v . , . A , LNITED EE' TES OF AMERICA NUCLEAR REGUIATORY CDMISSICN
BEEORE THE CQHISSICNERS Q i N-E'E0 v - 6. ; - T * Nunzio J. PallaM no, Chairman Victor Gi1insky John F. Ahearne * p' ,. y _ 7 AjQ ;j 8 Thcznas M. Roberts j
James Asselstine d/[//-- , . .: ; ~:. :.. ;;- ; : and ~- __D-p''--
BEEDRE THE ATtMIC SAFmY AND T.TPFNSING BOARD .
Iouis J. Carter, Chairman Oscar H. Paris Frederick J. Shan ______) In the Matter of ) ) CCNSni.TTWTED EDISCN COMPANY OF NEW YORK ) Docket Nos. 50-247 SP (Indian Point Unit 2) ) 50-286 ) POWER AlmMITY OF THE STATE OF NEW YORK ) (Indian Point Unit 3) )
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UCS/NYPE M7fICN EOR REXXNSIDERATICN OF CQHISSICN RULING AIJIMING INTERIM OPERTJICN AND FOR ISSUANCE OF A SHOW CAUSE ORDER AGAINST THE LICENSEES PRIOR TO COMENCEMENT OF THE EVIDENTIARY HEARING G4 THE SAFELY OF THE INDIAN POINT NUCLEAR POWER PIR7fS
. In support of their motion for reconsideration of the Ccmnission's ruling permitting interim operation of Indian Point Units ! and 3 pending the outome of the Atcrnic Safety and Ilcensing Board investigation and for the issuance of a show cause order against the Licensees prior to ccmnence- ment of the evidentiary px tion of the investigation, the Union of Concerned Scientists (UCS) and the New York Public Interest Research Group, Inc. (NYPIRG), in acco.h with the Ccmrission Order of January 8,1981, present herein new evidence of deficiencies in mergency planning for the Indian Point nuclear pcrer plants. D5o3
8206090152 820604 DR ADOCK 05000247 - PDR V ' page z * -
. . . 1. In its Order of January 8,1981, the Nuclear Regulatory Ccmnission rn1ra that the Indian Point nuclear power plants would be permitted to operate ? during the prr m dings that had been ordered on May 30,_1980 to investigate safety issues concerning the plants. The Ccmnission's decision was based upon the finding of the Director of Nuclear Reactor Regulation on February ll, 1980 that the interim risk of the continued operation of the plants did not warrant their shutdown and upon the June 1980 reccmnendations of the Task Force on Interim Operations of Irvhan Point. The Task Force had been established by the Carmission two weeks earlier to conduct a preliminary review of information available at the time bearing on the question of interim operation of Indian Point II and III. Order of January 8, 1981, at
p. 3.
2. The Ccmnission stressed that its ruling on interim operation of the plants was not a final judgment and invited the subnission to the Ccmnission of "new evidence" warranting interim relief. Ibid. Both units have been operating during the seventeen nonths since the January 8,1981 order, apart frcm the periodic shutdowns that are ccmton at Irviinn Point.
One half of the operating life of Unit 3 and one third of the operating life - of Unit 2 have pasned since the filing of the petition of the Union of Concerned Scientists in Septanber,1979. There is still no resolution of the issues raised in the petition.
3. The decision permitting interim operation of the plants was supported, at least in part, by the Ccmnission's observation that the absence- of an approved energency plan at Irviian Point was not an unusual situation, but applied to many of the plants across the country. Order of January 8,
1981, at p. 4. UCS and NYPIBG subnit that new evidence exists that renders
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lack of preparedness at Indian Point uniquely grave: 1) the fomal
, rejection on May 18, 1982 of the Rockland County Radiological Emergency Response Plan (CRERP) by resolution of the Iagislature of Rockland County (see Appendix A), a major part of whose territory is within the plum exposure mergency planning zone; and 2) the continuing deficiencies in the Indian Point energency plans as noted by the Regional Assistance Conmittee (RAC) of
the Federal Emergency Managenent Agency in April and Der ,1981, including
the refusal of the County Executives of Westchester;=Orancje, and~Putnam{to ' sign onto (endorse) the Radiological Hmrgency Response Plans prepared for their counties by the Licensees' consultants.
4. These two categories of new evidence warrant a reconsideration by the Catmission of its ruling allowing interim operation pending the outcame
of the safety investigation. Further, the lack of preparedness at Indian Point cmpels the issuance of a show cause order against the Licensees pursuant to 10 C.F.R. 2.202, so that the outcate of the forthcaning evidentiary hearings can be a definitive order fran the Ca: mission rather than merely an
|. invitation for another hearing. The new evidence described in this notion
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, indicates that public health and safety require the present proceedings to |
| contain at least the potential for remdial action. The description of the j emrgency planning process at Indian Point found below (see Appendix B), I nukes it clear that no effective mechanism exists, apart fran a show cause order, to enforce at Indian Point the Catmission's regulations on emrgency planning. The so-called 120-day clock has proven to be a hopeless and hapless tool for correction of emrgency planning deficiencies at Indian Point where, as the Ccrmission knows wil, the density of prpulation in the surrounding area and the particularly acute problens of evacuation canbine to enhance the i ! dangers of operating the plant .
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. . , The Rejection of the County Radiological Emergency Response Plan by the Rockland County Iagislature Makes the Plan Incapable of Inpleentation. ,
5. On May 18, 1982, after the occurrence of the March 3,1982 emergency planning exercises and seventeen nonths after the first draft of the County Radiological Emergency Response Plans was subnitted, the Rockland County Iegislature formally rejected the Rockland Radiological Dnergency Response Plan. prepared by consultants to the Licensees. A copy of the resolution is annexed
as Appendix A. Regardless of how the Camission interprets the April 1,1981 inplsentation annaline for the Indian Point emergency plans, there can be no further pretense that a plan is in effect in Rockland County, or that one is , likely to be capable of implementation before December 31, 1982. See resolu- tion of Rockland County Iagislature. The Indian Point plants cannot be permitted to operate during the m ergency preparedness vacuum brought to light by the Rockland County Iagislature.
Even if Rockland County Had Not Rejected the County Radiological Diergency Response Plans, the Deficiencies in the Indian Point Plans and in the Planning Process are Continuing and are So Severe as to Warrant Inwodinte Action by the Camission.
. 6. The regulations of the Nuclear Regulatory Ca mission mandated that mergency plans "shall'be implsented" by April 1,1981, over a year ago. 10 C.F.R. g50.54 (j) (2) . Off-site emergency plans are still not inplsented or implemntable. If an accident occurred at Indian Point today, the plans would not provide even a minimum of workable procedures to protect the public
health and safety.
7. A description of the pattern of problens in the mergency planning process at Indian Point is annexed as Appendix B. In Appendix C are quotations fran the Deh 31, 1981 Review by the Regional Assistance Camittee (RAC) of
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the nore serious criticisms of the CRERPs for Indian Point and the New York State Radiological Bergency Preparedness Plan . (REPP) . Unless otherwise noted, , these criticisms were also made in the April 1981 RAC review. The criticisms have been grouped into mergency planning categories: I. Areas of Responsibili- ties, Including Intters of Agrement; II. Dmrgency Cam:unications Capabilitieu; III. Dguipient Needs Beyond Camunications; IV. Public Information and Notification; V. Protective Actions, Including Tine Estimates for Evacuation; VI. Training and Drills. The specific citation to the RAC's coments is the guidance elment, consisting of a letter followed by a number and occasionally other subsections, which corresponds to the outline of the NRC/fHR sergency planning guidel.ines in NUREG 0654, REP I, Rev.1, used by the RAC as the outline for its reviews.
. Wherefore, on the basis of the new evidence presented herein, UCS and NYPIRG nove the Camtission to reconsider its January 1981 ruling permitting operation of Indian Point Units 2 and 3 pending the empletion of the investi- gation of Indian Point and request the issuance of a show cause order against the Licensees to provide for the possibility that the result of the current proceedings be enforceable corrective action rather than simply another
i hearing. UCS and NYPIRG do not seek by this notion any delay in the camence- nunt of the evidentiary hearings scheduled to begin June 22, 1982.
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[1 , ' J 10LT, PIO7TI DIRTIOR Public Interest Research Group, Inc. 9 Street New York, New York 10007 ( ) 349-646 _hb f mu , e k AMANDA Purniena.D, ESQ. d- )d Counsel for New York Public Interest Research Group, Inc. Box 384 Village Station New York, New York 10014 (212) 227-0265
. Q p = ELL M WEISS, ESQUIRE Counsel for the Union of Concerned Scientists HARMON & WEISS 1725 I Street, N.W. Suite 506 Washington, D.C. 20006 I (202) 833-9070 h Date: June 4, 1982
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. Introduced by: Referrol No. 667S Hon. Herbert Reismon May 18, !cB2 Hon. Kenneth Ingenito Hon. Som Zalmon Gdanski Hon. Edward Gormon
RESOLUTION NO. OF 1982 PROHIBITING THE EXPENDITURE OF COUNTY FUNDS OR USE OF COUNTY EMPLOYEES FOR THE FEDERALLY MANDATED ROCKLAND COUNTY RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR INDIAN POINT, BUCHANAN, NEW YORK.
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WHEREAS, Consolidated Edison of New York (hereinefter referred to os " Con Edison"), and the Power Authority of the State of New York (hereinafter referred to os "PASNY"), each operate nuclear electrical generating facilities of Indian Point, Buchonon, New York, and WHEREAS, there are substantial inherent risks in the operation of the nuclear e|ectrical generating facilities which pose threats to the heoith, safety and welfare of the citizens of Rockland. County, and WHEREAS, there have been numerous violations of safety requirements of the Nuclear Regulatory Commission at the Indian Point power facilities which pose substantial threats to the health, safety and welfare of the citizens of Rockland County, - and
' WHEREAS, there are more people located within a ten-mile radius of the nuclear
> electrical generating facilities at Indian Point than within the ten-mile rodius of any | other nuclear electrical generating facility in the United States, and WHERAS, it has been. publicly acknowledged by the Nuclear Regulatory Commission members that present safety standards would prohibit the erection of nuclear generating facilities at or near the existing location of the Indian Point power plants, and WHEREAS, the Nuclear Regulatory Commission has promulgated a regulation which requires the development and implementation of a Radiological Response Plan for all residents within on orbitrary ten-mile radius of each plant, and
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Referrol No. 667S . May 18,1982
WHEREAS, Con Edison and PASNY have developed, through the use of independent contractors, with the State of New York, o Radiological Emergency Response Plan for
the inhabitants of the four counties who reside' within on orbitrary ten-mile radius of the Indian Point nuclear focilities, and WHEREAS, the aforesaid counties include the Counties of Rock!and, Orange, Westchester and Putnam, and WHEREAS, the Radiological Emergency Response Plan for Rockland County is unsatisfactory in that Rockland County hos not been provided with sufficient communication equipment to inform public officia's of safety hozords; sufficient warning devices to inform the general public of danger; and adequate training for the personnel required to implement the plan, and WHEREAS, the existing roadway system of Rockland County is totally inadequate and would be unable to accommodate the safe and timely evacuation of the citizens cf Rockland County within the offected areo, and Federo! WHEREAS, Rockland County officials, os well as officials of the Em9rgency Management Agency (hereinafter referred to os " FEMA"), have criticized theJRodiological Emergency Response Plan for Rockland County, and WHEREAS, the County of Rockland has mode o good faith effort, expended to develop the aforesaid Radiological funds, and used its employees in on attempt Emergency Response Plan for the inhabitants of Rockland County, and WHEREAS, the County's continued participation in the Radiologico! Emergency Response Plan will require the continuous expenditure of County funds and personnelhours with little or no protective benefit to the citizens of the County of Rockland, and^ WHEREAS, the Executive Low of the State of New York authorizes the County of Rockland to prepare a Disaster Prepardeness Plan, and the County of Rockland, through its Office of Emergency Services, has and will continue to develop such plansos may be necessory to insure the health, safety and welfore of Rockland County citizens from all contingencies, and WHEREAS, the Multi Services Committee of this Legislature has met, considered and approved this resolution, now, therefore, be it RESOLVED, that the Legislature of Rockland County hereby authorizes, empowers and directs the Of fice of Emergency Services to continue to develop, in cooperation services and school officials, o Disaster Preparedness Plan for with our volunteer Rockland County, which program shall be funded by the County of Rockland, and be it further RESOLVED, that the Legislature of Rockland County further directs the County Office of Emergency Services to develop a plan in response to o potential nuclear
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Referrol No. 6675 '.
" May 18,1982
occident occurring of the Indian Point Focilities and to utilize all sources of information in preparing such plan for the maximum protection of the citizens of Rockland County, such plan to be presented to the Legislature of Rockland County by December 31,1982, and be it further RESOLVED, that the Legislature of Rockland Couny hereby authorizes, empowers and directs the Office of Emergency Services, the Treasurer of Rockland County and/or the Chairman of the Legislature of Rockland County to pursue and accept oil Federal and State monies, equipment and personnel training in connection with Rockland County's own Disaster Preparedness Plan and the' Rockland County Nuclear Evocuation..ond . Preparedness Plan for the purposes aforedescribed, and be it further RESOLVED, that the Legislature of Rockland County hereby prchibits the use of Rockland County employees or the expenditure of Rockland County funds in any manner concerning the further development of the Federolly mondated Radiological Emergency Response Plan for the nuclear electrical generating facilities owned and operated by Con Edison and PASNY of Indian Point, Buchonon, New York, and be it further RESOLVED, that the Legislature of Rock!cnd County hereby directs the Chairman of the Rockland County Legislature not to assist FEMA, Con Edison and PASNY, their agents, servants or employees, in any manner concerning the further development of. the Federally mondated Radiological Emergency Response Plan for the nuclear electrical generating facilities at Indion Point, Buchonon, New York, and be it further RESOLVED, that in the event of a nuclear occurrence at the Indian Point Focilities, the Legislature of Rockland County hereby authorizes, empowers and directs its Chairman, notwithstanding this resolution, to take any and all action in coordinating | ! and cooperating with any and oil Federal and State agencies to protect the lives and property of the citizens of Rockland County, and be it further RESOLVED, that the Legislature of Rockland County hereby requests the chief executive. officers of the legislative bodies of the Counties of Orange, Westchester and Putnam to odopt similar resolutions prohibiting the use of their county employees or the expenditure of their respective coun y funds for the planning, development or implementation of Federally mandated nuclear Radiological Emergency Response Plons for the nuclear electrical generating facilities owned and operated by Con Edison and PASNY of Indian Point, Buchonon, New York and be it further RESOLVED, that the Legislature of Rockland County urges the Nuclear Regulatory Commission to immediately suspend the operating licenses of the Indian Point nuclear f acilities, and be it further
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Referral No. 6675 -' May 18,1982
RESOLVED, that the Clerk to the-Legislature of Rockland County be and she hereby is directed to send a copy of this resolution to Senators Alphonse D'Amato and Daniel Patrick Moynihon; Congressman Gilmon; the Majority and Minority Leaders of the United States Senate and House of Representatives; Hon. Hugh L. Corey, Governor cf the State of New York; Hon. Linda Winikow and Hon. Richard Schermerhorn, New York State Senators; Hon. Thomas Morohon and Hon. Eugene Levy, New York State Assemblymen; the Majority and Minority Leaders of the New York State Senate. and the New York State Assembly; the chief executive. officers of the . Counties of . - Westchester, Orange and Putnam; the officials of PASNY, FEMA,'NRC and Con Edison; and to such other persons os the Clerk, in her discretion, may feel proper in order to effectuate the purpose of this reso!vtion.
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' Nuke-evacuation plans draw criticism '
' " ' '' "si,I|g"s"riN,* "*' , PASNY representatives acknowledged the plan needs fine schN Y l$ca?o"f5ta1s to vpd te t$ \5, Ibl- | the area'surmunding the Indian Point eie.rians tot an em*rgency evacuauen et tuning, but sitIdplans ti.ey and doubtit said sussesuons would evermade atbe the implemented muting would be considered when the plan L1 g lf I clear power plant in Buchanan were st. is adjusted annually r afM o s C \ \ ~ ' O Td 4 *> s tacked Wednesday by Yorktown residents' " *" " who called for the closmg of the plant until said, "I want to mention my pers.onal, ' About. Indian Point, a citizens tro"P. stood. i better plans are prepared absolute, categorical and definitive dismay, . . Many of the speakers brought the panel For esample, he said most of the evac- f More than ItQ residenta attended the disgust and contempt for a plan which, petitions that they said contained hundreds 'uation area, whicb' includes everything i , klormational s'ssione at the Mildred E. purports to assist people who in reality an of signatures of, people opposed to' the within a IO. mile radius of the plant, would i Strang Middle School in Yorktown which F'* did * 8' '' P''I'"CI*filY ''*P JI ''th a evacuation plan and the operation of the probably not be evaduated Di case of an = e.s organised to esplain the plans to (Nuclear llegulatory Commission) regula., nuclear pbnt itself. . emergency. Quinn said the evacuation s rssidents and teach them how to react in tion to develop a plan. .g/ The PASNY panel, which included Jack would probably be limited to the area s case of an emergency $ree-man W now you an aWmpung to Merak bmW, community relations iepesenta- downwind of the plant at the time of any { H ow ever, the t panel, rep, ly ram it dbwn our proverblat throats" he live, Austin Decker Jr, manager of opera, emergency. 1 resenUng the Power Authority of the State said. . . . Oonal analysis and traning, and Dennis The evacuation plan was prepared last el cf New York at the meeung heard more Also condeming the plan were Christine Quinn, siadiological engineer. defended the year under an order from the NflC, t$e il than 20 residents, some of whom would Triano, a representative of the Yorktown plan. They acknowledged it needs fine federal commission charged with oversee- i e have a par * in the implementation of the High School Student Senate; Betsy Doepheo, tuning, but said they doubt it would ever be Ing nuclear plants. In February, a booklet
[ plans, read prepared statements condemn. president of the Yorktown Parent. Teacher . implemented. . . - describing the plan was mailed to all home. Association; John Rodeh, pregident of the "It's not the best in the world, and we're owners living within 10 miles of the Bu. ,3, ing the proceduresSteven Wills, a Yorktown school board Yorktown teachers uniori; Vincent Rubco, a going to work on it," Brumfield said. "But chanan plant. The booklet was prepared by ., member was one of those who protested, representative of the Ossinink Teachers' we're digressing from the fact th.t the ic "In rny position, as one of the elected Association; and James Wenzel, a snokes. chances of evacuation are remble. We're . ,. trustees of the Yorktown school board," he man for the Yorktown Parents Concerned planning for the worst " - - D Condasd front page see Many oiher specifica!!y critici , g 1- the plans for evacualmg childret 1 , r'*- ,,, PASNY, whicle owns one reactor at schools. . le * ,f _ . }- ' J Indian Point., PTA president Doephen ques. ; s '+ , . Con Edison owns the two other re'ac. how parents =9uld be kept from go. / 9 tors, only one of which is currendy in schools to get their children anJ 'l j , * operation, teachers would te kept at the sch* ' According to the plan,in the event of ' awa from their own f amelics. , ~ ~# at the plant h' **W the Incal PTA, 18925701 ~ \ apeopl* major La radioactive the le m0e leak eres would be 722 memises, . 1d nne .. t ev acuated on gn ebeigna t,d rw t,. * **** **v adM aw School culdren would t ev.evat,d by {"***d ~ s* *~' aat =** *w * * d - I their teachers and placed on school dren and yowth" and ''aw wrug ed.q.. I buses to centers outside the area. Paren. I' " ' I **" and protnuon I ts are lutr c # '" and outh , not to drive to schools cha At Wednesday's ' meeting, parents and tendent of schools, who also chaired * our annung. a e how k wo school officials called the plans unwor. * hable and said PASNY was at fault for '#'' '' "" # , falling to work fully with. local offic "I * , ln tha preparation of,the procedures.do .ials under the pla n. lie also said Because officials were not contacted, doubted he would te aNe k prew , they said, the capacity of local roads wasdren. parents from coming to get their c: } overestimated, non 4r sistant roads a p- Greene asked the PASNY panel . . pear on evacuauon maps, and large there w ere no miscounts of sebool populadons oe. provisiom for ha. evr M . 6 capped students in the plans and g y,,g g,,e two dri.ves =w nd to me,= 6 Me stal tras Pt=nt thet dews te swwww es ber rom d, serves . g whde the details et the evacuaten plas ,thee drweri would come se Vortie are worked out," asked one resident. And he asked why only 45 of the who said the has two daughters in.a buses needed to evacuate Yorktown's local elententary school. 875 public students.would te available -.t .*. ,a g, , , ,
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. ' I'l (W ' t' . , \f I : 1 . L Rockland .c.ondemns nuk'e plants, ; crisis plan ' ' By KEVIN bicCOY independent emergency plan, disregarding- 'd * Staff Walser - - - - -nt,Predictions..ho., that the mov,e would leave the 7 a ,lah e em-gency re- Pump pro blem- shut doivn . , . . keeps Ind,ian Point , The Rockland County legislature has sponse plan and cut off state emergency , , . . g. sent a message of condemnation to the funding. Problems with a backup pump contin- automatically take over for' the , main No injuries were reported and no utd t.es that operate the Indian Point nucle. "It's not irresponsibildy.. It's cet . of ,ved at the Indian Point 2 nuclear genera- feedeater pumps. ' i radioactivity has been released The plant
ar power plants and to state officials re. desperas.on that we're doing it ** said )(en- for Jhis morning, keeping the plant shut . . is owned and operateJ by Con Edison # sponsible for public safety. Your nuclear neth Ingemte. D Stony Point. . down for a third straight day. It was not - Indian Point 2 shut at 5.45 a m. Fon. ~ known ahen it would be back in service' day after a worker inadvertently opened This is the second time in two months plants are " unsafe and your emergency, the legislators.The resolution passed- '* by an- Il 6 vote of that both Indun Point Mclear power response plans unworkable.. '... '- . . a circuit breaker ~during routine laspec. .. The pump, one. ants are Hmultanewsly at of se* In a tumultuous session Tuesday night ' Supporters argued thata separate Rock-. of 'three avsaliary gjen, ,g plant instruments. Valves that the county legislature voted to withdraw land plan would adequately deal with flaws ( , feedwater pumps; was tested Tuesday " " "YI " #" from the Indian INnt nuclear evacuation in the four . Opponents of the resolution, in addi, tion, said that the withdrawal could cost the county as piuch as $400,. ~ , 000 in state aid. * > s , * 6 , e e ~ . .{4VvpNd W Rockland q uits n d kM.j;th'4"9-t,%@Grac plan ."-; % \6:,*T.7.Q W . , ' ' By KEVIN McCOY which outlines evacuation routes and B'u t I don't'think Esi rdthrkpating in and the county's ' portion of $4.75 million Staff Writer relocation for more than 225,000 resi. the plan will do lh'at,** said,Ela,rkstown, in additional funding proposed by state dents Inving within, a 10-mile radius of Republican Eugene Grogin.C'Without a Arsembly Speaker Stanlay Fink. Tne Rockland County Legislature the plants in Rockland, Wettchester, plan, the only thihg de.will bela'ble to do State Transportation Commissioner narrowly voted to withdraw from the Orange and Pu'tnam counties. .$eirc'r My God William _IIennessey, h ad of the state Indian Point nuclear evacuation plan at Instead, the county's 'two.[n'an Office isTo joinTi.ee.' hands " and; sing,'A(31Q .Emergency Disaster Preparedness - d .( a - , a tumultuous Tuesday ' night session of Emergercy Services was ordered to Gra nt, a J.Itaverstraw', .pe:nocrat, . Commission, tvarned in a letter read at , which included a call for the shutdown develo'p the courtty's own plan by the end echoed the sentiment,'arg6iig~ that it' the meeting.that Rockland withdrawal . of the Buchanan auclear plants. of the. year. , could take the co'unty; year $Moevelop' could cut off, all state funding for an Disregdrding predictions that the $ %Mf:54. . emergency evacuation plan. move would leave the county without a by anTuesday. overflow crowd night's in New vote City, was but applaudedEmergency- 'ils own plan.''|'.:)Wahitioribialip. But Legislature were Vice Chairman fler. viable emergency response plan and cut condemned by a utility official and.seve. ordered for all U.$. niicleiQlaatphy the - bert Reisman,. a Ramapo Democrat, * off state emergency funding, the legis. ral Rockland lawmakers. federal Nucle'ar Regdb(ejyCon1 mission. argued that. safety and a workable plan lature voted to develop an independent 588 m re important. Re said the resolu- ' Legislature? Chairman John' Grant. Ih the ' wake 'dytpTiirM%in pla n. iidated tion would send a message to Albany "It's not irresponsibility. It's out of and'the emergency Donald services McGuire, office, . eacti deputy Edison and director'of the' Pow t ' reactor shuld6wn.}h'e'257DN'Nac.ilstand,t : 3hov'e it * desperation that we're doing it," said questioned whether Rockland could 'ad.5N71 State of Nevirs Yorkp$uthoritfjf'thepat'e the - . John Duf'fy, assistant generai counsel Stony Point Democrat Kenneth ingenito. equately take on.the job of plarining a two n eactors alln&an Po y,. Supporters of the resolution, which full-scale evacuation. . .o , , Supporter's Sof 3fues 'msolutloo "to PASNY, condemned the resolution. The need for such a plan is apparent passed by a 218 to tu vote under .the' ' Opponents'of the resolution, in. addl believe'. lack ei Iil6ckla'rfdtp 1pation even if the Indian Pomt plants never weighted voting system (11 legislators to tion, said that the withdrawal could. cost could delay NRC,approva1%!!1he, entire'c existed," said Duffy, arguing that the 6), argued that a separate Rockland plan the county as much as $400,000 in state. . Indian Point plan'fand possh ilead to a '. utilities' blueprint for a nuclear evacua. would adequately deal with flaws in the aid for 'past and future ' participation' in' federally-ordered %hutdb [thereac. tion would deal with any type of general four. county emergency response evacua. the project,and Ichve R6ckland with;no -tors. . pPh.% y ..' . emergency.,W ithdrawa., he said, "would tion plan tested March 3. back-up in the event of.an emergency,at - .But.'the, wiihdrawal 'a . pold cost be to consign to death or serious injuries The resolution blocks continued the Indian Point reactors." . . . Rockland 330,000,lt;was|eipecting from hundreA of tigousands of people 'who Rockland participation in that plan, "I want to close Indian Poin't down. . the utilities for pastemejr enet,'plannirig. might be erbosed to radiation." ' * .-. . . . ' ''.i _ . , - v, ., - - . &fW , ., , 3 |',h';- &.g9 h.ty< r.e ,\y '.t. ,. . w. ;( . , . . . , , , . . g s . ' ' ' ' ' * . . s . .| f ' * , J. . , , %. .... , ." . ., j. , ; . k .:.. w :.~u.-..~...u.8.. 2. . . . ' . , , :,, . - - . _ . . _ " . _ ____ , . . . . 'THE NEW 10RK. TIMES;.THURSDAWbfA Y;20,*.1982'. '' .- .. : ~. E' :. . . . . , Emergency. Plan: Withdrawal, ' Will coa RocklChnd-8100,ddo i - i . .' \. ... '. , + .s s , '*- . s .. ,, uw * G._ . . .--~~ - .;~.- --- By EDWARD HUDSONJ _' * sp.dai m n. N v.s nm. .. r, r ' -. . ' = . ..x, . 1.: n . . , g. ,. ,- . . r.W. .2e.. NEW CITY. N.Y., May 19-The head ambulance drivers boycotte'd .the dr1U of New' York State's Disaster Prepared. because of .what .they. called. a . lact.o(_ J ness Commission'said today that}ock, Jraining equipment 44nn Rockland. Orange and Putnam Coun. ', . ties who live within .10 miles of the ' MAKE A DREAM COME TRUE plants, was tested in a drill last March . GIVE TO THE FRESH AIR FUND 3. Rockland volunteer firefighters and ;.ig;gg,,, 7 I * ~ ~ ' ~*: r :: .t1 . ! . . . . - . . _ . g u, v p. - Business peach, BI yB. . ' . . l' - , ~ -a ! i 1 l' / ' j , ''; ur ht6 fB. y _ , 'IL9Wr for | .The chief said he did not know the motive l: episode, but he understood Mann had "some kin t.( , *. if.fN U < e o a n . h s ? .'By KEVIN McCOY , . Stoit Writer The chairman of the state Disaster Prepare . , - a Commission flatly predicted Friday that Roc . in special funding T *.y,would . lose at least $150.000W 7, result' of the county's withdrawal from the J Point nuclear evacuation plan. D '4; , But the of ficial. Donald Davidoff| agreed I M(state attorneys to research state evacuation' h @.".y legislation to determine the county's eligibilit. . said Rockland would be reimbursed for 330,' F. evacuation pl M- personnel and other nuclear ' , expenses already incurred by the county."We interpret the statute to mean you eithe M or you don't, at the county's option,'' D>.vido , af ter a Frifay morning mccting with county :: g, In New City. "That is our position. The cour c. asked us to put it in writing and we have agree Of- - e., so " , Following the meeting. Rockland governmt ). - - rescritatives said they would simultaneously ,. - state Attorney Generalt office to study the T- Rciterating arguments voiced before the H , Legislature voted to withdraw liom the plan. ofheials and civic group representatives predi county would be no better prepared for a disastcr. even without emergency planning "because the evacuation plan as it stands just W or k." s. .% ~ [- l f - ______. . . THE NEW YORK TibfES, FRIDAY, JUNE 4,1992 ._ . DelBello SeekingDeadline ForNuclearAccidentPlan By EDWARD HUDSON speow une m vars n== , WHITE PLAINS, June 3-The West. Isttertr. agencyChairman chester County Executive said today that he and other county officials Mr. DelBello, in a letter to Nunzio doubted that residents could be safely Palladino, chairman of the Nuclear evacuated f rom the Indian Point area in Regulatory Commission, asked the theeventof anuclearaccident. ederal omcial to ne County Executive, Alfred B. Del. ,{ regulatory dockprocedure , tnatiate putting a 120 day Bello, called on the Federal Nuclear me state and W utilities, h Consoli. Regulatory Commission to set a 120New York City's plants, in 8 - in the most densely poptlated area of Croton reservoir system. any nuclear reactor in the United Mr. DelBello said be hoped the Nu. States, clear Regulatory Commission would ne County Executive said Westches. not use its hearings as an excuse to ter reached its conclusions about evacu- delay action on his request, but he ex. ation planning after two years of trying ' pressed confidence that the Federal to cooperate with state and utility work. agency could not sweep the issue under ers drafting the evacuation plan. the rug. His anrancement came alittle more "ney can't avoid a specific issue," , than two weeks after the Rockland he said. "If there are no bus drivers County Legislature, whieb also labeled working in the summer, what are they , the plan unworkable, formally pulled going to do?" he asked, referring to the ' that county out of further participation . use of school buses for part of an evacu. in Indian Point emergency planning.I ation. Orange and Putnam Coudes an ak Daniel P. Gujdo, Westchester's Com. covered by the same plan. missioner of Public Safety, said he be. lieved that a nuclear accident wnuld ' precipitate " spontaneous evacuation." - -a a- Iaa- ee a w. - - . - - SA n ------, - A--2n-.A au _s -- _ . . . a Aa- --- +------ h h e e O APPENDIX B ! - i i i 1 1 I I t ' , ! r i 4 --. -- . --- - _- -- - . - . .m._ , - . , , _ . . ~ , . --. _ _, _ _ _ . . . _ _ _ _ , , . . ------_ ~__ - . . . . APPENDIX B %e Atanic Energy Act of 1954 and the statute that established the ? Nuclear Pegulatory Ccmnission enacted in 1974 requires the agency to protect the public health and safety as it might be affected by the nuclear industry. In 1979, the amir%nt at tree Mile Island nuclear power facilities heightened public and official awareness of the need for omrgency planning to protect the people living near the nation's nuclear power plants. We Kmeny Ommissicn was formed to report to the President on the accident. In response to the Kemgpv Ccmnission Report, President Carter issued Executive Order 12148 designating the Federal Dnergency Managanent Igency as the lead agency to c6 ordinate the mergency planning functi:ns of executive agencies and in Decarber 1979 issued a directive assigning to FDR leM responsibility for offsite anargency preparedness around nuclear facilities. ne division of respcn- sibility between FDR and NBC with respect to mergency planning left to FDM the responsibility of revicwing and evaluating the effectiveness of state and local omrgency plans, ard specifically to "make findings and determinations as to whether State and local energency plans are adequate and capable of inplementation." Memarandun of Understanding | between Fan and NRC (MOU), effective January 1980, page 2. ! In June,1980 FDR published proposed rules entitled " Review and Approval cf State and Incal Radiological Drergency Plans and Preparedness," that were later erdified as 44 CFR 350. W e proposed rules have yet to be adopted in final form although [the] FDR apparently considers itself bound by their provisions. FD E's rules provide for Regional Assistance Ccmnittees (PAC's), through which it reviews state and local plans. The existence of county and state anargency plans becme a condition of a utility's license to operate when the NRC formally adopted 10 CFR 50.54(s) (1) in its final form in Atygust,1980 as follows: [- .. . . .* 10 CFR 50.54(s) (1) Fach licensee who is authorized to possess and/or operate a nuclear power reactor shall sutruit to the NBC within 60 days of the effective date of this amendment the radiological mergency response plans of State and local goverments that are wholly or partially within the plme exposure pathway EPZ as well as the plans of State goverments wholly or partially within the ingesticn pathway EPZ. We 60-day ax11ine established by the above-qtoted regulation expired on January 2, 1981, when draft plans for New York State and for the counties within the plum exposure pathway EPZ for Indian Point were sulznitted to the NRC by the State. In April, the FDR's FAC review evaluated the state and county plans and forwarded its critique to the New York State Ccmnission of Disaster Preparedness. April 6,1981 letter with attachmnts from Vincent Forde, FDR to William Hennessey, Chairman, New York State Disaster Pre-' paredness Ccmnission. April 23, 1981 letter with attachments frm John Dickey FDR to Brian Grimes, Nuclear Pegulatory Ccmnission. We | deficiencies described in the FAC review of April prmpted the Ctmnissicn to trigger the enforement clause of the cmergency planning regulaticns, 10 C.F.R. 50.54(s) (2) and cxrmenced the "120-day -clock? at the end of which period all of the probl e s described in the RAC review were to be corrected. April 24, 1981 letters frtxn Boyce Grier, Nuclear Regulatory Ccmnissicn to George T. Berry PASNY and to John D. O"Ibole, Cbnsolidated j Edison. In July, 1901 % fore the expirations of the 120-day clock, New York State sutraitted to NRC revised plans for the State and the counties. The | NRC accepted these plans as correcting the deficiencies identified in the April _-. . _ _ _ _. _ . ._ . _ _ . ._ ._ . . _ . , . , ' . r 1981 FAC review, and stopped the 120-day clock stating that the issues had been " resolved satisfactorily." August 24, 1981 letter from ; Boyce Grier, NIC to Geroge T. Berry, PASNY and to John O'Toole, Consolidated Edison. Another four nonths passed before FDR's FAC subnitted its critique of the revised plans. Dece ber 31, 1981 letter with attachments from , Vincent Forde, Acting Begional Director to William C. Hennessev, Camissioner, New York State Lisaster Prenaredness Commission. ?bst of the deficiencies identified by the PAC in April were again noted in Decenber. Some categories found adequate in April were apparently worse in the final plans and were deemed inadequate in Deconber. In April 1981, out of the 98 criteria reviewed, for the In the Decernber critique of | county plans, 58 were found inadequate. the final plans, 69 out of 88 criteria were deficient. The State of i New York has yet to subnit its timetable for correction of the deficiencies noted in the PAC review. i | | , . I i . ! ! - . - - . . , - _ _ - . - - . - , _ , , _ . . . , - . . _ . , . _ . - . _ - . - - - - . _.- * --.a-- a- - + - - - -- ,--,. - -- .- , g 4 0 e e APPENDIX C . f a ! i y .- - - .. , , - .- - - -. . . _ , - - - . - ,m -----, -- - _ _ _ . * APPENDIX C . I. AREAS OF RESPCNSTRTLTTIES, DCIJDDG IEI'IERS OF AGREEMENT CRITICISM OF CDUNIY PIANS * A.l.a. A . clear statment nust be nude in all county , , plans that clearly defines the change of responsibilities once a State declaration of disaster is nade. All private sector organizations have not been identified. A.l.b. 'Ihe concept of operation for each organization has not been provided. A.2.a. . . . specific functions and responsibilities for najor elments of the emergency response are not adequate at this time, A.3. 'Ibe County Executive crucairnnn of the . Iagislature nust sign off on the letter under Appendix I which endorses each County plan. 'Ihere are no agreenents between the c:>unty 4 ani non-governnental organizations listed in the plans. 'Ihese should be obtained. and included in the plans. Specifically, I there are no letters of agreements frcun bus cmpanies, unions, volunteer fire departments and. ambulance services, or EBS station managers for activation of the EBS. Mut22al aid agrements with the.other counties within the 10 mile EPZ for equipTent and personnel resources~ should be considered. - C.4. Have all facilities and resources of non- governnental organizations been identified? | Ictters.of agrement are not available for all I. organizations listed. , | ! ._ _ - - - ___ _ . __ - . . _ . - - - - - . - - - . - . .. . F,1.e. * Alternate individuals for each energency . response agency have not been designated. ' J.10 9 Althoug' ne means of relocation is described, there appear:s to be no ocxn'itnent 1%ferenced ! ' .mau nents?) Ibw many operational buses are avail- able in each garage at any given time? Is augmentation necessary? Where will it come frtrn? L.4. Insufficier.;. information is furnished to deter- ~ mine adequacy.of the arrangenents for trans- porting victans of radiological accidents to nM ical support facilities. M.1. Although reentry and recovery procedures are described, insufficient infornution is furnished regarding assignmenti of responsibility, criteria for reentry and d'etails on the long term rarliation and nMical nonitoring programs. | : O.l.b. *FIch off-site response organization.:shall part- | icipate in and receive training. Where nutual | aid agreenents exist between local agencies such as fire, police and ambulance / rescue, the training shall also be offered to the other departsuents who are memben; of the nutual aid district. P.6. *1he CRERPS do not contain a detailed listing of I I supporting plans anc their sources. | | *Found adequate by April 1981 RTC review, but inadequate by Decerber 1981 R,T review. . e e. e- @6* # . . ' CRITICIS4 OF STATE PIMS A.2.a., Menoranda of Understanding in the generic r State RERPP are not finalized. 'Ihis un- certainty casts doubt on the validity of the interrelationships depicted in Figures 7 thru 15. J.10.g. Although the neans of relocation is decribed there is no assurance referenced in this plan that the public and privately owned buses would resimnd, up6n call up, to transtort personnel if so desired. Ietters of Agree- nentsnOUs are lacking. How nany buses are available in each bus garage at any given tine? What are the passenger capacities of these buses? Is augnentation necessary? Where will it cme frcrn? II. OWMUNICATIONS CAPABIIlTIES CRITICISM OF OJUNI"I PIANS .. A.l.e. * .. .we could not determine whether or not provisions allow the individual in charge of each organization's energency response could be reached 24 hours a day (e.g. during non-duty hours away frcm hone or in transit) . E.6. What is the actual date for installing the supple- nental notification devices (the alert receivers) ? F.1.a. *It is not clear from the plan what the alternate nethod of conmunications is for notification and and activation of the energency response network. *Found adequate-by April 1981 RAC review, but inadequate by Decenber 1981 RAC review. i - . . ______ . , F.1.b. *Ihe plans have not provided for conmunications betw3en contiguous States and counties in the * 50 mile ingestion exposure pathway. In ^Mition, - .* provision for all alternate conmunications links between States and counties has not been clearly defined in the plans. F.1.c. Although the plan states there is to be ccnmmi- cations with Federal agencies, there is no indication how this will be accomplished. * F.1.d. Ibw will comunications be nuintained with the field . nonitoring teants'? F.2. It is unclear fran the pians whether cmnunimHms links for the fixed and nobile rmaimi support facil- ities exist. Rw ific infornation concerning the nnthod of canunications linking.the hospital and the nobile ' support units and the types of canunications equip:ent at both the nobile and fixed facilities are not , provided. ' G.4.b. Spx ifice are not provided as to how infornation will be exchanged anong spokespersons. I.8. 'Ibe IStbicatio'n neans nny be either lanalines or radio but it is unclear as to how specific response personnel are notified. Transportation arrangements for nonitoring teams are not dice 1ssed. . . . there is little eviden .of backup arrangenents and to discussion of canunimHm for field nonitoring teams. N.2.a. * Provisions have been nude for the nonthly testing 6f canunication systens within the county, with the State . and surrouniing counties' and for annual testing of cat- nunications between the NFO and the State and county *Fbund adequate by April 1981 R/C review, but inadequate by December 1981 RTC review. _ _ _ . _ _ , __ . . ECCs and field assessment teams. However, the plans * do not contain specific pro dures for conducting the tests. CRITICISM OF STATE PIAtB ~~ E.1. .. . procedures for verification of messages were not addressed. III. EQUIPMENT NEEM BEYOND COMMUNICATIONS CRITICISM OF COUNTY PIANS H.7. [with respect to the environmental monitoring system, 7 _ the plan nust discuss both the adequacy of calibrations, and security frcm damage. h " radiation nonitoring energency kits for county field teams," discussed in the Appendix J, are really personnel support items which are not available in sufficient quantity - for the anticipated personnel who will make up these teams. H.11. *Attachnent 16 lists energency supplies, incitding rolls of dines and nickels (purpose unspecified) . 'Ihere are no personnel dosimeters or permanent record devices in this list. 'Ihere is no radiological equiprent available at this tine. Specify anticipated acquisition time. Discuss the emergency use of the personnel, transportation, and conmunica- tion equipTent with respect to the various energency response actions in the plan. | H.12 *'Ihe portion of the CRERPS referenced identify where the' field data will be collected and recorded, but the plans do not specify where field data will be analyzed and where sanple nedia will be coordinated. j I.7. Develop specific Standard Operating Procedures (SOPS) , for each type of nonitoring equipment and instructions. on data and sanple collection. Specify location or | *Found adequate by April 1981 PAC review, but inadequate by December 1981 F/C review. I ! .. .- . . . nonitoring site naps which are sufficiently detailed to allow rapid arrival at destination by teams un- . familiar with the locations (i.e. DOE, county teams, newly trained Nm teams) and for the use of the county official to whcm the teams are reporting their data. Discuss transportation arrangements for nonitors... If there are :no seperate county nonitoring -teams, for whcm are the " Instruction for Radiological Manitoring" intended? 4 J.2. . . . facilities and neans for nonitoring (s:ergen'r ' . pannel and evacuees are inadequate or ocxtpletely lacking. J.10.a. .:.none of the maps depicts preselected radiological sanpling and nonitoring points. K.S.a. ... procedure does not satisfy specific instrunentation to be utilized fonTreasurment'(of contaminated , persons). 'Ihe CRERPS do not state what level of contamination follopup is necessary (e.g. bio-assay i nasal wipes, etc.) Records that are to be kept on every individual who is surveyed shoold detAi1 areas | of body surveyed and level of contamination. Records should also incitde neans of decontamination attenpted and fesults achieved by each step. , K.S.b. Ibscribe nedical treatnent arrangenents for personnel whci have been contaminat6d or exposed to high levels of radiation. Discuss deo3ntamhntion stations, especial- | ly locatiors, facilities available, and waste disposal neans. . . Discuss source of teams needed to nonitor cnergency workers and evacuees, to determine need for decontsstination and to assure results, Explain or identify nedical or 1 * . . radiological authorities to which contaminated personnel will be referred for additional consultation or ~ treatment. J.9. **Since there is a potential for bypassing the reception ce;1ters, it is necessary to have registration, nonitoring, and decontamination facilities, at both types of centers (now considered adequate) (receptien and congregate care centers --shelters) . During an energency of this nature, it is necessary to ' mandate' nonitoring and decontamination activities, not ' encourage' them as stated on page A-37, paragraph 3. (now considered adequate) . CRITICISM OF STA'IE PIANS H.7. The State has no iodine detection capability as part of the off-site nonitoring equipnent in the vacinity (sic) of the site. I.7. 'Ihis criteria elenent asks what field nonitoring capability each organization (licensee, state, and local) has within the plune exposure pathway. Attach- nent 5 does not describe what field nonitoring capability the State has. If the State has no capability, the plan should so state and provide infornation on what field iconitoring data the State intends to use for its evaluation at various stages of an accident. I.9. As of July,1981, the State had no field measurement capability to detect and measure radioiodine concentration in the air. **'Ihese two quoted criticisms are included because of- the severity of the RTC's language. Parodoxically, however, the RAC found these factors to be z.dequate in December despite the barshness of the criticisms. -. . . . IV. PUBLIC INFOWATIQ1 Ato torIFICATICN CRITICIS4 OF COUtTIY PIANS .* E.5. We GERPsdo not satisfy the planni.~; guidelims regarding the dissenunation of information to public using the EBS... %e plans do not contain any detailed information crmng the method of coordination of all EBS messages anong counties within the EP3, as well as with the State. E.7. We draft announcements are not adeqtute neitha.r in number rot content to neet the energency - information needs for people with (sic) the Indian Point EPZ. @ of the deficiencies mentione_d7 which should be renedied are: Announcements should indicate coordination with other counties-in EPZ ard should include information for residents of other counties. Were is a critical need for coordination in this area because obviously a Westchester County resident, for exanple, could be listening to a Pockland County rMin Station. Seperate announcatents regarding scirol evacuations should be prepared. We General DTergency evactntion announcenent should nane reception centers and routes to be used to the reception centers. People should be provided with a runer control ntriber Considering the size of the transient population, is . y - w e - . . the EPZ as well as the density of the permanent population, it's 3 evitable that, in the event of , an incident, there will be a nurber of people who will be in special circumstances requireing aid and/or information. G.2. 'Ibere are no specifics regarding the public information program f6r perenent and transient populations of the plume exposure EPZ. What is the methodology to ensure ' that the public infor .ition program materials will be available to all pernanent and transient populations? ' G.4.c. . . .the county Public Information"O'fficer is -rssponsible for establishing a Ru: tor Control Center. Ibwever, provision has not been mde, as yet, since no specific informtion concerning the Center has been included in each plan. In addition, the plans do not reflect a * full understarding of the purpose of rutor control. Ru: tor Control is primrily designed to provide the general public a point of cantact to obtain answers . - to individual questions. Notwithstanding, evaluation of questions coming into rutor control my point up a need for new releases on frequently asked questions. 'Ihe plan does not provide information and the staffing of Rumar Control Centers. J.10.b. Maans for notifying all seg: rents of the transient and resident population are not adequate. . . J.10.d. The CRERPs do not address those individuals who are impaired or confined, but are not institutionalized. . -. _ - .- . . .. . ' . ; 1 | ' ? CPlTICISMS OF STATE PIR E ! E.7. 'Ihe Site Specific Operations does not provide draft nessages.,Neither does the generic REPP, No sanple of public information is cited. V. PIOm:nVE 1CTIONS, INCI1]DDG TIME ESTIMATE EOR:EV. ACUATION CRITICISMS OF COUNIY PIANS J.2. All CRERP response actions are - predicated on the asstmption of a release of radinactive materials which develops over a period of tine. J.9. '1he vehicular evacuation tines under adverse conditions for many ERPAs are nuch greater t!un the tines for people to walk out of the EPZ. 'Ihe circumstances under which vehimlar evacuation ceases to be a viable protective action might be an appropriate inclusion for Appendix A. (now considered adequate). J.10.h. * ...some of the, relocation centers. appear to be less than 5 miles beyond the boundary of the plume exposure EPZ. J.10.k. * Insufficient infornation is furnished to determine adequacy of neans for dealing with potential inpedinents to use evacuation routes,and contingency neasures. *Found adeqate by April 1981 RAC review, but inadequate by Decenber 1981 RAC revies. i , - . . . , J.10.1 *Although evacuation tine estimtes under various ,cather conditions are described in table form in Appendix A. of each CRCRP , the estimtes are . described by ERPA rather than by sector and distance. mreover, a determination of adequacy of planning for this element cannot be determined . until Appendix 4 (cited in the cross - reference) is subnitted to the RAC by the State and reviewed. Based on a c3nversation between FD % Regional Staff and the State Nuclear.:Brergency Preparedness Group (IEPG) on December 28, 1981, the Appendix 4 report ' has not been received by NY State frttu the licensee's consultant, Parsons, Brinckerhoff. The rating for planning related to this elenent will remin inadequate until the RAC has nade a determination on the adequacy of Appendix 4. J.9. Discuss the conditions under which evacuation will no longer be a viable protective action, i.e. inclenent weather, short-term duration of a high exposure plurte. (Not Adequate in April, Adequate in December) ' E. 3. . There is no nention of pernanent dose recording devices in any of the plans. Specify where dose | j records will be kept and for hcw long. It it unclear i t if the dosinnters are presently available on a 24 hour basis. 'Ihe dose record form (Attachment 8, ! Procedure 3), as a field record log, should be revised to allow an individual to record periodic readings for one shift. Attachment 8 in its present | 5 | design is inaIpropriate either as a field or pernonent | | ! dose record. | .. . . . - . . . . - - - . . t t _ , . . CRITICISM OF STATE PIANS I.8. *Ihis criteria elment asks for provisions for ' ' activation, notification neans, field team omposition, transportation, cxxmunications, nonitoring equiptent and estinated tines. Attachnent 5 does not provide any of the specific infornation. 'Ihe generic (plan) is similarly deficient. J.2. 'Ihis plan does not address alternatives due to specific radiological corditions. J.9. 'Ihe Site Specific Operations is not clear in identifying who will nake the decici6ns to inplenent protective actions. J.10. Paragraph 7.2.13 states that " Normal procedures for evacuating spebial facilities will be inplenented when ordered." 'Ihis statenent does not provide i sufficient detail to ascertain whether the neans for protecting those persons wiese nobility nay be inpaired due to confinenent, stc., is adequate. J.10.k. Insufficient information is furnished to determine whether or not identification of and neans for dealing with potential inpedinents to use evacuation routes, and contigency neasures. J. lD . l'. .Although evacuation tine estinates.under various weather conditions are described in table form in Attachnunt 6 of the Site Specific Operations, they are described by ERPA rather than by sector and distance. bbreover, a determnation of adequacy of planning for this element cannot be determined until I t | 'C .iteria cxunitted in April,1981, RAC l | | . . . . ' . Appendix 4, (cited in the cross-r::ference) is subnitted to the PIC by the State and revied. Based on ' a conversation between FD% Pegional Staff and ,, the State Nuclear Dnergency Preparedne'ss Group (NEPG) on December 28, 1981, the Appen.lix 4 report has not been received by New York State from the licensee consultant, Parsons Brinckerhoff. We rating for planning related to this elernent will restain inadequate until the RAC has made a determination on the adequacy 1 of Appendix 4. J.ll. Paragraph 6.2.2 does not.specify the protective neasures to be used for the ingestion pathway, including . the methods for protecting the public frcm consunption of contaminatAd foodstuffs. VI. TPADMG AND DRTT.is CRITICISMS OF dOUtn"I PIANS I N.l.b. Were are no provisions in the plans for the exercise to be conducted under various weather conditions or for unannounced exercises. N.5 * Insufficient information has been furnished to determine whether means exist for evaluating observer and participut acrments. We plans do , t not assign responsibility for inplementing cor- i | rective actions. Ibnagement controls to ensure | that carrective actions are inplemented as a result . { l of acceptance of observer crrments were not discussed. . O.1. *We CREPPS do not have sufficient'infornation to .- evaluate the planning elenent . . .Without having personnel assigned to specific duties one cannot determine: wto needs the training by position, what training *Found adequate by. April 1981 RAC review, but inacLyste by December 1981 RTC' review. . - - .-- . _ . . -. .- _-- ., . . by position is necessary, and who will conduct ,, trainirg. , I O.5. *h CRE:RPS do not adequately provide for the initial and annual retraining of personnel with energency response responsibilities. P.3. *Who, by title, is resposible in each agency of the county for maintaining and updating emergency plans (i.e. telephone lists)? ' > d I ! , t . *Found adequate by April 1981 PGC review, but inadequate by Ibccmber 1981 review. , , -, . . - a- - - - . - , , ...... - - - , - - . - - - - n- -. -+ , - - - , ------. - ... . . UNITED STATES OF AMERICA i - NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 'E a,-7 90:19 7*'W. t.. ?. - In the Matter of: Docket Nos. 50-247 SP ~ CONSOLIDATED EDISON COMPANY OF 50-286 SP NEW YORK (Indian Point, Unit 2) POWER AUTHORITY OF THE STATE OF - NEW YORK (Indian Point, Unit 3) ) SERVICE LIST . Docketing and Service Branch Paul F. Colarulli, Esq. Office of the Secretary Joseph J. Levin, Jr., Esq. U. S. Nuclear Regulatory Comission Pamela S. Horowitz, Esq. Washington, D.C. 20555 Charles Morgan, Jr., Esq. Morgan Associated, Chartered Louis J. Carter, Esq., Chairman 1899 L Street, N.W. Administrative Judge Washington, D.C. 20036 At'omic Safety and Licensing Board U.S. Nuclear Regulatory Comission Charles M. Pratt, Esq. Washington, D.C. 20555 Thomas R. Frey, Esq. Power Authority of the Dr. Oscar H. Paris State of New York Administrative Judge 10 Columbus Circle Atomic Safety and Licensing Board New York, N.Y. 10019 IJ.S. Nuclear Regulatory Comission Washington, D.C. 20555 EllynR.WeisfEsq. William S. Jordan, III, Esq. Mr. Frederick J. Shon Harrnon & Weiss Admi..nistrative Judge 1725 I Street, N.W., Suite 506 Atomic Safety and Licensing Board Washington, D.C. 20006 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Joan Holt, Project Director Indian Point Project Janice Moore, Esq. New York Public Interest Counsel for NRC Staff Research Group Office of the Executive 5 Beekman Street Legal Director New York, N.Y. 10038 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 John Gilroy, Westchester Coordinator Indian Point Project Brent L. Brandenburg, Es.q. New York Public Interest Assistant General Counsel Research Group Consolidated Edison Co. 240 Central Avenue of New York, Inc. White Plains, New York 10606 4 Irving Place New York, N.Y. 10003 . . . , . ' -2- Jeffrey M. Blum, Esq. N rc D P$rris 1Isq. ' New York University Law School County Attorney 423 Vanderbdilt Hall County of Rockland 40 Washington Square South 11 New Hemstead Road New York, N.Y. 10012 New City, N.Y. 10010 Charles J. Kaikish, Esq. Geoffrey Cobb Ryan Litigation Division Conservation Committee The Port Authority of Chairman, Director New York and New Jersey New York City Audubon Society One World Trade Center 71 West 23rd Street, Suite 1828 New York, N.Y. 10048 New York, N.Y. 10010 Ezra I. Bialik', Esq. Greater New York Council on 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 . Atomic Safety and Licensing Board Panel Alfred B. Del Bello U.S. Nuclear Regulatory Commission Westchester County Executive Washington, D.C. 20555 Westchester County g 148 Martine Avenue Atomic Safety and Licensing New York, N.Y. 10601 Appeal Board Panel J U.S. Nuclear Regulatory Commission Andrew S. Roffe, Esq. Washington, D.C. 20555 New York State Assembly Albany, N.Y. 12248 Honorable Richard L. Brodsky Member of the County, Legislature Renee Schwartz, Esq. Westchester County Botein, Hays, Sklar & Herzberg County Office Building Attorneys for Metropolitan White Plains, N.Y. 10601 Transportation Authority 200 Park Avenue Pat Posner, Spokesperson New York, N.Y. 10166 Parents Concerned About Indian Point Stanley B. Klimberg P.O. Box 125 Croton-on-Hudson, N.Y. 10520 General Counsel New York State Energy Office 2 Rockefeller State Plaza Charles A. Scheiner, Co-Chairperson Albany, New York 12223 Westchester People's Action Coalition, Inc. Honorable Ruth Messinger P.O. Box 488 Member of the Council of the White Plains, N.Y. 10602 City of New York District #4 Alan Latman, Esq. City Hall 44 Sunset Drive Croton-on-Hudson, N.Y. 10520 New York, New York 10007 .] . _ - ;.. . -3- ( Lorna Salzman * Mid-Atlantic Representative Friends of the Earth, Inc. 208 West 13th Street New York, N.Y. 10011 Zipporah S. Fleisher West Branch Conservation Association 443 Suena Vista Road . New City, N.Y. 10956 Mayor George V. Begany Village of Buchanan 236 Tate Avenue Buchanan, N.Y. 10511 Judith Kessler, Coordinator Rockland Citizens for Safe Energy 300 New Hemstead Road New City, N.Y. 10956 David H. Pikus, Esq. Richard F. Czaja, Esq. 330 Madison Avenue New York, N.Y. 10017 Ms. Aranda Potterfield, Esq. P.O. Bax 384 Village Station Now York, New York 10014 Mr. Donald L. Sapir, Esq. 60 East Mount Airy Poad IE 1, B3x 360 Croton-on-Htrison, New York 10520 . .- . - _ ..