ML20094E002
| ML20094E002 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/26/1984 |
| From: | Federal Emergency Management Agency |
| To: | |
| Shared Package | |
| ML20094D997 | List: |
| References | |
| NUDOCS 8408090059 | |
| Download: ML20094E002 (10) | |
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ATTACHMENT #1 EVALUATION OF ADDITIONAL ISSUES RAISED BY NUCLEAR REGUI.ATORY COMMISSION RELATED TO NYPIRG'S PETITION 4
TO SUSPEND OPERATION OF INDIAN POINT UNITS 2 AND 3 i
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I Prepared by
, Federal-Emergency Management Agency
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REGION II New York, New York j JULY 26, 1984 8408090059 840731 PDR ADOCK 05000247 F PDR
I. NYPIRG's Concerns:
- 1. p.4. To date, the scenarios (sheltering, evacuation, early diami==al) have not been made explicit to all school districts which will be called upon to respond.
- 7. p.12-13 Information in the emergency infonnation booklet related to evacuation of school children appears to be in contradiction to current New York State official thinking (Att. G.)
FEMA's Response:
According to the State of New York, the State comnenced a detailed infonnation program for schools as early as October 1981. Between Decarber,1981 and February 16, 1982 every school superintendent who had a role in radiological energency preparedness, schools within the 10 mile EPZ and host schools beyond the EPZ, received letters, procedures, maps and details regarding their role in case of an emergency. Meetings were also scheduled for all these superintendents and, in mest cases, they attended.
Since 1982, nost schools have chosen to becane nore involved in the planning effort arx1 in 1983 began to refine their early dismissal plans and energency disaster plans, which, at that time, were required by the State FAucation Depart-ment, as outlined in the booklet entitled: Muumum Requirements for Schools in New York State, 1980.
Specifically,Section II of this booklet entitled " Disaster Planning and Civil Preparedness in Schools" (New York State Office of Disaster Preparedness) outlines the following requirements and definitions:
Each. school district, annually, nust review and update the district's emergency disaster plans and standard operating procedures to assure that such plans and procedures are current.
Natural disasters include extreme weather conditions such as snowstorms, thunderstorms, hurricanes, tornadoes, heat and cold waves, floods, earthquakes, tidal waves, and forest fires.
Man,. de dwasters may take the fann of technological failures, accidents involving nuclear or chemical production facilities or the transportation of sucn materials, fires and explosions, and environmental pollution related or unrelated to the above.
Enemy attack could cause severe damage fran blast effect, fire and fallout, and could deliver chenical or biological agents.
Every county and several cities have an office which has the primary responsibility for disaster preparedness and civil defense. This office, by whatever name known locally, is charged with the coordination of survival, recovery, and governmental functions in accordance with the mandated " State of New York Emergency Operations Plan" prepared by the New York State Office of Disaster Preparedness. This local office should be contacted regarding assistance to the school district in the I develognent and/or refinement of school district planning and to insure that school district plans are consistent and in concert with local connunity efforts.
Plans must take into account the variable effects of each type of disas-ter providing for protection and/or orderly dispersal of students. Plans include a "Go Home" plan and a " Stay Where You Are" plan with variations with regard to licensad fallout shelters, the " safest area (s)" of a school building, and " duck and cover."
In addition to disaster preparedness planning, every school system should provide instruction which will effectively prepare students to respond to
. any disaster situation in an intelligent, practical way and, hopefully, to save their lives in the process. Instruction should be at the elementary school, junior high school, and senior high school levels; chould be an element of regular instructional activity; and should provide basic information and an understanding which can be translated into an appropriate response if and when a disaster strikes. Instruction may be based on any appropriate course area including Strarrl V of the Health Education curriculum and "Your Chance to Live," a publication of the Defense Civil Preparedness Agency of the Federal governnent. This publication is on hand in many districts and available, in limited quantity, fran the local disaster preparedness office.
In addition to the information provided by the State, on May 3,1984, hYPIRG subnitted numerous documents to FE4A which they obtained fran the State of New York urxler the Freedom of Information Act. A review of these documents revealed that school districts and school administrators / principals have indeed been contacted, and their roles and responsibilities in radiological emergency planning discussed.
Also, as we stated in our initial response to NYPIRG's petition dated June 8, 1984, issue number IX, the study conducted by Argonne National Laboratory revealed that a majority of the school organizations had been contacted regarding their role in the Indian Point Radiological Emergency Response Plan for the county.
Sane school organizations had received training in evacuation procedures.
With regard to NYPIRG's claim that the emergency information booklet' related to evacuation of school children contradicts the current New York State official thinking, the Stau responded as follows:
"Many discussions take place between concerned parties during plan developnent stages and in ensuing years (ref. answer to NRC question 5).
The purpose of ongoing cooperation and the REP program is to keep plans current and implementable.
Neither the Disaster Preparedness 0:xrmission ncr the county officials have developed new implementation procedures that contradict the booklet,
' Indian Point, emergency planning, and you' ."
In summary, EH4A concluded that:
New York State Education Department requires that each school district is responsible for the review and update of the district's energency plans and procedures.
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Three response options for school children (sheltering, evacuation, early dismissal) are presently contained in the county plans and are covered in the Public Blucation Brochure for each of the four (4) counties within the Indian Point plume exposure pathway EPZ.
School superinterxlents/ administrators have been provided with details regarding protective response options and their role in case of an energency.
Actual selection and implenentation of protective response options for scMol children will be tested during the forthcaning exercise.
New York State concitried that there is no contradiction between the Public Education Brochure and the current New Yo A State official think-ing.
II. NYPIRG's Cbncerns:
- 2. p.8. The representations given by certain State and county officials regarding planning and preparedness for schools were inaccurate and assurances were eipty prunises.
- 3. p.8. Inconsistency exists between NY State Department of Education (B. Walsh) and NY Director of Rad Bnergency Preparedness Group regarding the education law of NY requiring school districts to fonallate plans for early M ami aa=1/go-hane.
FEMA's Response:
NYPIRG contends that certain representations given by New York State and county officials regarding planning and preparedness for schools were inaccurate and assurances were anpty pranises. To prove this, they cite an apparent inconsist-ency between testimony of Mr. Davidoff, Director of the Radiological Energency Preparedness Group, and a statenent made by Dr. Walsh, Administrator for Educational Facilities and Management Services, New York State Departnent of Education.
In address 1ng this NYPIRG concern, the State indicated that:
The alledged (sic) inconsistency of Mr. Davidoff's testinony ml Dr.
Walsh's letter was explained to Ms. Joan Holt of NYPIRG in i Niephone conversation between Ms. Holt and Dr. Walsh, February 29, 1984.
Dr. Walsh explained that although there were no specific education laws and regulations requiring schools to develop such detailed go hane plans, such laws have not been necessary as this planning has been a routine standartl operating procedure based on custon anc1 context of Article 2-B of. the State Executive Law which is the 'masterplan' of local munici-pality and political subdivision anergency planning, underwhich (sic) schools are included."
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FHM has also reviewed several letters by Dr. Brian Walsh whereby he strongly encourages all school officials to beccrae involved in attending meetings and urged school administrators / principals to contact him for any assistance they may require in producing adequate energency plans. On one occasion Dr. Walsh wrote to all school officials in Rockland County on the New York State Radiolcx3i cal Energency Plan (dated August 15, 1983). Here he defined specifically the three response options for schools. Dr. Walsh also stated:
"Because the characteristics of each school population vary considerably, the guidelines which appear in this memorandum are of necessity broad. It is the responsibility of school officials to develop specific plans to meet the needs of students for whan they are responsible."
FHM agrees with the State that there was no inconsistency of substance between Mr. Davidoff's and Dr. Walsh's statemeits reganhng planning requirenents for schools. tbte also that as indicated in FHe's response number I above, since 1980 certain disaster planning and preparedness requiremnts have been enunciated for thw York schools although they were not strictly speaking a matter of law.
III. lEPIRG's Concerns:
- 4. p.lO. FDR has consistently identified deficiencies in the area of an inadequate public information, education and notification program.
- 6. p.12. FDR has repeatedly pointed out that, despite distribution of the emergency information booklet to households in the EPZ, many residents do not know such basic data as the meaning of the warning sirens.
FH e's Response:
As agreed in the June 26, 1984, telephone conversation between the Nuclear Regulatory Ocmnission (tRC) and FHM staff, FH%'s response will treat only public information, education and notification deficiencies mentiored in the two most recent post-exercise assessments cited by INPIRG in its footnote on p.lO of the petition, i.e., the September 26, 1983 assessment report and the April 14, 1983 assessment report.
Notification. FS M recognizes that in the past (1982 exercise), there have been probtens with the offsite siren systen for the Indian Point sites. However, since then, the utility has upgraded the siren systen by rroving existing sirens aryl providing additional sirens within the EPZ. The original 88 sirens were increased to about 150. In fact, there were no deficiencies in the March 9, 1983, exercise that linked to the siren system. In the August 24 and 25, 1983, exercise (Septenber 26, 1983 report), there appeared to be sonewhat of a problen in hearing sirens in Rockland County. It should be noted, however, that until recently, only spot-checks could be used to discover problems with siren systens.
In the past, some aspects of the total alert and notification (A&N) systens (e.g., call-down capability,15-minute notification within 5 miles of the site, Dnergency Broadcast Systen (EBS) activation aryl broadcasting) have been observed during exercises and evaluated by FDR. However, FD R has not yet been able to concluct design reviews of entire systens in accordance with IUPE-0654/FHM-REP-1, Appendix 3, criteria. This process entails a technical engineering review of the alert and notification system itself as well as the conduct of a statistical telephone survey of the population of the EPZ.
Historically, FINA has not had the requisite technical expertise and guidance to
-perform such reviews. The subsequent developnent of the testing criteria through contractor support was time-cmsuming. However, FEMA will publish its " Standard Review Guide for the Evaluation of Alert ami mtification Systems for Nuclear
- Power Plants," FEMA-43 in final form by August 31, 1984. As an interim &cument, this guidance has been tested, both in two pilot demonstrations and 5 fonnal denonstrations. These tests have shown that the telei onet survey methodology and acoustical review procedures are successful.
FEMA plans to use these methods to' test alert and notification systems at 11 plants in FY 84 and 28 plants in FY 85. The utilities operating the Indian Point units currently plan to subnit to FEMA the acoustical design of their 1%N system in mid-August 1984. Due to the time necessary to perform the engineering review and the quality assurance tests done through cmputer modeling, the telephone survey will probably take place in February 1985.
Public Education and Information. The April 14, 1983 post-exercise assessment reported that spot checks in Westchester, Rockland, and Ora.x3e Counties revealed that many people interviewed neither understood the meaning of the sirens nor knew that they were supposed to listen to EBS messages over the radio. However, it is important to note that since the Rockland 03unty plan had not been cm-pleted, no public education brochures had been distributed in Rockland County within the year prior to the exercise. In Westchester County , information brochures were not distributed until June 1, 1983. In Orange (bunty, brochures had been distributed only a week before the exercise. The primary cause of the lack of awareness in Westchester County and Rockland County was, we believe, due
@ the distribution problem rather than the format and content of the brochures, which had not yet been received by the public. The September 26, 1983 post-exercise assessment also lists problems in public awareness of emergency procedures in Rockland County. However, it also mentions that many improvements have been made, i.e., that an interim brochure had been distributed, radio-spots had been broadcast, etc. When the final brochure is distributed in Rockland, we i
anticipate that the situation will be improved. However, public awareness will be checked again at the time of the Fall 1984 exercise at Indian Point.
FEMA strives for clarity and effectiveness in the public education materials distributed in the vicinity of the nuclear power plants. In fact, in addition to individual review of brochures currently performed through the FEMA Regional offices, FEMA is now in the process of performing, through a contractor, a uniform review and critique of sone seventy (70) existing brochures for reactor sites across the mtion, including Indian Point. Using established educational criteria, the contractor is to determine the reading and coaprehension level of each brochure and set guidelines for future publications.
In the case of Indian Point, we intend to verify each year that the information 4
contained in the brochures agrees with the information in the plans. However, we also recognize that the style, reading level arxl manner of expression of the documents are important in determining hos mucn information is retained by the public. It is anticipated that the review of the Indian Point brochure and the general guidelines will further improve the current Indian Point public infonna-tion materials.
IV. NYPIRG's Concern:
- 5. p.lO. The description of the Red Cross role at reception centers does not ooincide with the function that the Red Cross acNally agreed to perfonn (Att. F).
FEMA's Response:
On July 13, 1984, New York State responded to NYPIRG's concern as folloas:
"The September 29, 1983 American Red Cross letter, written by Mr. Michael Reilly, Director of Disaster Services to Ms.
JR Dillenback, REPG has been taken out of context. The Septenber 19 letter refermd to by Mr. Reilly was a request by Ms. Dillenback to review the reception /corgregate care system presently in place and to, once again, look at the possibility of conbining their function ard the context of their letters of agreenent. Previous phone conversations and meetings between the state and the American Red Cross indicated such a possibility for future consideration."
Red Cross has the primary responsibility at the Congregate Care Center facility.
Here they will provide food, clothing, shelter, first aid an1 other basic ele-ments for confort and survival. It is important to note that the Statement of Understanding between the State of New York and the American National Red Cross clearly describes the responsibilities of the Red Cross at sheltered facilities:
In carrying out its responsibilities to provide for mass care in peacetime disasters, including precautionary evacuations and peacetime radiological emen3encies/ nuclear accidents, the American Red Cross will operate appropri-ate facilities (congregate care centers) and arrange for mass feeding and other appropriate support.
The American Red Cross disaster responsibilities are nationwide. Therefore, when the local chapters in the affected areas are unable to meet the needs of disaster victims, the resources of' the total organization are made avail-able.
Furthermore, the Statement of Understanding states:
In the case of peacetim radiological emergencies / nuclear accidents, which have conpany or owner liability implications, the American Red Cross will conduct shelter and feediry operations in centers ard facilities designated in advance by the Office of Disaster Preparedness, urder arrangements worked out among the Office of Disaster Preparedness, the American Red Cross and official or owners of the buildings.
In New York State, the Department of Social Services has the primary responsibil-ity at the Reception Center. Social Services will provide initial assistance to the evacuses such as registration, decontamination (if necessary); first aid; and the release of evacuees to housing of their choice; including Congregate Care Centers. In addition, the Department of Social Services will coonlinate activi-ties of the Red Cross, Salvation Army, and other recognized volunteer organiza-tions.
In suninary, FalA finds that the Red Cross role at sheltered facilities (congregate cam centers) as described in the Statement of Understanding be-tween the State of New York and the National Red Cross coincides with the role described in the New York State Radiological Dnenjency Response Plan for Iniian Point.
V. NYPIRG's Concern:
9.'p.15. The survey conducted by AE (under contract with FEMA) anring January 22 to February 19, 1983, revealed lack of trainir.3 in emergency procedures
, and lack of <ytidance provided to schools. During the ensuing year, there is no evidence of inprovement in training and gnidan~.
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FEMA's Response:
Based on information provided by the State of Ne# York, it was deternnned that many meetings have baen held and information shared between planners arvi county and State officials and school administrators over the last year especially due to; the develognent of the Transportation Safety Planning Group's (TSPG) plan in
. Westchester and Rockland, the Conpensating Measures Plan in Rockland, and the developnent of slide shows for each county that are presented to clubs, schools, PTA's, etc., as requested (Rockland has not completed their show to date).
In addition to the information provided by the State, on May 3,1984, tWPIRG subnitted numerous documents to FH4A which they obtained fran the State of New York under the Freedon of Information Act. A review of these documents revealed that school districts and school administrators / principals have indeed been con-tacted, and their roles and responsibilities in radiological enurgency plannmg discussed. (see also FH4A's Response #II)
Also, as we stated in our initial response to INPIRG's petition dated Jane 8, 1984, issue number IX, the study conducted by Argonne National laboratory revealed that a majority of the school organizations had been contacted regarding their role in the Indian Point Radiological anergency Response Plan for the county. Some school organizations had received training in evacuation procedures.
VI. NYPIRG's 03ncerns:
- 8. p.14. The routine early dismissal plan does not incorporate special needs (i.e., during an emergency children should not be sent home on foot or dropped off at unattended road intersections).
- 10. p.15. The "go hone" plan is not feasible hamnaa of changing social condi-tions, (i.e., it is no longer true that the majority of fanilies have soneone home during the day).
- 12. Amanlir K - issues raised by Village of CrotnH]n-Hudson officials on irwiarpwies related to evacuation of 130 anbulance evacuees, ocxmunication capability of police and dosimetry for emergency workers.
FEMA's Responses i As agreed in the June 26, 1984 telephone conversation between NRC and FB4A Staff, FD4A's response will not treat matters raised in Issue 12, as they are presented on NRC's list. Issue 12 refers to Appendix K of the NYPIRG petition, which was a May 19, 1983 letter fran the Village of Croton-on-Hudson, New York to FH4A. The NYPIRG petition refers to it in a footnote only in connection with Section F of the letter, which raises a school evacuation issue. The same matter was also raised in issues 8 and 10 on the NRC list so a conbined response has been prepared for issues 8, 10, and 12.
With regard to the statement on page 14 of NYPIRG's petition, the provisions for early dismissal of schools are contained in the plans and covered in the Public Edacation Brochure for each of the four (4) counties within the Indian Point plume exposure pathway EPZ (this issue was previously addressed by FIM\ in its evaluation of NYPIRG'c petition dated June 8,1984 issue number X) .
In addition to question number 8 on the previous page, NYPIRG gives the example on page 14 of their petition:
'*Phe teenage babysitter or grandnotherly neighbor who can care for a child sent haae with a sore throat, during a snow stonn, or after school while the parents work, may not have a car or may not be an appropriate person to handle an evacuation slould the need arise."
It is important to note that neither the State of New York or Fil4A are aware of any infonnation regarding the views of parents and teachers as well as sone school adnunistrators on the subject of canparison between radiological emergen-cies and snow days.
The REP training programs and literature do, however, stress that early dismissal is based on ensuring that the children are wherever their parents want then to be prior to any possibility of a health hazard due to a radiological emergency. A review of the documents obtained by NYPIRG fran New York State under the Freedan of Information Act noted examples of school districts having detailed procedures in place for notifying parents in the event of an emenjency early dismissal and for securing alternative contacts when parents cannot be reached by phone.
One example cites the following procedures developed by school district officials and principals dated March 13, 1984:
Verification fonas for nanes and phone numbers of alternative contacts will go home with students in the 3nl quarter report card envelotes.
Teachers will follow-up to insure that a return is received fran each child.
Class lists will be updated at the local building to include the child's home phone and the alternate names and phone numbers of the person to be contacted.
Updated class list information will be distributed to class nuthers.
A master list will be maintained in the principal's office. Changes requested by parents will be recorded and the appropriate people will be notified of such change.
In the event of energency early disnissal, principals will notify the chairperson of the class mothers cannittee or the alternate (s) to initiate telephone contact to parents.
Parents have to be reminded to give specific instructions to their children for emenjency early disnissal in the event that the parents or the alternate person can't be reached by phone.
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--With respect to INPDG's concern regardiry the Blue Mountain Middle School Drill, New York State responded on July 13, 1984 with the. following:
"Fbr the record, we respectfully subnit the following facts:
The drill was a surprise to the faction of personnel to be tested.
The caly people who knew of the date were the School Superintendent and the School Principal. Teachers, drivers, dispatchers, etc. . . . .
were tested.
The phone survey conducted in White Plains was not part of the drill.
The intent of that survey was to test some state-of-the-art equipment for speed calling. Second calls were not made as the contact was rot part of the drill.
As to the conclusion based on the " Blue Mountain School telephone drill",
- that was not a drill. State and local planners and officials reinforce their statenents that due to changing social conditions it is imperative that each parent identify a place for their child to be taken in the event of g emertjency. - Go hone plans are not new for the creation of REP planning.
01urr.hes, neighborhood safe havens, etc..can be identified and have been designated during this plan awareness period."
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