ML20073S242
| ML20073S242 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/04/1983 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20073S244 | List: |
| References | |
| NUDOCS 8305060506 | |
| Download: ML20073S242 (16) | |
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? @99Federal %. Emergency Management Agency h,k[E.,. Washington, D.C. 20472
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o MAY 4 1M , .
Mr. Samuel J. Chilk c'- ; *' iPJ.'.1SEit I"**'""~".77C......r..k rc .
k Secretary of the Commission U.S. Nucidar Regulatory Com=ission Washington, D. C. 20555 _.
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Dear Mr. Chilk:
83 it c -5 P2 T This is in response to your letter of April 26, 1983, concerning the Westchester County, New York, bus driver issue, the.Rockland County, New York, plan issue, and the ~~ additional questions rai, sed by Commissioners Ahearne and Roberts as a result 'of the recent Federal Emergency Management Agency (FEMA) briefing and status report on of fsite emergency preparedness at the Indian Point Nuclear Power Station. Our responses will follow the same order as your inquiry, with each question being restated and followed by our response.
A. Westchester County Under planning Standard J as described in NUREG-0654/ FEMA-REP-1,-Rev.1, NRC and FEMA are to predict stether a range of protective actions reasonably could be implemented in the plume exposure pathway emergency planning zone for emergency workers and for the public. In making its overall assessment.
of compliance with the planning standard (10 CFR 50.54 (q), see 10 CFR 50.47 (b) (10)), the NRC must assess the significance of the bus driver situation as described by FEMA for Westchester County. In doing so -
it would be useful to have supplemental 'information from FEMA concerning the above pre =ise and the. following catters of f act: * ~
- 1. Do you know how many people and stat segment (or segments) of the population (by age) would be dependent on buses in an emergency? Is there any information available on this question?,
, RESPONSE:
l According to the county plans, the following segments of the population would be dependent on buses in an emergency:
School children ,
28,573 Hospitals , nursing homes, etc. 2,770 General population 10,838 TOTAL 42,181 8305060506 830504 PDR ADOCK 05000247 PDR g
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- 2. For _ purposes of your evaluation, how many people and what l segment (s) of the population did you assure would be dependent '
on bus transportation in an emergency? Do the number of ' people 3 and the population ' segment (s) so dependent in any way affect your sssessment as to whether this deficiency is significant in terms
! of preparedness?
RESPONSE :
Approximately 42,181 individuals could be dependent upon buses, vans, etc.,
for evacuation. No, we are concerned with whether there is sufficient capability to carry out the evacuation. This capability is more difficult to realize with increasing numbers of people who are dependent on bus trans po rt ation.
'3. Does the plan to send children home at the alert stage lessen the number of bus drivers needed in an emergency? Did you consider this f actor when you concluded that the f ailure to obt ain a commitment from bus drivers in Westchester County was a significant deficiency?
RESPONSE: .
No. The new evacuation plan does not lessen the number of bus drivers needed in an emergency, it only eliminates the need for certain bus ,
drivers to return into the emergency planning zone af ter the school children are evacuated.
4 In making its conclusion about the bus driver deficiency and its effect on compliance with Planning Standard J, what percentage of bus drivers '
did FEMA assume would actually respond in an emergency? Is this
__ assumption based on actual . responses in other emergencies? ..
- RESPONSE: .. ,
We have no inf ormation or. what percentage of the bus drivers would or would not respond in an emergency. The previous County Executive for Westchester County and some bus drivers both had stated at the Atomic Safety and Cicensing Board (ASLB) hearings that the bus drivers may not respond to evacuate the general population af ter the initial evacuation of school children was completed. This situation resulted in the need for written agreenents to give reasonable assurance that the bus operators would respond. ,
- 5. At the April 20, 1983, Commission briefing, Mr. Petrone of FEMA stated that FEMA required letters of agreement with bus drivers who would respond during an emergency.
- a. How many State and local plans have received PEMA approval to date?
- b. Do all of the FEMA-approved plans have such agreccents' with the bus drivers? If not, how many do? Are they part of the State or local approved plans?
RESPONSE
(a) Eighteen State site-specific plans (within 10-mile emergency planning ,
zone) have received FEMA approval to date. Fif ty-one local plans have also received an upproval for a tot al of 69 State and' local plans.
(b) The FEMA-approved plans contain agreements which co=mit transportation mechanisms for evacuation purposes in accordance with Planning Standard
- A.3 of NUREG-0654/ FEMA-REF-1, Rev. 1, The specific nature of the agreements varies due to jurisdictional differences in governmental infrastructure unique to each site.
- 6. Do you agree with the conclusion in NUREG-0396 that sheltering vill be preferable to evacuation in all but the worst and rarest events?
Is it your premise that preparedness is inadequate unless evacuation is possible in all seen,arios? When you determined that preparedness was inadequate, did you consider .whether the bus driver deficiency thould be viewed in light of the preferability of sheltering to evacuation in most scenarios?
RESPONSE
While NUREG-0396 is a complicated document" with some room for interpretation, FEMA is not aware of a conclusion that sheltering will be preferable to evacuation in all but the worst and rarest events. Rather, the data presented in Appendix 1 support a statement of the report (page 13) that:
For the plume exposure phase, sheltering and/or evacuation would likely be the principal immediate protective actions to be recommended to the general public within the EPZ. -
Further, at Page 1-49 Appendix I, the report states:
Within five miles of the reactor, evacuation appears to be more
~ ef fective ~1d reducing the' n'unber of early health ef fects thin sheltering,'
as long as the delay time and nonparticipating segment of the population
- are kept suf ficiently small.
During the , spring of 1980, FEMA chartered a study of the 12 most populated l
sites to determine the overall time dyna =ics of evacuation, and to provide a basis for the writing of Appendix 4 of NUREG-0654/ FEMA-REP-1, Rev.1.
These 12 studies were reviewed and commented upon by FEMA in the report FEdA-REP-3 dated February 1981. A principal conclusion of that report, which was restated in the forwarding transcdttal letter, was that basic assumptions so color the results of such studies that they are best
. conducted using a computerized simulation model where comparative assumptions can be tested for sensitivity of effect.
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Since that day, it has been FEMA policy to consider site specific aspects of protective action recommendations as paramount over generic policies.
Given the time for advanced alerting and notification, there appears to be merit in early. evacuation out to two or three miles in all cases N involving potential core-melt accidents. Beyond that distance, the ,
demographics , road networks, and meteorological conditions at the tL=e would govern the policy recommendation to be made. In coming to such a drecommendation, the local of ficials would be best guided by prior perf ormance of technical simulations of evacuation time dynamics on a site-specific basis which prepare decision-makers for dealing with the range of consequences implicit in the assumptions. FEMA is developing the technical capability to perform such simulations in conjunction with State and local of ficials , on a site-by-site basis.
Therefore, our premise is that it is not possible to make a complete judguent on preparedness unlels time, distance, and the nature of the.
accident are considered in coming to a conclusion. Further, preparedness may be greatly enhanced by the operational simulation of planning options and is therefore, a relative judgment.
Therefore, in casing to a conclusion on the issue of the bus driver deficiency, FEMA was guided principally by the need to preserve evacuation as an option, Given a more general consensus on the nature of the accident to plan for, the bus driver issue might be given less weight, or might be 'given differing weight as a function of time and distance on a site-specific basis. .
In the absence of analyses of this level of detail, FEMA came to the only conclusion possible, namely that the lack of capability to perform evacuations, even to nominal distances, and for a small fraction of the total population of the emergency planning zone, constituted a deficiency in preparedness. ,
B. Rockland County 1 In assessing the degree to which New York State involvement for Rockland County's non participation should be weighed,- the NRC is- underrtandably -
concerned about the interaction between Parts I.E and I.F of NUREG-0654/
FEdA-REP-1, Rev.1, Part 1.E. explains that local plans should include mutually supportive emergency planning and preparedness arrangements by several levels of government; Part I.F. states that "although the guidance ' indicates the criteria are applicable to one or more specific organizations, the intention throughout has been to provide for an adequate state of emergency preparedness around the f acility." Part I.F. also explains that "if weaknesses in one organization are identified, but compensated for in another orSanization, the reviewers can still find that an adequate state of emergency preparedness exists." The rulemaking record is replete with references to the substitution of resources of one level or agency of . government for another as part of " alternative compensating measures." To assist
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it in deter =ining the adequacy of such measures under 10 CFR 50.54(s),
the NRC would appreciate FEMA's supplemental views on (a) the above statements, (b) whether aside from the f ailure of Rockland County personnel to participate in the exercise, there were significant ,
deficiencies in implementing e=ergency measures by state personnel (please be' specific), and (c) as indication of' FEMA's views on Rockland's
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co=mitment to respond if there were an actual emergency and od Rockland's capability to respond adequately, assuming State supervision.
RESPONSE
(a) FEMA believes that State governments can compensate for local govern-ment, although this would not be easily done in highly populated areas.
FEMA has seen no evidence that New York State is developing procedures and dedicating resources for Rockland County to go beyond the exercise capability. For of ficial FEMA policy, see the April 18, 1983, letter from Director Giuf frida..to Chairman Palladino. ,
(b). There were no significant deficiencies evident during the exercise in the ability of the State to implement emergency measures. The limited commitment of less than 50 State personnel was adequate for the purpose of the exercise; however, the overriding concern is the resource base to suppo rt an actual emergency in a timelv manner. FEMA's finding is that the State of New York has not demonstrated that adequate personnel and resources exist and could be provided to support an actual emergency in Rockland County or that the personnel can be mobilized, dispatched, and
. in place in a timely manner. The State Compensatory Plan submitted to
- FEMA only identifies a senior management team consisting of six persons representing six State agencies that were identified to supplement county resource s . FEMA does not have a plan identifying the persons and ' resources which would be necessary to totally compensate for f ailure by the county -
to respond.
(c) Rockland has committed that the . county would respond in the event of an accident, , FEMA has had. no . basis to evaluate the capability of Rockland~
County personnel to respond nor is there a county plan in place.
- 2. Section 2. 5. 7 of the report states that due to the absence of detailed evacuation plans and procedures for Rockland County, the capability to implement actions to protect the public could not ,be measured against a plan. Why was the Rockland County Draf t Evacuation Plan, which was implemented by New York State (NYS), not evaluated for this planning standard?
RESPONSE
FEMA did not receive a copy of the draf t Rockland County plan until February 18, 1983, less than one month before the exercise. This plan was incomplete when furnished by the State and had not been adopted by the county. The plan was submitted with the intent that the State's senior management team would oversee the use of this plan by county emergency response personnel., However, in early March the county voted not to participate in the exercise. There was no formal submittal or request to review the incomplete draf t plan by the State of New York.
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- 3. At the April 20, 1983 Commission Meeting, Mr. Petrone stated that if New York State intended to take over' all response in Rock 1ghd County, the NYS Compensatory Plan needed to be changed to reflect this and iti would be.nec's:sary for the State to have the State employees who '
would impleme'nt these measures "in lockland Count'y stationed there.
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- a. Do any of the State employees who responded to the Rockland County EQC during the March 1983 exercise live or work in Rockland County?
If so, what is the proportion or number of those who responded, who do live or work there? ys ,
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- b. Is it a FEMA requirement that county responders (in any cou^nty) live in that particular county or within a certain distance oI travel time of their response location? If so, what are your distance or time limits? Are they applied to all plans t and locales uniformly?.
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_ ~. c . t County Was it your in ninety intentorto minutes indicate less was a that NYS responseq deficiency? If so, then o Rocklay,C,it was c.
s a significant deficiency? Is the same true for Putnac Count'y? ~
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> w Note that Mr. Petrone's point was that if ,the State were to compensate:; -
for Rockland County, these employees would hav'e to be in the Rockland -
County area.
- RESPONSE: - ,
(a) The only informatdon FEMA has ,on the residences and employment location of the New York State employees who res}onded to the Rockland County emergency operating center during the March 1983 exercise is '
contained in the enclosed tele'hhone listing. Individuals with an area
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code of 914 may live in Rockland County, however, area code 518 does not _
cover Rockland County, but is' for the Albany. arekh
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( b')' FEMA has no 'rdquiremeht clia't' county responders hive in the particular -
county in which they would be grequired. to respond or within a certain distance or travel time ' of,,their response location.
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(c) It was,not our intent to indicate that the New York State response to Rockland County in 90 minutes or less was a significant deficiency. '
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However, we indicated in our report that delayed arrival of key St' ate personnel who had to travel long distances as f ar away as Poughkeepsie, Monticello, and Albany, i'nitially caused some confusion at the Rockland County emerge'ncy operating center.s This was highlighted to demonstrate that some delays were inevitable under the compensatory set up, however these delays 'did not occui in th^e initial critical response functions. '\
It should be. noted that the futnam County emergency operating center was fully staffed and activrted within 90 minutes which was determined to bei. .
an acceptable response. ' *~ # *,
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'. , 3. In the Indian Point Post Exercise Assessment Report, Rockland and Wests. heater Counties are cited as significantly deficient regarding
. the public understanding as to their response to sirens or tone alerts.
"' - Orange County was not, despite the conclusion that most people there ,
did not understsad the reanir.3 of.the sirens. Report at 47-48. Was this deficiency in Westchester and Rockland primarily based on the brochures. What criteria were used?
f ailure to distribute,\ ,
-e , RESPONSE:
,f The annual public educatYon brochures had not been distributed in either Westchester or Rockland Counti'es prior to March 9,1983. These brochures
_ Jhad been distributed in Or.ange and Putne. Counties.
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. The deficiencies cited in the Aprilfi4,1983, Post Exercise Assessment
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_1 Report will beco.:le sigriificant if the public education brochures are not
., hl' distributsa in Westchester by Juneil,1983, This is because the following
- p u. ditiont,6xisT is these counties. j .
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', WesgehAster County - Tbe trandp'ortatiori @rtion of the county plan is 3., beitsg revised and the public educ,htion brochge is being reviewed and raised to include these changes. j . % s
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- }'Rockland County - As the county plan has not been completed, no public "N $ education brochure has been distribut.ed to Rockland County residents during the, last year. -
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belod eachfour questions question. raisp[l by Co=tissiorer Ahearne eith the response
- 1. Has FDiA reached the judgment that the bus drivers in Wectchester
' County will not resped absent contractus1 comcitmnts?
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RESPONSE: /
In light of concerns raised by We.s tehester County of ficials and lack of agreements with bus operators, FD'.A caneut assure that bus drivers will respond. * .
- 2. What are the contractual obligafic,',s FEXA would want in order to conclude that availability of bys drivers would not be a significant deficiency for Westchester County?
RESPONSE
FDiA wants assurances by whatever mead that bus drivers would respond.
Currently, there is a doubt that they will . At a minimum, FD1A would like to see letters of agreement oetween the bus operators and county, including a commitment of resources , i.e. , buses and drivers. We would construe these letters .of agreement as a com itment of bus drivers to i respond in case of an emergency. _.
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- 3. Such contracts would be between Ubat parties?
RESPONSE
/
Contracts of this nature would mas,t 1,ikely be between the county and the
, bus company owners. ,
4 What is the status of negotiating such contracts?
RESPONbE:
There are no negotiations ongoing to our knowledge, however the county is engaged in negotiations for a transportation study that would also address this issue.
During the April 20, 1983, Commission meeting, Commissioner Ahearne asked that FEMA provide an estimate of the number of transients located in the emergency planning zone.. Accordingly, the current transieht
' population projection within the emergency planning zone is estimated at 87,119 people. Also, Commissioner Ahearne requested that FEMA supply him ,
with an indication on the ef fectiveness of those methods being employed to notify transients. We are in the process of obttining this information from our Regional Offices and will supply
- it when it becomes available in the near future.
Below are the questions raised by Commissioner Roberts with the response -
below each question.
Indian Point Ouestions
- 1. On April 15, the Regional Director of FEMA, Frank T. Petrone, issued a press release in connection with the post-exercise assessment of the Indian Point March 9 drill. The press release stated:
According to Petrone," 'significant progress has been ma'de since the -
March 3,1982, exercise. "However, at this time, I cannot assure that public health and saf tey can be protected in the ten mile emergency planning zone around Indian Point," Petrone stated.
In co'nnection with any nuclear plant or emergency drill, has FEMA ever given an assurance that the public health and saf tey can be prot ect ed? If so, cite the specific f acility or drill assessment in which FEMA publicly stated its assurance that public health and saf ety can be protected.
. Why was it necessary for the Regional Director to issue a press release with that specific statement?
RESPONSE
FEdA's role with respect to NRC's licensing process is to provide the NRC a statement as to khether or not State and local government preparedness is adequate to assure that public health and safety can be protected in the event of a nuclear power plant accident.
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This statement of adequacy for offsite preparedness is made by rtaA within two contexts, the 44 CFR 350 process and interim findings. FEMA's proposed rule, 44 CFR 350, provides the Agency's policy and procedures for, 44 CFR 350 deter =inations of approval or disapproval per our review and evaluation of Sta'te and local goverhme'ht emergency re'sponse plans, their participation in exercises, and the conduct of public meetings. .
Section 35012 of our rule provides the procedures whereby the FEMA Associate Director makes the determination of adequacy of State and local government prepartdness based on the FEMA Regional Director's review and evaluation.
The Associate Director's determination is based on two criteria:
That State and local government planning and preparedness:
- 1. "Are adequate to protect the health and safety of the public living in the vicinity of the nuclear power f acility by providing reasonable assurance (underlining added for emphasis) that appropriate measures can and will be taken offsite in the
. event of a radiological emergency; and
- 2. "Are capable of being i=plemented. . . ." [350.12(b)(1)(2)).
As of April 1983, FEMA had made determinations of adequacy and given 44 CFR 350 approvals with statements provided to the NRC asserting that State and local government preparedness provides reasonable assurance t, hat public health and safety can be protected in the event of a power -
plant accident for these States and f acilities:
Facilities States Sequoyah Ten'nes s ee Farley Alabama & Georgia
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Hatch ,
McGuire "~
North Carolina ' -
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Summe r ' South Carolina Robinson South Carolina Arkansas Arkans as Fort St. Vrain Colorado Brunswick North Carol,ina LaSalle Illinois Palis ades Michigan Troj an Oregon & Washington Dresden Illinois Surry Virginia North Anna Virginia
- Oconee . South Carolina In addition to these 44 CFR 350 approvals, FEMA also provides interim findings to the NRC on the adequacy of offsite State and local govern-ment plans and preparedness within the context of the NRC-FEMA Memorandum of Understanding (December 16,1980, 4 5 FR 82713) . Interim findings are based on emer5ency tesponse plans and/or exercises. A Q .-
, . l statement of " reasonable assurance" is also provided in interim findings similar to such statements in the 44 CFR 350 approvals. Interim findings are prcvided routinely per request from 'the KRC for their licensing proceedings for commercial nuclear power plants. i
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Finally, stateme'nts of '" reasonable assurance" are also made in the F, eda Regional Director's review and evaluation of exercises in which the -
licensee, State, and local governments participate. The intent of such
- statements in this context is that the exercises demonstrate the capability of State and local governmente to implement their plans and preparedness.
- 1. Why was it necessary for the Regional Director to iscue a press release with that specific statement?
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RESPONSE
FEMA Regional Directors have authority to issue press releases that relate to activities and organizations -for which they are responsible within their Regions. There is no requirement that press releases be made on the results of joint exercises at commercial nuclear power plants.
- 2. Why is the June 1 date critical for distributing the brochure?
o Are posters to notify transients recuired by any existing regulations?
RESPONSE
Planning Standard G.I. of liUREG-0654, FEMA rep-1, Rev. 1. requires an annual dissemination of inforcation to the public. Brochures have been the means used to accomplish this dissenination around Indian Point.
For purpose of consistency with the exercisa requirement (1 year and 3 months), FEMA has chosen this to mean a distribution of the brochures -
must be accomplished within 15 months of the previous one, or June 1,
_, 19.83. .,
l While posters are not specifically required by NUREG-0654, they are l mentioned as one of the methods to inform the public.
Planning Standard G.2. of NUREG-0654 states, "The public information program l shall provide the permanent and transient adult population within the plune exposure emergency planning zone an adequate opportunity to become aware of the information annually. Signs or other measures (e.g. , decals, posted notices or other means, placed in hotels, motels, gasoline rA:tions and phone bo'oths) shall' also be used . . . ."
During the 120-day clock period, the Public Information Officer (PIO) Task Force comprised of the State, counties and utilities determined that posters would be an appropriate method to disseminate information to any transient population.
- 3. FEMA States that the deficiencies in Rockland and Westchester County plans to notify transients such as those in motel rooms using methods such as pos ters, etc. , leads to the conclusion that the
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Protective Response Planning Standard is nct met. As a practical matter, aren't most of those persons within range of the sirens, radio or TV EBS mess ages? Don't you think that motel operators will notify transients in their facilities? '
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, RESPONSE:
i FEHA does not at this time conclude that Planning Standard G of NUREG-0654 is'significantly deficient. Our statement is that if the brochures are not printed and distributed in Westchester County by June 1,1983 then the FEMA evaluation would be one of a significant deficiency.
FEMA hopes that all people in the EPZ would be able to hear the sirens if they are sounded and would recognize the need to turn to the EBS station for
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4 important emergency information. However, based on the spot checks at the March 9, '1983 exercise, the public appears generally not to understand the 4
meaning of the sirens, nor did they know that they were to listen to EBS.
Motel operators and their employees would, we believe, notify their guests of an accident at Indian Point. However, FEMA is concerned that written material is not available at hotels and motels to provide appropriate information to the operators or guests if an emergency or , accident occurs. The posters I
have- been printed and are being distributed for display. State and county efforts are~ ongoing.
- 4. 'On p. 35 in your conclusion you state that your proposed regulations .
"necessarily implies mutually supportive emergency planning arrangements by several levels of government." That is a concept I do not dis agree with; however, does this mean that each level of government must have its own plans which conforms to the " guidance of NUREG-0654"?- Or does ,
this mean that somehow the level of offsite emergency preparedness must meet the planning standards in the regulations and that " mutually supportive emergency plans" is the best, way to get there? .
RESPONSE: , , , . .
4 Each level of government (State and local) should develop mutually supportive emergency response plans Which conform to the guidance in NUREG-0654/ FEMA-REP-1, Rev. 1. Notwithstanding this basic principle, in cases where the State claims to have compensated for the absence of a local' plan in a State site-specific plan, FEMA will evaluate and pass judgment on the adequacy of such a plan. The requirement for State and local government plans is based on both NRC and FEMA rules, specifically 10 CFR 50.47, Appendix E and 44 CFR 350.5, respectively.
This means that both levels of government (State and local) should develop emergency response plans that conform to the planning standards and related criteria in NUREG-0654/ FEMA-REP-1, Rev.1, and that this is the best way we
, have found to assure that there are mutually supportive plans among offsite responding organizations. As stated above, it is not the only way that I adequate offsite preparedness could be achieved. FEMA believes that a State
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could, in selective and caref ully arranged situations, provide for the short- ,
comings of local planning and preparedness measures. In the Indian Point '
March 9,1983, exercise, for example, it was not that FEMA departed from this principle in regard to Rockland County participation but rather that the' State did not ad6quately demonstrate. compensatory measures by dedicating resources that go beyond one-tice exercise capability. .
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- 5. . On p. 35 and elsewhere in your April 14 report, you are critical .of
,, New York State for not requiring Rockland County personnel to participate in the drill. You find the State to be deficient in their compensating measures because their written procedures were not followed to the letter. Nowhere, however, do you comment 'on 1
the substantive itcue--that is, did the State personnel participating in the drill- demons.trate that. they were capable of substituting for County personnel?-
RESPONSE: **
'The brief written procedures that- FEMA has reviewed as compensating measures for Rockland County prt.vided only for the State to supplement County resources (management team) not supersede or substitute for them. '
FEMA agrees that the State generally performed well at the exercise in their management tean ce,4acity. However, FEMA has not seen any evidence ~ that the State has the resources necessary, stationed, locally, to substitute for those of Rockland County in responding to an accident in a timely fashion. More emergency workers would be required- to respond .
to an actual accident than to participate _ in an exercise.
- 6. To What extent is your deficient finding for New York State--
Rodkland County--due to shortcomings in actual perforLance, and to what extent is it due to the f act that procedures were not literally followed?
RESPONSE: .
The' deficiency in Rockland County is due to the f ailure of the State procedures to identify sufficient resources needed to supersede the county's non participation. The county has stated that it would respond to an actual incident. However, FEHA has not received or reviewed a 4
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plan acceptable to the county nor has FEMA been able to evaluate the county's capability to implement an acceptable plan. -
- 7. In Section 2.5 you state, with regard to Rockland County:
(a) Emergency ope' rations f acilities and resources were acceptable (b) Alerting and notifications of staffs were acceptable (c) Emergency operations management was good (d) Public alerting and notification were good (e) Public and media relations need improvement but were not inadequate 4
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. _13-(f)
Accident assessment was good (g) Realth, medical, and exposure measures were acceptable (h) Recovery and reentry measures were good
\ You then go on to say that in spite of the above acceptable f actors, '
actions to protect the public could not be judged adequately because the State filled in for the county and carried out some actions without a plan and because bus drivers do not have radios.
It appears to me that you have documented how -a State can indeed fill in for a county.
RESPONSE
All of the above items were acceptable based on observations at the exercise. However, FEMA, recognizes that the situation in Rockland County is unique, in that emergency workers are to be furnished by the State
' and are not necessarily drawn from the locally available emergenc?y response In order to ensure that personnel are available in adeq'uate identify where organiz ations .
quantity and can respond in a timely manner, the -plan cast timely manner.
In that the State has never developed a plan addressing a complete takeover of Rockland County's emergency
- 8. Are there any important safety functions which you feel could -
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not be adequately performed around Indian Point based on your knowledge of the of f site preparedness there?
RESPONSE
the ability of Rockland County and/or FEMA has serious reservations about ident the State without county participation to respond to an iactual
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dependent acc -
.. and the abili,ty of Westchester County to evacuate trans t individuals.
is FEMA's collective experience that
- 9. Wouldn't you say that it everyday emergency response capabilities, such as fire, police, State and local disaster resources, has been de=enstrated rather well at a large number of natural and man-made disasters, of ten with plans f ar less sophisticated and developed as those in New York?
RESPONSEt FEMA's local government collective kno.wledge of and extensive hat experi types of disasters and emergencies clearly supports However, the assertion in many t preparedness exists for a wide-range of contingencies. l com and visible hazards, such as flooding, fires , or nere recently , chemica Through its wide-range of emergency management programs, extremely FEMA spills.
has found that sophisticated technical information is in f act
usef ul to the mitigation of a d nresponse to " everyday" emergencies involving these hazards. Many of FEMA's more hasard-specific prograns (e.g. , the National Flood Insurance Program, Da= Safety Program, etc.) ,
provide just .this kind of technical information. If State and local ,
governments need this kind of tech ^nic'al support in 'd'ealing with " traditional" hazards, it is logical to provide it in connection with a radiological hazard where the technical aspects are generally much less known at the local level. Without added planning and preparedness efforts, the unique technical response proble=s which occur because of the radiological hazards in a nuclear power plant accident allow only partial transfer of a community's " everyday" emergency response capability to such an accident.
The President's Commission on the Accident at Three Mile Island (known as the Kemeny Commission) studied the planning, preparedness, and response capabilities that were exhibited in the Three Mile Island incident. The Commission's study revealed that a significant shortcoming demonstrated in this accident was the inability of the of fsite response organizations to ef fectively cope with a power plant accident.
This finding is su=marized in the Kemeny Co==1ssion report (pp. 15-16) as follows:
We found an almost total lack of detkiled plans in the local communities around Three Mile Island. It is one of the many ironies of this event that the most relevant planning by local authorities took place during the accident. In an accident in which prompt defensive steps are necessarf within a matter of hours, insufficient advance planning could prove extremely dangerous.
It is FEMA's position, therefore, that while State and local governments '
have repeatedly demonstrated an inherent preparedness for many types of .
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contingencies, this level of preparedness is not considered sufficient for ,
coping with accidents at nudl' ear power plants. Planning and preparedness for a power plant accident must demonstrate both sufficient attentien to .
technical detail as well'as the comprehensive planning aspects to assure adequate preparedness are represented by the criteria in NUREG-0654/ FEMA-REP-1, Rev.1, which are jointly approved by both agencies.
- 10. Is it possible that adequate preparedness can exist, without detailed plans? For example, is there adequate preparedness -
in the area to protect the public from chlorine barge accidents?
RESPONSE
Since questions 9 and 10 are related, the response to this question will essentially highlight the central assertions presented in our previous respo ns e.
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FESA is knowledgeable about State and local emergency planning capabilities and can assert from our experience that an inherent level ,
of preparedness exists with State and local governments for many types ,
I of contingencies. However, the degree to which this level of preparedness is determined to te adequate is mor~e of ten than not 'directly related to the extent which detailed preplanning was accomplished.
To determine the level of detail needed for planning for a specific type of emergency, it is necessary to caref ully exacine the risks, response actions and response organizations associated with this emergency in order to determine the level and extent of planning and preparedness needed.
Our answer to question 9 addresses the level and extent of planning and preparedness needed for nuclear power plant accidents and supports the need for detailed planning.and preparedness for such accidents as reflected in our joint (NRC-FEMA) guidance, NUREG-0654/ FEMA-REP-1, Rev. 1. We believe t'he degree of detail needed for these accidents, as reflected in our
. guidance, is commensurate with the risks, necessary res ponse organizations and inter-relationships of the participating organizations.
- 11. Are you aware that Rockland County personnel participated in an actual evacuation involving over 100 people earlier this month in a chemical f actory accident and, thus, demonstrated a capability to publicly and adequately react in an emergency? .
RESPONSE
FEMA was aware of Rockland County's ability to evacuate over 100 people a short time ago. Houever, we do have serious reservations about the -
County's ability to evacuate up to as many as 100,000 people without a plan, and without trained emergency response personnel on their role in this plan. ,
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What is the' status o!'FsSAs regulations 44 CFR 350?' Are t' hey
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final regulations yet?
RESPONSE
FEHA's rule, 44 CFR 350, has been published twice (June i4,1980, and August 19, 1982) in proposed form. While 44 CFR 350 is a proposed rule, it has served as the basis for FEMA policy and procedures for the review and approval of State and local emergency plans and preparedness for coping with the of f-site ef fects of commercial nuclear power plant accidents.
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B Language for the final rule has been draf ted taking into account the' comments on the August 19, 1982, version. It canr.ot be published in final form until the Commission acts on a staff propos al for a relaxation of the frequency of joint exercises by a change to 10 CFR 50. Since it -
is essential that the language of the NRC and FEMA rules on this subject be essentially the same, FEMA will determine its course of action for finalizing 44 CFR 350 af ter the Commission makes its decision.
- 13. In a real emergency; Rockland County seys that its resources would be available to the state. Given this, how do you justify criticizing the State.'.s 1.mplementation of compensating measures during the exercise based upon unavailability of County '
resources? (p. 36)
RESPONSES:
See responses to Questions 6 and 7. ,
Please contact me at 287-0176 if you have any questions regarding the above.
Sincerely,
^~
rd W . Krim.
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Assistant Associate Director
. Office of Natural and Technological
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Hazards
Enclosures:
- 1. Palladino Letter
- 2. Telephone Listing .
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