ML20203N093
| ML20203N093 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/17/1986 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 2.206, CLI-85-06, CLI-85-6, NUDOCS 8609230138 | |
| Download: ML20203N093 (25) | |
Text
.
j* Federal Emergency Managernent Agency e Washington, D.C 20472 9
0 0 SEP l 71986 MEMORANDUM EOR: Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response Offic of Insi tion and Enforcement N ry Cm mission l
FROM: R Kri in istant Asso:iate rector Office of Natural and Technological Hazards Programs
SUBJECT:
NYPIl0 2.206 Petition on Indian Point This is in response to your memorandum of December 6, 1985, requesting a finding and determination about whether, at the present time, the offsite radiological emergency response plans for Indian Point are adequate to protect the health and safety of school children in the event of a radiologi-cal emergency at the site. You ask specifically about the significance of any remaining deficiencies with respect to the ability to take adequate measures to protect school children. The information is needed to assist you in formulating the final Director's Decision on the 2.206 petition (CLI-85-06) filed by the New York Public Interest Group (NYPIDG) on these issues.
l Attached is the finding prepared by Region II of the Federal Emergency i Management Agency (FEMA). It is based upon material submitted by the State of New York through August 12, 1986. Additional material continues to
, be submitted, including, for example, a list of proposed changes to the Rockland County plan, four Letters of Agreement with Westchester County transportation providers, etc. Also, a remedial exercise is to be l scheduled later in 1986 which may affect same issues concerned.with the
- protection of school children. In order to reflect any changes or enhance-I ments incorporated in additional sutmittals and to report on the results of the remedial exercise, we propose to submit a supplemental finding on this issue on February 1,1987.
Taking into consideration plan subnittals and exercises which occurred prior to August 12, 1986, FEMA is unable to provide reasonable assurance that the public health and safety of school children in the four-County l Emergency Planning Zone at Indian Point can be protected.
Attachment As Stated 8609230138 860917 PDR
(
F ADOCK 05000003 l PDR 1 4 ", y
INTERIM FINDING - INDIAN POIffr (September 17, 1986)
This is in response to the December 6,1985 memorandtsn from the Nuclear Regulatory Connission (NRC), requesting a specific finding and determination about whether, at the present time, the offsite radiological emergency response plans for Indian Point are adequate to protect the health and safety of school children in the event of a radiological emergency at the site. You ask specifically about the significance of any remaining deficiencies with
- - respect to the ability to take adequate measures to protect school children.
On April 28, 1986, a draf t of the Federal Dnergency Management Agency's
- (FEMA) finding and determination on the adequacy of offsite radiological
- emergency plans to protect the health and safety of school children was provided to New York State. This draf t was provided so that the State would have the opportunity to respond to any issues which FEMA found to be unresolved.
On May 9, 1986, a meeting was held at the offices of FEMA Region II to discuss the status of the issues in the four counties that comprise the 10-mile pltane EPZ for the Indian Point site. Attending the meeting were representatives from the Federal Emergency Management Agency Region II, NRC Region I, New York State, Westchester, Putnam, Rockland and Orange Counties, the New York Pcuer Authority and Consolidated Edison. As a result of this meeting, New York State agreed to resolve certain issues and to provide FEMA with information on the latest status of resolving the remaining concerns. On July 7,1986 New York Stato submitted the following information to FEMA:
- Suspense dates for training of bus drivers;
- Proposed revisions to the Rockland, Westchester and Putnam County plans; and
- Modified letters of agreement with bus providers.
This finding and determination incorporates the results of FEMA's May 9, 1986 meeting with the State, counties and utilities, the State's written response of July 7,1986 regarding the April 28, 1986 draft of this report. A meeting was held on August 13, 1986 with the State of New York, Westchester and Rockland counties. Correspondence submitted as corrective action by the Governor's authorized representative to FEMA after the August 13 meeting has not been reviewed for adequacy and is not reflected in the body of this report.
i
4
. o A. Rockland County Special Issue Rockland County The State has in the past and again recently, said that there is no need j for letters of agreement in _ Rockland County between the county and school
! officials since the county executive has the right to use school facilities in an emergency. This position was stated in a letter dated July 1, 1985 to FEMA which stated in part:
"Rockland County school districts have premised their plans on Article 2-B of the Executive law and the ability of the Chief Executive to use the facilities during an emergency.
Their plan, therefore, is based upon the Chief Executive's order to open these schools as reception centers."
In a February 20, 1986, letter to FEMA, New York State again said that no letters of agreement are necessary, however, in this case various sections of the Rockland County Charter are cited as the basis of this position.
The resolution of the issue is not easily accomplished because of two other New York State letters to FEMA. In a response to FEMA's June 11, 1984 letter regarding the NYPIRG Petition of April 6,1984, the State responded to the question:
Q. "To what extent are school districts required by New York State Executive Law 2-B to participate in radiological i
emergency planning and preparedness exercises and drills, and actual emergency response activities?"
A. " Executive Law Article 2-B does not require school districts, or any other units of local government, to i participate in radiological emergency matters."
In a New York State letter to FEMA dated February 12, 1986, the State said in part:
f "We have and will continue to include local school officials in our planning process but as previously stated there is no i guarantee that the school officials have to abide by a FEMA Guidance Memorandum".
l Further, the same letter states, "Although the guidance addresses the local government responsibility for coordinating with school officials, there is no assurance that school officials will adopt recommended emergency procedures."
I l
l
-_._--_ __ -- _ _ _ _ .,~-_ _ _-. _ _ _ . . - _ _ . _
The above quotes from various State letters to FEMA point to clear incon-sistencies. The four county plans vary greatly with respect to how this issue is approached. Some counties have signed letters of agreement which appear to give the local authorities the ability to make use of school property as is necessary.
As a result of FEMA Region II's May 9,1986 meeting with the State, counties and utilities, FEMA's Regional Counsel reviewed Rockland County Executive Laws No. 14 (1984) and No. 7 (1985). He then discussed the need for letters of agreement as they relate to various school facilities in Rockland County with C. Roger Lunder, Esq. , counsel to the Division of Military & Naval Affairs for the State of New York and John Lamberski, Esq. of the New York Power Authority. EEMA's Regional Counsel communicated his concerns to the State in a letter dated July 23,1986 (copy attached) . The State has requested a legal opinion from the State Attorney General on the adequacy of the Rockland County statute.
It has been and continues to be FEMA's position that letters of agreement are required to assure the availability of necessary resources such as reception centers and transportation equipment.
B. Protective Actions Rockland County The school population will be protected by either early dismissal or evacuation.
The Rockland County Plan (page IV-39) states that there are two potential actions to be taken with regard to the school populations:
Close schools and have students at home with families prior to an evacuation order; If the "Go Home Policy" is not the safest course of action for affected schools, children will be evacuated to predesignated School Reception Centers.
It should be noted that the Plan (Procedure SCH-1, Section 5 3 2) states that at an Alert Emergency Classification Level (ECL) or " Greater Emergency" the Assistant Superintendent of Business and Finance of BOCES will direct the Administrators of schools within Rockland County to take one of several steps which are means of implementing the "Go Home Policy." In Section 5 2.6, the provision is made for school evacuations to be directed. It would seem reasonable to limit the "Go Home Policy" to the Alert ECL. Any use of this option at higher ECLs has greater potential for not having completed the "Go Home Policy" prior to an evacuation order.
i
The State responded on July 7,1986 to this planning issue stating that the "Go Home Policy" has been clarified by deleting "or greater emergency" and replacing it with " Site Area or General Emergency." FEMA has determined that this answer is not responsive to the Agency's earlier concern because the 4
change in wording is not a substantive change in the plan. The proposed change means that Rockland County still intends to use the "Go Home Policy"
, at the higher ECLs where there is. greater potential that school children may not have been returned to their homes before the implementation of an evacuation protective action recommendation. However, on August 14, 1986, the State
- submitted additional proposed plan changes to correct the tabeittal of July 7, 1986, proposed changes, i.e. , to clarify the "Go Home" procedure on page SCH-1, 3 '
by deleting all words af ter " Alert." FEMA finds these proposed plan changes to be acceptable. FEMA will await the formal submission of these plan changes in 1987 in order to verify that the corrections have been made.
1 In the November 28, 1984 full-scale exercise, an area requiring corrective action was identified which involves the unsuccessful training of school l officials in response options (see Post Exercise Assessment (PEA), February 27, 1985, page 63) . Additional training must be provided to assure that all school officials understand the various response options and are aware of their responsibility in the event of an emergency. During the June 4, 1986 j full-scale exercise, it was determined that plans and procedures have not been developed for at least two nonpublic schools. Although the county provided evidence of written offers to assist schools in the review of i emergency preparedness plans which were sent to schools in a letter dated October 7,1985, the school officials interviewed could not recall having
- been offered this assistance. This issue has been classified as a deficiency
+
and FEMA has recommended that State and County officials should followup with the nonpublic schools in Rockland County to insure that plans and the j necessary resources to protect nonpublic school students are in place.
Also, according to school principals, information has not been provided i to parents of students at two (2) non-public schools for three (3) years.
. According to these school principals, the last information provided to either school was in a 1983 letter with instructions to parents and an emergency information brochure, (PEA dated September,1986, page 82) .
j The State responded to these unresolved exercise issues stating that school 1 officials will be provided training in September 1986. FEMA intends to attend a sample of these training sessions for school officials to verify
- the adequacy of the training.
i Westchester County 1
l The Westchester County plan considers two (2) conditions for whether schools
{ are open or closed and specifies four (4) protective action recommendation (PAR)
- options for the Alert, Site Area Emergency and General Emergency ECLs.
These are as follows:
' Early Dismissal including keeping schools closed. (Alert ECL) i i
h
' Shelter in place.
' Move students to school reception centers.
' Keep students in school, until normal dismissal time.
At the Site Area Emergency and General Emergency ECLs the plan also provides for selected evacuation of students under 12 years of age, pregnant women and others with a low tolerance to radiation.
There are statements in the plan that require the decision makers to consider the specific circumstances of a given emergency before selecting the PAR that is to be implemented for schools.
The plan states (Section C of Attachment 3 to Appendix A) that if the supply of buses is limited, the buses will be used to evacuate school children before the evacuation of the general public.
In addition, Westchester County has informally provided FEMA with copies of the school plans that are in place for use in the event of a radiological emergency at Indian Point. FEMA has not reviewed these school plans since they are subordinate to the County plan which describes in detail the manner in which protective action recommendations will be developed and implemented for schools in Westchester County.
However, during the June 4,1986 full-scale exercise, it was observed that the second-shift school coordinator at the Westchester County EOC was not trained and used a long-obsolete 1981 version of the school procedure portion of the County plan (Procedure 4). FEMA has recommended that sufficient numbers of backup school coordinators should be trained and supplied with current plans.
Putnam County The Putnam County Plan states that school facilities, including nursery schools and day care centers, are considered special facilities for evacuation planning purposes (Attachment 5 to Appendix A) as required by NUREG-0654.
r Protective Action Recommendations for the school population would be selected from the following options which are specified in the School Procedure.
At the Alert ECL, Keep schools closed if not in session Shelter in place
At the Site Area ECL, Any of the above Selective evacuation of students under 12 years of age, pregnant women, and others with a low tolerance to radiation At the General Emergency ECL Any of the above Move students to a school reception center At the May 9,1986 meeting FEMA pointed out that (1) the early dismissal option was not included in the Putnam County plan and (2) the option to evacuate students to a school reception center was not included as an option at either the Alert or Site Area Emergency ECLs. The State responded that the Putnam County plan is being revised to include these considerations.
When these modifications are complete, the Putnam County plan will include the following PAR options for schools at the Alert, Site Area Emergency and General Emergency ECLs.
' Keep schools closed if not in session
' Early dismissal (Alert ECL)
' Shelter in place
' Move students to a school reception center Several issues related to radiological emergency preparedness for schools in Putnam County were identified during the June 4,1986 full-scale exercise.
These issues fall into two groups as follows:
' The availability and awareness of emergency planning information for schools; and,
' The allocation of bus resources to schools.
For example, areas requiring corrective action included:
- 1) No information had been provided to students of either the Noah's Ark Nursery School or the Putnam Valley Junior High School regarding emergency response procedures related to Indian Point. FEMA recommended that students in public, nonpublic, and nursery schools should be made aware of the procedures to be followed in the event of a radiological emergency at Indian Point (PEA, September 1986, page 126).
- 2) The principal of.the Putnam Valley Junior High School indicated that eight (8) buses would be required for evacuation. Based on Table 1, Attachment 1 to Procedure 5, Schools, of the Putnam County plan, only seven (7) buses have been allocated to the Putnam Valley Junior High School. FEMA recommended that the allocation of bus resources to schools in Putnam County should be reviewed to ensure that the supply of buses is adequate to meet the demand in the event of a full evacuation (PEA, September 1986, page 126).
Orange County The Orange County Plan states that school facilities, including nursery schools and day care centers, are considered special facilities for evacuation planning purposes ( Attachment 5 to Appendix A). The possible Protective Actions for the school population would be selected from the following options which are specified in the School Procedure:
At the Alert ECL, Keep schools closed if not in session Shelter in place Early Dismissal At the Site Area ECL, Keep schools closed if not in session Shelter in place At the General Emergency ECL, Keep school closed if not in session Shelter in place Move students to school reception centers The early dismissal option was listed in the implementing procedure under both the Site Area and General Emergency response actions. Since this option is specified only for the Alert ECL, it was suggested that this option be deleted from these two higher ECL's to avoid possible confusion.
The State responded stating that early dismissal is being deleted for Site Area and General Emergency ECLs. This proposed change is acceptable.
Based on the results of the June 4, 1986 full-scale exercise, a deficiency was identified that included that the administrators at some schools were not aware of radiological emergency response procedures (PEA, September 1986, page 103).
l.'
4
- FEMA recommended that training in radiological emergency response procedures j should be provided to school officials (PEA, September 1986, page 103).
( C. Reception Centers j
Rockland County The current Rockland County Plan lists four (4) facilities as school recep-l I tion centers (Procedure DPT-2. Attachment 4). They are the following:
' Don Bosco H.S., Ramsey, N.J.
' Ramapo' Community College, Mahwah, N.J.
j ' ' Bergen Community College, Paramus, N.J.
l
' Orange County Community College, Middletown, N.Y.
Since these facilities are not within Rockland County, and regardless of the
! resolution of Rockland County's executive law, it is reasonable to assume these four facilities which are located in New Jersey and Orange County, j New York would not be covered by the Rockland County executive law. There-1 fore, letters of agreement are still required with these four (4) facilities.
In the November 28, 1984 full-scale exercise, an area requiring corrective j-action was identified which found communications between the Rockland County EOC and the Bergen County EOC difficult to complete, repeating a deficiency observed at the 1983 exercise of the State Compensating Measures l Plan for Rockland County. Arrangements for Bergen County to send an "
i operations liaison to the Rockland County EOC have 'not been completed (PEA dated February 17, 1985, page 89). FEMA recommended that representatives
! of Bergen County and New Jersey meet with representatives of New York and l
Rockland County to establish the responsibilities of a Bergen County EOC liaison and ensure that this function will be staffed in the future (PEA
- . dated February 27,1985, page 89) .
f During the June 4,1986 full-scale exercise an area requiring corrective l
action included the dedicated telephone line interlinking Bergen County and Rockland County. The telephone was not operational and was reported 7
l to have been inoperable for the past six months. FEMA recommended all communication equipment should be operational and tested in accordance with plans (PEA, September 1986, page 187).
i
- One result of the communications problem between Rockland and Bergen Counties i is that the opening of the reception centers located in New Jersey is difficult to coordinate with the implementation of protective action recom-mendations that would involve the relocation of populations (e.g. school
- - children) from Rockland County, New York. This difficulty was observed at both the 1984 and 1986 full-scale exercises.
The State responded to these unresolved plan and exercise issues in their July 7,1986 letter by stating that:
' Letters of agreement with school reception centers is still an open issue; and, A dedicated telephone system between Bergen County and Rockland County is in service.
FEMA finds the issue of letters of agreement with school reception centers to be unresolved until all necessary letters of agreement are obtained. The dedicated telephone system between Bergen County and Rockland County will have to be verified during the next FEMA observed exercise.
Westchester County i
The current plan in Table 1 of Attachment 1 to Procedure 4 identifies that there has been a recognition of the planning needs of the school populations.
This Table lists the schools within the 10-mile EPZ, the planning area number, the enrollment, the school reception center, the associated general population reception center, the number of evacuation vehicles needed, and the source of the evacuation vehicles. A summation of the individual facility data shows:
' 54 schools with 23,264 enrollment
' 45 nursery schools and day care centers with 1824 enrollment
' 430 evacuation buses 4 ' 80 evacuation vans
' 29 school reception centers However, an inconsistency was found in Procedure 4, Attachment 1 and Appendix A, Attachment 5, with regard to the operation of the school reception centers. Attachment 1 to Procedure 4 (Section B.1.g) states that the children not collected by parents or others within a reasonable time will be bused to the associated general public reception center. Attachment 5 to Appendix A states that the school reception centers will remain in operation until all children have been reunited with their families.
These sections should be reviewed and amended accordingly. Attached to the July 7,1986 letter from New York State were proposed plan changes which correct this inconsistency.
In addition, the issue of the assured availability of the facilities listed as school reception centers is not completely resolved. Many of the school reception centers are also listed as general public reception centers. As discussed in the January 31, 1986 FEMA Status Update for Indian Point, not all of the facilities are covered by acceptable letters of agreement.
The State responded in their July 7, 1986 letter that:
The operation of school reception centers have been reviewed and revisions have been made; and, By transmittal letter dated June 25, 1986 FEMA had received all of the school reception center agreements located in Westchester County. However, five school reception centers which are located in Dutchess County are still pending.
Work is ongoing to obtain these letters.
The following list has been compiled from the current plan and data submitted from New York state:
School Reception Center Letters of Agreement (X) Yes
(-) No White Plains I.S., White Plains, N.Y. X German School of White Plains, N.Y. X Mamaroneck Ave. School, White Plains, N.Y. X Ridge Street School, Port Chester, N.Y. X Fishkill Plains E.S., Fishkill Plains, N.Y. -
Gayhead E.S. , Hopewell Junction, N.Y. -
Myers Corner Rd. Wappinger Falls, N.Y. -
Beacon H.S., Beacon, N.Y. -
Brinkerhoff E.S., Fishkill, N.Y. -
Ridgeway School, White Plains, N.Y. X John Jay S.H.S., Cross River, N.Y. X No. Salem H.S./M.S., No. Salem, N.Y. X Solomon Schecter, White Plains, N.Y. X Ardsley H.S., Ardsley, N.Y. X Park Ave. , Port Chester, N.Y. X Fox Lane M.S., Bedford, N.Y. X St. Patrick's, Bedford, N.Y. X John Jay J.H.S. , Cross River, N.Y. X Horace Greeley H.S., Chappaqua, N.Y. X Blind Brook H.S., Port Chester, N.Y. X j King Street School, Port Chester, N.Y. X Dobbs Ferry M.S., Dobbs Ferry, N.Y. X Pequanakonck Elementary School X Harrison High School X Port Chester Middle School X FEMA found most letters of agreement to be in place and will await the formal submission of revised plans to verify that corrections for inconsistencies within the procedures have been made, i
f
, n-., - , , . - - - - , - - - , , . - -
. , . , - . , - - , , . . - - - - - - , . . + - , , . - - - --
Putnam County The current plan in Table 1 of Attachment 1 to the School Procedure shows that there has been a recognition of the planning needs of the school populations.
This Table lists the schools within the 10-mile EPZ, the planning area number, the enrollment, the school reception center, the associated general population reception center, the number of evacuation vehicles needed, and the. source of the evacuation vehicles. A summation of the individual facility data shows:
' 6 schools 'with 2526 enrollment
' 5 nursery schools and 90 enrollment (no enrollment shown for two schools)
' 45 evacuation buses
' 3 school reception centers
- South Avenue School, Beacon, N.Y.
- Sargent School, Beacon, N.Y.
- Rombout School, Beacon, N.Y.
However, in reviewing the current plan, FEMA found an inconsistency in Table 1 of the School Procedure and Table 2 of the Transportation Procedure. According to the data in the Transportation Procedure, four of the five nursery schools listed do not need transportation assistance. However, in the school procedure the table indicates each of the five nursery schools required 1 bus. This information should be reviewed and amended accordingly.
The issue of the assured availability of facilities listed as school reception centers is not completely resolved. At this time FEMA does not have a copy of a letter of agreement between the county and the school district operating the 3 schools in the town of Beacon which are listed as school reception l centers. The State responded in their July 7,1986 letter by stating that:
i
[ ' School reception centers for Putnam County school children l are located in Dutchess County (Beacon School District). As l of this time, the school board has not convened to discuss j this issue and grant approval. The Dutchess County Emergency Management Director is diligently working to ensure that these Letters of Agreement are obtained. The Director has indicated that the Letters of Agreement should be available by August 1, 1986.
More recently, it was indicated that the letters of agreement will not be available until October 1,1986. Both iteos remain unresolved until the plan has been corrected for inconsistencies and letters of agreement with school reception centers are obtained.
I l
,. . l Oranne County The current plan in Table 1 of Procedure 4 shows that there has been a recognition of the planning needs of the school populations. This Table lists the schools within the 10-mile EPZ, the planning area number, the enrollment, the school reception center, the associated general population reception center, the number of evacuation vehicles needed, and the source of the evacuation vehicles. A summation of the individual facility data shows:
' 4 schools with the enrollment of 1442 1 nursery school with enrollment of 15
' 28 evacuation buses 1 evacuation van
^
1 school reception center
- South J.H.S.
There is an existing letter of agreement with the Newburgh City school district for use of their facilities in the event of an emergency which assures the availability of the school reception centers.
D. Transportation Resources Rockland County Appendix 4 of NUREG-0654 (Section II and II.c) states that the school popu-lation shall be evaluated in the special facilis,y segment when estimating the number of people to be evacuated and the means of transportation chall be described. In the current version of the Hockland County Plan, a tabulation of the population could not be located. A previous version of the plan listed the school population at approximately 22,000. The current version of the plan lists (Procedure DPT-2, Attachment 1) 218 buses as being available
! from primary sources and an additional 346 buses as being available from secondary sources. In tha event that the "Go Home Policy" has not been implemented or the decision is maie that this option is not the safest course of action, the school evacuation option must be implemented.
Assuming that the school evacuation option may be required, the process or priority whereby the available bus resources would be assigned between the
. school and general public evacuation needs could not be located in the plan.
In gathering information for a response to the NYPIRG petition in May 1985,
- the State indicated to FEMA that 246 buses would be required for the evacuation i
of Rockland County. In addition, the State indicated that there were 333 buses available 333 buses under contract, and that there were 161 trained drivers.
l
. i However, data taken from Procedure DPT-2, Attachment 3 of the current plan indicates that there are 7558 people requiring bus transportation and that 242 buses are required which is in agreement with the State figure shown above. These figures indicate that the average capacity per bus is 31 people jlC this figure is used to estimate the bus resources needed for the school evacuation, approximately 710 buses would be required if we are to consider a one-wave evacuation plan for school children.
The current plan also states that if the "Go Home Policy" is not the poten-tially safest course of action, based on instructions from the Emergency Coordinator, the school emergency coordinator will direct the affected schools to evacuate to a School Reception Center. Therefore, we must assume Rockland's evacuation plan exceeds a one-wave evacuation.
Information supplied by the State in May 1985 stated that there were 333 buses under contract while the current plan lists 564 buses. Even this larger value may not be sufficient, depending on the average capacity of the buses. Letters of agreement are required with the bus providers to assure the availability of the needed resources. The following information was compiled from the current plan dated May 1,1986 and data submitted to FEMA from New York State on July 7,1986.
Transportation Companies Vehicles Vehicles JJLL ,
Required per Available (X) Yes Plan Per LOA (-) No
~
Act II Transportation Inc. ? 53b, 32v Sc X_. Unsigned Laidlaw Transit Inc. 56 48b, 42v K_ by County (formerly Harran)
Clarkstown Central Sch. (primary) 39 Not Identified _
Haverstraw (primary) 73 65b, 65v X_ Unsigned Peter Brega (primary) 50 51b, 4v x_ l by County Rockland and City T.R.I.P.S.
(primary) ? Not Identified -
Red and Tan 160 -
Short Line 90 -
E. Ramapo Central School District 22 -
Ramapo Valley Rapid Transit 40 -
Nanuet Union Free Sch. 15 -
So, Orangetown Sch. 12 -
3 Educational Transport 40 -
Additional County Bus Operators 112 -
(see pages Dpt-2)
As stated in " FEMA's Analysis and Response To: Supplement II to the NYPIRG et al. Petition For Suspension of Operation of the Indian Point Units 2 and 3" dated May 9, 1985, in-depth bus transportation plans were being compiled.
They were finalized by the Transportation Study Planning Group (TSPG) in September 1985.
In a project status report of the Transportation Plan for Rockland County dated September 17,1984 six (6) tasks were addressed. They include:
' Demand Assessment
' Resource Analysis Roadway Network Characteristics
- Service Design
' Transportation Resource Procurement
- Training Program The conclusions and recommendations of the Transportation Study have been included in the current plan. However, the plan should be reviewed and amended to clarify the current data by identifying separately the general population transportation resources and the special facility population (including school children) totals and resources. This information is needed to assure that sufficient transportation resources exist to adequately protect the school children in Rockland County.
Also the information supplied by the State in May 1985 indicated that there were then 161 trained bus drivers available in Rockland County. No new data has been provided to FEMA to indicate that additional drivers have been trained. In the November 28, 1984 and the June 4,1986 full-scale exercises several issues were cited which indicate that the training of the bus drivers has not been completely successful. One issue concerned inadequate training of the school evacuation bus drivers in that they did not know the specific location of the school reception center (PEA, February 27, 1985, page 67) .
In the June 4,1986 exercise, the bus dispatcher for Haverstraw Transit Company stated that only 6 of the 95 bus drivers expected had received training in using dosimetry (PEA, September 1986, page 83).
FEMA recommended that maps should be developed showing the location (s) of school reception centers to which schools are assigned. These maps should be maintained at the bus garages for distribution to drivers in the event a school evacuation becomes necessary (PEA, February 27, 1985, page 67) .
During the June 4,1986 full-scale exercise it was noted that there were no maps available at the Haverstraw Transit Company to direct drivers from their assigned schools to the Reception Center (PEA, September 1986, page 82).
i
< New York State responded to the issue of bus providers by stating:
Letters of Agreement with bus providers have been obtained and indicate the number of buses which would be made available.
Note that Clarkstown School District is a bus provider but it is the contention of the county that no Letter of Agreement is required as Clarkstown is a municipality. Training of all bus drivers will be accomplished by September 30, 1986.
FEMA finds these issues to be unresolved until plans are amended to include the necessary transportation resource information, all letters of agreement are obtained and a bos driver / provider training schedule is submitted to FEMA for review.
Westchester County The issue of assured availability of school transportation resources is not completely resolved. The plan lists three commercial companies and three school districts as being bus suppliers. One of the school districts has been assigned to the transportation needs of their own schools. In a July 12, 1985, letter to FEMA, the State provided copies of agreements with the same companies listed as suppliers of buses for the general public evacuation needs. FEMA found that these letters were not acceptable for several reasons including not being signed by the County, not being dated, not showing ef fective dates of the agreement, not showing the equipment being provided, etc. In a January 29, 1986 letter to FEMA, the State gave assurance that Westchester County was pursuing the signing of letters of agreement with the bus companies.
Because the current letters of agreement which are available to FEMA do not always list the number of buses being committed, FEMA can not verify whether sufficient buses are available. Information supplied by the State to FEMA in May 1985 indicated that in Westchester County 432 buses would be required, 1011 buses were available, 780 buses were under contract, and that 955 trained drivers were available. Considering the number of buses listed as being needed for school evacuation (430), if the single wave evacuation option is desired, the number of buses raquired chould be reevaluated and letter' scf agreement must be obtained to assure the availability of the necessary resources. The following information was compiled from the I
current plan dated September, 1985 and data submitted to FEMA from New York
S 4
State on July 7, 1986: \; \ ,(
Vehicles Vehicles Transportation Companies JJUL Required per Available (X) Yes Plan Per LOA (-) No Laidlaw (formerly Vanguard) 175b, 67v 450b X Lakeland S.D. 62b, 4v Not Identified X eCroton-Harmon S.D. 8b, 25v - ,
Liberty 144b 200b X Chappaqua 21b Rot Identified X Hendrick Hudson S.D. 19b Not Identified -
eNo letters of agreement are required for Croton-Harmon S.D. , since they only s carry their own children.
All letters of agreement were unsigned by the County. Also, all letters '
of agreement must identify the number and types of vehicles available. -4 The State responded in their July 7,1986 letter as follows:
Proposed Letters of Agreement are enclosed for 4 of the 5 bus providers. The one remaining Letter of Agreement is with ,
Lakeland. Lakeland will sign a Letter of Agreement once contract language is completed. ;
All the Letters of Agreement are only proposals. These agree-ments have to go through a 3-step process before the County Attorney will sign them. The steps are: ,
t
- 1) Presentation of Letters of Agreement to the County Board of Acquisition and Contract (public meeting, possibly public hearings);
- 2) Signature of Approval by Commissioner of Transportation; and,
- 3) ' Signature of County Attorney.
The time involved in this process would indicate that September,1986 would be the earliest official date letters of agreement would be available .
Some training issues remain open. In the 1986 exercise, the bus dispatcher at the Laidlaw Bus Garage in Ossining did not demonstrate an adequate knowledge of her responsibilities, apparently because she was new on the job.
This could have impeded the protection of the public because it could have resulted in the improper dispatch of evacuation buses. In addition, d
s, s.
3 :
ss, '
v-
)0 %
_17
\ .
she did not demon.' strate an adequate knowledge of her responsibilities for snergency worker cratiological exposure, control. Finally, she had no knw-s ledge of KI and did not. distribute it to either of the 2 bus drivers dis-patched fron 'that garage. We training of all the Laidlaw BJs Dispatchers should be deviewed and proper training provided to all those who have not been tralnod (or whose. training is stale) on the energency worker radiological exposure control procedures contained in the County Plan and the Plan in general (PEA, Septanber 1984. pages 59-61). In aldition, one of the bus drivers from the LaidlawtBJs Garage did not read her dosimeters at the proper intervals and did not understand the proper use of the mid-range DRD. It is s
reemrnended that all Laidliiw bus drivers be trained on the use of all the dosimeters which would be distributed to then in case of a ra31ological emergency at Indian Point (PEA, September 1986, page 60) .
FEMA firvis these issuM to be unresolved until 1) all Iatters of Agreenent are obtained and the number of buses available can be verified as sufficient to transport the transit dependent population (includity school children) in Westchester County and 2) a bus driver / provider training schedule is suty-mitted to FEMA for review.
\ .,
Orance County i, , s
[9 The icsue df, the assured a/ailability of bus resources has been resolved.
A Re plan lists tw commercial bus ccrnpanies/ ao being bus providers and one s school distri'ct bus provider: *
)
,' [ehicle Vehicles IIR Transpor$ation Ccrnpanies Required per Available (X)Yes i ' Plan Per IIR (-)No West Isint Tours , 31 Any or All Available X BOSO! 7 X
!bnroe' r Woodbury School District ? " "
X ii t
!T
\ In aidition, a letter dated July 8,1986,fran Ntest Point Tours aldresses the i
fact that zsnong these bus providers who have signed Disaster Assistance
, 5 - Agree ents', there are tsice the rumber of vehicles available for a general 9\. w evacuatic>n as the number of vehicles required in the plan.
3 - New'Ycirk State responded to this in their July 7,1986 letter to FE2iA by stating:
y 1
- 1 Training of the required number of bus drivers has been
' conpleted..
t
- Intters of Agreenent for bus providers are enclosed. NJmber
'\
of buses are indicated in the agreements.
s "
' 1 s
\y ' *
- r
.s- - . . ,
/ _. - .--
FEMA finds that letters of agreement with transportation providers are in place. However, the training of bus drivers must be verified by the submittal of training syllabus and training schedules from New York State. FEMA intends to attend a sample of these training sessions.
Putnam County The issue of the assured availability of bus resources has been resolved. The plan lists one bus company and three school districts as being bus suppliers.
They are as follows:
Vehicle Vehicles LOA Transportation Companies Required per Available (X) Yes Plan Per LOA (-) No Hudson Valley Bus Co. 14b, 2v 14b, 2v X Mahopac Central School Dist. 7b 64 buses X 23 vans 3 wheelchair buses Garrison Union Free School Dist. 1b Any or All Available X Haldane Central School Dist. 15 (cars) Any or All Available X Additional Transoortation Cos.'
Putnam Valley Central School Dist. e 15 buses X 10 vans Carmel Central School Dist.
- Not Identified X <
Brewster Central School Dist. e Not Identified X
'These companies will serve Putnam County but they are supplemental resources l to those required by the plan.
t Information obtained from the State in May, 1985 and a review of the current plan dated September 1985 indicates that the total number of buses required to evacuate the student population within the Putnam County EPZ is 41. The l
plan also states in the event tht school evacuations are required, the transit l dependent general public evacuation will be accomplished in a second wave l evacuation using the same bus resources as those used for the school evacuation l (see Table 1 of Transportation Procedure).
New York State responded in their July 7,1986 letter to FEMA by stating:
' Letters of Agreement with bus providers are enclosed and do j indicate numbers of buses which would be made available.
- The correct table has been inserted which provides information l on buses required for each school in the EPZ.
l l FEMA will be awaiting the next formal submission of the Putnam plan revision
[
l
to review the proposed changes.
E. Public Information Rockland County The Rockland County Plan prescribes that if the school evacuation option is implemented, an EBS message must be aired to provide information to parents (Procedure SCH-1, Section 5 2.6) . As the plans now indicate, in the event of an Alert or greater ECL, prior to the implementation of a school evacuation PAR, school administrators will be directed to follow school closing procedures.
At the Alert or greater ECL's, the School Coordinator will ensure that any information involving the safety of the children will be forwarded to the Public Information Officer for EBS instruction (Procedure SCH-1, Section 5.2.5.) .
The Rockland County plan adequately provides for parents to be notified of school closing /early dismissal (i.e. , the "Go Home" policy) which is currently the preferred response option at the Alert or greater ECL's. However, in response to FEMA comments, the Go Home policy is to be limited to the Alert ECL, according to proposed changes submitted on August 14,1986 (See page 4 above).
Westchester County The Westchester County Plan states that parents will be notified by the local media (radio station) of the situation for response actions at the Site Area and General Emergency ECL's (Procedure 4, Sections 5.5.1 3 and 6.5 1 3). The plan should be revised to include the same notification at the Alert ECL (i.e., in Procedure 4, Section 4.5.1 3).
Putnam County The Putnam County Plan states that parents will be notified by an EBS message which is appropriate to the response action at the Site Area and General Emergency ECL's (School Procedure, Sections 5.5.1 3 and 6.5.1 3). The plan should be revised to include the same notification at the Alert ECL (i.e.,
in School Procedure, Section 4.5.1 3).
Orange County No statements could be located in the Orange County Plan with respect to how the parents of the school population would be notified as to the response action taken for the protection of this group. The plan should be revised to include, in the School Procedure, a requirement that the parents would be notified of the' response action.
New York State responded to these issues on July 7,1986 by stating:
Parental notification on the status of protective actions for
p ..
l
-2 0-children who are in schools located in the EPZ will occur at the l Alert ECL. Where appropriate, this revision has been included in county school procedures as a point of information.
Since public information is an overall coordinated response in all four counties within the 10-mile EPZ, each plan should be coordinated and amended so that they are consistent with each other.
FEMA will await these plan revisions and review them accordingly.
Public Information Brochures A review of the current public information brochures, dated 1985, addresses the coordinated response of all four counties. The information contained in each of the four brochures includes instructions for the protection of school children with the following protective action response options:
'Early dismissal
' Sheltering
' Evacuation Under the evacuation response option, the text of each of the brochures references the evacuation route maps contained in the brochure. Each map identifies the school and the associated school reception center. FEMA finds these brochures to be adequate. The 1986 brochures are to be distri-buted in late September or early October of this year. FEMA will await their arrival and revies them accordingly.
Joint News Center Procedures All four counties have agreed to a coordinated approach to public information and EBS message release. To meet this coordinated role, public information procedures have been compiled in a single Joint News Center Procedures and Public Information/ Education Workplan. The 1986 version of this Procedure contains prescripted EBS messages with appropriate areas for insertion of the description of geographic areas where response actions are to be implemented.
These prescripted messages have been prepared to assure that tim:ly information will be available for release to the public once a PAR has been finalized by the appropriate decision makers. However, there are several problems with the current messages with regard to the school populations.
The current prescripted messages do not appear to provide information which is in accord with FEMA's understanding of the concept of operations with regard to response actions for the school population. It is FEMA's understanding that the Early Dismissal (Go Home Policy) is the preferred response option for the school population if that response action can be completed prior to other public PAR's. There are no prescripted messages which give any information regarding school response actions for situations where no other
public PAR's are being implemented.
New York State responded to this issue by stating:
The need for an EBS transmission to indicate status of school children will be decided by the individual County Executive at the time a school protective action is implemented. Therefore, the appropriate EBS message will be formulated at that time.
FEMA finds the State response to be unacceptable for two reasons:
' Parental notification must be consistent with provisions specified in the county plans. In some counties, parental notification via EBS may occur at the Alert, Site Area or General Emergency.
' It would be helpful if all four counties agree on a means of notifying the public on protective actions for school children. Exercise experience has shown that even with prescripted messages, the fifteen-minute requirement is just barely met. Therefore, FEMA requires that prescripted messages be prepared for all forms of protective actions for school children.
A formal submission of proposed changes to the plan will be required by FEMA.
Summary Based on the information provided by the State of New York on July 7,1986 and FEMA's review of the current Westchester, Rockland, Orange, and Putnam County's Plans; FEMA found the following:
2pekland County Protective Actions:
' Proposed plan changes to clarify the Alert ECL as the only ECL in which the "Go Home Policy" will be implemented must be formally submitted to FEMA in the next annual submission.
' Areas requiring corrective action identified during the November 28, 1984 and a deficiency in the June 4,1986 full-scale exercises must be resolved. This would include the training of school officials in both public and non-public sectors to insure that plans and procedures are in place.
4 Communication problems identified between Rockland and Bergen County identified during both the November 28, 1984 and June 4,1986 full-scale exercises are still unresolved.
Receotion Centers:
Letters of agreement are still outstanding for the school reception centers located in New Jersey and Orange County, New Yo rk.
Transoortation Resources:
The Plan clearly identify the transportation resources totals for school children, the special facility population (including school children) to assure sufficient transporta-tion resources exist.
Adequate training of school evacuation bus drivers must be made.
Training schedules must be submitted to FEMA.
Letters of Agreement with Transportation companies have been submitted to FEMA; however, they are unsigned by the County which negates these contracts.
Westchester County Protective Actions:
An area requiring corrective action was identified during the June 4,1986 full-scale exercise with regard to the insufficient number of backup school coordinators.
Training syllabus and schedules must be forwarded to FEMA for verification.
Reception Centers:
4 All Letters of Agreement are in place for school reception centers located in Westchester County. Five letters of agreement are still pending from Dutchess County facilities which host students from Westchester and Putnam Counties.
Proposed plan changes were submitted to delete inconsistencies found in the plan in Procedure 4 and Appendix A. However, these changes must be submitted formally to FEMA in the next annual submission.
Transoortation Resources:
' The issue concerning Letters of agreement with Transportation Companies is still pending. Agreements have been submitted; however, they are unsigned by all parties which negates these contracts.
' Number of buses available must be included in the Letters of Agreement to verify there is a sufficient number to transport the transit-dependent population.
Orange County Protective Actions:
' Proposed plan changes to clarify the Alert ECL.as the only ECL in which the "Go Home Policy" will be implemented must be formally submitted to FEMA in the next annual submission to avoid inconsistency.
' A deficiency iound during the June 4,1986 full-scale exercise included that the Administrators at some schools were not aware of radiological emergency response procedures. Training in these procedures should be provided to school officials.
Reception Centers:
All Letters of Agreement with School Reception Centers are in place.
' ' Current plan procedures are adequate.
! Transoortation Resources:
l l ' Letters of Agreement are in place with transportation providers.
~ ' Current plan procedures are adequate.
' Training syllabus and schedules must be forwarded to FEMA for verification.
Putnam County i
p Protective Actions:
' Proposed plan changes to include the "Go Home" option at the Alert ECL and the option to evacuate students to a school
a 4 .F
-2 4-reception center at either the Alert or Site Area Emergency ECLs must be formally submitted to FEMA in the next annual plan revision submission.
' Areas requiring corrective action identified during the June 4,1986 full-scale exercise must be resolved. These include the availability and awareness of emergency planning information for schools and the allocation of bus resources to schools.
Receotion Centers:
' The issue concerning Letters of Agreement for School Reception Centers is still pending. These Reception Centers are located in Dutchess County and; therefore, are being obtained by the OEM of Dutchess County.
Plan changes must be made to delete inconsistencies found in the current plan between the School Procedure and Transportation Procedure. These revisions should be submitted to FEMA in the next formal submission.
Jransoortation Comoanies t
' Letters or Agreement are in place with Transportation Providers.
Proposed changes of the plan must be submitted during the formal submission to clarify tables of bus requirements.
Public Information for all Four Counties:
' Each county plan should be coordinated and amended for consistency with each other. FEMA will await these plan revisions in the next formal submission.
l
- Interim Finding:
l l Based on FEMA's review of plans and procedures and the criteria contained in NUREG-0654, FEMA is unable at this time to provide i
reasonable assurance that the public health and safety of the school children in the four-county EPZ at Indian Point can be prot ect ed .
l l
. .