ML20054F737

Response Supporting Ucs/Ny Pirg 820604 Motion for Reconsideration of Commission Ruling Allowing Interim Operation.Show Cause Order Should Be Issued.Certificate of Svc Encl

ML20054F737
Person / Time
Site:	Indian Point
Issue date:	06/08/1982
From:	Hartzman R, Scheiner C FRIENDS OF THE EARTH, NEW YORK CITY AUDUBON SOCIETY, WESTCHESTER PEOPLES ACTION COALITION, INC.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8206170267
Download: ML20054F737 (23)

Text

'

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSIONERS .

Nunzio J. Palladino, Chairman Victor Gilinsky John F. Ahearne . 4 1 070

.._~~

Thomas M. Roberts James Asselstine and - -

s.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Louis J. Carter, Chairman Oscar H. Paris Frederick J. Shon x

In the Matter of x x Docket Nos.

CONSOLIDATED EDISON COMPANY OF NEW YORK x (Indian Point Unit 2) x 50-247 SP x 50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK x (Indian Point Unit 3) x June 8, 1982 x

FOE /AUDUBON AND WESPAC'S RESPONSE IN SUPPORT OF UCS/NYPIRG MOTION FOR RE-CONSIDERATION OF COMMISSION RULING ALLOWING INTERIM OPERATION AND FOR ISSUANCE OF A SHOW CAUSE ORDER AGAINST LICENSEE'S, AND FOE /AUDUBON AND WESPAC'S PRESENTATION OF ADDITIONAL NEW EVIDENCE

1. On June 4, 1982, the Union of Concerned Scientists (UCS) and the New York Public Interest Research Group (NYPIRG) moved for reconsideration of the Commission's ruling permitting interim operation of Indian Point Units 2 and 3 pending the outcome of the Atomic Safety and Licensing Board investigation, O

T)D and for issuance of a show cause order against the Licensee's, prior to commencement of the evidentiary portion of the inves-tigation. In their submission, UCS/NYPIRG presented new evidence of deficiencies in emergency planning for the Indian Point nuclear power plants. Friends of the Earth, Inc.(FOE), the 8206170267 820608 PDR hDOCK 03000247 C PDR

• =

q New York City Audubon Society (Audubon) , and Westchester Peoples Action Coalition (WESPAC) are filing this response in support of UCS/NYPIRG's motion. In addition, FOE /Audubon and WESPAC present further new evidence of emergency plan

deficiencies which have come to light since filing of the UCS/NYPIRG motion. <

2. The Nuclear Regulatory Commission (Commission) in its order of January 8, 1981, which set the course for this proceeding and permitted interim operation of the Indian Point nuclear power plants, declared that when new evidence warranted interim relief, a different course of action in this proceeding could be ordered. Order of January 8, 1981 at p.3. FOE /Audubon and WESPAC are in agreement with UCS/

NYPIRG that the new evidence submitted by the latter parties demonstrates a woeful lack of emergency preparedness at Indian Point. The serious deficiencies in the Indian Point emergency plans described by the Regional Assistance Committee (RAC) of the Federal Emergency Management Agency (FEMA) in April and December of 1981 lead to the inescapable conclusion that there is no assurance that appropriate protective measures can and will be taken in the event of a radiological emergency a at Indian Point. Furthermore, local emergency plans are clearly inadequate and incapable of implementation, as emphasized by I

j the formal rejection on May 18, 1982 of the Rockland County i

Radiological Emergency Response Plan (CRERP) by the Rockland 1 .

County Legislature.

_3-

3. The evidence presented by UCS/NYPIRG would in

~

itself be more than sufficient to warrant interim shutdown of the Indian Point nuclear power plants and issuance of a show cause order. But new information just made available portrays a situation far more grave than previously apparent.

On March 3, 1982, a joint exercise of the emergency prepared-ness plans for Indian Point was held. Participating in the exercise were the Power Authority of the State of Pew York, owner of Indian Point Unit 3, and officials and agencies of the State of New York, and the Counties of Westchester, Rock-land, Orange, Putnam ati Dutchess. Findings were reported to FEMA which, on June 4, l'! J2 released its " Post Exercise Assessment," dated May 27, 1982. The Assessment reported that "Amont the four counties, nine functional areas were evaluated as weak." Post Exercise Assessment, at p.9-10. (a copy of the Executive Summary of the Assessment is annexed hereto as Appendix A) These substantial and significant deficiencies underscore the fundamental and overwhelming degree of inade-quacy of the emergency plans and the broad failure to meet the mandatory. standards of 10 C.F.R.850.47.

Among the deficiencies reported by FEMA are:

weakness in the means of alerting the public to a serious radiological emergency, in non-conformity with 10 C.F.R.550.47 (b)(6). Sirens did not sound or were inaudible to residents.

The backup system of notification by sound trucks was not even tested. There was a lack of public understanding of the mean-ing of the sirens, and a lack of notification of transients.

weakness in the public education program in non-conformity with 10 C.F. R. a50. 4 7 (b) (7) . Public education pamphlets were

,.4- .

ineffective. The public as a whole lqcked knowledge of -

radiological emergency preparedness, and, in particular were uninformed about protective actions and ERPA zones. Awareness l of the emergency procedures by the non-English speaking .

population was not demonstrated.

the minimal extent of participation by Rockland County's 4

police, fire and volunteer ambulance corps demonstrates the lack of success of the exercise in assessing the capability i of the second largest county to meet the standards set forth in 10 C.F.R.950.47(b).

weakness in recovery and reentry procedures for Orange County in non-conformity with 10 C.P.R. 850.47 (b) (13) .

- weakness of Westchester County's health, medical and exposure control capabilities in non-conformity with 10 C.F.R. 1 E50. 4 7 (b) (12 ) .

weakness in accident assessment capabilities for Rockland County and deficiencies elsewhere, in non-conformity with 10 C.F. R. 650. 47 (b) (9) .

inadequate backup for two key people in Putnam County, the CD Director and radiological defense (RADEF) officer, in non-j conformity with 10 C.F.R.550.47 (b) (1) .

weakness in emergency operations facilities and capacity for alerting and mobilizing staff in Rockland County in non-conform-ity with 10 C.F.R.850.47 (b) (5) and (8).

weakness in 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capability to determine exposure of emergency workers in Westchester County in non-conformity with 10 C.F. R. 05 0. 4 7 (b) (11) .

i

_s-serious deficiencies in communications capabilities among

~

state and local emergency response facilities in non-conform-ity with 10 C.F.R. 350.47 (b) (6)

These observations are just 2 sample of the range of serious deficiencies that exist in emergency preparedness as revealed by the FEMA Post Exercise Assessment. But they do demonstrate that the emergency plans are basically inadequate and incapable of implementation. These are not deficiencies which can be corrected through remedial action procedures.

If effective emergency preparedness is at all possible, at a minimum, fundamental revision of the plan itself is a stark necessity.

4. The information contained in the letter of June 2, 1982 from Alfred Del Bello, Westchester County Executive, to Commission Chairman Palladino, and in the departmental comments attached to his letter, provide further evidence that major deficiencies in emergency preparedness exist in Westchester County. County Executive Del Bello stated that his trans-portation professionals are of the opinion that evacuation plans will not work as currently drafted. Letter, p.2. The l

County Executive also indicated that funding for radiological

! equipment, training, and communications systems needed to make

{

the potentially workable aspects of the plan implementable in fact, is " grossly inadequate." These are only two major deficiencies among those reported in these ma.terials.

l 5. The sum of this new evidence and that presented to the Commission by UCS/NYPIRG patently warrant a changed course of action in this proceeding. Continuation of the evidentiary I

l hearing without a show cause order wil1 be redundant and wasteful, and will unnecessarily delay a definitive decision by the Commission. While it is our contention'that no feasible emergency measures can protect against the long term consequences of a serious accident at Indian Point, it is now~ crystal clear that the responsible parties have repeatedly failed to meet their obligations under existing emergency regulations to develop effective plans to deal with the immediate exigencies of an accident at Indian Point. Further

" preliminary" investigative hearings are unnecessary to demon-strate the inadequacies and dangers at Indian Point. The known facts compel issuance of a show cause order and interim suspension of operations at the power plants.

6. Nor can the triggering of the 120 day clock be expected to remedy the lack of emergency preparedness. This mechanism was used once without any results, as borne out by the December 31, 1981 RAC Review, the May 27, 1982 FEMA Post Exercise Assessment, the rejection of emergency plans by Rockland County, and the submissions of Westchester County Executivd Alfred Del Bello. This evidence irrefutably demon-strates that the August 24, 1981 NRC conclusion that deficiencies in Indian Point emergency plans had been " resolved satisfactorily,"

was mistaken and misguided. To try the 120 day clock a second time in the face of continuing deficiencies which render the emergency plans fundamentally inadequate and incapable of implementation, would be to disregard the long delayed and immediate need for providing for the safety of those living and 1

_ - - - -- 1

working in the vicinity of Indian Point. This situation can only be remedied through a show cause

• order and interim shutdown of the Indian Point nuclear power plants.

WHEREFORE, FOE /Audubon and WESPAC request, in support of the UCS/NYPIRG motion, and upon the basis of the' additional new evidence presented herein, that the Commission issue an order to show cause why the licenses for Indian Point Units 2 and 3 should not be revoked, and directing the interim

suspension of the operation of said nuclear power plants.

Respectfully submitted, i

fc RICHARD M. HARTZMAN, Esq.

Counsel for FOE /Audubon

. Friends of the Earth, Inc.

208 West 13th Street New York, New York 10011 l

/ -

SAfll CHARLES A. SCHEINER Co-Chairperson Westchester People's Action Coalition, Inc.

P.O. Box 488 White Plains, New York 10602 Dated: June 8, 1982 o

NPENDix -

A-

• g

,_______m_,

W e5 e

i POST EXERC SE i e

! ASSESSMENT l Essssssssssssssssssssssssssssssss f

Exercise of the New York State and Westchester, Putnam, Rockland and Orange Counties Raciological Emergency Plans for INDIAN POINT NUCLEAR 3ENERATIN'3 STATION M AY 2 7,19 8 2 Federal Emergency Management Agency Region 2 FRANK P. PETRONE 26 FEDER AL PLAZ A Regional Director New Yo rk, N.Y.10278

,o . . .

TABLE OF CONTENTS ,

e -

Page

1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . I

1. FEMA Responsibilities . . . . . . . . . . . . . . . . . . . I

2. Exercise Event. . . . . . . . . . . . . . . . . . . . . . . 2

3. Excrcise Objective. . . . . . . . . . . . . . . . . . . . . 2

4. Participating State and Local Organizations . . . . . . . . 4

5. Exercise Critique . . . . . . . . . . . . . . . . . . . . . 6

6. RAC Evaluation Objectives . . . . . . . . . . . . . . . . . 6

7. Federal Observer Team . . . . . . . . . . . . . . . . . . . 6

8. Evaluation Criteria . . . . . . . . . . . . . . . . . . . . 8

9. Remedial Action Procedures. . . . . . . . . . . . . . . . . 8

10. Review and Approval Procedures. . . . . . . . . . . . . . . 9 II. EXECUTIVE

SUMMARY

. .. . . . . . . . . . . . . . . . . . . . . . 10

1. Ove rv iew. . . .. . . . . . . . . . . . . . . . . . . . . . 10

2. Summary: State Activities. . . . . . . . . . . . . . . . . 11

3. Summary: Indian Point Emergency Operating Facility . . . . 12 4 Summary: Westchester County. . . . . . . . . . . . . . . . 13

5. Summary: Rockland County . . . . . . . . . . . . . . . . . 14

6. Summary

Orange County . . . . . . . . . . . . . . . . . . 15 t 7. Summary: Putnam County . . . . . . . . . . . . . . . . . . 17 III. EXERCISE SCENARIO. . . . . . . . . . . . . . . . . . . . . . . . 20 IV. EVALUATIONS AND RECOMMENDATIONS. . . . . . . . . . . . . . . . . 21

1. State . . . . . . .. . . . . . . . . . . . . . . . . . . . 21

2. Emergency Operating Facility. . . . . . . . . . . . . . . . 24

3. Westchester County. . . . . . . . . . . . . . . . . . . . . 27 4 Rockland County . . . . . . . . . . .. . . . . . . . . . . . 39

5. Orange County . .. . . . . . . . . . . . . . . . . . . . . 48

6. Pu t n am Coun t y . . . . . . . . . . . . . . . . . . . . . . . 56

7. Dutchess County . . . . . . . . . . . . . . . . . . . . . . 67 V. CORRECTIVE ACTION FOR DEFICIENCIES . . . . . . . . . . . . . . . 68

1. Scheddle for Correcting Significant De fic ienc ie s . . . . . . 68 k

-- - ~ ---- - - ,., -- -

, . ~ ~ , - . - , . , - - - - - - . . .

10 II. EXECUTIVE

SUMMARY

e -

A joint exercise of the emergency pr e pa red ne s s plans fo r the Indian Point site was held on March 3, 1982. The of f-site exercise was observed by a team of 50 federal observers, who re po rted their find ing s to the Fed eral Emergency Management Agency (FEMA) . Pa r t ic ipa t ing in the exercise we re the owner of Indian Point Unit 3, Power Authority of the State of New York (PASNY), of ficials and agencies of the State of New York, and the counties of Westchester, Rockland, Orange, Putnam, and Dutchess.

Emergency response facilities observed by FEMA included:

e the Indian Point Emergency Operations Facility (EOF);

i e the state Emergency Operations Center (EOC) in Albany; -'

e the state EOC in the Of fice of Disaster Preparedness, Southern District; e the Westchester County EOC; e the Rockland County EOC; e the Orange County EOC;  ;

e the Putnzs County EOC; e the Dutchess County EOC; and e the Emergency News Center in Verplanck.

The Dutchess County EOC also chose to pa r t ic ipa te in the exercise, although it is not within the 10-mile emergency planning zone.

Evaluators also observed procedures at pe r sonnel monitoring centers, at reception / congregate care centers, and at hospitals where simulated acci-dent vic t ims were treated .

1 over 50 state, local, and private agencies and departments participated in the exercise.

1. Overview During the review of the exercise, each of the ten functional areas d esc ribed in section I.6 were evaluated fo r the state operations and each of the four mun ic ipal counties' operations (except Dutchess). At the state level, all observed func t ion s were carried out well; only minor deficiencies were noted. Among the four counties, nine functional areas we re evaluated

11 I

i l as weak. Th e se de fic ienc ie s , po s i t ive areas of pe r fo rma nc e , and corr,ec-tive reconmendations are detailed in the sunmar ie s prov id ed below and in the following pages.

Several concerns we re id ent i fied dur ing the exercise that in flue nc ed the evaluation of that element. Some of these concerns are identified below, e The primary means for alerting the populace to a serious radiological emergency will be a system of sirens. This system is now being installed and is to be tested by the l'icensees. The existing sirens were activated during the exercise, but some of the units did not sound or were inaudible to local residents. The backup system of noti-fication by sound trucks (police / fire trucks equipped with public address systems) was not used.

e Rockland County's police, fire and volunteer ambulance corps initially chose not to participate in the exercise, .. (

claiming that inadequate training had been provided. During the exercise these groups participated, but to a minimal extent, thereby reducing the training benefit of the exercise and the ability to fully evaluate the county's preparedness, e The ef fectiveness of the existing radiological public educa-tion program should be strengthened. Currenti*, pub lic education on radiological emergency procedures relies on distribution of pamphlets to residents. Concern remains as to the level of public awareness and response. The se concerns include the public's understanding of the concept and geographical boundaries of planning zones. Also, the level of awareness of the non English-speaking residents l iv ing in the area should be analyzed.

2. Summary: State Activities Emergency Operations Facilities and Resources. Fa c il it ie s and resources in 'the state EDCs in Albany and Poughkeepsie were good. Di s pl ays were wa ll placed and promptly u pd a t ed . Some additional plotting of dose l

calculations is recommended. Th e commun ic at ions between state and local accident a s se s sment te ams we re we a k . Internal commun ic a t ions and public in fo rma t ion arrangement s were good .

Alerting and Mobilization of O f ficials and Staf f. All mob il iza t io n ac t iv i t ie s functioned well.

12 Emergency Operat ions Management. Management of the response organiza-

• e .

t ion was well demonstrated. Increased fl ow o f in fo rmat ion in both directions between agencies and decision-makers would be beneficial.

Publte and Media Relations. At the state EOC in Albany, press f ac il i-t ies and media briefings were good. At the Joint Media Center, the state PLO staf f demonstrated good capability.

Accident Assessment. Ac cid ent a s se s sment capabilities were good.

However, the state did not demonstrate their own independent field monitoring capability. Some additional computational aids would be-of value.

Recovery and Reentry. Short-term and long-term recovery and reentry procedures appeared to be good.

Relevance of the Exercise. Participants felt that the exercise was beneficial for training and experience. Use of simulated meteorology and the rapid pace of scenario events detracted somewhat frorn the realism of the exercise.

3. Summary: Indian Point Emergenev Operating Facility (EOF)

Emergency Operations FaciS.ities and Resources. We EOF in Buc hanan had acceptable capabilities; however, space was limited and inconveniently arranged. Internal and external commun ic a t ion systems could be im p rov ed .

Alerting and Mobilization of Of ficials and Staf f. Staf fing and notifi-cation was acceptable. Add it ional feedback f rom the state and counties to the EOF would be o f bene'it.

Emergepey Operations Management. Management of the re s po nse was good for state representatives and acceptable for the ecunty representatives. More involvement of the state and county in decision making is reco= mended.

l i

i Accident Assessment. Capabilities in this area were acceptable.

Computing capability for rapid response is recommended. Improvement is needed in use of monitoring data.

l Relevance of the Experience, he exercise was felt to be beneficial to i

l the participants.

l I

I I

I L

13

l. . Summarv: Westchester County e *

, Emergencv Operations Facilities and Rescurces.

• Th e facilities at

the We s t c he s t e r County EOC were good overall.

Th e working space was small 1

g but adequate because of the layout. Commun ic a t ion , internal and external, was good. Backup RACES communication capability was demonstrated. Displays and maps were well organized and security was good.

Alerting and Mobilization of Of ficials and Staff. Westchester County demonstrated a good capability for alerting and mobilizing officials and staff in a timely manner. This resulted from good communications and from adequate procedures and backup personnel. The capability for 24-hour alerting and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day operation was good. The re is some concern over the avail-ability of enough persoinel to adequately staf f the reception centers if an actual emergency started an a weekend.

Emergency Operations Management. Emergency operations management, headed by the County Executive, was very good, and demonstrated well-defined leadership at several levels. Th e staff was kept well in fo rmed through periodic brie fings by the leaders.

Public Alerting and Notification. Public alerting and notification actions were weak, due primarily to the unsatisfactory pe r fo rmanc e of the siren system. Lack of understanding by some of the populace of the meaning of the sirens; lack of knowledge of the emergency response planning areas (ERPA);

and lack of adequate notification of transients were observed. The procedures for broadcasting EBS messages were very good; EBS messages we re we ll wr it ten and timely. Ac tivation o f EBS s tation and issuance of first EBS message were excellent.

4 Public and Media Relations. The public and media relation actions were acceptable, however, public education programs and rumor control procedures need im p r ov em e n t . Public education pamphlets were mailed and received by rate payers, but apparently were not e f fec t ive, because the pub lic as a whole seemed to have a general lack of knowledge of radiological emergency prepared-ness. People sto do not pay utility bills directly, such as some tenants, may not have rec e iv ed the pamphlets. Emergency in fo rmat ion. wa s not po s t ed , nor was it printed in the telephone book.

Accident Assessment. Ac c id en t assessment capabilities were evaluated as acceptable but some de fic ienc ie s are noted. Th e rad io log ic al assessment t

14 instrumentation was good, except that the instrument used for measuring e =

r ad io iod ine should be equipped with a silver-containing air filter. Pro-c ed u r e s for quickly measuring contamination in liquid samples are needed.

Projected dose calculations were good, and field monitoring teams we re we ll trained and capable. The ability to recommend protective actions based on the protective action guidelines was well demonstrated.

Actions to Protect the Public. Overall, the Westchester County person-nel demonstrated an acceptable capability to protect the public by implement-ing protective measures. Improvements are needed in the details of the procedures for relocating residents who do not have private vehicles, in protecting mobility-impaired persons, and in dealing with po tent ial imped i-ments to evacuation.

Health, Medical, and Exposure Control. Mo s t of the health, medical, and exposure control c.pabilities were weak. The 24-hour capability to decemine exposures of emergency workers was weak. because of instrtsoentation problems, wh ile decontamination procedures were weak primarily because of a lack of adequate vaste d is po sal , especially for liquid wastes. Control of access to evacuated areas was good, and maintenance of dose records was good. Ac t io n levels that require decontamination procedures were well established.

Recovery and Reentry Operations. Simulated reentry operations made it appear that the capability to recover and reenter exists.

Relevance of the Exercise Experience. Participants felt that the exercise was a good learning experience.

2

5. Summary: Rockland County Emergency Operations Facilities and Resources. The facilities at the Rockland County EOC were weak. Significant d e fic ienc ie s were noted relating to external and internal communications, leadership in the EOC, and space allottment.

Alerting and Mobilization of Of ficials and Staf f. The capability for alerting and mobilization of staff from the EOC was weak. De fic ienc ie s were noted related to the lack of telephone lines and staf f to perfom initial c a l l ing . Backup staff was also lacking. Overall improvement in communica-t ion s is needed.

I '

, 15 Emergenev Operations Management. . Or gan i z,a t ional control, leadership, e

and decision making s.e r e acceptable. However, e f fec t ive management. o f the EOC by one individual was not d em on s t r a t ed . More familiarity is needed with response procedures. .

i Public Alerting and Notification. In it ial notification of the ' public i

was weak, primarily because of siren system malfunction. . Activation of the

EBS station and issuance of the first EBS message were well coord inated .

EBS messages were professionally coordinated, cleared, and issued.

. Public and Media Relations. Media capabilities were acceptable.

However, public awareness of a public education brochure was low. Rumor f

control needs to be strengthened. There may be a need to translate the brochure in order to reach non-English speaking individuals.

a j Accident Assessment. Ac c id en t assessment capabilities were weak. Poor j communication systems contributed to problems in this area. Field monitoring teams need more training with their instruments. The role of the county representative at the EOF needs to be better defined.

Actions to Protect the Public. Ca pab ilit ie s fo r protection of the pub l ic were good. Evacuation and decontamination were well demonst rated .

4 Health, Medical, and Exposure Control Measures. The se ac t ivit ie s we re well demonst rated . Facilities were good and well staf fed.

J Fecovery and Reentry Operations. The capability of the EOC for recov-

) ery and reentry was good, as demonstrated by simulation. Ac t iv it ie s in the field were not observed, due to the shortness of the scenario. I I

Relevance of the Experience. Lack of involvement by some local agen- i cies reduced the ef fectiveness of the exercise. Th e inclusion of a simulated wind shift in the scenario was good, but the county's computer analysis system was not used during the exercise.

Th e exercise id en t i f ied areas that would benefit from additional training and better equipnent.

4

6. Summary: orange County Emergenes Operations Facilities and Resources. Th e facilities at the Orange County Emergency Operating Center (EOC) were evaluated as acceptable.

I 4

. s, .,,..w-,r----m.-----,-. -,y..., .

,-..-,,,,,,,,__,,,,._.w,,.- -

, ,,.,.-------,,,.7-.._,y.-y---,r,r-_,m%-m-,

10 I

, Some deficiencies were noted, particularly gith the commun ic a t ion sy' stem j linking Orange County with the other counties. Internal commun ic a t ion s systems could also be improved. Maps and displays were generally good.

Acceptable security was provided.

Alerting and Mobilization of Officials and Staff. The overall capa-bility for alerting and mobiliza t ion was evaluated as we ak , based upo n a d e fic iency in the key element of 24-hour shift change capability. Backu p personnel did not d emons t rate suf fic ient knowl ed ge in all essential areas.

The remaining elements in this category were in general ad equa tely d emon-strated, although poor commun ic a t ions between ag enc ie s in the EOC led to difficulties in establishing access control points.

Emergency Operations Management. Organizational control, l ead er ship ,

decision making and suppo rt by o f fic ials we re acceptable. Pe r fo rmance was a f fec ted by internal commun ic a t ions in the EOC, which d epend ed upon hand-carrying me s s.sg e s between rooms in the facility. Briefing of agencies was sporad f c and written updates were not always available.

Recept ion centers, congregate care f ac il it ie s , and the decontamination center were well staf fed and organized.

Public Alerting and Notification. Public alerting and no t i fic a t ion we re weak, due primarily to the un sat is f ac tory pe r formance o f the siren system. The EBS was activated in a timely manner. Th e first EBS message was coordinated with the siren sounding. Procedures for issuing EBS messages were good.

Public and Media Relations. The capability for dealing with the media was go'od. Rumor control need s to be strengthened. Pub lic educ a t ion programs also should be strengthened.

Accident Assessment. Ca pab il i t ie s fo r ac c id en t assessment we r e rated as acceptable. De fic ienc ie s noted inc lud ed the failure of the field monitoring teams to carry full instrumentation.

Actions to Protect the Public. Means fo r sheltering or evacuating the public were evaluated as good. All observed facilities were well staffed.

Lack o f data on rad io iod ine levels in the field were believed to af fect decisions for public protec t ion.

3

17 .

, Health, Medical, and Exposure Control Measures. Procedures for medital treatment and exposure control were evaluated as acceptable. De fic ienc ie s noted inc lud ed the lack of provision for d i s po sa l of contaminated wastes.

Hospital personnel need additional training. Permanent dose recording instru-ments were not available for emergency workers.

Recovery and Reentry. Recovery and reentry procedures were evaluated as weak. The significant deficiency related to the lack of full simulation by participants.

Relevance of the Experience. Th e exercise seemed to provide an acceptable level of experience. One ' drawback noted was that some re s ponse teams were not fully tested, while others were tested on skills that we re considered routine.

7. Summary: Putnam County .

Emergency Operations Facilities and Resources. The working space in the Putna:n County EOC was cramped, which resulted in some minor discomfort to the staff. The overall functioning of the EOC was good in spite of the small size, because the management was good. Communication systems were good, and had good backup.

Alerting and Mobilization of O f ficials and Staff. Putnam County demonstrated an acceptable c a pab il it y for alerting and mobilizing o f fic ials and staff. The procedures used would have been ef fective at any time during the day or night , and resulted in a prompt and timely activation of the EOC and field monitoring teams. A capability for continuous operations 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day was well demonstrated by executing a shift change and by exhibiting lists o f backup persennel. This shift change revealed that two key people, the CD Director and the radiolo;ical defense (RADEF) officer, do not hav e adequate backup. An emergency generator was not available in the event of power failure.

Emergenev Operations Management. Th e manag ement of the Putnam County EOC was very good and was well supported by elected of ficials. Many s pecific -

organizations had well-defined roles and demonstrated good pe r fo rmanc e.

i.eadership was excellent and suppo rt by the RACES organization was excellent.

s  ;

! i.

Public Alerting and Nottitcation. Pub l i.c alertsng and notif tCat)on e

we re we ak , due primarily to the un satisf actory per formance of the stren system. Ac t iv a t ion of the E85 station and issuance of first E85 message were good. Other ESS messages were cleared and issued on a timely basis.

Some route alerting by police and fire vehicles was simulated but no FA announcement s were made. Deficiencies were noted in the ability to notify the transient po pula t ion.

Public and Media Relations. The capability for public and media relations la putnam County was acceptable overall. Public education brochures were sailed to the pub lic , and public training courses were given by the fire department and RACES personnel. Nevertheless, there appears to be a need for additional education to help the public understand protective actions and ERFA sones. The F10 of ficer had good access to all information, and prepared t imely and appropriate relea se s. There was no ev id ence of a coord inated ef fort to identify and control rumors.

Accident Assessment. Accid ent as se s sment capabilities were evaluated as acceptable; however, some deficiencies were noted. Initial projections of radiological esposure were ande independently in a timely manner and confirmed the utility projections. Field monitoring temas were promptly deployed, and were very competent. The instrumentation for thole body ganea ray was good.

However, there was no capability for measuring rad ic iod ine. - Silver-loaded filters are needed to provide capability for seasuring radioiodine.

Actions to Protect the Public. Putnas County d emon s t r a ted a good capability to pro t ec t the public. Roadblocks were set up promptly. Orders were given in a timely manner for the actions to simulate sheltering and then evacuation. A bus load of stud ent s was evacuated (in actuality) to the cong'egate care center in Dutchess County. This was well done. The cong re-gate care centers were well located, well sta f fed , and well equipped. The ir procedures were good; however, the radiation sonstortag personnel could I benefit frors aJditional training.

Health. Medical, and Euoosure Control. Overall, the health, medical, and esposure control actions were acceptable, with the except ion of the proceJures fo r ulttiste d i s po sal of contaminated Itquids. Direct r eaJ ang l

r t

l l

4 i

i t

I

19

\

Josimeters suppl ied to emergency wrkers had approprtate ranges and sengi-tivities. Re ad ing s were made and rec o rd ed frequently, and the results r epo r t ed by radio to the EOC. No pe rmanen t- r ec o rd dosimeters were provided.

Procedures for approval of exposure of emergency workers in excess of protec-tion action guides need to be clarified. Ac t ion levels for decontamination

'f procedures were known.

t Recovery and Reentry Operations. Reentry operations were demonstrated by simulation only. An acceptable capability for reentry and recovery appears to exist.

l Relevance of the Exercise Experience. The re was un an imous ag reement that the exercise was very beneficial to the pa r t ic ipan t s , all of whom took

the exercise very seriously and pe r fo rmed as if the powe r plant acc id ent actually occurred.

l  :

I l

1 A

i

UNITED STATES OF AMERICA NUCIl%R REEUIATORY CXM,iISSION -

BEFDRE 'I1E A10MIC SAFEIY AND LICENSING DOMtD  ; , f/

. a

,p In the 145tter of )

~

) Docket Nos. 50-247 SP CONSOLIDAIED EDISON COMPANY OF NEW YORK ) 50-286 SP (Indian Point Unit 2) )

)

POWER AUI10RITY OF 11E STATE OF NEN. YORK )

(Indian Point Unit 3) )

Certificato of Service I hereby certify that copies of:

FOE /AUDUBON AND WESPAC'S RESPONSE IN SUPPORT OF UCS/NYPIRG MOTION FOR RE-CONSIDERATION OF COMMISSION RULING ALLOWING INTERIM OPERATION AND FOR ISSUANCE OF A SIIOW CAUSE ORDER AGAINST LICENSEE'S, AND FOE /AUDUBON AND WESPAC'S PRESENTATION OF ADDITIONAL NEW EVIDENCE tuve been served on the official minimum service list for the above

( captioned proceeding by depositing in the United States nuil, first class, this STII, day of JUNE, 1982.

l A

/

,e d 4 2- cA RICliARD M. HARTZMAN'"

Friends ofithe Earth, Inc.

208 West 13th Street New York, New York 10011 (212) 675-5911

(

l l

UNITED STATES OF AMER 4CA NUCLEAR REGULATORY C0tHISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD _ j'

7 In the Matter of: Docket Nos. 50-2'47 SP CONSOLIDATED EDISON COMPANY OF 50-286 SP NEWYORK(IndianPoint, Unit 2)

POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit 3) f

)

SERVICE LIST Louis J. Carter, Esq. , Chairman Paul F. Colarulli, Esq.

Administrative Judge Joseph J. Levin, Jr. , Esq.

Atomic Safety and Licensing Board Pamela S. Horowitz, Esq.

7300 City Line Avenue Charles Morgan, Jr. ,'Esq.

Philadelphia, PA 19151-2291 Morgan Associates, Chartered 1899 L Street, N.W.

Dr. Oscar H. Paris Washington, D.C. 20036 Administrative Judge Atomic Safety and Licensing Board Charles M. Pratt, Esq.

U.S. Nuclear Regulatory Commission Thomas R. Frey, Esq.

Washington, D.r.. 20555

• Power Authority of the State of New York Mr. Frederick J. Shon 10 Columbus Circle Administrative Judge New York, N.Y. 10019 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Ellyn R. Weiss, Esq.

Washington, D.C. 20555

• William S. Jordan, III, Esq.

Harmon & lleiss Brent L. Brandenburg, Esq. 1725 I Street, N.W., Suite 506 Assistant General Counsel Washington, D.C. 20006 -

Consolidated Edison Co. of New York, Inc. Joan Holt, Project Director 4 Irving Place Indian Point Project New York, N.Y. 10003 New York Public Interest Research Group flayor George V. Begany 9 l'urray Street Village of Buchanan New York, N.Y. 10606 236 Tate Avenue Buchanan, N.Y. 10511 i

=

John Gilroy, Westchester Coordinator Indian Point Project New York Public interest Research Group 240 Central Avenue White Plains, N.Y. 10606 Marc L. Parris, Esq.

Jeffrey M. Blum, Esq. Eric Thorsen, Esq.

New York University Law School County Attorney, County of Rockland 423 Vanderbilt Hall 11 New Hempstead Road 40 Washington Square South New City, N.Y. 10956 New York, N.Y. 10012 Geoffrey Cobb Ryan Charles J. Malkish, Esq. Conservation Committee Litigation Division Chairman, Director The Port Authority of New York City Audubon Society New York and New Jersey 71 West 23rd Street, Suite 1828 One World Trade Center New York, N.Y. 10010 New York, N.Y. 10048 Greater New York Council on Ezra I. Bialik, Esq. Energy Steve Leipsiz. Esq. c/o Dean R. Corren, Director Environmental Protection Bureau New York University New York State Attorney 26 Stuyvesant Street General's Office New York, N.Y. 10003 Two World Trade Center New York, N.Y. 10047 Honorable Richard L. Brodsky Member of the County Legislature Alfred B. Del Bello Westchester County Westchester County Executive County Office Building Westchester County White Plains, N.Y. 10601 148 Martine Avenue White Plains, NY 10601 Pat Posner, Spokesperson Parents Concerned About Andrew S. Roffe, Esq. Indian Point New York State Assembly P.O. Box 125 Albany, N.Y. 12248 Croton-on-Hudson, N.Y. 10520 Janice bbore, Esq. Charles A. Scheiner, Counsel for NIC Staff Co-Chairperson Office of the Executive Westchester People's Action Legal Director Coalition, Inc.

U.S. Nuclear Regulatory Ccrimission P.O. Box 488 W'

a shington, D.C. 20555 White Plains, N.Y. 10602 Honorable Ruth Messinger Lorna Salzman Member of the Council of the Mid-Atlantic Representative City of New York Friends of the Earth, Inc.

District #4 208 West 13th Street City Hall New York , N.Y. 10011

)

New York, N.Y. 10007

Alan Latman, Esq. Ms. Amanda Potterfield, Esq.

44 Sunset Drive P.O. Box 384 Croton-on-Hudson, N.Y. 10520 Village Station New York, NY 10014 Zipporah S. Fleisher West Branch Conservation Renee Schwartz, Esq.

Association Paul Chessin, Esq.

443 Buena Vista Road Laurens R. Schwartz, Esq.

New Ci ty, N.Y. 10956 Margaret Oppel, Esq.

Botein, Hays, Sklar & Hertzberg Judith Kessler, Coordinator 200 Park Avenue Rockland Citizens for Safe Energy New York, NY 10165 300 New Hempstead Road New City, N.Y. 10956 D. Whg David H. Pikus, Esq. New York State Public Service g ,,t,,1g, Richard F. Czaja, Esq.

330 Madison Avenue 3 2pire Plaza New York, N.Y. 10017 Albany, NY 12223 U Nu e Regula r A 8" "Y n

Washington, D.C. 20555

• U.S. Nuclear Regulatory conmission Atomic Safety and Licensing Appeal m s % 2n, D.C. 20555 Board U.S. Nuclear Regulatory Comission Washington, D.C. 20555

• Docketing and Service Section Office of the Secretary -

U.S. Nuclear Regulatory Comission Washington, D.C. 20555

• 4

. - - - , - .