ML20072S577

Citizens for Employment & Energy Concerns Re Draft of Proposed Nuclear Facility App to Monroe County Emergency Operations Plan

ML20072S577
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Site:	Fermi
Issue date:	04/30/1983
From:	CITIZENS FOR ENERGY & EMPLOYMENT
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ML20072S573	List: ML20072S570 ML20072S577
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NUDOCS 8304070246
Download: ML20072S577 (45)

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CITIZENS FOR EMPLOYMENT AND ENERGY

1. CONCERNS REGARDING THE DRAFT OF THE PROPOSED

( NUCLEAR FACILITY APPENDIX TO THE MONROE COUNTY EMERGENCY-OPERATIONS PLAN i-I i

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TABLE OF CONTENTS I. Citizen Concerns Regarding Nuclear Facility Procedures Appendix to the 1 Monroe County Emergency Operations Plan II. Concerns Regarding Recovery and Re-entry Respo.nsibilities Within the 3 Basic Plan III. Concerns Regarding Beach Area Evacuation 5 IV. Concerns Regarding Protection of Livestock and Pets 7 V. Concerns Regarding Direction and Control Annex 9 VI. Concerns Regarding Warning Annex 11 VII. Concerns Regarding Damage Assessment Annex 13 VIII. Concerns Regarding Public Information Annex 14 IX. Concerns Regarding Radiological Defense Annex 15 X. Concerns Regarding Law Enforcement Annex 23 XI. Concerns Regarding Fire Annex 27 XII. Concerns Regarding Health and Medical' Annex- 31 XIII. Concerns Regarding Public Works Annex i 34 XIV. Concerns Regarding Social Services Annex 36 XV. Concerns Regarding School Annex 40

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I. CITIZENS CONCERNS REGARDING NUCLEAR FACILITY PROCEDURES APPENDIX TO THE MONR0E COUNTY EMERGENCY OPERATIONS PLAN Nuclear Procedures Appendix to the Monroe County Emergency Operations Plan needs to be completely re-evaluated. Numerous deficiencies and erroneous suppositions exist which at best would canpromise the effectiveness and safe implementation of the plan as proposed. A summary of items or topics requiring further consideration or clarification follows:

1. Evacuation Of EPZ By Zones: To be completely effective and guarantee the safety of all citizens, the entire EPZ should be evacuated as a unit. The proposed plan, at present, does not anticipate and has no provisions for the complete evacuation of the EPZ.

2. EPZ Ten Mile Limit: According to a Sandia National Laboratories' Study con-ducted at the request of the NRC, a more realistic EPZ of 25 miles should be established since, " irrespective of size, population centers beyond 25 miles do not contribute to early fatalities."

3. Seasonal Plans: Due to the extreme changes in meteorological conditions ex-perienced in Michigan, the plan should provide for mobilization under all weather conditions and not assume the evacuation / emergency will occur in perfect weather.

4. Changes in Plume Direction: Details of the plan direct evacuation of the area in a corridor perpendicular to the path of the radioactive plume. Any change in plume direction, once the plan has been initiated, would render the evac-uation useless since re-direction at that point would be impossible and only result in generating mass confusion.

l 5. Independent Monitoring: The present plan relies on Detroit Edison to monitor its own perimeter and includes no provisions for independent monitoring.

Independent monitoring would guarantee that no radioactive release goes unde-tected. It would also give Monroe County residents the security that the protection of their lives and property is not solely dependent on the identi-fication of an incident by Detroit Edison.

6. Federal / State Employee Cooperation: According to Michigan Public Act 390, Federal and State employees are expected to respond to the Governor's direc-tive for evacuation assistance. However, this response is presumed and

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questionable. As experienced in the past, many people respond to calls for assistance in natural disasters, but a nuclear accident represents an

" unnatural" disaster and presents little, if any, advance warning which precludes adequate preparation. The plan does not allow for panic or emo-tional response by emergency workers fearful of being contaminated by radiation.

7. Volunteers / Insurance / Liability / Agreements: Emergency workers who are not government employees are considered volunteers. Volunteers and those per-sons committed by Michigan Public Act 390 will have limited or no insurance /

liability coverage according to current insurance policies. In addition, the Price-Anderson Act currently limits the nuclear industry's liability for accidents to $560 million; yet, the current liability / damage estimates for the accident at Three Mile Island are in the billions of dollars. Also, there presently exists no written agreements with teacher unions, bus drivers, fire fighters, the Department of Public Works, etc. defining / securing their cooper-ation and coordination with the operation of the emergency plan for Fermi II.

8. Education /Infonnation: Finally, the efficient, timely execution of an evacu-ation presupposes an aware, informed public which possesses certain informa-tion which is not or has not been made generally available. Detroit Edison distributed a brochure entitled "Your Guide to Emergency Preparedness",

dated 1-82 to educate the general public. An analysis of the brochure using the Frye Readability Scale revealed the brochure to be on a college reading level. An appropriate brochure would have a sixth grade reading level.

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iia CONCERNS REGARDING RECOVERY AND RE-ENTRY RESPONSIBILITIES WITHIN THE BASIC PLAN The Appendix I of the Nuclear Facility Procedures to the Basic Plan defines the responsibilities for the recovery and re-entry into the areas evacuated and/or

. contaminated due to an off-site release. These responsibilities include:

A. Decontamination of people, property and food; B. Continued security of evacuated areas to prevent unauthorized entry and vandalism; C. Health and medical services for evacuees; D. Mass care and welfare; E. Monitoring of people and property; F. Transportation; G. Radioactive waste disposal; H. Engineering support; I. Long-term monitoring; J. Scheduling and controlling re-entry based on criteria established by the Michigan Department of Public Health; K. Preparing a sumary report of the emergency with recommendations for further actions and information to the local Emergency Operation Plan.

Until March, 1983 these responsibilities were designated to the local govern-ment. The Monroe County Board of Commissioners realized local government did not have the expertise, personnel and resources to fulfill the above responsibilities.

On March 22, 1983 the Monroe County Board of Comissioners changed the draft of the Basic Plan concerning the recovery and re-entry. The Board of Commissioners assigned tasks A through I to the " Federal and/or State Government." As of this date no one has accepted the major responsibilitias for recovery and re-entry.

To re-enter a contaminated area land and water .nust be tested previous to the recall of people. Radioactive waste must be disposed of in a manner as to cause no harm to the people returning. To test the water and land within the EPZ zone would be a task that would take many months and many more people with sufficient expertise than would be available. Because of the release of at least fifty-four radionuclides, Strontium-90 being one with a half-life of over thirty years, the testing for contamination will of necessity, be on-going for the lifetime of many adul,ts in this area. It is noted that in the. Ural Mountains of Russia after a nuclear accident sixty square miles of land became permanently uninhabitable.

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The environmental impact statement concludes:

"Where the material becomes fixed in its location as an environmental contaminant (for example in the soil), the hazard can continue to exist for a relatively long time --- months, years, or even decades."

Michigan State Representative Mark Clodfelter and Michigan Senator Douglas Ross stated on January 28, 1980, that Michigan is not prepared to protect the health and safety of its citizens in case of a serious accident at one of its nuclear power plants because of inadequate coordination, insufficient personnel ,

and equipment.

Therefore it is dubious that Michigan State Government can accept the respon-sibilities Monroe County is asking it to assume. There is no documentation stat-ing that the Federal or State governments could or would do this tremendous task.

Yet, it is eminently clear that no local government could take upon itself the

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awesome task of testing for re-entry.

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III. CONCERNS REGARDING BEACH AREA EVACUATION The geographic peculiarity of the Lake Erie beach residential subdivisions adjacent to Fermi II poses a unique problem for any proposed evacuation plan of the area. From scattered lake front summer homes and cottages in the 1930's have grown several organized, year-round, self-governing beach areas fronting the lake and nearly all bounded on the west by Dixie Highway. Some of the larger beaches have populations of from 300 to 500 families.

Jefferson School District (with a population of 10,132 as of October,1982) encompasses all nine of these residential beaches, and draws the major portion of its school population from them. All four Jefferson school buildings are on the west side of Dixie Highway. -There are also two Catholic schools within the district.

From the entrance to state Park Subdivision to Port Sunlight Road (the only road into Estral Beach), there are approximately 200 openings onto Dixie Highway from the Lake Erie side. These include roads, private driveways, business en-trances, and entrances to'a VFW, two churches, and some parks and marinas. When a private driveway or business had two exits, both were counted.

It is a way of life for all those people living lakeside of Dixie that they must get on or cross this two-lane road in order to shop, go to school, get medical care, reach ar.y expressway, etc.. With only four traffic signals from State Park Subdivision to Port Sunlight road, just gaining access to the highway on any given day can be trying. Twice a day, during peak traffic to and from Fermi II, getting 4

on the road is very frustrating. In the event of an accident at Fermi II, getting onto or across Dixie Highway could be peri <lous.

For the three beach areas that have only one exit each (Indian Trail ~s, Stony Point, and Estral Beach), it would be extremely difficult for traffic to emerge onto Dixie with anything like the speed needed for an evacuation emergency. Add to this the more than 100 private driveways from which citizens may be trying to leave in one or more vehicles, traffic from Sterling State Park with only two exits, and from all the other beaches (highly populated Detroit Beach has only two roads out),

and you have the potential for traffic chaos.

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These physical obstables to a calm evacuation will be compounded by the potential of panic and fear caused by this area's proximity to the Fermi II site.

These problems are such that uniformed licensed law enforcement officers should be controlling traffic within the subdivisions themselves. However, the plan provides only limited number of traffic control points on North Dixie Highway.

The problems created by having a sole evacuation route are especially acute for Estral Beach and Stony Pointe because these residential subdivisions border the plant perimeter. Residents of these areas have expressed their concern that at least two routes be available to provide access to North Dixie Highway. The Monroe County Board of Commissioners are investigating their request and studying the feasibility of providing a second escape route for Estral Beach and Stony Pointe. The serious investigation of~these routes is just and necessary. An evacuation plan for these two beach areas will not be adequate until two routes are available to the residents so that residents are not trapped by severe weather or a traffic accident. Being trapped in Estral Beach or Stony Pointe by a traffic impediment on the sole escape route would be extraordinarily hazard-ous because of the proximity to the plant.

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IV. CONCERNS REGARDING THE PROTECTION OF LIVESTOCK AND PETS

.Aside from a single reference to feeding animals " stored feed," the proposed evacuation plan doesn't address itself to the large animal population in Monroe County. Besides the countless number of household pets, much of the primary EPZ is farmland with cattle, horses, pigs, sheep, goats and raobits. There are also poultry farms in the area.

Although most farmers keep enough feed stored, a nuclear accident just before the hay is cut and stored, or just before or during the harvesting of grain, might result in a seriously low supply of safe feed. If, for instance, ready-to-cut hay or hay baled but still in the field were contaminated, the whole county could be caught short.

The stored feed that the individual farmers normally put away for their live-stock isn't always kept in air-tight butidings, but in deliberately airy places like corn cribs, large hay rolls in the fields or barns that are generously vented.

These conventional designs which keep feed from molding would allow contaminated air and particulates to spoil the feed.

Perhaps fanners (whether they have huge investments in very large numbers of animals, or they feel a humane responsibility and love for the animals they own) might choose not to be evacuated in event of a nuclear catastrophe rather than leave their animals without care for an unknown period of time.

A great many herds and flocks of animals spend most of their time outside in corrals and pastureland. These animals could not be herded quickly to inside shelter, especially without the possibility exposing the farmers to undue radia-tion hazard.

This will leave large members of animals out to forage, putting them in double jeopardy of ingesting contaminated feed outdoors, while perhaps taking large whole-body doses without any protective shelters.

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Those animalt which are either sheltered during a fermi II accident or take a less-than-lethai dose because of things like meteorological conditions, may still pose a short or a long-term threat to human health. Because they may not look or act sick, farmers may still butcher them for meat, or use their eggs or milk.

Another animal question not addressed in the emergency response plan under study is that of household pets. County dog census and license tallies can give a pretty reliable figure for dog population, but cats and less common pets such as hamsters, gerbils, etc., are not required to be licensed; so there can be no practical way to estimate their numbers. In all probability, there may be more

• households with pets than not.

Again, as with the farmers and their livestock, many people may refuse to be evacuated without the animals they share their home with.

Some elderly, for instance, keep a dog or a cat as their constant companion, and would find it unthinkable to leave it behind. To many children, also, it would be like leaving a member of their family to abandon their pets. Pets, of course, would not be allowed to be evacuated on buses, but thousands of families, fleeing in their private cars or trucks, would arrive at the decontamination centers complete with a dog and/or cat.

Many dogs, because of their inside-outside habits, or because they might normally be kept in a yard or chained to a doghouse, might already be contaminated.

The reception / contamination centers will have all they can do to register people arriving, test them for contamination, and decontaminate them without having the problems of large numbers of animals. The congregate care centers will be no better prepared to cope with the influx of pets. At the very least there would be problems of pet food, containment and noise.

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V. CONCERNS REGARDING DIRECTION AND CONTROL ANNEX Appendix 1 to the Basic Plan, section IV: Concept of Operations, Part B states: "If a nuclear incident occurs at the Enrico Fermi Atomic Power Plant the plant operator is required to immediately notify the nearest Michigan State Police Post and the Monroe Joint Communications Center. The plant operator will not wait for off-site radiation readings or canplete information."

Under this arrangement residents of the EPZ have no guarantee that such prompt notification will take place. Yet, such notification is crucial given the Sandia National Laboratories' recent estimates of early fatal injuries (8,150 persons) and property damage ($136 billion) resulting from a worst case accident at Fermi II. Furthermore, given previous experience with delayed or non-reporting of nuclear incidents at other sites (Fermi I, October,1966;l Three Mile Island, March, 1979;2 Browns Ferry, March, 1975;3) continuous independent radiological monitoring of the plant and its perimeter by local authorities becomes essential.

The draft plan makes no provision for this type of independent monitoring and notification.

Appendix 1 (Nuclear Facilities Procedures) to the Direction and Control Annex states in its Concept of Operations that the Monroe County Emergency Operating Center will be housed in the Office of Civil Preparedness (0CP) located at 106 E.

First St., Monroe. This location presents irreconcilable barriers to the safe execution 0f an evacuation plan.

a. The EOC is located within the 10 mile EPZ, yet the building is not designed to protect inhabitants from radioactive contamination; nor does the Plan make any provisions for the building's renovation.

b. The building has no separate water or air purification systems,

c. EOC workers are assigned to 12-hour shifts thus creating the necessity for the unmonitored movement of people in and out of a building in a potentially contaminated area. Although decontamination and reception centers are to be established for evacuees of the EPZ, no measures are outlined for decontamination and radiological dosage monitoring of workers entering and leaving the EPZ.

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d. Currently the Office of Civil Preparedness houses three full time staff persons. This annex calls for 19 staff to operate out of this facility in a state of emergency (Attachment C to Appendix 1, Direction and Control Annex). No alteration of this facility to accommodate additional emergency staff is stipulated in the plan. Direction and Control cannot be accomplished without such renovation or relocation.

1. Fuller, John, hijt Almost Lost Detroit, c.1975, pp.1,208-9.

2. Stephens, Mark, Three Mile Island, C.1980, p.22.

3. Webb, Richard, Accident- Hazards of Nuclear Power Plants, C.1976, p.198.

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VI. CONCERNS REGARDING THE WARNING ANNEX The draft of the basic plan and annexes fail to address the notification, warning, evacuation, access control, decontamination and recovery /re-entry of persons in boats and other craft on Lake Erie in the eastern sector of the Primary EPZ. The Coast Guard is to be notified in the event of a nuclear incident, but the plan does not specify how the above functions are to be implemented on the Lake. The plan cannot be considered complete until all disaster recovery functions for the marine sector of the EPZ have been estab-lished.

A siren warning system has been purchased by Detroit Edison for use in the event of natural and radiological emergencies in the primary EPZ. However, the following are questions not addressed in the current draft of the Warning Annex; the manner in which sirens will differentiate nuclear incidents from natural eraergencies.

- the distinction between Civil Preparedness warnings and other local siren systems.

- provisions for early warning of deaf and hearing impaired residents of the EPZ.

- establishment of siren coverage maps of the Primary and Secondary EPZs.

Due to the high risk of citizen confusion, even panic upon siren activation, details of siren follow-up procedures by emergency personnel must be outlined further in the Warning annex.

Under attachments B to Appendix 1 to both the Direction and Control, and Warning Annexes, E0C staff training responsibilities are assigned to the OCP l

Director which cannot be adequately performed. The Director has stated that i present staffing is inadequate to undertake such training. He estimates that a minimum of two and a maximum of four full time preparedness training personnel l must be hired to undertake this ongoing function.

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Small and major-scale exercises required cannot be implemented since funding sources for them have not been designated. Furthermore, the Warning Annex, p. B-1-7 under " Drills and Exercises" states that "a major exercise will be held in the Primary EPZ for Enrico Fermi when required." The Plan fails to stipulate the frequency or regularity of such a major exercise or e

its source of funding. The OCP director has stated that the County is incapable of funding such an exercise.

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VII. CONCERNS REGARDING DAMAGE ASSESSMENT ANNEX The Nuclear Facility Procedures to The Damage Assessment Annex to the Monroe County Emergency Operations Plan lacks both information concerning qualifications and training of personnel and a timetable for reporting damage relating to a nuclear incident.

According to this Annex, " Planning personnel will record and compile all information related to damage of any type sustained as a result of the nuclear incident." (IV. Tasks and Execution, #4) The Annex does not provide a descrip-tion of the type of training that would adequately qualify personnel for this complex task. There is no evidence of technicians educated in the area of nuclear radiation damage in the list of Damage Assessment Personnel.

The second part of #4 states, "After the incident, they will assist the Office of Civil Preparedness Director / Coordinator in any written reports related to the type and extent of radiological damage as requested by Stat'e and/or Federal authorities." Again, the Annex neglects to state qualifications, in particular the specialized ability to identify types of radiological damage and the extent of the damage. Considering the expansive and permeative characteris-tics of radiological fallout, it is unrealistic that even highly trained personnel could determine the extent of damage.

Another consideration not covered in this Annex is a designated date for identifying, reporting and assessing damage from an incident. The environmental impact for Fenni II clearly shows how land may be contaminated for decades.

Yet, the Damage Assessment Annex does not account for long term damage evaluation.

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l VIII. CONCERNS REGARDING THE PUBLIC INFORMATION ANNEX According to the Public Information Annex, a rumor control telephone line will be put into operation following a nuclear incident at Fermi II.

The telephone s.ystem in the Monroe area has never been tested fully for an incident of this type. The closest the community has come would be the blizzard of 1978 when 20 inches of snow fell within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Access to a dial tone was delayed up to 5 minutes because of overload usage. There was no danger involved, only the inconvenience of not being able to travel.

During a nuclear accident the danger would be very real. Citizens will turn to the rumor control telephone for vital and accurate information. The potential of this line being constantly in use and the telephone lines congested is great.

If citizens are unable to successfully use the rumor control line, it will increase the potential for fear and panic. The strong possibility of congested telephone lines defeats the very purpose of the rumor control line. Instead of reducing panic it will increase it.

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IX. CONCERNS REGARDING THE RADIOLOGICAL DEFENSE ANNEX Appendix I, Nuclear Facility Procedures, to the Radiological Defense Annex states: "Should a nuclear facility incident occur at the Fermi II plant, immediate notification will go to the Radiological Defense (RADEF) officer who will alert RADEF personnel to mobilize." (see G-1-1, II. A)

The Basic Plan addresses the importance of the role of off-site monitoring:

"Off-site monitoring and sampling will be necessary to determine any changes in the plume." There is some ambiguity as to when this important monitoring function will begin. The Appendix to the Radiological Defense Annex states that RADEF monitors will report to their assigned duty stations, should a State of Emergency be declared.

(G-1-1,II,B) However under State and/or Local Off-site Authority actions, alert status, not emergency status calls for the provision of " confirmatory offsite radia-tion monitoring and ingestion pathway dose projections" in cases where actual re-leases "substantially exceed technical specification limits." Since no independent monitoring exists until this point, this implies that the monitoring initiative depends upon the facility's notification specifically, that actual excessive release has previously occurred. It is at this point that some 10 sanitarians will be asked to proceed to 25 on-land monitoring points, 10 of which are within the 2 mile radius of Fermi II to take radiological readings.

It is unclear in the plan as to whether the actual appropriate equipment avail-able is suitable for moniforing radioactive effluents resulting from a nuclear acci-dent, and what equipment is actually designed for other types of monitoring, such as expressed in other sections for use in monitoring energency workers and residents in decontamination centers. (G-1-16) "It is recognized that some of this equipment is not suitable for monitoring radioactive effluents "

The proposed radiological monitoring is inadequate to realistically meet emer-gency notification needs. Provision should be made for remote ongoing monitoring between Fermi and city water intake, at sites around the plant vicinity allowing immediate and direct warning to the county. The county should not be dependent upon the facility's decision to notify as its sole source of warning. Periodic biological monitoring for intrusion on concentrations of radionuclides in lake food chains should also be implemented so that the county is assured of early warning of exposure from identified pathways.

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Accurate assessment of radiological threat is imperative to any mitigating action-decision. Information both on severity of exposure potential and confirma-tion of pathway of plumes are essential to any appropriate and timely response.

The major concerns for exposure come from the airborn releases of radioactivity:

primarily the noble gases, radiciodines and radiocesiums. People caught in the plume would receive radiation doses from inhalation; external radiation from pass-ing ' cloud-shine', external radiation from aerosols sticking to ground, building

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surfaces, etc., and ingestion from exposure pathways such as contaminants in drink-ing water sources. (Beyea, Journal o_f_ Atomic Scientists #36)

Unpredictability of the time factor in emergency development is a major one and one unaccounted for throughout the plan. (See G-1-4, mere deployment time for monitors is 1-2 hours.) Depending upon the type of accident--response time may be limited to seconds, or weeks. Depending upon the type of " event" and its repercus-sions within the reactor system, unanticipatable escalation may occur rapidly. The evacuation plan is inherently flawed in its assumption of an orderly unfolding of events with broad expanses of time, and the availability of reliable information with predictive value allowing sound decision making for the mobilization of de-tailed and major responses. In fact, most of the' assessments of risk to the popula-tion and environment ASSUME timely emergency evacuation. (Environmental Impact Statement NUREG 0769) This is simply not a 'given' and in fact, is improbable. It is highly unlikely considering the problems in carrying through such a large task as a major evacuation in that the nature of the circumstances under which evacuation occurs are likely to engender panic and confusion. Timeliness of response is as problematic as it is~ crucial to 'public protection. Indeterminate progression of an accident delimits the available time permitted for remedial action -- and, most remedial action requires substantial time for implementation.

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I Other factors contribute to the unlikeliness of timely evacuation. Because of the magnitude of the measures being called into play, decision makers at every step are certain to be hesitant to declare emergency steps as necessary. This hesitancy has been evidenced repeatedly in plant operators reluctance to notify appropriate coninunity and NRC personnel. When faced with the moment of an occurrence that may potentiate disaster, denial is a common human reaction. Evidence Indian Pointe Reactor II where an unusual event occurred clearly requiring NRC notification -

notification was not given and thousands of gallons of river water entered the reactor vessel pit, or, at TMI, where the decision to evacuate was not taken and the decision to distribute KI was delayed unt'll the possibility of significant radio-logical exposure had already occurred.

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Despite the effectiveness of KI as a thyroid blocker for the incorporation of radioiodines and the fact that the public was in the process of receiving major radiological exposure (TMI officials said that the available radiation monitors had gone off scale) and protective action was delayed.

Debate still continues on the extent of radiological exposure this community received and its significance. (see Sternglass,.1979) Operating under the pressure of the moment and the fear of triggering community panic, decision-makers were unable to take any timely preventative actions. Despite instructions from the Secretary of the Department of HEW to do so, and the similar advisement of several radiological experts (Sternglass, Nation, 1981) KI distribution was not made nor was there timely evacuation of the at-risk population. Sever?1 experts suspect that pregnant women received significant and avoidable exposure as a result of this inaction that has resulted in some infant and fetal fatilities.

The public faced a community threatening and life threatening emergency that to them was of unthinkable dimensions. At the worst assessment, a number of highly qualified experts in radiology feel that the TMI community has and will experience serious physical damage from the radiological release during this accident. Some maintain with data that infant and fetal mortality has increased significantly and that there will be some genetic impact. At the best, public trust in the nuclear industry has been critically wounded and deserves to be systematically addressed.

Apart from the debate as to actual resultant damages from TMI, the pub!!c awareness of the duplicity of utility representatives in deliberate misrepresenta-tion of the extent of danger has left a crisis of confidence. Extensive literature has been generated on the psychological impact of the stressful uncertainP.y upon the TMI area residents - indicating the importance of credible reporting to the public during an emergency and affirming the necessity for checks and balances that will assure authoritative, reliable data availability. TMI isn't the only blow to public confidence, the history of nuclear power has other instances where proper notification regarding unusual events occurring at plants was not made - notable subsequent to TMI are Pilgrim and Indian Pointe II sites. In-the case of Indian Pointe several thousand gallons of Huron river water flooded the reactor vessel pit covering the hot vessel to a depth of 9 feet - this in close proximity to the popu-lation center of New York City.

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This particular instance, according to procedures (10 CFR 50.72 Notification j of Significant Events) required expeditious NRC notification. Notification wasn't given until 3 days following the incident. This incident also exposed the fact that the NRC, following the onset of the Reagan Administration's policies, was not meeting inspection responsibilities. In the testimony covering aspects of this accidental occurrence at Indiar Pointe it was noted that while the public was feeling reassured by the mandated presence of NRC representatives in reactor control rooms (subsequent to TMI), under the Reagan Administration, the Nuclear Energy Pro-gram continued operation with 114 vacancies in the inspection program (1981). While the NRC coverage was seen as important to assuring that the licensee was adequately implementing safety responsibilities, Victor Stello, Jr. Director of the Office of Inspection and Enforcement, NRC, stated in testimony that less than half of the operating time of power facilities was being monitored by NRC staffing.

Cutbacks of funding and shortages of staff in the resident inspector program resulted in expanses of time when no NRC representative was available on plant sites.

In the Indian Pointe situation this enabled multiple events to pass unreported.

Significantly, this occurred in a plant where all safety precautions should have been followed in a 'model' manner because of the sites sensitive proximity to New York City where it is acknowleged that no realistic possibility of evacuation exists.

The Rasmussen report had projected that potential damages from reactor accidents combined with probabilities of occurrence warranted the confining of nuclear facility development to remote areas, and suggested the closing of alread operating facilities (such as Indian Pointe) near major population centers. One would assume that given this warning, and the uniqueness of this site, extraordinary care would be exercized in operation.

Incidents such as Indian Pointe reveal some of the vulnerability points within regulation of ' notification' and in operator vigilance which cannot be tolerated by the public in pursuing its own need for self-protection.

"Most significantly of all - given the fact that the NRC is not fully meet-ing its inspection responsibilities - the utilities operatir.g nuclear pow-er plants continue to show highly disturbing management failures; these failures make it apparent, despite the anti-regulatory rhetoric of the day that the nuclear industry cannot safely be left alone to operate this uniquely complex technology. . ."

(Mr. Moffett Subcommittee Chairman Testimony on Indian Pointe Water Spill and NRC Inspection program. Subcommittee hearings on Government Operations.

House of Representatives. 97th Congress 3/5/81)

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Because Monroe County needs to provide reasonable assu'rance of security to I

county citizens, and the credibility of timely notification has been severely challenged historically - ongoing monitoring of radiological conditions on major pathways of exposure must be provided to give direct and immediate remote data and warning. Of particular concern is the aquatic. pathway since radionuclides and chemicals will be released annually with frequencey in liquid. effluents from coolant and radwaste sources in nomal operations. Changes in the amount of radiological release occurring in this manner over the course of the plant lifetime are plausi-ble as the plant system ages and threaten the intrusion of significant radiological

, material into lake biological systems, food pathways (via fish from lake, crops and t dairy sources dependent upon irrigation water) and direct ingestion of ' potable' water. The city's municipal water intake is particularly vulnerable in that it is only 3.2 km down current from.the Femi site effluent source. (Environmental Impact Statement, NUREB 0769) l Good public relations for the nuclear industry and a rebuilding of a basis for J public trust, warrants providing clear proof to the nearby community that its health ,

i isn't being threatened ongoingly, and that eminent threat in a crisis is accurately assessed. Periodic monitoring of the lake food chain also is pertinent especially in the light of the public alarm over the evident dioxin contamination already

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threatening fishing in some of our inland waters from the assimilation of this troubling chemical into biological systems from Dow Chemical effluents. Michigan residents too, are still recovering from the worries of the PBB contamination ex-perience, and the memory of the core damage at Fermi I which was greatly misrepre-sented t'o the imediate populace in impact.

The effects of low. level ionizing radiation are a subject of great controversy i among knowledgable scientists. Data demonstrating effects of disturbing significance from low level ionizing radiation exposure exist and are still a source of concern for many. Recent comissions on low level ionizing radiation have created waves of debate from the scientific community - one such notable is the BEIR report so fre-5 quently cited in the support of Enrico Fermi II - Environmental Iinpact Statement h conclusions. State-of-the-art limitations place many of the co'nclusions regarding the impact of low level ionizing radiation doses from ordinary operations upon lake biological systems, and upon the nearby populo,us. in emergency situations in the

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realm of conjecture and therefore, greater cautionary measures are warranted and urged, b

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The Radiological Defense Annex states, "The RADEF Officer will contact RADEF monitoring teams and instruct them to report to their assigned locations."

The estimated deployment time of 1-2 hours renders this ineffective monitoring for any accident where radiological release is major and occurs swiftly.

The plan depends upon the willingness of RADEF staff to enter areas that may result in major radiological risk. One interviewed RADEF staff member seriously doubted the feasibility of implementing this step under possible limited time frame-works, possible conditions of significant radiological exposure, and expressed an unwillingness personally, under such a threatening situation to enter an area for 3 monitoring. It is likely that other personnel when confronted with an actual emergency situation, particularly where their families may be endangered, may not want to engage in monitoring functions. Such an essential function should not be left vulnerable,'nor so plausibly dependent upon the willingness to incur life threatening jeopardy.

The Appendix to the Radiological Defense Annex states: "The RADEF Officer will as.sess the protective action requirements based on the information received from various sources". Protective Actions Guidelines (E-1-9) state that for whole body dosage of 5 rem +, and Thyroid 15 rem + evacuation for some persons is appropriate; other persons in affected areas should "go indoors and close windows, doors, and other air openings to prevent inhaling dangerous radioactive materials which are already being carried downwind..." and that persons living in the affected area

" proceed to ...(location)... to pick up a supply of potassium iodide tablets that will be issued." If KI is to be used at all, it should be pre-distributed as an educational and preventative measure, rather than stockpiled. Other mitigative measures should also be explored that offer protection of individuals, such as distribution of or encouragement of the procurement of respiratcrs.

One of the most clearly documented risks of radiological exposure is the development of thyroid cancer in significant numbers of the exposed population.

While other responses to radiological exposure are of dubious efficacy, thyroid cancer along is specifically combatible. If KI can be administered in appropriate dosage prior to exposure - saturation of the thyroid occurs blocking uptake of radioiodines. The greater the delay of KI ingestion, the lower its effectiveness.

XI cannot remove radiciodines from the thyroid once uptake has occurred. KI can

I 21.

only serve as a blocker. Therefore, any plan to distribute KI after an accident to the population is flawed. Persons travelling to a distribution point would  !

incur additional radiological exposure. Apparently, the best measure to take for radiological releases posing a possible exposure of 5 rem to the whole body, or 15 rem thyroid, is to minimize avenues of exposure by remaining indoors and closing sources of ventilation. The requirement to travel to distribution points places conflicting demands upon an already confused and panicky population (see: Public Info Releases p. E-1-9, Emergency Evacuation Plan) thereby subjecting the population to exposure risks. This plan opts for informing the public of necessary protective measures at the last unavoidable minute leaving the public still more vulnerable and presents an opportunity for panic. The Ti1I incident clearly revealed this.

Decision-makers were afraid to distribute XI simply because it might promote panic by suggesting the seriousness of the radiological threat to an unprepared public.

The planned deferral of KI distribution in an emergency can only perpetuate delay in delivering protection to the community. Postponing the infdrming of the public can have many unfortunate effects. Lack of clarity about the functior. and mode of operation of KI and the limitations of its protective capacity could generate public reactions such as confiscation and hording of KI supplies in the charged emergency situation. Planned deferral also creates an unnecessary decision point within the crisis situation wherein decision-makers may experience considerable pressure to delay implementation, potentially increasing exposure of the public.

The cost of KI supplies is insignificant in comparison to benefits to be gained by accessibility. If a sincere commitment exists to realistic education of the public regarding emergency preparedness, in the possibility of a reactor accident, the preventative distribution of KI in the community could only serve as a valuable instructive toll and first line of defense:

1. Familiarity with XI and its role would promote public awareness of their necessary part in emergency measures.

2. A prepared public would be less likely to panic in the accident situation than a public faced with an unfamiliar drug in the midst of a confusing, frightening and emotionally charged emergency.

3. Ingestion of a timely dosa y of KI would be more reasonably assured.

4. Dangerous risk of exposure in obtaining KI would be sensibly eliminated, along with concomitant complications of excess travel contributing to traffic congestion and hazard being eliminated.

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IlthePublicisactuallytoreceivemeaningfullyundatedtrainingorinformation on emergency procedures - contact every 3 years (the shelf life of KI) would be necessary regardless. Presented in a positive and well prepared manner KI distri-bution could be an effective emergency preparedness measure.

~0ther measures should also'be taken - Respirators would limit inhalation ex-posure and are recommended by many radiological experts. At the very least the public has a right to be informed that the availability of respirators for use in such an emergency could make a significant difference to the impact of exposure upon their health. The use of respirators should be explored for use by emergency workers.

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X. CONCERNS REGARDING LAW ENFORCEMENT ANNEX

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The Nuclear Facility Procedures.to the Law Enforcement Annex to the Monroe County Emergency Operations Plan defines the responsibilities and conrnitments

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of law enforcement within Monroe County in the event of a nuclear incident at Enrico Fermi Atomic Power Plant - Unit II. The sheriff or his designee will take his place in the Monroe County Emergency Operating Center as the Law Enforce-ment Operations officer. The Law Enforcement Operations officer will see that the following tasks are implemented:

1. ensure notificatior. and warning is carried out

2. if evacuation is necessary he will see that the jail inmates are trans-ported to Washtenaw and Lenawee jail

3. if evacuation is necessary the Youth Center population will be evacuated to Adrian College

4. light rescue and first aid treatment

5. establish evacuation routes

6. set up traffic control points

7. provide for traffic control

8. security at decontamination / reception centers

9. security at congregate care centers

10. provide for access control (including airways, waterways, and railways)

11. curfew restrictions may need to be enforced

12. maintain nonnal vital law enforcement in all areas including security

13. confirm evacuation of households (door to door)

14. remove impediments to traffic routes

15. security for Monroe County Emergency Operations Center

16. assistance in security at Joint Public Information Center

17. if needed - assistance to on-site evacuating personnel Local law enforcement should be able to immediately meet these responsibilities within the 10 mile EPZ. Although local forces will be augmented by State Police and National Guard immediate coverage is essential.

'The Monroe County Sheriff's Department has 96 sworn officers and 65 special deputies personnel'(auxiliary). The Monroe City Police Department has 48 sworn officers and 36 auxiliary personnel. (The following deals with the duties which are the responsibility of County Sheriff's officers and city police only).

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Ten officers will be needed to evacuate the 100 inmates from the Monroe County Jail to Washtenaw and Lenawee Counties. (According to Kim Hooper, Chief Deputy, Monroe County Sheriff, June 16th transcript of Public Review RERP p. 83) 154 total sworn officers minus these 10 leaves 144 officers to deal with all the other responsibilities.

There are 24 traffic control points _ which are the responsibility of the law enforcement personr. 1. The people being evacuated will be anxious and scarsd The traffic will be extremely heavy. Families and friends will want to reunite.

At least 2 personnel should be at each point. If one sworn officer and one auxil-lary personnel are at each point that leaves 120 sworn officers and 77 auxiliary personnel.

It is ridiculous to think that a barricade alone will stop the people, they will panic and could easily move or go around it. There are 27 barricades which must have a sworn officer and a back-up auxiliary person in control. That leaves 93 sworn officers and 50 auxiliary personnel.

There are 33 access control points listed for roads and railways, one officer and one back-up auxiliary person at each point leaves 60 sworn officers and 17 auxiliary personnel.

There must be at least 4 personnel at each of the 5 reception / decontamination centers. People may panic, each wanting to shower first. Traffic may be heavy.

This type of situation brings out the worst in certain segments of society. Security will be essential. If 2 sworn officers and 2 auxiliary personnel were assigned to each, that would leave 50 sworn officers and 7 auxiliary.

Again, there must be at least 4 law enforcement personnel at each of the congregate care centers. People will be worried and frantic, anxious to be re-established with loved ones and friends. Ten more sworn officers leaves 40. Ten more auxiliary personnel leaves negative 3.

An officer and back-up auxiliary personnel for security at E0C leaves 39 officers and negative 4 auxiliary.

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An officer and back-up for security at JPIC leayes 38 officers and negative 6 auxiliary to handle all of the following:

1. Local Law Enforcement officials will maintain normal law enforcement in all areas including security.

2. It is the responsibility of the Local Law Enforcement to control traffic at the various waterway accesses. Since such a large percentage of the 10 mile.EPZ involves Lake Erie, this is important. Commercial and re-creational water or ice vehicles will need direction. These vehicles will need to be monitored and possibly decontaminated. A safe docking area must be set up with transportation provided for individuals to take them to the reception / decontamination centers, since their cars may not be at this docking area. Obviously the boats won't be able to dock in a possibly contaminated area. Safe docking areas will need to be north and south of Fermi II. Some people will also want to leave via water causing many traf-fic problems. Many people will want to dock to reunite with family and friends. They will want to get to their cars and trailers.

3. It is also the responsibility of the Law Enforcement to handle access con-trol points at the air ways. There are 2 airports (Custer and Marshall).

4. Light rescue and first aid are also the Law Enforcement officials respon-sibility. There will be a multitude of minor accidents and other situations which need assistance. Roving crews must be provided to help with these problems.

5. The possibility of a curfew being enforced is great. To keep vandalism and looting at a minimum, a strong number of law enforcement personnel must be provided.

6. Icpediments in the road ways would cause dangerous situations. The large number of anxious people need to move smoothly, yet cars and trucks will stall, run out of gas and there will be accidents. These impediment are the responsibility of the Law Enforcement. Movement of the impediment will be complicated by large volume of traffic.

7. Some personnel will be busy establishing the evacuation route.

8. Many people may not be aware of the evacuation (the hearing impaired, people unaware of signal meanings, etc.). Others may not leave their dwelling because of physical disabilities or fear. Confirmation of household evacu-ation is essential and the law enforcement's responsibility. A door to door check would necessitate many officers and may also save lives.

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9. Law Enforcement officers will be responsible for picking up dosimeters and distributing them to the various officers.

All the above tasks are to be accomplished by 39 officers.

Another problem is the number of required cars. The Monroe Sheriff's Department and City Police have a total of 42 cars.

There are 24 control points, each of which will need an official car to be more visible and for traffic control. That leaves 18 cars.

There are 27 barricades, each of which will need a police car to be more visible and for traffic control. That leaves a negative 3 cars.

There are 33 access control points, each of which will need a police car, leaving negative 36.

Five cars will be needed at reception / decontamination centers, leaving negative 41.

Five will be needed at congregate care centers, leaving negative 46.

One car will be needed at the E0C, leaving negative 47.

t One car will be needed at the JPIC, leaving negative 48.

Roving crews for light rescue and first aid will need cars.

Roving crews for curfew control will need cars.

Door to door confirmation of evacuees will require cars.

In addition to all the-above needs, cars will be needed for normal law enforcenent.

Clearly the law enforenent personnel of Mcnroe County are insufficient to meet the vital responsibilities assigned them. This fact is compounded by the possibility that officers may receive the maximum allowable dose of radiation and will need to be-removed from active service in the EPZ.

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XI. CONCERNS REGARDING THE FIRE ANNEX The Nuclear Facility Procedures to the Fire Annex to the Monroe County Emergency Operations Plan defines the responsibilities and commitments of fire departments within Monroe County in the event of a nuclear facility incident at Enrico Fermi Atomic Power Plant, Unit II. These responsibilities and commitments include:

1) All fire agencies within Monroe County will provide disaster relief services dealing with fire.

2) Frenchtown fire department will provide on-site fire and rescue services at the Enrico Fermi plant.

3) Fire departments will provide notification to residents not provided .by siren coverage. They will utilize public address equipped fire vehicles.

4) Fire personnel will assist immobilized or institutionalized persons leaving their home or facility if evacuation is ordered.

5) Fire personnel will decontaminate vehicles at the reception / decontamination centers operated for the general public. The fire department in whose jurisdiction the decontamination center is located will perform the decontamination functions.

6) The fire departments will perform other specialized decontamination tasks as required.

7) Each fire department will perform re-entry and recovery tasks as necessary.

The responsibilities and commitments assigned to the fire agencies are vital to the evacuation process. Each responsibility must be met fully for the health, safety and welfare of residents of Monroe County to be protected. The fire agencies within Monroe County can not fulfill the responsibilities assigned them by the

Radiological Emergency Response Plan because of the equipment and personnel needs of each task.

There exists the normal possibility of fires and the need of a fire agency to promptly and adequately respond to fire during a radiological emergency. Since, numerous agencies will be called upon to carry out a variety of tasks, the necessary commitment of personnel and equipment severely weakens the normal response to the disasters. The fire protection Monroe County residents rely upon will be eroded by

! the use of fire fighting equipment to notify residents using a P.A. system, the

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commitment of Frenchtown fire department to provide on-site services, the use ,.

. of. fire personnel to assist in moving institutionalized and immobilized persons, and the fire agencies responsibil.ity for decontamination. t Frenchtown fire departments commitment to provide on-site fire and rescue service at the Enrico Fermi Plant itpelf has a detrimental impact on not only Frenchtown Township but the entire County. If Frenchtown Fire Department is called on-site, surrounding fire departments must then fulfill its responsibility to provide fire fighting services for Frenchtown Township because of a Mutual Aid Pact.

i This has a domino effect throughout the entire County. As other fire departments

assume Frenchtown's responsibilities', there is an overall weakening of the ability to fight fires and to fulfill.-the radiological emcrgency response tasks assigned fire agencies. This weakening of the County wide ability to fight fires becomes crucial when it is evaluated as part of all the responsibilities fire agencies '

have during a radiological emergency.

't It is absolutely essential that notification for evacuation be given to persons not provided with siren coverage. However, it is clear that fire agencies should not be responsible for this task. An inventory of fire agency vehicles equipped with P.A. systems shows that these vehicles are essential fire fighting equipment. It is unsound to use a variety of valuable equipment necessary to respond to a fire disaster to drive .through an area to be evacuated making public

address announcements. It is unwise to commit pumpers, tankers, and rescue

vehicles to such a task. This commitment of fire disaster response equipment is inadvisable when the overall response to. fires is seriously weakened by the other fire agency. resporisibilities..

I Fire agency. personnel are called upon to help transport institutionalized and

. immobilized persons. The plan does not specify the quantity of personnel needed

- nor does it identify which departments.will provide this service. Since' fire agencies

, have numerous vital responsibilities in the event of an evacuation, it becomes. g l essential that the plan specify which agencies will provide the numbers needed. The draft of the proposed plan does not provide a system for identifying home-bound individuals and retrieving this'information during an emergency. ,This information l

! is~ invaluable if fire fighters are to respord to the needs of immobilized individuals

. with the speed necessary to protect them. The plan does not identify the vehicles-fire fighters will use to perform this task. ,

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The Health and Medical Annex identifies eight institutions that may be evacuated with fire fighter assistance. The plan makes no attempt to establish the number of institutionalized people who will need assistance.

The plan does not identify the vehicles available to assist in the trans-portation of these individuals. It does not attempt to specify the number of fire fighters needed and the departments that will provide this personnel. There is no proof that fire agencies can fulfill this task while attempting to carry our their other responsibilities.

Fire agencies within the jurisdiction of the reception / decontamination centers will perform the decontamination functions at these centers. The plan calls for this to be accomplished by hosing down contaminated vehicles using fire equip-ment at the schools used for reception / decontamination centers. Five potential schools are identified as probable centers, but the actual establishment "will be dependent on the wind direction for their location and the type of accident for the necessity of establishing these."

The fact that the exact locations of these centers will not be established until the last moments before an evacuation is ordered creates three severe problems. The first concern is the choas created by confused evacuees trying to follow instructions and directions in the emotionally charged atmosphere of an evacuation. Second, all potential schools (not just the five identified in plan) must be willing and capable to fulfill the responsibilities assigned to schools which host reception / decontamination centers. Third, township governments and volunteer fire departments within every possible center must be trained, equipped and willing to perform the decontamination process.

No procedure has been established to systematically decontaminate vehicles and contaminated water. No study has been done to ascertain the environmental impact in using this process in close proximity to schools and in areas dependent on well water.

Although the plan calls for the decontamination of emergency vehicles by fire agencies there is no established decontamination center specifically for emergency vehicles and there is no identification of the~ personnel to perform the work. The plan makes absolutely no provision for decontaminating interiors of vehicles. The

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plan also creates no method of dealing with vehicles which may not be able to be compl'etely decontaminated. The process of hosing vehicles down in open areas will create contaminated puddles of water and contaminated mud. This may create a dangerous obstacle to the decontamination process as the area being used becomes saturated with contaminated water. No estimate has been made of the number of individuals and equipment needed to perform the decontamination of vehicles. The decontamination process outlined in the fire annex is suspect until it can be proven that the process itself is safe and effective and that the County has the resources to properly; perform the decontamination of vehicles.

There are no letters of agreement from fire departments and township govern-ments demonstrating their willingness to participate in the evacuation process placed on file in the Monroe County Office of Civil Preparedness. The Monroe County Board of Commissioners should not consider approval of the Nuclear Facility Procedures appendix to the Monroe County Emergency Operations Plan until these letters are on file. Before these agreements are sought, the fire departments should be fully appraised of every detail of the tasks they are asked to assume. It is particularly essential that the decontamination procedure and all its possible hazards are fully articulated.

In early Fall,198'2, serious concerns and reservations about the responsibilities within the Fire Annex were raised at a Monroe County Firemen's Association meeting attended by Mr. Jon Eckert, Director of the _ Monroe County Office of Civil Preparedness.

At this meeting, representatives of the County's fire departments stated that they have not been fully informed of their role in a radiological emergency. They questioned the praticality of assigning them so many tasks,. They raised numerous concerns and questions about their liability during a radiological emergency. In addition, they voiced far reaching questions about the insurance coverage of themselves and their equipment while performing this particular kind of emergency work. As of this date, no one has addressed their concerns and questions. No fire department has commited itself to performing the off-site emergency tasks assigned them in the draft of the Fire Annex.

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XII. CONCERNS REGARDING HEALTH AND MEDICAL ANNEX There are only two medical facilities outside the 10 mile EPZ listed as treatment centers for radiation victims. These facilities are committed to receiving on-site victims (ie., Power Plant Employees). No facilities are indicated for the receiving and treatment of off-site victims, especially emer-gency workers who will be exposed to much higher radiation levels. No consider-ation has been given to the number of beds, accomodations, or medical equipment available outside the EPZ. for the relocation of the sick and elderly from hospitals and nursing homes within the EPZ, as well as for those suffering from illness and accidents occurring during the evacuation.

The Monroe County Office of Civil Preparedness has not been informed of physicians with expertise in treating victims of radiation exposure. In response to the question of competent medical care, authorities responsible for implemen-tation of the Radiological Emergency Response Plan (RERP) have not indicated that local practicing physicians or nurses are informed about preventive or therapeutic treatment of victims exposed to radiation. It is reasonable to expect that physical and psychological damage to victims must result as a consequence of a nuclear accidsnt, yet treatment of the former is not adequately provided for and the latter is not_ even mentioned in the RERP.

Approximately 15,500 school children and 1100 nursing home residents and hospital patients will require transportation during an evacuation. Another extimated 2800 people will need public transportation to leave the area.

Added to this number will be on-site and off-site radiation victims needing emergency transportation. At present, local bus passenger capacity (including schools, SEMTA, etc.) is only 10,000 people, if all vehicles are operable and drivers respond to an emergency request, however, the number of people requiring transportation can easily exceed 20,000. The school operations officer, or any other official, for that matter, cannot adequately coordinate the deployment of available vehicles based on greatest need versus order of request. There are no provisions for resolving the conflict between transport of radiation victims and l_ the " normal" transport of other emergency victims, nor'for the segregation of radiation victims according to degree of exposure.

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The plan lists four ambulance services of which only E.M.T.S. is still in service. As indicated previously, available bus capacity will be exceeded and cannot be depended on for the timely evacuation of nursing homes and hospitals in the affected area. Dependance on transport vehicles located a distance from tne EPZ would pose an increased hazard of exposure to those persons.not immediate-ly evacuated. Within the plan, there is no list of trucking companies available for emergency transport of victims / patients or necessary/ critical hospital supplies.

For the plan to be effective, letters of agreement should be on file with several persons designated to coordinate dispatching (in case one or more designees are not available at time of the emergency). Nowhere in the plan is the problem of bus / truck drivers agreeing to emergency transport addressed. Even if their services are ordered under P.A. 390, they may not respond due to concerns for the safety of their own families and the reluctance to enter contaminated areas.

Essentially, under P.A. 390, these people would be volunteers and because of the limitations of P.A. 390 and applicable insurance policies, they would have limited or no liability coverage.

The Protective Action Guides for contaminated human and animal food and drinking water are based on established exposure level guidelines. However, these guidelines are not adequate as indicated by studies following the accident at Three Mile Island. Also, the disposal of contaminated food / feed presents addition-al hazards to local people and ground water where the disposal sites are located.

There cannot exist enough F.D.A./M.D.P.H. personnel to monitor all human and animal food sources including home-grown and home-processed foods. The RERP does not detail any program or procedures for the storage and distribution of guaranteed contamination-free animal feed. Locations of emergency supplies of " safe" animal feed are not indicated. Ingestion of potassium iodide (KI) has been accepted as a means of reducing the dangers of exposure to specific types of radiation by its thyroid blocking properties, however, KI must be ingested immediately for maximum protection. According to RERP, the M.D.P.H. keeps a supply of KI at its central office for transport to the local area where a nuclear accident has occurred. Ware-housing introduces an unacceptable time lag between exposure and preventive / protective l treatment. Therefore, adequate supplies of.KI should be distributed to households before an accident, or at least to homes where there are pregnant women, infants, or  !

I small children because they would be most affected due to the increased radio-sensitivity of younger age groups and the possibility of fetal hypothyroidism.

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4 The Monroe area water supply comes from a surface lake /which will almost

immediately be contaminated. An alternate source of potable water is not provided for in the RERP, however, Mr. Jon Eckert advises that a Monroe water system tie-in to the Toledo water system can be made in 30 minutes. The validity of this  !

4 procedure is questionable because the City of Toledo's water supply inlet is located in the'same lake downstream from Monroe and in the direction of the westerly winds. Contamination of the water source cannot be immediately detected because, although there is periodic monitoring by the M.D.P.H., there is not continuous independent monitoring of the intake for the City of Monroe's water system or the plant perimeter. Monitoring of the air / atmosphere for radioactivity is not addressed by the RERP. Correction of this deficiency requires prudent /

accurate placement:of-monitors, periodic reading / logging of data, and a program of regular maintenance. The above points also apply to radiation monitors for the water supply. Effective use of pocket dosimeters requires an effective means of distribution and the application of the correct dosimeter for the type of radiation to be monitored. In an evacuation drill held at the vicinity of the Indian Point Nuclear Power Plant, 75,000 pocket dosimeters proved to be totally inadequate when

. it was discovered they did'not monitor the type of radiation that the National Guard and volunteers would be. exposed to in such a radiation emergency.

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XIII. CONCERNS REGARDING THE PUBLIC WORKS ANNEX In the event of a nuclear incident at Detroit Edicon's Fermi II facility, the Managing Director of the Monroe County Road Commission will take his/her place in the Emergency Operations Center as the Public Works Operation Officer. The Public Works Operation Officer is responsible for providing the services listed below:

1) Set up barricades at Traffic Control and Access Control points, or at any additional locations requested.

2) Keep evacuation routes free of ice, snow or any debris which may impede traffic flow.

3) Transport emergency supplies as directed by the E.0.C.

4) Maintain traffic control devices.

The E.0.C. is located at 106 East First Street, Monroe, Michigan which is within the ten mile EPZ. It is unadvisable for the Managing Director of the Monroe County Road Commission to be directing the Public Works response to a radiological emergency from a building within the primary EPZ. This is especially true when the building is not adequately prepared to house the EOC. (see Direction an'd Control section).

The Public Works annex calls for barricades to be placed at Traffic Control and Access Control points. The Law Enforcement Annex details nearly 80 such points.

An inventory of Public Works equipment within Monroe County while the plan was being developed detailed enough barricades to close only 13 roads. This reveals the lack of coordinating the resources the County and the demands of implementing the plan.

In the case of severe winter weather, the Public Works Operation Officer is responsible for cleaning ice, snow and debris from the evacuation routes. Research done during the construction of a draft of the emergency response plan for Fermi II showed that the City of Monroe has only two snowplows and Monroe County has 28 snowplows. No studies have been done to prove that roads can be kept clear of snow and ice with the equipment and personnel available.

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The draft plan attempts to address this issue by stating that evacuation routes "will receive priority snow clearance." It is true that evacuation routes need to be immediately freed from ice and snow. However, this cannot be accom-plished by weakening the snow removal response in other areas. The Public Works

. annex does not address the need for immediate snow removal within the entire EPZ so that evacuees are not hampered by snow and ice. The plan does not give priority snow removal to the routes to decontamination / reception centers, congregate care centers, and host schools. In addition the plan does not prioritize snow removal for the routes which will bring emergency workers from the county and from outside the county into the EPZ. The plan also does not account for the difficulty of snow and ice removal from roads congested with traffic fleeing the EPZ.

Severe weather will always be severely hamper any evacuation and suergency response. Until it can be proven that County and City of Monroe resources can effectively remove snow and ice in a timely and continual manner from all the roads involved in the evacuation process, severe winter weather must be assumed to cripple the emergency response process.

The Public Works Annex calls for coordinating the removal of traffic impedi-ments with law enforcement. This may include stalled or disabled cars. The' plan is dependent upon private wreckers to do this task and has not identified which wreckers or mechanics will be available during an evacuation. The plan also has not dealt with the difficulty of moving equipment to remove a traffic impediment into an area congested with evacuation traffic.

This is the same difficulty that the Public Workers Operation Officer will face as he/she attempts to coordinate the transport of emergency supplies and maintain traffic control devices. Moving smoothly and efficiently through areas congested with evacuation traffic is difficult to imagine. Even though the tasks of the Public Works Annex seem to be limited and some what well defined an evalua-tion proves that a systematic evaluation must be done to prove that the responsi-bilities assigned to the Public Works Operation officer can be fulfilled.

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XIV. CONCERNS REGARDING THE SOCIAL SERVICE ANNEX The responsibilities that have been placed on the Monroe County Department of Social Services (MCDSS) during a nuclear incident are numerouss cumbersome and beyond the scope of their capacity. The tasks for which MCDSS will be held pri-marily responsible for under the Nuclear Facility Procedures (BP-1-15) are as follows: clothing, mass feeding, registration, temporary housing, voluntary agency coordination. Crisis counseling and decontamination centers are support responsi-bilities. The entire staff of DSS workers for M6nroe County as of March 20, 1983 stands at 103, 42% of which live outside of the county. No workers will be noti-fied until a Site ~ Area Emergency status has been reached. At this time a phone I

system to notify workers will be implemented. Workers are then expected to arrive

.at predetermined points ahead of the populace they are to serve at these points.

These predetermined points are subject to change depending on meteorological con-ditions but there has been no provisi.on made for communications while MCDSS workers are in transit.

The capacity of the DSS workers (all workers) to respond is greatly restricted because there will be no notification attempt of workers until Site Area Emergency status has been reached. And unlike a natural disaster where you are aware of rising water levels, or snow storms to come,there may be no escalation of events that could warn workers to be on alert. It is essential for the MCDSS workers who are to oversee the reception / decontamination centers to arrive ahead of the populace.

Evacuation of EPZ within 4h hours.has been recommended by Federal guidlines for the safety of the population. This prohibits the allocation of time for MCDSS workers to arrive at reception / decontamination locations ahead of populace. Depending on the time and circumstances surrounding the nuclear accident there can be no assur-ance as to the number of MCDSS workers that will arrive at reception / decontamination centers. The issue of MCD3S workers and availability number will be addressed later for now we may assume a staff of 103.

According to Attachment J to Appendix 1 to the Basic Plan,the 1980 population within Enrico Fermi II Primary EPZ is 80,129. Federal Criteria States that suffi-ient resources shall be available for registering and monitoring evacuees in a 12

hour period. The Basic Plan has established 5 decontamination / reception centers which will attempt to process these 80,000+. These locations are 1) Monroe High School

37. j

' '2) Monroe Intermediate, 3) Ida Communi,ty Schools, 4) Airport Community Schools,  !

5) Mason High School. Problems exi.st with the very location of these centers which will be discussed later.

The Monroe County Department of Social Services has been asked to meet the responsibility of registering 80,000+ persons at these 5 locations within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

However, depending on hieterological conditions and the extent of radiation released it may be necessary to move the population out of the decontamination / reception centers immediately. The plan requires all movement of population to be recorded.

Immediate information must be available as to an individual's whereabouts when family members become separated in order to re-unite them. Family members will be separated should the evacuation take place during a school day because the plan calls for the direct busing of children to Congregate Care Centers. No provision has been clearly made for the decontamination of all students in the event that the students have been contam.inated. While it is assumed that the majority of adults can successfully fill out the registration form, extensive assistance must be provided for K-8 students. The accuracy of this information is essential if children are to be re-united with parents. The Disaster Center Registration record has 19 items which must be filled out. The task of filling out these registration forms may be placed upon the individual. But once these forms have been completed there are no operational procedures'to organize and retrieve this information.

The immediate retrieval of this information is essential to reunite families. This information is necessary for law officers to confirm the evacuation of individuals in a given area. There are no accomodations for providing information at one relocation center to the other 4 relocation centers and to the Congregate Care Centers. If we take the 80,000 figure and divide it by 5 we can expect each Re-location Center to have the monumental task of processing 16,000 individuals, and setting up retrieval of this information. The entire staff of MCDSS consists of 103. They are to perform this task as well as staffing the Congregate Care Centers.

This same task of registration is called for again at the Congreate Care Centers so that an individual's family may be traced.

The MCDSS has the responsibility of housing, mass feeding and clothing at Congregate Care facilities. However, the responsibility of clothing must be met at the decontamination / reception center because MCDSS must also aid the radiological defense in the decontamination process. A change of clothing will be necessary at

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this point. The clothing will be provided by the American Red Cross. But the amount of clothing and distance from Monroe. County where the clothing is warehoused is not addressed. The clothing will be needed immediately. It cannot be assumed that the clothing will arrive at the decontamination / reception centers ahead of the populace. The distribution of clothing,1f it should arrive,must be orderly to prevent panic. This task will require several MCDSS workers. The reception centers must N prepared to process the entire primary EPZ of 80,000+ because: 1) These are the'only locations where attempts at decontamination will take place, 2) These are the central' locations where registrations takes place and separated family members may hope to' learn of each other~ whereabouts., 3) These are the locations to which the law' enforcement personnel will be directing the population.

-The Basic Plan states that-certain zones may be evacuated first then the next zone. Once'a single zone has been notified the other zones will be notified by friends and relatives.- The entire Primary EPZ will be evacuating ~and the centers are not prepared M handle those numbers. There exists an inherent catch 22 in

the reception centers and decontamination centers being one. The more people pro-

_ cessed through the decontamination center the greater the contamination which will exist at the center. . Highly contaminated persons: police, firemen, EMTS, volunteers,

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must also come to the decontamination center exposing those of low radiation to hich radiation. Also, contaminated automobiles are to be washed off in decontamination j l centers which must process the populace. This will be contaminating school property.

This creates the situation that schools must be closed until the schools have been

[ fully decontaminated. MCDSS workers may become contaminated through the processing of the populace but there isino. provision in the plan for their relief once they I receive 25 rems.

L f-i .The location of the decontamination / reception centers presents a problem in

itself. First, Monroe High School and Airport Community School fall on the border

of the Primary EPZ. Monroe Intermediate is located 1 mile outside of primary EPZ.

L These are.not safe locations as established by the Federal Regulation of a 10 mile Pfrmary'EPZ. Second, Monroe High School, Monroe Intermediate and Ida Community Schools are all'in a line southwest of the Fermi II plant. A movement of the plume southwest will render all three ' econtamination/

d reception centers useless. Other f

l facilities exist that could replace these but a shift of 60% of the decontamination /

reciption centers at the last moment will create tremendous confusion for the-f

!: populace and for those expected to serve the populace. These three locations in any; event will be using the same roadways which may contribute to congestion.

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The entire staff of MCDSS workers consists of 103. MCDSS is required to staff 5 relocation centers for registration of populace and retrieval of this information. MCDSS is required to staff 5 decontamination portions of center for clothing distribution. MCDSS is required to staff 5 Congregate Care facilities for registration of populace and retrieval of information, to oversee temporary housing, to oversee food distribution. MCDSS is responsible for all Voluntary Agency Coordination and for Crisis Counseling in the event of a personnel crisis.

Forty-two percent of MCDSS workers live outside of Monroe County. No estimate has been made of the time needed for these workers to arrive at their positions or their availability during off hours. No evacuation has been done to assess the willingness of out of county employees to drive into Monroe County during a radiological emergency.

No study has been done to evaluate the specific staffing needs MCDSS must fulfill to show how 103 workers can meet the varied and numberous tasks assigned to this department. The overview of the responsibilities provided herein shows that it defies common sense to assume the Monroe County Department of Social Services can provide the vital services that the draft plan for a radiological emergency at Fermi II requests of this department.

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l XV. CONCERNS REGARDING SCHOOL ANNEX The School Annex to the Nuclear Facility Procedures Appendix to the Monroe County Emergency Operations Plan has serious omissions and erroneous conclusions which render the implementation of the School Annex impossible. Most personnel

'have not been included in devising this section nor are there any letters from

school authorities stating their intentions to commit personnel, school buildings, or-buses in the event of a nuclear accident at Fenni II. There is no alternate plan as

to where all these school children and staff will go in case the plume is carried-in a westerly direction. . All the host / reception / decontamination centers.

would be in its path then.

, It is most important to stress that this plan does not deal with the panic

. factor and how it will affect the children's, parent's and general public's think- -

-ing and actions during a nuclear incident at Fermi II. School children are often terrified of loud buzzers and sirens for fire and tornado drills, even with the chance to practice for those events. Many citizens are confused by what the exist-ing-siren system signals. The new sirens must be necessarily very loud and thus more frightening and confusion producing. The plan does not spell out how the

[ general population will be taught how to differentiate what signal of the possible three.special sounds-will alert it to a nuclear incident, as opposed'to tornado, i flood or fire or war, etc.

The administrative assistant from Intermediate School District or his designee must both be involved in all planning and drills. He must be willi.ng to enter the EOC office which may be in a contaminated area. No provision is made as to who pays i

.his salary when he works on this plan and/or drills and not on ISD school business.

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Many parochial schools and day care centers, nursery schools and licensed

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home' day care do.not have monitors. They will have to be contacted by normal telphone lines. If the general public is aware of an' accident at Fermi all tele-

' phone lines may be in use and it will be impossible to make fast, repeated contact with so many schools. -No_ provision has been made as to whether all the above will have to purchase monitors and who will pay for them. One button opens up all moni-tor mikes to all schools at once. The only provision that has been made for

answering individual school's questions and need for clarification is by public

, telephone' lines.

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There is no mention of how parents will be notified that their children are being evacuated. There are no examples of forms that school staffs wi.ll use to keep track of all~ children. For example, the children who are bused and/or those who are picked up before that school is evacuated. Some parents may refuse to let children be evacuated by bus. Many parents work outside the county, no 4 mention is made as to how they will be informed of their childrens' whereabouts.

Some parents do not drive and/or are not familiar with roads or schools outside of their neighborhoods. Even with maps, which are not likely to have been kept i~

handy at home,' coupled with panic and no former chance to have practiced any of the evacuation drill,there is likely to be inordinate chaos as parents try to retrive children from host schools.

No provision is made for organizing host schools so children can be easily located in'each one. Many children will be unable to fill in the forms. Teachers must take all this infonnation with them on short notice or school secretaries must have all information on each child and who is absent that day. Truant children will be unaccounted-for. If a teacher drives the only family car, their family will not be able to leave the EPZ because teachers are to go with their pupils.

They must be_ included in the number of people who will need to leave the EPZ by public transportation. That goes for families whose breadwinners go to work out-side of Monroe County also.

It is questionable whether it is advisable to use schools as decontamination centers and to highly contaminate the buildings, fields and perhaps the well wcter supplies. This problem becomes more profound. depending on the weather conditions.

School District: representatives must be present at each facility. No pro-vision has been made for when or if school days missed will be made up and who pays

. teachers when they may have to stay overnight at host centers. Teachers Unions are not aware of teacher responsibilities involved in this plan. The plan assumes total co-operation on everyones'part.

The plan states that" Social. Services will coordinate the provision of supplies-clothing, bedding, registration forms and food." There are no statements as to who i will purchase and/or pay for all of the above. School Districts in Monroe County are not financially able to provide food as the plan says they m_ay be asked to.

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• The plan states that "the Superintendent of the School District to be evacuated will provide vehicles for this purpose. Other districts will provide additional vehicles as needed. School district employees will drive the vehicles."

There are no letters from School Superintendents on file agreeing to the above statement. No. school system has enough buses to evacuate all its students in one shift. No mention is made concerning evacuation of teaching staff which would mean four more buses in Monroe Public Schools alone. Monroe Public Schools bus a combined total of 10,507 Public and Parochial school children with a total of 53 buses that have a capacity for 3,498 passengers. Schools outside the areas to be evacuated will be using their buses to transport their children home because

- the plan calls for their dismissal if an evacuation is called. Decisions will have to be made as to which schools are evacuated first, second and third. Parents will be alarmed and panicky. Traffic congestion around schools will be unmanageable. It all ready has been when schools have had to deal with tornadoes and bad storms.

No evaluation has been made of how long it will take to evacuate all children when two or three shifts may be necessary to evacuate a school system to a host school.

The plan does call for the monitoring of decontamination of school children or buses. This problem becomes significant when three of the host schools are not also decontamination centers.

" Residents without transportation will be instructed to walk to a designated center in their comunity." They may be walking through contamination and there is no provision to protect them. Those who can't walk will be instructed to call a well publicized telephone number. One number for all those people' When our phones are overloaded it can take a long time to get a dial tone and then these people are likely to get a busy signal.

Again all this decision making and implementation will take a great deal of time and we don't have time when threatened by radiation. No where is there a plan listed to educate the public as to all they will need to know in case of a nuclear incident.

And very importantly, no provision has been made for bilingual communications.

A brochure sent to Edison customers dated January,1982 titled "Your Guide to Emergency Preparedness" has a college reading level. The quarterly newsletters are at high school and above reading level according to the Frye Readability Scale.

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.A sixth grade reading level would be appropriate for all material wri.tten for general public consumption. In the brochure, "Your Guide to Emergency Prepared-ness," it is also stated that host schools will serve as reception centers (p.14) but in the plan it states that Monroe Public School children will go to Bedford which is listed as a Congregate Care Facility on map p. M-1-8. The confusion in terminology and subsequent function of certain host / decontamination / reception /

Congregate Care facilities will make it impossible to determine where clothing,

-food, bedding, dosimeters, medical assistance, police, Social Service.. staff and parents should all go.

Parents will need specific information as to their children's whereabouts and how to reach them. Some families could have a child in preschool, and a child in Intermediate School District Education Center and a child in elementary school such as Jefferson, and a child at Monroe Catholic Central or St. Mary's Academy.

They would have to know all needed information to go to Ida, Dundee and Mason schools. These grave problems are not dealt with with clarity or thoroughness, nor with any thought as to how to prevent mass confusion.

There will have to be complete clothing changes. -Plans to clean and return decontaminated clothing are not mentioned.

It is clear that the School Annex must be restructured and thorough research must be done before it can be determined if the lives of the school children within the EPZ can be adequately protected.

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