ML20087J565
| ML20087J565 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/21/1984 |
| From: | Harris D, Mayer M SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20087J534 | List: |
| References | |
| OL-3, NUDOCS 8403220310 | |
| Download: ML20087J565 (43) | |
Text
- ow a RELATED CORaEaPONDW DOCKETED U'5?IRC UNITED STAI'ES OF AMERICA NUCLEAR REGULA'iORY . COMMISSION 84 HM7 22 N0:18
-Before the Atomic Safety and Licensing Boara .7
)
In tne. Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-J22-OL-3
) -(Emergency Planning)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
DIRECT TES11 MONY OF DAVID HARRIS AND MARTIN MAYER ON BEHALF SUFFOLK COUNTY REGARDING CGNTEdTIONS
, 24.Jr 04.N, 60, 63, AND 72 I
INTRODUCTIOi4 Q. Please state your names anc positions.
A. My name is David Harris. I am tne Commissioner or Health Services for Surfolk County, New York. My proressional background and qualifications'are set fortn in Attachment 1 co Direct Testimony ot David Harris on 'Behalt or Suttolk-County Regarding Contention 25 -- Role Contlict. (See ti. Tr. 121o.). '
My name is. Martin Mayer. I am Deputy Director of Public:Healtn for Suffolk C6unty, New' York. 'My'proIessional backgretind and qualifications are set.out in Attacnment'1.to, '
-1 Direct-Testimony'ot Davia Harris and Martin-hayer on-Bendit or .-
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a e Suffolk County Regarding Contentio'ns 24.G, 24.K, 24.P, 75 ano 75.
Q. What are the purposes of this testimony?
A. The purposes or this testimony are to adaress Sutro1K County Contentions 24.J, 24.N, 60, 63, and 72, ano to express our concurrence with those contentions. We both have been in-volved in planning for and provicing nealen services to persons in Suffolk County for many years. This experience has provideo us with considerable familiarity with the healen facilities available in Suffolk County, including their capabilities.to respond to emergency situations. Tnis experience has also pro-vided us with familiarity witn the types or persons wno mignt require emergency assistance if enere were an emergency at Shoreham, and wilat . would be involvec in proviaing sucn assis-tance. All tne testimony whien follows is jointly sponsorea oy botn of us.
Q. Have you reviewed the LILCO Transition Plan?
A. We have reviewed, among others, those portions ot the Plan that contain proposed protective actions for special -
facilities.
o O Q. What is your opinion of those provisions?
A. In our opinion, enose provisions are unwornable ror tne reasons set forth in tne contentions aadressea by tnis tes-timony. An attempt to implement'LILCO's proposals would likely result in increased morbiolty ano mortalir.y; tnat is, some peo-pie would become more ill or disableo than they were berore, and otners might die as a direct result of an attempt to imple-ment LILCO's proposals.
II CONTENTIONS 24.J AND 24.N - LACK OF AGREEMENTS Q. Are you familiar witn Contentions 24.J ano 24.N?
A. Yes. The LILCO Plan relles on the services or numerous non-LILCO organizations and individuais ror imple-mentation or its protective action proposals for patients anu resiaents of special ano nealth care facilities in anc near tne EPZ. Witnout the services and cooperation ot-sucn incivicuals and organizations, LILCO's proposals for special tac 111tes could not be implemented.
Because to our knowledge tnere is no requirement tnat spe--
cial facilities, healen care facilities or eneir starts cooper-ate with LILCO in the event of a Shoreham accioent, tne best, 1
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o e and possibly the only way to assure their participation is through' agreements of tne proper scope and detail. Despite their importance, nowever, L1LCC coes not nave tne agreements necessary to assure implementation or enese essential aspects of the Plan.
Q. Please state Contention 24.J.
A. Contention 24.J is as follows:
Contention 24. LlLCO has falleo to ootain ag:eements from several or the orga-nizations, entities ano individuals for performance of services required as part or the orfsite response to an emergency pursu-ant to NUREG 0654, as follows:
Contention 24.J. The LILCO Plan re11es upon special facilities, nursery scnools, and their employees to perform several functions necessary to a successtul evacuation or such facilities according to cne LILCO Plan. (See Appenoix A 11-26 to Il-29, IV-166 to IV-178.) (The tacilities involved are tne nursing and acult nomes and the nursery scnools in and near tne EPZ, Association for the Help or hatardea Cn11dren (ABRC) fac11ities, United CerebraA Palsy facilities, John T. hacher hemorial Hospital, St. Cnarles hospital, Central Suftolk Hospital, Maryhaven Center or Hope facilities, and tne'BOCES Learning Center.)
However, the Plan does not incluce agree-ments witt the special facilities'in tne EPZ to implement the evacuation procedures set- fortn in the Plan, and thus tne pro-posed evacuation of sucn tacilities cannot and will not be implemented.
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Q. Does LILCO have agreements witn any ot tne special facilities named in Contention 24.J?
A. To our knowledge, LILCO has no sucn agreements. .As a result there is no assurance that LILCG's evacuation proposals for such facilities would be implemented.
Q. Wny?
A. It an evacuation were orderea, tne sterts or special facilities are expected by LILCG to implement unworkable pro-posals about wnicn tney have inadequate information. LILCO's proposals for evacuating healen care'tacilities are unwornable, because they ignore the medical problems involveu in caring for
- the ill and disabled. In our opinion, because LILCO has no agreements with special facilities concerning the imple-mentation of LILCO's proposals, it is highly unlikely tnat in tne event of a Shoreham emergency cne scatts or enese facilities would attempt to implement LILCO's proposals. In-stead, if tney took any actions, they would be likely to tane the steps wnich seemed most beneficial to' tnem at tne time.
Thus, it is very likely that insteac of the coorcinatad ' set ot-actions anc results wnicn LILCO's Plan sets torth on paper, each facility would-choose and implement in itsfown way wnat-ever course (s) or action it deemed appropriate. tnere is no 3
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4 assurance that such a'n ur.coorcinated series or actions woulo protect the patients or tne special facilities, ana indeea it might interfere with the implementation of otner aspects of the
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LILCO Plan.
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Q. Please state Concencion 24.N.
A. That contention reads as follows:
Contention 24. LILCO has fallea to obtain agreements f rom several or tne orga-nizations, entities and individuals for performance of services requireo as part or
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.tne offsi'ts response to an emergency pursu-ant to NUREG 0654, as fcilows:
Contention 24.N. Tne LILCO Plan relies on the availabllity of non-LILCO facilities and medical institutions as re-location and reception centers for evacuees. (See Pl'an at 4.2-1; OP1P 4.2.1; Appendix A at IV-166 to IV-17 4. ) However, LILCO has no agreements witn.cne owners of the proposed identified f acilities whicn s provide that the facilities will be avail--
able<as relocation centers in the event or a radiological ~e,mergency at Shoreham. See FEMA Report at 10.(noncompliance witn NUREG 0654 Section II.'J.10.h). ~
In addition, tne Plan does not even 1aentify, mucn less include agreements with, the faciitties to tua used as relocation or reception centers tor school chiicren, patients ir. hospitals,.
, handicappea;in,dividuals, or resioents ot any special' facilities other than United Cerebral Paisey of Greater suffolk, 'Inc.
( Appendir A at IV-166 -- IV-174). In tne-
, absence or(such'ag reements , tne protective r action'of evacuation'c'annot ana will not be 7
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Does LILCO have agreements witn any reception centers?
A. No. We believe this is one of the inost serious deticiencies in LILCO's Plan, and we discuss it furtner below with respect to Contention 72.C.1/ Special facility aaminis-trators are unlikely to agree to evacuate their facliities it there is no assurance that an identified and adequately started and equipped facility is available ano has agreeo to receive the evacuating patients. Consequently, without prearrangea ano agreed upon reception centers, LILCO's evacuation proposals coulo not be implemented.
Q. Does LILCO have agreements witn the relocation centers it has identified in the Plan for use by tne general public?
A. No. Although the Plan asserts that tnree facilities, the State University or New York ("SUNY") at Stony Brook, the BOCES facility in Islip, and the Ammerman Campus of Surroin 1/ Indeed, David Glaser, a-LILCO consultant on the subject or nursing and aoult homes, has testitie6 tnat in oroer for an emergency plan for a nursing or aoult home to succeed it is necessary to have agreements witn facilities tnat will receive patients being relocatea from nursing or adult homes. (See Deposition-or Davio Glaser, Marca 17, 1984. ("Glaser Deposition") at 40, 41.)
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' County Cordunity College ("SCCC") in Seloen, are primary relocatio,n centers (Plan at.4'.2-1) and two facilities, SUNY at
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. / Farmingdale'and St. Joseph'd'" College in Patchogue are backup y relocation centers (Plan at 4.2-1), to our knowleoge LILCO has
, no agreements with the owners of any of those facilities for their use by.LILCO in the 'eyent of an emergency at Shoreham.
s (See also' Testimony of Robert Kreiling on Contention 24.0. )
, Use of those facilities as relocation centers would necessicate the disruption of their normal activities. > Consequently, one
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Just cannot assume that they would respond as envisioned by LILCO's Plan unless they' have agreed to do so.
CAI CONTENTIONS'60 AND.63 - SELECTIVE SHELTERING AND SELECTIVE EVACUATION y
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Q. Are you familiar.with Contentions 60 ano 63?
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A. Yes. Contention 60 states:
l At page 3.6-5 of the LILCO Plan, LILCO' states:
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j Tn le] protective action [of selective snel- '
teringj may be ordered at projected doses below the accepted PAGs to minimize radio-active exposure, particularly tofpregnant women and chiloten.... ,.
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. ,e The Sheltering option may bejtocommended as an effective option for inditviduals wno 8
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, could not be safely evacuated. This woulo i
include indiviouals vno have been desig-l natea medically unable to witnstand the j physical stress or an evacuation, as well as tnose individuals wno require constant, i
sophisticated medical attention.
l The Plan fails to set forth guioelines to be used by command and control personnel: (a) in choosing to recommend the protective action of selective sheltering; or (b) in determining the indiviouals who should or would be subject to such a recommendation. Rather, as quoted above, tne Plan contains only generalized statoments wnich, in fact, provide no guidance at all. In addition, there are no procedures wnich inoicate .
the means by which such a recommendation would j or could be implemented. The Plan thus fails to j comply with 10 CFR Se:tions 50.47(a)(1),
50.47(b)(10) and NURTG 0654, Sections 11.J.9 ano J.10. ~
Contention 63 reaos as follows:
Tne LILCO Plan states at page 3.6-6:
l Selective Evacuation pay be implemented to evacuate trom tne arfected area or the plume exposure EPZ members of the general public who might have a low tolerance to radiation exposure. Specitically, tnis would include pregnant women and ch11oren 12 years and uncer.
The Plan fails to set forth guicelines to be used by command and control personnel: (a) in choosing to recommend the protective action or selective evacuation; or (b) in determining, identifying and locating the individuals wno should be subject to such a recommendation. In addition, there are no procedures which indicate the means by wnicn such a recommendation could or would be implemented. The Plan thus fails to comply with 10 CFR Section 50.47(a)(1),
50.47(b)(10), and NUREG.0654 Sections 11.J.9 and J.10.
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Q. Do you agree with Contentions 60 and 63?
A'. Yes. The LILCO Plan coes not contain acequate planning for eitner selective sheltering or selective evacua- !
1 tion. First, there are no real standards in tne Plan by wnica l command and control personnel could decide to recoinmend eitner of these protective actions. The Plan contains no stancards for recommending selective sneltering. And although tne Plan states that selective evacuation "may be implemented tor projected dose levels or 1 to 5 rems whole booy or 5 to 25 rems to the thyroid, but not witnout consultation witn the N.Y.
State Commissioner ot Health" (Plan at 3.6-6), this vague statement does not indicate the projected oose levels at wnlen selective evacuation would be recommended.
Further, the assertions contained in the LILCO Plan tnat selective sheltering and selective evacuation have been acoptea trom the radiological emergency plan or the State of New York, and that neither would be recommended without consultation with the Commissioner ot Healtn (Plan at 3.6-$, 3.6-6) are not standards.
The statement that the New York Plan mentions tnese options contains no guidance wnatsoever tor LILCO's command ano control personnel, and the assertion that neither would be rec-ommended without prior consultation with-the State'is-10 -
meaningless. Whetner it means tnat LILCO woulo not recommeno selective sheltering or evacuation unless une beate told it to, or,that LILCO would merely inform the State or its decision, it does nothing to remedy the deficiency in LILCO's Plan. Tne as-sertion is not a substitute for adequate guicelines or standards to be used by the LILCO personnel wno are responsible for making the decisions to recommend selective sheltering or selective evacuation.
Similarly, there is insufficient guidance in tne LILCO Plan to permit the LILCO employees responsible for making pro-tective action decisions to determine whicn people in tne EPZ are sufficiently radiosensitive to warrant advice to snelter or evacuate. The Plan mentions pregnant women, children ages 12 and under, and individuals meoically unable to witnstano tne stress of evacuation (Plan 3.6-5, 3.6-6). But it ooes not mention otner raciosensitive groups, such as women or childbearing age who are not pregnant, or women wno are in tna early stages of pregnancy but do not yet realize tnelr condition. And, it does not indicate wnetner the groups mentioned in the Plan are the only groups to be consicereo by LILCO's command and control personnel. Moreover, tne Plan does not define those. persons who could not withstand one stress of an evacuation. Because the LILCO Plan contains such incomplete I
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e information, command and control personnel have no basis for making informed decisions about who shoulo be advised to snel-ter or evacuate, should selective sheltering or selective evac-uation be tne chosen protective action.
Finally, the Plan includes no procedures by wnich sucn recommendations could be implemented. LILCO in ettect has cone nothing more than state that selective sheltering ano seAective evacuation are options; it nas f ailed to plan for implementing
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those options. LILCO's proposal to recommend selective shei-tering to protect those persons medically unaole to evacuate is especially flawed. LILCO has not developed plans for imple-menting a recommendation that special facilities snelter patients unable to evacuate. Sheltering is not a viable alter-native for many such persons in special facilities for several reasons.
First, tne LILCO Plan contains some snetchy provisions about how the Health Facilities Coordinator would. contact spe-cial facilities to inform them or a selective sneltering recom-mendation. (OPIP 3.6.5 at 8; Appendix A at 11-18, IV-16o, IV-173, IV-174.) Appendix A and OPIP 3.6.5 contain general
, statements that sheltering would be the primary protective action fcr hospitals (OPIP 3.6.5 at 1; Appendix A at 11-28, t
IV-172 to 173.), and that sheltering might be the preterreo protective action for nursing and adult homes. (Appenoix A at 11-29.) But the closest LILCO's Plan comes to proposing how special facilities would implement such a recommenaation are the following statements in Appendix A The hospitals will be directed to implement their sheltering plans whicn include naving patients either remain in place or relocate within the hospital....
If sheltering is recommended, [ nursing ano adult homes) will be advised by tne EBS message to institute standard sheltering procedures.
(Appendix A at IV-173, IV-174.) Tnus, LILCO's selective snel-tering proposal for special facility patients wno could not be safely evacuated rests on the assumption that tne hospitals and adult and nursing homes in or near the EPZ have oeveloped snel-tering plans which they could implement on notification from LILCO. This assumption is incorrect.
Our staff has contacted tne special facilities incluceo in ene LILCC Plan to datermine the status of their planning for sheltering. We have learned that LILCO representatives have visited the special facilities, toured the buildings, _ indicated that sheltering would'be the preterred protective action be-cause of the difficulties involved in implementing an
evacuation of patients, and given the facility administrators advice about how to shelter their patients. The administrators have been told by LILCO representatives what portions of their buildings LILCO believes would be the most suited to shel-tering, and have been given instructions about the need to pull down window shades, and isolate ventilation and air condi-tioning systems in. order to make sheltering effective. Despite LILCO's visits and advice, however, the special facilities have not developed " plans" for implementing a sheltering recommenda-tion during a radiological emergency.
Indeed, all the administrators we have contacted have expressed doubt about the feasibility of sheltering their patients, and many have stated outright that they believe shel-tering to be impossible. To begin with, in most institutions the areas with sufficient shielding characteristics are not -
large enough to hold the entire or even a large proportion of' the patient population. For example,-the administrator of the Sunrest Nursing and Health Related Facilities told us that of the 104 patients of hJs nursing facility, he could fit no more than 20 of them in the portions of his building LILCO represen-tatives identified as the places where the patients should be sheltered. Similarly, the" administrator.of the Suffolk County Home and Infirmary believes thatLno more than.70 to 90 of his
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215 patients could be accommodated in the basement areas LILCO representatives advised him to use for sheltering. The admin-istrator of the Woodhaven Nursing Homes and Home for Adults also expressed the opinion that it would be impossible to fit all her patients in the basement areas designated by LILCO.
Similar concerns were expressed by administrators of the three hospitals included in the LILCO Plan. Thus if sheltering were attempted at the special facilities in or near the EPZ, the staffs of many of those facilities could not fit all their patients into sheltering areas. Some patients would have to be left in unshielded areas, where they would not be effectively sheltered from radiation.
Second, LILCO employees have advised the administrators of nursing and adult homes to shelter their patients in areas such as hallways, chapels, kitchens and boiler rooms which, in many instances are not equipped for the proper care of ill people.
LILCO seems not to have appreciated these practical difficul-ties.
For example, the Suffolk County Home and Infirmary has un-dersized doorways into its patient rooms, and therefore beds cannot be rolled out of the rooms. 'Because the facility does not have enough gurneys to accommodate all its. patients, there
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would not be enough beds avnilable to accommodate all the patients in shielded areas, even if there were enough room in those areas for all the patients. Similarly, the Sunrest Nursing Facility could not implement LILCO's recommendation that it shelter its patients in its boiler room. Patients could not be cared for adequately in a room with heavy equip-ment. This problem would be even worse for a hospital, because many hospital patients are dependent on equipment, such as monitoring devices and outlets for oxygen, suction, and elec-tricity, all of which are absent from common areas like hall-ways or basements. For example, in Central Suffolk Hospital oxygen and suction are provided through a central system.
There are no outlets in the hallways or other common areas.
Thus, those patients of Central Suffolk dependent on oxygen or suction could not be moved out of their rooms, unless the hospital had enough portable equipment to meet their needs.
Central Suffolk Hospital does not have enough portable oxygen er suction equipment to move its patients out of their rooms, and the administrator of the hospital has no plans to obtain the extra equipment.
Third, LILCO's sheltering proposals could not be imple-mented at many special facilities where it is impossible to keep outside air out of the buildings. For example, the
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Suffolk County Home and Infirmary is an old building, which, in the opinion of its administrator, simply could not be sealed up adequately. The air conditioning units at the Riverhead Nursing Home and Health Related Facility cannot De isolated from outside air, and therefore would have to be turned off.
Furthermore, this building has many vents and windows, all of which, according to the administrator, could not possibly be sealed. Oak Hollow Nursing Center and Crest Hall Health Relat-ed Facility also rely on outside air for their air condi-tioning. To cut off outside air, their air conditioning systems.would have to be shut off.
The air conditioning system for a special facility simply l cannot be turned off at certain times of year. In hot weather, people would die if that were done. It is unrealistic'to suggest that elderly people should be expected to stay for several hours in a stuffy, hot basement with no circulation.
Those conditions would be unbearable.- Indeed, anyone who tuus been involved in the nursing home industry'long enough to re-member the days before air.co,nditioning was widely used, also remembers that11n those. days nursing home patients frequently died premature,1y in hot weather directly because'of the heat.
And those deaths occurred when'the patients were in. rooms with open. windows and when every effort was being made to maximize
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the circulation of outside air. By contrast, if sheltering were attempted, every effort would be made to minimizo outside circulation. The elderly are especially vulnerable to heat stroke and heat exhaustion. In addition, many nursing home patients are prescribed drugs that reduce the ability of their bodies to handle heat. Thus the health threat involved in LILCO's sheltering proposal is very real for nursing home patients.
Fourth, LILCO's selective sheltering proposal also ignores the need for adequate staff. Preparing and moving all the patients in an institution, with necessary equipment, to shel-tering areas requires a large number of staff. In addition, personnel grow tired and need to be relieved. If an emergency occurred during the night shift, there would not be enough staff on hand to handle the emergency. They would need rein-forcements. Indeed, the staffing problem would be made even more serious by the fact that many staff members would not report for duty because of role conflict. (See Direct Testimo-ny of David Harris Concerning Contention 25 -- Role Conflict ff. Tr. 1218.) Despite these needs, however, LILCO's Plan contains nothing about the need for reinforcing the staffs of special facilities.
Even if people could be found who would be willing to report for work during a Shoreham accident, the reinforcements may be contaminJ;ed on their trip to the special facility. If contaminated workers were allowed into the sheltering area, contamination would be spread throughout it. However, at most special facilities there would not be any equipment for determining whether or not newly arrived staff members were contaminated, and the staff would not be trained in l decontamination techniques. As a result of these problems, l 1
staff would become ineffective through fatigue, and the patients would suffer.
Fifth, even if sheltering were possible for special facilities, OPIP 3.6.1 does not contain shielding information or sheltering capabilities relating to any special facilities.
Consequently, LILCO's command and control personnel would not have enough information with which to make an informed deci-sions as to whether selective sheltering would provide adequate protection for special facilities patients. The situation would be even worse for the administratorn of the special facilities, because they would know nothing about the situation except what LILCO revealed to them. OPIP 3.6.5 says-that a hospital would be evacuated if the administrator desires it.
(OPIP 3.6.5 at 1.) But an administrator could not really i
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choose between sheltering and evacuation, if LILCO were the only source of information, and if the administratar had received no detailed plans or standards ahead of time.
LILCO's proposal to selectively shelter persons unable to evacuate is equally inadequate with respect to handicapped individuals at home. It is likely that many of these individuals would be unable to withstand the stress of an evac-uation, but many of these individuals probably could not be sheltered as an alternative to evacuation. First, the Plan does not provide for qualified personnel to determine whether an invalid who resides at home could or could not be evacuated.
LILCO command and control personnel could not do that, nor could LILCO expect that an EMT or AEMT could examine a home-bound individual about whose medical history he knows nothing and make such a determination. EMTs and AEMTs are not trained to make that sort of evaluation.
Furthermore, even if a correct decision were made that the person could not be evacuated, such an individual who is so sick that he could not be moved could not close the fire place flue, pull the drapes, or move to the basement. Furthermore, there is no assurance that the home of any given homebound individual would be suited for sheltering. The physical jobs 4
involved in sheltering would be impossible for people who were too disabled to be able to withstand an evacuation. As a ,
result, regardless of the protective action recommendation, professional assistance would be necessary at the residences of severely disabled individuals. And, elderly people who reside at home are just as vulnerable to heat stroke and heat exhaus-tion as elderly people in nursing homes. Therefore, in hot weather elderly homebound persons in many cases could not turn off their air conditioning or cut off their circulation of outside air. LILCO's Plan ignores these practical difficulties.
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V CONTENTION 72 - EVACUATION OF SPECIAL FACILITIES h
Q. Please state Contention 72.
A. Contention 72, as admitted by the Board, states:
Contention 72. The LILCO Plan proposes to evacuate all hospitals, nursing homec and other special health care facilities in the EPZ, using buses, ambulances, and ambulettes. (Plan, Appendix A at II-28 to 29; IV-166 to 168; IV-172 to 178; OPIP 3.6.5). This aspect of the Plan cannot be implemented; accordingly, people in special facilities will npt be adequately protected in the event of an emergency and the LILCO Plan fails to comply with 10 CFR Sections 50.47(a)(1), 50.47(b)(3), 50.47(b)(8),
50.47(b)(10) and NUREG 0654, Sections II.A.3, C and J for the following reasons:
Contention 72.A. Assuming the neces-sary vehicles were available to LILCO and were mobilized, tho time necessary, follow-ing mobilization, to accomplish the pro-posed evacuation of special facilities will be too long to provide adequate protection from health-threatening radiction doses.
Evacuation will take too long as a result of: the large number of trips necessary to transport persons individually to reloca-tion centers; the other mobilization and evacuation traffic congestion which the evacuation vehicles will encounter; and the time necessary to load and unload passen-gets from ambulances. Thus, the Plan fails s to comply with 10 CFR Sections 50.47(a)(1) and 50.47(b)(10).
Contention 72.C. The Plan fails to identify any relocation or reception centers for persons evacuated from any hospitals, nursing homes, or other special health care facilities other than the Unit-ed Cerebral Palsy of Greater Suffolk Inc.
Contention 72.D. The LILCO Plan i recognizes that under certain circumstances l the evacuation of John T. Mather Memorial, St. Charles and Central Suffolk Hospitals might be necessary, and that LILCO may 1 recommend such an evacuation. - (Appendix A I at II-28, IV-172; OPIP 3.6.5 at 8). How-ever, the Plan fails to specify adequately or accurately the circumstances that would i
necessitate an evacuation'of the hospitals, 1 and does not include adequate procedures to -
4 permit the person in command and control to make an accurate determination as to.wheth-er or not such an evacuation is needed.
Thus, the Plan fails to comply with NUREG 4
0654 Section II.J.10.m and 10 CFR Section 50.47(b)(10).
Contention 72.E. Instead of planning i
to provide adequate protection to hospital patients in the event of such an evacua-
} tion, the LILCO Plan simply provides that "LERO will evacuate these facilities-using i an ad hoc expansion of transportation
- resources that are; presently committed to- !
other aspects of evacuation." (AppendixLA at II-28, IV-172). Apparently, this ad hoc
, plan will not be developed until an emer-
, gency actually occurs.. (See Appendix A at II-28; II-172, 173). The ad hoc plan will' utilize the vehicles assigned to implement the evacuation of other segments of the population, but such vehicles will be
- supplied for.the purpose of evacuating hospital' patients.only "on an as svailable a
basis," and only "as1the rest of the af-fected population evacuation nears comple-tion." .(Appendix A at IV-173). Thus,
-there is no assurance that. adequate protec-tive measures could or would be taken for hospital patients and LILCO-has thus' failed to satisfy the requirements of 10 CFR' Sections 50.47(a)(1) and-50.47(b)(10), and NUREG 0654,Section II.J.10.d. . ,
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f e O Q. Do you agree with Contention 72?
A. Yes, we do. LILCO's proposed evacuation plans for special f acilities would not work for several reasons. Indeed, any attempt to implement them probably would result in in- (
creased incidences of morbidity and mortality. The two most important reasons that LILCO's proposals could not work are those identified in subparts C and E of Contention 72.
First, as we noted above with respect to Contention 24.N, the LILCO Plan does not identify reception centers for_any spe-cial facilities except the United Cerebral Palsey facilities.
Apparently, these' reception centers have yet to be determined.
(See OPIP 3.6.5, Attachment 2.) In our opinion, given this crucial defect in LILCO's Plan, its proposed evacuation of the special facilities could not be implemented.
C. Why?
A. We do not believe that physicians, nurses or adminis-trators would consent to the movement of patients committed ~to their care if there were no adequately staffed and equipped fa-cility waiting to receive them. Similarly, ambulance or ambulette crews would be unlikely to assume responsibility for patients if there were no health care facility-to which to take
them. Indeed, command and control personnel probably could not even recommend evacuation if there were not a sufficient number of hospitals or other facilities able to receive the evacuees.
Without identified and available reception centers, all the provisions of LILCO's Plan concerning evacuation are words on paper and nothing more.
Moreover, regardless of whether or not LILCO has tried to make adequate arrangements and obtain agreements with reception facilities, it would be very difficult for LILCO to find an adequate number of facilities within a sufficiently reasonable distance of the EPZ to make their use practical, which could handle the numbers of evacuating patients expected under LILCO's proposals. According to LILCO's estimates, the handicapped institutions in or near the EPZ have approximately ._
74 non-ambulatory residents. (Appendix A at II-18). The nursing homes which will receive evacuation help from LILCO have about 900 residents. (Appendix A at IV-175.) And, the three hospitals covered by the LILCO Plan on average have ap-proximately 630 patients. That is, a total of over 1500 individuals might have to be evacuated from these facilities.
Although a few patients in handicapped facilities, hospitals, and nursing homes might ce able to go to regular relocation centers, most of the census of such facilities would require L - - - _ - .
special relocation centers providing a level of medical care comparable to the institutions from which they came.
In earlier versions of the Plan, LILCO proposed to utilize Kings Park State, Pilgrim State, St. Johns, Northport V.A.,
Eastern Long Island and Southhampton hospitals, as well as the Central Islip Psychiatric Center and the Suffolk Developmental Center as reception centers. Conversations our staff had with the administrators of these facilities confirmed that these facilities together could not handle 1500 evacuees or, indeed, anywhere near that number. Although most hospitals have casu-alty influx plans, a hospital with a total bed capacity of ap-proximately 200 to 400 beds, which is typical of hospitals in Suffolk County, probably could free up only about 50 to 60 beds in order to handle a sudden influx of new patients. The ab-sence of receiving facilities makes LILCO's Plan unworkable.
Second, as stated in Contention 72.E, although LILCO admits that an evacuation of hospitals might be necessary under some circumstances, LILCO does not have a detailed plan which can readily be implemented to cover such a possibility. In-stead LILCO intends to evacuate the three hospitals included in its Plan "using an ad hoc expansion of transportation resources that are presently committed to other aspects of evacuation."
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e (Appendix A at IV-172). Concerning this expansion, the Plan states:
The sources of (the] vehicles [to be used to evacuate hospitals) will be the companies who are supplying vehicles for the evacuation of other segments of the population. Those vehicles will be supplied on an as available basis as the rest of the affected population evacuation nears completion.
(Appendix A at IV-173.) LILCO thus virtually admits that under its Plan hospital patients will be ignored unless and until everyone else in the EPZ has been evacuated. Then, if resources are "available," LILCO will turn to the hospital I patients. This aspect of LILCO's Plan is unacceptable, since ,
I there is no assurance at all that a timely evacuation of hospital patients, if required by the seriousness of an accident at Shoreham, could ever be accomplished.
These two reasons set forth in Contentions 72.C and 72.E alone render LILCO's evacuation proposals for special facilities unacceptable. In the following testimony, we will address additional deficiencies in LILCO's proposals for evacu-ation of special facilities.
As asserted in Contention 72.A, one of the fundamental reasons why the proposed evacuation of special facilities is
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unlikely to work as expected by LILCO is that it would take too long. LILCO's time estimates assume that in normal weather the last evacuation vehicle carrying special facility patients would leave the EPZ seven hours and fifty minutes after the start of an evacuation. (Appendix A at IV-177, IV-178).
LILCO's time estimates, however, are too optimistic, and in fact, the patients of special facilities probably could not be evacuated in that amount of time.
Other witnesses have addressed the fact that serious traf-fic congestion is likely to occur throughout.the EPZ once an accident at Shoreham reaches the point that an evacuation is ordered, and the effect that such congestion would have on the time necessary to complete an evacuation.. Our testimony will not address traffic conditions, but instead will focus on the time necessary to begin the evacuation process and to prepare, load and unload the patients. -The point'concerning traffic that one must bear in mind is that the aspects of an evacuation that we will examine by themselves probably would take too long, even without considering the effects of traffic conges->
tion on actual travel time. With crowded conditions on the roadways, the' total time necessary to complete an evacuation would be even longer.
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O. Why will LILCO's evacuation plans for special facilities take too long?
A. The reasons fall into two categories. First, the process by which LILCO employees at the EOC would attempt to
" coordinate" the evacuation would take too much time and would in fact cause further delay by creating confusion. In addition, the tasks that would have to be performed at special facilities in order to accomplish an evacuation would take a very long time.
Q. Why would LILCO's plans for coordinating the evacua-tion take too long?
A. First, because accomplishing the tasks specified by the LILCO Plan as necessary to coordinate the evacuation would 4
require a substantial amount of time. If an evacuation were ordered, under OPIP 3.6.5, Section 5.2.2., the Health Facilities Coordinator is given a very difficult task. He is expected to telephone the four organizations that operate facilities for the handicapped, the ten nursing or adult homes, and the three hospitals included in the LILCO Plan. He is sup-posed to inform each facility of the need to evacuate, and then collect from each institution information about transportation and special medical care needs. Then he is supposed to-relay
tne transportation information to tne LILCO Ambulance ano sus
. Coordinators. In addition, he is supposed to contact an unspecitied number of reception centers (that are not ioenti-fled in the Plan), inform their staffs of the pending evacua-tion, and relay to them the information from the evacuation facilities about special care needs. Obtaining and relaying that much information to and from that many facilities would take the one person LILCO has assigned the job a long time.
Even if other persons assisteo the Health Facilities Coordinator (and no sucn assistance is set torta in the Plan) it is quite likely that the necessary communications coulo not be accomplished prior to the predicted arrival or ambulances and ambulectes at special facilities, a little more tnan two nours after an evacuation order.
In addition, the information tnat must be transmitcea through LILCO's coordination process must to be relayed a number of times to several different parties. That information might very well become garbled as it was transmitted'trom person to person. Consequently, wnen receiveo by tne last re-cipient, it could be inaccurate. The people wno had to act in reliance on this inaccurate intormation might unknowingly act inappropriately and cause delays.
Q. Are ene flaws in LILCO's provisions for cooroinating tne evacuation the only reason that LILCO's evacuation plans for special facilities would take too long?
A. No. The second major problem, as asserteo in Conten-tion 72.A, is that performing the tasks necessary to implement an evacuation of special facility patients also would take a long time.
Q. But why would the special facilities not be aole to perform these tasks in a timely manner by implementing tne oi-saster plans they already have?
A. It is true tnat hospitals and nursing nomes nave "ol-saster" plans of some sort. However, tnose plans are for situ-ations such as fires and storms, ano are inapplicable to tne actions LILCO expects special facilities to perrorm in a Shoreham emergency. Existing plans generally do not envision relocating all or most or the patients in a nospital or nursing home to another facility miles away, and they do not include details for how to accomplish such a total relocation. The ex-tstence of these plans does not, therefore, eliminate the problems involved in implementing LILCO's evacuation proposals in a timely manner.
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e O Q. Please explain the reasons wny tne evacuation process would take too long.
A. First, the LILCO Plan appears to ignore completely the amount of time that would be necessary to prepare patients for evacuation. Preparing the occupants of a nealtn care ra-
{ cility for evacuation and relocation is not simply a matter of giving the patients their clothing and an extra blanket. Eacn patient's records and medication would have to be collecte6 and brought to the patient for use at the reception center. More-over, the condition of each patient would have to be indivicu-ally assessed by professional personnel. Tnis woulo be neces-sary in order to allow tne starf botn to determine the order in which patients woulo be moved, and to allocate scarce equip-ment.
Q. Why must there be a predetermined order?
A. Because some patients, inevitaoly, would be in worse condition than otners. Indeed, some patients would be too 111 to be moved. These incivlauals would have to be identiried, and arrangements would have to be made for their care, including the assignment of staff to remain benind. Of those patients who could be moved, the most seriously ill assigned to any one vehicle would have to be loaded last and unloaaed first, so that they would spend less time outsloe tne hospital or nursing home rooms. it would be unacceptcble simply to loaa patients in any convenient orcer without considering tneir rel-5 ative conditions. The process of evaluuting patients would be time consuming.
In addition, many patients depend on special equipment such as traction, suction and respirators. Provisions woulo have to be made to have the right equipment available for eaca patient ducing the move. Because special tacilities have a limited amount of portable equipment ano therefore probably , ,
1 could not provide such equipment to all patients who neecea it, 's i the staf f of a health care f acility would nave to wait unt11 the conditions of all the patients had been evaluated anc tne order of evacuation determined, before eney coula allocate ilm-ited pieces of equipment. Patients coulo not be movea near outside doors and away from permanently instailea equipment in
'tneir rooms until this preparatory work haa been completea. (
And, because most nursing homes do not nave a gurney or wneel-chair for every patient, some patients could not be movea t' rom their rooms ahead of time. That is, in-some tacilictos the '
staf f could not create a little staging area near the'cutside door for all the patients, but instead would nave to move many patients from their. rooms after vehicles arrive. This would-lengthen the loading process significantly.
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Second, LILCO has not considered the problem of starting.
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The work that would have to beyp ertormed by the starts of spe-cia.1' facilities.to evacuate their patients.would be overwhelming. If the patients ot these facilities were to be evacuaced, it would require the ebforts of nea'rly everyone on x the staffs, including physicians, nurses, orderlies, laboratory staff, office personnel, administrators, and maintenance per-sonnel. However, even without consideringsthe reduction in
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s available staff that will be caused by role conflict (see N
Direct Testimony of David Harris Concerning Contention 25), it m .
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~s is podsible that enough workers woulo not be available to ~
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assiskintheseeffortsonatime,ly' bas'is. ,
o At a typical nealth
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" care facility, af ter normal business hou'r's ,there are almost no clerical personnel or laboratpry personng1, ver'y few aominis-
-b[ative'Ar maintenance personnel and few doctors on duty. Even
_s N' the nursing staffs are reduced by about^50 percent in a typical
. s hospital at nignt. The staffing reductions ac nignc at nursing homes and other special facilities are even greater enan ac-nospitals. Consequently, if an evacuation were oroered at night, special facilities woulo have to contac,t many'aodicional employees and request that 'thhy report -to wor \k. It could easi-
'ly be hours before a tacility hao a relatively' full start on hand, assuming that all ;tde staf f would attempt 6 t'o report.
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Although the limited nighttime staff could begin evacuation preparation tasks, until ott-duty personnel reporteo, only a limited amount of work coulo be performed.
In audition, many of tne health care personnel at any given facility would not be available to assist in tue evacua-tion efforts. At the time an evacuation were oroered, some professionals might be involved in surgical operations tnac could not be interruptea once they have begun. Consequently some professional staff could be unavailable in tna early stages of an evacuation. And, as LILCO itself recognizes, some ,
patients are so critical that eney could not be moved at all.
(Plan at 3.6-5.) If patients were to be left behind, mealcal personnel would have to stay with tnem in order to minister to their needs. Because tne patients to be left behind woulo be tno most critical, they would require intensive care. Conse-quently, a portion of the nealen care personnel woulo be tieu up providing c ue to seriously ill patients and woulo not be available to help in the evacuation.
In sum, LILCO's evacuation proposals would take too long because there would be too much work to be cone. LILCO's Plan contains no recognition of the awesome amount of work tnat would be necessary to evacuate the special facilities. Moving 35 -
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-r 111' and injured human beings is not..<like moving . :aerchandise, and'/ for a host of reasons, this taan could not be accomplisheo J t ,,
An'a few hours, as LILCO expects; All the problems we have describeo so .far have involvec h, 4 the problems of the special facility stb 4ts attempting, to
[ prepare, move and; care for tneir patients. The time necessary
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tc evacuate the special. f acili ties; wilj,,b,e inc:ceasea cecause ,
LILCO h,as ubderestimated tne .ntimber yA- VenicJ er, neeced to
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, r O. , Why do you say that?
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,1l A. LILC0 explaans its assumptions about the number or s r.
I venicles and the amo'unt.of
--- time neeaed to evacuate the ERZ at ?
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pages IV-175 to IV-178 of Appendix A. It is' apparent from'
,,j theshpages:that_LILCOhasmadesomeseriouserrors.
1 One flaw in LILCC's estimates of tne numoer of necessary vehicles is its reliance on ambulettes. An ambulette is a v'an 4i '
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that'is'equiphed to.2ccommoddce people in wneelchairs.
e t St$cn a y
vehicle has a lifs t for- l'oaaing and unloading ;^
wheelchairs, and
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it hasj space to accommodate perhaps t'our sneelenairs. But, as p ., . --
~ LILCO has been informed by its own con Nactors, ambuleptos do Y '
not. provid,e their own, wheelchairs. '#(See Plan at Appendix, -
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49.) Thus, in an evacuation, LILCO apparently expec ts the special facilities to provice enough wheelchairs for all the patients whom LILCO expects to evacuate in ambulettes. More-over, LILCO's estimates assume tnat almost all the l non-ambulatory patients ot nursing homes (with the exception ot the Suffolk County Home and Informary), would be evacuated oy ambulette. (Appendix A at IV-175.) It is unlikely tnat a nursing home or hospital would possess enough wheelcnairs to accommodate almost all its non-ambulatory patients. Particu-larly in the early stages of an evacuation a special tacility could not let many wneelchairs leave the facility with evacuating patients, because most of tne wneelchairs are likely to be needed to move patients within the facility and to vehi-cles. Therefore, if an attempt were made to implement LILC0's proposals, a large number of ambulettes would be or no use, be-cause of a lack et wheelchairs. As a result, ambulances wouto have to make many additional runs to pick up the slack. A great amount of time would be lost in tne process.
In addition, LILCO assumes in-its Plan tnat six ambulettes could be loaded simultaneously in fifteen minutes, ano tnat six I ambulances could be loaded simultaneously in twenty minutes.
(Appendix A at IV-175.) However,-it,LILCO means tnat six veni-cles could be loaded at a time at any one special racilicy, as
opposed to six throughout the EPZ, LlLCO is probably wrong.
Although six ambulances could be lined up in a parking lot, at many facilities, six vehicles could not park simultaneously im-mediately outside the doors suited for loading patients.
More importantly, however, LILCO's fifteen and twenty minute time estimates are too short. Perhaps they would be reasonable if the patients all could be bundled up and waiting by the outside doors. But as we discussed above, the patients of some f acilities woulo not be near entrances to the bulic-ings. Instead, tney would have to be moved from their rooms to entrances and then out to vehicles. That process, witn the constraints ot available personnel, elevators, gurneys, and wheelenairs, would take longer than fifteen or twenty minutes per vehicle.
Q. Other than the reasons you have already discussea with respect to nursing homes and handicapped facilities, are there any additional reasons why LILCO's retusal to plan for an evacuation of hospitals makes sucn an evacuation impossible?
A. First, as asserted in Contencion 72.D, tne LILCO Plan contains inadequate standards to be used by LILCO command ana' control personnel who are assigned the responsibility ot determining whether to recommend evacuation. And, if LILCO l
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intends to leave the decision' up to the hospital administrators, without necessary factual information about the shielding characteristics of the hospitals, and evacuation pro-cedures that could provide an estimate of how long it would take to evacuate the hospitals, an administrator would have no basis upon whicn to determine whether an evacuat_on of his patients was necessary, desirable, or possible.
Moreover,.as asserted in Contention 72.E, LILCO's proposal to evacuate the hospitals if necessary on an ad, hoc basis is unlikely to succeed. First, because LILCO plans to assign ve-hicles to the hospitals only as they finish their otner assign-ments, it would be several hours'before the evacuation or tne hospitals could even begin. .According to'LILCO's estimates, 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 25 minutes after the start ot an evacuation one ambu-lance and one ambulette would be leaving the EPZ. (Appendix A at IV-177.) After these two vehicles droveJto reception centers and were unloadeo, they coulo then proceed to the hospitals in order to help in the evacuation of those f acil ities, assuming that they were not needed .for auditional trips to the other special facilities. ' According to LILCO's numbers, it would be almost eight hours betore the last of the ambulances and ambulettes involved in the remainder.ot the' evacuatio" ot'special facilities left the EPZ. (Id.) And
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e e these time estimates assume normal weather conditions. In reality, it would take even longer than LILCO estimates to begin the evacuation of the hospi*als, because, as we discuss above with respect to Contention 72.A, LILCO has seriously.
underestimated the time that would be needed to evacuate the other special facilities. Since, under the LILCO Plan, evacuating hospital patients would not begin until the vehicles involved in evacuating the rest or the population hao completed that task, hospital patients would be exposed to greater risk 1
of exposure to radiation than everyone else in the EPZ because their evacuation could not even begin until several nours after an evacuation order.
Second, because of the long delay at the start ot the evacuation, the degree of confusion involvea in attempting to implement an evacuation would be even greater at hospitals than-at the other facilities. Immediately after--cne evacuation rec-ommendation, staff and patients would anxiously attempt to prepare. The urgency of the situation would be. apparent to.-
everyone. But people in the nospitals would know they were to be the last evacuated, and several hours would pass betore the first vehicles. arrived to begin to transport patients out of the danger zone. Under-those circumstances people'almost cer-
-tainly would become even more anxious and frightened. In ll ---__-------uw -am-------1u---,-n.------------,,,,m..-.----st-- - . a--.-- ---m-- --- -~.
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addition, the situation at Central Suftolk Hospital coulo be particulatly bad, since it is expected to care for contaminated injured persons in the event'or a Shoreham emergency. The ar-rival of a contaminated patient at the hospital, wnile ene staff is attempting to evacuate its otner patients to avoid being exposed to contamination, is likely to heighten anxiety levels even more.
Q. Please summarize your testimony concerning the evacu-ation of tne special facilities in the EPZ.
A. LILCO's proposals for evacuating special facilities could not and would not be implemented for a number or reasons.
First, the coordinating procedures that LILCO has deveAoped to oversee the whole evacuation would be too time consuming. In particular, the Healtn Facilities Coordinator could not do his or her job fast enough for the evacuation-to get underway quickly or to proceed smoothly. In addition, LILCO's proposals would take too much time to implement, and tne pacients of spe-cial facilities therefore might not receive adequate protection. LILCO has made unwarranted assumptions about tne amount of work involved in such an evacuation. LILCO has not estimated conservatively needs or' resources, such as the numbers of necessary vehicles, wheelchairs, or portable medical F
. n equipment. LILCO nas not addressed majot contingencies such as the possibility of an evacuation recommendation at night when staffing is low. LILCO has not been realistic in its expecta-tions of human behavior, for example t'he likely reactions of hospital staffs and patients.
Despite all the problems that are likely to render an at-tempted evacuation of the other special facilities unworxable, however, the situation is much worse with respect to hospitals.
LILCO has failed to plan at all for an evacuation of tne tnree nospitals covered by the LILCO Plan, notwitnstanding LILCO's acknowledgement that such an evacuation could become necessary.
The result is that any attempt to evacuate the nospitals would suffer not only from all the flaws involved in LILCO's propos-als for evacuating the other special facilities, but also trom a complete lack or planning.
Finally, LILCO's plan for special racilities evacuation could not be implemented, because LILCO has not arranged for reception centers for the patients of those facilities. There is not enougn available space at health care tacilities near the EPZ to accommodate the likely number ot evacuating pati,ents, ano no evacuation could or would be implemented in the absence of identified facilities with-the capacity and-capabilities of caring for the evacuees.
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I Q. Does that conclude your testimony?
A. Yes.
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