ML20028E383

Submission Re Revised Contentions on Commission Questions 3 & 4 Concerning Emergency Planning & Offsite Emergency Procedures.Certificate of Svc Encl

ML20028E383
Person / Time
Site:	Indian Point
Issue date:	01/06/1983
From:	Scheiner C WESTCHESTER PEOPLES ACTION COALITION, INC.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8301210279
Download: ML20028E383 (5)

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UNITED STATES OF AMERICA )

NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD I

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In the Matter of l 33 3120 m):03 Consolidated Edison Company [ Docket Number _.50-247SP of New York (Indian Point Unit 2) ; ,

Power Authority of the Stato  : Wr.CM of New York (Indian Point Unit 3) . Docket Number 50

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January 6 1983

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• WESPAC SUBMISSION REGARDING 1 0- REVISED CONTENTIONS ON Y7 ~ COMMISSION QUEST 70NS 3 6, 4 __

P.t The Westchester People's Action Coalition, Inc. (WESPAC) '

• T.~ spoligizes to the Board and the parties for missing the filing ia g date for supporting contentions on Commission Questions 3 & 4,

@ and hereby gives notice that WESPAC continues to support 'its original - I contentions filed'on December 1, 1981, for the reasons stated in 7'

the. bases for those contentions. .Nothing hasoccurred in the past 4 '7~

$. year which would have any effect on WESPAC's contentions.

3 Most emerqcncy workers have not. been trained. '

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Equipment has not been provided on an adequate j

scale. - 6 F'

l;;r Procedures are'ineffectivo and people arc ill-informed., ,

The Red Cross is unpropared to provide mass + care ' 'a .

[,W - in a matter ofthours.  !

The plan for transportation. dep~endent people is 'ic t P -

not adequatc. j f?,.~ ' % u m,. , ~~~. '

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• The nuclear facility';operat6rs ' are;not . trusted 'or 6 IE trustworthy, although they'are= relied on in the' ' '

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plan to trigger emergency procedures.

• The telephone system will bc intolerably stressed L -

during a radiological emergency.; People have not read and will not! obey-the_ih'.struction not to use the - o .

telephone. ~-

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• The nonds of deaf and?non- English speaking people has not been adequaLely__addrcssed. '

• Drills are not an effectivo means of evaluating preparedness, and,off.cctive. drills;are precluded by cost, public ignorance,yand the fact thd the

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circumstanceu of, a rehl caccident 'cannot be anticipated.

• The plan is based on fallacious assumptions of human behovior. -

• The plan relies on unworkable traffic routinos for the high density population density of Westetiester.

8301210279 830106 p3 ;e .oecsoseeem

• Plans for identifying and evacuating special needs populations are inadequate. The weakest and most vulnerable members of society would _

be left behind, or would be the last to leave.

WESPAC is prepared to support all the contentions in the Board Memorandum and Order (Formulating Contentions, Assigning Intervenors, and Setting Schedule) of April 23, 1982, for which WESPAC was assigned lead or contributing intervenor responsibility. These are as follows:

a a 3.1 Dmorgency planning for Indian Point Units 2 '

r n ,cmd 3 is inadequate in that the present plans do not meet any of-

the sixteen mandatory standards set forth in 10 C.F.R. -50.47 (b),

ir. nor do they meet the standards sot forth in Appendix E to 10 C.F.R.-

2f Part 50.

t; WESPAC with respect to New York State Radiological f emergency Plan and dcficicncies therein relating to notification, y communications, training, drills, equipment, and' procedures, hhd YN 3.2 Emergency planning for Indian Point Units 2 -

and 3 is inadequato in that the plans make erroneous assumptions

% about the response of the public and.of utility employees during E radiological cmergencies.

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WESPAC with respect to problems of local traffic f$k._ -

3.4 The Licenscos cannot be depended uponito notify the proper authoritics of an emergency promptly and' accurately

,- enough to assure effcetive response.

3.6 The emergency plans and proposed protective action do not adequately take into Occount the full' range!of accident p[t.

1 scenarios and meteorological conditions for. Indian Point Units 2 & 3.'

h',y , n WESPAC with respect to the impracticality of conducting

(, effective drills covering all likely conditions.

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gi 3.9 The road system in the vicinity of the Indian't T~ Point plant is inadequato for timely evacuation.

WESPAC with respect t'o Westchester County 4.3 There are no feasible of fsite emergency pro-Z. - cedures which can adequately protect the public. *

, WESPAC with respect to the impossibility of upgrading the road network in Westchester county.

4.4 The emergency plans should be upgraded by taking account of special groups wit.h special needs in emergencies. In par-3 ticular, provision must be mado for evacuating peopic who are depen-dont upon others for their mobility.

WESPAC with respect to Westcheset.er County T ,

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. 4.7 The present emergency planning brochures and

. _present means of alerting and informing the population of an emergency do not give adequato attention to problems associated with persons -

who arc deaf, blind, too young to understand the instructions, or.

who do not speak English. l q

WESPAC with respect to the present means of ' alerting and informing the population of an emergency. h 1 WESPAC wishes to emphasize the following contentions: ,

I) The plan relies on unworkable traffic. routings for the high I density population in Westchester County. O SEE BASES, CONTENTIONS OF TI!E WESTCHESTER PEOPLE'S - j I7, i ACTION CO-ALITION, DECEMBER 1,'1981, CONTENTION 5- 'l

, II) The plan for transportation dependent people is not adequate. _

3 P . BASES l r SEE BASES, CONTENTION 6, DECEMBER 1, 1981 j in addition:  ;

ut; ,1) Update Report.on the Status of Remedial Actions Cited in

..i the July 30, 1982 Intermin Fihdings on the Adequacy of Radiological-  !

I.', Emergency Response Preparation of. State and Local Governments atothe g- Indian: Point Nuclear Power Station, December 16, 1982', Prepared by

':- the Federal Emergency Manaqcmont Agencyi: Region II: '" Planning Standard i m J... remains significantly deficient...[T]he additional time required i g, military to respond cannot be judged by FEMA to be adequate toiprotecti i the public health and safety. .

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2) Letter, Alfred B. DelBello,to Chairman NunzioP'lladino,T a '

I .USNRC, December 5, 1982: "Our major problem remains the lack of a workable transportation component of tho' plan."

III) The public information and emergency notification needs of.

deaf and non-English speaking people have not-been adequately addressed.

BASES

1) The survey which concluded that there is no need to pro--

y duce an emergency planning brochuro in languages other than English

-.o was not reliable. It relied too heavilylon information from school' NL' districts. i -

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2) The person in a family who is most likely to be the non-English speaker would bc Lhe wife / mother, home alonc during the day and without transportation.

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3) The utilities have not. begun or prepared a special outreach '

program to " community, soc 161, and reli.gious leaders"! of the foreign U languago speaking community.

4) FEMA erroneously accepted the " outreach program for the i

non-English speaking residents" as an adequato solution ~to the public information deficiency. Even assuming that such a program is vigor-ously pursued (which assumption WESPAC challenges), the piogram would not aid non-English speaking residents or transients during an actual emergency, regarding notification or specific cmergency instructions.

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IV) Drills are not an effective means of evaluating preparedness,

- - and effectivo. drills are precluded by cost, public ignorance, and the -

fact that the circumstances of a real accident cannot be anticipated.

SEE BASES, CONTESTION 3, DECEMBER 1, 1981 V) The plan is based on f allacious assumptions of human behavior.

SEE BASES, CONTENTION 4, DECEMBER 1, 1981 VI) Plans for identifying and ovacuating special needs populatbns are inadequate.

SEE BASES, CONTEh"rION 6, DECEMBER 1, 1981 Respectfully submitted,

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, CERTIFICATE OF SERVICE Charles Scheiner I hereby certify thi.Six Co-Chairperson copies of this document, Westchester People's Action WESPAC SUBMISSION REGARDING Coalition REVISED CONTENTIONS ON 255 Grove Street COMMISSION QUESTIONS 3 & 4, White Plains, New York 10602 2

havo been sent by Express

- Mail to Ruthanne Miller, Law Clerk, Atomic Safety and Licensing Bcard, UShT , Washington, D.C., 20555. Other parties will

' be served by hand at the beginning of the hearings on January 10, 1983, and will be mailed to absent parties on that date.

t O e c u_&

Charlos Scheiner, WESPAC n

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.. OFFICE OF PUBLIC AFFAIRS NEWS St9894Rf J M14 W 20. 1983 l ". WASHINGTON--Two Washington State public utility districts have filed a $1-billion . ..

t damage suit in U.S.. Court of Claims. alleging Bonneville Power Administration

-illegally presstsid them to take part in the construction of two nuclear power - -

plants can::elled by Washington Public Power Sopply System. The Snohomish and Callan County districts allege that in the mid-1970s officials threatened to reduce or cut off future sales of electricity to the counties to coerde thts: into helping pay for building WPPSS Units 4 and 5. Wall Street Journal. 1/20.

. - TOLEDD--Operators at the Davis-Besse nuclear pdwer plant declared "an unusual avent" when a main steam isolation valve failed to close as a result of electrical.

problems. Toledo Edison said repairs on the unit, which shut down automatically. -

would take several days. Wall Street Journal. 1/20. .

NEW YORK--A Babcock & Wilcox engineer who is in charge of analyzing safety measmes testified in Federal court that if his guidelines had been sent out to operators

, of ihree Mile Island the accident there in 1979 never would have occurred, He said his guidelines were contained in a memorandum that described a relief valve ' -

incident at the Davis-Besse plant in Ohio. NewYorkTimes.1/20.

The Soviet's crippled nuclear-powered surveillance satellite is descending at a rate of two to three miles a day and a large part of it could fall .out of orbit -

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and spread radioactive debris over parts of Earth as early as this weekend, Li U.S. intelligence sources say. New York Times. Washington Post 1/20. .

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