ML20079L882

Testimony of DB Davidoff & LB Czech on Commission Questions 3 & 4 Re Emergency Planning.Related Correspondence

ML20079L882
Person / Time
Site:	Indian Point
Issue date:	02/21/1983
From:	Czech L, Davidoff D NEW YORK, STATE OF
To:
Shared Package
ML20079L862	List: ML20079L859 ML20079L882
References
ISSUANCES-SP, NUDOCS 8302230477
Download: ML20079L882 (14)

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, N4D CORRESPONDENCE O?,k'

" ,Q"'ED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0]

FEB 22 A11 :1 BEFORE THE' ATOMIC SAFETY AND LICENSING BOARD-In the Matter of )

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CONSOLIDATED EDISON COMPANY OF NEW YORK ) Docket Nos. 50-247 SP (Indian Point Unit 2) ) 50-286 SP

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POWER AUTHORITY OF THE STATE OF NEW YORK ) February 21, 1983 SUPPLEMENTAL TESTIMONY OF NEW YORK STATE'S WITNESSES ON COMMISSION QUESTIONS THREE AND FOUR DONALD B. DAVIDOFF l DIRECTOR RADIOLOGICAL EMERGENCY PREPAREDNESS GROUP LAWRENCE B. CZECH CHIEF, NUCLEAR PROTECTION PLANNING RADIOLOGICAL EMERGENCY PREPAREDNESS GROUP i

8302230477 830218 PDR ADOCK 05000247 T PDR

INTRODUCTION New York State witnesses on questions three and four hereby submit supplemental testimony in this proceeding. The purpose of this testimony is to update testimony originally submitted in' June of 1982 and to sponsor revisionL to State and County plans.

In our original testimony we. stated that the plan was adequate,-but indicated that efforts were underway to improve emergency planning.

Those efforts intensified after the FEMA Interim Findings. Now the plan has been improved. More work needs to be done, but we remain satisfied with the level of emergency preparedness.

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3.1 Emergency _ planning for Indian Point Units 2 and 3 is inadequate in'that the present plans do not meet any of the sixteen mandatory standards set forth in 10 CFR 50.47(b) , nor do they meet the standards Get forth in Appendix E to 10 CFR Part 50.

Since the submission of New York State's testimony on June 7, 1982, there have been a number of developments which impact on this contention.

FEMA Interim Findings And NRC Action i

As a direct result of this Board's' deliberations, the NRC requested that FEMA submit Interim Findings on the status of offsite preparedness related to Indian Point.

The On June 30, 1982, FEMA issued its Interim Findings.

document concluded that there were significant deficiencies in five of the 16 planning standards (10 CFR 50.47 (b) and Appendix E to 10 CFR Part 50). The Interim Findings were submitted to the Board.

On August 3, 1982, af ter receipt and review of the Interim Findings, NRC issued an Order to the Indian Point licensees requiring that the deficiencies be cured in full, or that acceptable efforts commence within 120 days of the Order.

The State, the affected counties and the licensees, at the request of NRC and FEMA, formed a work group to solve the problems identified in the Interim Findings and adopted by NRC in its 120 day

> order.

Seven biweekly meetings were held to summarize and report on the NRC and FEMA staff attended each session and played progress being made.

a significant part in shaping the work of the group and its task forces.

(The final report of the work group is attached as New York State Exhibit

7) .

On. December 17, 1982, FEMA issued a review of progress on the significant deficiencies for NRC use in determining what action, if any, it should take against the licensees because of the Interim Findings.

New York State Exhibit 7, referred to above, provides a summary of the issues raised by FEMA and the steps taken to settle each item. By the endlof the 120 days, only two items remained as not acceptable to FEMA: mass transit in Westchester County, and Rockland County's participation.

Cn December 22, 1982, NRC concluded that it was appropriate to permit Indian Point to return to power status. No sanctions were imposed.

NRC and FEMA have reserved further judgement on the adequacy of preparedness until after the March 9, 1983 full scale Exercise has ~

taken place and been analyzed. ,

Financial Assistance to the Counties On October 27, 1982, the affected counties received:

Putnam $ 27,962 Orange 31,691 Rockli d 57,870 Westchester 94,724

$212,247 The funds are to be used for State approved radiological emergency preparedness costs. The 1983-84 State Budget now being deliberated by the Legislature contains an identical appropriation for each county. Funds should be available by May 15, 1983.

The licensees have provided an additional $210,000 to the State as agent for the counties to help improve preparedness. $75,000 has already been distributed. $90,000 more is being processed. The remaining $45,000 is reserved for police training in Westchester County.

In addition, $78,270 has been expended for the acquisition of dosimeters and TLDs which have been, or shortly _will be, given_to the counties. New York State Exhibit 8, attached, details dosimetry and TLD

, distribution.

34,000 units (14 tablets per unit) of Potassium Iodide (KI) have been obtained_and are being distributed for potential use by emergency workers in: accord with newly. revised State policy.

Since the issuance of the Interim Findings, more than 80% of-REPG. staff time has been devoted to Indian. Point offsite preparedness efforts: State and local plan review'and revision; State and local procedures review, revision and development; FEMA /NRC consultations; and i preparation for the March 9, 1983 Exercise.

Training >

1 The first task which confronted the counties and the State as:

they attempted to meet the new Federal requirements in'1980 was to write plans. That-assignment has in the main been accomplished, although substantial Plan revisions are still being made. The revision process will be ongoing.

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l The next major task was to make'the plans implementable.

l l Exercises and other forms of training are the means which -make it

possible for emergency workers and the public.to cope with an actual-l l radiological emergency.

l Those who need training and the scope of that training have been identified. Some training has been provided. Much more has been scheduled. The training pace has picked up to a very respectable level.

l New York State Exhibit 7 sets forth the training commitment f for the Indian Point area in general terms. The specifics are detailed.

in New York State Exhibit 9, attached.

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Westchester Mass Transit FEMA remains concerned about the mass transit component of the Westchester County Radiolocical Emergency Preparedness Plan.

Westchester, of all'the'New York State Counties near nuclear power plants,_ relies to the most significant degree on buses to assist in.

evacuation from the Emergency' Planning Zone. County officials are not satisfied with the current "two wave" plan. :They are also not-able to

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assure that bus drivers, who are not. county employees, will respond.

Westchester has proposed a plan revision which abandons the-

"two wave" concept. Instead, school children will be evacuated as a.

matter of first concern. This concept.should make' evacuation more

" efficient, and should be more acceptable _to the drivers. The proposal has much merit. County and State staff are working on this significant '

new approaach with the intention of evaluating it during the March 9.,

Exercise. Funds are available to assure bus owner assistance in the

Exercise.

[ It has'been agreed that Westchester County,-State and i

licensee officials will meet immediately after the Exerc'ise to design a study of other' evacuation' issues and to propose a work' plan for. solving those problems. A qualified consultant will be retained. A six month study is anticipated.

Further comment on this issue should come directly from Westchester officials, but significant progress has been made recently, l

l and more appears on the horizon. In the interim, the National Guard l

( . compensating measure will be tested during the Exercise against the new l

j concept. We believe the use of Guardsmen in the revised plan will be feasible.

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Rockland Preparedness Rockland County has chosen to undertake a major revision of the original County Plan. The revision process is well underway. State

. staff is assisting the county. The total revised _ Plan will not be ready in time for the Exercise, although a copy of the material. completed to date has been provided to FEMA for information, and is attached as New York State Exhibit 10. The revised Plan as of February 17, has been adopted by the State for use in the Exercise.

Therefore, a State team, consistent with the provision in the State Plan for such contingencies, will manage the Rockland portion of the Exercise. There will be some Rockland presence for training and observation purposes. The precise extent of Rockland training and observation has not yet been determined. FEMA will evaluate the State effort -- not Rockland's.

We are pledged to continue our assistance to Rockland County as its Plan nears completion. We have also agreed to a full scale Exercise of the revised Plan at the County's convenience.

Status of the State Plan and the Westchester, Orange and Putnam County Plans The State portion of the Radiological Emergency Preparedness Plan has been revised to address FEMA /RAC comments, the Interim Findings, and our own refinements. The revisions dated July 7, 1982 and January 14, 1983 were previously sent to the parties. These revisions will be New York State Exhibit 6.

The Putnam, Orange and Westchester portions of the

• Radiological Emergency Preparedness Plan were similarly revised. The Putnam portion is completely revised. It is attached as New York State Exhibit 11. The Orange submission is a partial revision. It is attached hs New York State Exhibit 12.

The Westchester submission is also a partial revision. Final production of the material is not yet completed.- It will be provided.to the parties as soon as it is available, and will'be sponsored as New York State Exhibit 13.

The Plan revisions are too numerous and too varied to describe in brief.

However, for each submission a cross reference table is appended to identify Interim Findings-issues.

These tables 1should be compared with the RAC comments and the State's item by item response previously sent to the parties. That document is New York State Exhibit 4.

In developing the revisions to the County Plans, the State consulted extensively with County officials. In particular, we conducted meetings with'these officials during January and February of 1983. The Plan revisions suggested during those meetings by County officials have been made.

3.2 ' The emergency plans for Indian Point Units 2 and 3 do not conform with NRC/ FEMA guidelines because the assumptions made therein with respect to human response factors during a radiological emergency are erroneous. Hersce , the estimates of evacuation times and of the feasibility of timely evacuation for certain areas'are incorrect.

We did not submit testimony on contention 3.2 as originally formulated. However, as reinstated and reformulated above,.we can supply some information. The response of emergency workers and the public during.the accident at the Ginna Nuclear Power Plant on January 25, 1982 was excellent. Workers manned their posts, including positions near the plant. The public exhibited no panic. The plan worked.

We recognize that evacuation was neither called for nor necessary at Ginna and that the. Indian Point Emergency Planning Zone is more densely populated than the Ginna zone, but h'uman response at Ginna was as assumed when the Radiological Emergency Preparedness Plan was developed.

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3.7- The problems of evacuating children from threatened areas have not been adequately addressed in the present emergency plans.

As stated in our supplemental testimony concerning contention 3.1,.a major change in the Westchester evacuation procedures will improve our ability to evacuate children. The'new concept will evacuate schools first, and at an early stage in an accident's progress. This concept will be explored with the other counties after it hir been evaluated.

Orange County has contracted with an association of bus owners to review all aspects of its evacuation procedures. Special emphasis is being placed on schools and their pupils.

Rockland County has expressed interest in a similar study.

The State has agreed to fund the contract if one is negotiated.

Meetings with school officials in all four counties have continued on an ongoing basis to solve problems as they arise. There has been a marked increase in school officials familiarity with the Plan and its implications to schools. This is a high priority aspect of the

! Radiological Emergency Preparedness Plan.

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l 3.9 The road system in the vicinity of the Indian Point plant is inadequate for timely evacuation.

One of the significant developments reported in our supplemental testimony on contention 3.1 and referred to in 3.7, applies here as well. Elimination of the "two wave" concept makes the road situation in Westchester more feasible.

In Rockland, county officials are considering expanded use of the Palisades Interstate Parkway to expedite _ traffic flow. A "four way.

south" concept is being studied. State officials support this proposal. .

This idea is one of many that have emerged now that experienced county staff has had time to conduct an indepth review of plans and procedures.

Each county portion and the State portion of the Radiological Emergency Preparedness Plan now contains specific feasible procedures for removing highway impediments which might otherwise hinder timely evacuation.

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3.10 The_ emergency plan fails to conform to NUREG-0654 in that, contra y to Evaluation Criterion II.J.10.d., proper means for protecting persons whose mobility may be impaired have not been developed. Specifically, adequate provisions have not been made for groups named in the bases submitted for the following contentions:

WESPAC 6 Parents I, basis (22) and.II, basis (7)

UCS/NYPIRG I(B) (2) , basis (6) and I(A), basis (7).

Our testimony on original contention 4.4 (now contention 3.10) stands.

As supplemental testimony, we can advise that each of the four counties has received, reviewed and made arrangements for all those mobility impaired persons who responded to the special assistance cards mailed as part of the Public Information Brochure to most residences and businesses within the Emergency Planning Zone.

A new set of brochures is being prepared for mailing in early 1983. Putnam and Orange County material is being printed at this time.

The Westchester brochure is awaiting some final revisions. The Rockland brochure will be prepared when the revised plan is completed.

Each of the new brochures will again contain a post card for use by the mobility impaired. We urge all concerned parties to help l

l identify and then encourage the mobility impaired to make their needs know to appropriate county officials.

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4.2 The following specific, feasible off-site procedures should be taken to protect the public:

a) Potassium iodide should be provided in an appropriate form-for all. residents in the EPZ.

Our testimony on contention 4.2 stands, but we would like to add some supplemental information oa the availability of potassium iodide to_ emergency workers and other persons (prisoners, patients, etc,) who can not leave the Emergency Planning Zone.

Emergency. workers (see: supplemental testimony on' contention 3.1) will receive an adequate supply _of potassium iodide for possible use in an emergency. The State policy is being communicated to.all facilities within the Emergency Planning Zone, so that they can make arrangements to acquire supplies of the thyroid blocking agent. It is-the responsibility of those facilities to arrange for funding of the -

potassium iodide costs.

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4.7- The emergency plans should be upgraded to provide more adequate  !

methods for alerting and' informing persons who are deaf, blind, '

too young to understand the instructions, or who do not speak English.

Alerting and informing persons-with non-mobility handicapping conditions (eg: deafness or blindness) cannot be improved by an upgrade in emergency plans. If such persons are in need of special assistance to become aware of a radioloical emergency, they would require the same assistance in any emergency. Every effort is being made to identify such persons and to assist them with special arrangements. However, as with the mobility impaired, a burden remains with families or friends to

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identify individuals in the first instance.

Children are children. Parents or other_ guardians must deal with the needs of minors in advance and must see to their needs in all emergencies. The school time cases are covered ay th*e Radiological Emergency Preparedness Plan. Children in special facilities'are also covered by the plan.

A study of the Non-English speaking character of residents in the Emergency Planning Zone was conducted as part of the 120 day clock remedial action process. The study revealed very few unsupported Non-English speakers within the Emergency Planning Zone, and no predominant foreign langage among those identified. This information was supplied to FEMA which agreed that it would be impractial to develop plans or brochures in other languages in view of the limited number of Non-English speaking residents.

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