ML20099D127
| ML20099D127 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/06/1984 |
| From: | Dufour K AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#484-189 OL, NUDOCS 8411200209 | |
| Download: ML20099D127 (4) | |
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J BOOKSELLERS AND PUBLISHERS J --, C.
POST OFFICE box 449 e
- CHESTER SPRINGS. PENNSYLVANIA 19425 -
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b Nuclear Regulatory Commission Docket #50 352 Washington DC 20555 gjgg4
Dear Commissioners,
Since I most likely will'be unable to -attend. the. upcoming public hearings wherein you will consider the public's comments on whether Emergency Evacuation Plans are " adequate" and whether.they will-work to protect the citizens in the event of a nuclear accident' at Limerick Nuclear Power Plant in Limerick, Pennsylvania, I have decided to. send my comments to you instead.
I do hope that you will listen to, consider and act on comments submitted in letters (and not throw them -out as my husband has suggested) just as you will at -the hearings?
I have a number of comments and questions regarding differing, yet _important aspects of the Emergency Evacuation. Plans, and the question as' to whether such plans are feasible or not.
- 1) School Evacuation Plans, especially in " risk". school districts:
I am extremely concerned about these plans since children are particular-ly sensitive to radiation.
Philadelphia Electric Company'.s proposed school plans have been submitted to the Nuclear Regulatory Commission as if they were written and prepared by the schools themselves, but that is not the case.
Present plans include instructions for students to place wet cloths over their mouths and noses if " sheltering" or staying inside school buildings is recommended during an accident at Limerick.
Such act. ion would take place if bad weather or slow arrival of transportation were to take place and prevent a prompt response. If such sheltering were to occur, for how long would this sheltering be necessary? How long can one reasonably expect students (especially young ones, Kindergarden age) to place wet cloths over their mouths and keep them there? And who, really, is going to take care of these students be it for sheltering, or transport?
I know that in the plans teachers and school staff are expected to remain l.
with stddents during sheltering, or if an evacuation were to occur, teachers l
are expected to accompany children on buses to the host schools where they mus't remaing until children are picked up by their parents. What kind of guarantee is there that teachers will in fact abide by these plans?
I know several teachers who teach in " risk" schools who, in such an emergency, would put the welfare of their own f amilies first, not that of their students.
It is the position of Pennsylvania State Education Association lawyers that any unilateral acceptance of these s.hool plans without in-volving teachers in their development and discussing it with the union is an unfair labor practice in violation of the law. How can school evacuation plans be accepted as " adequate" if there is no guarantee #1)that teachers will stay with their students #2)that even if they do remain that they would be able to enforce the ' recommended practice of keeping wet cloths over students mouths and #3)that this second practice would even really help?
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~Yet7another topic'to;censider whenfdeciding.whetherLtheischool, evacuation 1plansiare:" adequate."Lis the' question of' busing xIn_most~-
p icasesischool! bus' drivers" ha'ven ttleven beeniasked : to (volunteerrahead
=of. timelfor evacuation " duty. _ LItd s l assumed"by the' Philadelphia? Electric:
JCompanyland by;the Pennsylvania 1ManagementiAgency.thattaicontractLwith
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- a1 bus company alone will guarantee lthat -busedrivers'.will/show up.
- But,
-the: contract #with th bus company are not : legally. binding and; are e
written' to1 provide 1 buses'"to 'thetmaximum extentJpossible." ~Howican'the school evacuation. plans be: approved as " adequate" whenEno minimum:
guaranteed _ number ofl buses'hasteven'been agreeditofbyfthenbusicompanies?
For that matter, school districts'just outside1theLten-mileLEmergency.
Zone' are in many: cases not inclined ~ to give?upitheir busesDfor' evacuation inside the EPZ when they have :their'own students ~ to transport.
In a letter-dated. March 5,11984, Tredyffrin/Easttown School District-o made the -point that. should they.give up theiriown: buses, "we would not I-b.e.able. to. safely-and expeditiously' delivercstudents to :their homes.".
The danger and the desire of parents to get their children.out of? the area in case of' a serious accident at Limerick does not stop: at: ten miles.
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I' have yet other' quettions about the schoo,L plans which I think should be answered before the plans are deemed " adequate". Will high school students with cars be allowed to -drive-their ca,rs? Who will be responsible for their safety?
Is the Philadelphia Electric. Company-responsible' for any injuries to the students or damage. to the buses if an accident-or accidents should occur during an evacuation? Who will pay for the implementation of school evacuations or sheltering?-
-#2) Day Care Centers:
Since children are particularly sensitive to radiation, I am concerned not only with whether evacuation plans are adequate for schools, but also. for day care centers.
Do the evacuation plans currently in existence take care of the evacuation of children, even' younger than Kindergarden age, in day care centers?
Who is' responsible for.their care and evacuation? ' Are buses and drivers (provided they are found) expected to help with private day care centers? If not, and parents are supposed to (and would of course'want'to) pick up their children.,
l-this would no doubt create _ traffic problems, especially when parents had1to go "the wrong way" on routes designated as evacuation routes. Parents would have to do this to reach day care centers nearby.
And remember,
'the parents would not be coming from a nearby) residence (otherwise the
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child would most likely be home to begin with but from the place of work. nce doubt a farther location, hence prolonged traffic problems...
Unless workable plans are drawn up which -deal with these very tiny, n
.special_ children (the number of which is increasing due to the increase
~M of'both parents working), how can any evacuation plans be approved as
" adequate?"
'#3) Traffic and the evacuation routes:
I have a number of questions regarding' the topic of traffic routes
-and whether they are workable or
- not.'Such need to.be examined and resolved before it should be decided 5-
. whether:the evacuation plans are "a'dequate".
For the plans to even-4 begin,to=" work" depends upon each' driver in the EPZ_ knowing.not one
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- route f(for11 nstanceithe : rou'te< goi ng f rom one 's homa. out' of. the. EPZ'
/toia1 Mass Care; Center),1but.all?of the different routes,,and for EthatTmatte'r, alliof'thes roads in _ the county :to enabletone to zg'et'.to -
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thoselroutes.
ForVins_tance, 'I have' nol knowledge 'of the. roads zin
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' Spring City (the'. towers rof Limerick are -within sight of this town)-
- with the exception of the.ones'which take me -from my home or: place.
of work tota printer'with whom my ' company;does business.-If I;were there and the alarms' sounded.(provided there were no. failures in.
the Lpublic alert system, a different topic again),fI would not know-
-to where:I was: supposed toL drive toD evacuate. -Thisnis a frightening 4t thought.-
How can the evacuation ~ routes be deemed " adequate"'when they unrealisticallyLrely upon one's havingiknowledge:of~all of the roads-in the EPZ and all of -the evacuation routes?
If the traffic; 4
plans-are not. to ; rely Lupon individuals ' total: knowledge of _the-. area, since this is rather unfeasible, how is a driver going'to know how to leave? Are.the -radio. stations to which one is supposed to. turn (and how is one to know what station that is in a vehicle?) going to go road by road to tell drivers where to go? How are the numerous-persons from outside the county (salespersons, delivery. persons,
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tourists, person simply,priving through) who find themselves-in the EPZ during an emergency, know what to do_ar whera.to go? Having officers at designated points alon'g escape routes only is not_ going to help those persons in the EPZ, not familiar with the roads.or' the evacuation l
routes, who are not on the evacuation routes.
Closer to my home, the Pennsylvania Emergency Management r
Agency (on its Evacuation Plan Map dated June '83)~ estimated that aprox-imately 1478 automobiles from four townships would travel over Route 100 in the period of two hours on their'way to the intersection with Route 113, and then Downingtown. As it is now, without any sort j.
of emergency, traffic on Route 100 during rush hour is almost always-i backed up on Rt.100 from the intersection of Rt. 100 and Rt.113, to i
the PA Turnpike entrance (and sometimes beyond).
How realistic is it j
to say that 1478 vehicles from four townships could trav&l over Rt. 100
'in the. period of two hours when it takes 10-15 minutes during rush-hour fo'. only a fraction of that number to pass ~ through? Is it possible in r
two hours time (providing that the two hours is realistic, and it is not) to escape. radioactive gases or particles that are being blown by the wind from a source only about twelve miles away?
With'such. a mass of vehicles traveling one way out of the EPZ, will oth'er necessary vehicles such as the school buses, police, fire vehicles, tow trucks, snow plows if necessary, volunteers (provided there are willing drivers and volunteers), be able to travel into the EPZ on these most, direct routes?. Are gasoline dealers really going to. remain open for business in the~ face of advancing radioactivity? Does the public I
have some sort of guarantee about that? Are there enough-tow trucks and volunteer operators to keep the roads clear?
Until these problems are resolved how can evacuation plans be called "adequite?"
o
. In their report written.af ter 'the July 25th test evacuation drill, i
the Federal Emergency. Management Agency concluded that tt3 current Radio-logical Emergency Plans are not adequate to protect the public. They cited q
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deficiencies:
--a lack lof 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> emergency response capability in nineteen (!)
emergency operations centers, including the Pennsylvania Emergency Management Agency's communications office in Harrisburg and the Montgomery County _ emergency operations center in Eagleville, Lower Providence.
--insuf ficient means to evacuate. "mobili ty impaired.and~ transit' dependent. residents" in the ten-mile EPZ. In the same category, FEMA,
criticized the failure of officials of the State Corrections Institute at Graterford and of various school districts to participate in the drill.
--insufficient radiation detection equipment for' inspections of victims and of ~ air and water.
--the elapse of 25 minutes between-the time the. governor declared
- a. hypothetical evacuation of the EPZ and the time the alert sirens surrounding the plant were activated.
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--the non-participation of townships and municipalities that represent-ed 25% of the population of-the EPZ.
Who is going to pay for the - correction of these deficiencies' (if they can be corrected) and what sort of guarantee does the public have that the " corrections" will be maintained?'
Since there are so very many unresoTved, deTinite problems with the emergency evacuation plans (and in this long letter I regret I have had I
the time to mention only a few), and absolutely no at"this time " reason-able assurance" that workable evacuation plans.are in place,-I do hope that the NRC will decide not to issue a Full Power Operating License.
for the Limerick plant.
Since it is my (as a resident and business owner within the EPZ) and of course many others' possible futures for which you are directly responsible with regard to your decision as to whether Philadelphia Electric Company should be granted a Full Power Operating License, I do hope that you will examine all of the problems with the emergency evacuation plans, and make sure that all of them are resolved before making a final decision.
I thank you for taking the time.to read and listen to one citizen's comments.
I look forward to hearing your response.
t Most since ly, Kristin Dufodr
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