ML20102A359

Comments on Plans for Evacuation of Emergency Planning Zone (Epz).Reliance on Ad Hoc Planning Outside EPZ Would Invalidate Emergency Plans

ML20102A359
Person / Time
Site:	Limerick
Issue date:	12/17/1984
From:	Dardis M AFFILIATION NOT ASSIGNED
To:	Cole R, Harbour J, Hoyt H Atomic Safety and Licensing Board Panel
References
CON-#185-435 OL, NUDOCS 8502080325
Download: ML20102A359 (16)

Text

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- g. L x R.D. 2, Box 46 Newtown, Pa..18940 December 17, 1984

- Atomic Safety and Licensing Board '85 F2 -7 49 ;4 U. . S. Nuclear Regulatory Commission Washing; ton, D.C. 20555 AdmikhtideJudgesHelenF.Hoyt, Dr. Richard,J;j dle] and Dr. Jerry Harbour p Re: Limerick Nuclear Generating Station Docket Nos. 50-352; 50-353

Dear' Administrative Judges:

ff S 7M Thank you for your attention to the concerns which I expressed at the public hearings of.your Board at Likerick Information Center, and for the s _ opportunity to submit the notes from which I was working. I have tried to

assemble _and_ organize them as best I can; they are essentially the same as

-I;was using that evening, but I have added a few pertinent up-dates.

. In first looking into this question, I begar. with a concern whether.the support plan- suggested by ECI for my own county (Bucks) could fulfill the implicit promises to the evacuees. I soon'had to question whether my own county would itself.be protected under certain conceivable conditions. Fin-

. ally, I began-to' question certain assumptlons in the plans for evacuating the EPZ itself.

-These notes reflect two. inherent-difficulties in the assessment of the'

' evacuation plans:' (1) that the ability to_ evacuate people from the EPZ and to

' care for_them is intimately related"to_what happens in surrounding areas, and

- (2);that, depending upon weather, there is a potential no-man's' land extend-

ing: outward from-the edge of the EPZ to'a distance of/at least another-15. miles.

/In that-"no-man's-land",.the predicated evacuation routes and ' support func-Lt ions would not operate as' envisioned; on ithe other hand', residents ' of that region would'themselves be in need of the services which have been designed for; the 10-mile EPZ', but .without benefit of any realistic prior contingency; f planning that ' I. have been ~ able to ~ discover,

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Indeed,'if. Francis' Bacon wasiright about the value of_ negative research.

then_my efforts of the_past six months have been phenomenally. successful.

Most 'of the . time, .I have found myself. in pcssession _ of more information on femergency planning (which,' being the _ ECI draf ts, was. precious little) than

-the. officials from whom I,was.' seeking enlightenment. My quest began early/

'lastLJuly, _ when I pointed out' to my County Commissioners that they were about -

to consider'a plan, of which they.had not.yet received copies, that listed as- -

mimass; care center a vacant: school which had.been-put up for sale two years

, previously.7 The quest' goesion:' ECI's most recent update of-: the plan, dated .

-c 10ctober,:1984, changes a fire company assignment- on that. page, but has tmade.

no substitution for the defunct. school.

Having begun with a basically null hypothesis,'I have. asked questions of-many sources:3 Red Cross, police, fire, and ambulance workers,1 nurses, truck drivers, ithe County-' Agricultural Agent, the Direc' tors of PEMA and BCEMA,

);b New Jersey EMA, people _ from EPA- and FEMA, school officials, and a variety of

. Melected' representatives.

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Adminis%rative Judges Docket Nos. 50-352 50-353 Atomic Safety and Licensing Board Letter of M. Dardis, 12/17/84 Included here are those responses which I thought most useful to you, with a table to indicate the content of the paragraphs. I am sorry it is so long. .It was difficult to omit discussion of a question's significance when the answer, as so often happened, was not directly responsive to what had . initially been asked, especially when the answer revealed either remark-able ignorance about radiation or about the plans, or else deep scepticism about' evacuation possibilities. In general, the consensus among the people with'whom I spoke, sometimes "off-the-record" for all practical purposes,

-was :that the plans were unworkable, a farce, and no more than paper.

A case in point is what happened to several people who accompanied me to the Stowe meeting. They arrived too late to testify because, ironically, we had followed in the reverse direction along.the evacuation route from a Doylestown mass care center past a reception center and thence to Limerick; we then took Route 422 to Stowe. A trip of approximately 32 air miles required nearly an hour and three-quarters, with the result that my

. passengers, one of whom had particularly new and relevant observations to make, Iound themselves at the bottom of the list. It was particularly frustrating for them to discover that so many people above them on that list seemed to regard their mission as a celebration of the nuclear indus-try, rather than- addressing. the real question of satisfactory evacuation plans. ~If the people concerned with the issue can't get into the EPZ in

time to testify, how can we expect the people in the EPZ to get out f.n time to save their lives?

I was impressed by the statement yesterday of Deputy Director McGraw of .the -E.P. A. ,1J1 which he , told David Brinkley that no emergency plan, especially an evacuation plan, could effectively protect people's lives unless the people themselves were involved in total community knowledge and effort. .

Although I personally,believe Karl ' Abraham's statement, which he re-peated to me a fewl days.ago, that because of the density of population,

-Limerick should not have .been built and certainly would not be built today, so that Ilalso believe that a truly workable evacuation plan'.is probably impossible, 'I think nevertheless that it would be irresponsible not to -

examine whether such a plan could be devised. Clearly ( to me, at 'least),

it. has not yet been devised, 'certainly not by ECI. That is why, in con-clusion,1I must go beyond my original null hypothesis, and agree with .the Chairman of the. Bucks County Commissioners in his judgment that the plans .

under consideration are "a dangerous trap".

'If I can be of 'any help to your Board by way of explanation or supple- -

Jaentary information, I'm. glad to offer it.

Very truly yours, t

l(jf "f, 4 tf Margalet M. Dardis J

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{  ; INTERFACE '0F 10-MILE EPZ PLANS AND PROPOSED SUPPORT PLAN (BUCKS) i' l._ Will evacuees-be able safely to reach the intended reception centers?

The list of service . stations available for gasoline, towing, and other .

l assistance brings to mind scenes in this area during the gasoline shortage e ten years ago. It is not stated in the Montgomery plans that there are

specific assignments to maintain order at such facilities, nor does there seem to be-a consideration of the effect on traffic flow of queues of vehi-cles waiting to gas up.

In a conversation with Corporal Eliot of the State Police barracks at Trevose, I learned. that the procedure for clearing the Turnpike of west-bound . traffic at the Philadelphia Interchange would require about an hour, presumably diverting that which was about to enter there as well as that which was traveling westward on the highway from New Jersey. Apparently the solution would be to send the impacted traffic back to New Jersey by

_w ay of I-95 and the 'Scudders Falls Bridge. [ Depending upon weather condi-

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tions and the. time of day and week, it is my estimation that this diver-

'sion could create an impenetrable traffic jam, or could be managed fairly '

-smoothly; during daylight and early evening hours, during the week, and es-

_pecially in ice, snow, or rain, it could impede, first, the movement of family members to their homes, volunteers to their assignments, Land finally, of -evacuees to the' reception points.]

Information from the Director of Safety at AAA in Philadelphia yields a very substantial. number of daily service calls in Montgomery County in

the winter time,~ an overwhelming majority for dead batteries. Unfortunately, the figures could not be broken down to isolate the EPZ. Mr. Joseph Tom-linson, a long-time service station manager, estimates that at the supposed 4 Levacuation speed, most evacuees who started with an. average level of gas in

. their cars would need to refuel in Bucks County. 'Under-the conditions of-disruption of traffic patterns, especially around U.S.1, the . Turnpike, and

[_' I-95 East, gasoline resupply deliveries would drop' off to almost nothing.

The Montgomery Plan provides a list' of service stations, .but in ' the absence of:a security force at each one, there is danger of long queues of cars and disruption of traffic patterns, as-occurred during the gasoline crisis.. i

[' . fA further problem appears to be unavailability of fuel. on the Turnpike-

['. - and, to al lesser extent, on the other evacuation routes.

i According ' to a Colonel Kuba, with whom I was finally put in touch at Indiantown-Gap, evacuees would jam the Turnpike before the National Guard could respond to get its own vehicles and people up there. [ Cpl. Eliot had already mentioned

. that there are 'almost no accessible entrance points to the raised section cf l Lthe highwayLbetween Willow Grove'and U.S. 1.] Col. Kuba was somewhat net-47 tied that he had not seen the plans. "You seem to be privy to information l.

that .I have 'not been made privy to," he. said. "Perhaps the General has seen-l<- it. . I haven't." He went on to stress that their reaction time, to get a ,

I few drivers and' vehicles on their way, would be a-minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and-D, :more:likely close to a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> response. [Having read the. testimony before

~ lyou by s ' representative: of the National Guard, ~I realize that it conflicts with,the ' opinion that:I have just cited. Not knowing the place of either

. man in the chain of command'nor their direct involvement in implementing-emergency procedures, I don't know which one to believe.]

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e INTERFACE: E PZ-S UPPORT In efforts to obtain information directly from Willow Grove, I was referred to Sgt. Fitzpatrick, who works there in charge of the fire equipment, but did not reach him at 4:10 P.M. of the day I called; a clerk answered and told me, "They all go home at 4 o' clock." Granted that all personnel are on call, it is still clear that emergency response is on a call-up, not a minding-the-store basis, with a resulting delay in mobilization. On July 23rd, I

, spoke with Lt. Portnoy, and later with Col. Kuerschner, both of whom seemed genuinely puzzled when I asked them what their role in the forthcoming test would be. They had no idea where any orders would come from; presumably from the Gap. When I asked about support services on the Turnpike, Col Kuerschner said, "You're hitting me completely cold."

In any event, evacuation of so many people over winding country roads and along the Turnpike, with questionable fuel and emergency services, is very likely to p] ace them in competition with self-evacuating Montgomery County residents from outside the EPZ as well as those from Bucks and possibly parts

of Philadelphia, for both gasoline and road-space.

Most important, there is the question of the possibility of radiological injury to the evacuees in the course of their movement.

The Pennsylvania Turnpike, between Norristown and the Philadelphia Inter-change, curves back and forth between the 10% and the 16% wind frequency sectors (the highest and third highest of the compass divided into 16). The other two evacuation routes, 113 and 202, travel basically through the and . wind frequency sectors, respectively. A tie-up on the Turnpike itself could.thus subject to radiation people who had managed to complete the first phase of the evacuation process unscathed.

The assumption that half the evacuees would elect to keep going is a disturbing one. Supposing even that they eventually make their way to New Jersey, some might very possibly be in need of prompt decontamination. No machinery appears to be in place to accomplish the necessary monitoring. As far as the State of New Jersey is concerned, I understand from Mr. Joseph Hayden at the N.J. Emergency Management office in Trenton that people wishing to use their mass care centers would be permitted to do so if they requested shelter. At that point, they would presumably be monitored. Otherwise, any-one entering the state on the way to stay with. cousin Debbie and her kids would be permitted to do so, even.though car, possession, and people might all

have become contaminated without their knowledge. In the confusion it might be

.some days before they were properly cared for. (Reports from the accident in 1 Bhopal cited cases of people who did not receive medical treatment because they i ran off into the woods and were not even counted among the casualties at first.]

L [It is my personal opinion that an evacuation plan which fails to provide, even require, exit monitoring for.all evacuees after a major release of radio-

. nuclides is inherently immoral. This is especially-true in view of the assump-tien that, in a. day-time accident, commuters and parents returning to the EPZ before evacuation might not be aware of their own exposure as they moved about the area.-]

Mr. Hayden also remarked that their Trenton center was a genuine shelter

. ("That's more'than you people have," he added.) He estimated that it would take a half.to a full day to get the evacuees onto the Turnpike, along it, and off either at U.S7 1 or to the Trenton area. One problem would be fuel on the Turn-pike: "All the guys that pump gas will have jumped on their motorcycles and left."

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i 11 INTERFACE: EPZ-SUPPORT personne1' in a major chemical disaster, if their families were within the danger zone.

[I do not impugn the devotion of emergency workers generally. My brother was' an Army Ordnance safety officer in two wars, a successful safety di-J rector for a large coal-mining company, and later afety director in a petrochemical complex, with experience over a quarter-century. I am there-fore well. aware of what can be expected, as well as what can't be.]

In particular, what can be expected of volunteers is a question, both for the EPZ evacuation directly and for its facilitation in support areas.  ;

Both willingness and-logistics must be taken into account.

On logistics, attached is a column from today's Courier-Times on the

-permanent traffic jam afflicting the central and lower Bucks area. A large number of the predominantly middle-class people who are volunteers live in this. area, but work during the day, most of them at least 10 miles from their homes, many of them in Philadelphia, and some on the periphery or even within the EPZ. Their commutation routes, U.S.1, the Pennsylvania Turnpike, and I-95, are the roads that would be most impacted during an-emergency.

When the ~ Red Cross sent a " team" to the Neshaminy School in the recent November " exercise", they barely managed to get together the requisite num-ber of volunteers to open one center, but according to Mr. Reardon at the Lower Bucks office, they would have been hard put to it to field more than that. He deplored the fact that the exercise was held during the . day, be-

cause so few people were available.

In a "real" emergency, however, he would be called upon.to supply more than a dozen teams. Of course, many more vol-unteers.would drop everything and attempt to report for duty than during the exercise, but the fact. remains that they would probably be faced with nearly impenetrable traffic jams, not only on the roads cited, but also on such normally overloaded routes as 332 and 413.

b On willingness, . the thoughts of a friend of mine who is Director of.

i; ' Volunteers .at Germantown Hospital (itself within the 25-mile region) are

-significant. . She'.is an extraordinarily ethical person, an ecumenical Chris-7.>- tian, who tried to give an honest answer to the two-part question: What Lwould'be the response of volunteers to such a situation ao an emergency at l

l. - Limerick and what would be her own? She noted that volunteers who have family obligations generally do not come in when family needs supervene.

Other volunteers are' of ten older people, who tend not to come in during

< bad. weather. . " Thinking about myself, I know that' I wouldn't volunteer to L- ' help move contaminated people. That may be selfish or irrational, but I.

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' keep remembering-that I have children at home. If I didn't have them...

I:might... but I do. My first thoaght would be to get back to 'them (Bucks -1 County) and take care of them."

There is also a question of'the degree to which volunteers understand

the nature of a nuclear accident'and to which'they are protected by insur-

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ances this question bears'directly on the willingness of some volunteers to serve. Lack of radiological training, 'noted, elsewhere, suggests that people

. asked to enter,a contaminated area might do so without the benefit of.know-

--ledge equivalent to medical informed consent. As far as insurance is ~ con-tcorned, Pennsylvania' state law allows part-time employees and some categories E of. volunteers coverage under Workman's Compensation. The awards formula, l~ however . is pegged to a person's earnings, so that a young person with a f fire company, for example, who has not yet entered on his adult career, would receive compensation based only on his low earnings. Another law, 35 Pa CSA r

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_ INTERFACE: ' EPZ-SUPPORT Section 7706, is a provision for pure volunteers. Under this, the state would pay a small sum (42,500 for accidental injury le dinga to death; up to $1,500 for medical and hospital expenses; and weekly payments of 450 during disabilities arising from accidental injury). This law applies to those cases where. Workman's Compensation does not. Considering how small.this coverage is, taken together with the way in which the high population of the Limerick environs waters down any Price-Anderson awards, volunteers" are unlikely to be as willing to risk themselves in contaminated areas as they would be to face much more limited hazards in ordinary ezer-

.gencies. It therefore becomes an important question: When is a person (nurse,. bus driver, volunteer ambulance driver, etc.) removed from the pro-tection of e=ployee status? Attempts to explore this with several emergency units met with little success; they know as little about the coverage as I.

. 4. How is the evacuation of the EPZ affected by the 10- to 25-mile region

-under a plume?

The most serious failure in the plans for the 10-mile EPZ, at least from a technical standpoint, is the failure to provide appropriate con-

tingency pre-planning for the 10- to 25-mile region.

As already pointed out, the plans as they stand set up the potential tragedy of moving evacuees to " safety" in an area where they can come under a dangerously concentrated plume.

As already pointed out, also, the possible necessity of evacuating and abandoning facilities designated for care and back-up, both in Montgomery and in Bucks County, would destroy considerable parts of the existing plan

'i n practice, without an orderly substitution.

Furthermore. the~ commitment of Bucks County personnel to support of-the 10-mile evacuation-plan leaves no leeway for an effective, appropriate response if it should become necessary to start moving people from the 10 Eto 25-mile region of Montgomery, sus well as Bucks. Since that region downwind is the most heavily populated in the two counties, only a little less dense than that of the more northerly parts of Philadelphia, which also fall in the same region gan influx from there could triple the evacuees.

The -implications of all this for the people of the EPZ are that their escape routes'might quickly become jammed with an' enormous number of. cars from various parts of Philadelphia, fleeing in whatever direction"the-4 drivers might guess was. safe, along with much more' rationally impelled people from southeastern Montgomery County, attempting to get across the LDelaware bridges to northern New Jersey rather than risking Center City routes. In this scenario, parents returning to the EPZ for their children, emergency workers and volunteers, and emergency vehicles, as well as evacuees on- their way. out, could 'all be impeded by the lack of planning in 'the sur-rounding area.-

' Nothing in the long series of anecdotal reports which I have given

'would indicate that ad hoe planning is feasible. Indeed .like the weather

- of the 16 sectors, everyone talks about it, but no one does anything about it.-

. . ~ Reliance on ad hoc planning outside the EPZ would invalidate the plans

_ for:the EPZ, even if they were workable up to the (arbitrary) 10-mile border, which apparently they are not.

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emeraency .

involve the public in INTERFACE:: :EPZ-SUPPORT effect of failure to tion

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'5. What-hals been ~ of the Limerick Evacua In an t planning? lt in all aspects to include thef public from the beginning.(Sunday, for

- Perhaps the fundamental au of emergency. planning d Brinkley show yesterdaye neartotal thecommunity Union Carbi e planning;is.the failure A discussed the problem t

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interview;on the ha PavidDirector:McGraw Valley, especially thosy planning of themust EP inv the. people of the Kanaw be effective. ECI in October, 1983, was f

He stressed that emergenc plant. and effort.in. order to I was ,one of less than ,

It frightens me'that a plan produced byblic; six. month

-knowledge -

d Cross of it. months not available to the mypu county who had aicopy ssioners through the Rehad n a dozen people'in unity, from County Comm f ailable. occurred.

. protecting the comm bulance, and fire chie s, drafts are not do wn to local police,.am later. : To this 'date, thery for genuine planning u

. local-: input necessa .

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PAGE A3 Traffic M 3 0 anis .-

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9 are cloggmg , g Lower Bucks j O

Y t If you've lived, worked or visit.

I ed New York City, you linow the Q problem of trying to drive an auto- m

' g mobile crosstown during rush ' '

W hour or at any other tirre of the m day. It's almost an endicss traffic l

jam. $

If you've gone to New Orleans s

to be a part of Afardi Gras mad-

. y ,

J10 0 ness you know what h.nppens to r all the streets funneling into Can-al. It's an endless tra ffie jam.

If you're watching the Philadel- halberstein I l

e at eteran St diu e CourierTimes Columnist ,

same time there is a sellout rock concert at the neighbor ng Spec- ley Mall. Traffic problems that m trum, you know what aw. nits you. used to be minor irritants to driv-An endless trafficjam.

b.

ers now have reached the gritting L.

Welcome to Lower Bucks Coun. teeth stage. Yet to come- nail bi- ' -

ty, acvwhere in the vicinity of Ox- ters and blowing the stack.

ford ulley Afall. Langhorne Bor. In the Route 413 corridor from ough, Route I near I 9 > and proba. Langhorne to Newtown, construc-bly a few other aworted places. tion of r:ew homes is doing what The endless traffic jam has found the planners feared might happen us. and the state experts said

. Granted, it is the holiday sea- wouldn't. The two-lane highway is son and the shoppers are out in full beginning to look a lot like over- ,

force. In 1981, though. the shop- loaded. c pers have only exacerbated the There is no magical solution in n en problem. not eaused it. sight as traffic conditions grow For months prior to the Christ- worse, which they will. It is a Q mas rush that began with " Black time honored American tradition n O

Friday," the day after Thanksgiv- to permit a landowner pretty - c ing, scenes like these have been much to do what he or she wishes commonplace, when the right amount of money A driver on Route 213 in Sfid- turns up. That is: Sell.  ; o dlctown Township trying to get to Farmland in desirable Lower the traffic signal at Staple Avenue Bucks areas inexorably is giving 4 @

x 4 and Pine Streclin Langhorre Bor- way to homes and shopping cen- 4 g ters.

4 oughbumper may find himself as to bumper- fer back The state Department of Trans-as Reed. m i a q man's around 5 p.m.That's nearly portation will do what it can. So y g a mile. will the Lower Bucks municipall-On Route 413. also 'n 3 fiddle- ties. They'll give motorists a turn- m 4 m town Township. It is not unusual ing lane or two, a left turn signal .

for bumper to-bumper traffic to ortwo. 4 4 form all the way from the traffic Still, those of us who call tower , i signal at Bridgeton Pike to the - Bucks County home can say good. .

T Neshaminy JQnior liigh School. bye to the era of leisurely driving -

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e That's nearly a mile. from Route 13 to Route 1 or from At almost any point on Route 1, Aforrisville to Bensalem. I $

m 4 from Penndel to Oxford Valley The day of the horse and buggy y "<

4 Road, making a turn into and on narrow farm roads, the day of .

E away from traffic is getting to be the quick ride from Fairless Ilills i >

like Chinese checkers. to Bristol Borough, the day of the '

s  ?

What has happened? scenic Sunday drive to the Dela- 4 >

. The answer can be found in bne ware River and around - those

t. - word: Development. are all in the memory book of New businesses and the reloca- tomorrow.

tion of Delaware Valley llospital The traffic jam, that too mod.

have changed the landscape on ern, ever. growing unwanted phen-diiE Route lin the area of Oxford Val. - omenon,has found us.

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INTERFACE

EPZ-SUPPORT

2. Can evacuees from the EPZ be properly processed upon arrival at the Reception Centers?

4 The EPZ (Montgomery) plan directs evacuees to three reception centers in Bucks. Of these, two, County Line Plaza and Montgomery Mall (actually in r Montgomery County, but dispatching to Bucks mass care centers) lie well within a 20-mile radius from LGS. When frequencies of wind direction are plotted on'a -sector map, County Line Plaza is in a 5% region and Montgomery Mall.in the lWG sector (16 sector total). The two malls are, however, close enough that an accident with a moderately wide angle of dispersion could simultaneously affect both, making them unacceptable for further use as staging areas.

Mr. Jack Clemens, of County Line Mall, had signed a letter of agreement 7 for use of his mall in an emergency. He had been totally unaware that he would be receiving so-many evacuees, or that there was any possibility of radiological contamination of vehicles or persons. He was especially con-cerned that, upon arrival af ter quite a number of hours of preparation and driving, people would need various facilities which his store just does not have, especially toilets. He seemed to be a man of compassion and scruples, who would not, however, promise on paper something that he doubted he could fulfill in practice.

Mr. David Filippone, of Neshaminy Mall, had signed a similar letter,

. and was similarly startled when he discovered the nature of the commitment.

,, . Since then, _ the owners of the mall have elected not to participate in the ECI plan even tentatively, pending further study of its implications.

Although Neshaminy Mall is 35 miles from LGS, it lies just inside the

-10% sector, adjacent to the 16% wind frequency sector, and is therefore at much-greater risk of receiving-the tail of_a plume than if'it were located further north. Unfortunately, h1 that instance, the evacuees would be very likely to have come under the plume once or more during their travel on the L Turnpike, so that their arrival at the . reception center would constitute a major radicmedical emergency.

l _ _ Ambulance corps members from Bristol, Yardley, Trevose, Newtown, and Penndel tell me that they do not-carry monitoring equipment of their own, but generally rely on the fire companies for radiologicalLback-up.- The ECI plan calls for monitoring and decontamination to be done at the mass.

care centers to which people would be. dispatched essentially at random (only in the order of their arrival at the' reception center).1 The result is that, on -the one hand,- contaminated persons might be subjected to additional irradiation while finding and being processed at the mass care center,,and,

~on the other hand, ambulance personnel ~ called for the various medical emergencies.likely to occur at the mass care centers, would have inadequate monitoring of patients. A consequence of this could be the contamination of-an unnecessarily large number of ambulances, which would then have to be taken out.of service. Another consequence could be the contamination.of-

. various facilities in virtually every high school in Bucks County, whereac tonitoring at the reception.. centers could avoid that inconvenience.

Mr. Willard McKay, who is associated with both ambulance and fire

~ companies in the Erwinna area, tells me that the ECI prescription for monitoring would be'remon, if followed, to fail a student in radiological training, because .it does not instruct the team to cease monitoring and recording as soon:as an abnormal count is detected. At that point, the

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< INTERFACE: EPZ-SUPPORT patient is to be' stripped and scrubbed, in order that no further harm be done. In view of this medical policy, I find it unbelievable that, after

~ hours on the road, evacuees would be sent on for what may be another hour or more, in the direction of a mass care center, without being screened.

I was glad to see that, in their review of the July 25th drill (despite  !

some gross errors and misinterpretations on other points), FEEA noted the

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inadvisability. of doing the decontamination monitoring at the mass care centers, thus agreeing with many of us who had questioned this aspect of the:ECI proposals. No notice seems to have been taken of the criticism, however, for E0I's current " update" of the proffered (but not accepted)

Bucks County support plan makes not change whatsoever in the procedure.

(The date of_ transmittal of the " changes" is November 1, 1994.) This failure to read and respond to rational criticism so undermines the credi-bility of the Limerick plans to date, as written, that it is warranted to

- junk them and start over. The Emperor's new clothes can't be made adequate by reta11oring . them.

Depending upon the length of time individuals'have had to prepare and on the 1ength.of time they have been on the road, there might be substantial non-radiological medical armergencies arising at the reception centers, but there are no plans or proposed agreements for handling such emergencies

'under roof. Heart conditions, epilepsy, psychiatric emergencies, diabetes, labor, etc., might all intervene before people could receive and follow

-strip maps. Inclement. weather could compound discomfort and even loss of life.

The problem of safely reaching the mass care center is complicated by.the problems of traffic on Bucks County roads and the probable behavior of.the residents. This will be discussed in the.section dealing with the 25-mile radius and ad hoc plans. It must be stressed, however, that .in the

-best of conditions, the normal run from the reception centers to some of their corresponding mass care centers can take almost an hour. Under winter conditions, the perilous trip from Montgomery Mall to Bucks County Community-College might simply be impossible: I have watched students take-three hours to negotiate the exits from the college and successfully reach the top of_

the first hill on Swamp Road.

Furthermore, despite the various traffic Leheck points, strip maps issued to people unfamiliar with Levittown could

.be a source of confusion and delay. Even people born there get lost there.

The trip from Neshaminy Mall tocouncil Rock HS, 'Pennsbury HS,or Pennwood HS,

' sin the.midst of possible self-evacuation, is problematical. The effect upon anyone who had already been contaminated is an unconscionable added insult

'to the. body.

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5 4

- INTERFACE: EPZ-SUPPORT 4

3. Would housing, medical, and other services be adequate for the evacuees from the EPZ?

A considerable number of the mass care centers are located within or on the edge'of the 25-mile radius. These include schools in Warrington, Perkasie, Doylestown, Chalfont, and Warminster; they are slated to receive more than 7,000 evacuees. The possibility therefore arises that, if they were to arrive in good time, followed by a wind shift and the plume, all

< these evacuees would have to be re-evacuated at the same time that the emergency management authorities would have to devise ad, hoc measures to notify and move the Bucks County residents.

Roughly twice as many people would be assigned to mass care centers located beyond the 25-mile zone and as far away as 40 miles, unfortunately,

- the majority of these lie in the 10% and a few in the 16% wind frequency sectors, so that some problems of food handling and personal care could

'- possibly arise. At what point, if any, it would be necessary to move the centers, and what preccutions should be taken up to that point, I have been unable to discover from any official agency, including Mr. Charles McGill '

of. the Bucks County Emergency Management Agency and Mr. John Patten of the Pennsylvania Emergency Management Agency, with whom I discussed some of

these issues.at lunch a couple of months ago. Basically, the answer seemed

, to be that-they would figure out what to do when and if the time came, a

response which does meet the usual definition of planning.

On the theory that strong radiological training on the part of a con-siderable number of key Red Cross volunteers would help to shfeguard the health of evacuees for whatever time they h&d to remain in the Ingestion Zone,' I asked Mr. Bill Reardon of the Lower Bucks County Red Cross what background his workers.had. Last summer he said that several of his work-era had' already had radiological training and that he had hoped that more would receive it, but that it was very difficult to'get people to take the courses. They are able to get,perhaps three or four people at a time to sign up for them. (At that-time, Mr. Reardon had not yet received a copy 7

of the ECI plan.) ,

_ More recently, Mr. Reardon has chored up a question which had-troubled me: how would the Red Cross supply cots, blankets, and other materials'from its warehouse in Philadelphia, across the probable traffic block at City

' Line? He admitted that the maneuver would probably be impossible,'and that materials would have to be airlifted in from.other points, probably taking about 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This assessment, although realistic, raises'the question of the health and comfort of evacuees, especially any that had had to under- '

. go decontamination.

The ability of the-schools themselves to make way for evacuees during the, school year is ques'tionable. InLaccordance with a requirement by the Intermediate Unit,-~every school has a general emergency plan covering vari-ous eventualities. Dr. . John Byrne, Superintendent of Council Rock Schools, .

has told me that"the school plan is by no means .the PECO plan." In the event of snow or an emergency which would prevent parents from being at home to -receive their children, the school policy is to keep the children,

including those in

senior high school, at the school. Dr. Byrne's feeling was that an accident at-Limerick would result-in a situation in which it

~

U would take many hours for parents to return home, and many more hours before students could be discharged af ter verification by telephone. It is very

'likely that his-schools, four of which are scheduled to accept-1,175

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6 t

INTERFACE: EPZ-SUPPORT evacuees, would .give priority to housing and feeding an unknown, but possibly substantial, number of students. He did not have, and had never seen the ,ECI plan. He also offered the unsolicited opinion that no evacu-ation plan'would work. Assistant Snperintendent Hoffmann of Neshaminy told me- that his schools would respond in an emergency, but also with the speci-fic plans worked out for each district to deal with all emergencies these might run. counter to PECO's plans, but they would hold the students at school, regardless of whether the space was needed for mass care centers.

Mr. Dick- Knippel. .of the Intermediate Unit, verified that the plans in place at the school districts are their emergency plans for care of their students. He was somewhat skeptical about the efficacy of any evacuation

- plans ("I was at a school conference in Harrisburg at the TMI of TMI and drove home along the Turnpike, looking over my shoulder for the plume.")

Although Mr. Knippel did not rule out the possibility of the schools' l . accepting evacuees, he was not in a position to discuss the specifics,

-because he had not received the plan.

The feeding of evacuees depends upon a number of factors. In the sum-mer time, reliance would have to be on stored canned goods. In the winter, I more fresh foods would be on hand in addition to the canned, but a consid-erable number of school' children might have to be fed for several meals.

I am told' by Mr. Bernard Hoffmann of the Neshaminy School District and by

Mr. Reardon that there are local depositories of food for the schools which would'auffice fer at least a week. At the Pennsbury School District, I ran into the fact that some of the food service people would probably be em-

-

ployed to prepare food for the evacuees, under some arrangement with the Red. Cross, according to Mr. Gawrilak, who is in charge of the food service there. Mindful of the possible question of,special' precautions if the i

' Pennsbury area should become part of the plume Ingestion Zone, I inquired whether anyone on their staff had had radiological training or would know how to safeguard food in those circumstances. Obviously the question had

- never occurred to him, and neither he nor his staff was prepared to deal 7, with it.

At Bucks County Community College, Mr. Martin Beeman, an . independent concessionaire, was utterly amar.ed when-I inquired about feeding 3190. people on an emergency basis. Although there would not be a short-term problem, he had never heard of the plan and had never been contacted about his capacity 1or willingness to serve. A much more serious problem concerns the sleeping u facilities there.. The figure of 1100 seems to have been predicated on the

- seating capacity of the gymnasium. - As President Rollins- explained to 'me,

~

"Some : people ;came round about a year ago and asked how many people the gym could hold; I told them eleven hundred."-

- -Although some schools have-two gymnasiums as well as large ecfeterias,.

1some of.the mass ' care capacity figures on the ECI list look suspiciously high.: As notedJelsewhere,'one' mass care center no longer exists: Delhaas High School, which was sold and converted into offices. I tried to check any possible new assignment by calling the fire company originally assigned there for decontamination. The man .on duty, Gearhart, knew nothing about any emergency assignment. "The Chief might have a list in his desk drawer."

- When would the chief be back?" I asked. "Maybe tomorrow... hard to say..."

It would be better if I called the Bristol Township Fire Marshal. It turns out' that .the Fire Marshal lives in New Jersey "the other side of the bridge','

i.

4

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I 7

h INTERFACE: EPZ-SUPPORT Bristol Township Third Fire Distict's lack of knowledge regarding emergency plans is typical of organizations throughout the county. ECI had guarded the ' proposed support plan as if it were an industrial secret, with the result that no input-- and certainly no adverse criticism--

could take place Criticism would raise the fundamental question of whether the emergency services in Bucks County could possibly undertake the functions laid out by EC I. - Both fire and ambulance units are already understaffed, so that some find it difficult to arrange for one fully operative day-time unit, and units are constantly called upon to cover for other companies.

The Levittown-Fairless Hills Rescue Saumd, for example, has some 50 to 60 members- on record, but has to maintain 2 paid crews, 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> a day 5 days a week,~with a part-time crew at another station. Most of the members work.

They.are, however, able to muster 20 people during the day, plus the 7 paid workers. Most of their men have had the few hours of radiological training which is-included in the Basic ENT; otherwise, some 20 paramedics have had

'somewhat more. They have no dosimeters nor any other specific radiological equipment. ~ Asked what would happen if one of their ambulances picked up an apparent- medical: case who was also contaminated, my respondent, Mr. Bernie Powers,.said the vehicle would have to go out of service. He further.com-mented that :there is no ' county-wide utilization of squads, no one directing them in covering for one another; no division of_ territory, and no cohesion.

• How well would the plan work, he was asked. Answer: "It wouldn't!"

The Morrisville Ambulance Company, at,the tiae of my call in August,

said that their disaster plan was just a general response; they do not have i, a real blanket _ plan. As far as she knows, no one had ever.seen or been

. approached about the ECI plan .(whidi -I identified as .the " Bucks County plan, cetc., -reading from.the_ title sheet). The' only training she was aware of

among the personnel was the regular 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or so< given with the Emergency i s. Medical > Technician training. When-I inquired what procedure they.would c follow if(a patient might be contaminated, she said they .would

call _ the EPA 1-

. The unit haslno dosimeters; she knew of no procedure' for getting them. She

. backed down a bit L on calling the EPA, .and said that in an emergency they ji would havefto be guided by the patient's physical condition only. The only

/ .

type of class given- for disaster training, she said, was not geared to that b high a' level.

l' The : Newtown ' Ambulance- Saund numbers about 50 people, of whom 35 to 40 ,

l _

- are active; of those one or- two are also in the fire company. Between 20%

-and!40% of members work within a 10 mile radius of the station; about 90%

/ work.in the county. :Mr. Robert Anderson, with'whon'I spoke, confirmed that, L ,

asLwith the other squads, there were no dosimeters or other equipment for monitoring radiation.-2His opinion was that-he and other' members were not l.

.too:well prepared for a radiological emergency; he had seen no copy of the

/ plan.' ,

b The' Bucks County Rescue-Sausd, with fully paid day and midnight shifts

~

, _during the week, has only 25 to 30 volunteers to cover on evenings _and

! ' weekends, according to Chief Michael'Plebani. They have.3 Basic and 2_Ad-

, .vanced Life Support units,' and 1 Mobile Hospital Unit, which can be used - as

.an operating room or can carry 4-to 5 stretchers. Neither the paid person-nol'nor the-volunteers have had radiological training; for some reason, he  ;

said, . it does _ not drew' interest. 'No dosimeters or other radiological -

[ 9_

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- 8 L -

INTERFACE: EPZ-SUPPORT -

1:

' equipment. No knowledge of plan except a small ites in the newspaper.

• At the Penndel-Middletown Emergency Squad, Mr. J. R. Douthart and Deputy Chief Dennis Mitchell brought up an interesting point: that there

- are often several duplications of people serving in two emergency capacities at ~ once: fire and police, cns ambulance and fire, for example. Their squad has some 7 or 8 such cross-overs. [I have found this situation in several

. other instances; it may be more serious than appears from the numbers, because the people who double up that way seem to be better trained, more dedicated to service', and are leaders in the groupa. An emergency that would require

, mobilisation of both groups for a long period of time, during which the vol-

[

unteer would have to remain constantly with one of them could result in de-

. creased effectiveness of the other group.] Both men were unhappy about the

. current state of preparedness. "No one is really trained," said Mr. Douthart.

" We need a genuine drill." That, despite (or perhaps because) of the fact

_ that some 6 or 8 of their volunteers have had radiological training at the Bucks County Fire Schools this statement may apply to cross-over members of  !

i. the fire company who also serve with the ambulances.-

• Since each squad is expected to go out of its own area only on request to cover for another squr.d, Deputy Chief Mitchell was somewhat disturbed by

[ the possibility that he would be called directly to Neshaminy Mall if there L

were emergencies among arriving evacuees. "Neshaminy Mall is not my job, man. -

p I - would have to rely on other companies, bring in Yardley, Morrisville, to cover for me." I asked what would happen if they were unavailable because L of" covering for other units already dispatched to the reception centers or to accidents. "I'd have to call in some of the New Jersey units," he answered. .

Further discussion elicited the fact that cooperation across the river is .

fairly common; the problem, of course, would be whether the ambulances could buck the tide of eastbound trucks and evacuees. I inquired about procedures if they -had to pick up a radioactively contaminated patient. He replied that the personnel would use " sterile gloves, masks, and gowns; af terward a good

• vacuuming inside the . vehicle, with the geiger counter to make a sweep of.the inside afterward." As far as the plan was concerned, he had no knowledge of what would be expected. "I don't think we are adequately prepared. There are several. people in both fire and ambulance who were or are qualified-- but R ' there's no drill._ If it came down, we'd do it, but haphazardly."-

I ^

It was Mr._ John R. Douthart who advised me when an accident should be scheduled: "It would be better after 6:00 P.M. , best on Saturday I - between 5 amd 6 o' clock. Monday afternoon would be the worst time-- and of j

course it's bad during . working hours every day. Also late July and August are not so good." He went on to say that a majority of their volunteers r

work in-the county, many fairly close by, so that the number stuck in traffic L would not be particularly high.

t Chief Panini of the Bensalem Rescue Sound was well informed on chemical emergencies, and briefed me at length about his concerns with transport of both chemical and: radioactive waste. He used"to be fire-chief; the fire com-pany.had a lot of equipment then,1but the ambulance personnel would have-to treat a-patient on the basis of his apparent condition. He had followed the July 25th drill, and was not favorable toward Montgomery County's perform-L ance.: He was well aware of the possibility of a plume extending downwind into Bucks, and commented: "There aren't too many in the lower end (of the ,

county 31that are' equipped-to deal with that' situation."

t

4 9

4 L INTERFACE: EPZ-S UPPORT Unfortunately, I have lost my notes from an interview with a man who is from-the Trevose Heights Rescue Souad, located near the Turnpike -

U.S. 1. Interchange, He has had long experience as a fire chief, and more r

advanced radiological training in the military. Discussing the main out-lines of the - ECI . plan, which he had not seen, but had read about, he castigated the idea of evacuating people by the Turnpike. "Any fool knows you don't stand downwind from a burning building!" Even without notes, I recall his words.

I The Newtown Fire Company informs me that their only method of notifi-cation, in the event of our being downwind after an accident, would be to

-blow the air raid siren signal at the firehouse: "Many people would think

-the fire whistle was stuck-- if they could hear the sirens at all."

-I asked about the procedure that had been suggested by Karl Abraham, of the Valley Forge NRC Office, for notification outside the EPZ: "Ask your

- police or fire department to notify you by telephone." That is clearly

• not possible, said the man at the desk at the fire department. He went on to say that he was not familiar with the emergency plan-- either.the

. local Township plan or the ECI plan; he was not aware of training or any l  ; radiological equipment. Not being sure that he had all the information,

.I called back this morning, and was told that no one would be in until evening; fire calls are taken by the emergency number.

The Lower Makefield Township Civil Defense office responded to their

-phone in the township building. The Township clerk asked, "Would you hold  :

while I look.this up." She then advised me to call the Bucks County EUA nun.ber in Doylestown. I told her that Mr. McGill, if I inquired there, would refer me back to her. She does not know of any standard operating emergency procedure.

=Because my own Newtown Township has a supposedly functioning emergency

. committee, I called Chief Adam Duffy, and received a taped message te call the county-wide police emergency number if necessary. Somewhat'later, I-called his number again and got our dispatcher, Shirley Milnor. When I explained my concern, her response.was: ' "That's terrible. If there is a-L plan, IL don't know about' it." (Chief Duffy is with the police department.)

It is true that I live somewhat outside the 25-mile radius, approxi- :

( ",

mate y 32. miles from LGS. I am not morbidly affaid of radiation. having I-rays when necessary,' and a radioactive thallium test a while ago. _Q THERE

IS A..7-DAY 200-REM GROUND DOSE IN THE .NEIT TOWNSHIP OVER,' HOWEVER, ^I DON'T WANT TO STAY AROUND FOR. A WEEK TO ABSORB ( AND INGEST BY ACCIDENT) WHATEVER MAY DRIFT MY-WAY. My efforts- to find out what procedures would be taken for the- protection of my friends and fellow citizens closer to the plant, gi as well as my friends, . neighbors, and myself in this area, simply confirm D ,,g imy suspicion that there are no present workable plans, and that the plans M developed by ECI for PECO are worse than unworkable: on the face of'them,

.they were never even intended to be workable. Almost complete lack of knowl edge'about radiation, part-time employees, plans non-existent ~or locked away i in a file cabinet, back roads, and- the magic incantation, AD HOC by the

- state, county, and federal planning ' agencies do not forecast a rational, l' orderly response to an event that, if it ever occurs, will make everyone p wish:theyhadplanned.}

- - - - - - . - - , . -v- ,-

, 10 4 ,

INTERFACE: E PZ-SUPPORT A necessary central resource in an evacuation is the hospital system.

-Precant.results of changes in medical logistics have resulted in a greater

, availability of beds in some hospitals than a few years past. On the other

. hand,fa greater number of patients discharged immediately after elective i surgery to the care of their families might respond adversely to an evacu-ation, so that they would constitute an additional load on the support facil-ities,. including outpatient services. I have seen no provision in the plans 4

for evacuation of a fairly considerable number of large hospitals in the 10-_to_25-mile area. In fact, Abington Hospital, which is on the edge of that region, is one of the " support" hospitals for the EPZ. Plume travel

_along one of-the most likely paths could require relatively rapid evacua-tion of that facility and abandonment of its support function in the EPZ plan.

As far as the ECI Bucks County hospital support interface is concerned, a: page of hospitals with supposed bed capacity and radiological capability has been supplied by ECI. .

A check of the listed facilities revealed that the capacity (number

'of beds)' listed applied to the total number of beds in the hospitals; most

~ of them are, of course, in use at any one time. The implication in the list is that the number of beds listed would be available for " Treatment of Contaminated Individuals"-- a manifestly ridiculous statement when one

. takes'.a second look. The relevant information, number of beds available

- for . treatment of contaminated individuals, is omitted.

Furthermore, the figures given are incorrect with regard to the primary

- care facility, Lower Bucks County Hospital. Mr. Janssen, Assistant Admin-istrator, was puzzled. "Even the number of beds (323) is alien to me.

> Currently we have 290 beds. We never had 323. In an emergency situation, we could_probably make.a. total _of 175 beds available by discharging elective patients, adding. beds in extra spaces, etc. Under a real push, perhaps a -

bit more.- -

.To some extent, the hospital staffs face the same dilemma as the bus drivers and the teachers: that'they would wish to take their own families to safety firsts such "self-evacuation"'would be hampered by traffic con-i ditions, and-even though some of them express a willingness to return to

- their' assigned duties, they. question their ability to get there. In the r_ course of teaching,EI have used this question on occasion as an illustra-tion of ethical problems, and since a number of my students are nurses or b . in nurses' training,-' the discussions have been illuminating. . Those who -

^

have families and young women of child-bearing. age, working at Abinston.

Warminster, Holy Redeemer, Lower Bucks, and other hospitals, were unanimous in giving first thoughtoto their families. One or two said.they;would stay at their posts if. they could verify that another_ family member had L. Ltaken children to safety several said they would finish a shif t if Lthere -

__ w ore a short time left-on it;-others said they'would not report for duty.

<- .-if they-were home.

'This reaction is-at first surprising. But when a young unmarried bus.

- driver-in our local school district told'me that he'would go home-for_his

. parents and leave,.and when I'1 earned that'some' National Guard members on

. active duty had discussed whether to_ evacuate'their families before under-

.taking.their other duties, it is clear that the same' assumptions cannot be:

made about:an accident at' LGS'as about a flood, hurricane,-etc. After Bhopal,'it would be difficult to. predict the behavior of emergency

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