ML20134M714
| ML20134M714 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/30/1985 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| CLI-85-06, CLI-85-6, NUDOCS 8509040230 | |
| Download: ML20134M714 (31) | |
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gg g M49 g Federal Emergency Management Agency Washington, D.C. 20472 Ik-s AUG 3 01985 MEMORANDUM FOR: Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement N r egu a or ommission FROM: g ic ard' T'. hlte Assistant Associate Director Office of Natural and Technological Hazards Programs
SUBJECT:
Indian Point Special Proceeding Decision (CLI-85-06)
This is in response to your memorandum of June 17, 1985, requesting that the Federal Emergency Management Agency (FEMA) provide information in response to certain items in the May 8,1985, Commission Decision (CLI-85-06) on the October 1983 findings of the Atomic Safety and Licensing Board (ASLB) on Indian Point. You also asked for information on the current status of emergency planning at Indian Point and on whether deficiencies identified by the Hearing Board and by the Commission in the a proceeding have been corrected. Finally, FEMA was asked to advise NRC on q two Board recommendations: 1) emergency planning related to aovance alerting of the public during adverse weather conditions, and 2) additional measures for communicating with handicapped or non-English-speaking
, people.
The attached report, prepared by FEMA's Region II office, provides the information you requested. The original deadline was extended because of the work-intensive schedule of the Region II office and because New York State was requested to provide additional information.
We wish to note that in the May 1985 review of the revised Westchester County plan, the Regional Assistance Committee found that letters of agreement (LOA) with bus companies were not incorporated or referenced in the plan. The State subsequently submitted four LOA's, which were found to be improperly executed. FEMA Region II wrote to the State on July 26, 1985, in an attempt to resolve this issue. However, the State's
, August 6, 1985, response continued to support the existing version of the LOA's. In addition, some concerns also exist with LOA's for reception ;
and congregate centers. Details on these issues are contained in the attached report.
f 8509040230 850830 PDR ADOCK 05000003 F PDR
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i As an additional note, FEMA is in the process of developing a Guidance Memorandum on Evacuation of School Children which will discuss, among i
other things, evaluation of plans in .which early dismissal is an option for the protection of school children in the event of a ractiological l emergency at a nuclear reactor site. It is still in the draft stage at the current time, however.
If you have any questions, please feel free to contact me at 646-2871 or
- Robert S. Wilkerson at 646-2861.
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i Attachment As Stated i
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FnWs Respcmse to the 02anission Decision on Indian Point ,
Dated May 8, 1985 I
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i I. INTRODUCTIN
'1he Atomic Safety Licensing Board (ASG) 'in its reconnendation to the Nuclear Regulatory Cbmnission (NRC) on Indian Point, dated October 24, 1983, addressed each planning standard as .it applies to the Westchester, Putnam, and Orange Cbunty plans. With regtxd.to Rockland County, the AS W decided not to evaluate the Rockland Couaty plan against each of the planning standards of 10 CFR 50.47(b) and 'NUREXM)654 since neither the Rockland County plan nor the State Conpensatory Plan were complete at that time. On February 1,1984, the Federal Emergency Management Agency (FDR) subnitted its connants on the findings of the ASG to the NRC's staff.
FDR's report, datal January 30, 1984, addressed the status of planning {
and preparedness around Indian Point at that time.
'Ihe Omnission in its decision datei May' 8,1985, directed the NRC staff to confer with m% and report to the Cannission on the current status of emergency planning at Indian Point i and Whether or not the deficiencies identified by the ASm and by tha 02nnission have been corrected. In the June 17, 1985 letter from Mr. FAard L. Jordan of NRC to Mr. Richard W. Krimn of FDR, the NRC formally ^ requested the assistance of FDR in evaluating the status of off-sita energency preparedness at Indian Point. In addition, FDR was requested to advise the NRC staff at the advisability of two Board rm..wdations including:
inprovement in energency planning relatal to advance alerting of the public during adverse weather conditionst j need for additional- measures for connunicating with~ handicapped
' l and non-English speaking people. .
In acmrdance with this requast, mm subnits this rep:>rt diich is divided into two sections:
Canission Question 3: Status of Brar p ,cy' Planning at Indian Point; Comnission Quest, ion 4: Inprovements' in Dnergency Planning.
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, II. O'M1ISSIG4 QUESTION 3: SrKIUS OF EMERGENCY PIANNING AT INDIAN POINT t
A. Status of L. @ .cy Planning in Rockland County i
ASIA's Finding he Board concluded that planning and preparedness were generally deficient and that the (then) draft Ibckland plan, that the State had adopted as a ccmpensating measure, had " substantial" omissions, including school children, for adequate training, and for
- inplementation provisions for evacuating' of public education requirements. Se Board reached no conclusion as to the adequacy of the "New State Q:mpensatory Plan," which was used during the August 1983 exercise, nor was the Board aware of the status of the planning progress in Rockland in the 5-amth period between the close of the record and the issuance of its Opinion.
7 n=dmaion's Comments 1 i he 0:nmission directed the NRC staff to confer with fBR to deter-mine dwther the deficiencies have been corrected.
FDR's Response In FDR's response of January 30, 1984 to the ASIE's rhtion to the Cbnmission on Indian Point, it was reported that the State Otmpen-satory Plan for Rockland County was reviewed and found adequate by the l Regional Assistance Conmittee. In addition, this plan was successfully j tested during the exercise on August 24-25, 1983. Based on EDR's review of the State Cbrpensating plan and the results of the exercise cn Septentzer ,
29, 1983, FDR concluded that there was an adequate level of emergency preparedness in Ibckland County to protect the public in the event of a radiological energency at the Indian Point Nuclear Pwer Station.
he level of emergency planning in Rockland County has significantly advanced since the close of the Atmic Safety and Licensing Board's record
, and FDR's report to NHC of January 30, 1984. On February 7, 1984, the Rockland County Imgislature voted to join the four-county planning effort and to regain lead responsibility in energercy preparedness for the Irdian Point Nuclear Generating Staticms.
On February 16, 1984, the first task force meeting was held to develop a new Rockland Cbunty Emergency Response Plan. Representatives from the State, County and FDA attended that meeting. Se task force identified idiate and long4.erm goals. Se inmediate goals included:
plan developnent including the input frun ea& county agency with respect to their resources and SOPS, I
i-training of all energency response personnel.
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l 'Ihe long-term goal identified was that Ibckland County would assume full responsibility for emergency preparedness upon the approval by both the State and FEMA of the overall preparedness in Rockland County.
On October 9,1984, the draft Rockland County plan was subnitted to FEMA for review and consnent. 'Ihe plan was reviewed by FEMA and the Regional Assistance Conmittee. Discussions of these reviews were held with the State ard County officials cn November 1,1984.
On Decen1ber 10,1984, EEMA fccmally subnitted the Reg'onal Assistance Conmittee's (RAC) review of the Rockland County plan to the State. Over-all, the plan properly identified all organizations that were intended to be part of overall emergency response and their respcnsibilities during a 1 radiological emergency. Although FENA identified sane in=&qeies in its review of the draft Ibckland County plan, it was determined that this plan contained all critical elements na====ly to test the capability of ;
Rockland County to respcmd to a radiological incident.
l 'Ihis plan also included provisions for evacuating school children, for 2
adequate training of emergency workers and for inplernentation of public education requirements Which the Board found to be deficient in the State Conpensating Plan.
With respect to school children, Rockland County's RmM nlogical Emer- '
1 gency Preparedness Plan states that at the ernergency classification level
- of " alert or greater energency", the Assistant Superintendent of Business and Finance will direct the Administrators of Schools to take one of the appropriate following actions
PRIOR to 6:30 AM, classes will be cancelled for all schools in Rockland County. School superintendents and local radio stations will be advised of this action.
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4 APIER 6:30 AM, pone or all schools in Ibckland County are in
!' the process of opening, the Adninstrators of these schools will be directed to follos school closing procedures, having i arriving buses return their students to their homes, and to
- have students Who do not normally use buses return harne in their usual manner. 'Ihe radio stations will be notified of the closings of schools.
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i DUR1tG SCHOOL IOURS, the A&ninistrators of the schools will send their students home, or to an alternative address pre-viously designated by the parents, in accordance with each t
school's "Go Hane Plan", developed fcr use in case of a fire, explosion or similar emergency.
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If the energency is not radiological in nature, the Emergency Coordinator may order the continuation of normal school sessions until the end of the school day, at which time students will return hane in their usual manner and on their regular schedules. .
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- In the event the "Go Ibne Polich is not the potentially safest course of action, based cn instructions from the Chairman of the legislature, the Assistant superintendent Business and Finance will direct the affected schools to evacuate to a School Recepticn Center.
Schools outside the 10 mile EPZ will be advised of the situaticn arri informed of the possible need fcr use of their facilities as Reception Centers.
'Ihe Assistant Superintendent of Business and Finance will assure that any movement of children other than the early dismissal plan will be coordinated with the Public Information Officer for EBS instruction.
If a " State of Emergency" is declared by the State of New York during a radiological event, State officials would be respcnsible for directing and controlling the situation and supplementing Rockland County resources.
With regard to provisions for inplementation of public education reqairements, the State, in conjunction with the four (4) counties, developed in 1984 a Public Informaticn Procedural Manual. 'Ihis manual states that information shall be made available to transients via informa-tional stickers and telephone directory inserts. 'Ihis information will be made available to managanent personnel of all public buildings, public parks, hotel /motelo, rgstaurants, shoiping centers, schools and office conplexes.
With respect to training of emergency workers, the plan states that Rockland (bunty, in conjunction with the New York State ram nlogical Emergency Preparedness Group (REPG), is charged with establishing a suit-able training program that is specifically oriented toward radiological release incidents for all county emergency response agencies including nutual aid agencies. In addition, Rockland County in connection with the State REPG, has the primary responsibility fcr establishing initial training and periodic retraining of all county emergency respcmse person-nel agencies including nutual aid agencies.
Although the RAC determined that the plan needs to be revised to incorporate the details of training, the State of New York provided FDR with the ca.prehensive sunmary of training conducted in 1984. In an
, August 6, 1985 letter, the State informed FD R that the report regarding the first six ntnths of training activities in 1985 is now being prepared.
l As of this date, FDR has tr:rt received a copy of this report.
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In preparing for the Novenber 28, 1984 full scale exercise, Rockland County held a table top exercise on Noveter 14, 1984, which FDR informally evaluated. FDR's feedback was shared with all asunty partici-pants on Novenber 15, 1964. On Novenber 28, 1984, the joint exercise of the plans ard preparedness for off-site energency respcnse organizations and personnel was conducted for the Indian Point Nuclear Power Stations.
his was the first time since March 1982 that Rockland (bunty fully participated in the exercise with the State and remaining three (3) oounties.
Based cn FDR's detailed analysis of the findings and evaluaticus of the federal observer team, two deficiencies were identified during this exercise that would lead to a negative finding. In brief, these deficien-i cies were:
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@e information and issuance of EBS messages from the Joint New Center was not timely; and, Decisions regarding protective acticm reccmnendations were delayed in Rockland (bunty.
In accordance with EDR rule, 44 CFR 350.9, and the NRC rule 10 CFR, Appendix E, FDR scheduled and evaluated a remedial exercise cn April 10, 1985. mis remedial exercise was designad primarily to test whether or I l not these two (2) deficiencies had been corrected. To acocmplish this, it
{ was necessary to activate fully the Joint News Center and Rockland County Emergency Operations Center (EDC). 'Ihere were only partial activations '
and limited evaluations of energency respcnse organizations in New York State and Westchester, Orange and Putnam Counties.
Based on the evaluation of the April 10, 1985, exercise by a team of federal observers, both deficiencies identified during the Ncneter 28, 1984 exercise were corrected.
On May 14, 1985, the FD% Regional Director concluded that the level of planning and preparedness in Rockland County had reached a point where he could provide reascnable assurance that the public health and safety of the citizens within the emergency planning zone (EPZ) could be protected.
Werefore, there was no longer a need for the State Coupensating plan for Rockland County. Consequently, in the May 14, 1985 letter to Mr. Herbert Reisman, Chairman of the Rockland County Imgislature, Dr. David Axelrod, Chairnan of the New York State Disaster PreparedrAss Otanission stated:
. . . . I have notified the Governor that the state conpensating team is no longer required to supervise preparedness activities in Rockland County. We team has been disbanded, and formal responsibility returned to you, as chairman of the County Imgislature.
4 B. STATUS OF ENEDGENCY PIANNING IN WESIQiESTER, PlmOM AND ORANGE QXNTIES
- 1. ASSIGtNENT OF _ RESPONSIBILITY - NUREKM)654 - PIANNING STANDMtD A 10 C.F.R. 50.47(b)(1) j ASIB's Firvlings:
i No significant deficiencies.
Q:rmtission's Comnents:
No comnents were made regarding this planning standard.
FDR's Response No Federal Action is required.
- 2. CNSITE DERGENCY ORGANI2ATIN - NURm-0654 - PIANNING STANEARD B 10 C.F.R. 50.47(b)(2)
ASIE's Findings:
l No significant deficiencies.
Ocmaission's ocm nents:
No hu d.s were nude regarding this planning standard.
FDR's Responses No Federal Action is required.
- 3. ENERGENCY RESPCNSE SUPPORT AND RM11RCES - NURED-4654 - PIAtNING STANDMtD C 10 C.F.R. 50.47(b)(3)
ASIB's Findings:
Record inconclusive as to existence of letters of agreenent with reception and congregate care facilities.
Ocasuission's rv==nts:
Further, though various schools were designated as reception centers or congregate care facilities and were notified of their designation, not all
,o accepted the designations and letters of agreement are missing for most of them. Transcript at 11,919-23, page 47.
's he Comnission directed the NBC staff to confer with FD% and report cn the status of conpliance with this requirement.
FD%'s Response In FDR's response of January 30, 1984 to the, ASIA's Reconmenda-tion to the Comnission, it was indicated that cn December 23, 1983, FD%
requested the State of New York to incorporate or reference the agreements with reception and congregate care centers in the plan. On January 6, 1984, the State responded to our reconmendation by saying: -
Congregate Care Centers letters (Red Cross and building cuners) exist and are listed.
If recepticn centers are placed in public schools, there are no agreements, so none can be listed.
FDR found the State's respcuse to be too general and not adequate in providing detaf1s on the subject of the inquiry and EDE requested that all letters of agreement be provided for review.
he RAC cczipleted its review of the draft Rockland County plan in November of 1984 and the revised Westchester, Putnam and Orange Cbunty plans in May 1985. hese reviews revealed that letters of agreement with reception and cxangregate care centers were not included or referenced in the four (4) cxaunty plans. FDR requested that all letters of agreement, that are currently in effect and those to be obtained, should be refer-enced in the plan as well as be signed and dated. On May 30 and 31, 1985 meetings were held among FDR, RAC, New York State and Westchester, Orange and Putnam County representatives to discuss the results of the EDR/RAC plan review.
At that meeting each county stated that most letters of agreement are on file and that they would be submitting them to FD% through the State shortly.
In a July 1, 1985 letter to FDR, the State indicated that they agreed to provide a listing of agreements in the plan. We actual agree-ments are on file and available for FDR/RAC's review. Furthermore, in a July 18,1985 letter the State informed FDR that:
Westchester Cbunty has letters of agreement with each reception center. Putnam evacuees
- go to Dutchess Cbunty. Were is a letter of agreement with the Dutchess Mall as the primary center.
Se county is obtaining additional school agreements through the Red Cross. Rockland County school districts have premised their plans cm Article 2-B of the Executive Law and the ability of the Chief Executive to
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use the facilities during a local emergency declaration. W e plan therefore is based upon the Chief Executive's order to opm the schools as reception centers (refer pg. IV-43).
Were are therefore no letters required.
Orange (bunty has letters of agreement with ,
each reception center.
On July 26,1985 FD%, in a follow up letter to the State, requested a further clarification of the Executive Law 28. Specifically, FD%
pointed out that the latest State's position appeared to be in conflict with their previous reply to EDR's June 11, 1984 letter regarding the NYPIRG Petition Where they stated that the Executive Law, Article 2-B does I not require school districts, or any other units of local governmmts, to participate in radiological emergency matters.
In the July 26,1%5 letter, FD% also restated its previous position that letters of agreement are required with schools designated as reception and omgregate care centers for each of the four (4) counties including Rockland County.
On August 6,1985, the State provided FEMA with some letters of agree-ments with school districts and other types of facilities dtich serve as Reception and/or Congregate Care Centers. Wese letters of agreement are primarily fran Orange and Westchester Counties. W e State has also advised FD% that they are awaiting copies of the agreements for Putman (bunty, and will forward them to FD% upon receipt. With respect to Rockland County, the State replied that:
Were are letters of agreement for primary facilities established as Cbngregate Care Centers for Rockland County. W ese facilities are adequate to handle the ntnber of evacuees, although additional facilities would be optinzu.
Diligent good faith efforts by State, Cbunty, and Red Cross staff to cbtain these additional letters of agreement have bem unsuccessful to date.
However, Rockland County and REPG staff will jointly explore the possibility of finding and using other suitable sites Where letters of agreement may be obtainable. Furthermore, we have requested the Red Cross to attempt again to d:rtain letters of agreenent and to provide us with copies of the previously signed letters.
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l By nutual understanding between Rockland Cbunty ard the participatiry schools, there are no letters of agreement for the sites Whi& are utilized as Reception Centers. Instead, the schools have agreed to respond ard to make their facilities available if the Qxalty Chief Executive gives than an order to do so in accordance with a duly executed County disaster declaration. 'Ihe Rockland Cbunty plan has been rewritten accordingly, and adequately
' demonstrated. I do not forecast that we .
will obtain letters of agreement with schools Whim are usa $ as Reception Centers in Rockland Cbunty. .
i IArtters of agreenent have, however, been obtained for the Reception Centers located in Orange Cbunty and utilized by Ibckland eV3Cuees.
Because of certain penvisions of Article 2-B of the New York State Executive law, we consider the issue of letters of agree-ment to be moot. Specifically, section 21.3(f) provides: "the Cbmnission, span a firding that a nunicipality is unable to t
manage l eal disaster operations, may, with the approval of the Governor, direct the l
i tenporary organization to assume direc-tim of the local disaster operations of such nunicipality, for a specified period of time, and in su& uses su& tenporary organizatim shall asstyne direction of ;
such local disaster operations, subject to !
the supervision of the (bmnission. In such event, su& organizaticn may utilize i such nunicipality's leal resources, I provided, however, that the state shall not be liable for any expenses incurred in
- using such nunicipality's resources."
'Ihe New York State Disaster Preparedness Oczanissicn has anple pwer and authority
! to insure that required l eal resources will be available.
With respect to Rockland County, FDR feels that although, the New i
York State Executive Iaw, Article 2-B gives the Otief Executive the autho-rity to use the facilities as reception centers, pre-emergency planning is essential to have an effective and ocordinated response to a radiological j emergency. In sumnary, FDR concludes that letters of ags _ _ _ d. are required with schools and other facilities designated as reception and congregate care centers in each of the four (4) counties. Until all letters of agreement are provided to FDR, and found acceptable, this issue remains i
unresolved.
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- 4. DERGENCY CLASSIFICATION SYSTEN - NUREG - 0654 - PIANNING STANDMtD D 10 C.F.R. 50.47(b)(4)
ASIE's Findings:
No significant deficiencies. I I
Omanission's Casnents:
No connents were made regarding this planning standard.
FDR's Respoones .
No Federal Acticn is required.
- 5. NOTIFICATION MEHH006 AND PROCEDURES - NUREXM)654 - PIANNING STANDMtD E
ASIR's Findings:
No significant deficiencies, but record inconclusive with respect to the existence of or need for route-alerting or other procedures for the
- event the siren systen fails.
Ctmnission's Ocnnents:
'the existence of route alerting procedures remains an issue of fact for which there is no affirmative evidence in the record. 'Ihe 02rmission directed the NRC staff to confer with FDR and report on tM status of ccurpliance with this requirement.
FDR's Response:
Folicwing the,.1982 exercise, FDR rhe-ded that route alerting or other procedures be developed in the event of failure of the siren system. In addition, on Decent)er 23, 1983, PD R asked the State of New York 7
whether or not formal route alerting procedures exist, and in the event that there are no route-alerting procedures in place, how the public would be notified if the siren alerting system nalfunctions.
On January 6,1984, the State of New York responded to our request by stating:
Route Alerting is an established activity in each County. Detailed procedures are not necessary since this response activity is a 4 routine responsibility similar to setting g '
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4 FD% evaluated the State's response and found there is a need for additional clarification with regard to route alerting procedures. me State agreed to provide FD% with additional information (see FDR's report of January 30, 1984).
As a result of the May 1985 FDM/RAC plan reviews, it was determined that route-alerting procedures, to deal with the potential for siren failure, were not incorporated 3,nto the plans. At the HNA/RAC meetings on my 30 and 31, 1985, New York State, Westchester, Putnam and Orange counties indicated that route alerting procedures are in place arv3 will be irwirmated into the revised plans. Also, in the July 1,1%5 letter to i
FDR, the State indicated that route alerting procedures are in place in the Indian Point area. On July 26, 1985, in the letter to the State, m%
requested that route alerting procedures be submitted at the earliest date possible. In response, on August 6,1985, the state informed HMA that these procedures will be forwarded to our office with the annual plan revisions. As of this date, HMA has not received the route-alerting procedures.
It should be noted that during the November 28, 1984 exercise a sartpling of route alerting was dem21strated in each of the four (4)
~ counties and evaluated by Federal observers. he results of those obser-vations were reported in the Post Exercise Assessment dated February 27, 1985 as follows:
- Westchester County dures.
A siren failure was sinulated to test backup route alerting proce-A Westchester (bunty patrol car was deployed with a message card to read the over the unit's nobile public address system in the area served by siren. Although they did not have a specific route nap for the area covered by the siren, the drivers knew the local streets well and traversed the required area. Bey demonstrated route alerting by sinulating the use of the public address system.
Ibckland County
! he objective to demonstrate the ability to provide backup public alerting procedures, if necessary, in the event of partial siren system failure, was partly met. A local police unit equipped with a public i address system was dispatched to denonstrate route alerting of the population to be alerted by Siren 25 (around Central Highway and Route 210 3
in Stony Point) which was sinulated to have failed at approximately 1130.
IniHally, the local police could not locate the siren area nap and the mobile unit was delayed in arriving at the field location until approximately 1220. Route alerting was intially demcnstrated in the wrong )
area. After police officers were told of the error, the mit conpleted i
their route alerting responsibilities, covering the appropriate area in a satisfactory manner. It is reconmended that local organizations with backup route alerting responsibilities should be familiarized with the siren unps and trained to couplete this function in a timely manner (i.e.,
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within 45 mintues of the initial notification). Standard operating procedures were reu. .a -ded.
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i Orange County Backup public alerting procedures in the event of a partial siren system failure were successfully denonstrated via the simulated failure of I one siren. 'Ihe territory to be alerted by the failed siren was covered in about an hour. However, in a real emergency three teams would be utilized, providing coverage in about 20 minutes. Resources available for route alerting in a real emergency consist of three fire ampany auto-mobiles equipped with portable loudspeakers, and two (2) police cruisers.
'Ihe emergency worker indicated that route alerting would be conducted regardless of siren function in a real energency.
Putnam County Backup public alerting procedures, in the event of a pirtial siren system failure, were successfully deamstrated. Ibute alerting was caipleted pronptly and effectively by three Putnam County police cars.
The police officers had route maps and a written message to read over the mobile public address system.
Also, based cn these ci)servations, FEMA determined that standard route alerting procedures are necessary in all four counties as a back-up system to assure that public alerting can be accouplished within 45 minutes of the initial notification.
- 6. DEIGENCY CDMNICATION - NUREG-0654 - PLANNING STANDARD F 10 C.F.R. 50.47(b)(6)
ASIE Findings:
Record inconclusive as to adequacy of capability to cx2municate with emergency workers.
Comnission's ccanents:
The Ccmnission directed the NRC staff to confer with HM4 and report on the status of caTpliance with this requirenent.
FDR's Response:
In FDR's response of January 30, 1984 to the ASLB's Pecomnenda-tion to the Ommission this issue was addressed. At that time FL%\
reported as folicws:
During radiological exercises, the notification ard mobilization of all energency response organi-zations, especially those assigned to the EDC are tested. With regard to notificaticn of bus drivers and ambulance drivers sone rely cn radios, others on telephones.
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l Se New York State Radiological Emergency Cbmunications ,
System (REX:S) interconnects Warning Points operated cn a 24-hour basis by the Nuclear Facility Operator (NED), State '
and the four counties surrounding Indian Point Nuclear Power Stations. Wis provides a reliable and conpatible emergency convunications system. Were is also installed a backtp radio system between the NED, the county EDCs, and County Arning Points. We system uses the local government radio sets.
Connunications between contiguous States and counties in the 50-mile ingesticn' exposure pathway is a New York State respon-sibility and will be acccuplished by the State Warning Point.
Cbmunications with field radiological monitoring teams may be acccmplished by four different means:
Primary - Portable nobile radio with each team.
Secondary - Transport of the team by police vehicle equipped with police mobile radio.
. 3 Backup -- Team nay be acconpanied by a RACES operator with mobile radio.
Alternate Backup - Furnishing each team with a roll of dimes for use in public pay telephone to relay readings to the Cbunty BOC.
We Emergency Medical Cormunications System provides radio linkage between antulances (EMS and fire), hospitals, ard the County EDC. System includes fixed and nobile radio stations and operates cm a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.
Schools are equipped with tone alert radios and crmmercial telephones. Buses rely cn radios and telephones.
Were is also a dedicated executive hotline located in the Cbunty and State EOCs whicit is used to keep the four County Executives and the Chairman of the New York State Disaster Preparedness Ocmnissicn in constant oormunication to insure a total mordinated effort.
Overall, the key energency response personnel in all four counties as well as the State are equipped with pagers.
Since ED R's report to NRC on January 30, 1964, oormunications capabi-lities have inproved significantly. Additional pagers for officials have been obtained and inprovements continue to be nede in emergency agencies radio cormunications. According to the State, they have ordered three state-of-the-art mobile oormunications vans with catellite capability. We vans include telephone, radio and micrcmve systems.
In addition, during the Novenber 28, 1984 exercise four (4) counties and the State effectively demcnstrated the ability to cxzmunicate with all appropriate locations, organizations, and field personnels using primary and backup cxamunication links.
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- 7. PUBLIC EDUCATION AND INEDRMATICH - NUREn-0654 - PIRNING STANDARD G 10 C.F.R. 50.47(b)(7)
ASIB's Findings:
Public Infonnation brochures and posters were not distributed in Westchester (bunty. ,
Ocnnission's Ocmnents:
he Comnission believes the record suggests that the use of public information measures other than brochures may be desirable, and directed the NRC staff to confer with IBR and report at the status of this issue.
ED R's Response Since the close of the ASIB proceeding, revised brochures have been distributed in both 1983 and 1981. Brochures were distributed in Westchester, Orange and Putnam Counties in June 1983 and in Rockland County, based on the State Ompensating Plan, in August 1983. With Rockland County actively returned to preparedness activities for Indian Point, revised brochures and transient information stickers were distrib-uted in all 4 Indian Point Counties in Novenber 1984.
In Deceiber 1984, New York State Radiological Emergency Prepared-ness Group, in conjunction with New York Power Authority and Con Edison, incorporated energency information as an insert to telephone directories covering the entire 10-mile EPZ. In addition, as part of the ongoing public awareness program, county civil defense directors have been presenting energency information workshops for the public cn a regular basis.
'Ihe 1985 brochure is scheduled for distribution in Septenber of 1%5. We New York Stgte Public Education Management Group (PENG) which is cx:rrprised of twenty six (26) state, county and utility officials meets regularly to evaluate the success of public eduration program and ide1tify strategies to increase its effectiveness.
Currently, the PEMG is work:ng on three statewide public education projects:
Revision / redistribution of the Radiological Emergency Planning brochure for farmers; Develognent of public education materials specific to schools within lO-mile EP4's; and Investigation of the feasibility of establishing a
- statewide newsletter, specific to New York State, but generic to all counties and nuclear sites.
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k In conclusion, FDR finds the measures undertaken by the State and counties and ongoing effort by the PDG are adequate to satisfy this Planning Standard.
- 8. DERGENCY FACILITIES AND EQUIEMENT - NURa3-0654 - PIAWDU STANDARD H 10 C.F.R. 50.47(b)(8)
ASIB's Findings:
Na significant deficiencies Cbmmission's Conments:
No carments were stade regarding this Planning Standard.
FDR's Responses No Federal Acticn is required.
- 9. ATIDENT ASSESSMENT - NURm-0654 - PIANNING ST)GDARD I 10 C.F.R. 50.47(b)(9)
ASIB's Findings:
Na significant deficiencies Ocstmission's Ocstments:
No carments were made regarding this Planning Standard FDR's Response No Federal Acticn is required.
- 10. PBorecrIVE RESPWSE - NJRm-0654 - PIAMING STANDARD J l
10 C.F.R. 50.47(b)(10) I Q.1 ASIB's Findings:
". . .that insufficient attention has been given to protective actions during a severe winter storm . . ."
Ocxtmission's Conments:
2- According to the Ostmission (Chtmission Question 4, Page 51) the Board suggested that the Ostmission consider whether the energency plans needed nodification to provide for alerting the public at the Site Area i Dnergency classification level, instead of the customary General Emergency Imvel, When adverse weather conditions were likely to degrade the evactution routes. 'Ihe Comnission directed the NRC staff to confer with FDR and provide reastmendations to them.
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A.1 FDR's Response:
FDR, in its respcnse of January 30, 1984 to the ASI.B's Reom-mendaticn to the Ctztmission on Indian Point, stated:
Ihring the 120-day clock (Aug. 2 - Dec. 2,1982),
New York State provided FDR with a list and pro-cedures of State, Cbunty and private resources available to deal with inpaMments to evacuation, including sncw removal equipnent. Details cm procedures for the renoval of inpediments fran highways in the event of an Emergency, Attachment 4.
(Previously subnitted to NRC).
With regard to the ASLB's suggesticn to provide a note to the tables advising the decision-makers of '
additional time required to clear snow; this concern was forwarded to the State on Deostber 23, 1983 for consideration and appropriate action.
In the response letter dated January 6,1984, the State of New York concluded:
In January 1981, New York State evacuation experts met with PBQ&D, consultants, to resolve level of service (IDS) issues affecting the evacuaticn times. 'Ihe issue of weather scenarios was resolved throucA an agreement to include a range of realistic evacuation times for IDS E capacities representing ideal cordi-tions and IDS D capacities representing less than ideal conditions. Rewriting of the notes on each table was done to ensure provisions to the decision
- maker of adequate guidelines for selecting an evacua-tion time corresponding to prevailing conditions. 'Ibe notes clearly define the capacity corditions. Note 1 was added to each chart to read, "'1he Evacuation Time (Ranges) Es'timates presented in this table are based on operational strategies indicated in the evacuation inplementing procedures: (NYS REPP Part II, Section 1.B, Att.6, pgs.1-16) . Inherent in these procedures for each county is evacuation route maintenance, "the effects of weather (snw , rain, ice) traffic accidents, highway contruction and other ciretrnstances can inpede the novement of evacuating vehicles. Prcmpt actions will be undertaken to clear evacuaticn routes of such inpediments Where possible. Where clearing of the evacuation route is not possible, alternative routes and links will be established with police authorities" i - (NYS REPP, Part II, Secticn 1, B. page IP - 56). ,
l "Should decision nakers find an evacuation route inpassable, police ard transportaticn authorities will provide an alternate route with amended time estimates. Further note should be taken that the
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clearance of inpassable roads due to severe winter storns will be done prior to en evacuation protective action order and thusly, wxild not affect the adverse condition tables."
We find the State respcnse to be adequate. ,
1 With respect to the issue of alerting the public, the county plans !
state that at the Site Area C1'assification uvel, in coordination with the Public Infcrmation Officer of the NED, New York State, Putnam, Rockland,
- Orange and Westchester Counties, the Chief Executive of each county shall order the activation of the public notification system and the Emergncy Boardcast System to issue advisories to the news media to notify the general public of the situation and of any protective actions that should be taken.
Since the plans clearly state that the public will be notified no later than at the Site Area Classification I4 vel, regardless of the weather condition, there is no need for the plan ncdification.
Q.2 ASIB's Findings:
Plans for protection of school children were rot finalized.
Ctanission's Ocaments:
i l 'Ihe Ocmnission directed the NRC staff to confer with FDR and i report on the status of conpliance with this zwquirement.
A.2 FDR's Respcnse:
I According to the State (letter dated April 3, 1985), school districts are participating in energency preparedness programs. 'Ihese pro-grams involve superintendent briefings, principal / teacher training, procedure review and public education material developnent. Some schools have used their Radiological Dnergency Preparedness Plans as a guide for !
other emergency response.
'Ihe current status of the four county plans is as follows:
i
- School evacuation is retained in the four county plans as one of the protective actions to be used When schools are in session and an evacuation of the general population is reatm-
! mended by the Chief Executive of the county or State. Bus canpanies providing service to individual school districts will maintain their normal respcmsibilities to the school l
district until all school children have been moved to their j predesignated school reception centers.
School administrators and staff of the schools to be evacuated will assist children in boarding buses and acotmpany them to the school recepticn centers Where children will be reunited with their families. School reception center adninistrators will maintain records of children's names, names of persons l
picking them tp, and destinations upon leaving the reception l i _
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center. % e reception centers that schools &ildren will '
be evacuated to are listed cri the back of maps includal in the county-specific public education brochures. In addition, per FDR's agreenent with the State of New York, these recep-tion centers will be specified in EBS messages as a means of parental notificaticri in the event that school evacuation is inplemented due to a radiological energency at Indian Point.
he school reception centers will renain in operation until all children have been reunited with their families.
Early dismissal is the preferred precautionary action to be racw.wded by the 011ef Executive of the county or State at the Alert a wrgency classification level (i.e., in the early stages of an incident before a release occurs). his course of action will result in school children beirg at hone with their families, or persons designated by their families, prior to any general evacuaticr1 order. Early disnissal plans have evolved through years of emergency experience and the accept-anoe of responsibilities by school officials. %ese plans have been developed by school officials to address varying conditions, sucts as the breaking of a boiler, fire, blizzards or floods. We objective of the plans is to return children to their hones, or to the hone of soneone predesignated by the parent in the safest, most expeditious nenner. he adaptation of early dismissal in the radiological energency preparedness plans for Indian Point is based upon the tested sucess of early dismissal by New York schools that have been exposed to einargercies that require the inplementatics of such plans.
Werefore, it is the State's position (letter dated April 3, 1985) that there is no reason to review or evaluate the specific plans for early dismissal of schools that have been developed by local school officials with parental input.
FDR's investigation of this matter has revealal the counties have been working with school districts within the 10-mile EPZ of Indian Point to develop radiological emergency plans for schools. For exanple, Westchester County has completed the developnent of school radiological energency preparedness plans for its ten (10) school districts. hose plans are cri file at each school ard at the county EOC. %e school plans are not identical; but rather have been tailored to meet the particular needs of eacit school district. Also, Ibckland Q:unty officials in cooperation with the State, have cx]nducted two (2) meetings with local school officials. %e purpose of the meetings has been to develop training programs for schools that have response functions (e.g., for protective actions, reception centers, etc,) and to develop public education programs for school staff, students ard parents.
Q.3 AEEA's Findings:
In Westchester (as in Rockland) insufficient attention was given to the identification of the non-institutionalized, mobility-inpaired populace and assessment of their needs.
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! Comnissicn's Cbmants: 1 i
he Ocnnission directed the NRC staff to confer with FE% to deter- i
- mine whether or not the Ibard's recumnendation for additional measures to i
- inform handicapped persons need to be undertaken, and report cn this issue.
A.3 FDR's Response .
In our response to the'ASla's Recamnendations to Comnission dated 4
January 30, 1984 we stated: + ,
l In each of the four (4) counties, including Westchester
! County, lists of non-institutionalized mobility-inpaired
- individuals have been ompiled. R ese lists were deve-i loped fran the return " tear-cut cards" in the emergency
- planning brochure, lists of nobility-inpaired fran county j offices of the aging, social services departments, and j leva 1 public health nurse agencies. S e State has assured l us that procedures for updating these lists exist in each 4
county.
l In addition, during the March 9, 1983 Indian Point i Exercise, FDR evaluated the evacuatics of selected
- non-institutionalized, mobility-inpaired persons for l Westchester County on a free play basis. Se exercise
!. provided us with the basis for testing the capabilities of decision-makers to identify individuals with special needs and to test the knowledge of bus and anibulance drivers to t locate those individuals and evacuate them to respect.i a 4 Reception Centers.
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4 Pursuant to FDR's response dated January 30, 1984 to the Atomic safety and Licensing Board's Recmmendation to the Mission on Indian
- Point, a program to reach the non-institutionalized mobility-inpaired
- population is an ongoing process. hrough public education 'and annual
- brochure distributions, individuals requiring special assista.we are '
i encouraged to mail back cards incorporated in the brochures. Both i Westchester and Rockland Counties demonstrated the proper means and proce-
. dures for protecting persons Whose mobility nay be inpaired during the Novetaer 28, 1984 exercise. he following evaluations were nede by the l
Federal Observer Team, and can be found in FDR's Post Exercise Assessment Report dated February 27, 1985.
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s Westchester County:
A sanple of resources necessary to evacuate non-institutionalized mobility-impaired individuals was adequately demonstrated by dispatching an ambulette to simulate the transportation of individuals located at five addresses. A vehicle was dispatched in a timely manner frcra the garage selected for this exercise. We driver was able to locate the assigned addresses quickly with the aid of good maps. It took about 2 1/4 hours altogether from dispatch to arrival at the reception center, stosping about 5-10 minutes at each of the 5 pickup addresses. We anbulance's radio worked nest of the time but did not fu.Ttion well in the northern reaches of the county. Telephcne backup was demonstrated.
Ibckland County:
he resources necessary to evacuate non-institution 11 zed mobility-inpaired individuals within the 10-mile EPZ in Rockland County were effectively demonstrated. A driver and vehicle representing one transpor-tation conpany wre mobilized and dispatched to sinulate the pick up of mobility-inpaired persons at five addresses and their transportation to a reception center. his transportation conpany currently has vehicles capable of holding 10 wheelchairs and expects this capacity to be expanded to 16 wheelchairs in the near future. Based cm the performance at this exercise, it was evident that the driver had been trained concerning his route and responsibilities, correcting a previously observed deficiency.
It was noted, hcuever, that the transportation conpany observed at this exercise is open only 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day tenday through Friday and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> on Saturday. It was suggested that the procedures for notifying this and other cxmpanies with responsibilities for transporting runinstitutionalized nobility-inpaired individuals be reviewed to ensure that these aanpanies can be notified and resources nobilized on a 24-hour basis.
On May 6,1985, the State responded to FDR's reatmnerxlation indicat-ing that a review of the procedures for provisions of transportation for the mobility inpaired has been undertaken by the Office of Dnergency Services. We procedures are being revised to provide a methodology for 24-hour notification and the provision of personnel necessary for adequate resources to address evacuation needs. Actual demonstration of this procedure will be verified by FDR during the next full-scale exercise.
Q.4 ASul's Findings:
. No letters of agreenent for Westchester County bus drivers. l l
Otanission's Otenants:
No comnents were made regarding this Planning Standard.
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A.4 FDR's Response With regard to volunteer bus drivers, the State as well as the bus expanies, do not believe that it is necessary to obtain letters of agreement from individual bus drivers.
It is also FDR's opinion that according to NUREG-0654, letters of agreement are required only with bus cxmpanies, but not individual bus l drivers. 'Ihe State maintains that the ongoing training and driver awareness of the REP plan will continue to provide a pool of drivers large enough to acu, malate activation of existing evacuation procedures.
In the May 1985 review of the revised Westchester (bunty plan, the Regional Assistance Cbmnittee found that letters of agreement were not incorporated or referenced in the plan.
On July 12,1%5, the State of New York provided FD% with letters of agreement with four (4) transportation ompanies in Westchester county.
FDR has reviewed these letters of agreement and found the following:
Vehicle Ltr. Signed Ltr. Signed Termi-Bus Qxpany Resources By Bus 03. By Westchester nation Identified Date County - Date Date Not Vanguard Tours, 450 11/21/84 Not Signed Identified Inc. _
Not Hendrick Ibdson 22 2/13/85 Not Signed Identified School District Not Qiappaqua Trans- 55 11/27/84 Not Signed Identified portation Inc.
According to the Liberty Lines Stater operat- 11/27/84 Not Signed 12/31/84 Transit Inc. ing assistance agreement with the 0:enty calla for 300 vehicles In the July 26, 1985 letter, FD% informal the State that all four (4) letters of agreement have not been properly executed, since they have not been signed by Westchester County. In addition, FDR indicated that the letter with Liberty Lines expired on Decent)er 31, 1984 and therefore, is no. longer valid.
In the response letter dated August 6, 1985, the State of New York concluded:
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b he conmitments have been signed by the transpor-tation providers. With or without the Cbunty signature on those documents, the County deems those comnitments, to participate in the REP plan, as valid. So do we. Unilateral letters are acceptable. All ccmnitments, with the exception of Liberty Lines, are open ended.
here are no expiraticn dates nor will there be, unless both parties agree to mcx11fy the doctanents.
%e " operating assistance agreement" referenced by Liberty in its letter refers to its agreement with Westchester Cbunty to operate the County's bus system. As we have previously explained to your office, Liberty Lines serves as the Cbunty -
bus conpany. Liberty operates County owned buses for the County. hus, the REP Liberty vehicle agreement is reviewed annually to coincide with its major county contract. me major contract goes well beyond radiological emergency preparedness issues, and as such is not subject to Federal review.
In the August 6,1985 letter, the State also provided FDR with the follcwing information with respect to transportaticn resources in Westchester County:
Buses required (per plan): 432 Buses under contract: 695 FDR has evaluated the State's respcnse and determined that these letters of agreement are not unilateral and, therefore, need to be signed by all parties involved. FD%'s decision is based on the fact that accord-ing to these letters, the Westchester Cbunty has certain obligations towards the bus conpanies. Specifically, these obligations ares he county shall indennify and hold harmless the .
Participant and its officers, agents, and enployees frcm all clains and liabilities for bodily injury cr property damage arising out of the use by the Cbunty of the Participant's facilities, equipment, or personnel under this Agreement; provided, hcuever, that the duty on
' the part of the (bunty to indennify and save harmless prescribed by this action shall not arise (a) Where the injury or damage resulted frcm intentional wrongdoing, recklessness or i
negligence on the part of the Participant or its officers, agents, or anployees; or (b) with respect to any claim for which the (bunty is inmine frczn liability pursuant to Secticn 25(5) of Article 2-D of the Executive Law; or (c) in the event that the involved utilities shall expressly assume such duty to indemnify and hold hannless.
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'Ihe Cbunty shall reinburse the Participant for all reasonable an1 necessary costs incurred as a result of Participant's assistance to the County pursuant to the terms of this agreement.
With respect to Liberty Lines, FDA will continue to require proof of agreement between the county and bus conpanies and the number of vehicles that wot.ld be available in case of a radiological energency.
In conclusion, FDA finds that the issue of letters of agreement remains unresolved until all necessary doctanentation establishing the existence of these contracts with bus ccanpanies is provided by the State including:
signatures of all parties involved:
- a current contract with Liberty Bus Lines that includes information as to available bus resources including type of vahicle to be provided.
Provisions related to the period of time covered by the contract, i.e., information concerning contract expiration /
termination provisions.
'Ihese concerns are again being ccanunicated to the State of New York.
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O.5 ASIA's Findings:
FDR ehould review the need for better comnunication with the
! non-english speaking population including publication of brochures and j posters in spanish, if warranted. . !
l Omanission's oczanents: i
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! '1he Ocronission indicated that the licensees criticized the last l l Board conclusion, arguing that there were few " unsupported non-English !
j speakers in the EPZ" and no single foreign language was y..adnant.
j Furthermore, the Comnission stated that if the licensees' omenant is correct, they doubt that such measures are warranted. 'Ihe Omanission 4
directed the NRC staff to confer with FDR to determine the validity of this issue.
A.5 FD R's Respanos: l l The joint FDm/tec Guidance Mornorandum (G.M.) $20 entitled, .
j Foreign language Translation of Public Education Brochures and Safety [
t Messages, providen guidance on this issue. It takes the Voting Ri@sta Act '
i of 1965 with Amerslments of 1975 and 1982 (Public law 94-73) as a point of -
l i
departure. Under this let the Director of the Bureau of the Omnsus is required to identify those States and political subdivisions dare more ;
than 5% of the citizens of voting age are menbers of a single language ;
minority. Political subdivisions are defined by the Act as casunties and F independent cities, except for certain cases such as louisianna Where parishes are the " equivalent *subdivisim. et $20 states:
Licensees, states, and local gewerrunents should provide public education and information (bro- 6
, chures and safety messsages) translated into a foreign minority language, if the ramtzer of the :
foreign minority populatim of vot.ing age ====rk t I 5% of a surrounding county's or equivalent population. '
sudi a county or equivalent is ocwored urder the Act ,
and is already under an cbligation to provide bilingual ;
3 ballots and voters services. I Furthermore, this nomoranden rectamends that l
}l f If minority language individuals in the Plane Exposure f
1 Pathay EPz do not exceed 5% of the population and there -
l are no foreigt language materials provided, other efforts should be made to afford then protection similar to that provided to the general population. ;
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' During the 120-day clodt, a survey was conducted by the New York i State PIO work group to determine Whether there were any paracns living l in the Indian Point lO-mile emergency planning mone dio did not .
speak / read English and, if so, dist their primary languages are. '!his l survey identified several relatively anall non-Englid. _id_ing commani- i ties; hcasever, these coremanities did not amount to the 5% of the total l
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population. Based on this survey, New York State reccmnended neeting with the non-English speaking crimunities, social and religious leaders as a nore effective way of reaching the non-English speakers.
On Novenber 18, 1982 FDR reviewed the rewi. 54ations for aldressing information needs of non-English speaking persons residing in the Indian Point 10-mile EPZ and found it to be acceptable. FDR agreed that it would be inpractical to develop brochures in languages other than English considering the limited ntsnber of non-English speaking residents.
According to the State's letter of July 1,1985, there is still no evidence of the need for additional provisions for the non-English speak-ing population at this time. A Hassidic ocum2nity in Rockland County has been provided with an alert / notification systen Whereby cormunity leaders can provide notification and instructions in Yiddish. Reports of Hispanic population have been investigated and the amall population was found to be mostly bilingual.
1 FDR fouM that efforts undertaken by the State and county are ade-quate and a further study does not appear arranted.
i Q.6 ASIE's Findings:
Record inconclusive with respect to protective respcmse planning in the ingestion pathway EPZ.
Ocnnission's otanents
'Ihe Ccnnission directed the NRC staff to confer with FD% and report on the status of canpliance with this Planning Standard.
A.6 FDR's Response:
FDR in its response of January 30, 1964 to the ASIB's Reccanen-dation to the ccmnissfon already stated that during the 120-day clock (Aug. 2 - December 2,1982), tne issue of surface wter inventory and dairy farms was investigated. New York State demmstrated to the RAC that surface water inventories and maps identifying the location of produce farms as well as dairy farns frcan 10 to 50 miles around Indian Point were conpiled and are available. Based on our review of these maps, we found they are acceptable and are in full ocmpliance with planning element J.11.
As of this date, the New York State plan remains in conpliance with this planning stardard.
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- 11. RADIOILGICAL EXPOSURE CCNTROL - NUREXMMS4 - PIANNING STANIRRD K 10 C.F.R. 50.47 (b) (11)
ASIR's Findings:
No significant deficiencies, but record inconclusive as to the adequacy of provisions for disposal of contaminated waste water.
Canaission's Cbrunents:
No comnents were made regarding this Planning Standard. However, the Omnission directed the NRC staff to confer with FDR and provide then with rem.-.dations.
FD R's Response Since the closing of the Atomic Safety and Licensing Board record, the (4) four counties have incorporated procedures into the plans for disposal of liquid aste generated by decontamination of personnel and equipnent. 'Ihese procedures are in accordance with guidance supplied by the EPA Region II RAC mernber for disposal of such emergency generated waste. However, in the latest FD %/BAC review, dated May 1985, the perti-ne:nt criteria element, K.S.b, has been rated inadequate. 'Ihis rating ws made because of a recent awareness of the New York State Diviraranental Cbnservation I4w Which rray require an environmental inpact statement and/or the obtaining of a permit to allow for the inplementation of the proce-dures. FDR has requested from New York State an interpretation as to the applicability of this law.
On July 23, 1985, the State infomed FDR that Article 2-B of the Executive law contains a provision Which serves to resolve this issue.
Specifically Section 29-A provides that "the Governor may by executive order tenporarily suspend specific provisions of any status, local law, ordinance, or orders, rules or regulations x parts thereof, of any agency during a State disasters emergency, if atmpliance with such provisions
- would prevent, hinder, or delay action necessary to cope with the disaster.
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FDR has evaluated the Stata's response and found it acceptable for those situations in dtich the Governor declares a state Maanter emer-gency. Itwever, further classification is needed for those situations in which the county is in conmand and control (no state declaration).
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- 12. MEDICAL AND PUBLIC HEAUIH SUPPORT - NUREG4654 - PIANNING STANDMtD L 10 C.F.R. 50.47(b)(12) side's Findings:
No significant deficiencies.
I Comnission's Comments:
No ocmnents were made regarding this Planning Standard.
FDR's Responses No Federal Action is required.
- 13. REXINERY AND __REEN11tf PIMING AND POErrWNWP OPERATIOi - NUREG-0654 P1ANNING STANEARD M 10 C.F.R. 50.47(b)(13)
ASIB's Findings:
No significant deficiencies.
- Otanissim's Otanents:
No connents were nude regarding this Planning Standard.
FDR's Response:
No Federal Acticn is required.
- 14. EXERCISES AND DRI1ZE - NUREG-0654 - PIMING STANDARD N 10 C.F.R. 50.47(b)l4 ASIA's Findings:
No significant deficiencies.
Ozanissim's otsunents l No ocmnents were snade regarding this Planning Standard.
FDR's Response No Federal action is required. ',
Ctanissim's Consnent:
No atunents were made regarding this Planning Standard.
0,,
b FD R's Response No Federal action is required.
- 15. RADIOIDGICAL DERGENCY RESPNSE TRAINIlO - NUREEME54 i PIANNING STANDARD 0 10 C.F.R. 50.47(b)(15) i ASIB's Findings:
Training of emergency workers was deficient-record inconclusive as to the extent of this deficiency. Training manual was deficient.
Ctanission's Carrenants: -
No amments were trade regarding this Planning Standard. However, the Cbtmissicn directed the NRC staff to confer with FDR and report cn the status of this training.
FD R's Hesponse:
FDR in its respcnse to the ASIB's Reccumwndation to the Ommis-sion of January 30, 1984 determined that the training of enertjency wrkers havingfrole in the plan was adequate. Since that time, the State provided FDR with the detailed starmary of training conducted in 1984 of all a@ropriate categories of emergency worker FDR is still awaiting the details of training in 1985 (see also FD%,s. s comnents cn the status of Dnergency Planning in Rockland County).
During the November 28, 1984 exercise riost participants were well trained and danonstrated the capability and knowledge necessary to deal with a radiological smergency.
- 16. RESPNSIBILITY POR*HE PIANNING EFTORT: DEVEIDFMENT PERIODIC RE'/IEW AND DISTRIBLIIIN OF DERGENCY PIANS - NUREG-0654 - PIANNING STANDARD P 10 C.F.R. 50.47(b)(16)
ASIR's Findings:
tb significant deficiencies.
Ozmission's Otressants:
No crziments were trade regarding this Planning Standard.
- FDR's Responses No Federal Acticn is required.
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III. Corrmission Question: Inprovernents in Br@cf Planning
'Ihe conmissim posal the folicwing question:
Wat inprovements in the level of energency planning can be expected in the near future, ,
and on what time schedule, and are there other specific offsite emergency procedures that are feasible and should be taken to protect the public?
'Ihis questicn deals with several issues t&tidt for clarity reasons, have been addressed under appropriate NUREG-0654, Planning Standard in Section II above. Specifically, those issues were:
whether the emergency plans needed modification to provide for -
alerting the public at the Site Area Dnergency Invel instead of the custanary General Emergency Imvel, then adverse weather conditions were likely to degrade the evacuation routes.
(addressed under Planning Standard J, Q.1).
whether additional assistance should be providal for comunicating with handicapped in a densely populated areas (addressed under Planning StaMard J, 0 3).
whether there is the need for better ammunication with the non-English speaking population (addressed under Planning Stardard J, Q.5) .
'Ihis concludes FDR's response to Mr. Jordan's June 17, 1985 letter to Mr. Krima.
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