ML18004A397

Urges Denial of Util Request to Waive Full Scale Test of Evacuation Plan Before Licensing Plant to Operate,Based on Findings of Encl Critique of Lee County Evacuation Plan Prepared by Citizens.Existing Plan Inadequate & Unworkable

ML18004A397
Person / Time
Site:	Harris
Issue date:	08/06/1986
From:	Jay Robinson AFFILIATION NOT ASSIGNED
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8608070317
Download: ML18004A397 (47)

Text

REQUL*T INFORMATION DISTRIBUTI0 YSTEN (R IDS)

ACCESSION NBR: 8608070317 DOC. DATE: 86/08/06 NOTARIZED: NO DOCKET FACIL: 50-400 Shearon Harris Nuclear Poeer Plant Unit i. Carolina 05000400 AUTH. NAI'%UTHOR ~~FILIATION ROBINSON, J. L. Affiliation Not Assigned RECIP. NANE RECIPIENT AFFILIATION DENTONp H. R. f Of ice of Nuclear Reactor Regulation. Director (p ost 851125

SUBJECT:

Urges denial of util request to tuaive full scale test of evacuation plan before licensing plant to operate> based on findings of encl critique of Lee County evacuation plan prepared bg citizens. Existing plan inadequate 8c unworkable.

DISTRIBUTION CODE YE03D COPIES RECEIVED: LTR I ENCL JRelated SIZE:

TITLE: Request for NRR Action (e. g. 2. 206 Petitions) i% Correspondenc NOTES: Application for permit renewal +iled. 05000400 RECIPIENT COP IES RECIPIENT COP IES ID CODE/NANE LTTR ENCL ID CODE/NANE LTTR ENCL PNR-A PD2 LA 1 1 PAR-A PD2 PD 1 BUCKLEY, B 01 1 INTERNAL: EDO/ACB 1 1 ELD/HDS1 1 1 ELDER 1 1 NRR DIR 1 f f EXTERNAL: LPDR 03 f 1 NRC PDR 02 1 1 gSIC 05 1 1 TOTAL NURSER OF COPXES REGUIREO: LTTR

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504 Gotten Road Sanford, North Carolina 27330 August 6, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 RE: SHEARON HARRIS NUCLEAR POWER UNIT 1 - DOCKET NO. 50-400 EMERGENCY PREPAREDNESS EXERCISE

Dear Mr. Denton:

It is my understanding that Mr. S. R. Zimmerman of Carolina Power and Light has made a special request of you and your staff to except CP&L from a full scale test of the emergency evacuation plan within one year before the plant is granted a license to operate.

I submit to you a Critique of the Lee County Evacuation Plan prepared by concerned citizens who believe the plan to be yet inadequate and unworkable.

We have contacted numerous individuals from different agencies identified by the plan as those persons responsible for public health and safety in the event of a nuclear accident. Many of these persons acknowledged a lack of understanding of their duties and responsibilities in such event. In fact, at a public meeting held in Sanford on July 31, 1986, the Emergency Operations Coordinator acknowledged that the County School Superintendent had not received a Standard Operating Procedure until two weeks prior to that meeting. Such Standard Operating Procedure includes the duties and responsibilities of persons involved with the safety and welfare of school children and persons who will interface the use of the schools as evacuation shelters. Needless to say, such procedures represent a large part of the emergency plan. Yet, available until July of this year. Consequently, there is it was not no way that this 0 important part of the plan could have had previous testing.

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i geR OOD, i NO Another serious deficiency indicated in the Critique which was made even more apparent at the public meeting on July 31, 1986 is the lack of coordination

+A and understanding between the many governmental agencies who are responsible for iNO implementing the plan. Mr. Al Joyner, representing the State Emergency Planning NO Office, on three occasions referred to the telephone which connects the Sanford OR Emergency Operations Center with the Shearon Harris Plant as the "Blue Phone,"

while Mr. Bill Ray Cameron, Lee County Emergency Operations Coordinator, iN referred to the same phone as the "Red Phone."

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Mr. Harold R. Denton Office of Nuclear Reactor Regulation Page 2 August 6, .1986 Now, it would seem that for any telephone so important, the color would be clearly decided in advance. And, no matter whether for SERT or Lee County, the color would clearly relate to its purpose.

The Critique also identifies the need to establish one point of authority and eliminate any need to transfer authority and/or control during an emergency.

When Mr. Cameron was questioned about this matter at the public meeting on July 31, 1986, his response was, "I'm t'e boss. I will not turn over authority or control." Now, the plan clearly states that local government and emergency service organizations must plan for and be prepared to direct all off-site emergency operations for approximately the first one or two hours of the emergency. Thereafter, the State shall assume direction and control.

In view of the fact that the Director of Federal Emergency Management is empowered with authority to enact marshal law and/or arrest even the President of United States himself during a state of emergency, it would seem that Billy Ray Cameron's statement reflects more concern for his own personal ego than the safety and welfare of the citizens of Lee County.

Please, I urge you to consider each of the findings of the attached Critique and with your very best conscious do not grant the request from CP&L to waive the full scale test of the evacuation plan before licensing the plant to operate.

Thank you for your attention and concern in this matter.

Sincerely, Jack L. Robinson JLR/cs Enclosure cc: Editor, The Sanford Herald Editor, The News & Observer Editor, Durham Chronicle

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CRITIQUE OF THE NORTH CAROLINA EMERGENCY RESPONSE PLAN IN SUPPORT OF THE SHEARON HARRIS NUCLEAR POWER PLANT (Revised September 1984)

Fifteen years ago, at a time when gasoline was twenty-eight cents per gallon and electricity one cent per kilowatt hour, the citizens of Lee County were promised a safe, clean, efficient, low cost source of power. It was to be fail safe. There would be no noxious fumes to poison our forests. It was to be so efficient that a small thimble could contain the energy equal to one hundred tons of coal, and it was to be so inexpensive that some folks were lead to believe that metering would be unnecessary. In fact, it was heralded in some forms to produce more energy than it consumed.

Shortly thereafter, in 1973, came the Great American Scare. Overseas energy sources dried up. Americans were told that the demand for electric power was doubling every ten years; that our natural resources were almost gone; that natural gas would last less-than twenty five years; that oil would .run out shortly thereafter, and that coal would be gone in less than 100 years.

We were told that nuclear power was the only solution. It was needed for nation-al security. It was our only hope to maintain the way of life to which we had become accustomed. It was patriotic. To.believe otherwise was considered un-American.

It's sad to say, but we were fooled. Five things have changed to evidence that fact.

1. The need for electric power has not continued to double at the rate predicted. Conservation and awareness to save energy have reduced demand and consumption.

2. When the price of crude oil reached thirty dollars per barrel, more reserves suddenly appeared.

3. CP&L claimed nuclear power would be cheap. Only later did they acknowledge that the increased cost of constructing the power plant would actually increase the cost of electricity.

4. CP&L claimed nuclear power would be safe. Yet, recerit accidents at Three Mile Island and Chernobyl (as well as many less publicized "incidents")

indicate otherwise.

5. Should CP&L successfully operate Shearon Harris as a nuclear power plant without an accident for 30 years, we will still leave a lethal radioactive waste problem for future generations.

After fifteen years, CP&L has not only neglected to find a solution to the problem of safely disposing of nuclear wastes, but intends to compound the danger by transporting hazardous wastes from Brunswick and Robinson plants to be stored at Shearon Harris.

We, as citizens of Lee County, feel we have been duped. We have helped build and pay the interest on Shearon Harris through the cost of work in progress (CWIP).

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We have supplemented the CP&L retirement plan through the Federal Income Tax Credit.

And, just as others at THI and Chernobyl, we have been repeatedly told that the plant is safe. If it were truly safe, would we need an evacuation plan2 Just as those aboard the Titantic and even more recently, those aboard the Challenger were victims of a false sense of security, we believe the Shearon Harris plant is another attempt by man to fool himself into thinking he can accomplish the impossible.

We have reviewed the Lee Count Procedures to Su ort The Shearon Harris Nuclear Power Plant with revisions dated September, 3, 1984 and present to you our findings.

LEE COUNTX PROCEDURES TO SUPPORT THE SHEARON HARRIS NUCLEAR POWERED ELECTRIC GENERATING PLANT PURPOSE The United States Nuclear Regulatory Commission Regulation /10654 Revision 1, dated November 1980, required that local government develop an emergency response plan for all areas that lie within ten miles of a fixed nuclear facility. A portion of Lee County lies within the ten miles radius of the Shearon Harris Nuclear Plant.

Having initially met the necessity to present a plan on paper does not automat-ically guarantee protection of people and property or fulfill the needs of the commu-nity. The comment has been made that any plan is better than no plan. A plan which is adequate for a natural disaster may not be so in the event of a nuclear accident.

Having conceded that because of inadequate information and lack of input from both county employees and the public. B. R. Cameron claimed in an .interview on June 23 that he is still writing a plan to be released in July. This discounts a previous report he made in the Herald that the plan was complete and would be available in a few days at the local library.

CONCEPT OF OPERATIONS The best planned evacuation will undoubtedly experience "foul-ups" but to develop a plan where authority and control are intended to shift during the emergency is pure folly. It goes without saying that a nuclear accident would effect the population of more than one county. For this reason any valid plan must include immediate state response. The present plan provides for state direction and control only after the counties have attempted to cope with the problems for one to two hours. Since any nuclear accident will effect the lives of people in more than any one county it is important that the state assume immediate control in such emergency. The one to two hours delay as presently called for is inefficient and unnecessary. Naturally, the county response teams can be expected to mobilize and be at the site first, but they should do so with the State Emergency Response Team in control to. avoid unnecessary delay and confusion. There is absolutely no emergency condition which could or should be allowed to exist without the knowledge and involvement of the State Emergency Response Team. To do otherwise is pure follyl The Emer enc Plan is not desi ned to deal with the most serious nuclear accidents ossible.

>beany persons contacted who would be responsible for implementing the evacuation plan, including B. R. Cameron, deny any need to prepare for radioactivity and decon-tamination.

The worst type of nuclear accident would most probably release radiation before this plan could possibly be implemented. At THI, the radioactive plume escaped hours before the accident was publicly announced.

The citizens of Lee County deserve a plan designed to meet the worst case situation. To settle for anything less is irresponsible.

CP&L spokesman D. W. Graham has stated "There is no way that people who shelter in place wouldn't be exposed to some radiation." Such would apply to those who were informed in time to seek shelter. For those who are uninformed, decontamination becomes even more important.

Since there can be no absolute guarantee of safety, why are we denied the peace of mind insurance coverage can buy2 The Emer enc Plan rovides no rotection at all for eo le outside the ten mile zone.

That means that in the event of a major nuclear accident, there is no plan whatsoever for Sanford. In fact, the plan will evacuate people to Sanford. Yet in Sweden, over 800 miles from Chernobyl, they cannot drink the milk they produce. A Nuclear Regulatory Commission Reactor Safety Study (1975) states that a core meltdown with a breach of containment would contaminate 3,200 square miles (31.9 mile radius) to such levels of- radioactivity that they'ould remain uninhabitable for a century.

CP&L denies that a meltdown is possible at Shearon Harris; yet the Oak Ridge "Precursor Study" suggests that the chance of a core meltdown accident in the next seven years is 64X and that it is 93X by the year 2000. And on Sunday, April 9, 1979, following the 'Qil accident, E. E. Utley, CP&L Vice President for Power Supply, stated in an interview with the Ralei h News & Observer that "The Shearon Harris Nuclear Plant is basically similar to the TMI plant, and it would be possible for a similar accident to occur here." Yet the plan calls for the evacuation of only those within a ten mile radius.

There is now new information that points out inadequacies in the NRC's and CP&L's ten mile maximum Emergency Planning Zone. 'Although the recent nuclear accident at Chernobyl supports this information, this research is totally independent of that event.

"Those responsible for assuring the health and safety of the public should be aware that current techniques have not been used in establishing the EPZ and there are serious questions in regard to some of the assumptions under which it was established.

The obvious implication is that these calculations and the resulting 10-mile recommen-dation are therefore suspect and uncertain for purposes of protecting public health."

(Appendix A)

These statements are supported by another expert who has worked in the Triangle area for four decades as an expert in air pollution meteorology. Hershel Slater says, "Notwithstanding current NRC regulations, CP&L and the State can take the initiative to fine tune the configuration of the SHNPP EPZ. CP&L has the data and the pro-fessional competency to do so. In light of the concerns of so many, it is prudent for CP&L so to do." (Appendix B)

Even in its present form the emergency plan suggests the following: "The size of the EPZ and the emergency plan are not restricted to, nor designed specifically for protecting only the people in, the 10-mile EPZ. They are designed for the protection of all areas and all people that could be affected by an accident. The NRC assumes

that any emergency plan deemed adequate for a 10-mile radius is sufficiently detailed to be adequate to cover emergency needs in areas beyond the 10-mile EPZ (NUREG 0396, pp 15-16)....Local officials are responsible for deciding if this type and size of emergency'planning is acceptable and adequate. There should be demonstrable assurance of ad hoc capability being adequate." (Appendix A)

Essentially what this means is up to date methodology is required to determine where the radiation plume is once an accident has occurred, but techniques that are as much as ten years old were the basis of the present ten mile zone. In the field of meteorology, this ten year difference may be compared to trying to achieve earth orbit with a helium balloon instead of a modern day rocket.

The Emer enc Plan offers no rotection at all to livestock and a ricultural interests.

The ERP makes no plans for the protection of livestock during a nuclear accident.

And yet, farming is integral to the livelihood of Lee County. CP&L is presently obtaining baseline radiation level information in the ingestion pathway, which is a 50 mile radius around SHNPP. " They aie concerned about radiation levels in dairy milk, water sediment, broad leaf crops, as well as air. This is being done to determine potential food chain implication. Numerous unanswered questions exist. How will farmers be notified quickly and what are their available responses to take to protect their livestock? There may be farmers who live outside the ingestion pathway zone who have animals inside the zone. These farmers under the present plan will not be notified to take protective measures for their livestock and the financial well being of their businesses.

The local Extension Service is expected to help feed the evacuees, locate uncon-taminated feed for livestock, and restrict the sale, distribution and warehousing of livestock, produce, and processed food products as needed. The Extension Agent, when contacted, was totally unaware of his responsibility to sample and monitor areas accessible by fish, close contaminated areas to fishing and confiscate or prevent the sale of fish from the contaminated area.

Not only was the Extension unaware of'll this, but it also causes one to wonder where the Fish & Wildlife people have gone.

The fact is farmers have not been systematically identified and notified of instructions in case of an evacuation as a separate group with special needs. There are no feed reserves as of this writing and there are no water alternatives planned for animals at this time. Additionally, there is no special state or federal agricul-tural team or individual ready to monitor farm products. Presumably, experts would be called in to accomplish this work, but the question remains how long this process will take to get underway.

Other uestions are:

Who is a farmer? Do State officials know all growers regardless of size? What about the few pigs or chickens in someone's backyard? What about small plantings of commercial produce sold at farmers markets?

I How'will farmers be protected from exposure if they reenter contaminated areas as the plan says, following an accident to provide feed and water to their animals?

'I The Emer enc Plan unreasonabl relies on the rom t and effective coordination of more than thirt federal, state and local a encies.

Common sense dictates that without much careful practicing of the Plan by all parties involved, this type of coordination is impossible to expect, especially in the short time allotted them., Key personnel will inevitably be unreachable (errands, vacations, etc.). If the emergency occurred at night, personnel would be groggy, and coordination with other agencies would not be feasible.

Research conducted in Suffolk and Nassau Counties in New York shows that up to 40% of the population within 25 miles may self-evacuate if it is even suggested that some of those within 10 miles will be evacuated. This research was conducted BEFORE the Chernobyl accident. The Emergency Plan does not take into account this "shadow effect," as total traffic flow for the area during the accident is based upon evacuation occurring only for those within the ten mile area. Much higher traffic congestion levels than assumed by the Plan would undoubtedly occur. Our informal polling of Lee County residents who live further than ten miles from the plant suggests that most will self-evacuate in the event of any nuclear accident.

In addition, studies of the recommended (but not required) evacuation of the Three Mile Island area show that while parents with young children will self-evacuate far into the "shadow" around ten miles, the elderly even those within the recommended evacuation distance are much less likely to be willing to leave their homes and their land.

There has been far too little research completed for any state agency to predict actual public behavior in the event of a serious nuclear accident. The research which has been conducted directly contradicts assumptions central to the feasibility of the current evacuation plan. (See Appendix A)

Steven A. Forry agrees with those who have concerns. "The bottom line is that in all reality there is no such thing as a feasible plan," said Forry, Deputy Director of Emergency Management in Newberry Township, about three miles from the TMI plant.

"Even in so called controlled circumstances like TMI, we had fist fights trying to get gas so people could head down the road and'ot stop ... I know for a fact that if you tell thousands of people to evacuate, no eight or ten people will stand in their way."

ORGANIZATION AND RESPONSIBILITIES The Emer enc Plan makes unreasonable assum tions about and inade uate rovisions for medical care.

The Central Carolina Hospital in Sanford has been designated to receive a maximum number of 10 patients. Given the potential number of contaminated victims which might result from a serious nuclear accident, it is reasonable to assume that these facilities are far from adequate. Dr. Robert Gale, who witnessed the evacuation of 92,000 from Chernobyl, has questioned the ability of all the medical facilities in the U.S. to handle the victims of a major nuclear accident.

In light of Dr. Gale's statement, we seriously question the ability of area hospitals to handle their designated number of contaminated patients. We question where and how large numbers of severely irradiated people will be decontaminated.

Billy Ray Cameron has stated that he is not concerned with decontamination he is only concerned with evacuation. He claims there would be no radioactive contamina-tion.

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We are concerned about the overall and unknown effects of radiation contamination from contaminated victim washdown. The current plan calls for contaminated water to enter the ground water through the sewage system. The effects of this on the ecosystem are unknown. Although dilution of the contaminates might appear to be high, many forms of life selectively absorb and concentrate radioactive elements.

EXEC U TION The Emer enc Plan is based on erroneous assum tions about how the ublic will res ond in the event of a nuclear accident.

The most fundamental inaccuracy is that the public will react to a nuclear disaster as they would to a non-nuclear disaster. Research on natural and non-nuclear disasters has shown that individuals and families will only evacuate when confronted with direct sensory evidence or explicit and convincing warning messages. Whereas in the event of a radiological disaster, studies suggest the public intends to ignore official advice by eva'cuating sooner than recommended, more people will evacuate than required, and those evacuees will travel farther than suggested.

The Emer enc Plan makes unrealistic assum tions about the amount of time it will take to warn and evacuate the ublic.

Warning procedures are cumbersome, convoluted and even shared by several persons and agencies. Prompt notification is nearly impossible to achieve.

The warning system for Lee County involves ringdown, callback verification, authenticator code words, warning message report forms, and telephone calls to the County Manager, Chairman of the Board of Commissioners, EOC staff, Mayor of Sanford.

Notifying the public involves locating the County Manager or Chairman of the County Commissioners to make the decision to activate the Emergency Operations Center. The second step involves first sirens, then vehicles with sirens or public address systems, and finally door-to-door alerting. The times for notification of the public by public address systems mounted on vehicles are 37 and 42 minutes for vehicles covering 13 to 14 miles; yet these vehicles are to stop every quarter mile to make announcements.

Furthermore, the Emergency Plan is primarily of a precautionary nature. Yet the NUREG-0654 upon which it is based states: "The range of times between the onset of accident conditions and the start of a major release is of the order of one half hour to several hours." Yet, Billy Ray Cameron has determined it will take at least one hour to activate the Emergency Operations Center under the very best conditions. The only other option is sheltering (staying at home with the windows closed) which FEMA (Federal Emergency Management Agency) guidelines indicate may be effective no longer than two hours.

In the event of a nuclear reactor accident, those responsible for the health and safety of the public will have to decide how to protect the public. The Emergency Response Plan (ERP) for the Shearon Harris Nuclear Power Plant outlines two basic ways to protect the public: evacuation and sheltering. The term "sheltering" refers to members of the public taking advantage of the inherent radiation shielding available in normally inhabited structures by remaining indoors while the radioactive cloud passes.

The relative merits of evacuation versus sheltering depend upon the specifics of the given accident. Some parameters to be considered include severity of the accident, site location, meteorological conditions, and effectiveness of the

F, sheltering (1). The ERP does not however address the issue of sheltering effectiveness in Lee County. The amount of effective sheltering will vary depending upon the construction of the dwelling. A wood frame house without a basement provides little shelter (.9 shielding factor) from gamma cloud sources of radionuclides (2).

The FEMA/NRD emergency planning and preparedness criteria document'NUREG-0654) requires nuclear facility and state officials to provide the bases for the choice of recommended protective actions for the plume exposure pathway during emergency conditions (3). The bases are to include, for example, expected protection afforded in residential dwellings for direct and inhalation exposure to radionuclides (2). The ERP does not document any established shielding factors (shielding effectiveness) for the dwelling in the ten mile Emergency Planning Zone (EPZ) in Lee County. How can an appropriate decision be made whether to evacuate or shelter without such information?

SUPPORT RESOURCES Sanford water supply is picked up two miles south of the Haw and Deep River junction. If northern Lee County is contaminated, then the water supply of Sanford will be contaminated, the ramifications of which are unthinkable.

Storehouses of food and clothing are not known to exist. B. R. Cameron claims he has authority for impounding/and/or confiscating supplies. Who will pay?

The plan specifies a certain number of monitoring devices to be stored at the Emergency Management Office and issued to the Sanford Fire Department. There has been no provision for constant off site monitoring conducted by persons in no way connected to CP&L. Such equipment is needed in each community and base line readings are needed before the plant goes into operation.

The Chernobyl accident demonstrated that the first workers on the scene had the most radiation exposure. Yet, the Emergency Plan provides no backup personnel for the local firstline people responsible for emergency work. At best, the state needs at least two to three hours to have a full command post. How long will traffic control people within the radiation area be able to stay at their posts? Who will replace volunteer fire and rescue personnel?

The Plan states that the senior elected official may order personnel back into irradiated areas until they reach a 75 rad. limit. (This is enough radiation to cause sickness, burns, genetic damage to offspring, tumors, lowering of immunity, etc.)

This policy indicates the lack of backup personnel and protection for volunteers. We hope volunteers will be notified of such an order and be given an opportunity to reject the order. What measures would be used to enforce such orders?

The evacuation map shows the Buckhorn Road routed one way with the east section routed back toward the radioactive area.

What means will be used to enforce the plan?

Would weapons be used to implement the plan?

What provisions are included for shifting winds which might change the plume?

The plan states that it will take seven years to fully test all responses to the plan. Obviously, it has not been seven years since the latest revision of the plan.

Shouldn't all phases of the plan be tested to prove the plan is 100K operational?

Why was the June 14 mock evacuation called off2 We believe this plan should not and must not be accepted until all phases have been tested and roven o erational.

EMERGENCY COMMUNICATIONS The plan indicates that the amount of time required to activate the EOC can range from one hour to two hours fifty minutes. We consider this unacce table)

Fire departments and sheriffs'epartments are responsible for public warning.

It is also their responsibility to identify hearing impaired. households so that in an emergency they can provide "knock on the door type notification." No provisions are made in the ERP to make sure the individuals who knock on the door can communicate effectively with a hearing impaired person. Identification of these people will be through a "special needs response card" received from an annual mailing of safety information to all ten mile EPZ residents. No provision is made for those who might move to the area or lose their hearing between mailings.

Night notification has not yet been checked out but the plan calls for at least one annual exercise between 6 p.m. and midnight, and one between midnight and 6 a.m.

in the next six years. The plan does not say what we will do if an accident occurs during those times before the test exercise.

There is no provision for those who are temporarily without transportation or temporarily handicapped or "shut-in." Annual mailings will make a list of those who send in their cards, but there is no one "assigned" the responsibility for the There their condition is also no way to know worsens between mailings.

if an individual becomes handicapped or lists'ccuracy.

if There is another aspect of notifying the public that should also be considered by emergency planning personnel. Again, this is a factor that is not required by the NRC, the State, CP&L, or any other organization, but research has shown that there is a tendency in a nuclear accident for a larger area to evacuate and for people to leave; hence making the responsibilities of local officials even greater. The ERP does not take this effect into account. (Appendix A)

The Emer enc Plan makes inade uate rovisions for the'trainin and rotectin of volunteer workers.

i Many Lee County volunteers, health and other social service personnel, have expressed serious private reservations about the adequacy of the Plan.

We feel the Plan does not adequately address the effects of high turnover in volunteer organizations on training.

During an interview, a landfill employee stated that he:was aware that he was written into the plan. His role is to assist with washing vehicles with water in order to decontaminate them. He stated that he was not trained to do this and that he would not participate. This response was common to others who normally do not participate in emergency response but who are included in the ERP. Their basic concern in our opinion relates to the difference between a nuclear accident and a more common accident (i.e. chemicals/hazardous waste). In many normally encountered emergencies, people have been extensively trained prior to the situation and they are nearly always supplied with state of the art safety equipment. This, as far as we can tell by investigating the plan, is not the case with many of the rescue/emergency

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workers who are designated to work during an emergency evacuation resulting from a nuclear release from Shearon Harris Plant. These same volunteers did not believe the evacuation drill completed last year (1985) was adequate. Some felt a need for more on the gob .training with more public participation than during the last drill in order to better simulate a realistic accident. Some mentioned that they had not received much training in decontamination. The logistics of separating contaminated and uncontaminated people in the shelter needs to be worked out as does the specific tasks of staff members at the shelters.

It appears the drill conducted last year in Lee County indicated that equipment and facilities are "marginal." Webster's dictionary defines marginal as "close to the lower limit of acceptability." This directly conflicts with statements by CP&L, the State, and FEMA.which highly praise the success of the drill. Do we in Lee County want a plan that our very lives depend upon to be "marginalf" Part of the problem with the'acilities is that they cannot possibly contain all the people that might in fact need them. Federal Government projections of the number of people that will utilize the Jordan Lake area are 27,000 people per day. Even if only 15,000 people at the Lake required evacuation, and they were divided between the three schools in Lee County (our evacuation centers),. they would clearly be over the "assumed capacity of 4202 evacuees that the plan says these facilities can hold.

PLANS, EXERCISE D RILLS AND TRAINING The Emer enc Plan makes inade uate rovision for the rotection of school children.

School bus drivers, frequently high school students, are expected to drive school children to the evacuation shelters. We question, not only their ability under stress, but also whether their parents would condone such responsibilities.

Teachers are also expected to accompany their class or classes to the shelters and remain there as a calming influence until parents arrive. The teachers we con-tacted were not aware of their responsibilities. They also had child'ren of their own to be concerned about.

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The Emer enc Plan makes inade uate rovision for evacuation of the elderl , the handica ed, and the immobile.

The Emergency Plan is based on the assumption that rescue personnel have in hand at all times an accurate list of the location of the elderly, the handicapped, and the immobile.

How often is this list updated2 Are such special people in Lee County's ten mile EPZ known to the EOM. How many people might be temporarily immobile and not on the EOM's listP Ken Franklin, President, North Carolina Alliance of 'Disabled and Concerned Citizens stated:

"Officials are making certain assumptions about this situation, but it's their responsibility to protect all the people. In Russia, school children were evacuated from Kiev, which is 80 miles away. Yet, here the limit is only ten miles."

"The quality of life in a shelter would be detrimental to persons with conditions which could require special foods or equipment, such as diabetes, heart conditions, asthma, spinal injuries."

"What if the immobilized people are not at home if an accident happens2 Rescue workers could risk their lives trying to save people who are not even there."

The Emer enc Plan makes unreasonable assum tions about and inade uate rovisions for trans ortation.

There is no empirical basis for the assumptions about traffic movement. In fact, the 1,500 cars per hour figure assumes that evacuation is orderly, without accidents, and only within the ten mile zone; all these assumptions are preposterous and totally ignore the element of panic and the two lane roads.

The plan does not anticipate the need of evacuees for gasoline. There are no provisions for mobile gas stations or private stations remaining open.

The Plan is based on evacuation by private vehicle. Those without transportation are a constantly shifting population. There is not adequate provision for locating or evacuating these citizens. Many non mobile people are unaware of the need to send in a card. Even if they do, they have no assurance help will arrive in a panic.

The evacuation plan states that home healthcare vans, school buses and volunteer fire department vehicles will provide transportation for the schools, homebound, handicapped, mobility impaired, those without transportation and evacuees with impounded contaminated vehicles despite the fact that the schools and fire squads and home healthcare organizations are already burdened with responsibilities which over-extend their capabilities and overtax their resources.

ALSO TO BE CONSIDERED:

1. Where are signs for evacuation routes and decontamination stations2 Such signs need to be erected ahead of time and decontamination stations located and constructed with containment units for washdown.

2. Is protective equipment for volunteers in place where it will be needed2

3. Is monitoring equipment'vailable where needed and does it work2

4. Is the KI on hand at shelters and how long is the shelf life2

5. Are there special provisions for women'ho are pregnant2

.~ "Crap J

CONCLUSION We believe the following resolution needs to be adopted in Lee County to allow consideration for the county wide population.

RES OL U TIO N The Lee County Board of Commissioners, having met in regular session with quorum present and all requirements satisfied to undertake the matters below, Hereby, FIND, RESOLVE,,ENACT AND PETITION AS FOLLOWS:

1. WHEREAS Carolina Power and L'ight Company has built a nuclear power plant and associated facilities in Chatham and Wake Counties and has applied for a license to operate the plant;

2. WHEREAS as part of the licensing requirements to operate the plant, Carolina Power and Light has prepared a plan to evacuate and protect nearby citizens in case of an accident or dangerous release of radioactive substances;

3. WHEREAS in earlier considerations of the Shearon Harris emergency plan the Board of Commissioners did not have adequate information and input from both county employees and the public;

4. WHEREAS the Lee County Board of Commissioners has now studied additional information, heard more fully from the public and CP & L, and consulted with county employees who would be responsible for important parts of the emergency plan; (

THEREFORE THE COMMISSIONERS HEREBY RESOLVE AND ENACT:

1. Lee County rescinds and withdraws from any prior approval of the emergency plan for the Shearon Harris Plant;

2. Lee County shall establish an advisory committee consisting of ten Lee County citizens representing varied special interest and occupational groups to make further evaluation and recommendations to the Board of Commissioners concerning the evacuation and accommodation of all persons living and working in the county.

3. Lee County shall request CP&L to provide monitoring equipment to be installed and operated at not less than five different locations within the county.

4. Lee County shall require CP&L to demonstrate the adequacy of the emergency plan by conducting a full scale unannounced mock emergency to include Sanford and the entire population of Lee County.

5. Lee County requests the Governor of North Carolina, the Nuclear Regulatory Commission, the Federal Emergency Management Agency, and all other responsible federal and state agencies and officials (a) to revoke and/or refuse to issue any permit, license, or other approval which Carolina Power and Light Company may hold or need to operate the Shearon Harris nuclear plant with an emergency plan; (b) to prevent and prohibit the fueling of this plant and its operation at any level of output.

(c) to enforce the above revocations and prohibitions until such time as all matters of public health and safety have been addressed to the satisfac-tion of this Board.

APPENDIX A Comment on Outdated Federal Guidance for Size of the Emergency Planning Zone Kenneth G. Sexton, Ph.D.

Research Associate Dept. Environmental Sciences and Engineering School of Public Health University of North Carolina June 30, 1986 Q. "IS A 10-MILE EVACUATION AK<M ADEQUATE'P" A. NO ONE REALLY KNOWS.

Why not'? There are many uncertainties in predictions of nuclear-power-plant-accident consequences. These result from uncertainties in the prediction techniques and in input data. The NRC is currently attempting to resolve major uncertainties for'isk assessment. Generic rather than site-specific calculations were performed (using some outdated techniques and over-simplifying assumptions) to help determine the distance. The 10-mile evacuation plan is supposedly adequate to use as a base for evacuating additional areas outside the 10 miles as needed on a "ad

~h c" basis when an accident does occur. No one knows if will work until an accident happens because there are no it required formal, predetermined, evacuation plans in place outside the 10-mile area to evaluate. No one claims that deaths and injuries will not occur outside the. 10-mile EPZ in the case of a more severe accident.

There are several important points that should be made very clear to all officials concerned about protecting the safety and health of the people in the counties surrounding

~an nuclear power plant. These facts come from reports and regulations from the Nuclear Regulatory Commission and the North Carolina Emergency Response Plan (NCERP). The immediate concern is with the Shearon Harris Nuclear Power Plant (SHNPP). However, the following discussion applies to any nuclear power plant of comparable size because the 10-mile EPZ is a generic distance which applies to all U.S.

nuclear plants of comparable size.

The 10-mile emergency planning zone (or EPZ) is based on findings of a joint NRC-Environmental Protection Agency (EPA) Task Force which were published in 1978 (NUREG-0396).

They concluded that the 10-mile EPZ was more than adequate to protect the public. However, it is also made clear that:

Although ~o early fatalities and injuries will occur inside the 10-mile EPZ, the NRC (NUREG-0396, pg 17; NUREG/CR-2239, pp 1-3 to 1-6) and the NC Emergency Response Plan (NCERP, Part 1, pg 1) acknowledge that some of the early severe health effects (injuries or deaths) which would result from the more severe accidents will occur beyond the 10-mile EPZ.

provide for s ta e uc 'n "In addition, the EPZ is of sufficient size to early severe health effects (injuries or deaths) in the event of the more severe Class 9 accidents."

(NUREG-0396, p 17)

2) The size of the EPZ and the emergency plan are not restricted to, nor designed specifically for protecting only the people in, the 10-mile EPZ. They are designed for the protection of all areas and all people that could be affected by an accident. The NRC assumes that any emergency plan deemed adequate for a 10-mile radius is sufficiently detailed to be adequate to cover emergency needs in areas beyond the 10-mile EPZ (NUREG-0396, pp 15-16). The NRC, CP&L, and NCERP acknowledge that emergency response outside the 10-mile EPZ may be needed. -"The size of the EPZ represents a judgment on the extent of'etailed planning needed to assure an adequate response base" (NCERP, Part 1, pg 1).

The concept in the NCERP and NRC guidance is to use the EPZ planning as a "base for expansion of response efforts if necessary" (NCERP, Part 1, pg 1) and to respond on an "~ad oc" basis (NRC, NUREG-0396, pg 16).

3) The size of the 10-mile EPZ is "tempered" by probability (NUREG-0396, pg 15). Some amount of risk was determined by the NRC to be acceptable. Their decision was affected by low-probability estimates of the occurence and nature of severe accidents (NUREG-75/014). More recent NRC reports indicate that many of these earlier accident estimates may be too low (NUREG/CR-0400 cited in NUREG/CR-4199, pp 1; and NUREG/CR-4199, pp 8-9). There is much uncertainty in risk and probability estimates, as well as disagreement among experts on this matter (as indicated in different

NRC reports). The inclusion of' greater accident probability could result in the establishment of a larger EPZ upon reevaluation. Also, it should not be implied that the term "low-probability accident,"

indicates that a long time will pass before such an event occurs. It is therefore reasonable to expect that consideration of emergency plans be "tempered" by these uncertainties. Local officials should plan accordingly, especially when highly-populated areas are very near but beyond the presently-accepted 10-mile EPZ.

4) The latest NRC regulations published January 1, 1986 cite ~onl this 1979 Task Force report as a basis i'or determining the EPZ (10 CFR 50.47 and its Appendix E).

No report is cited which discusses or suggests a smaller EPZ for nuclear plants the size of the SHNPP.

Simple techniques and information now known to be inappropriate, or at least not the best, were used for

~ene ic calculations used in determining the lO-mlle EPZ. Furthermore, seemingly inconsistent NRC regulations do require "state-of-the-art" (current) computations be performed after an accident using site-s ecific information (eg. information specific to SBNPP) (NUREG-0654, Appendix 2, pp 2-2 and 2-3).

"State-of-the-art" models (NRC-sponsored) have been used in recent years to estimate radiation doses to the public under a .variety of accident and normal operation conditions, but evidently have not been used for reevaluation of the EPZ (NUREG/CR-2239, NUREG/CR-4199, NUREG/CR-3344, NUREG/CR-4000). Uncertainty is a major problem in accident predictions (NUREG/CR-2239, pp 2-7 to 2-10). There is, in fact, an on-going program for reevaluation of nuclear accident risk at the NRC, but work to date has been "greeted with skepticism...

There is a disagreement over the credibility of some computer modeling codes that are the basis for all the predictions that will come out of NUREG-0956"

(~i 'ncn April 1986, pp 153-154, attached).

Therefore, there is justification in requesting the NRC to review and update the 1978 Task Force Report, and consequently the justification for the size of the EPZ.

Current thinking would suggest that, the NRC should require the SHNPP and all other plants to reevaluate the 10-mile EPZ using on-site and national weather service weather data specific to the area.

Local officals are responsible for deciding type and size of emergency planning is acceptable and if this adequate. There should be demonstrable assurance of ad hoc capability being adequate. For example and specifically related to the SHNPP, consideration should be given to the effect on local emergency response efforts it were determined that Raleigh (and the state government) if needed to be evacuated. Local officials must decide they accept the very low NRC accident-risk and probability if estimates which were determined before the Three Mile Island accident -- a serious accident which 'occurred despite its "low probability" of occurence.

Those responsible for assuring the health and safety of the public should be aware that current techniques have not been used in establishing the EPZ and that there are serious questions in regard to some of the assumptions under which it was established. The obvious implication is that these calculations and the resulting 10-mile recommendation are therefore suspect and uncertain for purposes of protecting public health.

ADDITIONAL DISCUSSION

~db as The 10-mile Emergency Planning Zone (EPZ) follows:

th N I R 1t, tl '

is (NRG)

"Generally, the plume exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles (16 hm) in radius, and the ingestion pathway EPZ shall consist of an area about 50 miles (80km) in radius. The exact size and configuration of the EPZs surrounding a particular nuclear power reactor shall be determined in relation to local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries." (10,CFR Part 50.47 "Emergency Plans" )

This regulation recognizes that approximately a 10-mile radius is appropriate, but also implies that alternate sizes and configurations may be very significantly more appropriate. Although the regulation requires consideration be given to several area-specific factors, no mention is made of local meteorology. This is in contradiction to regulations for siting and post-accident calculations (10 CFR 100.10 and 10 CFR 50.47, respectively), and the findings of more recent accident-consequence estimates (NUREG/CR-2239, p 1-3), all of which consider local meteorology. Local officials must carefully determine local emergency response needs and the adequacy of emergency capabilities in approving a

~

fl ~

The 10-mile EPZ is based on the report of a joint NRC-Environmental Protection Agency (EPA) Task Force which was published in 1978. The report's principal meteorological references are dated 1968 and 1970 (USAEC, 1968; Turner, 1970). The report concluded that the 10-mile EPZ was more than adequate to protect the public.

However, they used 1) meteorological techniques that are now outdated, and 2) nuclear-reactor-accident estimates developed before the Three Mile Island accident .

experience and before subsequent additional experiences with nuclear reactor problems. These early calculations and EPZ estimates depend on the estimates of the amount of radioactivity that would be released during accidents and the probabilities of different types of accidents occurring. Assumptions were made which now may be incorrect or inappropriate. Very simple assumptions were made concerning the behavior of the radiation plume that might be, released in an accident. The atmosphere and its weather systems are very complex, and a wide range of plume behavior is possible. "The weather conditions at the time of a large release will have a substantial impact.

on the health effects caused by that release" (NUREG/CR-2239, pg 1-3). Given a plume released during an accident that would result in injury within the 10-mile EPZ, there are meteorological conditions which could result in significant exposure at distances beyond the 10-mile EPZ and even hundreds of miles "downwind". The plume can meander rather than travel in a straight line, making predictions of exposure difficult and allowing for multiple exposures to the population. Also, important considerations such as the effect of rain were mentioned but not included in calculations used in the final .distance determination in the 1978 report (NUREG-0396, pp I-25 and I-26). The importance of the effects of rain on downwind radiation doses to the public are now documented by the NRC (NUREG/CR-2239; NUREG/CR-1244). Significantly-larger doses to the public can occur further downwind if the radiation release is "washed-out" of the air by rain (rain can clean the air of radioactive particulate as it falls, creating "hot spots" on the ground). On the official average, North Carolina receives rain on one of every three days. As another example, it was assumed in the report that the major dose exposure would occur within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the accident.

This assumption is debatable and has several implications.

The evacuation time estimate for the NC Emergency Management Plan for the SHNPP is almost 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Sheltering in place until the released radiation passes may be the best strategy under some adverse conditions, but some meteorological conditions could result in long and uncertain sheltering times (waiting) while some lower-level exposure continues. Therefore, careful dose estimates and monitoring," accurate evacuation-time estimates, and good management by emergency personel are needed to minimize personal injury not only within the

10-mile EPZ but also at distances beyond the 10-mile EPZ.

Unfortunately, beyond 10 miles these types of decisions and management will be performed ad hoc after an accident occurs. With a mean wind speed of approximately 7.5 mph in this area, there will not be much time (1-2 hours) before there could be a problem beyond 10 miles. It is prudent to be able to respond to problems beyond this distance for this reason, if for no other.

All nuclear units operating in this country are subject to the same type of plan. The calculations used for determining the 10-mile EPZ were performed for hypothetical accidents and meteorological systems. The generic 10-mile-distance calculations obviously do not use meteorological parameters or other factors specific for the Shearon Harris site and power plant. There are now better methods for modeling a specific site which result in more appropriate calculations. The NRC now uses more up-to-date (more correct) techniques and computer models to estimate site-specific radiation releases and doses to the public. Several of these models were developed by the NRC itself but evidently have not been used for reevaluation of the 10-mile EPZ. Even with these improved techniques, it is recognized and documented by the NRC that the reliability of the risk and dose estimates is still limited by the uncertainty of the amounts of radiation that will be released during accidents (NUREG/CR-4199, p 8). These uncertainties are further increased by the uncertainties of the meteorological estimates (NUREG/CR-4199, p 9; NUREG/CR-2239, p 1-3).

The obvious implication is that these calculations f ~

and the resulting 10-mile recommendation are therefore suspect and uncertain for purposes of protecting public health. Reevaluation with more current methodologies and recent experience could result in a larger EPZ distance which would require modification of the emergency plan and required participation ~outs'de a 10-mile radius before licensing of a plant. Part of demonstrating that an emexgency plan is adequate is'to show that the size of the area affected by the plan is appropriate. The problems and limitations of the older methodologies are now well documented. o and safet of the ublic should be aware that current techni ues have not been used 'n establishin the RPZ and tat t r aese 'os u was established.

assum tions under w ich it e ard o som of the Conse uentl the erne enc an ot be uate to rotect the health of the ub i e a . This is especially serious in the case of the SHNPP because heavily-populated areas including the state government systems 'exist so close to the presently-accepted 10-mile EPZ.

An appendix is being prepared which further documents these statements, includes additional findings and comments, and contains references which document the widely accepted criticisms of the older and simpler assumptions, dispersion parameters, and methodologies. These criticisms are found in 1) reports from the NRC, EPA, AMS (American Meteorology Society), a joint AMS-EPA workshop, and a Department of Energy (DOE) -sponsored DOE-AMS workshop; and

2) a statement from Herschel Slater, formerly of the Monitoring and Data Analysis Division, Office of Air Quality Planning and Standards, EPA, a meteorologist who co-authored the guidance document for EPA Air Quality Models in 1978 (This statement is attached).

Statement by the author:

I am a research associate in the Department of Environmental Sciences and Engineering at the School of Public Health, University of North Carolina, Chapel Hill, where I received my Ph.D. My research field is atmospheric chemistry and computer modeling of photochemical smog.

This report represents an independent study not done in connection with my work at UNC.

My personal interest in the emergency plan for the Shearon Harris Nuclear Power Plant (SHNPP) is in regard to the techniques used to establish the size of the emergency planning zone. My reason for preparing this report is a sincere concern that the present plan and zone may be less than adequate to protect the general public in the event of an accident at the SHNPP. I am neither an anti-nuclear activist nor a member of the Coalition for Alternatives to Shearon Harris Steering Committee.

Kenneth G. Sexton, Ph.D

References Cited In This Summary NUREG-0396; EPA 520/1-78-016, "Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," December 1978.

NUREG/CR-2239, "Technical Guidance for Siting Criteria Development", SAND81-1549, December 1982.

NUREG-75/014, "Reactor Safety Study'- An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plant,s, NASH-1400, U.S. Nuclear Regulatory Commission, 1975.

NUREG/CR-0400, "Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission," NRC, 1978.

NUREG/CR-41'99, "A Demonstration Uncertainty/ Sensitivity Analysis Using the Health and Economic Consequence Model CRAC2," May 1985.

Title 10 CFR, Chapter 1, Nuclear Regulatory Commision, Part 50.47, "Emergency Plans", 1-1-86.

Title 10 CFR, Chapter 1, Nuclear Regulatory Commision, Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities", 1-1-86.

NUREG-0654/REV-1, Appendix 2, including ANNEX I, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.

NURZG/CR-3344 NUREG/CR-4000 Science, April 1986, Vol. 232, pp 153-154, "Nuclear Meltdown: A Calculated (and Recalculated) Risk".

(NCERP) North Carolina Emergency Response Plan, In support of the Shearon Harris Nuclear Power Plant Feb. 1984, Rev.l Sept. 1984.

USAEC. Meteorology and Atomic Energy 1968 '.

TID-24190. National Technical Information Service, Springfield, Va. 22151 Slade, ed.

Turner, D. Bruce, Workbook of Atmospheric Dispersion Estimates. Ap-26. USEPA Office of Air Programs, .Research Triangle Park, NC 27711. 1970 Revision.

NUREG/CR-1244, "Impact of Rainstorm and Runoff Modeling on Predicted Consequences of Atmospheric Releases From Nuclear Reactor Accidents, U.S. Nuclear Regulatory Commission, February 1980.

"Guideline on Air Quality Models", J. Tikvart and H.

Slater, EPA-450/2-78-027, OAQPS No. 1.2-080, Research Triangle Park, NC, April 1978.

Some Additional References Referred to In Last Paragraph of Summary Which Will Be Cited in the Appendix EPA/600/S3-85/072, "Research on Diffusion in Atmospheric Boundary Layers: A Position Paper on Status and Needs,"

Project Summary, G. A. Briggs and F. S. Binkowski, December 1985.

EPA/600/S3-85/056, "Atmospheric Diffusion Modeling Based on Boundary Layer Parameterization," Project Summary, J.S.

Irwin, S.E. Gryning, A.A.M. Holtstag, and B. Sivertsen, December 1985.

Hanna, S.R., G.A. Briggs, J.

Deardorff,

BE A. Egan, F.A.

Gifford, and F. Pasquill, "AMS Workshop on Stability Classification Schemes and Sigma Curves--Summary of Recommendations," Bulletin American Meteorological Society, Vol. 58, No.12, pp 1305--1309, December 1977.

Weil, J. C., "Updating Applied Diffusion Models'", J. of Climate and Applied Meteorology, Vol. 24, No. 11, pp 1111-1130, November 1985. 4June 1985-- This paper is an overview of the review and recommendations arising from the AMS/EPA Workshop on Updating Applied Diffusion Models held in Clearwater, Florida, January 24-27, 1984.

"Proceedings of the DOE/AMS Air Pollution Model Evaluation Workshop", Kiawah, South Carolina October 23-26, 1984, Volume 3, Summary, Conclusions, and Recommendations, DP-1701-3, Robert J. Kurzeja, and Allen H. Weber, Approved by A.L. Boni, Research Manager, Environmental Technology Division, Sponsored by the Office of Health, and Environmental Research, U.ST Department of Energy, Publication Date: December 1985, E.I. du Pond de Nemours &,

Co., Savannah River Laboratory, Aiken, SC, 29808, Prepared for the U.S. Dept. of Energy under contract DE-AC09-76SR00001.

10 B I BL IOGRAPY

1) Rahn, F.J., Adamantiades, A., Kenton, J., Braun, C. A Guide to Nuclear Power Technology. John Wiley and Sons, New York, 1984

2) Federal Emergency Management Agency. "Report to the President-State Radiological Emergency Planning and Preparedness in Support of Commercial Nuclear Power Plants" (June 1980)

3) U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency.

"Criteria for Preparation and Evaluation of Radiological Emergency Response k

Plans and Preparedness in Support of Nuclear Power Plants, for Interim Use and Comment" (NUREG-0654/FEMA-REP-1) (Jan. 1980)

4) Army Corp of Engineers Personal Communication with John Young. June 1980

5) U.S. Department of Health and Human Services. "Preparedness and Response in Radiation Accidents" (FDA 83-8211) , AUG. 1983)

6) "Precursors to Potential Sever Core Damage Accidents" ("Precursors"),

NUREG/CR-2497, Oak Ridge National Laboratories, 1982

7) "In the Matter of Consolidated Edison Company of New York and Power Authority of the State of New York ( Indian Point 2&3)," CLI-83-16,June 10, 1983

8) BLueprint For Chaos II: Pilgrim Disaster Plans - Still A Disaster MASSPIRG 1983

APPENDIX B Statement Concerning the Procedures for Selecting the Size and Configuration of an Emergency Planning Zone (EPZ)

Herschel H. Slater, Consultant Air Pollution and Meteorology Chapel. Hill,NC 27514 June 28, 1986 (I am a meteorologist, specializing in air pollution matters with experience and training that spans four decades.

My experience includes service with the US Weather Bureau; US Air Force, as a career officer; Environmental Protection Agency; Adjunct Associate Professor, School of Public Health, UNC-CH; and Logistics Manager for Project GALE for NCSU and the Natonal Center for Atmospheric Sciences.)

I am concerned about the size and configuration of the emergency planning zone (EPZ) as it applies to the Shearon Harris Nuclear Power Plant. CPL and the State of North Carolina apparently have accepted the Nuclear Regulatory Commission's suggested plume exposure pathway EPZ, NRC suggests an esscntia11y circular area having a radius of about 10 miles.

Fortunately, meteorological data and analytical techniques have been developed over the past decade that enable more definitive configurations of EPZ's. CPL has the data and the competence to apply more sophisticated methodologies to this problem than the generic approaches suggested'in NRC-promulgated regulations.

CPL should be required to re-evaluate the proposed boundaries of the EPZ. I expect the result would be a more realistic and effective emergency response plan.

Since the NRC regulations that pertain to the size of an EPZ were issued, most nuclear po~er facilities collect meteorologica data on site. Not only are the date site-specific, but they are designed to be applied directly to the problem of estimating the transport and- dispersion of a.cloud or plume of radioactive materials Until such weather data began to be collected by commercial nuclear facilities, the weather data used to assist in choosing the boundaries of an EPZ usually came from the nearest official National Weather Service station. In the case of SHNPP, this is the station at the Raleigh-Durham Airport.

Data collected at RDU is of highest quality'he equipment is well-designed, excellently maintained and the observers are well-trained and dedicated civil servants'. The problem is two-fold: 1) The data are not observed where, in the event

of an accident, the radioactive plume will generate and 2)

The equipment is not designed to sense the meteorological phenomena that determine the rate that a plume of nuclear material will disperse. The equipment and observation procedures used at RDU are designed to meet the needs of aircraft operations and safety and to meet the needs of forcasters in preparing forecasts for the general public. The scales (or size) of atmospheric motion sensed for these purposes are much larger than those which control the dispersion of a plume.

The wind equipment at the airport is designed to be insensitive to the small gusts that are significant in determining the dispersion process. Observations are generally made at hourly intervals. This is much less frequent than needed to charactcrizc the power of the atmosphere to disperse pollutants and to sense the rapid changes of gustiness during periods of the day when this phenomena changes rapidly. Also, the wind observations are made at 10 meters, about 32 feet, above the ground, far below the height that a plume likely may travel.

CPL has a body of meteorological data gathered by sensing equipment specifically designed to study'and estimate the dispersion and transport of clouds or plumes of pollutants. Unlike the equipment at RDU it is sensitive to the important small-scale motions of the atmosphere. Also, some data are sensed at heights where a plume is most likely to occur.

The rate a cloud disperses is often determined by the character of the surrouding topography. The character of the gustiness is influenced markedly by the roughness and the thermal response of the surrounding surface. Is it farmed or forested?

Plowed or covered with vegetation? Is a body of water nearby?

The nearby SHNPP lake must have a significant affect on the way the atmosphere would disperse pollutants in the event of an accident. The lake's effect varies with season, time of day and cloud cover. Hith these considerations, go'od judgment dictates the use of available on-site data rather than data from a distant point when developing the optimum EPZ.

NRC documents stress the importance of-rainfall on peak concentrations. A shower may immediately create a surface "hot spot". If a plume is emitted into a rain situation, little of the radioactive material may leave the site itself. Mith rain occurring on the average of about one day in three in central North Carolina (except in 1986!), careful analysis of rainfall statistics may dictate EPZ boundaries different than a circle.

Notwithstanding current NRC regulations, CPL and the State can take the initiative to fine tune the configuration of the SHNPP EPZ. CPL has the data and the professional competency to do so. In light of the concerns of so many, it is prudent for CPL so to do.

'PPENDIX C.

Human Reaction to Radiological Accidents:

A Review of the Research Prepared by Dr. Barbara Risman Department of Sociology, Box 8170 North Carolina State University Raleigh, NC 27312 (919) 737-3114 At the time of the Three Mile Island nuclear accident in Pennsylvania, no community within five miles of the plant had an emergency response plan approved by the Nuclear Regulatory Commission (Cutter and Barnes, 1982). This raised serious concerns with the Presidential Commission on the Accident at Three Mile Island. The Commission delegated the study of such concerns to a special task force on Emergency Preparedness and Response. The Task Force recommended that before an operating license be granted to a nuclear facility, an evacuation plan must be reviewed and approved. This. recommendation has been instituted (see Sills et al, 1982 for details of other recommendations). The Task Force on Emergency Preparedness and Response also noted that the assumptions upon which emergency plans were based were not well documented (Dynes, 1982). As of 1982, emergency plans for nuclear accidents were based on data from research on "natural" and non-nuclear technological disasters. The Task Force recommended that research be undertaken to study actual human responses to evacuation specifically during radiological accidents at nuclear power plants.

Such research has now been completed (Cutter and Barnes, 1982; John and Ziegler, 1983; Ziegler and Johnson, 1984; and Ziegler, Brunn and Johnson, 1981) and the results are clear and consistent: any evacuation related to a nuclear accident will include an EVACUATION SHADOW. An evacuation shadow is "the tendency of an official evacuation advisory to cause departure from a much larger area than was originally intended.

(Ziegler, Brunn and Johnson, 1981, p.7)." That is, many more'eople will evacuate than officially advised to do so. Voluntary evacuation will occur at least as far as twenty-five miles from the accident. And'most evacuees will travel over fifty miles from their homes.

There are two sets of research upon which the above conclusions are based.

First, there have been at least three studies of the advisory evacuation at Three Mile Island (Cutter and Barnes, 1982; Ziegler, Brunn and Johnson, 1981; and Flynn, 1979).

These studies are mutually supportive, despite having been conducted independently at Rutgers University, Michigan State University, and for the Nuclear Regulatory Commission. Four components of the EVACUATION SHADOW were first identified in research on the Three Mile Island evacuation.

1) The number of actual evacuees 'far outnumbered those advised to do so:

3,000 preschool children and 444 pregnant women were advised to evacuate.

144,000 people actually evacuated.

2) The geographic area from which people evacuated was five times as large as the advisory area.

- Pregnant women and children within five miles were advised to evacuate.

39% of those within 15 miles actually evacuated.

9% of those between 15 and 25 miles away evacuated.

3) The distances travelled by evacuees far exceed the distance advised.

Evacuees fled a median distance of between 85 and 100 miles.

4) Evacuees do not flee to shelters, whatever the official advice.

74-81% of evacuees fled to homes of friends and relatives.

The maximum number of persons in any shelter at one time was 185.

A second set of studies (Ziegler and Johnson, 1984; Johnson and Ziegler, 1983) also support the existence of an EVACUATION SHADOW during potential nuclear accidents.

A survey of 2,595 households on Long Island, NY provides a data base for analyzing potential behavior in response to a nuclear accident. In this research, respondents were asked how they intended to behave given three different scenarios of possible problems at the Shoreham Nuclear Power Plant. Three components of a potential EVACUATION SHADOW were identified.-

1) The actual number of evacuees will far outnumber those advised to do so. And the geographic areas from which people will evacuate will be much larger than the advisory zone.

- If anyone within five miles of the plant is advised to shelter-in-place (e.g. stay inside with closed windows), 18-34% of the population between 10 and 25 miles plan to evacuate.

If those within five miles are advised to evacuate, 25-44% of those within 10 to 25 intend to evacuate.

If those within 10 miles. are asked to evacuate, 39-63% of those within 10 to 25 miles intend to evacuate also.

2) The distances travelled by evacuees will far exceed the distances recommended.

Over two-thirds of those who intend to evacuate under any circumstances, plan to travel over fifty miles.

3) Evacuees do not plan to flee to shelters, regardless;of official advice.

- 60% of potential evacuees plan to flee toward the homes of friends and relatives.

18% of potential evacuees plan to flee to commercial establishments.

- Only 6% to 8% of potential evacuees plan to go to shelters. (Some undecided)

Overall, this research suggests that the public fully intends to IGNORE official advice in the event of a radiological disaster. The public will respond with dramatic behavior in the event of a nuclear disaster, evacuating sooner than suggested, more people will evacuate than required or recommended, and those evacuees will travel farther than suggested.

These results are striking because they contradict what is known about evacuation behavior from studies of natural disasters. Research on natural and non-nuclear

',disasters has .shown that individuals and families will only evacuate when confronted with direct sensory evidence or explicit and convincing warning messages (Drabek, 1969; Perry, 1979). Indeed, during non-nuclear accidents, emergency evacuation workers often have to persuade the public to evacuate their homes and land.

Therefore, any evacuation plan for a nuclear accident modeled after plans for non-nuclear accidents are destined to fail. The data does exist to correctly to specify emergency evacuation plans for nuclear accidents. But emergency planners must accept the reality that public behavior cannot be controlled and capitalize on predicted behaviors by incorporating such action into emergency response plans.

The research first suggested by the President's Commission on the Accident at Three Mile Island is now complete and the conclusions are important: emergency evacuation plans for nuclear accidents need to be based on different assumptions about human nature'han any other evacuation plan. Emergency plans for possible nuclear accidents must include at least 25 miles because roads will be clogged by persons who reside outside the ten mile zone whether or not they are advised to evacuate.

Voluntary evacuation beyond 25 miles will occur. It may even be that with the increased fear of radioactivity accompanying the Chernobyl accident, more people will evacuate from an even greater distance that the pre-Chernobyl research indicates.

Any evacuation plan for the event of a radiological accident at a nuclear power plant which does not include at least 25 miles is simply inadequate based on the most recent research by social scientists. The most excellent technical plan cannot work if. itignores,the reality of human behavior.

References Cutter, Susan and Kent Barnes, 1982, "Evacuation behavior and Three Mile Island,"

Disasters, Volume 6,2.

Drabek, Thomas. 1969, "Social Processes in Disaster: Family Evacuation," Social Problems, Volume 16.

Dynes, Russell R., 1982, "The Accident at Three Mile Island: The Contribution of Social Sciences to the Evaluation of Emergency Preparedness and Response," in David L. Sills et al (editors), Accident at Three Mile Island: The Human Dimensions, Boulder, Colorado: Westview Press.

Flynn, Cynthia B., 1979, "Three Mile Island Telephone Survey: Preliminary Report on Procedures and Findings," prepared for the Nuclear Regulatory Commission, Washington, D. C.: U. S. Government Printing Office.

Johnson, James H. Jr. and Donald J. Zeigler, 1983, "Distinguishing Human Responses to Radiological Emergencies," Economic Geo ra her, Volume 59.

Perry, Ronald W., 1979, "Incentives. for Evacuation in Natural Disaster." Journal of the American Plannin Association, Volume 45.

Sills, David L., and C. P. Wolf, and-Vivien B. Shelanski, 1982, (editors) Accident at Three Mile Island: The Human Dimensions. Boulder, Colorado: Westview Press.

Zeigler, Donald J. and James H. Johnson, Jr., 1984, "Evaluation Behavior in Response to Nuclear Power Plant Accidents, Professional Geo ra her, Volume 36,2.

Zeigler, Donald J., Stanley D. Brunn and James H. Johnson, Jr., 1981, "Evacuation from a Nuclear Technological Disaster," The Geo ra hical Review, Volume 71,1.