Statement by Federated Conservationists of Westchester County
March 1982
CONCERNING

THE WESTCHESTER RADIOLOGICAL EMERGENCY RESPONSE PLAN
PRESENTED TO THE INDIAN POINT ATOMIC SAFETY AND
LICENSING BOARD AT THE HEARING JANUARY 14, 1982 IN CORTLANDT.

We have reviewed the Westchester County Radiological Emergency Response Plan (WCRERP) and, although a great deal of thought and effort has gone into it, much more remains to be done before it can be considered an "implemented plan." We have two main areas of concern and criticism: the first is with the plan itself and the second is with the implementation of the plan.

The plan itself is deficient because it considers only the 10 mile emergency planning zone (EPZ). It is granted that the 10 mile EPZ meets the letter of the requirements of the Nuclear Regulatory Commission (NRC). The spirit of the NRC requirement is that the plan for each site accounts for the unique aspects of each. A major unique feature of this site is the enormous surrounding population. The must be considered in the plan s it may influence operations within the 10 mile EPZ. The plan does not do this. If there is a release of radioactive material from the plant requiring notification of the public, a great many people who do not live or work within the 10 mile EP are going to react. Their reactions will influence the events within the 10 mile EPZ. Therefore, the plan should include a detailed consideration of the effects of a public announcement on the surrounding population, anticipate their possible reactions and the consequences thereof and include a public education/information campaign to mold these reactions in reasonable directions.

There is another aspect of the plan that we question. This is the designation of fixed egress routes for each emergency response planning area (ERPA). It seems reasonable to us to expect that the optimal egress route would depend on the meteorological conditions, whether the evacuation is partial (some ERPA's) or complete (all ERPA's), and the size and type of release from the plant. Are these provisions for tailoring the egress routes on the basis of these additional variables? The plan doesn't seem to contain any.

We also believe that a message exchange center should be part of the plan. The purpose o such a center would be to facilitate the reuniting of families separated in an evacuation. It would function by receiving and storing phone messages from anyone involved in the evacuation and by retrieving and conveying the messages to anyone querying the system. Such a message center would relieve much of the anxiety caused by being urged to evacuate in other than family groups.

Our main concern about the plan centers on its degree of implementation. There are 5 areas that concern us and until these concerns are resolved we believe that the plan should not be considered implemented.

1. Agreements must be signed between the various agencies in charge of carrying out the emergency responses under the plan and the facility operators. These agencies must accept the responsibility for carrying out the actions delegated to them in the plan and they must believe that they have the means of doing so. Specifically some of these agencies are:
   

   a - the four county governments
   b - the bus companies and drivers
   c - the various school districts inside and outside the EPZ that would be involved
   d - the teachers, nurses and doctors
   e - the tow truck owners and drivers
   f - Conrail and its employees

   If an evacuation is necessary, many of these individuals will have conflicts of interest. Hey will be torn between helping in the evacuation and concern for being with and getting their own families out. We believe that enough of these people will participate in the evacuation but that they must be recruited and informed. Their commitment to help must be formalized or they cannot be counted on.

2. All necessary hardware (dosimeters, radios, protective clothing, maps, etc.) must be acquired, and in workable conditions.
3. Assurances must be given that necessary personnel have been trained and will always be available.
4. Sufficient funds must be made available to create and maintain the resources to carry out the plan. The $250,000 assessment per plant under statute may be adequate for most sites in New York State but is undoubtedly inadequate for the Westchester and metropolitan area.
5. The public information/education program must be implemented. Six months have elapsed since the plan was to have been implemented and still there has been no distribution of informational materials. In addition, a survey should be conducted after the first round of public education has been carried out. It is our feeling that the public informational program is inadequate and therefore the plan should be considered not implemented until 80% of the general public with the EPZ can:
   

   a - identify the ERPA of their residence and workplace (as it would be identified in a public announcement).
   b - Cite the means and routes of egress from their residence and workplace.
   c - Identify the means of egress and the destination (reception center, congregate care center or school reception center) that all members of their immediate family would use in the event of an evacuation on either a school or non-school day.

In conclusion, we believe that the WCREP was not implemented as of June 21, 1981 nor do we believe it is implemented or implementable now. If this means that the plants must be shut down, so be it.