ML20067D429

Urges That Facilities Not Be Restarted Until Emergency Response Plans Are Fully Workable & Implementable.State of Emergency Planning & Preparedness in Westchester County Still Inadequate

ML20067D429
Person / Time
Site:	Indian Point
Issue date:	12/05/1982
From:	Delbello A WESTCHESTER COUNTY, NY
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML20067D426	List: ML20067D429
References
NUDOCS 8212130254
Download: ML20067D429 (12)

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C%$yD Westchester(cunty ~32 CE 10 Pi:21 2=

ALFRED 8. DEL BELLO - -- -

County Executive December 5, 1982

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'Mr. Nunzio Palladino -

Chairman  :

Nuclear Regulatory Commission ~

1717 H Street, N.W Washington, D.C 20555

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Dear Mr. Palladino:

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. - _n On March 3, 1982 a drill was conducted for th' e four ' -  ::- 1 tri-

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county area surrounding the Indian Point Power P1 ants;:- - '- -  ; n+

7 ;_;- -- Subsequent to the drill, Westchester County s'ubmitted findings :r --- *

. showing deficiencies in our emergency response planning!and '- ' -

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. . preparedness to the Nuclear Regulatory Commission (NRC) -

!-- and to the Federal Emergency Management Agency ~ (FEMA) on' - --

l June 2, 1982 At that time, I requested that the NRC initiate the 120-day clock against the facilities at Indian Point.

On August 3, 1982, the Nuclear Regulatory Commission initiated a 120-day regulatory clock against the f acilities located at Indian Point, after determining that there existed significant deficiencies in the off-site state and local emergency response plans for these plants.

The 120-day regulatory clock has now expired. After a careful and extensive review of the emergency response plans for Indian Point, I have determined that although we are in an improved position over a year ago, the state of emergency planning and preparedness in Westchester County is ceill inadequate.

8212130254 82121o DR ADOCK 0500o247

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) On August 18, af ter the initiation of the regulatory clock, five task forces were established by FEMA and the State of New York to " insure timely corrective actions."

Bi-weekly meetings were held between FEMA, the-State and i

utilities during the 120-day clock for the first two -

months, with the counties paticipating in sessions beginning on October 19. Efforts to correct deficiencies during the most recent 120-day clock have focused upon the deficiencies noted by FEMA in their Interim Report of July 30, 1982 on the status of emergency planning. For the most part,_the -

conclusions concerning the manner of correcting deficiencies have occurred at the state level.

FEMA'S Interim Report on the status of emergency planning noted significant deficiencies in five planning standards of 10 CFR 50.47 (b). These deficiencies were noted in the following planning standards: notification methods and procedures, public education and information, protective response capabilities, radiological exposure control, and responsibility for the planning ef fort. The following summation is the Westchester County perspective on the adequacy of corrective actions taken during the recent 120-day period.

CORRECTIVC ACTIONS REGARDING FEMA DEFICIENCIES:

Protective Response The deficiencies noted in this planning standard included:

the lack of methods for notifications of transients, lack of maps and lack of details for the means of clearing

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P.3 evacuation routes, no monitoring capability at relocation

. centers,- inadequate collection of field data, lack of identif-ication of the non-institutionalilzed mobility impaired persons, lack of operating agreements with bus drivers and bus companies and the lack of County bus radios.

Westchester County is dissatisfied with the current status of the plans in this planning area. Our major problem remains the lack of a workable transportation component for the plan. The proposed mass transit aspect of the plan is still in its most rudimentary stages; details must be worked out and drivers must be trained. Questions remain as to whether the proposal to utilize the National Guard to replace commercial bus drivers or those drivers who choose not to respond will provide reasonable assurance for the safety of transit-dependent residents in the 10 mile zone. We have serious reservations about the ability of the National Guard personnel to mobilize and carry out their responsibilities in the few hours required under the plan.

An assumed five hour mobilization time for these drivers can potentially retard our entire evacuation scenario . We anticipate further complications arising from their unfamiliarity with local roads and conditions . Even if these personnel were able to mobilize rapidly, our transportation experts have grave concerns about the feasibility of the two-wave concept of evacuation in light of the existing road network and logistics involved. Major revisions in the existing emergency response plan are necessary in order to orchestrate an evacuation of this size and scope and in the time suggested.

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. With respect to transportation of non-institutionalized mobility impaired persons, there are still no adequate

. procedures.

Our Emergency Medical Services (EMS) depart-ment does not have the personnel to develop the necessary -

information nor the capability to provide the requisite transportation. (A further discussion of the-transportation component of the plan can be found on page 7.)

Notifications Methods and Procedures ___.;____

- Deficiencies noted by FEMA included faulty sirens,-lack of adequate procedures for EBS activation and -transfer, lack of criteria for news releases, and the lack of training for Public Information Officers (PIO's).

In general, Westchester is satisfied with the corrective actions taken in this area. Our County P. I.O. has been instrumental in revising EBS procedures and in revising the contents of news releases. A training course has been held to familiarize county P.I.O's with these new procedures.

Nineteen additional sirens have been installed to supplement the existing system, although the County would still like to see a full testing of all sirens. Single station alert radios will be distributed to special facilities, including hospitals i and nursing homes, in the 10-mile EPZ, and procedures exist l for instructing these facili1 ties on use and purpose of l these radios.

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-p P.5 Public Education and Information Deficiencies noted in this planning area included: the lack of public awareness of the Radiological Emergency Preparedness Plan, inadequate distribution of the informational brochure, need for a multilingual brochure, inadequate arrangements for dealing with rumor control, inadequate procedures for the notification of transients and the lack of detail for the arrangement of procedures for the joint media facility.

Overall response has been good in this planning area, specifically in the distribution of informational brochures where several methods (other than U.S. mail through Con Ed billing lists) will be used. With respect to the second language brochures, the utilities did a comprehensive study showing no need. Special non-English speaking communities will be informed by alternate means. Rumor control arrangements have now been clarified with phone number distribution to the agencies that the public is likely to call (i.e. police, city hall, etc.) The deficiency in the notification of transients has been rectified by the creation of posters; i

distribution is scheduled to occur January, 1983.

With respect to public awareness of the plan, Public Service announcements on radio and ads in newspapers offering brochures have already started and will continue, however, the public education program is not as comprehensive and as active as it should be. The arrangements of procedures for the joint media facility are now in order.

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Radiological Exposure Control ,

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. Deficiencies noted in this planning standard included:

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. absence of permanent dosimeters and the thermoluminescent dosimeters (TLD's), needed revision of decontamination procedures, no adequate procedure for disposal of con-taminated wastes, lack of procedures for distribution of thyroid blocking agents and inadequate calibration and maintenance of monitoring equipment.

The County is satisfied with the movement during the 120-day period to correct deficiencies in proc-dures regarding decontamination and disposal of wastes, but we remain unsatisfied with our capability to implement these procedures. There remain no finalized procedures for the distribution of thyroid blocking agents. About 200 health specialists still require training to fulfill their role in the emergency response plan. State officials have agreed to provide certain additional highrange dosimeters within the next few weeks. Yet, protective equipment, including lov-range dosimeters, TLD's and thyroid blocking agents still must still distributed.

l l CORRECTIVE ACTIONS REGARDING WESTCHESTER NOTED DEFICIENCIES:

On June, 2 1982 I wrote this Commission requesting the initiation of the 120-day clock. Along with that request I transmitted critiques from the Westchester County I department heads having responsibilities under the plan.

These critiques noted numerous deficiencies in emergency planning and preparedness which had become evident subsequent to our March 3, 1982 drill.

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- The major deficiencies that we noted were the lack of workable transportation component for the plan, and the lack of sufficient equipment and trained personnel to handle our county responsibilities under the plan.

Westchester is dissatisfied with the current status of the deficiencies noted by us in our report to you of June 2, 1982. We in county government cannot give the public reasonable assurance overall that adequate protective actions can and will be taken in the event of a major radiological emergency at Indian Point. The Nuclear Regulatory .

Commission's own regulations require that such assurance be provided, and surely as a public official I can demand nothing less.

Mass Transit Component i

i For two years now, we have worked with federal and l

l state officials to improve and revise the existing mass transit component of the emergency response plan for the Westchester Coc ity plan. We have informed the responsible state and federal officials and the utilities of our problems.

These problems are the Jack of county jurisdiction over private bus companies, untrained drivers, inadequate evacuation procedures which utilize a two-wave scattered bus route j concept, and the lack of an adequate radio communications I

system for the buses.

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P.8 During the 120-day period, we submitted a proposal by

_ .A.T.E. Management and Services Co. Inc., of Cincinatti, Ohio, to the utilities and state officials.This proposal

. addresses all of the concerns we have raised in the past

.regarding the transportation component of the evacuation -

plan. To date, we have not received a formal response from the utilities or the state.

. _ _ _: Lack of Suf ficient Equipment and Trained Personnel _____ ___ _ _ _

If a radiological disaster were to occur today, Westchester County remains unprepared both in terms of equipment and - .-

sufficiently trained personnel. Plans exist for the hoped for distribution of protective equipment, and for the training of county police, emergency medical personnel, firemen and social service workers and bus drivers. However, this distribution of protective equipment and training of emergency personnel will not be completed for several years at the current rate of effort. For example, to date, only 341 police officers have been trained out of 2,300 police officers in the county or 10%; 224 firemen have been trained out of 12,000 firemen in the County. We have received only 250 dosimeters out of 7,000 needed by emergency personnel in Westchester alone.

This lack of success at the state level in securing for us the resources needed to make these plans implementable is a potentially fatal flaw. Realistic preparedness requires some expensive and complicated equipment. The nature of a

e ,0 P.9 radioactive emergency, that it is colorless, odorless, and impossible to detect without special equipment, renders any typical emergency response ineffective without the requisite special training and equipment.

Chapter 708, a law which assessed each nuclear reactor in the state $250,000 and created a fund of $1.5 million to assist state and local-governments with their emergency response plans was enacted in July of 1981. In November of 1982, Westchester received its share of that fund, S94,000,with the state retaining about $1.1 million and distributing the remaining $350,000 to seven other counties involved in emergency planning. I have been informed that all of the counties in .the state receiving monies under Chapter 708 are dissatisfied with their allotments, with the exception of Monroe County. In Westchester, our allotment will certainly be helpful in getting some of the most basic communications and protective equipment needed for a response, but it will not be enough to transform an otherwise unprepared county into a prepared one. Our current minimum necessary radiological emergency response budget of S1.8 million exceeds even the total fund created under Chapter 708.

New legislation must be supported at the state level to accomodate the needs of those county and local governments l

having primary responsibilities under these plans, and to create a guaranteed flow of monies to those county and local governments.

P.10 Summary and Conclusion ,. ___ ,

.The federal regulations mandating evacuation plans for

. the areas surrounding every nuclear power plant in the country did not exist when Indian Point I was cited here in 1955, nor when Indian Point plants 2 and 3 were cited in 1966 and in 1969, although such rules were proposed. It was only after the March 28, 1979 accident at Three Mile Island that the NRC required the protection of everyone living within a 10 mile radius of nuclear plants. The necessity

, for these guidelines as a minimum, have been underscored by a recent report prepared for the NRC by Sandia National.

Laboratories. This report estimated that a " worst case" accident at Indian Point would result in many thousands of deaths, injuries and delayed cancer deaths and billions of dollars in economic losses.

The recently released Suffolk County plan uses the Sandia report as a planning basis. Their plan proposes to be able to evacuate people out to 20 miles from the Shoreham Nuclear Power Plant to avoid the plume exposure pathway. A full 3600 evacuation would occur out to 5 to 7 miles, and a partial evacuation would occur out to 20 miles to avoid the downwind drift of the plume exposure. I believe this planning concept should now be looked into as possibly being appropriate for Indian Point emergency planning.

We recognize that there are other nuclear power plant sites in the state where local officials are satisfied with the plant's operation and with their emergency response

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.~ .a P.11 capabilities. However, in Westchester, the Indian Point site creates unique problems in emergency planning and preparedness because of the density of the population surrounding these plants and the existing geographical barriers. The Indian Point plants are located in the most populous area of any nuclear power plant in the country.

Currently, 290,000 people reside within 10 miles of the plants, 1.1 million live within 20 miles, and 17 million live within 50 miles.

Proposed federal rules in 1959 and 1961 advised against building nuclear power plants near densely populated areas.

These proposed guidelines employed minimum numerical standards but have not been adopted by the NRC to date. Had these federal rules on population density been adopted, or had the NRC's existing guidelines on population density been weighed more heavily in the licensing process in the 1960's, Indian Point plants 2 and 3 would not have ever been located in the New York Metropolitan area.

It has been suggested that if the counties were dis-satisfied with the state of emergency planning and preparedness then as responsible public officials it is their duty to adequately provide protection from a radiological disaster or from any other large-scale disaster (i.e. a train wreck involving chlorine gas). However, we believe the accountabililty for the NRC siting decisions should not be transferred to the state and local governments. And surely, the utilities who have profited from longstanding services in the county should be kept accountable to those nearby residents requiring full and reasonable protection.

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, .. s a P.12 The time has come to assess our capabilities. The - -

County has worked diligently for several years with-federal

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. plan. However substantial conceptual and equipment / training related problems remain. For the reasons stated herein, the County, at the end of the 120-day clock period, is not satisfied with the state of emergency planning and preparedness.

Currently, neither Indian Point 2 or 3 are operating. I .

. urge this Commission not to allow the facilities at Indian

. . . Point to go back "on line" until the emergency response -

plans are finally made fully workable and implementable.-

er y, Alfred B.DelBello County Executive ADB/gv l

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