in the calculation of dose rates nor experienced in the use of all equi;zuent resources. In general, the backup staf f was not as proficien: as the primary participan:s. Radiological monitoring teams arrived promptly and were very e f ficien:. These teams checked through the ECC and were dispat:hed within an hour of a rr iv al . Emergency re s pons e organizations, exclusive of traffic control, demonstrated the ability for prompt no:ification. This was evidenced 4: the reception / congregate-care center and the decon: amination cen:er. Each of :hese organizations had ad equa:e communica: ions e quipmen: for alerting response personnel.
Difficulties were encountered in establishing access con:rol po in: s ,
due to poor in:eragency communication in the ECC. Af ter notification, :he .
Sheriff and 5:a:e Police responded promptly. A delay occurred in the ambu-lance : ansport of a "victis" to the hospital. The ac c id en t occurred a:
12:15 p.m. and :he pa:ient arrived at the hospital 2: 1:03 p.m., wi:hou:
com=unication by :ve-way radio be:veen the a=bulance and h'espi:al.
50 Recommenda: ions:
e Provide more ecmprehensive : raining for key backup pe r so nnel . (Re ference N1,* REG-0654, II. A.O e Establish a schedule for additional drills in order to develop = ore familiarity and ef ficiency wi:h procadures and resources.
e Provide additional : raining and resources for communica-tion wi:h field suppor: personnel.
Emertenev ooerations Management Emergency o pe rat ions management includ ing organizational control, leadership, decision making, and support by o f ficials was evaluated as acceptable, with some deficiencies noted : hat limited ef fective performance.
These are no:ed below.
Par:Leipants wi:hin :he main 50C operations roca were adequately organized. Th e EOC floor plan divided ac t iv it ie s among several rooms:
com=unications, accident assessmen:, and county executive of fice. Th i s required the Coun ty Director to divide his t ime among the various rooms.
Operations were on occasion . hindered by we ak in fo rma tion fl ow. In:ernal ecm=un ic ation required hand-carried messages between :he rooms. There is a need for greater communication between ECC leaders and agency par:icipants.
Briefing of these representa t ive s were s po rad ic . Written situation updates were not always available.
Command and control capabilities were evident. All participants *ct ew ,
who was in charge. The Co un t y C"J Direc:or as strued operational control of the ICC. The County Executive responded promptly and clearly exercised his decision-making authori:y. In his absence his deputy was present and in control. The RADEF o f ficer was fully responsible and involved with the direc: ion and execution of all radiological and associa:ed ac tiv it ie s . His ins: rue: ions :o field monitoring teams were clear, and :he teams were ef fec-
- ively deployed.
Emergency re s ponse organiza: ions, includ ing the reception center, ,
congregate care, social se rv ic e s , Red Cross, decon: amination center, fire depar:sent and s:a:e personnel moni:oring : enter were well organized, properly sta f fed and directed. Excellent leadership was noted a: :he congregate-care
s 51 center and the decon: amination center. A: the reception center, four staff members were present, at: hough i: wa s unc l e ar .+t o wa s in charge. All organi-
=ations und er s:and : heir assignmen:s. Vri::en procedures were faticwed.
Re c om=end a tion:
e The divided floor plan within :he ICC requires :ha ef fec:ive coccunication flow and procedures be established to ensure ef ficient management.
Public Alerting and Notification Means for alerting and notification o f the public were evaluated as acceptable, wi:h de ficiencie s noted that limi: e f fec tiv e pe r fo rmance.
The plan fo r ini:ial pub lic notification inc lud ed sound ing of sirens and use of the emergency broadcast system (E3S). The first E3S message was b road c as t by WA3C and local rad io stations. The siren system, however, was apparently not fully fune:ional at all locations, and sirens were not heard at some indoor locations. Alternative notification by helicopter was s tmul a ted .
Transient accommodations such as motels were adequa:ely inf6rmed of the aler:ing procedures.
A review o f county E3S messages and news releases indicated that in a limi:ed number of instances in fo rmation in news releases more properly should have been contained in E35 messages. All of ficial emergency public in fo rma t ion pertaining to public safety should, be b road cas t on E35. The pub lic has been advised tha: E35 is :he sole source for -!!icial emerg ency pub lic in fo rma tion.
Recem=endations:
- More extensive backup systems should be considered for loca: ions where sirens fail to func: ion or where they l may be inaudible :o : hose indoors. Use of bullhorns or rou:e aler:ing should be considered. ( Re ferenc e N1, REG-0 6 5 ?. , !!.E.6) e Criteria should be developed in conjunction with :he s:2:e and other counties to determine t.t.at type o f informa: ion will be aired over E3S and wha: type will be issued in news releases.
- ~ __ _. _
52 Public and Media Relations The publication and coordination o f release s o f in forma: ion we re evaluated as acceptable with deficiencies noted that limit e f fec tive per for-
=ance.
Pub lic in fo rma tion ac t iv it ie s were well coordinated between the ECC and the county PIO at the Jo int. Media Center. Co pie s of E3S messages and press releases were not distributed in the ECC, and runor control procedures were not observed. *4estchester County was responsible for coordination of all E3S messages from other counties.
Th e Jo in: Med La Faeility (JMF) vas the po in: o f contacc with the press. I:s loca:Lon about one mile SSW o f the plan: is of some concern since under certain wind cond itions it might be in a contamina:ed zone. The alternate JMF location is in White Plains and migh: not be conveniently reached under certain conditions for similar reasons. There was not adequate space or equipment, including maps and char:s a: the center.
3riefings in the media esneer were not always announced, and not all impo r tant briefings we re attended by the Plos; for example, when PASNY announced the site area emergency at 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br />, only the utility was present, and at the 1126 hours0.013 days <br />0.313 hours <br />0.00186 weeks <br />4.28443e-4 months <br /> briefing only PASNY and Westchester County were present.
Recommendations:
e Emergency workers in the EOC should be kept better informed of the information being released to the public.
e Press briefings should be announced in advance so that Plos can attend.
e Additional public education is needed so that the public will understand the locations of the areas that are to take protective actions and will know how to carry ou: :he pro-tective ac: ions. (Re ference NUREG-0654, II.J.10.a, G.1) e A new location for :he JMF with adequa:e space and equi;xnent that is outside the 10 mile EPZ should be found. (Re ference
. NUREG-0 634, !!.G.3.a) e Procedures should be reviewed for identifying runors and ,
for dealing wi:h them. (Re ferenc e NUREG-0654, II.G.4.c)
53 Acciden: Assess =ent Capabilities for pe r fo rming acciden: a s se s sment were rated as accept-able, vi:5 defi:iencies noted :ha: limi: e f fec:ive pe r fo rmanc e , as noced below.
A separate room in the ECC was pr ov id ed for accident a s s e s sm e n t .
Staff opera: ions wre ad equa t ely organized and direc:ed. Mo ni:oring :eams were well trained and mobile, but d id no t carry ins:rumentation such as h ig h-r an g e in s e rtsnen t s , 41: hough addi:ional equipment was av ailab le at :he ECC. Monitoring equipment for =easuring radiciodine was inadequa:e due :o :he use of a charcoal filter medium in the air sampling equipment, which limited i:s func:ional utility. . This filter collects the noble gases as well as iod ine , and therefore the readings do not meet the requirements o f NITREC-0654 The use of a silver :eolice filter instead of charcoal greatly reduces the collection of the noble gases. Prempt r e po rt ing of whole-body gamma field measurements to the ECC was observed. Good capability for airborne monitoring was demons: a:ed by deployment of a Civil Air Patrol airplane.
Rec ommend ations :
e Field teams should demonstrate familiarity with instrtanents having response ranges : hat might be needed during an actual event. (Re ference NUREC-0634, II.I.8) e Silver :eolice filters should be used in the air sampling equi;xnent that is used for measuring radioiodine. NOTE:
Charcoal filters may be used during drills and exercises but the silver :eolice filters must be in :he instrumen:
kits ready for use in an actual emergency. (Re ference NUREC-0654, II.I.9)
Actions to Protect the Public Means for shel:ering, evacuation of the public, reception and care, and tran s po r:a t ion wre ev alua ted as good, with only minor de ficiencie s noted.
All ob s e rved facili:ies were wil organi:ed, well sta f fed , and efficiently o pe r a: ed . 'ah il e :raffic control,at reception centers was sufficien: for :he exercise, no special provisions for the mob ility-impaired was ob served .
Th e evacua:!an bus route was well directed, and , a =edical drill was very wil execu:ed.
54 It was fel: tha: :he lack of accura:e means for radiciodine measuremen:
might af fect the decisions to evacuate or shelter.
Recommendations:
e Means for obtaining prompt and accurate field measurements of radiciodine should be specified to provide guidance on protective action decisions. (Re ference NURIG-0656, II.I.9) e Provisions for care of the handicapped should be considered at the reception centers.
Health. Medical, and Exoosure Control Measures Heal:h, medical, and exposure control measures were evalua:ed as acceptable, wi:h deficiencies noted : hat lbsic ef fective performance.
County procedures for contaminant monitoring of all employees active in the EPZ were closely fo llowed . Screening of evacuees and vehicles was also vell demonstra:ed; however, means for final disposal of contami'nated solids and liquids we re no t established. '4h il e po cke t dosimeters we r e effectively used fo r personal monitoring, pe rman e n t-rec o rd ing instrumen:s were not av ailab le. Sufficient staf f was avail able to avoid expo sure s in excess of protective action guides.
Recommendations:
e Disposal methods for contamina:ed materials should be developed.
e Permanent-recording devices (e.g. , TLDs or film badges) should be considered for emergency workers. (Re ference NUREG-0 654, II.K.3.4) e Additional training is needed at local hospitals on radiation monitoring.
Recoverv and Reentrv Ooerations Recovery and reentry operations were evaluated as weak, with signifi-can: deficiencies noted. This evaluation was based primarily on :he lack o f full simulation. The opera: ions of ficer conducted a concise general brie fing for ex er:ise par:icipan:s; this was followed closely by :e rmina:io n of :he
55 exercise. Although par:icipan:s appeared to unders:and the ir roles, no actions were simula:ed before the ECC was closed.
Rec ommend a: ion:
e impor:an: recovery and reentry procedures should be ef fectively demons: a:ed :o ensure capabili:ies and
- s provide : raining. (Re ference NUREG-0654, II.M.1)
Relevance of the Exercise Exoerience Observers fel: tha: the exercise pr ov id ed an accep:able level of experience. While participan:s at :he fixed facili:ies fel: :he experience was b ene fic ial, the field temas varied in their evalua: ions. The monitoring
- ezms were en:husiastic and gained valued experience. Access control per-
, sonnel, however, fel: :ha: their ac:ivities were rout in e. The scenario was good in : hat i: called for par:icipa: ion of all coun:ies in the EPZ; however, more ex:ensive use could have been made o f =eni:oring :eams by having :hes take more readings and samples.
. Rec ommend a: ion:
e Improv ement in the exercise experience could be gained by having ac:ivities designed :o thoroughly :es: teams with cceplex du:ies (such as field monitoring teams) while sinknizing activities : hat are routine for other partici-pants.
e
= .
56
- 6. Putnam Coun:v E=errenev Coerations Overall, the energency operating center (EOC) had good f acilit ie s ,
resources, internal cocunun ic ations , displays and securi:y. However, some minor deficiencies were noted and are described below. This EOC is located in the Coun:y Of fice Building, on Main Street, Carmel, New York.
The EOC was very small, and had a cramped working space tha: was es-pecially noticed in the radiological assessment area and in the communications area. The everall func tioning of :he ECC was good in spite of the small size, because the man ag ement was excellent. Amenities such as lighting ,
ventilation, and display space were good. However, a conveniently located drinking foun:ain would be a welcome addition.
Several pr imary and backup commun ic a tions s ys t ems provided a good performance. The primary system between the nuclear f acility, the sta:e, and a
the local governments was a dedicated ho t-line tel e pho ne , the Radiological E=ergency Commun ic ations System (RECS). Backup systems includ ed a special radio network, the commercial telephone, and the RACES system. The executive hot line functioned very well until it failed near the end of the exercise.
Tne backup radio was then adequately utilized.
The pr imary communication between the EOC and the agencies and or-gani:ations that provid ed :he local res ponse was via commercial telephone.
This consis:ed of many telephone lines and in s t rumen t.s that provid ed good pe r fo rmanc e . The backup RACES system was excellently equipped, and was =anned by very coepetent operators.
Communication vi:5 the buses used for evacuation was by radio. This channel was adequa:e, but in two ins:ances messages were delayed until the channel was cleared.
Co munica: ions with federal agencies was adequa:e.
Commun ic a t io n s wi:hin the E00 were excellent as a result o f the following procedures: messaies were quickly verified and logged before they were dis:ributed within the EOC; :he data desc ribing the plant status and :he radioiso: ope release ra:es were posted on a status board and promptly uoda:ed; and the s:aff was kept well informed by periodic briefings.
57 A small improvemen: in the fune:loning of the ECC could be ade by synchroni:ing all of :he clocks.
Infor=a: ion was well displayed a: all key loca: ions in :he ECC, and was e f fec:ively u:ilised in making decisions and in carrying : hem ou:. The displays consis:ed of a sta:us board and several maps. Th e in f o rm a:io n posted en :he sca:us board was easily read ir:m a dis ance. *he map :ha:
showed ev acua t ion routes wa s good; however, i: could be =ade more legible from a dis:ance. An excellen .ap showed the location of :he plume and :he locations of :he radiacion moni:oring stations, and g av e the field sampling da:a.
Securi:y was adequa:e except for the ini:ial 15 minu:es after activa:-
ing :he ICC. Dur ing :his initial time, the access was uncontrolled. After a securi:y officer was assigned to the entrance, and a f ter he had been ins: rue:ed, securi:y was adequa:e. A s ign-in procedure was required in addi: ion :o name tags. Not all workers were required to show iden:ification, bu: :his is because many of the '.orkers were known :o :he securi:y of ficer.
Re ceasend ations :
e The Crange County ECC should be added :o :he hot-line ne:vork so that all of the county ECCs can readily communicate with each other, e.g. , Pu: nam vi h Orange.
(Re ference NL* REG-0654, II.F.1.d) e The arrange =ent of : ables and :he loca ions for each emergency worker in :he ECC should be reviewed to =ini-
=ise :he ef fec:s of :he small space on the opera: ions.
(Re ference N13EG-0654, II.H.3).
e Procedures for security should be reviewed. (Re fe renc e NL* REG-0 654 II.H.3)
Alertint and Mobilization Pu: nam Coun:y de= ens: rated an accep:able capability to r es po nd to an emergency :ha: s: arts at any time during the day or night. However, sc=e deficiencies were noted :ha: L i=it ef fec:ive perfor=ance.
The aler: no: ice frem :he u:ili:y :o :he Sca:e Police was relayed to
- he Coun:y Sherif f's Of fice. *his of fice, which is staf fed 2 A hours per day, de= ens:ra:ed ef fec:ive call-ou: procedures for aler:ing coun:y officials or l _ _ - _ _ _ _ .
=
53
- heir alterna:es. Home :elephone numbers, home addresses, and some radio call sys: ems were available :o facili:4:e no:ifica: ion.
The coun:y officials reported promp:17 and ac:iva:ed :he EOC in a :imely manner. ? ocedures for notifica:icn of emergency response organica-
- ions and personnel were excellent. Mobilization was :imely, wi:h some personnel repor:ing vi:hin 15 minutes. All were on du:y in about 30 minutes.
Aler:ing of the radiation =oni:oring field :eams was accomplished by radio soon af:er the ICC was activated.
Mos t of the alerting was done wi:h :elephones, but radio backup was available. The RACES personnel provided excellent support.
The ECC verified messages (e.g., Alert, Site Area E=ergency, etc.)
from the ICF and the utility, both by repetition at the cime of notification and by call-back shor:ly af:er receipt of the message. Putnam County was dependen: on the k'es:chester represen:ative at the EOF for much of the radio-logical data needed for accident as s e s smen: at the Putnam ICC.
A capability to continue operations 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day was demonstrated 4: :he ICC by a shif: change at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, and by exhibicing a list of backup personnel. This revealed tha: two of the key people, the CD Director and
- he RADE7 Of ficer, do not have adequate backups.
Power fo r the communications equipment used for alerting depended on a ba:tery in case of power failure. This bactery had only an 8-hour capacity.
Re cocme nd a:io ns :
e A1:erna:es for the CD Direc:or and RADEF Of ficer should be trained as soon as possible. (Re ference NUREG-0654, II.A.4).
e An emergency power genera:or should be considered for use during a power failure. (Re ference NUREG-0634, II.A.4, F.1.d).
- Moni:oring teams should be dispa:ched to the field at the earliest possible :ime, so that they are in posi: ion
- o provide data for an independent early assessment of the emergency. (Re ference NUREG-0634, II.R.4, I.8). .
e Procedures for transmit:ing =eteorological da:a, plan emissions da:a, and data obtained by the utili:y field
-oni:oring :eams frem :he utili:y and EOF :o the EOC should be reviewed and s:reng:hened. (Re ference NUREG-0654, II.F.L.d, I.3).
= s 39 Esertencv coerations Managemen:
ne emergency operations management was good, with only minor deficien-cies noted. Be organi:a: ion, con:rol, and leadersnip, as well as :he support by elec:ed of ficials, were good.
Many specific organizations had roles in the response o f Pu: nam Coun:y :o the exercise scenario. It was clear that these organizations unders: cod : heir responsibili:ies and knew how to implement specific provi-sions in :he emergency plan. De operations of ficer consul:ed procedures and checklises frequeacly.
Leadership was excellent. De Civil De fense Director was clearly in charge of the ECC, and was sup po rted by the County Executive. De CD Direc:or, the County Executive, and the RADEF Of ficer conferred frequently, contacted other ECCs and :he state, and reached impo r tant decisions quickly.
Be MDEF Of ficer was clearly responsible for :he acciden: assessment f un c t ion. He directed the field teams, analyzed the data, and b rie fed :he heal:h officer and other ECC o f fic ial s . He used :he utility's emergency classifications.
De RACES organization was assigned to field monitoring, and provid ed excellent s uppo r t .
De Civil Defense Director, the County Executive and the leaders of the supporting organizations gave periodic reports to keep the workers in :he ECC up to date. De more importan: items were posted periodically.
Public Aler: and Notification Scme of :he ac: ions :aken for pub lic alerting and no:ification we re acceptable. 3ose that were weak and in need of substantial improvemen:
include p e r f o r= a n'c e of the siren system and the ability to no:ify the transien: po pul ation.
At the notice of a Site Area Emergency, che Putnam County ECC coordin-4:ed :he ac:iva: ion of the siren sys:em with the release of the first E3S message. Some of the sirens failed to so und . Others sounded but were not loud enough in all areas. In addi: ion, interviews wi:h the pub lic rev ealed that many had not heard the siren or did not know wna: they mean: or tha: they
60 should lis:en :o :he ISS for instrue: ions. Those in:erviewed also did not knov :he meaning of :he Emergency Response ?lsaning Areas (ER?A) or :he boundaries for the ER?As.
The E3S messages were writ:en, cleared, and broadcast (in simulation) in a :i=ely = anne r. No !7 moni:or was available in :he IOC to check :he ISS messages on :he 77.
Route aler:ing by police and fire crucks equipped vi:h PA systems is the backup for the siren sys:em. The adequacy of the backup system was not demonstrated. A few route aler:s were simula:ed, but no FA announcemen:s were made.
Checks vi:h motel opera: ors revealed cha: the sirens had not been heard. No evidence of notification of :he transient population was found.
A review of county E35 sessages and news releases indica:ed :ha:
in a limi:ed number of instances info rma t ion in news releases more properly should have been contained in E3S =essages. All of ficial e=ergency public inforsa: ion pertaining :o public safety should be broadcas: on E3S. The public has been advised :ha: E3S is :he sole source for official e=e rge ncy public inforsa: ion. .
Reccame nda tions :
e Test measurements of sound level should be made through-ou: :he 10-mile EPZ. Modifications and/or addi: ions should then be made until the system meets the notifi-cation requirement s. (Re ference NURIG-0654, II.E.6, J.10.c).
- Route-aler:ing messages and procedures should be devel-oped :o supplement the siren system, especially in those areas of low siren sound level. (Re ference NUREG-0654, II.E.6, J.10.c).
e Criteria should be developed in conjune: ion with the s:a:e and other counties :o determine what type of infor:ation vill be aired over E33 and what type vill be issued in news releases.
e in:ense ef forts should be sade to =ake :he public aware of the meaning of the siren signals. (Re ference NURIG- -
0654, II.G.1),
e A si=pler alterna:ive :o :he ERPA cone designations should be developed, or a very comple:e educational ca=paign that includes distribu: ion of =aps showing :hese areas should be condue:ed. (Re ference NURIG-0650, I!.J.10.a. G.1).
51 Publi: and Media Relacions Cverall, :he pub lic and media relations ac: ions were acceptable, but some de fic iencie s were no:ed. Public education programs and rumor con:rol procedures need improvement s.
Public education brochures were sailed to :he pub lic a shor: time before the exercise. These brochures listed a :oll-free :elephone nunber :ha:
the public could call :o get sore in fo r na tion. In addi: ion, : raining cour ses fo r :he public were given regularly by the Fire Department and RACES person-nel. They were assisted by Putnam County depart =en: heads. Never:heless, it appears that additional educ a t ion is needed to help :he public understand actions that are to be :aken in the event of an emergency. No posted noti:es and no info:mation in :he telephone book were found.
The Putnam County Public Informa: ion Of ficer (?!O) at the ECC was in -
charge of releases to the media. These were transmi:ted :o :he Join: Med ia Cen:er after they had been approved by the County Executive. The PIO had access to all participan:s in the ECC, including the County Executive, and :o
'all in fo rma t ion there. It should be noted that Wes:chester County was in charge of coordina:ing all E33 messages from the several counties. The Putnam County FIO staff a: the Join: Media Center ef fectively coordinated E3S and news release issuance.
Th e Jo in: Media Facility (JMF) was the po in t o f contac: vi:h the press. 1:s location about one mile SSW o f the plant is of some concern since under cer:ain vind conditions it might be in a contaminated zone. The al:ernative Jv.T location is in White Plains and =ight not be conv enien tly reached under certain conditions for sisitar reasons. There was no: adequate space or equi;c:en:, including maps and charts a: the cen:er.
3riefings in the Media Center were not always announced, and not all i=po r t an t b rie fing s were attended by the PIOS; for example, when ?ASNY announced the si:e area emergency a: 9:20 a.m., only the utili:y was presen:,
and at the 11:26 briefing only ?ASNY and We stchester County were present.
y.
62 Rec emmend a: ions :
e Addi:ional public educa: ion is needed so :54: :he public will understand :he loca: ions of the areas that are to take :he pro:ective ac: ions and will know how to carry ou: :he protective actions. (Re ference NUREG-0654, II.J.10.a. G.1).
e ?rocedures should be developed for identifying rumors and for dealing with : hem. (Re f erence NCREG-0634, II.G.4.c).
e A new location for :he JMF, with adequa:e space and equip-sent that is outside the 10-mile EPZ should be found.
(Re ference NUREG-0654, II.G.3.a) ,
e All major press briefings should be announced in advance so tha: ?!0s can attend.
Acciden: Assessment Acc id ent as se s smen: capabilicies were evaluated as acceptable, but seme deficiencies were noted. A problem in the =ethod for determining radiciodine should be correc:ed, and procedures for quickly dete rmining contaninacica levels in liquid samples need to be addressed. .
Initial projec: ions of the r adiolog ic al expo sures were made from release rate and =eteorotegical data measured a: the power plant. The Putnam County ECC had excellen: saps and transparent overlays to use for this pur-pose. These initial projections were used before field sample data we re av ail ab le .
Field moni:oring teams were deployed promptly by the RADEF Of ficer 'in the IOC. This was possible because of the excellent supper: provided by the RACES personnel, who also prov id ed c mmunications for transmission of the field data to the EOC.
The =enitoring equipmen: for measuring whole-body gamma-ray exposure ra:es was excellent. Monitoring equipment for =eas ur ing radic iod ine was inadequate, due to :he use of a charecal filter in :he air sampling equipment.
This fil:er also collects the noble gases, so tha: the readings do no: see:
- he requiremen: o f NUREG-0654 The use of a silver zeoli:e filter in place of .
the charcoal greatly reduces :he collection of the noble gases.
53 The nu=6er of readings :ha: the field :eams could =ake was limi:ed pri=arily by travel :ime from one sample po in t :s another. Nevertheless, if
- he sampling :eams were very e f ficien:ly deployed, da:a could be ob:ained in a shor: enough time for the ICC :o =ake an early independen: assesssen:.
No liquid samples were analyzed in the field; however, liquid and solid samples from :he field were delivered to :he cen:ral collec: ion point a:
- he ECC.
No field seasuremen:s o f radia: ion levels were ob:ained fr om :he utility through the ICF; however, some boundary dose projections were obtained.
Rec:cmend a t ions :
e Silver zeolite filters should be used in the air samp-ling equipment that is used for seasuring radiciodine.
Charcoal filters may be used during drills and exercises but the silver zeolite filter should be in the instrument kits ready for use in an actual emergency. (Re f erence NUREC-0 6 54, II.I.9).
e The sequence of sample poin:s used (routes driven by monitoring teams) should be carefully chosen :o give the saxtsum amount of da:a for use in making the early ,
independen: assessment. (Re ference N12EG-0654, II.I.3).
e Procedures should be developed for obtaining the field data measured by the utility's field monitoring teams.
(Re ference NURIC-0654, II.I.8),
e ne number of samples needed for an independent early assessment, and the possible hinderances to fast deploy-
=ent of :he field monitoring :eams should be reviewed in order to assess the possible need for addi:ional field soni:oring teams. (Re ference Ni: REC-0654, II.I.3).
Actions :o Protect the Public Pu: nam County officials de= ens: rated a good capability to take the actions necessary to protect the pub lic , and only minor deficiencies were noted.
Sisulated roadblocks were set up promptly, and most pe r so nnel under-s: cod : heir func: ions a: each si:e. Crders we re given in a timely manner for the various ac: ions tha: vere requir ed :o si=ula:e shel:ering and : hen evacua: ion. A bus-load of s:udents was evacuated to :he congregate-care center in "b: chess County. *his de=ons: rated evacua:icn was very goed.
64 The loca:isna of the :ongrega:e-:are cen:ers in 3 revs:er and Ou::hess counties are veil ou: side the 10-mile EP . They are loca:ed in schools where large gy=nasiums, :afeterias,. and :oni:oring and decon:msina: ion f acili-
- tes were pr ov id ed . In one case, :he 7asser Hospi:al cooperated :o pr ovid e medical care if required.
Ihe procedures fo r processing evacuees a: :he congregate-:are centers were good. Heal:h care, decon: amination, and monito ring ve re ad equa:e; however, :he oni:oring pe r so nnel could benefi: fr om additional : raining.
Th e f ac ili:ie s at :he congregate-care cen:ers vt e goed. An early shor: age of equipsen: needed for long-:ers opera: ion was relieved by :he a rr iv al of a Red Cross : ruck filled wi:h equi pmen: (e.g., cots, blanke:s, e::.).
The s:affing at the congrega:e-care cen:ers was excellen: and inc lud ed personnel fr:c Coun:y Heal:h, frem the ?olice, f rom Civil De fense, f r es RA0EF and fres the Red Cross. The nu=ber of personnel was ample.
Rec eccend at io n s :
e Additional training for those workers perfor=ing radi-ation monitoring and decontamination procedures is recoesended. (Re ference NUREC-0654, II.J.12).
e Procedures for dealing vi:h impedi=ents :o evacua: ion need to be developed and exercised. The se isped imen:s include au:o acciden:s, auto breakdowns, severe road cond itions and :he unavailabili:7 of gasoline when needed. (Re ference NUREC-0654, II.J.10.k).
Heal:5. Medical, and Excosure Control Overall, the health, =edical, and exposure :en:rol ac: ions were accept-able, vi:5 some ex:ep: ions. The procedures for ul:isa:e dispo sal of liquid and solid wa s:es need s to be addressed.
The pali:y o f the Departmen: of Heal:h of :he Sta:e of New York is that no po:assics iodide vill be dis:ributed :o :he general population.
The control of access to ev acua:ed areas was 3:od. Ro adbl ocks were canned, and the personnel a: the roadblocks unders: cod : heir f unc t io n.
65 Energency wo rke r s were pr ov id ed wi:h dosime:ers :s measure expo sur e.
Two ins:rumen:s o f :he direc: r ead ing :ype were provtded (0-20 Rem and 0-200 Rem) . The se were read frequen:Ly (e.g. , 15-minu:e in:e rval s) and :he r e ad ing s recorded on a card. Th e ICC called the field :eams :o obtain dost ecer read ing s for logging. No permanent-record dosi=e:ers (e.g., TL3s, film badges) were provided.
E=ergency worker exposure in excess of the 20 Rem li=i: vas no: ex pe r-ienced; however, ques: ions revealed :ha: :he approval of :he County Executive was needed before :his limi: could be exceeded. The CD Direc:or thought :ha:
his approval was necessary.
Ev id enc e fo r :he existence of ac: ion levels for determining the need for decontamination was not ob serv ed at the pe r so nnel monitoring center; however, the workers sta:ed tha: : hey existed and knev :he counting ra:es tha:
corresponded.
Personnel decon: amination procedures a: the personnel moni:oring :en:er were demons:ra:ed and were adequa:e. Decontamination procedures for equipmen:
and supplies were no: d emons t r a:ed . Mo re training in :hese procedures is needed. Prope r procedures for ul:imate d is po sal of contamina:ed articles
( e.g. , clo:hing) needs to be addressed.
Reccemend a:io ns :
e Procedures should be clarified so : hat all personnel know which individual (e.g., the Coun:y Execu:ive) can approve emergency workers receiving a radiation exposure in excess o f the PACS . (Re ference NUREG-0654, II.K.4).
e Addi:ional training is needed so :ha: personnel moni:oring workers vill be more familiar vi:h :he action levels for decontamina:Lon actions. (Re ference NCREG-0654, II.J.12).
e Training in me: hods for decontamination of equipment and supplies should be given to ?.M.C. verkers. ( Re ference NCREG-0651, II.K.5.b).
e Methods for permanen: disposal of con:mninated arti:les (e.g . , liquids , clothing) should be addressed. (Re fe rence NUREG-0654, II.K.5.5).
e Persanen:-record dosimeter s ( e.g. , TLDs , film badges) should be provided. (Re ference NUREC-0654, II.K.3.a).
e .,
66 Recoverv and Reen:rv Reentry operations were pe r fo r=ed in simulation only. An acceptable capabili:y for reen:ry and recovery appears to exist.
Be coun:y radiation moni:oring teams :entinued to func: ion during :he re:overy phase. They wo rked closer and closer :o the plume, until the simula:ed readings decreased :o background af:er a few days (simula:ed). Th is was hard to evalua:e because :he con: roller lef: before :he conclusion of :he exercise. The acciden: assessmen: :eam rev iewed :he expo sur e da:a be fo re making a recommendation.
Prior to :ermination of the exercise, the Coun:y Executive appo in:ed a commission :o plan and implemen: recovery over a 30-day period.
- Recom=end 4: ions :
e ru :ure exercise scenarios should provide more time for a de: sited reen:ry activity. (Re ferenc e NL* REG-0 6f!+ , II.M.1).
Relevance of the Exercise Exoerience There was unanimous agreemen: among :he federal evalua to r s : hat the exercise was very beneficial to the participan:s, all of whom cook the exer-cise very seriously and pe r formed as if the po,ve r plant acciden: actually occurred. Volunteers (nongovernment pe r sonnel) are especially commended.
'A il e :he sc enar io was a good test of emergency res po nse capab ili:ie s of county personnel, it did no: (and perhaps was not intended to) address issues of public awareness and public reaction :o an emergency.
, n e - - - - , -
s e L, 67
- 7. Outchess Coun:v 3ecause Outchess Coun:y is not located wi:hin :he 10-mile IPO, i: vas not re quir ed to de=enstrate its emergency preparedness :apabili:y. However, since Dutchess Coun ty could receive 4 large number of evacuees dur ing an ac:ual ac c id en:, the county, on its own ini:ia:ive , d ec id ed :o par:icipa:e fully in the exercise. The evaluations by federal observers of :he Du::hess Coun:y ac:ivi:ies are no:ed below.
The emergency operations center (ICC) had adequa:e space and equipment.
The facili:y was fully staf fed, includ ing parti:ipation by the Coun:7 Ixecu-c iv e . Securi:y was excellent.
The Putnam County Departmen: of Social Service demons: rated ::mpliance vi:h :he plan by notifying i:s coun:erpar: agency in Dutchess to expect evacuees item specific sec: ors.
The coun:y had some initial dif fi:ul:y contac:ing :he media : enter :o coordinate pub lic in fo rma: ion. Some :elephone nunbers were also inaccura:e.
Overall, the exerc ise was considered to be good as a training ex pe r-
~
ience for the county.
= .. - ,
e.',g
. .. 68 7 CORRECT!'.T ACTION FOR OEFICIENCIES
- 1. SCHEDL'I.E FOR CCRRICTING SIGN!?!CA:C CEFICIENCIES State and local jurisdic: ions should submi: :s the RAC :he correc:tve seasures they have taken or intend to :ake. If remedial ac: tons cannot be ins:ituted L2=ed ia:e ly , : hen a detailed plan for scheduling and impl ement ing remed ial ac: ions sust be prov id ed .ttich taclud e a :ime frame (dates) fo r completion.
The Regional Direc:or of FEMA is responsible for certifying :o :he FEMA Associate Direc:or, State and Local Prograns and Su p po r t , 'Ja s h ing :o n, D.C.,
- hat any deficiencies noted in the exercise have been repor:ed and that such corrections have been incorporated into the plan.
1 f
i 4
-s, , -- , , . - - .=--c ---,-e-, -.-s. - , , ,e v. , ,w ,
es.~ ATTACHMENT D STATE OF NEW YORK ,
DEPARTMENT OF HEALTH <_A OFFICE OF PUBLIC HEALTH TCnER 8UILCIN G
- THE GCVERNCR N EL5CN A. PCCKEFELLEM EMP,att ST ATE PL AZ A
- ALS AN Y, N.Y.12237 C AVic a z tL *C O W.D. GLENN C. M AU C MI C. W.O.
Co nneenwer Do mser June 9, 1982 Mr. John T. Grant Chaliman ~
county Legislature County office Building ,
11 New Hempstead Road New City, NY 10956 Daar Mr. Grant: .
Thank you for inviting us to discuss the implications of the Rockland County resolution on radiological emergency preparedness.
The May 28 meeting was very helpful to us. I hope that we answered your questiens. .
I received a copy of Mr. Hennessy's letter to Mr. Petrone on this subject. I believe a copy was also sent to you, but another copy is enclosed for your information. On the basis of our meeting and Mr. Henn'essy's statement, several corollary items emerge.
s The Radiological Emergency Precaredness Grouc will be able to continue Plan revision efforts with your staff, but the Plan must be yours.
REPG will be able to continue training efforts in Rockland County.
REPG will be able to pursue substantial funding of the Rockland radiological emergency plan effort. We expect to fund those costs submitted in relation to the March exercise, and a substantial portion of those items requested by the County for the future.
, REPG assumes that County staff will continue to be available to work on the above items.
REPG assumes that Rockland will continue to support the four county concept for the time being, and that the concept will be incorporated in the new plan.
REPG assumes that the County will continue to participate with un and the other affected counties in drills and exercises at reasonable times.
6
, Mr. Grant -
June 9, 1982 If this summary is an accurate statement of the situation, we are ready to move ahead as described.
Sincerely yours, M
D nald B. Davidoff Director Radiological Emergency Preparedness Group Att.
bec: Mr. Hennessy Dr. Axelrod ,
Mr. Leavy Dr. Stasiuk Ms. Milstrey Mr. Tyree s Mr. McQueen ,
Lt. Col. Law Mr. DeVito Mr. Thompson Mr. Kelly Mr. Brandenberg Mr. Pratt Mr. Petrone