ML20237E809
ML20237E809 | |
Person / Time | |
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Site: | Shoreham File:Long Island Lighting Company icon.png |
Issue date: | 12/18/1987 |
From: | Leugers M HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
To: | Atomic Safety and Licensing Board Panel |
Shared Package | |
ML20237E542 | List: |
References | |
OL-3, NUDOCS 8712290198 | |
Download: ML20237E809 (131) | |
Text
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LILCO, December 18,1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
. In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
LILCO'S MOTION FOR
SUMMARY
DISPOSITION OF CONTENTIONS 7 AND 8 (INGESTION PATHWAY AND RECOVERY AND REENTRY)
' Pursuant to 1.0 CFR S 2.749, LILCO hereby moves for summary disposition of Contentions EP 7 and 8, which address whether LILCO has the " legal. authority" to make and implement ingestion pathway and recovery and reentry decisions, respective-
.ly. ,
I. Introduction Contentions 7, Ingestion Pathway, and 8, Recovery and Reentry, concern traditi-onal State responsibilities and functions. Counties, for the most part, play minor roles.
For these counties, New York State has developed a radiological emergency plan (Ad-mitted Faci 34NI that details what it will do during the recovery and reentry and inges-tion pathway response phases of a radiological emergency and who on the State and.
local government level will be responsible for carrying out those functions (Facts 1 and -
2).
i 1/ " Admitted Facts" are the numbered statements in the " Statement of Material Facts"(Attachment A) attached to LILCO's Second Renewed Motion (March 20,1987). l l
)
l-NR o
h l 1
L ____--__a
1 The New York State Radiological Emergency Preparedness Plan (Rev. 8/87)
(hereinaf ter "the State Plan") is comprised of (1) a " generic state plan" that is applied to all nuclear power plants and (2) appendices containing the county plans for all nucle-ar power plants in New York (Fact 3). Since Suffolk County has refused to plan for a Shoreham emergency, there is no county plan for Shoreham appended to the State Plan.2/ Nonetheless, the State can apply its recovery and reentry and ingestion path-way procedures in the " generic plan" section of the State Plan to a Shoreham emergen-cy. Indeed, the new rule contemplates that the State will, in f act, do so.
The NRC's new emergency planning rule presumes that State and local authori-ties will use their "best efforts" to respond to a radiological emergency. 10 CFR S 50.47(c)(1), 52 Fed. Reg. 42,078, 42,085-86 (Nov. 3,1987). If they do not have a plan, "best efforts" presames that they will " follow the utility plan." Thus, during a Shoreham emergency, the State of New York would implement its " generic" recovery and reentry and ingestion pathway procedures since tbay are not site-specific and would use the LILCO Plan as needed to compensate for the f act that no county plan for Shoreham has been appended to the generic section of the State Plan. Suffolk County, on the other hand, would fulfill its clearly defined responsibilities in the State Plan by using the LILCO Plan and LERO resources. All responsibility for decisionmaking would remain with the State and County. LERO would take no independent actions that re-quired legal authority but would only proceed at the direction of Suffolk County and/or the State of New York.W It follows, therefore, that the issue of whether LILCO has 2/ In granting LILCO's summary disposition motion on Contention 92, the Board found that there was no State plan for Shoreham. Memorandum and Order (Ruling on Applicant's Motion for Summary Disposition of Contention 92) (Nov. 6,1987). This f act, however, does not prevent the State from using its generic proc'edures during a Shoreham emergency in a "best ef forts" response.
3/ It has always been LILCO's position that (footnote continued) 1 1 _ _ _ _ _ _ _ _ _ _ _ _ _ _
" legal authority" to make and implement recovery and reentry and ingestion pathway decisions is nonexistent. As such, there remains no genuino issue as to any material f act. LILCO's motion for summary disposition of Contentions 7 and 8, therefore, should
- be granted.
II. Recovery and Reentry Activities The State of New York directs all recovery and reentry activities for radiological emergencies for all nuclear power plants in New York State other than Shoreham (Fact 4). See the State Plan at IV. (The State recovery and reentry procedures are Attach-ment i to this Motion.) In addition, radiological emergency plans for counties in New York commonly defer to the State Plan for instructions on recovery activities (Fact 5).M Upon reviewing these county plans and the State's procedures, it is clear that a (footnote continued)
(s]hould Suffolk County, New York State, or Federa! gov-ernments choose to implement actions consistent with their respective legal autho'rities to protect the health and safety of the public, those actions will take precedence over LERO actions. The Director of Local Response will assure that LERO actforo continue as needed to support governmental response activities.
(Fact 6). The LILCO Plan S 1.4-la (Rev. 8). The Board recognized this fact in the PID where it said that LILCO would perform the State's traditional emergency response functions "in the absence of State participation." PID,21 NRC 644,883 (1985).
4/ For example, both the Indian Point Radiological Emergency Preparedness Plan for Westchester County (Rev.1/87) (hereinaf ter "Westchester County Plan") and the Oswego County Radiological Emergency Preparedness Plan (Rev. 7/85) (hereinaf ter
" Oswego County Plan") for the Nine Mile Point Nuclear Station and FitzPatrick Nuclear Power Plant state:
Recovery / Reentry Operations will conform with the guide-lines contained in the New York State Radiological Emer-l
! gency Preparedness Plan . . . .
(footnote continued)
_ _ ._ . _ _ _ _ _ _ _ _ J
county's role in the recovery / reentry phase of an emergency essentially involves as-sessing local needs, providing police security and fire protection, and implementing de-cisions recommended to them by the State.E (footnote continued)
The implementation of long term recovery operations is the primary responsibility of the State of New York, and will conform with the guidelines contained in the New York State Radiological Emergency Preparedness and Disaster Preparedness Plans.
(Fact 7). See Westchester County Plan at IV-1-2: Oswego County Plan at D-1-2. (The Westchester County Plan's section on recovery is Attachment 2 and the Oswego County Plan's section on recovery is Attachment 3 to this Motion.)
In addition, the Monroe County Plan for the Robert E. Ginna facility states:
" Complete instructions on recovery are located in NYS Radiological Emergency Pre-paredness Plan (Fact 8)." Monroe County Radiological Emergency Preparedness Plan (Rev. S/87) at II-E-1 (hereinaf ter " Monroe County Plan"). See Attachment 4 to this Mo-tion for the complete text of the Monroe County Plan's section on recovery.
1/ For example, the Monroe County Pian at II-E-3 states:
The particular needs of each affected area will be deter-mined by the County Executive and private organizations, in conjunction with the Office of Disaster Preparedness, which will be the State agency coordinating recoverv operations.
The County Executive will be assisted in making iecisions by the County Directors of Departments located at the County Emergency Operations Center.
Upon advice and recommendation of Chairman of New York State Disaster Preparedness Commission (or State Health Commissioner in his absence) a decision will be reached and instructions will be given by County Executive to implement verification of previously ordered protective actions and permit reentry into restricted areas and return to normal activity.
(Fact 9). According to the State Plan," Local Chief Executives assess the needs of their affected areas in conjunction with the State Emergency Management Office. They di-rect recovery operations in their jurisdictions (Fact 10)." State Plan at IV-1.
______________a
During a Shoreham emergency, using its "best efforts," the State would direct re-covery and reentry activities, using its own procedures, and Suffolk County would use the LILCO Plan and LERO's resources to meet its responsibilities. The following sec-tions do two things: first, they describe in detail the division of responsibilities between the State and local governments for recovery and reentry activities, and second, they explain how Suffolk County and the State would use the LILCO Plan in response to a Shoreham emergency.
New York State Would Convene a Recovery Committee in Response to a Shoreham Emergency In a radiological emergency,"[r]ecovery operations (would] commence as soon as the situation [was] stabilized . . . ."O (Fact 11). Stato Plan at IV-2. The New York State Plan provides that a State Recovery Committee would be appointed by the Disas-ter Preparedness Commission (Admitted Fact 61) to direct the recovery activities for those areas af fected by the emergency:
As provided by the New York State Disaster Preparedness Plan, a Recovery Committee having authority and major respons1bilities to make decisions relating to recovery activi-ties will be appointed by the Disaster Preparedness Commis-sion (DPC). This committee will be comprisectof representa-tives of the Commission's membership, and such other agencies as the Commission Chairman may designate. Specif-ically included will be representatives of the Departments of Agriculture and Markets, Commerce, Health, Environmental Conservation, Labor, Social Services, State, Transportation, Office o.t General Services, State Energy Office, Public Ser-vice Commission, Division of State Police and Division of Mil-itary and Naval Affairs / State Emergency Management Office.
(Fact 12). State Plan at IV-1. The responsibilities of the Recovery Committee for a 1
' radiological emergency include:
6/ The Board noted, in ruling that LILCO's recovery procedures were adequate, that
" recovery and reentry activities will be undertaken af ter an accident and an evacuation have occurred. It is f air to conclude that the public would be safe from radiation expo-sure at the time that consideration of recovery and reentry was undertaken." PID,21 NRC at 880.
-G-
[D]irecting State resources and recovery activities and for assisting in the total cooperative effort involving any or all of the other organizations having recognized roles in recovery.
During recovery operations the Committee is responsible for developing practical time parameters and activities consis-tent with this plan, and insures that there are adequate com-munications systems and processes for all State activities.
The Committee reports to the DPC and keeps it apprised of all matters relating to the recovery effort.
(Fact 13). State Plan at IV-1.
Throughout the recovery phase,"[t]he New York State Commissioner of Health continves to have the primary responsibility for recommending protective actions; for l
overseeing the total related radiological program; and for modifying, relaxing, and dis-continuing protective actions (Fact 14)." If there were an emergency at Shoreham, a "best efforts" response.would require that the State convene the State Recovery Com-mittee. The Committee would be comprised of the same State personnel and its mem-bers would be charged with the same responsibilities enumerated in the State's recovery procedures. .
Suffolk County Would Convene the LERO Recovery Action Committee l
At this point in the emergency, Suffolk County will have been working side-by-side with LERO, using the LILCO Phin, since the onset of the emergency. Since Suffolk County has no recovery plans for a Shoreham emergency, it would continue to use the LILCO Plan to coordinate its participation in the recovery phase until recovery and re-entry is accomplished.
The LILCO Plan, like the State Plan, also directs that a recovery committee be formed.E 7/ Other county plans convene local committees for recovery operations (Fact 16).
The Monroe County Plan at II-E-3 requires the County Executive to " establish a Recov-ery Committee to evaluate the potential of the incident to continue to effect the area (footnote continued)
The Director of Local Response directs the formation of the Recovery Action Committee. This committee is convened prior to recovery /re-entry to gather information to assist de-cision making regarding recovery /re-entry and to implement re-entry upon authorization by the Director of Local Re-sponse.
OPIP 3.10.15 5.1. (OPIP 3.10.1, Recovery, is Attachment 5 to this Motion.)EI The LERO Recovery Action Committee would be staffed by the following LERO members who would have been significantly involved during the response phase of the emergen-cy:
- a. Manager of Local Response - Chairman
- b. Health Services Coordinator
- c. Evacuation Coordinator
- d. Support Services Coordinator
- e. Coordinator of Public Information
- f. Radiation Health Coordinator
- g. Nuclear Engineer
- h. Others, see Section 5.1.2 5.1.2 Additional Committee members may participate if available. They are:
- a. FEMA Representative
- b. DOE Representative
- c. EPA Representative
- d. State Representative
- e. County Representative l
l (footnote continued) and the lives of the population." The County Executive would chair the Committee which would be comprised of other county officials (Fact 17). Id.
The Wayne County Radiological Emergency Preparedness Plan (Rev. 4 10/1/86)
(hereinaf ter the " Wayne County Plan") states: "The CCBS (County Chairman of the Board of Supervisors], in coordination with District Director of Health, County Direc-l tor of the Emergency Management Office, the New York State Health Department, and RG&E will make the decision for reentry into evacuated areas (Fact 18)." Wayne County Plan at 69. (The Wayne County Plan's section on recovery is Attachment 9 to this Motion.)
g/ OPIP 3.10.1 was entered into the record at Cordaro et al., ff. Tr.15,284 at Att.
1.
l 1
OPIP 3.10.155 5.1.1, 5.1.2.
The Suffolk County Executive and the Director of Local Response would contin-ue working together during the recovery and reentry phase. The County Executive would retain full responsibility for local decisionmaking and would direct the County's response to the emergency. Meanwhile, the Director of Local Response would serve as an advisory to the County Executive. The County Commissioner of Fire, Rescue and Emergency Services or his designee would work with the Manager of Local Response and would chair the Recovery Action Committee. Similarly, the County Commissioner of the Department of Health Services or his designee would work with the Health Ser-Vice Coordinator; the County Commissioner of Police or his designee would work with the Evacuation Coordinator; and the County Public Information Officer or his designee j
would work with the Coordinator of Public Information.
New York State Would Initiate,Its Recove'ry Operationtuurine a Shoreham EmerFLen,cy n Acc.ording to the State Plan, recovary operations involve four major considera-(
1 I tions:
1
- Determination o! the recovery actions to be taken.
- Dissemination of information on the appropriate re-covery action.
Provision of available State and Federal disaster assis-tance to affected areas.
Requirements for continued monitoring.
(Fact 19). State Plan at IV-2. For each of these considerations, the State Plan spells out in detail what the State Recovery Committee must consider in making recov-ery/ reentry decisions and recommendations. The Plan also designates which State and local agencies are responsible for providing the State Recovery Committee with the data and assessments it needs to make these decisions.
.g.
The "best efforts" principle requires that the State would commence recovery operations for Shoreham based on these four major considerations. Since the State applies the Plan generically to all other nuclear power plants in New York, it can apply it to Shoreham without modification. Thus, precisely how the State would respond to a Shoreham emergency is clear, as the following sections show.
- 1. Determination of recovery actions to be taken.
The State traditionally makes protective action recommendations during a ra-diological emergency in New York State. Radiological " plans for other plants (also]
specify that the State would perform" this function. PID,21 NRC at 883. In addition, these county plans say that making " dose projection [s] based on release data communi-cated to State officials" is the State's responsibility. Id.
The State Recovery Committee uses the following standard in recommending that protective actions be lif ted:
A general consideration for lif ting any protective action initi-ated as a result ci the emergency takes into account the ben-efit received from the reduction of the projected dose, should the protective measures continue, against the social and eco-nomic costs of continuing the action taken. However, initi-ated protective actions for the general population will not be relaxed as long as the projected dose comm1tment exceeds 500 mrem.
(Fact 20). State Plan at IV-2. As the Board noted in its Partial Initial Decision, the !
State's dose commitment for reentry of 500 millirem per year whole-body or equivalent organ dose is identical to that found in 10 C.F.R. S 20.105(a). PID, 21 NRC at 881.E Therefore, it would be appropriate for the State to use this same standard to make pro-tective action decisions for Shoreham.
9/ LERO uses this standard for evaluating whether or not an area is contaminated.
OPIP 3.10.1 5 5.3.2. See also Cordaro et al., ff. Tr.,15,284, at 6 and Att.2; Tr.
15,329-30,15,361 (Daverio, Watts). The Board also found that LILCO's " plans for estimating population doses are adequate." PID,21 NRC at 882.
The Recovery Committee evaluates all possible exposure pathways in de-termining whether the projected dose commitment exceeds 500 mrem. These include external exposure from surf ace contamination and all projected future atmospheric re-leases, ingestion of food and water, and inhalation of radionuclides from resuspension of deposited materials or from projected atmospheric releases (Fact 21). State Plan at IV-2. The State Department of Health makes these assessments and analyzes the data it collects (Fact 22). Id.
In addition to the projected dose commitment, the Recovery Committee consid-ers several other factors before making any protective action decisions. The State Plan 1
specifies that particular State and local agencies assess these factors for the Commit-tee. Table 1 below lists these ten f actors and the State and county agencies responsible for evaluating them. As Table i shows, the State Plan clearly delineates individual State and local responsibilities with the State taking the lead' role (Fact 23). Since the State wiu be implementing its recovery and reertry procedures, this division of responsibilities will also occur during a Shoreham emergency. The State would fol'ow its procedures and Suffolk County would fulfill its role in the State Plan by ustr<g LILCO's recovery procedures and resources.
- 2. Dissemination of information on the appropriate recovery action.
The State Plan has set procedures for disseminating information to the public {
l about what recovery actions are being taken. According to the Plan, the State Com-missioner of Health designates a person to "act as Public Information Officer (PIO) for radiological emergencies to ensure the accurate and timely release of information to the public and the media concerning public protective action recommendations and f
state emergency response activities (Fact 24)." State Plan at C-1. (Pages C-1 to -3 of the State Plan are Attachment 6 to this Motion.) The State PIO would be the State i
TABLE 1 FACTORS TO BE ASSESSED BEFORE LIFTING PROTECTIVE MEASURES AND RESPONSIBLE AGENCY
- State County Factors Responsibility Responsibility l 1
- 1. " Sampling and monitoring Dept. of Health ---
l of radiation and evaluation of data ...."
- 2. " Decontamination Directed by Undertaken by activities, including Dept. of Health local agencies waste disposal ...."
- 3. " Security, including State police Local police and police and fire protection fire agencies for affected areas ...."
\
i I
- 4. " Availability of ... ascertained by State and local medical service ...." health officials."
- 5. " Availability of Public Service ---
electric power and tele- Commission phone communications ...."
- 6. " Adequacy of food and Dept. of Agriculture ---
water supply ...." and Harkets, Eept. of Health
- 7. " Operability of sanitary Dept. of Environ-systems ...." mental Conservation
- 8. " Availability of
--- Local officials transportation ...."
- 9. " Availability of sources State Energy Office of heat ....
- 10. " Conditions and needs ".... surveyed and of the affected determined by Dept. of population ...." Social Services with assistance from the American National Red Cross."
- Chart material taken from State Plan at IV-2 to -3. For complete text of the State Plan precedures for making protective action decisions, see Attachment 1 to this Mo-tion.
contact for all county and utility public information officers and will keep them in-formed of all State PIO activities (Fact 25). Ld. " State, county and utility spokespersons [would] coordinate information sharing and release (Fact 25)." [d.at C-2.
The State Plan requires that three factors be considered before any information about recovery actions is disseminated to the public. These f actors are:
- The status of the services and conditions, Ifsted in Table 1, including infor-mation and guidance for the public on methods to overcome existing deficiencies.
l "The consistency of public announcements between all levels of govern-ment." The releases would be coordinated between the State and County Public Information Officers before they were released.
- How these announcements would be made given the existing situation and the affected areas.
(Fact 26). See State Plan at IV-3. Information will be released by the State PIO "with the approval of the State Disaster Preparedness Commission Chairman and the State llealth Commissioner . .. . ." (Fact 27). Ld. at C-2. The same decisionmaking process and coordination between the State and County would occur during a Shoreham emer-gency. The IERO Coordinator of Pubile Information would work with the County Pub-lic Information Officer to disseminate information on the local level.
- 3. Provisions of available State and Federal disaster assistance to affected areas. 1 I
Any county in New York State can receive State and Federal assistance to help I recover from the affects of a radiological emergency (Fact 28). Article 2-B of the New York State Executive Law provides that the Governor "may direct any and all agencies of the State government to provide assistance under the coordination of the DPC (Fact 28)." State Plan at IV-3.
l l
' The County Executive would be responsible for collecting data on the needs'of the affected areas and submitting that data to the State (Fact 29). State Plan at IV-1,
-3. The Recovery Committee and the Chairman of the Disaster Preparedness Commis-sion would submit these data to the Governor and recommend what actions the Gover-nor should take in seeking federal aid (Fact 29). If federal aid is granted the Recovery Committee and State and local agencies will administer the aid "in accordance with .
procedures adopted for use in administering Federal aid for any other type of an emer-gency or disaster declared by the President (Fact 30)." State Plan at IV-4. On the State level, the State Emergency Manageinent Office (SEMO) would be responsible for coordinating State and Federal assistance and program (Fact 15). State Plan at IV-1.
As can be seen here, Suffolk County's involvement in this area does not require special planning for a radiological emergency. Rather, the County would follow its nor-mal procedures for all other emergencies.
- 4. Requirements for sontinued monitoring.
In the State Plan, the State Commissioner of Health plays the lead role in con-ducting radiation monitoring for contaminated areas and in providing medical follow-up for the general public: ,
A radiation monitoring program for contaminated areas will 1 be established by the State Commissioner of Health. This l, monitoring program may be long term depending upon the type, levels, and extent of the contamination. The moni-toring will also take into account the nature of the contatni-nation as well as the area affected. Future activities af-fecting release of radiation (venting, etc.) will also require monitoring. Other State agencies will cooperate and assist )
the Department of Health in monitoring for long term ef- l fects. Monitoring Programs initiated during the response phase will continue during recovery until acceptable levels are reached.
Medical follow-up to monitor the ef fects of radiation on the i public and emergency workers after the incident may be es-tab 11shed, if required. Currently, the State Department of l Health conducts an ongoing study of selected health statistics J for counties with and without nuclear facilities as part of its !
2
epidemiological program. This program will be enhanced in the event of a radiological emergency.
(Fact 31). State Plan at IV-4 to -5.
During the recovery / reentry phase of a Shoreham emergency, the State would function in the lead position for long-term radiological monitoring and medical follow-up for the general public. The State would implement the same radiological monitoring activities and decisions for a Shoreham emergency that it would for any other power plant in New York State. Suffolk County would assist the State, using the LILCO Plan, in any manner that the State deemed appropriate.
Suffolk County Would Initiate Recovery Operations For Shoreham Using the LILCO Plan The State Plan limits a county's responsibilities during the recovery / reentry phase of a radiological emergency to a few distinct functions. As noted above, a coun-ty's involvement in lif ting protective actionsis:
Undertaking d. contamination activities, such as waste disposal, at the ci-rectico of the State Department of Health.
Providing security and fire protection for the af fected areas.
Ascertaining the availability of medical se:' vices jcintly with the State nealth of ficia's.
Determining the availability of transportation.
Ld. at IV-2 to -3.
In addition, the county Public Information Officer would work with the State Public Information Officer in issuing messages to the public; the Chief Executive would be responsible for gathering and submitting data to the State to support the county's re-quest for federal and state assistance; and the county would work with the State in ad-ministering any federal aid. M. at IV-1 to -3. The county woQld also be involved in monitoring during the recovery phase to the extent initial monitoring programs for the However, since these general public are continued during recovery. M. at -4 to -5.
activities are merely the continuation of emergency response activities, the county would not be performing any additional functions.
Consequently, the only functions that a county performs independently of the State are (1) providing security and fire protection, (2) determining the availability of I
transportation, and (3) gathering data and submitting them for federal aid. None of these functions require special radiological expertise. Rather, they are the types of ac-tivities that counties normally perform during any emergency (Facts 32 and 33). The only functionN that may require special assistance during a Shoreham emergency would be assessing the transportation needs of the public. The LILCO Plan, however, specifically addresses this activity. OPIP 3.10.155 5.4.1(b), 5.4.2(b), 5.4.5(c).
How Suffolk County and LERO Would Work Together The State Plan clearly delegates all recovery and reentry activities among its own agencies and local officials, Even though the LILCO Plan duplicates many of the State's activities, Suffolk County would still imp'ement all of LERO's recovery and re-4 entry procedures during a Shoreham emergency. This does not mean, however, that the olvision of State and County responsibilities in the State Plan would be disturbed. Rath-er, based on the "best efforts" principle, the State would implement its procedures completely. Any LERO activities that duplicate the State's would take a secondary po-sition, merely serving as additionalinformation and resources for the State and County.
Any LERO assessments would serve as " advisory opinions" to the County Executive and the State. In turn, Suffolk County, using "best efforts," would implement the LILCO 10/ In determining whether Contention 24.Q should be admitted, the Board said that it]here is no basis to assume that the Suffolk County police, contrary to their normal duties, would refuse to provide reasonable and appropriate protection in the event of any type of emergency in the County." Special Prehearing Conference Order r (Ruling on Contentions and Establishing Schedule for Discovery, Motions, Briefs, Con arence of Counsel, and Hearing) (August 19,1983), slip op. at 15.
r _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Plan to fulfill its responsibilities in the State Plan. Just how the State and County would use LILCO's procedures is described below.
Recovery and reentry activities in the LILCO Plan are assigned to the Recovery Action Committee members as follows:
Task Responsible Individual
- a. Administration Manager of Local Response
- b. Emergency Status Nuclear Engineer Evaluation
- c. Air Monitoring Radiation Health Coordinator
- d. Ingestion Pathway Radiation Health Coordinator Sampling
- e. Environmental Media Radiation Health Coordinator Survey
- f. Laboratory Analyses Radiation Health Coordinator
- g. Re-entry Area Radiation Health Coordinator Identification -
- h. Public Dose Radiation Health Coordinator Commitment
- 1. Environmental Health Services Coordinator
( Decontamination l j. Transportation Evacuation Coordinator
- k. Traffic Control Evacuation Coordinator
- 1. Communications Manager of LocSi Respor.se
- m. Security Support Services Coordinator l Coordinator of Public
- n. Public Information Information OPIP 3.10.1 S 6.2.
Tasks (c) through (h) parallel the State Department of Health's responsibility for the "[slampling and monitoring of radiation and evaluation of data . . . .'" State Plan at IV-2. The State will perform its functions and use their data in making protective ac-tion recommendations to the County. The County will take LERO's dataN under M/ LERO uses the same standards as the State uses in calculating projected dose commitment. According to LILCO procedures, reentry will not be initiated in an area if it is still considered to be contaminated. In the Plan, contamination exists if " direct constant exposure and inhalation of resuspended particulate for one year . . . results in a dose greater than 500 in mR to wholebody or equivalent to any organ." OPIP 3.10.15 5.3.2. This is the same standard used by the State and approved of by the NRC staff.
See PID,21 NRC at 881.
(footnote continued)
_ _ -________-____a
advisement in its discussions with the State about what protective measures to take.
l This process helps ass'. ire that the correct action will be taken.
Task (1), environmental decontamination, involves the sampling, collection, and transportation of solid and liquid radioactive wastes (Fact 34). See OPIP 3.10.1 S 5.4.3(d). According to the State Plan, the State Department of Health directs these ac-tivities, and local agencies undertake the actual implementation. State Plan at IV-2.
Since Suffolk County has no decontamination procedures in place, the County would use LERO's resources. The State, however, retains the responsibility for deciding when to begin these activities; LERO would not initiate environmental decontamination without direction from the County and/or the State.
Task (j), transportation, involves returning evacuees who required transporta-tion during the evacuation to their homes (Fact 35). OPIP 3.10.155 5.4.1(b), 5.4.2(b),
5.4.5(c). According to the State Plan, the County is responsible for this function. Since LERO has ar' rate,ements for transportation in place, Suffolk County would use LERO's rescurces.
Task (k), traffic control, involves directing the general puolic back into the evacuated area. According to the State Plan, the State and local police. provide securi-ty. Presumably, this incit. des traffic control, a traditional police function. The Courdy Executive would make decisions about where to set up traffic control points on the ad- l
)
vice of the LERO Evacuation Coordinator and the County Commissioner of Police. The j 1
(footnote continued) i i
LERO decides whether a yearly dose commitment is over 500 mrem based on an
"[e] valuation of environmental monitoring results, plant data, and/or laboratory analy-sis of isotopes . . . ." OPIP 3.1.0.15 5.3.2: PID,21 NRC at 881. Id. In making this eval-uation, the Radiation Health Coordinator would conduct air monitoring, ingestion path-way sampling, and environmental surveys. Under the State Plan, the Department of Health would make the same types of evaluations.
I l - - - - - _ - - - - _
Suffolk County Executive would decide whether LERO traffic guides should be used dur-ing the reentry process.
The responsibility for task (1), communications, rests with the Manager of Local Response and the County Commissioner of Fire, Rescue and Emergency Services. Any communications activities implemented by LERO would be at the direction of Suffolk i
County.
The LERO Support Services Coordinator is responsible for task (m), security. In the State Plan, security for the affected area is the joint responsibility of the State and local police. LERO would not perform any security functions on public grounds other than helping with traffic control at the County Executive's request.
On the local level, the LERO Coordinator of Public Information and the Suffolk County Public Information Officer would be responsible for task (n), public information.
The State Plan requires that the dissemination 6f public information should be join;!y coordinated by the State and County Public Information Officers. The County's use of i
the LILCO Plan would not change this arrangement.
The Manager of Local Response and the County Ccamissioner of Fire Rescue s and Emergency Services will jointly chair the Recovery Action Committee and, as such, i
would be responsible for the implementation of these tasks. They would brief the Coun-ty Executive and the Director of Local Response on the status of reentry operations.
The County Executive would take this information under advisement and would confer with the State on what protective action should be implemented. LERO would take no action separate of the County or State. LERO would only proceed at the direction of the County Executive who, according to the State Plan, is responsible for implementing recovery operations. Thus, none of LERO's actions during the recovery and reentry phase of a Shoreham emergency would require " legal authority." Consequently, there remains no issue of material fact to be decided and LILCO's motion for summary disposition of Contention 8 should be granted.
. _ _ _ - _ _-__-_-___a
III. Ingestion Pathway Response The generic section of the New York State Plan also contains a detailed inges-tion pathway procedure for directing and implementing protective measures for all op-erating nuclear power plants that have ingestion pathways extending into the State.O The governments of the affected counties around Shoreham, Nassau County and Suffolk County, are already part of the States ingestion pathway scheme. See list of counties for the " Alert and Notification Procedure" chart for Indian Point, State Plan at K-15.*
See the State Plan at K-1 to -23. (The State Ingestion Pathway procedure is Attach-ment 7 to this Motion.) The purpose of the procedure is to establish a framework for the responsibilities of the New York State Disaster Preparedness Commission (DPC) with re-spect to the radiological ingestion exposure pathway and pro-vides response for emergencies at commercial nuclear power plants, and identifies State agency emergency management readiness, response and recovery activities. J (Fact 36). State Plan at K-1. No part of the actual procedure is site-specific;M itis intended to be applied generically for each nuclear power plant having an ingestion pathway that extends over a part of the State. See Admitted Fact 35.
M/ The procedure states that it has been developed only for the operating nuclear )
' power plants depicted h1 Attachment 1 to the procedure. See Stato Plan at K-9. Those plants are the Ginna Station, the Nine Mile Point /FitzPatrick Nuclear Power Plant sites, Indian Point Nuclear Power Plant, Units 2 and 3, Oyster Creek Nuclear Power Plant (New Jersey), Millstone Nuclear Power Plant, Units 1, 2, and 3 (Connecticut),
Haddam Neck Nuclear Power Plant (Connecticut), Yankee Rowe Nuclear Power Plant (Massachusetts), and Vermont Yankee Nuclear Power Plant (Vermont). The introduc-tion to the State Plan, however, also includes plants in Canada. l 1 Although Shoreham is not included on this chart, there is nothing unique about Shoreham that would prevent the State from applying its ingestion pathway procedure to Shoreham. This f act is all the more evident upon review of Attachment 1. That At-tachment 'shows that almost all of the Shoreham 50-mile ingestion pathway EPZ is within the ingestion pathways of two other nuclear power plants (Indian Point and Mill-stone) that the State procedure does address.
M/ .There are three charts in the State Plan of the Alert and Notification Procedure, one each for Indian Point, Nine Mile, and Ginna. They differ from each other only in the names of the counties and the SEMO District Offices listed for each site (Fact 39).
1
The "best efforts" principle requires that the State implement its radiological in-gestion exposure procedure during a Shoreham emergency and use the LILCO Plan wherever site-specific procedures and information are needed. As such, the State would recommend protective actions and direct ingestion pathway activities for Nassau and Suffolk Counties, the only two counties in the Shoreham 50-mile ingestion pathway.
The State will have no problem using its procedure for this purpose since both of these counties are in the 50-mile ingestion pathways for Indian Point Units 1 and 2 (Fact 37).
State Plan at K-9. Furthermore, Suffolk County is in the ingestion pathway of the Mill-stone Nuclear Power Plant in Connecticut (Fact 38). I_d. Thus, while neither of these counties may have planned specifically for Shoreham, the State has figured both of these counties into its emergency response procedure. For example, both counties and I the local SEMO District Offices are listed on the " Alert and Notification Procedure" chart for Indian Point (Fact 43). See State Plan at K-15. Obviously, the State is pre
- pared to mobilize its district offices on Long Island for an ingestion pathwty raponse.
Therefore, they could do the sa:nc for S't7teham. In turn, since Suffolk County has de-clined to plan fo'. a Shorcham emergency, the "best efforts" principle dictates that Suffolk County use LILCG's ingestion pa#hway procedures and rascurces in response to such an emergency.
The following sections show what standards will be used by the State and County in making decisions during a radiological emergency at Shoreham and who will make these decisions. As LILCO stated above in discussing Contention 8 LILCO will take no actions that require " legal authority" independently of the State or County. The same is true for an ingestion pathway response. Consequently, there remains no genuine issue of material fact to be decided and LILCO's motion for summary disposition of Contention 7 should be granted.
I Responsibilities in the State l Ingestion Pathway Procedure j
{
"In response to an ingestion pathway incident (in New York State], State, Coun- l ty and Federal governments will be responsible for specific roles and activities . . . ."
l State Plan at K-1. " State agency coordination among federal and local governments, the nuclear facility operators, and the private sector for information, technical assis-tance or resources as necessary" would be required. Id. During an ingestion pathway response for Shoreham, the State, County, and federal government would fulfill these same roles.
The State's role in an ingestion pathway response includes (1) the " assessment of l
impact," (2) the " evaluation of response options," and (3) the " implementation of neces-sary response actions (Fact 44)." Id. The State Disaster Preparedness Commission, through appropriate State agencies, takes the lead position in evaluating the incident and in managing the State's response. In particular, the Commission wil!
activate appropriate State agencies' field staff; collect,' transport and analyze ingestion pathway sam- ,
i ples;
- assess and evaluate the potential impact of ingestion pathway contamination; alert local governments of the emergency and the po-tential for adverse public health impact.
(Fact 45). Id. In addition, State agencies provide the necessary resources to protect the public health, property, and the environment. " State agencies involved in the in-gestion exposure pathway response would use their own specific agency procedures.
These activities would be coordinated by SEMO (the State Emergency Management Of-fice] at the State EOC and in the appropriate District EOC." State Plan at K-6. De-partments of Health, Agriculture and Markets, Environmental Conservation, State Po-lice, and Transportation, the State Emergency Management Office (SEMO), and the
I Radiological Emergency Preparedness Group (REPG) will participate in assessing the impact of the radiological emergency on the ingestion pathway and will work with local governments in their response (Fact 46). Ld.
1 The State Plan lists responsibilities for each of these agencies. Ld. at K-6 to -7.
'Only one specific agency function requires site-specific information. The State De-partment of Agriculture and Markets is required to " maintain an inventory of dairy farms, food processing plants and state farms . . . ." [d. at K-6. The Department would use this information to " collect samples of milk, produce, and animal feeds . . . ." Ld.
I For these activities, the State would rely on the LILCO Plan which maintains complete j lists of dairy farms, food processors, duck f arms, beef farms, fruit f arms, vegetable and potato farms, farm stands, milk dealers, and ice cream plants. OPIP 3.6.6, Attachment 9-16b. (These Attachments are not appended to this Motion due to their substantial length). None of the other sampling activities require site-specific information.
The State Plan also describes what role the federal government would piay., The federal government, through the Department of Energy,is targeted to provide techni-cal resource supplement, personnel, monitoring and assessment, and laboratories. Ld. at K-1 to -2. The State Plan rolles heavily on the federal government for technical sup-port:
Technical Federal support is an integral part of New York l
State's ingestion pathway response. In the early hours or (sic) a radiological emergency, support will be provided through the U.S. Department of Energy's Radiological Assis-tance Plan (RAP). Technical expertise with sophisticated monitoring, sampling and laboratory analysis capability will be provided from the Brookhaven Area Office with USDOE and Brookhaven National Laboratory staff. Advance RAP teams are also avallble [ sic] from the Knolls Atomic Power Laboratory, West Valley Demonstration Project, Environ-mental Measurements Laboratory and the Pittsburgh Naval Laboratory. USDOE will provide sophisticated aerial moni-taring capability and plume modeling using ARAC. USDOE rearces from Region 1 will be supplemented as required from other DOE facilities including the National Laboratories. ,
if the emergency conditions warrant, the Federal Radiological l Monitoring and Assessment Plan (FRMAP) will be implemented to obtain Federal interagency technical support.
1
_ _ _ _ _ _ _ _ _ . _ _ _ _ _ __ _ l
l 1
(Fact 40). Id. at K-2.UI
' According to the State Plan, the counties impacted by the emergency would pro- !
vide the following support:
maintenance of ongoing monitoring programs (i.e., pub-lie water supply)
- provide information on local agricultural activities guiding State / Federal responders support State response for ingestion concerns (Fact 41). State Plan at K-2.
The State procedure also describes the licensees' involvement in the ingestion pathway response activities. For example, the State procedure says that the licensee l
"would continue to work to stabilize and return the plant to pre-accident conditions.
Offsite monitoring would also be supplied by the utility to supplement the county / State resources (Fact 42)." Ld. LILCO is in a particularly good position to supplement County and Statt resources rince it has a comprehensive ingestion pathway procedure in place that the Board found was workable (PID,21 NRC at 878) and because LILCO has a f ull l complement of emergency workers who are thoroughly trained in monitoring tech-niques, as well as in other ingestion patnway activities.
How the State Would Implement Its Ingestion Pathway Procedure for a Shoreham Emergency The State ingestion pathway procedure contains the structure needed to coordi-nate all ingestion pathway activities for a Shoreham emergency. For example, com-mand and control would be directed by the State as follows:
1_4, / The LILCO Plan also telles on DOE and the Brookhaven National Laboratory staff in its ingestion pathway procedures for this same type of technical support.
I l
In the event of a nuclear power plant incident, Command and Control Operations are managed from the State EOC in Albany. From this location, the Chairman of the DPC as the Governor's designee and other State officials direct the emer-gency management response and recovery operations. The
. Command Room is augmented by State and District EOC op-erations, radiological assessment and evaluation, communica-tions and public information. These components provide the necessary information to Command Room personnel to facill-tate the State's decision making.
From the Command Room decisions concerning State re-sponse and recovery are provided. Local officials will be in-formed of all decisions to insure continuity of the operation.
The objectives of the Command Room operation are:
to assess the magnitude of the situation; define radiological impact; implement procedures to respond to the situa -
tion; implement protective measures; initiate public information procedures; coordinate all actions with appropriate local government officials.
(Fact 47). . State Plan at K-5.
Public information about ingestion pathway activities during a Shoreham emer-
. gency would be disseminated according to th2 5 tate Plan. The State procedure requires that an extensive public alert and notification system be established by State and local governments because of "the potential magnitude and impact of an ingestion exposure pathway incident . . . . There is a requirement for notification to the general public, agricultural industry, retail and wholesale food and commodity distributors, industrial representatives and other appropriate entities (Fact 48)." State Plan at K-8.
A Joint News Center (JNC) located near the affected area would be set up and coordinated by local, State, Federal and utility public information officers (Fact 49).EI M/ The State Plan also provides that in the event there is no Joint News Center.
then information would be provided to the puDlic from Albany or another designated lo-cation. Id. at K-8. If necessary, the State would activate the New York State Emer-gency Broadcast System (EBS). Otherwise, the local EBS would be accessed.
From here, all emergency information on the status of the emergency and protective measures would be disseminated to the public (Fact 49). For Shoreham, the LILCO I Emergency News Center (ENC) would function as the Joint News Center since the ENC would have been used as such throughout the response phase of the emergency. Fur-l l
thermore, the "best efforts" principle requires the State and County to follow the LILCO Plan which calls for using the ENC for this purpose.
All news releases and EBS messages would be written at the JNC and then sub-mitted to the State EOC Public Informaion Officer upon completion. This process would remain intact during a Shoreham incident. The County, however, would use LILCO's procedures for writing EBS messages.
Suffolk County's Resporc,1bilities for Ingestion Pathway Activities at Shoreham County radiological plans for other nuclear power plants in New York State rely heavily on the State to direct and implement an ingestion pathway response for ra-diological emergencies. For example, the typical language found in these plans say:
The implementation and execution of the Isolation of Inges-tion Pathways and Sources Reslese Option will conform with the Isolation cf Ingestion Pathways Guidelines contained in the State of New York EmergTcy Plan . . . .
(Fact 50). Wayne County Radiological Emergency Preparedness Plan, pp. 49 (Rav. 4 10/1/86) (hereinaf ter " Wayne County Plan") (the Wayne County Plan is Attachment 11 to this Motion) and the Indian Point Emergency Preparedness Plan for Westchester County, pp. 111-29-30 (Rev. 7/85) (hereinaf ter "Westchester County Plan") (the Westchester County Plan is Attachment 12); see also the Oswego County Radiological Emergency Preparedness Plan, pp. C-27 (Rev. 7/85) (hereinaf ter " Oswego County Plan")
(the Oswego County Plan is Attachment 10).
I
The "best efforts" principle requires Suffolk County to use the LILCO Plan in re- J sponse to an emergency at Shoreham. Since the State performs most ingestion pathway response activities, Suffolk County can easily fulfill its designated functions in the State Plan by using LILCO's procedures for ingestion pathway. The LILCO Plan, howev-er, is much more comprehensive in the areas it addresses than the county functions spelled out in the State procedure. In the LILCO Plan, for example, the Radiation Health Coordinator is responsible for coordinating sample collection and analysis with DOE, the Shoreham facility, and other response groups (Fact 51). OPIP 3.6.6 S 2.0.
(OPIP 3.6.6, Ingestion Pathway Protective Actions, is Attachment 8 to this Motion.) In the State Plan, these functions are undertaken by the State Department of Health (Fact 52). Both LERO and the State can perform these functions without working at cross purposes since the County Executive would be responsible for implementing all LERO/ County activities and for coordinating them with the State. No protective ac-tions or measures will be taken or implemented by LERO without direction from the County or the State. As a matter of lact, the LILCO Plan does not contemplate LERO's taking any such actions when the State is willing to respond:
The Director of Local Responsa will contact the New York State Commissioner of Health and the Connecticut Depart-ment of Environmental Protection and provide the LERO In-gestion Pathway protectiva action recommendation:
New York State Commissioner of Health Connecticut Department of Environmental Protection, Chief of Radiation Control Unit If the above-mentioned state officials / agencies indicate that they are willing and able to implement the ingestion pathway plan for their state, no further action is necessary. If an ade-quate response cannot be ensured, refer to Section 5.4.
(Fact 53). OPIP 3.6.6. S 5.1.3.6. LERO never intended to linplement any protective ac-tions or measures where the State or County was willing to do so. Consequently, whether LERO has to implement an ingestion pathway response " legal authority" is not
an issue. As such, there exists no material fact to be decided and LILCO's motion for summary disposition of Contention 7 should be granted.
New York State's Ingestion Pathway Response For Shoreham Would Be Adecuate There can be no question that the State's response to an ingestion pathway inci-dent would be adequate. The State's Radiological Ingestion Exposure Procedure, as part of the " generic State Plan," received Federal approval from FEMA in February 1985.
State Plan at 2. In August 1987, a new revision of the Plan was issued. In October of this year, FEMA conducted a three-day federally graded exercise of the response plans for the Ginna Nuclear Power Plant (Fact 54). A test of the State ingestion pathway procedure was included (Fact 54). The State received very favorable remarks from FEMA about its response capabilities during the public critique that followed the exer-cise (Fact 55). The State's implementation of its procedures for Shoreham, should raise no more ccncern here than at any other nuclear power plant in New York or for any neighboring state's f acility.
IV. Conclusion For the reasons stated above, LILCO asks the Board to grant summary disposition in LILCO's f avor of Contentions 7 and 8.
Respectfully submitted, b '
)0///1l6 U;
?bM4/ B Donald fwiff ' W -f James'N hristman ~ J Mary Jo eugers Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: December 18,1987 l
i
4 STATEMENT OF THE MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTIONS 7 (INGESTION PATHWAY) AND 8 (RECOVERY AND REENTRY)
- 1. The New York Radiological Emergency Preparedness Plan (hereinaf ter the
" State Plan") contains detailed procedures about what the State would do during the re-covery and reentry ingestion pathway phases of a radiological emergency in the State.
- 2. These recovery and reentry and ingestion pathway procedures indicate who in the State and local government will be responsible for carrying out the recovery and reentry and ingestion pathway functions listed in the State procedures. .
3.- The State Plan is comprised of (1) a " generic state plan" that is applied to all nuclear power plants and (2) appendices containing the county plans for all nuclear power plants in New York Stata other than Shoreham.'
- 4. The State of New York directs all recovery and reentry and ingestion pathway activities for radiological emergencies at all nuclear power plants in New York other than Shoreham and has developed procedures that are applied generically to these plants.
- 5. County radiological emergency plans in New York defer to the State Plan
- for instructions on recovery and reentry and ingestion pathway activities.
- 6. The LILCO Plan at S 1.4-la provides that (s]hould Suffolk County, New York State, or Fed-eral governments choose to implement actions consistent with their respective legal authorities to protect the health and safety of the public, those actions will take precedence over LERO ac-tions. The Director of Local Response will assure that LERO actions continue as needed to support governmental response activities.
N _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
- 7. Both the Indian Point Radiological Emergency Preparedness Plan for Westchester County at IV-1 to -2 (Rev.1/87) (hereinaf ter "Westchester County Plan")
and the Oswego County Radiological Emergency Preparedness Plan at D-1 to -2 (Rev.
7/85) thereinaf ter " Oswego County Plan") .for the Nine Mile Point /FitzPatrick sites state:
Recovery / Reentry Operations will conform with the guide-lines contained in the New York State Radiological Emer-gency Preparedness Plan . . . .
The implementation of long term recovery operations is the primary responsibility of the State of New York, and will conform with the guidelines contained in the New York State Radiological Emergency Preparedness and Disaster Preparedness Plans.
- 8. The Monroe County Radiological Emergency Preparedness Plan at II-E-1
-(Rev. 5/87) (hereinaf ter " Monroe County Plan"), for the Robert E. Ginna facility states:
" Complete instructions on recovery are located in NYS Radiological Emergency Pre-
. paredness Plan."
- 9. The Monroe County Plan at 11-5-3 states:
The particular needs of each affected area will be deter-mined by the County Executive and private organizations, in conjunction with the Office of Disaster Preparedness, which will be the State agency coordinating recovery operations.
The County Executive will be assisted in making decisions by the County Directors of Departments located at the County Emergency Operations Center.
Upon advice and recommendation of Chairman of New York State Disaster Preparedness Commission (or State Health Commissioner in his absence) a decision will be reached and instructions will be given by County Executive to implement verification of previously' ordered protective actions and permit reentry into restricted areas and return to normal activity.
1 l
- 10. The State Plan at IV-1 states that " Local Chief Executives assess the
~
needs of their affected areas in conjunction with the State Emergency Management Of-fice. They direct recovery operations in their jurisdictions."
- 11. The State Plan at N-1 states that, in the event of a radiological emergen-cy, "(r]ecovery operations commence as soon as the situation is stabilized . . . ."
l 12. The State Plan at N-1 provides that the State Disaster Preparedness Commission will appoint a Recovery Committee as follows:
As provided by the New York State Disaster Preparedness Plan, a Recovery Committee having authority and major ]
responsibilities to make decisions relating to recovery activ- l ities will be appointed by the Disaster Preparedness Com-mission (DPC). This committee will be comprised of repre-sentatives of the Commission's membership, and such other agencies as the Commission Chairman may designate. Spe-cifically included will be representatives of the Departments of Agriculture and Markets, Commerce, Health, Environ-mental Conservation, Labor, Social Services,' State, Trans-portation, Office of General Services, State Energy Office, Public Service Commission, Division of State Police and Di-vision of Military and Naval Affairs / State Emergency Man-agement Office.
- 13. The State Plan at N-1 states that the responsibilities of the Recovery Committee include:
[D]irecting State resources and recovery activities and for
- assisting in the total cooperative effort involving any or all of the other organizations having recognized roles in recov-ery. During recovery operations the Committee is responsi-ble for developing practical time parameters and activities consistent with this plan, and insures that there are ade-quate communications systems and processes for all State activities. The Committee reports to the DPC and keeps it apprised of all matters relating to the recovery effort.
- 14. According to the State Plan at N-1, during the recovery phase of a ra- )
diological emergency, "(t]he New York State Commissioner of Health continues to
)
have the primary responsibility for recommending protective actions; for overseeing f 1 I
l the total related radiological program; and for modifying, relaxing, and discontinuing protective actions."
- 15. The State Plan at IV-1 says that the Director of the State Emergency Management Office (SEMO) is responsible for coordinating State and federal assistance and programs based on local needs.
- 16. Other county radiological plans in New York State convene local commit-tees for recovery operations.
- 17. The Monroe County Plan at II-E-3 requires the County Executive to "es.-
tablish a Recovery Committee to evaluate the potential of the incident to continue to effect the area and the lives of the population." The Monroe County Executive would chair the committee which would be comprised of other county officials.
- 18. The Wayne County Radiological Emergency Preparedness Plan at 69 (Rev.
410/1/86) (hereinaf ter the " Wayne County Plan") states: "The CCBS [ County Chairman I
of the Board of Supervisors], in coordination with District Director of Health, County Director of the Emergency Management Office, the New York State Health Depart-ment, and RG&E will make the decision for reentry into evacuated areas."
- 19. According to the State Plan at IV-2, State recovery operations involve the following four major considerations:
- a. " Determination of the recovery actions to be taken."
- b. " Dissemination of information on the appropriate recovery action."
- c. " Provision of available State and Federal disaster assistance to af-fected areas."
- d. " Requirements for continued monitoring."
- 20. In making protective action decisions during the recovery phase, the State Recovery Committee uses the following standard:
A general consideration for lif ting any protective action ini-tlated as a result of the emergency takes into account the benefit received from the reduction of the projected dose, should the protective measures continue, against the social and economic costs of continuing the action taken. Howev-er, initiated protective actions for the general population will not be relaxed as long as the projected dose commit-ment exceeds 500 mrem.
State Plan at IV-2.
- 21. According to the State Plan at IV-2, the State Department of Health is re-sponsible for analyzing the following exposure pathways: external exposure from sur-face contamination and all projected future atmospheric releases, ingestion of food and water, and inhalation of radionuclides from resuspension of deposited materials or from projected atmospheric releases.
- 22. The State Recovery Committee uses the evaluation of these exposure pathways to determine the projected dose commitment.
- 23. State and county responsibilities for determining the recovery actions to be taken are set forth in Table 1 of this Motion.
l l
- 24. The State Plan at C-1 says that the State Commissioner of Health will l
designate a person to "act as [the] Public Information Officer (PIO) for radiological emergencies to ensure the accurate and timely release of information to the public and the media concerning public protective action recommendations and state emergency response activities."
- 25. The State Plan at C-1 to -2 states th;t the State PIO will be the State contact for all county and utility public information officers and will keep them in-formed of all State PIO activities and that " State, county and utility spokespersons
[will] coordinate information sharing and release."
- 26. The State Plan at IV-3 requires that the following factors be considered before any information about recovery actions is disseminated to the public:
! The status of the services and conditions enumerated in the "f actors to be l considered," (a)-(j), on pages IV-2 to -3, including information and guld-ance for the public on methods to overcome existing deficiencies.
l "The consistency of public announcements between all levels of govern-ment." The releases would be coordinated between the State and County Public Information Officers before they were released.
How these announcements would be made given the existing situation and the affected areas.
- 27. According to the State Plan at C-2, the actual release of information by the State PIO during a radiological emergency will be done "with the approval of the State Disaster Preparedness Commission Chairman and the State Health Commissioner
- 28. The State Plan at IV-3 describes the provision of available State and fed-eral aid in the following words:
State and Federal assistance can be made available to as-sist affected counties in recovering from the effects of a radiological emergency.
Article 2-B of the New York State Executive Law pro-vides that when the Governor declares a disaster emer-gency for an affected area he may direct any and all agencies of the State government to provide assistance ]
under the coordination of the DPC.
- 29. The State Plan at IV-4 says that the County Executive will collect data on the needs of the affected areas and submit those data to the State according to federal
law and that the Recovery Committee and the Chairman of the Disaster Preparedness Commission will submit these data to the Governor and recommend what actions the Governor should take in seeking federal aid.
- 30. If federal aid is granted, the State Plan at IV-4 says that the Recovery Committee and State and local agencies will administer the aid "in accordance with procedures adopted for use in administering Federal aid for any other type of an emer-gency or disaster declared by the President."
- 31. The State Plan says at IV-4 to -5, that the State Commissioner of Health plays the lead role in conducting radiation monitoring for contaminated areas and in providing medical follow-up for the general public in the following words:
A radiation monitoring program for contaminated areas will be established by the State Commissioner of Health. This monitoring program may be long ter'm depending upon the type, levels, and extent of the contamination. The moni-toring will also take into account the nature of the contami-nation as well as the area affected. Future activities af-fecting release of radiation (venting, etc.) will also require monitoring. Other State agencies will cooperate and assist the Department of Health in monitoring for long term ef-fects. Monitoring Programs initiated during the response phase will continue during recovery until acceptable levels are reached.
Medical follow-up to monitor the effects of radiation on the public and emergency workers af ter the incident may be es-tablished, if required. Currently, the State Department of Health conducts an ongoing study of selected health statis-tics for counties with and without nuclear facilities as part of its epidemiological program. This program will be en-hanced in the event of a radiological emergency.
- 32. Providing police security and fire protection during an emergency is a ,
normal county function.
L __ ._._ _ _ . _ _ _ _ _ _ . _ _ _ _ _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .__
- 33. Counties normally provide transportation for members of the public who need it in an area affected by an emergency.
- 34. OPIP 3.10.1 S 5.4.3(d) provides for the collection and transportation of solid radioactive waste and the sampling of liquid wastes.
1
- 35. OPIP 3.10.1 S 5.4.1(b), 5.4.2(b), and 5.4.5(c) require that transportation be provided for those persons who required it during the evacuation.
- 36. State Plan at K-1 says that the purpose of the State's ingestion pathway procedure is to establish a framework for the responsibilities of the New York State Disaster Preparedness Commission (DPC) l with respect to the radiological ingestion exposure pathway and provides response for emergencies at commercial nucle-ar power plants, and identifies State agency emergency management readiness, response and recovery activities. j
- 37. Parts of Nassau County and Suffolk County are in the 50-mile ingestion pathway EPZ for Indian Point and are listed on the " Alert and Notification Procedure" chart for Indian Point. State Plan at K-9,-15.
- 38. Part of Suffolk County is in the 50-mile ingestion pathway EPZ for the Millstone Nuclear Power Plant in Connecticut. Ld. at K-9.
- 39. The only parts of the State's ingestion pathway procedure that are site-specific are three charts called " Alert and Notification Procedure," one each for Indian Point, Nine Mile, and Ginna. They differ from each other only in the names of the counties and the SEMO District Offices listed for each site. See State Plan at K-15,
-17,-19.
_9_
- 40. The State Plan at K-2 relies on the federal government for support during the ingestion pathway phase of an emergency in the following words:
Technical Federal support is an integral part of New York State's ingestion pathway response. In the early hours or
[ sic] a radiological emergency, support will be provided through the U.S. Department of Energy's Radiological Assis-tance Plan (RAP). Technical expertise with sophisticated monitoring, sampling and laboratory analysis capability will be provided from the Brookhaven Area Office with USDOE and Brookhaven National Laboratory staff. Advance RAP teams are also availble [ sic] from the Knolls Atomic Power Laboratory, West Valley Demonstration Project, Environ-mental Measurements Laboratory and the Pittsburgh Naval Laboratory. USDOE will provide sophisticated aerial moni-toring capability and plume modeling using ARAC. USDOE resources from Region 1 will be supplemented as required from other DOE facilities including the National La-boratories. If the emergency conditions warrant, the Feder-al Radiological Monitoring and Assessment Plan (FRMAP) will be implemented to obtain Federal interagency technical support.
- 41. According to the State Plan at K-2, the counties impacted by the emer-gency would provide the following support:
maintenance of ongoing monitoring programs (i.e., public water supply) provide information on local agricultural activities guiding State / Federal responders support State response for ingestion concerns.
- 42. The State Plan at K-2 says that the licensee "would continue to work to stabilize and return the plan to pre-accident conditions. Offsite monitoring would also be supplied by the utility to supplement the county / State resources."
- 43. Nassau County and Suffolk County and the local District SEMO Offices for these counties are listed on the " Alert and Notification Procedure" chart for Indian
(
l Point. See State Plan at K-15.
I
l
- 44. According to the State Plan at K-1, the State's role in an ingestion path-l way response includes (1) the " assessment of impact," (2) the " evaluation of response options," and (3) the " implementation of necessary response actions."
- 45. During an ingestion pathway response, the State Disaster Preparedness Commission will activate appropriate State agencies' fleid staff; collect, transport and analyze ingestion pathway samples; assess and evaluate the potential impact of ingestion pathway con-tamination; alert local governments of the emergency and the potential for ad-verse public health impact.
State Plan at K-1.
- 46. According to the State Plan at K-6 to -7, the State Departments of Health, Agriculture and Markets, Environmental Conservation, State Police, and Trans-portation, the State Emergency Management Office (SEMO), and the Radiological Emergency Preparedness Group (REPG) will participate in assessing the impact of an i
ingestion pathway incident and will work with local governments in their response.
1 1
- 47. The State Plan at K-5 says that the State is responsible for command and controlin the following words: _
In the event of a nuclear power plant incident, Command and Control Operations are managed from the State EOC in Albany. From this location, the Chairman of the DPC as the Governor's designee and other State officials direct the emergency management response and recovery operations.
The Command Room is augmented by State and District EOC operations, radiological assessment and evaluation, commu-nications and public information. These components provida the necessary information to Command Room personnel to facilitate the State's decision making.
. ' From the Command Room decisions concerning State re-sponse and recovery are provided.~ Local of ficials will be in-formed of all decisions to insure continuity of the operation.
The objectives of the Command Room' operation are:
to assess the magnitude of the situation; define radiological impact; .
implement procedures to respond to the situa-tion; implement protective measures; initiate public information procedures; coordinate all actions with appropriate local government officials.
'48.
The State procedure at K-8 requires that an extensive public alert and no-
' tification system be established by State and local governments. In particular, the pro-cedure says:
The potential' magnitude and impact of an ingestion expo- ;
sure pathway incident requires an extensive public alert and
- notification capability on the part of State and local govern-ment. There is a requirement for notification to the general public, agricultural industry, retail and wholesale food and
' commodity. distributors, industrial representatives and other appropriate entities.
- 49. A Joint News Center (JNC) located near the affected area will be set up and coordinated by local, State, Federal and utility public information officers. From here, all information on the status of the emergency and protective measures would be
' disseminated to the public. State Plan at K-8.
1 i
1
- 50. The Wayne County Plan at 49 and the Westchester County Plan at III-29 to 1
-30 state:
I 1
1 The implementation and execution of the Isolation of In-gestion Pathways and Sources Response Option will con-form with the Isolation of Ingestion Pathways Guidelines contained in the State of New York Emergency Plan . . . .
The Oswego County Plan at C-27 contains language virtually identical to this language.
- 51. In the LILCO Plan, the Radiation Health Coordinator is responsible for coordinating sample collection and analysis with DOE, the Shoreham facility, and other response groups. OPIP 3.6.6 5 2.0.
- 52. The State Departments of Health, Agriculture and Markets, and Environ-mental Conservation collect samples to be tested in the ingestion pathway. State Plan at K-6 to -7.
- 53. The LILCO Plan does not contemplate that LERO would take any such ac-tions when the State is willing to respond, in these words:
The Director of Local Response will contact the New York State Commissioner of Health and the Connecticut Depart-ment of Environmental Protection and provide the LERO In-gestion Pathway protective action recommendation:
New York State Commissioner of Health Connecticut Department of Environmental Protec-tion, Chief of Radiation Control Unit' {
If the above-mentioned state of ficials/ agencies indicate that they are willing and able to implement the ingestion path-way plan for their state, no further action is necessary. If an adequate response cannot be ensured, refer to Section 5.4. i OPIP 3.6.6. S 5.1.3.6.
- 54. In October of this year, FEMA conducted a three-day federally graded ex-ercise of the response plans for the Ginna Nuclear Power Plant. A test of the State in-gestion pathway procedure was included.
- 55. The State received very favorable remarks from FEMA about its response ,
capabilities during the public critique that followed the exercise.
INDEX TO ATTACHMENTS l
l l
Attachment 1: New York State Radiological Emergency i Preparedness Plan, Section IV: Recovery (Rev. 8/87).
Attachment 2: Indian Point Radiological Emergency Preparedness Plan for Westchester County, Section IV-D: Recovery (Rev. 1/87).
Attachment 3: Oswego County Radiological Emergency Preparedness Plan, Section D: Recovery (Rev. 7/85).
i Attachment 4: Monroe County Radiological Emergency l Preparedness Plan, Section D: Recovery (Rev. 5/87).
Attachment 5: OPIP 3.10.1 (Recovery / Reentry)
(Rev. 8).
Attachment 6: New York State Radiological Emergency Preparedness Plan, Part II, Sec. I, Proc. C, Public Information, pp. C-1 to -3 (Rev. 8/87). !
Attachment 7: New York State Radiological Emergency Preparedness Plan, Part II, Sec. I, Proc. K, Radiological Ingestion Exposure (Rev. 8/87).
Attachment 8: OPIP 3.6.6 (Ingestion Pathway Protective 3 Actions) (Rev. 8). ]
i Attachment 9: Wayne County Radiological Emergency Preparedness Plan, Section D: Recovery ;
(Rev. 4 10/1/86).
Attachment 10: Oswego County Radiological Emergency i Preparedness Plan, pp. C-27-28 (Rev. 7/85).
Attachment 11: Wayne County Radiological Emergency Preparedness Plan, pp. 48-49 (Rev. 4 '
10/1/86).
Attachment 12: Indian Point Radiological Emergency Preparedness Plan for Westchester County, pp. III-29-30 (Rev. 1/87).
l
Attachment 1 New York State Radiological Emergency Preparedness Plan CONTENTS PART I SECTION IV: RECOVERY P'7e A. INTRODUCTION IV-1 B. RESPONSIBILITIES 3 IV-1 1
C. OPERATIONS IV-2 IV-i
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(N O T U S E D) l 1
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New York State Radiological Emergency Preparedness Plan PART I SECTION IV IV. RECOVERY A. INTRODUCTION As provided by the New York State Disaster Preparedness Plan, a Recovery Committee naving autnority and major responsioilites to make decisions relating to recovery activities will De appointea by tne Disaster Preparedness Comission (DPC). Tnis comittee will be comprised of representatives of the Comission's memoersnip, ano sucn otner agencies as tne Commission Chairman may designate.
Specifically inclucea will oe representatives of the Departments of Agriculture and Markets, Commerce, Heal tn, Environmental Conservation, Leoor, Social Services, State, Transportation, Of fice of General Services, State Energy Office, Puolic Service Comission, Division of State Police ana Division of Military ana Naval Affairs /Stdte Emergency Man 4gement Office. ~
B. RESPONSIBILITIES The Committee is responsible for airecting State resources and
, recovery activities and for assisting in tne total cooperative effort
' involving any or all of tne otner organizations naving recognized roles in recovery. During recovery operations the Comittee i s responsible for developing practical tiue parameters ano activities consistent with tnis plan, anc insures tnat there are adequate communications systems and processes for all State activities. Tne Committee reports to the DPC and keeps it apprised of all matters relating to tne recovery effort.
The New York State Commissioner of Healtn continues to nove the primary responsibility for recommencing protective actions; for overseeing tne total related radiological program; ano for modifying, relaxing, ano discontinuing protective actions.
The director of the State Emergency Management Of fice (SEMU) coordinates St4te ano Feceral assistance anc programs witn perceived needs and the requests of the local Jurisdictions.
Local Chief Executives assess the neecs of tneir af fected areas in conjunction witn tne State Emergency Management Of fice. Tney di rec t i recovery operations in tneir jurisdictions.
The Governor may appoint a Recovery Planning Council tas cesignatea by Title VIII, Section due of tne P'uolic WorAs anc Econo:nic Development Act of 1903, as acced by Title V of Puolic Law 93-2e6 -
"The Disaster Relief Act of 1974") to nelp determine local neecs in tne recovery ef fort, gy.) 3.e v . 10/35
PART I, SECTION IV l
C. OPERATIONS Recovery operations commence as soon as the situation is stacilized and involves tne following four major considerations: i e Determination of tne recovery actions to'oe taKen. ,
e Dissemination of information on the appropriate recovery action. !
e Provision of availaole State ana Federal disaster assistance to affected areas.
e Requirements for continued monitoring.
- 1. A general consideration for lif ting any protective action initiated as a result of tne emergency takes into account tne benefit received from tne reduction of tne projected dose, snould the protective measures continue, against tne social ano economic costs of continuing the action taken. Howev er, initiatec protective actions for tne general population will not ce relaxec as long as tne projected cose commitment exceeds 500 mrem.
Certain incivicuals may oe allowec reentry to an af fectec area if tne situation warrants. An example is the farmer wno must tena hi s livestock. In tnis case tne farmer is treatec as an
~
emergency worker, given personal cosimetry equipment anc emergency worxer exposure levels apply.
In determining the projected dose commitment all possible exposure patnways are constcered. These incluce: 3
- a. External exposure resulting from surface contamination ana j ]
all, projected future atmospheric releases related to tne acc1 cent,
- b. Ingestion of contaminated milk, or otner agricultural !
procucts, or water,
- c. Innalation of racionuclices resulting from resuspension of cepositec material or from projectea atmospheric releases resulting from the accident.
Factors to ce considereo in assuring tnat the lif ting of protective measures will not result in undue rist to puulic healta incluce tne following:
- a. Sampling anc monitoring of raciation anc evaluation of cata by tne Department of Healtn.
- b. Decontamination activities, inclucing waste disposal, uncer tne cirection of tne Department of Healtn, uncertaken by tne appropriate local agency cepenoing on tne metnoc utilizec,
- c. Security, inclucing police ana fire protection for affectec i areas -- will De providec ey State and local police, anu local fire agencies.
- d. Availabili ty of medical service -- will ce ascertained ey State anc local nealtn officials.
Iv-2 i 1
PART I, SECTION IV
- e. Availability of electric power and telephone cenaunications
-- will be ascertained oy Puolic Service Commission.
- f. Adequacy of foca anu water supply -- will De determined by
- Department of Agriculture and Markets and Department of Healtn.
- g. Opertoility of sanitary systems -- will be detennined by Department of Environmental Conservation.
- h. Availability of transportation -- will be determinea by local of fici al s.
- i. Availability of sources of neat -- will be ascertained ey-State Energy Office.
J. Condition and needs of tne affected population - will ce surveyed and determinea by Department of Social h n, a with assistance from the American tJational Red Lross.
Dissmenination to the public of information pertaining to I 2.
l recovery actions consnences af ter consideration has been given to the following factors:
- a. The status of t.te services anc conditions enumerated in the
, preceding portion of tnis plan. This includes information I- and guidance on metnoas tne public should employ to overcome 1 existing deficiencies, i.e., sources of emergency water supplies, restrictions on use of all non-canneo foodstuf fs, etc. 1
! b. The consistency of puolic announcements bet,.een all levels of l government. Tne Puolic Information Officers anc affected County Public Information Officers coordinate sucn releases witn each other oefore tney are issueo.
I c. Tne metnods oy wnicn tnese announcements are mace depenas in I
- i. large part on the existing situation and tne affectea areas.
Television and ccaniercial radio broadcasts are tne primary means of dissemination. Follow-up newspaper articles are i also useo. In special cases printea hancouts anc voice communications are used for Congregate Care Centers and similar f acili ties.
- 3. State and Federal assistance can ce mace availaole to assist affected counties in recovering from tne effects of a radiological emergency. q l
Article 2-B of the tJew YorX State Executive Ldw provides tnat .
wnen tne Governu ceclares a cisaster emergency for an affected -
area ne may direct any ana all agencies of trie State government to provide assistance under tne coordination of tne DPC. Sucn l State assistance may include: i
- a. utilizing, lending, or giving to political succivisions, witn or witnout compensation therefor, equipment, supplies, IV-3
) ,
1
)
l PART I, SECTION I'l f acilities, services of State personnel, ano otner resources, '
other than tne extension of credit;
- b. distributing medicine, medical supplies, foco ano otner consumaole supplies througn any puolic or private agency authorizec to dis;.ricute tne same;
- c. performing on public or private lancs temporary emergency i work essential for tne protection of puolic healta ana safety, clearing debris anc wrecXage, making emergency repairs to and temporary replacements of puolic f acilities of political suocivisions damageo or destroyec as a result of sucn cisaster; ano
- d. making suca otner use of tneir f acilities, equipment, supplies anc personnel as may De necessary. l Tne Cnief Executive officer of any affectea county wnicn nas neec of Federal aisaster assistance accumulates and suomits tnrougn SEHO Di strict of fice to tne Director, sEMO, data as requi reo oy Puolic Law v3-288 and appropriate regulations. This cata wi11 oe suomitted to tne Governor tnrougn the Recovery Committee ano tne Chairman of tne Disaster Preparedness Commission witn a recommendation as to wnether tne Governor saoulo request tne Presicent to declare an Emergency or Disaster as defined by Public Law 9 a dd. If sucn a request is made anc grantes, tne g Feceral assistance wnich will then be provided would be administered by the Director, SEMO, for the Recovery Committee, j appropriate State agencies and local governments in 4ccorcance with procecures adoptea for use in administering Fecerol aia for I
any other type of an emergency or cisaster declarea by tne Presicent.
In instances wnere a Presidential declaration is eitner not requestea or grantea, specific types of Feoeral assistancy may De proviced by incididual Federal agencies acting witnin :neir own statutory autnoriti es. The Governor may request sucn assistance, based on recommendations of tne Director of tne State Emergency Management Office and the Recovery Committee wnien will oe submitted tnrougn tne Cnairman of tne Di saster Preparedness Commi ssi on.
4 A radiation monitoring program for contaminetto areas will ce estaolisneo cy tne State Commissioner of Healtn. Thi s monitoring program may be long term depenaing upon tne type, levels, and extent of tne contamination. The monitoring aill also taxe into account tne nature of tne contamination as well as the area affected. Future activities affecting release of raciation (venting, etc. ) will also require monitoring. Otner State agencies wiil cooperate and assist tne Department of Healtn in ,
monitoring f or long term ef fects. Monitoring Programs initiateo during tne resconse phase will continue during recovery until acceptacle l evels are reacned.
Medical follow-up to monitor tne effects of radiation on tne public ano emergency worxers 4f ter tne incicent may ue estaolisnec, i f required. Currently, tne State Uepartment of IV-4 Rev. lu/no
PART I, SECTION I'/ .
Health conducts an ongoing study of selectea healtn statist 1cs for counties with anc without nuclear facilities as part of its epiceuiological prograin. This prograh. will De ennanced in the event of a radiological emergency.
All personnel monitoring equipment distrfouteo during tne emergency will be collected, assuring that exposure recoras for emergency worxers are complete.
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(N O T U S E D) 1 I
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HEW YORX STATE RADIOLOGICAL EMERGENCY PREPAREDNESS PLAN i
CONTENTS j PART II - SECTION I: PROCEDURES i Pace A. Plan Maintenance 1.0 Purpose A-1 2.0 Responsioiliti es A-1 3.0 Implementation A-1 B. Communications /Warni ng 1.0 In troauction B-1 2.0 Abbreviations 8-1 3.0 Initial Communication 8-1 l 4.0 Response Action - Unusual Event S-2
$.0 Response Action - Alert B-3 -
6.0 Response Action - Site Area Emergency B-4 7.0 Response Action - General Emergency B-5 ATTACHMENTS
- 2. Test Procecures for New York State Radiological Emergency Communications Systen (RECS) 3A. Radiological L-ergency Communications System (RECS)
Indian Point Unit 2 and Unit 3 i 3B. Radiological Emergency Communications System (RECS) l Nine Mile Point Nuclear Station (UMPNS) ana James A.
FitzPatricx Nuclear Power Plant (JAFNPP) 3C. Radiological Emergency Communications System (RECS)
Ginna Nuclear Power Station l
4 Radiological Emergencies, Healtn Departuent Notification List '
5 Radiological Emergency Notification Li st - Office of Disaster Preparedness, DMNA
- o. Radiological Emergency Notification Li st, Di strict Offices, State Emergency Management Office, DHNA
- 7. Robert E. dinna Nuclear Station, Notification Communication
- 8. 5D10 Communication Systems SA, Communications and Frequency Charts - Indian Point, Nine Mile Fo1nt anc Ginna
- 9. SEMO Coenunications ano Worning Section Emergency Notification
- 10. State Agencies Not1fication List 10A. Specialized Contact List for Radiological Emergency Information or Sucport 11 Ingestion EPZ Counties, Warning Points ano ECC Pnone Numoers
- 12. National Warning System in New York State
- 13. County EBS Stations (i) Rev. 10/85
4 t
I C. Public Infonaation:
Statement.of Purpose. C-1 1.0 .
C-1 2.0 Outies of tne Designateo State' Spokesperson C-2
! '3.0- Coordination of Public Infonnation Attachments 1
- 1. ~ Emergency Broadcast System Concept and Procecures
'd Enclosure 1. Activation of EBS 4
- Enclosure 4 - EBS Message Content Enclosure 3 - Sample EBS Messages 5
- 2. . Arrangements .ana Procedures for the Joint News.
1 Center' Enclosure Arrangements and Procecures d'
- 3. News Media Briefings 1 1
'4 News Release Content 1
- 6. -Rumor Control Procecures Enclosure ,1 - Rumor Control. Inquiry Log 4
5 Enclosure 2 - Rumor Control Reference Materials 6 Enclosure 3 - of f-Air Monitoring Log Sheet
~
- 6. Public Ecucation workplan 1 0-1 ' State. Onergency Operations Center 1.0 Pu rpose D-l' Location 0-1 {
2.0 D-1 3.0 Noti ficati on . 8
.Daergency Staff' D-2 4.0 .
J-4 6.0 Venicle ana Traffic Control D-2 6.0 - Entrance.ana Identi fication 0-3 7.0 ' Activation 0 8.0 Facilities Availaole at the EOC D-4 9.0 Pronicited Possessions D-4 10.0 Securi ty D-4 11.0 Operati oils ATTACHriENTS
- 1. State EOC - ASG
- d. State Emergency Operations Center
- 3. . State EOC Floor Plan 4 New York State Emergency Operations Room 0-2 District Onergency Operations Center D-b 1.u Purpose D-b 2.0 ' Location . D-o 3.0 Noti fication 0-u 4.0 Onergency Staf f J-o 5.0 Venicle and Traffic Control U-u 6.0 Entrance and ' Identification 0-0 7.0 Ac tiv a ti on 0-7 8.0 Facilities Available at tne EOC 0-7
- 9. 0 ' Pronioited Possessions D-o 10.0 Securi ty J-8 11.0 Operations liii
l ATTACHMENTS
- 1. Central District Office
- 2. Lake District Office
- 3. Southern District Office 4 Western Di strict Office
- 5. Typical District Emergency Operations Floor Plan E. Puolic Education 1.0 Pu rpose E-1 2.0 Responsibilities E-1 3.0 Impl ementati on E -1 F. Training, Drills and Exercises 1.0 Purpose F-1 2.0 Scope F-1 -
3.0 Responsibilities F-4 4.0 Implementation F-4 ATTACHMENTS Page
- 1. Public Officials Conferences (POCs)
- 2. Emergency Operations Simul.ation
- 3. NY State Radiological Training Courses Appropriate for Peacetime Radiological Dnergency Response 4 Federally sponsored Training Courses
- 5. Nuclear Facility Operator Courses
- 6. State / Local Government Training 14 atrix G. Radiological Exposure Control Procedures 1.0 Purpose G-1 2.0 Scope G-1 3.0 Personnel Exposure Guidance G-1 4.0 In struments u-2 5.0 Personnel Contamination Control G-J 6.0 Thyroid Exposure Control 3-7 ATTACHMENTS
- 1. Raciation Exposure Recora
- 2. Group Raciation Whole Body Exposure Recora
- 3. Energency Worker Exposure Control Procedures 4 Contamination Referral Sheet
- 5. Stancard coerating Procedure for Initial Issue, Accountability and Maintenance of Self-Reading Dosimeters for tne Radiological Energency Preparedness Program ;
- 6. Standard Operating Procedure for the Issue, Accountability and Maintenance of Per:aanent Recora Indirect Redcing Dosimetry )
1 (iii)
e Attactunant 2
.a . INDIAN POINT RADIOLOGICAL EMERGENCY PREPAREDNESS PLAN FOR WESTCHESTER COUNTY TABLE OF CONTENTS bELIl0N li i
PAGE D. -RECOVERY IV-1 l
- 1. Mission I V a. Snort term reentry operations IV-1
- o. Long term recovery operations IV-1
- 2. Recovery / Reentry Operations IV-1
- 3. Long Term Recovery IV-2 i
I
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I IV-i Rey, 4 - 9/d6
PART I
- SECTION IV D. RECOVERY
- 1. MISSION -
The mission of th,is section is to describe details of those short tem recovery / reentry and long-tem operations which are unique to l
radiological emergencies and to provide the County Executive with the capability of implementing the safe reentry to their places of residence and/or employment for the members of the general public who have been relocated under one of the protective action response options described in Part I,Section III C.8. l The recovery phase is the final stage of the Radiological Emergency Preparedness Plan. During recovery, a planned effort to restore the quality of life to the community is made. Operationally, recovery begins during the response phase and continues u'ntil restoration of community life has been completed.
Recovery operations for radiological emergencies consist of the I
~
following two operational parts:
- a. Short tem reentry operations:
Reentry from a radiological emergency shall commence only af ter all emergency initiating conditions have been neutralized and the threat to public health and safety from a release of radiation no longer exists. The following shdil be confimed before initiating reentry operations:
(1 ) Safe shutdown of nuclear facility.
(2) Radiological materials are under controlled confinement.
(3) Initiating physical phenomenon has been stabilized (e.g.,
pressure relief from geographical fault).
- b. Long tem recovery operations:
Aside from long-term radiation and medical monitoring programs, long-term recovery operations are generic to all emergencies. For details and guidelines for the implementation of long-term recovery operations, refer to the tiew York State Disaster Preparedness and Radiological Emergency Preparedness Plans.
- 2. RECOVERY /REEUTRY CPERATIONS Recovery / Reentry Operations will confom with the guidelines contained in the New York State Radiological Emergency Preparedness Plan and will include the following:
- a. Completion of radiation surveys by the County Department of Healtn (C00H) and the New York State Department of Health (HYSDCH) wnich indicate that contamination levels in an evacuated area are witnin IV-1 Rev. 3 - 9/84
acceptable contamination action limits established by the NY State
- Commissioner of Health. -In areas which have been contaminated, the CDOH and the NYSDOH may direct that reentry be allowed to all but specially cordoned-off subareas.
- b. Determination that a threat to public health as a consequence of a releas'e of radiation no longer exists.
- c. Assess and aftigate the effects of an evacuation on public health and sanitation within the evacuated areas.
- d. Completion of the CDOH and NYSDOH directed decontamination I activities, including waste disposal, with assistance of County Fire Departments with assistance from the U.S. Department of Energy.
- e. Notification to incoming traffic control check points of the areas for which reentry is authorized and the realignment of the traffic control perimeter.
- f. In conjunction with the State of New York, the Federal Government and the Nuclear Facility Operator, the preparation and is'suance of announcements to the consnunications media (e.g., newspapers, and radio and television stations) and to Reception / Congregate Care -
Centers specifying the areas which may be reentered.
- g. Continuation of security for evacuated areas, including those for which reentry has been approved, to prevent unauthorized entry and , ,
vandalism.
} h. Provision of transportation for those individuals who needed it during the evacuation,
- i. Distribution of drinking water and foodstuffs, if necessary, for the isolation of ingestion pathways and sources (see Part I, l
Section III C.8.
- j. Establishment of a long-term radiation monitoring program for any contaminated County areas.
- k. Establishment of a long-term medical monitoring program for both the general public and emergency response personnel of the County.
- 3. LONG-TERM RECOVERY The implementation of long-term recovery operations is the primary responsibility of the State of New York, and will conform with the guidelines contained in the New York State Radiological Emergency Preparedness and Disaster Preparedness Plans. The County will provide support to the State upon request. County staff will follow up for State.
IV-2 Rev. 3 - 9/84
Attachm:nt 3 (Oswego)
SECTION D D. RECOVERY
- 1. MISSION This section describes details of those short tem recovery / reentry and long tem recovery operations which are unique to radiological emergencies and to provide the County Director of Emergency Preparedness (CDEP) with the capability of implementing the safe reentry to their places of residence and/or employment, for the members of the general public who have been relocated under one of the protective action response options described in Sect on C.8.
i The Recovery phase is the final stage of the Radiological Emergency Preparedness.s Plan. During recovery, a planned effort is made to restore the quality of life to the community. ,
Operationally, recovery begins during the response phase and continues until restoration of community life has been completed.
Recovery operations for radiological emergencies consist of two
- operational parts; they are:
- a. Short Tem Reentry Operations:
l Reentry from a radiological emergency shall corrnence only a'f ter all emergency initiating conditions have been neutralized and the threat to puolic health and safety from a release of radiation no longer exists. The following shall be confimed before initiating reentry operations:
(1) Safe shutdown of nuclear facility.
(2) Radiological materials are under controlled confinement.
(3) Initiating physical phenomenon has been stabilized (e.g. , pressure relief from geographical faul t).
- b. Long Tem Recovery Operations:
Aside from long tem radiation and medical monitoring programs, long tem recovery operations are generic to all eme rgencies. For details and guidelines for the implementation of long term recovery enerations, refer to the New York State Radiological Emergency Preparedness Plans and New York State Disaster Preparedness P1an.
- 2. RECOVERY / REENTRY CPERATIONS Recovery / Reentry Operations will confom w1th the guidelines contained in the New York State Radiological Emergency Preparedness P1an and will include the following:
0 -1 Rev. 3 - 3/83
)
- a. The County Radiological Officer, the NF0, and the New York State Department of Health (NYSDOH) will coordinate on the levels of contamination in an evacuated area that are within acceptable contamination action limits. In areas which have been contaminated, the County Connissioner of Health (CCH) and the NYSDOH may direct that reentry be allowed to all but cordoned-off subareas. ,
- b. Determination that a threat to public health, as a consequence of a release of radiation, no longer exists.
- c. Assess and mitigate the effects of an evacuation on public health and sanitation within the evacuated areas.
- d. Completion of the CCH and NYSDOH directed decontamination activities, including waste disposal, undertaken by County Fire Departments with assistance f rom New York State.
e, Notification to incoming traf fic control check points of the areas for which reentry is authorized and the realignment of the traffic control perimeter.
- f. In conjunction with the State of New York, the federal government, and the nuclear facility operator, the preparation and issuance of announcements to the communications media (e.g., newspapers, and radio and television stations) and Congregate Care Centers o
specifying the areas which may be reentered.
- g. Continuation of security for evacuated areas, including those for which reentry has been approved, to prevent unauthorized entry and vandalism.
- h. Provision of transportation for those individuals who were assisted during the evacuation.
- i. Distribution of drinking water and foodstuffs, if necessary.
- j. Establishment of a long-tem radiation monitoring program for any contaminated County areas.
l
- k. Establishment of a long-tem medical monitoring program for both the general public and the county emergency response personnel of the County.
- 1. Establishment of a long tem recovery committee to coordinate the above activities with the State of New York.
- 3. LONG TERM RECOVERY The implementation of long term recovery operations is the primary responsibility of the State of New York, and will confom with the guidelines contained in the New York State Radiological Emergency Preparedness and Disaster Preparedness Plans.
D-2 Rev. 3 - 3/63 1
. - _ _ _ _ _ _ _ . - _ _ _ .__ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . -Q
Attachm:nt 4 (Monroe)
SECTION D D. RECOVERY l
- 1. MISSION .
This section describes details of those short term recovery / reentry and long term recovery operations which are unique to radiological emergencies and to provide the County Director, Office Emergency Preparedness (CDOEP) with the capability of implementing the saf e reentry to their places of residence and/or employment, for the members of the general public who have been relocated under one of the protective action response options described in Part I, Section-C.8.
Recovery is that period of time which follows the response actions to an emergency and extends to a time when community life, within the Emergency Response Pl anning Area (s) (ERF As), has been restored l to normal . Operationally, recovery begins during the response phase and continues until restoration of community 1ife has been compl eted. ,
Recovery operations for radiolacical emergencies consist of:
- a. Short Term or Reentry Operations: i Reentry from a radiological. emergency shall commence only af ter all emergency initiating conditions have been neutralized and the threat to public health and safety from a release of radiation no longer exists. The following shall be confirmed before initiating reentry operations:
(1 ) Safe shutdown of nuclear facility.
(2) Radiological materials are under controlled confinement.
(3) Initiating physical phenomenon has been stabilized (e.g., pressure relief from geographical f ault).
- b. Long Term Recovery Operations:
l Aside from 1ong term radiation and medical monitoring programs, long term recovery operations are generic to all emergencies. Fo r details and guidelines for the implementation of long term recovery operations, refer to the New York State Disaster Preparedness and Radiological Emergency Preparedness P1 ans.
- c. Cecisions to Relax Protective Measures:
The County Executive, in coordination with County Health Director; County Director, Office of Emergency Preparedness; the New York State Health Department; and RG&E will make the decision for reentry into evacuated areas.
l I-0-1 Rev. 5/87
Congregate Care centers will be notified when personnel may return ,
home. The Sheriff will control traffic returning to the evacuated )
a rea s. !
A Recovery plan has been prepared and maybe implemented when requi red. The plan'is maintained at CEOC under supervision of !
CDOEP. (See Part II, Section E).
- 2. RECOVERY / REENTRY OPERATIONS d
Recovery / Reentry Operations will conform with the guidelines contained in the New York State Radiological Emergency Preparedness Plan and will ' include the fc11owing:
- a. Completion of radiation surveys by the County Department of Health (CDOH) and the New York State Department of Health (NYSDOH) which indicate that contamination levels in an evacuated area are at least below the contamination action guides in Table 0-1. In areas which have been contaminated, the CDOH and the NYSDOH may direct that reentry be allowed to all but specifically cordoned-off subareas.
- b. Determination that a threat to public health, as a consequence of a release of radiation, no longer exists.
- c. Completion of the CDOH and NYSDOH directed decontamination activities, including waste disposal, undertaken by County Fire , ,
Departments. Assistance and guidance in this area will be
' obtained from the U.S. Department of Energy. ,
- d. Notification to incoming traffic control check points of the areas for which reer.try is authorized and the realignment of the traffic control perimeter.
- e. In conjunction with the State of New York, the Federal government, and the Nuclear Facility Operator, the preparation and issuance of announcements to the communications media (e.g., newspapers, and radio and television stations) and Reception / Congregate Care Centers specifying the areas which may be reentered.
- f. Continuation of security for evacuated areas, including those for which reentry has been approved, to prevent unauthorized entry and vandalism.
- g. Provision of transportation for those individuals who were assisted during the evacuation.
- h. Distribution of drinking water and foodstuf fs, if necessary, for the isolation of ingestion pathways and sources (see Part I, Section C.8. ).
- i. Establishment of a long-term radiation monitoring program for any contaminated county areas.
I-0-2 Rev. 3 - 3/83
- - _ _ _ _ = _ . - _ _ _ - _ _ _ _ _ _ - -
4 MONROE COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN TABLE D-1 SURFACE CONTAMINATION ACTION GUIDES contamination Level s Usec in Estaolisning A Contamination Zone Airborne Contamination Direct Keacing Surface Transferrable Surface Type Radiation
- in Microcuries per/cu m Contamination dpm/100 sq. cm.
Alpna 2 x 10-o 300 cpm /100 sq. cm. 30 i Beta, Gamma 3 x 10-4 0.25 mrad / hour .1000 Contamination Guide for Skin Surfaces Di rect Survey Transferable (smear)
Skin Surface Alpha in dpm/100 sq. cm. Beta, Gmmna Al oha , Beta , Gam:
General Body 150 Non-detectable, i .e, Non-detectacle, i.e...
' ' including hands) -less than 0.05 mrad / hour less than 0.05 mrad /ho-Contaminated Guide for Clothing Di rect Survey Transferable in dpm/100 s Su rf ace Aloha in dom /100 sq. cm. Beta, Gamma Al pha, Beta , Gamm Shoes . 300 0.4. mrad /hou r . 30 10C Other Clothing 150 0.25 mrad / hour -- --
' *Measurements made with:
Alpha - Eberline- PAC 1 SA or equivalent Bota, Gamma - CDV 700 G-M Survey Meter - Window open window thickness 30 mg/sq. cm. (0-50 MR per hour) 1-0-3 Rev. 4 - 10/84
J. Establishment of a long-tenn medical monitoring program for both the general public and. emergency response personnel of the County.
'3. LONG TERM RECOVERY The implementation of long term recovery operations is the primary.
responsibility of 'the State.of New York, and will conform with the guidelines contained in the New York State Radiological Emergency and Disaster Preparedness Plans.
1 I-0-4 Rev. 3 - 3/83
Attachment 5 OPIP 3.10.1 Page 1 of 9 [
OPIP 3.10.1 RECOVERY / REENTRY 1.0 PURPOSE This procedure provides (1) decision-making guidance for the initiation of recovery operations including, but not limited to, the implementation of evacuee re-entry into evacuated areas and (2) guidance for the formation and operation of the Recovery Action Committee.
2.0 RESPONSIBILITY 2.1 The Director of Local Response is responsible for initiating and approving recovery /re-entry operation.
2.2 The Manager of Local Response is responsible for -
implementing this procedure and is the Chairman of the Recovery Action Committee.
3.0 PRECAUTIONS Special sit'uations requiring temporary re-entry require implementation of Section 5.5.
4.0 PREREQUISITES The prerequisites for the formation of the Recovery Action Committee are:
4.1 Protective action recommendations have been implemented l in response to an accident.
4.2 Conditions at the SNPS site have been declared stable and safe by the SNPS Response Manager / Emergency Director.
4.3 No further releases of radioactivity having offsite con-sequences are expected, as determined by the SNPS Response Manager / Emergency Director.
4.4 Radiological conditions in the affected area have been determined by the Radiation Health Coordinator to be stabilized.
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OPIP 3.10.1 Page 2 of 9 q 5.0 ACTIONS, 5.1 Recovery Action Committee The Director of Local Response directs the formation of-the Recovery Action Committee. This committee is convened prior to recovery /re-entry to gather information to assist decision making regarding recoven/re-entry and to imple-ment re-entry upon authorization 1by the Director of Local Response.
5 . L.1 -Composition of the Committee The Director of Local Response will ensure that the Recovery Action Committee is staffed by the following LERO members: .
l a. Manager of Local Response - Chairman
- b. Health-Services Coordinator
- c. Evacuation Coordinator
- d. Support Services Coordinator
- e. Coordinator of Public Information
- f. Radiation Health Coordinator
- g. Nuclear Engineer
- h. Others, see Section 5.1.2 5.1.2 Additional committee members may participate if available. They are:
- a. FEMA Representative
- b. DOE Rep'resentative
- c. EPA Representative
- d. State Representative
- e. County Representative 5.2 Tasks and assigned responsibilities of the Recovery Action Committee members are as follows:
Task Responsible Individual
- a. Administration Manager of Local Response
- b. Emergency Status Nuclear Engineer !
l Evaluation
- c. Air Monitoring Radiation Health Coordinator l Radiation Health Coordinator
- d. Ingestion Pathway Sampling
- e. Environmental Media Radiation Health Coordinator Survey
- f. Laboratory Analyses Radiation Health Coordinator
- g. Re-entry Area Radiation Health Coordinator Identification Rev. 5
l OPIP 3.10.1 Page 3 of 9 i
Task Responsible Individual i
- h. Public Dose Commitment Radiation Health Coordinator
- i. Environmental Health Services Coordinator Decontamination J. Transportation Evacuation Coordinator
- k. Traffic Control Evacuation Coordinator E 1. Communications Manager of Local Response
- m. Security Support Services Coordinator
- n. Public Information Coordinator of Public .
Information l l 5.2.1 The Recovery &ction Committee will perform the I actions identified in Sections 5.3 through 5.7 of J'^ this procedure as appropriate.
5.3 Initial Recovery /Re-Entry Actions .
5.3.1 The Nuclear Engineer will review the plant status and ensure that the plant is stable, no !
significant releases occurring, and other requirements for entering the recovery phase are.
satisfied.
5.3.2 The Radiation Health Coordinator will:
- a. Direct that surveys of the affected area be initiated. These surveys will include the following as appropriate:
- 1. Air Monitoring
- 2. Ingestion Pathway Sampling - Surface water (including lakes, ponds, and sumps), potable water, milk, crops (vegetables, fruit), forage, fin fish, shell fish
- 3. Enviror. mental Survey - Ground , equipment ,
structures, vehicles
- b. An area vill be considered contaminated if:
- 1. Evaluation of environmental monitoring l results, plant data, and/or laboratory analysis of isotopes shows that direct constant exposure and inhalation of resuspended particulate for one year (allowing for radioactive decay) will result in a dose greater than 500 mR to wholebody or equivalent to any organ.
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OPIP 3.10.1 Page 4 of 9
- 2. Applicable models for this calculation l are contained in Regulatory Guide 1.109 and WASH 1400.
- 3. Also compare results with Attachment 1 of l OPIP 3.6.6 for ingestion pathway considerations.
- c. Advise the Manager of Local Response as to the results of the surveys and the indicated actions.
5.3.3 The Manager of Local Response will convene the Recovery Action Committee to discuss the status of taska enumerated in Section 5.2 in preparation for re-entry. .
5.3.4 The Manager of Local Response will indicate to the Director of Local Response when all facets of the re-entry operation are determined to be ready.
5.3.5 The Director of Local Response will authorize the initiation of the re-entry operation.
5.3.6 The Support Services Coordinator advises the American Red Cross Coordinator on the details of r:he re-entry operation.
5.3.7 All Recovery Action Committee coordinators notify the members of the response organization that re-entry operations are initiated.
5.3.8 Either the Radiation Health Coordinator or the U.S. Environmental Protection Agency Office of Radiation Programs in accordance with their FRMAP assessment functions estimates total population exposure.
5.4 Re-Entry - Permanent (Note: Re-Entry / Temporary is j detailed in Section 5.5)
The Recovery Action Committee gives consideration to the number of people that have been evacuated, the transpor-cation needs (including special), and the logistics at l
the Congregate Care Centers. Re-entry actions may vary depending upon the specific emergency conditions.
Following are the four major re-entry scenarios : l 5.4.1 The radiological emergency involved an evacuation but did not involve a radiological release. The Manager of Local Response will direct the appro-priate Recovery Action Committee members to ini-tiate these tasks:
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OPIP 3.10.1 Page 5 of 9
- a. Determine that all utilities are functioning in the evacuated area.
- b. Provide transportation for those who required it during evacuation.
- c. Inform the public of LERO recommendations to re-enter the evacuated areas.
5.4.2 The radiological 1' emergency involved an evacuation and a radiological release; however, no con-tamination is identified. The Manager of Local Response directs the' appropriate coordinators to initiate these tasks:
i
- a. Determine that all utilities are functioning . !
in the evacuated area.
- b. Provide transportation for those who required it during evacuation.
- c. Inform the public of LERO recommendations to re-enter the evacuated areas.
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- d. Place TLDs in. predetermined, strategic locations throughout the evacuated area consistent with the locations utilized Enr SNPS as described in EPIP 2-6 and 2-15.
Determine exposure of these units as frequently as the results require.
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- e. Depending on the elapsed time that the _
evacuees had been absent, emergency food provisions may be supplied in cooperation !
with the American Red Cross mobile feeding facilities and the U.S. Department of-Agriculture (USDA).
5.4.3 The radiological emergency involved evacuation 1 and a radiological release where the evacuated !
area or a portion of it is determined to be contaminated. The Manager of Local Response ensures that the following tasks are performed:
- a. Continue radiological surveys (per Section 5.3) and plot the data on a map so that those portions of the evacuated area that are contaminated are accurately defined. These areas are not recommended for re-entry.
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OPIP 3.10.1 Page 6 of 9
- b. Around those contaminated areas (as defined in the preceding paragraph), create a buffer zone with readily recognized physical boundaries and place personnel so that the returning population will be advised of the possible exposure. EBS messages will also advise the public of the physical boundaries of these areas.
- c. Survey the contaminated area (s) as much as possible with consideration of the degree of contamination and the safety of the Radio-logical Assessment Teams to determine the means of decontamination The decision with regard toor this otherarea disp s) (osition. is made by the Director of Local Response. .
- d. Solid radioactive wastes from decontamination operations are collected and safely trans-ported from the affected areas to SNPS for disposal.
Liquid wastes will be sampled for laboratory analysis. The Radiation Health Coordinator will evaluate the isotopic activity found and ensure that it is below acceptable levels before discharge to sewers. Discuss this action with representatives from the EPA if l they are participating in the Recovery Action Committee
- e. Based on the results of laboratory analyses of food samples taken from the af fected area, j the Radiation Health Coordinator makes a !
comprehensive evaluation of the possible need {
to transport drinking water or food stuffs j I
into that area.
- f. For areas not contaminated, proceed as i described in Sections 5.4.2a-e.
5.4.4 The radiological emergency involved sheltering with or without a radiological release; however, no contamination is identified. The Manager of Local Response directs the appropriate coordinators to initiate these tasks:
I Rev. 5 i l
OPIP 3.10.1 Page 7 of 9
- a. Inform the public of the LERO recommendation to discontinue sheltering actions and return
. to normal activities.
- b. Place TLDs in predetermined, strategic locations throughout the sheltered area consistent with the locations utilized by SNPS as described in EPIPs 2-6 and 2-15.
Determine exposure of these units as frequently as the results require.
5.4.5 The radiological emergency involved sheltering and a radiological release; a portion of the sheltered area has been determined to be contaminated. The Manager of Local Response directs the appropriate coordinators to initiate these tasks: ,
- a. Continue radiological surveys and determine contaminated areas per Section 5.3.2. Plot the data on a map so that those portions of the sheltered area that are contaminated are accurately defined.
- b. Based upon decay patterns from the isotopic analysis and dose reduction factor offered by i shelter from surface contamination, determine -
if evacuation or continued sheltering is ;
appropriate for the affected areas. ,
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- c. If evacuation is recommended, ensure that all l evacuated people and vehicles are monitored.
Provide transportation and sheltering as necessary. If sheltering is recommended for an extended duration, it may be necessary to provide emergency food supplies. {
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- d. Continue with steps 5.4.3b-f as appropriate.
5.4.6 The Recovery Action Committee will meet periodi- I cally, as required by existing conditions, until the evacuated area is returned to normal. The committee will consider problems such as addi-tional areas to be re-entered, the situation of evacuees not yet permitted re-entry, and the mitigation of offsite radiological consequences.
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OPIP 3.10.1 Page 8 of 9 l
5.7 Re-Entry - Temporary There are situations wherein the evacuated zone must be re-entered by civilians either during the radiological emergency or after it--when the area has not been radio-Such situations may logically cleared for re-entry.
include the need to turn off/on utilities, attend to livestock, fight a fire, or other matters of a nature.
In these instances, the individual (s) pressing seeking temporary re-entry contact (s) the Health Services Coor-dinator at the Local Emergency Response Organization at
. the Emergency Operations Center in Brentwood.
Use the following procedure for these situations:
5.7.1 The Health Services Coordinator considers the l request to re-enter the evacuated area and makes his decision based on the latest radiological'
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surveys, the circumstances involved, and emergency dose limitations consistent with the Environmental Protection Agency Protective Action Guidelines for the general public.
CAUTION PERMISSION IS TO BE AUTHORIZED ONLY FOR A SPECIFIC DESTINATION AND TIME PERIOD.
The individual will be directed to report to a l 5.7.2 staging area near the destination. The staging area will be advised of the special re-entry permission.
5.7.3 The re-entering individual is assigned an escort I with a vehicle to provide transportation and radiological monitoring capability.
5.7.4 The re-entering person is assigned personnel I dosimetry, if necessary.
5.7.5 The group may not deviate from the designated I destination nor the allotted time.
5.7.6 Upon exit, the individuals report to the Brentwood i Emergency Worker Decontamination facility to be I checked.
Rev. 5 l
d OPIP 3.10.1 Page 9 of 9 5.3 The Director of Local Response may halt or reverse the recovery /re-entry operation when a change of conditions l warrants such actions. I i
6.0 REFERENCES
6 .1 - OPIP 3.6.1, Plume. Exposure Pathway Protective Action Recommendations 6.2 OPIP 3.6.6, Ingestion Pathway Protective Actions l Rev. 5
1 Attachmtnt 6 l
New York State Radiological Emergency Preparedness Plan PART II - SECTION I - Procedure C C. Public Information 1.0 STATEMENT OF PURPOSE Tne lead spoKesperson for tne release of information to tne puolic and tne press during a radiological emergency for tne State of New YurK shall De designated oy tne State Commissioner of Healtn. This 1 person will act as Puolic Information Officer (PIO) for radiological emergencies to ensure tne accurate and timely release of infomation to tne puolic and tne med1a concerning puolic protective action recommendations and state emergency response activities.
2.0 DUTIES OF THE DESIGNATED STATE SPCKESPERSON .
Tne State Puolic Information Officer (PIO) shall be responsible for tne following activities. .
2.1 Identification, recruitment and training of ouolic information starr: ine state vio wi 4 6 laentity rro:n among State agency puolic
! inrarmat1on of ficers interested and capaole incivicuals to serve as assistant State puolic information officers for radiological emergency preparedness.
The State PIO will provice training / orientation sessions for the assistant puolic information officers at least once eacn year, ana will provice tnem also witn complete copies of necessary state ano local puolic information/ education procecures, related maps ano educational materials on nuclear emerpncy planning.
2.2 Exerci se s/ Drill s: Tne State PIO ano assistant P10s snali participate in all preparedness exercises and snall ce responsible for ensuring tnat State puolic infor nation policies and procecures are appropriately ano accurately carried out.
2.3 Liaison with Local / Utility PI0s: The State PIO shall ce tne State contact point f or al t county ano utility public inforiaation officers on matters relating to eraergency preparedness public information.
He/sne will ensure county / utility PI0s are kept informed of Stata :
PIO activities, will participate in determination of site and l equipment for all near-site news centers, and will seem to ensure consistency and cooperation among tne related puolic information programs.
2.4 Tr ai ni rq- Tne State PIO snali provide to county Plus, as necessery, training in radiological emergency puolic information. Traini ng sessions snali inciace overview of plans, FIO responslutlities during exercises /emergenc1es, coordination of news releases, emergency broadcast system messages, equipment and staffing needs, anc ongoing puolic ecucation responsibilities anc projects.
2.o Public Education: Worxing witn county /utilitj FIos, the State PIO snas I cevelop and implement programs to raise public consciousness of ract ological emergency preparedness. These activities incluce, C -1 Rev. 10/03
but are not limited to: oriefings for news ecitors/ reporters; development and dissemination of germane booklets, brochures, and news releases; participation in " town meetings"; development of radio /TV public service announcements. Information snall be 4 disseminated to tne puolic at least once ennually. Suen infomation shall include educational informat1on.on radiation, contact numoer or place for additional information, evacuation routes and corresponding reception and/or congregate care centers, sheltering, respiratory protection, the special needs of tne nancicappeo ano a transient emergency information program.
2.6 Annual Press Briefina: Tne State PIO and assistant PI0s will conauct a ortering od New York's Radiological Emergency Preparedness P1 an for the media at least annually.
2.7 Plan Deveicoment: The State PIO shall review tne public inrunaation/eoucation portions of the State plan at least annually and make any necessary revisions and/or adoitions.
3.0 COORDINATION OF PUBLIC INFORMTION To ensure tne prompt dissemination of pertinent, credible anc reliable infonnation to the press and tne public during a radiological emergency, State, county and utility spokespersons snall coordinate information snaring and release.
3.1 DESIGNATION OF NEAR-SITE NEWS CENTERS .
To facilitate coercination of information release, eacn site snali nave a designatea near-site joint news center. Ini s news center snall oe tne sole site from whica information concerning tne emergency shall be issued to tne press and tne puolic oy cesignated spoKespersons (PI0s) for tne State, tne affectea countyties) and tne af fected utility.
Eacn near-site joint news center snall ce equip::ec witn acequate coununications equipment and proauction equipment to a11ow timely collection, writing and distribution of news materials and regular media oriefings.
3.2 INFORMATION RELEASE The State PIO sna11 release, on oenalf of anu witn ene approval of tne State Disaster Preparedness Commission Chairman anc tne State Healtn Comt ssioner, the foilow1ng general types of infomation curing en emergency:
e Announcement of State receipt of emergency notificat1cn oy the affecteo utility; e Announcement of activities of State emergency operations center; e Regular and timely upcates of State activities, determinations anc policies reldted to tne emergency; e State assessment of projected doses and/or cose rates related to j any release uf raciation; )
C-2 Rev. 10/8b l
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e State determination of any protective action ano tne basis for tnese determinations; and e Regular and timely updates of State recovery / reentry activities.
3.3 COORDINATION OF INFORMATION RELEASE WITH COUNTY /U11LIiY PI0s:
The State PIO shall coordinate infur: nation release witn county and utility PIDs.
Recordkeeping: The State PIO shall keep records of information releaseo to tne press and tne public during ar ;xercise or emergency, and snall maintain a log of telepnone inquiries related to any exercise or emergency.
3.4 RUMOR CONTROL Statement of
Purpose:
To ensure thet inisinformation and rumors in a radiological emergency are kept to a minimum, tne State PIO snall, in conjunction with county and utility FI0s, maintain a rumor control system capaole of responding to factual inquiries and ,
previoing input to wnien suosequent news releases and/or press i statements can be addresseo.
Information Monitoring: Information broadcast over electronic meule or printea in tne print media snall be monitored to intercept any inaccurate inforestion and provide corrective material.
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Attachment 7 1 .
New York State Radiological 1 Emergency Preparedness Plan i
PART II - Section I - Procedure K l Table of Contents 1
i K. RADIOLOGICAL INGESTION EXPOSURE l
K-1 1.0 In troduction 2.0 Concept of Operations K-3 3.0 Alert and Notification K-4 4.0 Command and Contro1 Responsibilities K-5 5.0 Organizational Responsibilities K-6 ,
6.0 Field Operation Responsibilities K-7 i 7.0 Public Information Responsibilities K-8 i
ATTAC hMEN TS 1 tbclear Power Plants with Emergency Planning Zones Impacting on New York State K-9 ;
2 Pathways for External & Internal Exposure of Man From Airborne and Liquid Releases of Radioactive Effluents K -11 3a Derived Response Le vels f or Emergency P AG K-13 3b Derived Response Levels for Preventive PAG K-14 4 Alert & Notification Procedure - Indian Point K-15 i
5 Alert & tbtification Procedure - Nine Mile Point K-17 I
- 6. Alert & Notification Procedure - Ginna K-19 7 *nformatio n Flow fo r Inges tio n Pathway K-21 j 8 Tasks / Responsibilities f or *ngestin Pathway Planning K-2 , )
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New York State Radiological Emergency Preparedness Plan PART II - Sec. I K. RADIOLOGICAL IiiGESTION EXPOSURE PROCEDURE
1.0 INTRODUCTION
The purpose of this procedure is to establish a framework for the responsibilities of the New York State Disaster Preparedness Cocmission (DPC) with respect to the radiological ingestion exposure pathway and -
provides response for emergencies at commercial nuclear power plants, and identifies State agency emergency management readiness, response and recovery activities.
The contents of this document reflect the current policies and criteria -
associated with the radiological ingestion exposure pathway from the operating nuclear power plants located within New York State, as well as those that border the State, and therefore require an ingestion exposure pathway component for response. Attachment 1 depicts operating nuclear power plants for which this procedur,e has been developed.
The information identified in this procedure relies upon the ability of the DPC, through appropriate State agencies, to accomplish the following:
e activate appropriate State agencies' field staff; collect, transport and analyze ingestion pathway samples; I e e assess and evaluate the potential impact of ingestion pathway contamination; e alert local governments of the emergency and the potential for adverse public health impact.
The DPC is responsible to the Governor for the implementation of the radiological emergency preparedness program. This procedure calls for l State agency coordination among federal anc local governments, the !
nuclear facility operators, and the private sector for information, technical assistance or resources as necessary.
In response to an ingestion pathway incident, State, County and Federal governments will all be responsible for specific roles ano activities in a coordinated response. The State's role, which is built around existing regulatory authority and ongoing programs, incluces; e assessment of impact e evaluation of response options '
e implementation of necessary response actions The role of the Federal government, which would be assisting the State through Department of Energy, the Federal Radiological llonitoring and Assistance Plan, and the Federal Radiological Emergency Preparedness Plan would include:
K -1 dev. 8/87
e technical resource supplement e personnel e monitoring and assessment e laboratories
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The impacted county (ies) would be called upon to provide the following support:
o maintenance of ongoing monitoring programs (i.e., public water supply) e provide information on local agricultural activities e guiding State / Federal responders e support State response for ingestion concerns l
The licensee which owns the affected plant would continue to work to stabilize and return the plant to pre-accident conditions. Offsite monitoring weald also be supplied by the utility to supplement the l county / State resources.
When considering ingestion pathway responses and actions, short term and !
long term aspects of this response must be kept in mind. Short term ,
consideration would be given to establishing intensive monitoring, sampling and evaluation programs aimed at preventing contamination of ingestion pathways or minimizing consumption of contaminated foodstuffs or water. Long term considerations will include restoration of contaminated areas, and dealing with the economic impacts of an ingestion 1
pathway accident.
Technical Federal support is an integral part of New York State's ingestion pathway response. In the early hours or a radiological emergency, support will be provided through the U.S. Department of Energy's Radiological Assistance Plan (RAP). Technical expertise with sophisticated monitoring, sampling and laboratory analysis capability will be provided from the Brookhaven kea Office with USDOE and Brookhaven National Laboratory staff. Advance RAP teams are also availble from the Knolls Atomic Power Laboratory, West Valley Demonstration Project, Environmental Measurements Laboratory and the Pittsburgh Naval Laboratory. USDOE will provide sophisticr_ted aerial monitoring capability and plume modeling using ARAC. USDOE resources from Region I will be supplemented as required from other DOE fccilit'ies including the ha tional Laboratories. If the emergency concitions-warrant, the Federal Radiological Monitoring and Assessment Plan (FRhAP) will be implemented to obtain Federal interagency technical support.
FRMAP is administered oy USDOE.
Sampling teams, which will De fielded by NYS in response to ingestion concerns can be comprisea of representatives from the Departments of Health Agriculture ano arkets, v
Environmental Conservation.
Transportation, and local Cooperative Extension /USDA, depending upon the situation. 00T will provice the vehicles f or the transport of the sampling teams to the necessary locations, and will coordinate transportation of sacoles to Albany for analysis at the DOH labs.
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Each State agency whic, nas a response in ingestion pathway will use ;
existing agency precedures based upon the responsibilities defined in the l NYS REP Plan.
K-2 Rev. 8/87
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2.0 CONCEPT OF OPERATIONS The concept for this procedure stems from those existing governmental and utility responsibilities currently identified within this plan. The procedures contained in the REPP form the basis for State response to an ingestion exposure pathway incident. fbwever, unlike the plume exposure pathway, the radiological exposure concerns from the ingestion pathway are not as direct and may not require immediate protective actions. The information contained within this procedure centers around these ingestion pathways: (see Attachment 2) . ,
l Milk Foodstuffs Animal feeds Water From an emergency management and public health perspective, the milk pathway is of primary concern. The radioactive materials would enter the human food chain by the following steps: deposition of radioactive material to pasture lanc, ingestion and concentration of this radioactive ,
material by lactating animals resulting in contamination in milk, and consumption and further concentration by the population. This two-step '
concentration of radioactive materials plus the short time period between' deposition and ingestion by the public, and the potential detrimental impact upon children anc infants who are most sensitive to the biological effects of radiation are what make the milk pathway a critical concern.
For potential ingestion exposure pathways, State agencies have preparec procedures which would be implemented under the direction of the Chairman of the DPC who is designated as the lead agent on behalf of the Governo r . Appropriate State agency procedures contain information for sampling, detecting the presence of contamination, analyzing and evaluating of the problem, and recommending and implementing protective actions.
Protective response measures associated with the ingestion exposure patnway incluce preventive protective actions anc emergency protective actions.
e Preventive protective actions are those employea to prevent or reduce the concentration of radioactivity on agricultural products, l with minimal impact resulting on the fooo supply, o Emergency protective actions are those taken by government officials to remove milk, water anc f ooc prooucts f rom puolic and animal consumption :nrougn emoargo or tnroug disposition. l Response levels for preventive anc emergency Protective Actions buices i are cased on U.S. Fooc anc ; rug Ministration guicance, shown in Attachment 3 (USFDA P AG'si .
i Notification and nf:rmati:n; anc coercination of agency Response and j Recovery Procedure s.
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Coordination and communication are necessary to effectively implement ingestion exposure protective actions. New York State, through the State Emergency Management Office (SEh0) system, will coordinate all operational and informational requirements with local governments and bordering states arid provinces. SEMO will insure that this information is coordinated among appropriate officials as necessary in accordance with the State Disaster Preparedness Plan and the REPP. In addition, State agencies, as appropriate, will maintain periodic contact with counterparts in contiguous states and provinces to provide specific details pursuant to respective responsibilities.
3.0 ALERT AND NOTIFICATION Procedures for the alert and notification of State agencies for a nuclear power plant accident are contained in Part III, Section 1 of this plan, and will be used as appropriate for mobilization of State agencies for the ingestion exposure pathway response. This ingestion procedure deals '
with the responsibilities of State Government for alert and notification to local government and other appropriate officials in the event of an .
ingestion pathway concern.,
Upon confirmation by Radiological Accident Assessment personnel that radiological ingestion is of concern, SEMO will implement procedures for alert and notification of all potentially affected local governments.
State radiological assessment personnel will provide a listing of those counties within the actual or potentially affected areas and continual }
o status updates. SEMO will notify: Radiological Emergency Preparedness s g Group, appropriate State agencies who send representatives to the State and District EOC's, and potentially affected local governments. In addition, notification will be made to other states and provinces (as appropriate) and the Federal Emergency Management Agency who will in turn notify appropriate Federal agencies and Canadian officials.
l l Attachments 4, 5, and 6 comprise SEM0's procecures for alert and notification, by operating nuclear power plant site, for the ingestion exposure pathway.
i In the event tnat expeditious notification to county emergency management !
offices is required, SEMO will use the National Warning System (NAWAS). l NAWAS provides the capability for simultaneous notification of local governments on the circuit.
The alert and notification procedures, as defined for the three operating i
)
nuclear power plant sites in New York, can be expanded to cover all NYS, or different areas of NYS, as the situation warrants. Subsecuent to identification of the area of imoact, other SEMO District Offices can use similar notification procecures in that area.
As a means of augmenting alert and notification for an incident, State agencies will emoloy their respective communications systems, such as the Division of State Police 's :nformation System, Departments of Transportation and Envir:nnental Conservation Radio Systems, etc.
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4.0 C0 WAND AND CONTROL Resp 0NSIBILITIES l In the event of a nuclear power plant incident, Comrand and Control Operations are managed from the State EOC in Albany. From this location, the Chairman of the CPC as the Governor's designee and other State officials direct the emergency management response and recovery operations. The Command Room is augmented by State and District EOC operations, radiological assessment and evaluation, communications and public information. These components provide the necessary information to Comnand Room personnel to f acilitate the State's decision making.
From the Command Room decisions concerning State response and recovery are provided. Local officials will be informed of all decisions to insure continuity of the operation.
The objectives of the Command Room operation are:
e to assess the magnitude of the situation; e define radiological impact; e implement procedures to respond to the situation; e implement protective measures; -
e initiate public information procecures; e coordinate all actions with appropriate local government officials. .
With respect to a plume exposure pathway response, Command Room personnel use the existing " Executive Hotlines", which are dedicated landlines, to coordinate emergency management actions with County Executive personnel.
In the event of an ingestion exposure pathway concern, this procedure l will continue with those counties on this circuit. For other counties potentially impacted in this pathway, Command Room personnel will direct SEMO to coordinate the dissemination of information. This will be done through SEMO District Offices. Attachment 7 depicts Command Room informational flow and coordination responsibilities for the ingestion exposure pathway.
The f ollowing is a checklist of Command Rocom activities which will be completed in the event of an ingestion exposure pathway incident:
- assess the magnituce of the ingestion pathway concern;
- determine appropriate protective actions to be employed to protect public health, property and the environment;
- implement protective actions or measures as required in coordination with local officials;
- coercinate tne dissemination of puolic information througn the Joint l
- ews Canter (wnere on exists); .
- keep local officials informed of protective action recomencations .I I
(PARS), the implementation of PARS and puolic information;
- determine the requirement for Federal resources that may be necessary to augment the State efforts pursuant to the Federal Radiological I Emergency Response Plan, the Federal radiological Monitoring and Assessment Plan, or the U.S. Department of Energy's Radiological As sistance Plan; K-5 Rev. 8/S7
. ._ ____ - ___ a
- provide periodic briefings to the Governor from Chairman of the DPC on the status and projection of the incident and provide recommendation on the requirement for a State Disaster Emergency
' Declaration pursuant to kticle 2-B of State Executive Law;
- as the incident progresses, evaluate protective actions and adjustment as necessary in the interest of public safety; -
- provide periodic updates on the status of the management of the incident to all components in the State EOC;
- manage the implementation of short and long term State recovery action s;-
- insure that all information is coordinated with other bordering states and provinces, Federal authorities and the nuclear facility operator.,
5.0 ORGANIZATIONAL RESP 0NSIBILITIES In the event of a radiological ingestion exposure pathway accident, State ,
agencies will provide the necessary resources to protect public health, '
property and the environment. State agencies involved in the ingestion exposure pathway response will use their own specific agency procecures.
Activities will be coordinated by SEHO at the State EOC and in the appropriate District EOC. Attachment 8 is a matrix of State /gency responsibilities. The following is a listing of the State Agency. j responsibilities associated with the radiological ingestion pathway: ;
- a. Deoartment of Health l
As the State's lead agency for the protection of public health for radiological incidents, DOH will:
e collect samples of potable water, soil and vegetation; e take environmental radiation measurement s; e provide laboratory analysis for samples taken in the field; e recommeno protective actions; e assist in the coordination and delivery of public information relating to protective actions implemented; e serve as the f ocal point in the State EOC for the analysis ano assessment of radiological information; e provide technical training as required.
- b. Ceoartment of 'criculture and Markets e maintain an inventory of dairy f arms, foco processing plants ano l stock f arms; ,
e collect samples of milk, produce, and animal f eeds; !
e recommend protective action s; e imolement protective actions as apprograite for milk produce anc animal feecs; ;
e embargo procuce and milk in contaminated areas; j e restrict use of animal feeds; e provide information and direction to all f armers within the affected areas; K-6 Rev. S/87
=
e assist in the development and release of public information; e coordinate with appropriate local agencies (Cooperative Extension, USDA) for necessary resources; e provide technical training as required.
- c. Decartment of Environmental Conservation e collect samples of environmental flora and fauna; e using agency resources, transport samples to laboratory f acilitiec; l e implement protective actions with respect to environmental flora and fauna; e assist in public information for protective actions; e support communications using agency resources.
- d. Division of State Police e provide division resources to support communications; e expedite the delivery of samples for laboratory analysis e maintain access control points.
- e. Decartment of Transportation e act as transportation coordinator for collection and transportation of samples to appropriate laboratories; e provide department resources for delivery of samples to appropriate laboratory for analysis; e assist in the maintenance of access control points; e support communications with agency resources; e provide resources for transporting ingestion field teams.
- f. State Emercency Manacement Office e provide coordination for resp 04se and recovery activities for the State ECC and the 5D10 District Offices; e provide notification to Federal, State and local governments; e assist the State DOH in radiological assessment at tne State ELC; e provide training and awareness to State anc local officials; e coorcinate the celivery and implementation of resources to sustain operatinal requirements; e support communications with agency resources.
- g. Radiolecical Emercency Preparedness Group j 1
e coorcinate the State's Puolic Information Program; e assist in the implementation of protective actions; e coercinate the overall ingestion pathway planning components of the State's procecure; e ;rovice liaison to appropriate Federal agencies; e provide training and awareness to State and local officials.
6.0 FIELD CPERAT*0N RESPONS:SIL: TIES !
County Emergency Operations Centers will coordinate information and requests for assistance with their respective representative in tne SEMO District Office.
K-7 Rev. S/87
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7.0 PUBLIC INFORt1ATION RESP 0NSIBILITIES 1
The potential magnitude and impact of an ingestion exposure pathway 1 inc ent requires an extensive public alert and notification capability on e.e part of State and local government. There is a requirement for notification to the general public, agricultural industry, retail and wholesale food and commodity distributors, industrial representatives and other appropriate entities.
Procedures exist in the State REPP for Public Information during a nuclear power plant incident. Through the use of a Joint fews Center (JflC), wb'.3 is located near to the potentially affected area, local, State, Fs it.:al and utility public information officers coordinate and disseminate all information to the general public on the status of the l incident and protective measures to be employed for public safety. Th e JNC (where one exists) is the one designated location for the release of information to the public durir.g an ingestin pathway emergency, if kept operational by fiew York State.
The JNC may, at the discretion cf %w York State, continue to operate f or at least the initial portions of an ingestion pathway concern. .
For long term ingestion pathway activities, the public information fun ~ction may return to Albany. In the event that no JNC exists in the areas with ingestion pathway impact, the information may be provided to the public from Aleany or another designated location.
To provide effective public information releases to the general public, g the New York State Emergency Broadcast System (EBS) can be activated if determined to be necessary. The primary means for accessing EBS for dissemination of protective action recommendations will be with the assistance of local access (county) Dersonnel. If the EBS cannot be accessed locally, or if a large region must be notified simultaneously, SEMO will coercinate the issuance of the message via EBS as appropriate.
While the JNC is operational, all public information news releases and EBS messages will De :ompiled and written at the JNC. This information will be provided to the representative for the Public Information function at the State EOC upon completion.
K-8 Rev. S/87
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1 AIRBO RNE LIQUID RELEASE of# RELEASE 0,
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- '/ 6 i y v LAND SURFACE
!?:* ERSION ANc SU3?.!ERS10N SHORELINE CONTA?.11?;AT10N 9
man EXTERNAL 0
4 AIREOR!;E . LIQUID RELEASE RELEASE
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j PATHWAYS FOR EXTERNAL ANO INTERNAL EXPOSURE OF MAN FROM AIRBORNE AND LIOUlO l
RELEASES OF RADIOACTIVE EFFLUENTS l
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DERIVED RESPONSE LEVELS FOR PREVENTIVE P AG 1
Radienuclide - I-131 Cs-134 Cs-137 Sr-90 Sr-89 l
SOURCE OF S AMPLE Initial Deposition 0.13 2.0 3.0 0.5 8.0 (Ground)
(u Ci/m2)
Peak Activity:
Pasture (uCi/kg)* 0.05 0.8 1.3 0.18 3.0 Milk (u Ci/1) 0.015 0.15 0.24 0.009 0.14 7.0 2.6 5 Total intake (u Cl) 0.09 4.0 0 .' 2 i
Case Cermitman: (rem) 1.5 0.5 0.5 0.5 0.5
- Fre s n 'a'e i g n :
N:~I: This tatte uses inf ants as the critical segment of the ;c:ulation.
Fo r * -131, ne ae .::rn inf an is :ne critical ;c:ulati:n segment. Fo r tne :her ra icnu 11ces "inf ant" ref er: to a chil less than 1 year of ace.
Refere ce: Ce:ar:..ar.t c f de ai:n and . Hm u. an Services F::: an: : u g 'dr.in is trat i:n Fe:ers r e : : : e r , '!: '.. r e 4 7 , .' 3. 2C5, Oct::+r 22, 1922 u Ci/m2 = micro curies per square meter u Ci/kg = micro curies per kilogram u Ci/l = micro curies :er liter K-14 Rev.8/87
Attacncent 4
. INGESTION EXPOSURE PATHWAY..
Alert and
- notification Procedure L Indian Point Nuclear Power Plant Sites Upon confirmation of an ingestion exposure pathway concern from the Indian Point Nuclear Power Plant sites, the State Emergency Management Office. (SEMO) Headquarters Staff will employ the following alert and notification procedure- i I
GOVER10R DISASTER PREPAREDNESS COMMISSION COMMISSIO1ER OF HEALTH SEMO -
STATE AGEiCY LIAISONS HEADQUARTERS STAFF FEDEPAL EMERGC4CY <.
. < FEDEFAL AGEICIES -
MANAGEMelT AGElCY
, + BORDERIi4G STATES
> SS10 NORTHER 4, CE1 TRAL, LAKE At40 WESTERi DISTRICT OFFICES I
v S E10 5 E10 SOUTHEEN EASTERi DISTRICT DISTRICT V y WESTCHESTER LOCAL EMERGEICY 1 OWGE MA:1AGEMEiT OFFIC ES FUTNAM I ROCKLAND !
I OUTCHESS NASSAU SUFFOLK ]
ULSTER NEW YORK CITY Note: The 5D10 District Offices notify tneir regional State agency liaisons and otner local emergency management offices as appropriate.
K-15 Rev. 8/S7
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. If4GESTION EXPOSURE PATHWAY Alert and Notification Procedure l I
Nine Mile Point /FitzPatrick Sites 1 .
)
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.Upon confirmation of an ingestion' exposure pathway concern from the Nine Mile Point' {
or FitzPatrick nuclear power plants, the State Emergency Management Office (SEM0) I Headquarters Staff will employ the following alert and notification procedure:
GOVER10R
-> DISASTER PREPAREDNESS COMMISSION COMMISSION ER OF HEALTH STATE AGE 4CY LIAISONS l S EMO + i HEADQUARTERS ~
STAFF -+. FEDEFAL EMERGSiCY '
t FEDEFAL AGE 4CIES I MANAGEMDIT AGCICY h
-+ CANADA - ONTARIO PROVINCE
-+. BORDERING STATES SEMO WESTER 4, EASTERl & SOUTHERV DISTRICT OFFICES g
v Y 5EMO 5EMO SEMO NORTHERi LAKE C CITFAL DISTRICT DISTRICT DISTRICT y V y LOCAL 0.TARIO 1
OSWEGO EMERGCICY CAYUGA 01C10AGA MANAGEMCiT SCIEC A JEFFE:5:1 WAY.l E OFFICES LEWIS ,
ON EIDA MADISN Note: The SEM3 District Offices notify their regional State agency liaisons and o:ner local emergency management offices as appropriate.
K-17 Rev. 8/67-
- - _ -_-_____i
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i K -18 Rev. 8/S7 I _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _
A ttacmnen: 5 INGESTION EXPOSURE PATHWAY ~
Alert and Notification Procedure Ginna Site Upon confirmation of an ingestion exposure pathway concern from the Ginna Nuclear
~
, Power Plant, the State Emergency Management Office (SEMO) Heao;;uarters Staff will employ the following' alert and notification procedure: i GOVER10R 4
DISASTER PREPAREDNESS COMMISSION COMMISSIONER OF HEALTH
.SEMO + STATE AGE 4CY LIAISONS HEADQUARTERS STAFF FEDERAL EMERGElCY '
FEDERAL AGEICIES MANAGEME4T AGE 4CY
- CA"lADA - PROVINC E OF ONTARIO BORDERING STATES 4
SEMO NORTHER 1, EASTERI AND SOUTHERl DISTP.ICT OFEICES i
-i v 4 SEMO 5 E'd0 1 5EMO ~
WEST ERl CElTPAL LAKE DISTRICT DISTRICT DISTRICT l
i
'f Y sg WAYN E MO:lRO E OSWEGO O PLEANS ONO:lCAGA ONTA RIO Y ATES LIVINGST;N STUEB C1 GC4 ESEE SCIEC A WYCMING CAYUGA Note: The SE*40 District Offices notify their regional State agency liaisons ano otner local emergency management offices as appropriate.
1 i
1 K-19 Rev. E/37
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Inventory of Dairy Farms Inven: Cry of EOCO x Pr??assinc P l a r.t s x Sample Ga:nering:
Petable h'ater l l lx I
l Sample Garnering:
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Attachment 8 L
l-OPIP 3.6.6 Page 1 of 50
. m OPIP 3.6.6 INGESTION PATHWAY PROTECTIVE ACTIONS 1.0 PURPOSE
( This procedure provides guidance for protective actions that will mitigate the consequences of a radiological release in the ingestion pathway. It is intended that sound judgment and personal assessment of the progress of events will be supplemented with the guidance found in this procedure.
2.0 RESPONSIBILITY The Director of Local Responsa is responsible for decision-making regarding protective action recommendations.
Personnel performing dose assessment calculations will develop l l ingestion pathway protective ' actions recommendations for the ;
review of the Director of Local Response. 1 i
i The Radiation Health Coordinator is responsible for the coordination of sample collection and analysis with DOE, SNPS l l and other response groups performing this function. The Radiation Health Coordinator is also responsible for the j l protercive actions implementation of this procedure.
The Radiation Health Coordinator is responsible for the direct telephone communication of protective actions recommendations to the food chain establishments. The Director of Local Response will direct the Coordinator of Public Information to inform the public of his protective actions recommendations.
3.0 PRECAUTIONS 3.1 After a radiological release from SNPS, the effects on the ingestion pathway will not be known, from field sample analysis , for several hours or days. The initial basis for a prot (;cive action recem=endation for fresh milk will be provided by the projected ground deposition calculated in OPIP 3.5.2. Field sample analysis of initial deposition will probably not be available for l several hours after the release. In areas where j
' laboratory results are available, use the =easured i deposition activity levels instead of projected levels.
The laboratory analysis of pasture grass and fresh milk for peak activity will not be available for. several days after the release.
Rev. 5 l
w OPIP 3.6.6 i Page la of 50
==
I 4.0 PREREQUISITES 4.1 The' release of radioactive material into the air.or water is either in progress or was in progress and has been terminated.
4.2 Offsite dose projections have been completed or dose levels have been measured in accordance with OPIP 3.5.2. ,,
5.0 ACTIONS-5.1 Protective Action Determination Following are the methods for determining the necessary ingestion pathway protective actions:
5.1.1 Fresh Milk L This subsection is used in conjunction with Attachment 3 to determine if protective actions are necessary for fresh milk. It is also used in conjunction with projected and measured deposition activity levels and the preventive and emergency response levels as referenced in Attachments 1 and 2. The preventive and emergency protective actions for fresh milk ingestion are outlined in Attachments 7 and 8, '
, respectively. ,
l 5.1.1.1 Pre-determined Actions
- a. In the early stages of an emergency, the milk pathway is the most significant. Thus, early protective actions for preventing contamination of milk in- the affected area are recommended prior to obtaining confirmatory data.
Rev. 3
I l
OPIP 3.6.6 Page Ib of 50 i
- b. If a Site Area Emergency is l
declared, an Lamediate recommendation will be made to place l
! milk animals located within 2 miles ,
l on stored feed. As more information !
)
becomes available, this may be modified as required.
- c. In the case of a General. Emergency, an immediate recommendation to place milk animals within 10 miles on stored feed will be made. This may be modified as more information becomes available.
5.1.1.2 The Dose Assessment Function will:
- a. Obtain Accachment 3, Fresh Milk Protective Action Worksheet.
- b. Determine the area for which the protective action analysis is to be made. Enter the area of concern on the worksheet as item 1.
- c. Obtain the projected ground deposition activity from OPIP 3.5.2, for the area of concern and enter into item 2.
- d. Obtain the measured ground deposition and peak activities for the area of concern, if available, I and enter into item 5. Record measurements on applicable USGS topographic maps,
- e. Complete the action scacements of items 3 and 4 and also items 6 and 7.
5.1.1.3 If any of the projected or measured activity levels exceed the listed preventive activity response levels, the preventive protective actions as outlined in Attachment 7, Preventive Protective Actions, should be considered. If any emergency response levels are exceeded, consult Attachment 8, Emergency Protective Actions.
Rev. 5
l-
~
OPIP 3.6.6 Page Ic of 50 i
5.1.1.4 If protective actions are required, the affected facilities can be determined from the following lists:
New York State Dairy Farms, Attachment 9 New York State Milk Dealers / Operating Plants, Accachment 16a New York State Ice Cream Plants, Attachment 16b 5.1.2 Water This subsection is used in conjunction with Attachment 4 to determine if protective actions are necessary for potable water.
As soon as water samples have been collected and analyzed, use the measured dose as a basis,for protective actions.
5.1.2.1 The Dose Assessment Function will:
- a. Obtain Attachment 4, Drinking Water Protective Action Worksheet.
- b. Obtain the measured drinking water activity level from the laboratory and enter into item lb.
5.1.2.2 If the =easured activity levels exceed the listed response levels, consider the preventive protective action for water ingestion as outlined in Attachment 7, Preventive Protective Actions, and the emergency protective actions as outlined in Attachment 8, Emergency Protective Actions.
5.1.2.3 If protective actions are required, the affected facilities can be determined from the following list: New York State Surface Water Sources, Attachment 16c.
Rev. 4 l _ - - . - - - _
OPIP 3.6.6 Page ld of 50 ,
5.1.3 Foods Other Than Milk This subsection is used in conjunction with Attachment 5 to determine if protective action is necessary for foods other than milk. This procedure uses the dietary factors of Attachment 6 and the measured food activity levels. The preventive and emergency protective actions for the ingestion of these foods are outlined in Attachment 7 and 8. .
5.1.3.1 The Dose Assessment Function will:
- a. Obtain Attachment 5, Determination of Protective Actions for Foods Other Than Milk.
- b. Determine the type of food for which protection analysis is to be made and enter into item 1.
- c. Enter.into item 2 and on USGS topographic maps the location where anal.yzed food sample originated.
5.l.3.2 Determine the daily consumption of i specific foods in kilograms per day for the general population from information in Attachment 6.
t t
1 Rev. 5 1
. \
OPIP 3.6.6 Page le of 50 5.1.3.3 Assessment of the effective days of intake (item 5) should consider the specific food, the population involved, the food distribution system, and the radionuclides. Whether the food is distributed to the retail market or produced for home use will significantly .
affect the intake in most instances. !
Thus, while assessment of intake should be on a case-by-case basis, some general comments may be useful in specific circumstances.
- a. For short half-life radionuclides ,
radioactive decay will limit the ingestion of radioactive materials and the effective " days of intake."
The effective " days of intake" in this case is 1.44 times the radio-logical half-life. For iodine-131 half-life-8.05 days), the effective
' days o f intake" is , thus, 11 days.
- b. Where the food product is being harvested on a daily basis, it may be reasonable to assume reduction of <
contamination due to weatnering. As an initial assessment, it may be appropriate to assume a 14-day weathering half-life (used for forage in pasture / cow / milk pathway) pending further evaluation. In this case, the effective " days of intake" is 20 days. A combination of radioactive decay and weathering would result in an effective half-life for iodine-131 of 5 days and reduce the " days of intake" to 7 days.
- c. In the case of a food which is sold in the retail market, the effective
" days of intake" would probably be limited by the quantity purchased at a given time. For most food, especially fresh produce, this would; probably be about a 1 week supply.
In some cases, however, larger quantities would be purchased for Rev. 5
OPIP 3.6.6 Page lea of 50 home canning or freezing. For most foods and members of the public, an effective " days of intake ' 30 days is probably conservative.
5.1.3.4 Perform the calculation in item 7 and enter the values in item 8. If the projected intake values for any isotope exceed the prevencive protective action guides, then Preventive Protective Actions, as outlined in Attachment 7 should be considered. If the isotopic projected intake values exceed the emergency protective actions guides, then emergency protective actions as outlined in Accachment 8, Emergency Protective Actions, should be considered.
5.1.3.5 If protective actions are required, see Seccion 5.4.
l 5.1.3.6 The Director of Local Response will contact the New York State Commissioner of Health and the conneccicue Department of Environmental Protection and provide the LERO Ingestion Pathway protective action recommendation:
New York State Commissioner of Health 1
- Connecticut Department of i
Environmental Protection, Chief of I Radiation Control Unit l
If the above-mencioned scace officials /
agencies indicate that they are willing and able to implement the ingestion Rev. 5
OPIP 3.6.6 Page if of 50
' pathway plan for their state, no further action is necessary. If an adequate response cannot be ensured, refer to Section 5.4.
5.2 Ingestion Pathway Sampling 5.2.1 DOE RAP Team personnel and SNPS environmental survey teams will be collecting field samples to determine levels of radioactive particulate deposition. The Radiation Health Coordinator will obtain the results of isotopic analysis of field samples and determine if the FDA Ingestion Pathway PAGs have been exceeded.
5.2.2 The Radiation Health Coordinator will request that RAP Team and SNPS field teams periodically, when monitoring outside the plume, check beta readings (using HP-210 probe with RM-14 Count
- Race Meter) at 3 inches above the ground. If at any time these readings are more than 400 cpm.
above background, this will be an indication that the ingestion emergency PAGs have been exceeded.
I
=
Rev. 5 l
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l OPIP 3.6.6 Page lg of 50 l
l l
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l Rev. 5 l
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OPIP 3.6.6 Page in of 50 j
l-5.3 Protective Actions Revision and Termination The decision to recommend protective actions will be made by the Director of Local Response. Likewise, any decision to revise or terminate protective actions will be made by the Director of Local Response. The Dose <
Assessment Function will monitor radiological release and field survey sampling values on an ongoing basis and will provide the Radiation Health Coordinator with revised protective actions recommendations where appropriate.
These recommendations in turn will be forwarded to the Director of Local Response for review and approval. The Radiation Health Coordinator will be responsible for implementing the decisions to revise or terminate protective actions.
5.4 Implementation of Protective Actions Recommendations I'f the state officials cannot be contacted or are. unable or unwilling to implement protective actions, as stated in Section 5.1.3.6, this section will be implemented by LERO.
Implementation of this section is the responsibility of the Radiation Health Coordinator with the cooperation of the Environmental Survey Function, the Dose Assessment Function, and the RAP Team Captain. The Radiation Health Coordinator will receive ingestion pathway sampling information from the Environmental Survey Function survey teams, analyses from designated laboratories, and protective action recommendaciens from the Dose Assessment Function. He or she will summarize the information to report to the Director of Local Response for decision-making. To assist in this effort, the following four ingestion pathway maps are available in the EOC:
Reservoirs
- Food Vendors and Processors
- Fruit and Vegetable Farms Livestock and Milk Products The Radiation Health Coordinator will implement such decisions communicating them as described in Section 5.4.3.
Rev. 4
OPIP 3.6.6 Page lna of 50 Following are the implementation procedures :
5.4.1 Notification of Affected Facilities The affected facilities are identified, by reference to Attachments 9 through 16c, according to food type, compass sector (s), and distance from the Shoreham Nuclear Power Station. The attachments provide the address and telephone number of each facility.
The Radiation Health Coordinator will:
- a. Activate the communicator group.
4 Rev. 4 l
. . e OPIP 3.6.6 Page lp of 50 5.4.2.3 Ingestion Pathway Protective Actions Notification Form Following is an explanation for the use of Attachment 18. Unless otherwise indicated, the information is provided by the communicator.
Line 3 Attachment number. This corresponds to the list of concerns to be called.
[Provided by the Coordinator.]
Line 4 Subdivision of the above list.
(Provided by the Coordinator.]
Line 5 Check appropriate box for person who completed the form.
Line 6 Name of concern contacted and name of person receiving the message.
Line 7 Phone number used for the contact.
Line 8 Food type (s) involved by the protective action. (Provided by the Coordinator.]
Line 9 Note whether concern contacted is a Supplier (Examples : water l
company, reservoir), processor l
(Examples : milk bottler, food I packager), or other (Examples:
farm, roadside foodstand).
Line 10 Sector - geographical area involved in the protective action. [Provided by the Coordinator.]
Line 11 Miles - distance from the utility involved in the protective action. (Provided by the Coordinator.]
Rev. 3
OPIP 3.6.6 Page Iq of 50 Line 12 Contamination - actual or !
potential. [Provided by the Coordinator.]
Line 13 Recommendation - indicate whether the action is Preventive
[Provided by the or Emergency].
Coordinator.
Line 14 Protective Actions - specific instructions. Use the Attachments 7 and 8 code provided by the Coordinator to secure the text to be transmitted.
Line 15 Name/ Phone No. of User - obtain this information from the person called. This refers to the recipient of the food produced / handled at this location. (Examples: The farm contacted may sell its milk production to the bottler. A food packager may sell its canned goods to a distributor or directly to retail stores.)
Line 16 LILCO Liability - Advise that LILCO will compensate for food that is not salvageable.
[Provided by the Coordinator.]
Line 17 Call Back Phone No. - provide the contact with a number to be used to obtain up-to-date information. [Provided by the Coordinator.]
Line 18 Other - additional data to be transmitted as provided by the Coordinator.
Line 19 Contact Comments - enter I information in detail.
l Rev. 3
OPIP 3.6.6 Psge ir of 50 Line 20 Name - print full name.
Line 21 Message No. - communicators enter sequential number, starting at the beginning for each shift.
If the space allotted is insufficient for any entry, use the reverse side of the form and reference on the front of the form.
Notification Forms will be regularly collected by the Radiation Health Coordinator who will monitor the entire notification process and insure optimum coverage. ,
5.4.3 Ingestion Pathway Protective Actions Messages The Radiation Health Coordinator will cog lece a Notification Form (Attachment 18) for each of the affected food chain categories in accordance with the instructions by the Dose Assessment Function and the RAP Team Captain.
5.4.3.1 Commerce and Industry (including farms)
A. Milk - Farms and processors
~
- 1. Advise of contamination or p(ossibility Icem 12). of contamination
- 2. Recommend not to move food until further notice (Icem 13).
- 3. Communicate recommended protective actions (Item 14).
Examples :
- a. Preventive - 1.la, b, and c, Attachment 7 .
- b. Emergency - 1.2a, d, e, Attachment 8 Rev. 3
i OPIP 3.6.6 Page is of 50 4 Request the name/ telephone number of purchaser of this facility's shipments (Icem 15) .
- 5. Advise that LILCO will compensate for vasalvageable food (Item 16) .
- 6. Provide the phone number to call for up-to-date information (Icem 17).
B. Drinking Water - Water companies and commercial users
- 1. Advise of contamination or p(ossibility Icem 12) . of contamination
- 2. Provide recommended protective actions (Icem 14). Examples:
- a. Preventive - 2.lb ,
Attachment 7
- b. Eme rg ency - 2. la , c ,
Attachment 8 Attachment 8
- 3. Provide telephone number to call for up-to-date inf or=ation (Icem 17).
C. Fresh Fruits and Vegetables - Farms, processors , and >/e ' ors
- 1. Advise of contamination or p(ossibility Item 12). of contamination l
- 2. Recommend not to move food until further notice (Item 13).
Rev. 3
~
i OPIP 3.6.6 Page is of 50
- 4. Request the name/ telephone number of purchaser of this facility's shipments (Item 15) .
- 5. Advise that LILCO will compensate for unsalvageable food (Item 16) .
- 6. Provide the phone number to call fo up-to-date information (Icem 17).
B. Drinking Water - Water companies and commercial users
- 1. Advise of contamination or
- p(ossibility Item 12) . of contamination
- 2. Provide recommended protective actions (Item 14) . Examples:
- a. Preventive - 2.lb ,
Attachment 7
- b. Emergency - 2.la, c ,
Attachment 8 Attachment 8
- 3. Provide telephone number to call for up-to-date information (Icem
- 17) .
C. Fresh Fruits and Vegetables - Farms, j
processors, and vendors
- 1. Advise of contamination or p(ossibility Item 12). of contamination
- 2. Recommend not to move food until further notice (Icem 13).
Rev. 3 f
a
OPIP 3.6.6 Page it of 50 1
- 3. Communicate recommended q protective actions (Item 14) . 4 Examples: {
l'
- a. Preventive - 3.la
- b. Emergency - 3.la, c 4 .- Request the name/ telephone number of the purchaser of this f acility 's shipments (Item 15) .
- 5. Advise that LILCO will compensate for unsalvageable food (Item 16).
- 6. Provide a telephone number to call for up-to-date information (Item 17).
D. Fin Fish and Shell Fish l'. Advise of contamination or p(ossibility Item 12). of contamination
- 2. Recommend not to move food until further notice (Item 13).
- 3. Provide recommended protective actions (Item 14). Examples :
- a. Preventive - 4.0a, b, e
- b. Emergency - 3.la, e f
l 4 Request the name/ telephone number of the purchaser of this firm's shipments - (Item 15) .
- 5. Advise that LILCO will compensate for unsalvageable j food (Item 16).
i Rev. 3
OPIP 3.6.6 Page 2 of 50
- 6. Provide a telephone number to call for up-to-date information (Item 17).
E. Other Foods
- 1. Advise of contamination or possibility of contamination (Item 12).
- 2. Recommend not to move food until further notice (Item 13).
- 3. Communicate recommended protective actions (Item 14).
Examples:
- a. Preventive: 6.0a
- b. Emergency: 3.la, c
- 4. Request the names / telephone numbers of purchasers of this firm's shipments (Item 15) .
- 5. Advise that LILCO will compensate for unsalvageable food (Icem 16).
- 6. Provide a telephone number to call for up-to-date information (Item 17).
5.4.3.2 General Public, via Public News Bulletins
- a. The Director of Local Response will communicate to the Coordinator of Public Information those protective actions recommendations pertinent to ;
the public which he has approved.
i
- b. The Director of Local Response will j communicate revisions of protective actions recommendation to the Rev. 3
- - ~ ^ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
4 OPIP 3.6.6 Page 3 of 50 Coordinator of Public Infor=ation.
This includes termination of l protective actions recommendations.
5.5 Disposition of Contaminated Foodstuffs The Radiation Health Coordinator will brief the Manager of Local Response and the Health Services Coordinator on a continuing basis. They will develop a proposal for the disposition of contaminated foodstuffs based on the following factors:
- a. The availability of other possible preventive actions (see Attachment 7).
- b. Relative proportion of the total diet by weight represented by the food item in question.
- c. The importance of the particular food in nutrition and the availability of uncontaminated food or substitute having the same nutritional properties.
- d. The time and effort required to effect corrective actions.
Any decision to recommend the disposition of contaminated food will be made by the Director of Local Response.
5.6 Alternate Food Sources If a particular food or water source is determined to exceed the values stated in Attachment 1, curtailed consumption may be recommended. Alternate sources of such food may be desirable, for which the following considerations are provided.
As food needs are identified:
- a. The Director of Local Response will approve the procurement of necessary supplies.
- b. The Logistics Support Coordinator will direct I
Material Purchasing to order the required supplies to be delivered to a designated central staging facility.
Rev. 3 l
OPIP 3.6.6 Page 4 of 50 l l
- c. The Support Services Coordinator will arrange for local distribution.
5.7 . Continued Insestion Pathway Sampling and Sampling Evaluation The Radiation Health Coordinator will monitor the continued sampling of ingestion pathway foods.
The overall strategy'for sampling.at, and notification of, affected facilities 'will be developed by using four 50-mile Ingestion Pathway.EPZ maps located at the EOC.
On'the maps are plotted the key land use data such as reservoirs, food vendors and processors, fruit and vegetable farms, livestock and dairy farms, the facilities, color coded for specific types.
Accompanying the maps is a directory which identifies each facility by locality (alphabetically and by assigned identification number) and by sector / distance. The ,
listings include the name, address, and telephone number for each affected facility. Included on this list are food processors outside 50 miles who may process food from within 50 miles.
Attachments 9 through 16e of this prccedure are listings of affected facilities by food type and cegass sector / distance. The name, address, and telephone number enables the affected facilities to be contacted by telephone or sampling teams dispatched to the site.
The Radiation Health Coordinator will:
- a. Function with Provide the Environmental information regarding the Survey places / food types to be sawpied as follow-up . When contamination attains a level less than that stated in Attachment 1, new instructions are to be communicated to the concerns / persons previously notified in accordance with the Director of Local Response decision.
t b. Provide the Environmental Survey Function with identification of new places / food types to be sampled
- based on information provided by the Dose Assessment Function.
- c. Advise the Environmental Survey Function to pick up samples taken by farmers, processors, etc.
L Rev. 4 l
1
OPIP-3.6.6 Page 5 of 50
- d. Coordinate with the designated analytical laboratories to expedite analyses, obtain data and forward the results to the Dose Assessment Function.
5.8 Maintaining and Updating Ingestion Pathway-Data
. The data presented in the 50-mile Ingestion Pathway EPZ maps at.the local EOC, in the accompanying directory, and in Attachments 9 through 16e of this procedure have been compiled from the sources listed in Attachment 19. -These will be maintained and updated in accordance with OPIP 5.4.1, Document: Control. All records, references, and documents from which these data have been compiled are stored at the local EOC.
6.0 REFERENCES
6 .1' Department of Health, Education, and Welfare, Food and Drug' Administration, 21 CFR Part 1090, " Accidental Radioactive Contamination of Human Food and Animal
' Feeds," Federal Register, Vol. 43, No. 242, December.15, 1978, p. 3a/vo.
6.2 Department of Health and Human Services Food and Drug Administration, Federal Register,-Vol. d7, No. 205, October 22, 1982.
6.3 OPIP 3.5.2, Assessment and Dose Projection (airborne.and waterborne).
6.4 OPIP 3.5.3, Ingestion Pathway Assessment and Dose Proj ection l
Rev. 4
~
i
_ - _ _ _ - _ _ _ - _ _ _ s
Attachment 9 (Wayne)
SECTION D D. RECOVERY -
- 1. MISSION This section describes details of those short term recovery / reentry and long term recovery operations which are unique to radiological emergencies and to provide-the Chairman of the Board of Supervisors (CCBS) with the capability of implementing the safe reentry to their places of residence and/or employment, for the members of the general public who have been relocated under one of the protective action response options described in Section C-8 and C-Be.
i Recovery is that period.of time which follows the response actions to an-emergency and extends to a time when community life, within the Emergency Response Planning Area (s), has been restored to normal. Operationally, recovery begins during the response phase and continues 'until restoration of connunity life has been completed.
Recovery operations for radiological emergencies consist of two -
operational parts; they are:
- a. Short term or reentry operations:
Reentry from a radiological emergency shall cor.unence only after all emergency initiating conditions have been neutralized and the threat to public health and safety from a release of radiation no longer exists. The following shall be confirmed before initiating reentry operations:
(1) Safe shutdown of nuclear facility.
(2) Radiological materials are under controlled confinement.
(3) Initiating physical phenomenon has been stabilized (e.g.,
pressure relief from geographical fault).
b., Long term recovery operations:
Aside from long term radiation and medical monitoring programs, long
) term recovery. operations are generic to all emergencies. For details and guidelines for the implementation of long term recovery operations, refer to the New York State Disaster Preparedness and Radiological Emergency Plans. (Part I,Section IV.)
- c. Decisions to relax protective measures
1 The CCBS, in coordination with District Director of Health, County 3 Director of the Emergency Management Office, The New York State l Health Department, and RG&E will make the decision for reentry into evacuated areas.
Congregate Care centers will be notified when personnel may return l
home: The Sheriff will control traffic returning to the evacuated areas.
Rev. 4 - 10/1/86
I I
A Recovery plan has been prepared and maybe implemented when ,
required. The plan is maintained at CE0C under supervision of CDOEP. j
- 2. Recovery / Reentry Operations Recovery / Reentry Operations will conform with the guidelines contained in the New York State Radiological Emergency Plan and will include the -
following:
- a. Completion of radiation surveys by the County Radiological Defense r Officer (RDO) and the New York State Department of Health (NYSDOH) which indicate that contamination levels in an evacuated area are at least below the contamination action guides.in Section D. Table D-1.
In areas which have been contaminated, the NYSDOH may direct that reentry be allowed to all but specifically cordoned-off subareas,
- b. Determination that a threat to public health, as a consequence of a i release of radiation, no longer exists. )
- c. Completion of the DDH and NYSD0H directed decontamination activities, including waste disposal, undertaken by County Fire Departments. ,
Assistance and guidance in this area will be obtained from the U.S.
Department of Energy.
- d. Notification to incoming traffic control check points of the areas for which reentry is authorized and the realignment of the traffic control perimeter. -
{
- e. In conjunction with the State of New York, the federal government, and the nuclear facility operator, the preparation and issuance of announcements to the communications media (e.g., newspapers, and radio and television stations) and Reception / Congregate Care Centers specifying the areas which may be reentered.
- f. Continuation of security for evacuated areas, including those for which reentry has been approved, to prevent unauthorized entry and vandalism.
- g. Provision for transportation of those individuals who were assisted during the evacuation.
- h. Distribution of drinking water and foodstuffs, if necessary, for the l
isolation of ingestion pathways and sources (see Section C-8f).
- i. Establishment of a long-term radiation monitoring program for any contaminated County areas.
- j. Establishment of a long-term medical monitoring program for both the general public and emergency response personnel of the County.
- 3. LONG TERM RECOVERY The implementation of long term recovery operations is the primary responsibility of the State of New York, and will conform with the guidelines contained in the New York State Radiological Emergency and Disaster Preparedness Plans. (Part I,Section IV)
Rev.1 - 5/1/84 L -
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Attachm::nc 10 (Oswego) e implementation and execution of the General Evacuation Respon Op on will include the following:
(1) Th ' notification of tne situtation to all members of th eneral publ witnin the areas to be evacuated and the offici ly reco, ded course of action (see Appenaix F). Inis oti fication will inc ce information on how far to evacuate, w t evacuation routes to e, reception centers, and how to not y authorities if any reloc ion assistance is needed. This eration will De directed by t Deli and assisted oy tne otn County emergency response organi ions.
(2) The establishment o traffic control pp nts at key intersections along tne evacuation tes. The fi 7 traffic control point will be locatea beyond e boundar of the plume exposure EPZ.
Tnis operation will be co ainst by the County Sheriff's Department (CSD) assisted b t County Highway Superintendent (CHS) and tne New York State lice (NYSP).
(3) The evacuation of nonmobi resia ts and hard-to-move (medical) residents who are witno access to ther transportation. Thi s i i operation will be coo inated by tne unty Commissioner of Healtn (CCH), the C nty Emergency Medi i Services Coordinator -
(CEMSC), the Coun Sheriff (CS), County 're Coordinator (CFC) and County High y Superintendent (CHS).
(4) The inonitor g of the evacuation rcutes ano tne facilitating of the evacu on traffic flow. This operation wil e directea by the CSD id assisted by tne CHS ano the :4YSP.
l (5) Tne tablishment of incoming traffic control points an securi ty I f evacuateo areas. Tnis operation will be coordinated tne D and assisted by the NYSP.
- f. Isolation of Irgestion Patnways and Sources i
In coordination witn New York State Departments of Agriculture and Market and Department of Healtn, tne County Director of Emergency Management (CDEM) has tne capaoility of receiving information to implement effective protective actions to ensure tnat the potential for individuals to receive radiological doses in excess of recommended limits tnrough the various ingestion pathways are mi nimi zed.
The implementation and execution of tne Isolation of Ingestion Pathways and Sources Response Option will conform with tne Isolation of Ingestion Pathways Guidelines contained in the New York State Emergency Preparedness Plan and will include tne following:
(1) Upon receipt of radiation monitoring results which indicate contamination of a drinking water supply or foodstuffs (ingestion of which could exceed recommended limits), tne CDE34 shall confer l with representative of U.S. Department of Agriculture and/or representative of NYS Department of Agriculture and Markets and the County Commissioner of Health in order to determine the C-27 Rev. 7/85
l requirements to quarantine foodstuffs and prevent the consumption of sucit water.
(2) Based upon additional examination, if isotopic concentrations i exceed those specified in Tables III-4 and III-5, the State will l inform the CDEM who will, in turn, coordinate witn tne county Commissioner of Healtn (CCH) and the New York State Department of Health tne appropriate actions to be taKen as inoicated in these taoles. '
O C-26 Rev. 7/ob Lm__ _ _____ _ _ _ . _ . _ . _ _ . _ . _ _ _ . _ _ _ . . _ . _ . _ _ _ _ _ _ _ . . . . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _
Attachment 11 (Wayne) e evacuation plan for Wayne County is described in Appendi A. The evacuation plan details the evacuation routes, traf ic con rol points, traffic capacities, and the total evacuat n time requirements for evacuating different areas of the Count These evacuation times represent the time req red to evacuat a particular area after the general public h been notified \ $hat an evacuation is necessary. Contingen evacuatio(plansaredevelopedtoaddressthepossi'lityof evacuating Kith the loss of a primary evacuation r ute and/or during adver weather conditions.
The implementa' tion and execution of the Gener Evacuation Response Option 11 include the following:
(1) The notification ofgall members of the gen ral public in the areas to be ev.acuated of the situ ion and the course of action /(see Appendix F.
officially This notification wil include informat'lon on how recommende(l far to evacuate, what ev'acuation rou s to use, reception centers, and how to notif authorities if any ,
is operation will relocation assistance is needed.
be directed by the CDEMO andsassi ed by the other County emergency response orghn ations.
(2) The establishment of traffic ritrol points at key intersections along the eva ation routes. The final j traffic control point will e located beyond the a boundary of the 10-mile E . This operation will be coordinated by the Count Sheriff's Department (CSD) assisted by County Tow and Village Police Departments and the New York Stat Police (NYSP). (
(3) The evacuation of nmobile residents and handicapped residents who are ithout access to other transportation. This operation will b coordinated by the County Superintendent of Highways, Distr'ct Director of Health, and thek/cbulance Coordinator. \
\
(4) The monitor' facilitati g ofgthe of the evacuationtraffic evacuation routesflow. and theThis\
3 operatio will be coordinated by the County Sheriff ahd assiste by the County Superintendent of Highways and the NYSP.
(5) The e tablishment of incoming traffic control points and ecurity patrols for evacuated areas. This op ation will be coordinated by the County Sheriff and a ,isted by County Town and Village Police Departments and th YSP.
- f. Isclation of Ingestion Pathways and Sources The Isolation of Ingestion Pathways and Sou'rces Response Option
( gives the CCBS the capability of implementing effective protective actions to ensure that the potential for individuals to receive Rev. 4 - 10/1/86 l
radiological doses in excess of recommended limits through the
-various ingestion pathways is minimized. This includes control of l radioactively contaminated drinking water and. foodstuffs.
The implementation and execution of the Isolation of Ingestion Pathways and Sources Response Option will conform with the Isolation of Ingestion Pathways Guidelines contained in the State of New York Emergency Plan and will include the following:
'(1) Upon receipt of radiation monitoring results which indicate contamination of a drinking water supply or food stuff (ingestion of which could exceed recommended limits), the CCBS shall immediately quarantine such foodstuffs and prevent the consumption of such water.
Based upon additional examination, if isotopic concentrations exceed those specified in Tables C-4 and C-5, the CCBS shall coordinate with the District Director of Health (DDH), the New York State Department -
of Health and the New York State Department of Agriculture and Markets, the appropriate actions to be taken as indicated in these tables.
The DDH shall make all arrangements necessary to ensure that available supplies of drinking water and foodstuffs are not contaminated by continuous sampling designated by the NY State Health Department. See State Plan for Ingestion Pathway Guidelines.
l
/ Rev. 4 - 10/1/86 i .
Attachment 12 l
(Westchester) l 1
.. te. implementation and execution of the General Evacuation Respon 0 ion of the CREPP will include the following:
(a) e notification of all members of tue general public in ne ar s to be evacuated of tne situation and tne official rec ended course of action (see Appendix F). Tnis noti ation will include information on when and h far to evacua l what evacuation routes to use, receptio centers, and how to n tify authorities if any relocation assi ance is needed. is operation will be directed by th CE and assisted by tne othe County emergency response organ ations.
(b) Tne estaulisn. nt of traffic control poi s at key intersections a ng tne evacuation rout . Tne final traffic control point wi be located beyond e boundary of tne 10-mile EPZ. Tni s peration will b coordinated by the County Commi ssioner/Sheri f of Public Saf y (CCPS) assisted by the Westenester County /lo 1 Law Enf cement Agencies and tne New York State Police.
(c) The evacuation of nonmoui esicents ano nard-to-move (medical) residents wno a itnout access to otner .
transportation. Tnis o rat n will be coordinates by tne County Commissioner of ospita assisted by the County Department of Transp tation (C T), tne County Local Departments of Pub c Works, Coun Emergency Medical Services ano tne County 0 artment of Gener Services.
(d) The monitorin of tne evacuation rout and tne f facilitating of the evacuat n traffic flow. Tnis ope tion will De coordinate by the CCPS assisted by the unty and local pol ice, d tne NYSP.
(e) Tne ablisnment of incoming traffic contro oints and sec . ity patrols for evecuated areas. Tnis op ation will be c rdinatea oy tne CCPS assisted of tne Westcne er ounty/ local law enforcement agencies and the NYS (6) Isolation of Ingestion Patnways and Sources The State of New York, througn tne Commissioner of Health with assistance from designateo agencies is responsible for the implementation and execution of tne isolation of Ingestion Pathways I and Sources Response Option containea in tne State of New York Emergency Preparedness Plan.
Tne Isolation of Ingestion Patnways and Sources Response Option gives tne CDOES the capauility of implementing effective protective dCtions to ensure tnat the potent 1GI for individuals to receive radiological doses in excess of recontnended limits througn tne various ingestion patnways is minimized. Inis would involve control of radioactively contaminated dr1nking water and foodstuf fs.
The implementation eno execution of tne Isolation of Ingestion Pathways and Sources Response Option will conform witn tne 111-29 Rev. 4 - 9/oS j
.. Isolation of Ingestion Pathways Guidelines contained in tne State of New York Emergency Preparedness Plan and will include the following:
(a) Upon receipt of raciation monitoring results wnich indicate contamination of a drinking water supply or foodstuffs (ingestion of which could exceed recommended limits), the Commissioner of Healtn shall immediately quarantine such foodstuffs and can tne consumption of sucn water.
(D) _ Based upon additional examination, if isotopic concentrations
' exceed tnose specifiec in Taoles III-4 and III-5, tne County Commissioner of Health (CCH) shall coordinate with the New York State Departlaent of Heditn the appropriate actions to be t4 Ken as indicated in these taoles.
(c) The CDDES with CDPW and tne Commissioner of General Services sna11 coorainate arrangements necessary for aistrioution of uncontaminated supplies of drinking water and food as necessary.
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