ML19351F850
| ML19351F850 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/30/1980 |
| From: | Sholly S THREE MILE ISLAND PUBLIC INTEREST RESOURCE CENTER |
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| NUDOCS 8102200364 | |
| Download: ML19351F850 (21) | |
Text
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Three Mile Island Public Interest Resource Center 1037 Maclay Street Harrisburg, Pa.17103 717/233-4241 A CRITIQUE OF:
"AN I?iCEPEtiOENT ASSESS 1E;iT OF EVACUA!!0N tit'ES FOR THREE MILE ISLAND NUCLEAR POWER PLANT" A study prepared by Wilbur Smith and Associates for the FEDERAL EMERGENCY MANAGEMENT AGENCY June, 1980 Introduction In the wake of the nuclear accident at the Three Mile Island Unit 2 reactor in 1979, the Federal Emergency Management Agency -(FEMA) was charged with primary responsibility for the adequacy of offsite emergency planning and preparedness. As part of its evaluation of emergency planning and preparedness around the nation's nuclear power plants FEMA contracted with Wilbur Smith and Associates to perform "an indepenaent assessment of evacuation times" for Emergency Planning Zones
- around nine nuclear power plants in the United States **.
l Such Emergency Planning Zones (EPZ's) were proposed by a joint NRC/ EPA l
study (published in December 1978 as NUREG-0396), and have been codified in recent amendments to NRC emergency planning regulations (45 F.R. 55402-55418, 19 August 1980).
The EPZ in question here is the so-called " plume exposure pathway" EPZ, with a radius of about 10 miles from the plant.
The plants studied were TMI, Limerick, and Beaver Valley in,. Pennsylvania; Enrico Fermi and Midland in Michigan; Maine Yankee in Maine; Millstone in Connecticut; and Shoreham in New York.
Cover sheet attached as Appendix B.
31 0220 0M 1
The evacuation time study for Three Mile Island concludes that under normal workday conditions, the 195.500 persons living within the 10-mile EPZ could be evacuated in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, while adverse weather. conditions (i.e., icy roadways) would increase the evacuation time by 22 minutes.
This critique reviews the TMI study and the assumptions which were made in arriving at the indicated evacuation times.
The critique concludes with recommendations for future action regarding emergency planning around TMI and for additional s tudy into evacuation times under various conditions.
PLANNING ASSUMPTIONS
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~'a '.albur Smith study of evacuation times for the Three Mile Island 10-mile EPZ makes numerous assumptions, both stated and implied, which do not appear to be warranted.
Some of these assumptions are generic to all nine plants studied, while many appear to be site specific.
Each assumotion which appears to be questionnable is stated in summary form, and then discussed with reference to the TMI evacuation plans and existing conditions in the EPZ.
1.
AN EVACUATION WART:ING IS MADE TO THE PUBLIC WITHIN 15 MINUTES OF AN ON-SITE NUCLEAR INCIDENT WARRANTING
.SUCH EMERGENCY ACTION.
This "is a major assumption of the study, and is significantly in' error on a number of counts.
The study was conducted utilizing demographic data and transportation facility information to predict public response to an evacuation warning based "on the assumption that such a warning is made within 15 minutes of an on-site nuclear incident warranting such emergency action." (study at page 2).
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Past history of such incidents shows that this assumption is very optimistic. The Three Mile Island Unit 2 accident is a perfect example of this optimism, wherein the actual notification of offsite emergency planning officials did not occur until three hours after the onset of the accident.
Despite the experience of the TMI-2 accident, recent incidents shew that the 15-minute assumption is still far off the mark.
The Crystal River 3 accident on February 26, 1980, eleven months after the TMI-2 accident, was marked by a notificnion to offsite authorities 54 minutes after the onset of the accident. A recent incident at the Indian Point Unit 2 reactor.
resulting in the immersion of the bottom nine feet of the hot reactor vessel due to an in-containment water leak, was accompanied by a failure to notify offsite authorities (including NRC) for three days.
There is little reason to expect that future serious accidents will be accmpanied by a more expeditious notification of offsite authorities.
Further, such a rapid notificatien of the offsite public is not even required by current regulations. Utilities are required by new emergency planning regulations to notify offsite acencies within 15 minutes
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of declaring an emergency condition. The June 1980 version of the site Emergency Plan of Metropolitan Edison Company (operator of Three Mile Island i
Unit 1) postulates the ability to recognize and declare an emergency 1
condition within 10 minutes of its onset (See " Emergency Plan for Three Mile Island Nuclear Station, Unit 1", Revision 2, June 1980, page 4-2).
The l
new Appendix E of 10 C.F.R. Part 50 of the NRC's regdations (published as I
l part of the new emergency planning regulations resulting from the THI l
l accident) require that NRC licensees be able to notify responsible state l
and local agencies within 15 minutes of declaring an emergency.
The same regulations require that state / local officials have the capability to ' essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes." Assuming for the sake of argument that Metropolitan Edison Company is correct in s tating that it can recognize and declare emergerciee within 10 minutes of their anset, the maximum permissible time period for completing only the initial notification of the public is 40 minutes (10 minutes to recognize and declare the emergency,15 minutes to notify offsite emergency authorities, and 15 minutes more to notify the public).
Significantly, the Reactor Safety Study (WASH-1400, the so-called "Rasmussen Report") concluded that major releases of radioactivity from a nuclear power plant can begin within 30 minutes of a major accident.
If such an accident occurs at TMI, a major release will be underway by the time the first residents offsite receive the warning about the emergency.
As detailed somewhat later, the TMI Public Interest Resource Center questions whether in fact the capability to notify the public within 15 minutes of receiving notification from TMI exists. The Resource Center, therefore, regards even the 40 minute delay from onset of the incident to completion of initial notification as optimistic for the Three Mile Island plant EPZ.
2.
THE STUDY ASSUMES THAT ALL " KEY PLANNING ELEMENTS" ARE PRESENT AND THAT THE SPECIFIC AGENCIES WHICH ARE EXPECTED TO EXERCISE ELEMENT CONTROL AND MANAGEMENT HAVE BEEN IDENTIFIED.
THE STUDY FURTHER AS$Uf1ES THAT ALL PLANNING AUTHORITIES ARE COORDINATED WITH THE LEAD AGENCY ON EACH KEY PLANNING ELEMENT, AND THAT THE REQUIRED TYPES AND NUMBERS OF PERSONNEL REQUIRED TO IMPLEMENT EACH KEY PLANNING ELEMENT ARE IN FACT PRESENT AND WILL BE AVAILABLE IN AN EMERGENCY.
This assumption was made without reviewing the actual existing TMI-related emergency plans. A review of such plans indicates that such an assumption is dubious with respect to several key elements, including traffic control and management and availability of sufficient numbers of trained personnel. The existing plans are not well-coordinated, although significant improvements have been made since the TMI-2 accident in " arch 1979. The fact rem'ains, however,~ that the assumption made here is incorrect.
Training of emergency personnel in radiological response techniques is lagging behind due to lack of funds for such purposes, and insufficient training resources.
Further, there is no guarantee that the personnel so trained will in fact be available at the time of an accident. Holiday travel, illness, and other factors will eliminate a given number of such personnel at any particular time.
Further, given the existing base of experience following the TMI-2 accident, it cannot be considered unlikely that emergency personnel will give first priority to assurin~g that their families are safely out of the danger area, rather than showing up immediately at their assigned duties in the emergency structure.
In fact, interviews conducted by citi:en intervenor groups in the TMI-1 Restart hearings before the NRC's Atomic Safety and Licensing Board show this to be the case with, l
among other, local police, fire, and national guard personnel. Such consioarations raise additional serious questions about the propriety of the stated assumption.
l 3.
THE STUDY ASSUMES THAT THE EMERGENCY EVACUATION WILL l
TAKE PLACE FROM THE H0ttE BY FAMILY UNITS.
EVACUATION WILL NOT OCCUR UNTIL ALL FAMILY MEMBERS, INCLUDING SLH00L STUDENTS AND WORKING PARENTS ARRIVE AT THE HOME.
A review of existing emergency plans for the five counties in the 10-cile l
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a 6
EPZ for Diree Mile Island (Dauphin, Cumberland, Lancaster, York, and Lebanon) shows that such an assumption is just plain incorrect. All of the county i
plans show evacuation occurring from wherever persons are at the time the warning is given.
In fact, planned emergency evacuatien routes would prevent any travel across the Susquehanna River, travel which would be necessary if many workers were to travel home before evacuating.
In fact, such a practice would unnecessarily expose many people to radiation as they travelled from more distant locations to within 2-10 miles of the plant to arrive at their homes.
Sending schcol students home would also unnecessarily expose many students to radiation in the event of a major release from TMI.
Frequently,
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students are farther from the plant at school than they are at home.
- Further, students walking home would be without any protective shielding at all, shielding which would be offered by a school building or vehicle of some type.
In addition, dismissal of stdents from school and transportation to their homes normally requires several hours due to a shortage of buses (many buses run multiple routes every day, with dismissal of primary and secondary students occurring at different times). Any attempt to alter bus schedules to accomodate an emergency trip to the homes for evacuation would face massive confusion, inevitably resulting in the stranding of many students at the school, or resulting i-tudents getting on the wrong buses and being transported to locations away from their homes (this would be particularly P.ae with primary schcol students).
The TMI Public Interest Resource Center regards this assumption to be dangerous to the public health and safety.
Further, it is flat wrong, and introduces a significant arror in the evacuation time estimates for
4.
THE STUDY ASSUMES TRANSPORTATION IN MASS TRANSPORT VEHICLES IS AVAILABLE FOR ALL THOSE NEEDING IT UPON TELEPHONE REQUEST TO LOCAL EMERGENCY OFFICIALS.
This assumption is not supported by the existing emergency pians. Where emergenc'y plans do provide for c phone number to call for such assistance, the numbers are generally not known to the public, there are an insufficient numoer of phones (3.6 personnel to handle the requests, and under emergency conditions, existing phone lines have been shown to be inadequate (this was readily proved by the TMI-2 accident).
For example, in Cumberland County (most of which is outside the 10-mile EPZ, but county cfficials and PEMA have determined that 20-mile plans are to be prepared) about five percent of the population will require transportation (about6,00bpersonsarewithoutautos). This figure may be optimistic because in one-car families, the working parent, who may be working in another county, will have the car and will evacuate (according to the plans) from the county where.he or she is employed. School buses in the county (including buses from districts outside the 20-mile planning area) have a capacity of about 17,000-18,000 persons. The school populations within the planning area alone exceeds 22,000 students. Additional buses are available from catside the area, but these buses will need drivers, and will be unavailable until they can be transported to the areas where they are needed, which may take several hcurs at be:t.
It is unclear that there will be sufficient mass transportation available for Cumberland County residents.
The situations in the other four counties, while thiy have not been ex$ mined in detail, cannot be presumed to be much better. The stated assumption cannot be supported by existing plans.
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5.
THE STUDY ASSUMES THAT DURING THE EVACUATION PHASE OF THE EMERGENCY, THE TRAFFIC NETWORK WITHIN THE EPZ HAS BEEN !SOLATED c THAT NO THROUGH TRAFFIC IS PERMITTED T ENTER THE EPZ GTHIN 15 MINUTES AFTER THE EVACUATION WARNING HAS BEEN ISSUED.
The existing emergency plans contain no such plans to isolate the traffic netwod within the EPZ so quickly. Tt do so would require thousands o f traffic sentrollers (i.e., police, firemen, national guardsmen, etc.).
Such numbers of traffic control personnel, trained in this activity, simply
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do not exist.
General warning of the emergency by radio and television would undoubtably restrict travel through the emergency area, but assuming a complete isolation of the EPZ's traffic network within 15 minutes of the warning is not warranted and is inaccurate.
Failure to meet this assumption will inevitably lead to an increase in the time required for evacuation.
6.
THE STUDY 43SUMES THAT TRAFFIC MANAGEMEi.T SY LAW ENFORCEMENT OFFICIALS WILL BE PERFORMED AT SELECTED INTERSECTIONS WHERE EVACUATION FLOW IS GIVEN PRIORITY.
The existing emergency plans evidence no such preparations.
It is.
unclear that there are sufficiant personnel available to accomplish this task even if it were planned. To expect it to occur where it is not preplanned is unreasonable. Undoubtably, certain key intersections will be manned to ensure orderly traffic flow, but it is unclear to what degree this will be true. Where this fails to occur, it is likely that bottlenecks will develop due to increased traffic flow and traffic accidents. Under adverse weather conditions, this problem will be more severe than under normal conditions.
7.
THE STUDY ASSUMES THAT EVERYONE IN THE EPZ HAS BEEN PROVIDED, IN ADVANCE, SUFFICIENT INFORMATION REGARDING THEIR ASSI5iED EVACUATION ROUTES FROM THEIR RESIDENCE.
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-9 This assumption is not supported by the facts. That the Resource Center has been able to determine, only York County residents have been provided such information from the revised plans, and then only some residents have received such information.
This type of information is required to be distributed annually under the recently adopted emergency planning regulations of the NRC. To date, however, no such information has been distributed, and there apparently exists no such plans for a distribution of emergency evacuation informatf or in the near future.
The Pennsylvania Emergency Management Agency (PEMA), which is responsible for emergency planning on a state level in Pennsylvania, has printed an information pamchlet cn radiological emergencies (including nuclear power plant accidents), but the document has not been widely distributed (Resource Center staff members have obtained copies at the TMI Observation Center, which is located h-mile from the Tt1I plant along Route 441 in Middletown).
8.
THE STUDY IS BASED ON A FOUR-PHASE RESPONSE TO AN EVACUATION WARNING: RECEIVE WARNING, LEAVE WORK, TRAVEL HOME, EVACUATE HOME. THE STUDY ASSUMES THAT THIS FOUR-PHASE RESPONSE IS TIME-DISTRIBUTED IN A NORftAL DISTRIBUTION.
This four-phase response.is not supported by existing emergency l
Plans.
Further, it is not certain that even if it was, that the time-distribution assumed above would be correct.
The study assumes that 40 minutes would be the maximum time needed to travel from work to homw in order to prepare the family for evacuation.
In fact, this is not an accurate assumption in the TMI area, where many residents of the EPZ work outside the EPZ, especially in Harrisburg. Adverse weather concitions will significantly lengthen tne estimated time, as anyone who works in Harrisburg can tell you.
. It is not uncommon, for instan:e, for it to take two-to-three hours for commuters alone to leave Harrisburg when roads are icy; this does not include the impact of all commuters and residents trying to leave at the same time under these conditions, and the restriction of routes for travel to accomodate evacuation plans.
The time estimate and distribution for the " receive warning" phase is subject to considerable doubt as well. The study assumes that the dorinant mode of notification of the oublic is by use of vehicles and helicopters mounted with loudspeaker $.
fio information whatsoever is presented in the study, and indeed, no such information is presented in the existing emergency plans, to support such a concept.
It is questionnable that sufficient vehicles and helicopters so equipped exist in the EPZ area, or whether such vehicles and helicopters could be brought into the area in time to cceplete the notification within the 20 minute period suggested by the study.
Existing plans in the EPZ call for the use of sirens and Emergency Broadcast Stations to notify the public.
EBS stations depend on people being tuned to the stations, or to people being notified to tune to the stations.
Siren notification would be minimally effective due to the lack of coverage of most of the EPZ. As an example, see the Siren Coverage Map of Cumberland County proviued herein as Appendix A.
It is certainly highly questionnable, absent some more definitive study or actual test, shether the notification l
of the public could be completed in the assumed time (20 minutes).
It is also l
worth noting that the new Emergency Planning Rules published in August require such notification within 15 minutes.
In response to interrogatories from intervenors in the TMI-I Restart Hearings before the flRC's Atomic Safety and Licensing Board, both the Com=cnwealth 1
L
. of Pennsylvania and the Licensee, Metropolitan Edison Company, admit that means to comply with the 15-minute notification requirement are not in place, and furthermore, each appears to be relying upon the other to finance and plan such notification systems.
Prospects are not bright for the required notification capability to be in place at any time in the near future.
A complicating factor in the study's proposed tining and time distribution of the four phases in the evacuation is the very high probability that phases will interningle.
For instance, this could create problems where the activities postulated in the study would require two-way traffic Another flow during times when the study postulates only one-way traffic flow.
factor which will nullify the usefulness of the study's predictions is the f act that persons will evacuate from where they are at the time the evacuation is called for, not from the home (this is based on existing emergency plans).
9.
THE STUDY ASSUMES THAT RADIO STATIONS IN THE EPZ AREA HAVE PH0!iE fiUf'3ERS KNOC TO THEIR LISTE!iERS WHICH PEOPLE CAN CALL DURIfiG Afi EMERGENCY FOR SPECIAL EVACUATI0fi ASSISTAriCE A!iD ADDITIONAL INF0PPATIOM. THIS FURTHER PRESUMES THAT THE RADIO STAT 10fiS HAVE SUFFICIENT PERSONiiEL AND TELEPHONE CAPABILITIES TO CARRY GUT THIS SERVICE.
This is another assumption from the study that simply has very little basis in tne existing emergency plans. Experience from the TMI-2 accident will, in all probability, restrict the flow of information from cmergency planning authorities to radio stations. There were several instances where local radio stations broadcast information which was either incorrect or misleading, a situation which caused all information flow to cease, save that of rectly from the Governor's Office.
It is unclear that the radio stations have sufficient personnel and icicphone capab'ilitics to handle such a service in any event, even if they
12-had access to the requisite information.
This assumption is flawed, and the service postulated cannot be relied upon in any significant measure in estimating evacuation times for TMI.
- 10. THE STUDY ASSUMES THAT ALL ORIVERS IN THE EVACUATION ARE HEACED IN THE SAME DIRECTICN, AND THAT ORIVERS ARE FOR THE MOST PART THE "MOST SEASONED, EXPERIENCED OF THE DRIVERS IN A HOUSEHOLD."
It is not at all clear that this assumpticn is correct.
Given the state of emergency planning in the TMI Ep2 area, and the public's knowledge of that planning, it is very possible that numerous instances of confused drivers will occur with respect to emergency one-way routing and closed roadways. Since most people do not know which routes to take or which routes will have restrictions in flow or direction, such instances will likely be very common, and will cause delays in the evacuation.
Regarding the latter part of the assumption stated above, since persons are to be evacuated, according to the existing plans, from wherever they are at the time the evacuation order is given, it is likely that many drivers will not be "the most seasoned, experienced" drivers in a family. What impact this will have on the evacuation is difficult to measure, but it is almost certainly true that it will not improve the situation.
Whether it will hinder the evacuation is a matter of speculation.
In instances where residents of the EpZ do know their assigned evacuation routes, such persons have their own ideas as to what evacuation route will get them out of the area more quickly.
It is likely that such persons will attempt to use their own planned " escape route" than the one assigned by local o f ficial s.
This will certainly lead to confusion, and may hinder the evacuation.
. 11.
THE STUDY ASSUMES THE FOLLOWING CHARACTERISTICS FOR THE USE OF RCACWAYS IN EVACUATIONS:
a.
Two-lane roadways would use one lane for evacuation and one lane for emergency vehicles.
b.
Three-and.four-lane roadways would use two lanes for evacuation and one or two lanes, rescectively, for emergene/ vehicles.
c.
Freeway traffic moves at 50 mph, and two-lane traffic moves at 30-35 mph depending on road conditions, d.
Lane capacities are 2,000 vehicles per hour per lane on freeways, and 1,000-1,500 vehicles per hour per lane on two-lane roadways.
These assumptions do not compare favorably with assumptions rade in actual emergency plans.
In York County, for instance, are the"following-a ssumptions :
a.
Major roadways will handle from 1,363 to 1,920 vphpl (estimates with trucks and buses and without) under ideal road conditions. A major roadway is defined as an example as Interstate-83, or U.S. Route 30, both four-lane highways.
b.
Minor and local roadways will handle from 1,051 to 1,660 vphpl (estimates with and without trucks and buses) under ideal road conditions.
Examples of such roadways are Pa. Routes 74 and 124, and Legislative Routes and Township roads.
c.
The plan notes that capacity can fluctuate greatly with speed, terrain, and accidents.
l Further, these capacity estimates do not reflect adverse weather conditions which would greatly reduce the capacities stated.
No information l
is given in the FEMA-sponsored study of, what assumptions were made under such conditions.
. Evacuation time estimates are highly sensitive to assumptions about road usage.
Detailed examination of local conditions is necessary, in the view of the TMI Public Interest Resource Center, to estab1'.sh accurate capacities for such estimations.
The blanket assumptioas made in the Wilbur Smith and Associates study do not provide much assurance 7f accuracy.
The study notes that much information was gleantd from examining 74-minute Quadrangle maps from the U.S. Geological Survey.
It is useful to note that such maps were last updated in 1972, and that much construction has occurred since then. Of particular interest, for instance, are the construction of a four-land roadway from I-283 to the Harrisburg International Airpor t in Middletown, and the fact that U.S. Route 30, which appears to be presumed to be four-lane in the study, actually converges to two lanes near the evacuation ared and will be a major source of ceiay as traffic cacks up when the four lanes converge to two lanes.
12.
THE STUCY ASSUMES THAT A NIGHTTIME EVACUATION WOULD BE PEDUCED COMPARED TO A NORitAL WORXDAY EVACUATICN.
This assumption is based on the further assumption that since most people would be at home at night, the travel time from work to home would be eliminated as would the time to prepare to leave work or schools.
The study fails to come to grips with now notification would be made at night when most people would be asleep.
It is certain that sirens could not be utilized for this purpose since siren coverage in the EpZ is insufficient to reach many people. Certainly, if the emergency occurred at night in the winter, many people simply would not hear the sirens even if they were near a siren.
The proposed use of vehicles and helicopters mounted with loudspeakers
. (as proposed in the study) has already been commented upon--sucn capability does not apparently exist, and it is not referenced in existing emergency plans.
It is not, therefore, at all clear that a night-time evacuation could proceed any faster than a normal workday evacuation.
In fact, when one considers the following factors, it is likely that such a night-time evacuation would take as 1cng, if not longer, than a normal workday evacuation:
a.
'iost people will be very sleepy, having been awoken in the micdie of the night, thus decreasing driving skills and increasing the chances of accidents.
b.
Driving at night is more difficult, especially given the emergency conditions, unusual road use during the evacuation, and limited visibility problems.
c.
Persons wouic likely taxe more time to prepare to evacuats (needing to get dressed, pack the car, and leave).
d.
Emergency personnel would probably require a longer period of time to report, and emergency control centers would probably take longer to be activated.
- 13. THE STUDY ASSUMES THAT THERE ARE NO MAJOR RECREATION AREAS IN THE EPZ AND THAT THE SUMMERTIME POPULATION IS THE SAME AS OTHER TIMES OF THE YEAR.
This assumption appears to be faulty.
There is heavy tourist travel in the summer, especially in the Lancaster County area (Pennsylvania Dutch and Amish tourist attractions), and in Hershey (Hersheypark, Chocolate World, and numerous lodging facilities).
In addition, there are parks (Gifford Pinchot, for instance) which frequently have heavy visitation during the summer.
The study ignores possible, problems with short-duration heavy
+p-m 9
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- concentrations of population attending special events at various times throughout the year.
For instance, there are numerous 3pecial events at the State Farm Show Arena throughout the year, including the annual Farm Show Exhibition which attracts about 100,000 people annually during the Farm Show Week. Also, there are nuteroet fairs and festivals throughout the summer which attract 'J. usands of tourists and residents from outside the EPA area.
In these cases, thousands of extra persons and vehicles are in the EPZ.
The s tudy makes no mention of these situations.
An evacuation time estimate should take such considerations into account in preparing a time estimate during these periods of special activity.
14.
THE STUDY ASSUMES THAT THE Ot1LY DIFFERErlCES SETWEEN NORMAL AND ADVERSE WEATHER CONDITIONS (ICY P0 ADS) IS A 50% REDUCTICN IN 5 FEED ON ROADS. AND A C003 Lit:G OF THE TRAVEL TIME FR0tt WORK TO HCME.
THE STUDY PREDICTS ONLY A 22-MItiUTE IrlCREASE FROM tiORfiAL WORKDAY C0t:DITI0t;S TO WHEN THE ROADS ARE ICY.
This assuoption is so utterly ridiculous as to be laughable if we were not dealing with so serious a problem.
It is not uncommon for icy road conditions to cause hours-long delays in travel in the Harrisburg-York-Lancaster area, and these delays account only for commuters, not for an allout evacuation (which would greatly increase the number of vehicles on the roadways). Further, the study appears to ignore the limited road-clearing capabilities available in this area for icy roadway conditions, and the fact that the number of accidents occurring under icy road conditions increases dramatically.
This situation is so critical that the Commonwealth of Pennsylvania, l
witnin the context of the THI-1 Restart proceedings, has been discussing the possibility of making restcrt of TMI-l conditioned on weather-dependent operation.
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That is to say, under weather conditions which..aald markedly slow evacuations, (icy roads or heavy snow, for instance) the plant would be required to shutdown to reduce the possible need for evacuation under such conditions.
The assumptions made nere are utterly ridiculous and cause a very serious underestimation of actual evacuation times under such ccnditions.
The Commonwealth of P:rms;lvania, for instance, has postulated evacuation ti;r,es under adverse weather conditions far exceeding the study's estimate of 3 hrs., 22 mins. (such estimates have ranged in the 8-11 hours area for evacuation under adverse weatherconditions).
SUPPARY CONCLUSIONS he TMI Public Interest Resource Center, af ter reviewing the study for Three liile Island and the generic Program Report which was common to
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all nine plants included in the study, has concluded that the study seriously understates the actual evacuation times for the Three liile Island Emergency Planning Zone. Other estimates of the time required to evacuate the TMI EPZ under a variety of conditions conflict with the Wilbur Smith and Associates estimates by a factor of 2 to 3.
Given the rapidity with which major releases of radioactivity can commence follcwing an accident at a nuclear power plant, the TMI Public Interest Resource Center considers such an underestimation of evacuation tices to be a very serious matter inasmuch as the study critiqued hercin may be used as a basis for emergency planning or a basis for delaying a protective action decision.
The TMI Public Interest Resource Center has concluded that the Wilbur Smith and Associates study of emergency cvacuation times for TMI is so seriously I
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13 flawed as to represent a serious danger to the public if the study is utilized by emergency planning officials.
RECOMMENDATICH The TMI Public Interest Resource Center recommends that the Federal Emergency Management Agency immediately publish in the Federal R_ecister a
" notice of withdrawal" of the Wilbur Smith and Associates study for the Three Mile Island plant.
The Federal Reaister notice should note that the study is being withdrawn because of serious questions about the accuracy of the evacuation time estimates.
FEMA should also make a serious effort to contact any agency or individual who received the study to notify them of tne withdrawal of the study.
Further, given the serious underestimation of evacuation times for TMI and the fact that the methodology was used for all nine plants studied by Wilbur Smith and Associates (similar assumptions appear to have been made as well), the TMI Public Interest Resource Center recommends that FEMA institute an expeditious review of the studies of the other eight reactor EPZ's to determine the extent to which those studies suffer from the same weaknesses as the TMI study. Studies found to suffer from these same weaknesses should be officially withdrawn.
In the view of the TMI Public Interest Resource Center, the continued construction of the nuclear power plant at Limerick raises serious questions about the ability of the public to safely evacuate in the event of an emergency a t the Licerick facility. The oublication by FEMA of the Wilbur Smith and Associates study of evacuation time estimates can only serve to further cor. fuse this already serious situation.
Continued cleanup efforts at TMI-2
. and the proposed restart of the TMI-1 facility also raise serious questions, especially in the light of recognized emergency planning problems and the experience of the TMI-2 accident.
In the view of the Resource Center, only a site-specific study of actual conditions and existing emergency plans and cacabilities can determine whether protective actions can be i=:lemented in a timely fashion for a particular site and set of conditions. The study sponsored by FEMA does not, in our view, constitute ser.h a study and serves only to ccnfuse the issues involved.
The TMI Public Interest Resource Center believes that the public interest is best served by an immediate and official withdrawal of the study for TMI and an expeditious review of the other eight studies.
ABOUT THE TMI PUBLIC INTEREST RESOURCE CENTER:
The TMI Public Interest Resource Center was formed in April,1980, by a coalition of six organizations in Central Pennsylvania which are concerned about the safety of nuclear power plants and about the TMI situation in particular.
The six sponsoring groups are:
ANTI-NUCLEAR GROUP REPRESENTING YORK, located in Ycrk, Pennsylvania.
ENVIRONMENTAL C0ALITION ON NUCLEAR POWER, located in State College, Pennsylvania (itself a coalition of many groups from Pennsylvania, Maryland, Delaware, and Virginia).
HEWBERRY TOWNSHIP THREE MILE ISLAND STEERING COMMITTEE, based in Newberry Township, York County, Pennsylvania.
PEOPLE AGAINST NUCLEAR ENERGY, located in Middletown, Pa.
SUSQUEHANNA VALLEY ALLIANCE, located in Lancaster, Pa.
THREE MILE ISLAND ' ALERT, located in Harrisburg, Pa. (a coalition of related groups in the Harrisburg area).
The President of the Board of Directors is Beverly Hess, a resident of Columbia, Pa., Lancaster County.
Board Herbers are chosen by the six sponsoring organizations.
This critique was prepared by Steven Sholly, Project Director. and Research Coordinator, January 1981.
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APPENDIX 3 VOLUME X
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