ML20063M990
| ML20063M990 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/10/1982 |
| From: | Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION |
| To: | Ahearne J, Gilinsky V, Palladino N NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-SP, NUDOCS 8209160512 | |
| Download: ML20063M990 (4) | |
Text
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i WEST BRANCH CONSERVATION ASSOCIATION DOCKETED M3 BUENA VISTA RWFAEC NEW CITY N Y 10956 Septemb g lg g8$2:i5 Hon. Nunziolhlladino, Chairman 0FFICE OF SECRETARY Hon. Victor Gilinsky DOCKETING & SERVICE Hon. John F. Ahearne BRANCH Hon. Thomas Roberts Hon. James K. Asselstine U.
S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Commissioners:
Re: Dockets #50-247-SP, #50-286-SP I understand that you had as guests to your September 9 meeting FEMA personnel to discuss the state of the evacuation plans surrounding the Indian Point stations.
We have written you on August 27 some about the failings of FEMA but due to the limbo in which we now find our-selves we took our time to write enclosed critique which lists where FEMA has failed to conform to 44 CFR 350.
We have not made a critique of where the plans fail NUREG-0654 Rev. 1 because we have at present no forum.
We hope you will read the enclosed and understand the basic two problems.
- 1. The State cannot substitute for the County unless it moves into the County.
No New York State law provides the State with the powers it would need to take over the functions.
They are to be found in Executive Law of New York State under sections 22 through 29.
- 2. The County of Rockland cannot suit the plans as offered by the utilities or the State.
There are in-sufficient buses, volunteers and roadways, among other f ailures. Especially has it no way to tax the citizens for the money to spend on equipment needed. Answers PEMA gives are all on-paper possibilities.
They shocked, and that is no exaggeration, the Fink sub-committee with Mr. Kowieski's testimony. See attached.
We hope you will allow the County of Rockland to speak for itself, or to read the transcript of the September 1 hearing before the Committee on Nuclear Power of. the New York State Assembly, hearing in White Pla. ins, N.Y.
Sincerely yours, ab I
S.
Fleisher xc: County Attorney Secretary R6ckland County 8209160512 820910 i
RDR ADOCK 050002g 1
n
d WEST BRANCH CONSERVATION ASSOCIATION NEW CITY N Y 10956 WEST BRANCH CONSERVATION ASSOCIATION's September 8, 1982 Critique of INTERIM FINDINGS ON THE ADEQUACY OF RADIOLOGICAL EMERGENCY RESPONSE PREPARATION OF STATE AND LOCAL GOVERNEMENTS AT THE INDIAN POINT NUCLEAR POWER STATION Prepared by FEMA and dated July 30, 1982 Page 16 of the Interim Findings, subsections 2 and 3, is no answer to the monitoring problem and certainly does not satisfy the Rockland County Health Department, which does not want to & pend on the licensees of the State whose response time would be too long, for the health and safety of Rockland County residents.
In fact, FEMA loses face in accepting it.
See 350.5 (a) (9) below.
It is not a " minor deficiency" that we want 12 monitoring teams.
In May, 1982 Mr. Davidoff offered three and now, in September he has brought the figure up to four.
Where would four teams be to satisfactorily cover a plume's path?
The Interim Findings then go on to page 17 with con-tinued references to " minor deficiencies" regarding field monitoring, instructions, standard operating procedures, etc. The whole monitoring program is a disaster, a "sig-nificant" one, not a " minor" one.
Page 17, Section 2. " Silver zeolite filters will be furnished to the counties by the State or utility when fuhds become available."
Mr. Donald Davidoff testified on September 1 that of the $1,250,000 which should be available via 708, $470,000 would be divided.by the eight counties surrounding nuclear plants and the rest would be retained by his office.
When might we expect any money to be disbursed? When would zeolite filters be available?
P How many dosimeters will be available? Enough for every emergency worker?
Why wasn't the failure to have in place sufficient and equipped monitoring teams considered a "significant deficiency" and listad in the Executive Summary on page 27 b.
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Page 17 writes off the problem by stating that when funds become availablo all will be corrected.
Page 17 is a litany of serious defects which are only noted.
These should be upgraded as vital to the success of the Accident Assessment.
If as stated on page 18 "the de-ficiencies noted cannot be considered resolved until re-medial actions are completed."
When will that be? Before November 17 Before December 37 If not, what then?
Page 18 details many operations that cannot possibly be met by any schedule or calendar suggested by Mr. Da-vidoff and Mr. Kowieski.
Evacuation time estimates, even if correct, allow that persons wishing to walk out of the
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EPZ could do so f aster than waiting for a bus in many, cases.
We know there are insufficient buses with wheel chair ties and that, if they will, it will take several trips for each.
Mr. DelBello has repeatedly stated the same problem as we have in Rockland, there are insufficient buses to meet the plans.
In Rockland we are worse off be-cause the County does not own a bus system of any propor-tions.
Nor has anyone the assurance that volunteers will be willing to drive or that they will even be in the County during an emergency.
It is imperative that FEMA demand a survey of the total number of volunteers, not duplicates, that would be needed to effect even a single segment evacu-ation, let alone one that would cope with "self evacuees" as well.
Why has no number of volunteers been assayed?
In fact, why has this whole subject been neglected?
What tests of evacuation times has FEMA found adequate as stated on page 19 in subsection 37 At the ASLB/NRC hearings the FEMA witnesses fell f ar short of proving such a statement.
Refer to the transcript of June 23.
Will you rely on the word of the State that remedial actions will be taken?
Will FEMA require any proof that they have?
Top of page 20 implies FEMA takes this seri-ously yet we are told that certification to the NRC is. now paramount.
Will the public have an opportunity to report directly to FEMA regardless of any claims made by the State before FEMA declares that a plan is in place and im-plementable?
The language all through 44 CPR 350 refers to "ade-quate and capable of being implemented."
FEMA has not addressed the road network surrounding Indian Point, and in particular, that in Rockland. County.
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i The following subsections have not been met by any plan offered Rockland County, in 44 CFR 350:
Page B-3, that NUREG-0654 is the guidance and accep-ted criteria.
Page B-4..."the NRC now will base its findings on a review of FEMA findings and detirmination as to whether State or local plans are adequcte and capable of being implemented..."
350.5 (a)(5) Telephone system can readily be over-loaded and other deficiencies in the notification system.
350.5 (a)(8) Support facilities are inadequate.
350.5 (a)(9) Rockland County Health Department does not feel it is prudent to depend on automatic equipment for monitoring.
A State monitoring team might arrive too.
late.
There are no radios with which to communicate find-ings from the field, nor are there telephone booths dotted all over the rural countryside.
Even if there were, would j
lines be open?
We need twelve monitoring teams. The four offered are insufficient.
350.5 (a)(10)
... protective actions during an emer-gency... appropriate to the locale have (NOI3 been developed."
350.5 (a)(11) Means have not been established for con-trolling exposure of emergency workers.
350.5 (a)(12)
Just listing the two local hospitals does not assure that they have the means to tseat exposed persons.
The State answered an interrogatory from Friends Of The Earth by listing the two local hospitals and the num-3 ber of beds they have.
Are they prepared to empty out all their patients and offer their full number of beds?
Good Samaritan Hospital has a four-bed decontaminaticn unit and Nyack is building one. Neither hospital has taken part in an exercise or drill.
Section 12 is fully deficient in Rockland's plan whether it be the State plan or Parson's Brinckerhoff's.
350.5 (b) Can it be said that any plan offered to Rockland residents " adequately protect (s) the publis health and safety providing reasonable assurance that appropriate protective measures can and will be taken of f-site in the l
event of a radiological emergency"?
0654 and other cri-teria have not been met.
FEMA tells us this is a " dynamic process." Is time no consideration? Has FEMA made a judgement regarding risk?
If so', what is it? On what is it based?
The plans Rockland has been offered are not implemen-table.
FEMA states that money will buy the way to imple-mentation.
To date none has been received nor is there enough in the forseeable future, if that were true.
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