ML20094E007

Addl Info Obtained from Ny State on New York Pirg Petition Which Suppls FEMA Rept to NRC

ML20094E007
Person / Time
Site:	Indian Point
Issue date:	07/26/1984
From:	Federal Emergency Management Agency
To:
Shared Package
ML20094D997	List: ML20094D995 ML20094E002 ML20094E007
References
NUDOCS 8408090061
Download: ML20094E007 (8)

Text

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' ATTACHMENT #2 6

i ADDITIONAL INFORMATION OBTAINED FROM NEW YORK STATE ON NYPIRG'S PETITION WHICH SUPPLEMENTS THE FEMA REPORT TO NRC DATED JUNE 8, 1984 Prepared by Federal Emergency Management Agency REGION II New York, New York I

! JULY 26, 1984 8408090061 840731

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June 11, 1984 Mr. Donald B. Davidoff, Director Radiological Emergency Preparedness Group New York State Department of Health Tower Building Empire State Plaza Albany, New York 12237 M RE: NYPIRG Petition for Indian Point

Dear Mr.,

Ddvidoff:

FEMA-REP-2-NY-2 Please find enclosed a copy of the NYPIRG petition for suspension of operation of Indian Point Units (2) and (3), dated April 6,1984 (Att'ach-ment 1).

On May 25, 1984 Mr. Edward Jordan of the NRC requested FEMA to evaluate the NYPIRG petition for factual bases on allegations cf inadequacy of emergency planning for Indian Point. FEMA has identified thirteen issues raised in the NYPIRG petition and has provided responses for twelve of these issues.

Also, please find enclosed a copy of FEMA's response to the NRC dated June 8, 1984 (Attachment 2). This report provides responses to the following issues identified by FEMA in the NYPIRG petition:

I. Residents lack confidence that school children will be protected.

II. School protective response actions cannot be selected and initiated before the local Emergency Operations Centers (EOC) are fully activated.

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III. Early dismissal of schools will impact the notification and mobilization of emergency workers.

IV. Parents may not follow emergency 1.tstructions to stay away l from the schools and attempt to esacuate their children if sheltering is advised.

V. There are not enough school buses to evacuate school children.

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'. VI. Early dismissal (i.e., "go-home") procedures that may be used by school districts have not been evaluated by FEMA.

I VII. Letters of agreement for transportation resources (i.e.,

buses and drivers) are lacking. .

VIII. Governmental guidance to help school districts in radio-logical emergency planning is 1Laited.

IX. Data to enable radiological emergency planning by schools is lacking. .

X. Public education and information programs for parents are inadequate.

XI. Sheltering guidelines for school buildings are not available.

i XII. Lists of non-public schools, pre-schools and day care centers f are not maintained. ,

Many of the issues raised by NYPIRG are beyond the scope of FEHA'sc responsi-

' bilities to evaluate State and local radiological emergency planning and preparedness based on the acceptance criteria defined in NUREG-0654/ FEMA ,

REP-1, Rev.1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. This guidance document does not provide specific acceptance criteria for evaluating the plans and procedures for protecting school children. The responses contained in this report are based on FEMA's experience and the efforts of New York State and the counties su.* rounding Indian Point to develop scceptable plans to protect the health and safety of the public. In developing this ' response, FEMA has specifically relied 4 on the following:

o Regional Assistance Committee (RAC) reviews of the plans based on NUREG-0654 acceptance criteria; o exercise and drill evaluations; i

! o testimony before the Atomic Safety and Licensing-Board; and i o correspondence with New York State concerning the status of .

. radiological emergency planning for schools.

i FEMA has made every ef fort to analyze and resporid to each of these issues.

However, FEMA has not been able to prepare a response to questions that are raised with respect to the legal and financial responsibilities that schools and school districts have to participate in radiological emergency planning I in New York State. NYPIRG has raised the following questions regarding this issuet l

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o To what. extent are school districts required by New York State Executive Law 2-3 to participate in radiological emergency , e,

planning and preparedness exercises and drills, and actual -

emergency response activities? .

o What other State and Federal laws affect the schools districts' -

• obligations?

1 o To what extent can school districts require staff participation

' and under what statute, rule, regulations, or contract pro-visions? ,

t o Who will reimburse the school districts for the extra staff time and materials involved in preparing to respond to a radio-4 logical emergency?

o What State agency will monitor the adequacy of local school

! district preparedness?

4 I In addition to answers to the specific questions regarding the legal and I financial responsibilities of school districts, FEMA has indicated that' further clarification and additional information is being solicited from

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New York State to complement the information continued in its June 8th report to NRC. New York State's responses to the following questions will

' also be transmitted to the NRC in an addendum to the enclosed FEMA report.

(1) What are the specific efforts made by the NYS Public Education Management Group, including methods and means by which the group is proposing to provide information to the general public on sheltering, evacuation, early dismissal and over-all

public awareness of radiological emergencie? (Schedule of presentations, if known) *

(2) What assistance and planning guidance has been offered to local school districts and school administrators to assure they are aware 'of emergency response plans and understand their roles

under emergency conditions?

4 l (3) What is the status of the training schedule to educate the -

l school faculty members and administrations?

i i (4) What specific new public information programs will support j public education to local school' systems?  ;

l (5) What is the current status of school emergency planning l

including: sheltering, dismissal plans, parental information programs, and school emergency drills for each of the four counties?

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2 (6) What is' the status of all letters of agreement with local response organizations in each of the four counties?

Available letters of agreement should be provided to FEMA. .

(7) What agency has been designated to monitor the adequacy of local school emergency response plans?

We encourage New York State to review the NYPIRG petition and evaluate each of the issues raised. We are especially interested in receiving detailed information specific to each of the four counties so that responses to the issues listed above can be better defined to NRC.

Your prompt response will be greatly appreciated.

Sincerely, Roger B. Kowieski, P.E.

Chairman Regional Assistance Conmittee Enclosures e

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< s State Replies to FEMA's June 11, 1984 Letter Regarding NYPIRG Petition, April 6, 1984 t 4 Page 2-3:

A. To what extent are school districts required by New York State Executive Law 2-B to participate in radiological emergency planning and preparedness exercises and drills, and actual emergency response activities?

Executive Law Article 2-B does not require school districts, or any other units of local government, to participate in radiological emergency matters.

B. What other State and Federal laws affect the school' districes' obligations?

We are unaware of any Federal laws on this subject. There are generic provisions in the State Education Law which deal with emer-

! gencies.

C. To what extent can ' school districts require staff participation and under what statute, rule, regulations, or contract provisions?

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Required staff participation during school hours follows their respective union contract. School staff is also asked to volunteer for emergency situations.

i i D. Who will reimburse the school districts for the extra staff time and materials involved in preparing to respond to a radiological j emergency?

i We are unaware of any specific reimbursement provisions. Emergency preparedness is a " cost of doing business."

E. What State agency will monitor the adequacy of local school l district preparedness?

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Without State laws to require the existence of school plans, no State agency can monitor the adequacy except as an advisory body.

I Under Article 2-B the State Disaster Preparedness Commission is man-dated to provide assistance and advice in the development of all 1 disaster preparedness plans.

As stated in a letter of December 7, 1983 (Attachment E, NYPIRG Petition), the State Education Department is developing a school l emergency planning handbook for school planning guidance.

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FEMA's June 11, 19o4 Letter... -

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1. What are the specific efforts made by the NYS Public Education Management Group, including methods and means by which the group is proposing to provide information to.the general public on sheltering, evacuation, early dismissal and _over-all public

- awareness of radiological emergencies? (Schedule of presentations, if known) l The Public Education Group is exploring such methods as:

Speakers Bureau, film strips, Public Service announcements, press conferences, school visits, exhibits at fairs and similar gatherings, l

joint programs with other interested groups and similar efforts. No

. schedule has yet been prepared.

2. What assistance and planning guidance has been offered to local school districts and school administrators to assure they are aware of emergency response plans and understand their roles under emergency conditions?

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! The State Department of Education is developing a school emergency planning handbook and an emergency preparedness film for training.

l Meetings and training sessions are available to all school districts by local and State planners. Many sessions have already

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been presented.

3. What is the status of the training schedule to educate the rehool faculty members and administrations?

i See Answer 2 above.

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4. What specific new public information programs will support public education to local school systems?

See Answer 2 above.

l 5. What is the current status of school emergency planning including:

sheltering, dismissal plans, parental information, programs, and school emergency drills for each of the four counties?

i 4 School emergency planning is ongoing under the overall REP j program within each county. The slide shows will be used to provide information to parental groups. School emergency drills have brought

- varying opinions from Superintendents and their Boards of Education. ,

Some schools have agreed to drill their go home glans but by far the 4

majority find that to practice a function that tTey do daily would 1

! disrupt the education process and subject students to a potential

> accident scenario.

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FEMA's June 11, 1984 Letter... ,

t k Westchester -- Some schools have volunteered to drill although

• the last poll taken reflected the above point of view for the majority of school administrators.

Rockland -- All school superintendents and respective Boards share the forementioned point of view against drilling.

Putnam -- Poll is being taken now. .

4 Orange -- Poll is being taken now.

6. What is the status of all letters of agreement with local response organizations in each of the four counties? Available letters of agreement should be provided to FEMA.

Letters of agreement with some local response organizations are still being negotiated. All available letters will be collected and provided to FEMA in accordance with agreed upon procedures.

7. What agency has been designated to monitor the adequacy of local

> school emergency response plans?

3 See Answer E above.

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