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Urges FEMA Update Rept Be Given Consideration in Decision To * . DOMETED T:NRC Iliance to CLOSEIndiaryRpiel , PO Box 1'" Crotorvon-Hudsen, N.Y. 10520 (914) 271-4074,or 27,1532(,. c . my: Mr.lif t.u e. SEF!CE | Present Members: Artists for a Safe World, Brtarcliff Citizens Concemed About indlan Point, Croton Parents Concemed AboutIndian Patrjt,k,pj i Greater ouining Neighborhood Action Group, Lakeland Citizens Concemed About Indian Poent, Mt. Piessant Citizens Concerned About Indian Point, Neighborhood Action Group, Neighbors of Indian Point to Close indlan Point, North Rockland Alliance on Nuclear oanger, Peeksluti |' Residents Against Indian Point Putnam Valley Neighbors to Close indlan Point Now, Rockland Citizens for Safe Energy, Rockland Famihes to j Ciose indian Point, west Branen Conurution Apociation, Westchuter Peoples Action Coalition, Women's infomational Lugue for Puce ' and Freedom,Yorktown Parents Concemed About Indian Point. .and growingl Decenber 22, 1982 - C1 z. : rr.;a n llu'. :i o t'a .1 a c i a c Octaissicnec John Ahearne Cornis sioner icaes T sseis tinc r anrri s s i o n e r "i c to '',i l i n s k y C mmissionar Th er.a r le;e r ts ' I;ni;ed Stetn t'ucl ea r negu ir to y Ca.7:ais s i c i ;717 " I t '- s t re i.: '. h.U. 0::r." T,'m Mr t1 >,' 3 O i n ] c o 1 D.C. 2WS PROD. & UTILY Ch'd' ' " * - SsdEb SP', 9ea r Comniissi cne: s : Tre All'ence tc l'.'ese incian Poi n i; co..s is ts o" 18 gi a r s- i on ti creurs oricF have s 3runo up in the a *ea a * ound the recctors : r. .uchanan, hen Yt; k. Tour o# the gecups , Pa rents Concerned /.;'Ou t % iac Point, W E' ', C , Wes t i ra r'.h C on s e rv.c t i on As s c i a t i on , and ".ock- l ace Ci ti za"s for isfc Er.ergy, a re i r tervenors ii the ' terent A trtic Scfety ar.d Lir.enring Board t r. vt s ti ga t i rn inte the " risk t, inci- v id uls, livir.g in# the n cini ty ref the ladian Poin t si + n, i r. c l u d : r. n '. h d t resUitinc - 1CU I C # e v a C u a t 'i * n in - t.a.' asis acced, te_n tneJemarcncum.t'/ Gif#k n_.aM Crder, J a n u a ry ., .5_0..ev, afel, _ me r r,C Ee) .1 C " . " The t-lli. ance a cknwiec 'es t ', a t the tw o a rea s c f tionificant & #iciency nutei by F,9 A in i ts U; aa te Renort dr.ted Decer,ber 'I wai.d indeed hampe r any eme rgency restonse i n cisTo f c a o c ci d en t at Indian 'oint, but we cannet acce,7t the Upc'a te Feoert as a d c f f it i t i '<a m lyris o f emeroency n'anning and prepa reones s for tn'e nacicar reas. tor s i +. e ! in the mos t d e n .; e l .v pcp d a ted arca of the Ur i tec S ta ta: . The Alliance to Close Indian Point is A ry . lase t t. the :; craency ;l a n t. i n g s i t u.: t i o n ; we a l l l i ve v. i th i n 5 0 r i l es o f th e lu: 'ecr raaett e s , hos t :ithia cnt te- mile Emercency 91 c ra i co Zone. Mc%e ; e th' Ailience have s,ea:eo1 y no;n tac ect da f i c' ? r c i e: in I 'h olan dich n "c lv'en clocscd ovcr he tne r p 7. a / a l u a '.o r i . u rth e. - :; a e: c e i ,3 C . s re te a t , m !A ia ve i',)e ed 5. een ia ; t t t e v s.r c- r tr.c ible %r - ! a n . i ' r; , .. te l y ic " : .n c l o r. i c a i .cfrm:j itc ' s ," (PEPI.j r.n.. -Fq c ;; 8212230228 821222 PDR ADOCK 05000247 O fs PDR V] - . -_ __ .-- - . - - . - - - - -- -- -- __ .. , * . Allianca to Close Indian Point Letter to the Comrissioners Decetber 22, 1982 Page 2 For exannie, the only provision for identi fying and rro- vidinn help f or people with snecial needs is a tea r-o f f nos t ca rc on tne back page of the public information brochure. Fanv handicapred Paople who rec eived the brochure did not unders tand the pos t card concepts others' dismissed. the idea of evacuation of several hundred triousand people -- or even the tens of thousands wi thin a few Ete r- 9ency Response Planning Areas (ECPAs) -- and refused to seek s pecial help. flany who sent in the post card have heerd nothing from the planners as tr what special help will oe provided. The Alliance cannot accept s planning concept that exposes the weakes t and mos t vulnerable members of society to the greates t harm in case of an accident'a t Indian Poin t. FEMA has 'r enestedly pointed out that no IE cters of agree- ment.are on file from response agencies such as fire departments, tow truck operators , bus companies, ambalance services , and school districts which are to act as hosts for the evacuees. The fiational Red Cross has submitted a general letter agreeing to of fer help in a disa3 ter, but local Red Cross workers have pointed out that local .' es ources a re s. trained wher. one family is burned 00t of its house. If Red Cross aid must come in f rom other 6reas , this will ado un- a :ceptable time to the evacuc'. ion ef fort. The Allience denands a demons tra ted abili ty and commi tment to respond f rom the local e er- 9ency workers themselves , in the form o f lettaes o f agreement from each respons a agency wi th assigr.ed res ponsibi li ty, si gned by the worke rs , not by the boss. 7:FA has allowed the REPii to igncre the requirement of letters of agreement. This shcas up particularly in Planning Standard J, Protective Response. FEf*A s ta tes in the Und3 te Re? ort, " Procedures have been revisec to give addi tional i r 'o rEa ti on on means for clearing impediment; on evacuation routes. Ta3 Coun ti er will use' county, town or village equipment or local nei va te con:rac- i tors to provi de necess a ry res nucces. " In fact, th :re a re nc contrac ts wi th priva te tow tr 10k opera tors ; they have not been assigned to nee- designa ted loca tions s o tha t tow trucks a re s ta tioned a t regular, f reenent intervals along evacuation routes. !! r . William Eohlandcr, Westchester Countv Commi ssi one c , of Publi c Works i n. s aid , res a ro a g ":cunty' resources," that "tPers canel pa rti ci pa tir.n f ron the Di vis i on | cf P"u d Main tai q ance have ne ve r- been gi ven adeoua ta trair.inc by tne 1 ! co.is al t an t. Their resnonse in an actual 2 vent remains questioncble. " 1 i I *t is inconceivable tha t Planning Standard F. Emergency Com- munica tions, should ba considered as having only "mi nor" de *icie ncies , ' whd6 colice chisfs , fi re chie fs , coun ty health and social s e rvi c e c *f icials , school adminis trators , and elec ted representati ves have l fe5t'iledly et;has ized the severe commrnications problems they will ' aava in case of an c:tua. enterency. By far the mor t imrortent means of Ocmmunication to mos ' ere rpe ncy wo rk e r s 1 | 5 1 be S.h e tels- | | Ohene, and telephone company renresen ta ti ves have c or. fi rmc o un a t ;cm.1on sense would lead nne to exntct: telenbore |ines a re likeli i to be ove ricaded. _ .. _ _ _ . - _ _ _ . _. _ _ _ . - . Alliance b Close Indian Point Le tte r to the Ct.nmissi oners ' December 22, 1982 P3ce 3 The serious nroblems of evacue ting children in school have not been addressed in any revisions because they were not nated as significant deficiencies by FEMA and are not covered by URC/FEi!A guidelines. The plan requit es s,tudents to be evacuated by the school adminis tration while carents go in a di ffe rent direc- ti on . This contradicts our s trongest narental instinct, to br with and care for our children in dancer, and many rarents will not obey thi ; o rder. The "assump tion that s u f ficien t funds will be aviaiable to cure the cited deficiencies ," is no more than an assumption. The Interim Findings of July 30, 1922, a re full of sta tements such as, "i + pEdecte d f und i ng i s provi de d;",' "a ddi ti onal funding w3s needed;' " based on the availabili ty of addi ti onal funds ;" " funding is not available at thi s tine;" " will require funds not currently availaole;" "pending additional funding;" "when funds became available;" " funds are being sought;" " depend on a vailabili ty of funds;" "assurairg funding is available " "contiagent on future funding *- 'There is no mention of funding in the Upda te Report.
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