ML20234A752

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Rept to Selectmen on Plymouth Radiological Emergency Response Plan
ML20234A752
Person / Time
Site: Pilgrim
Issue date: 03/31/1987
From:
PLYMOUTH, MA
To:
Shared Package
ML20234A759 List:
References
CON-#189-8144 2.206, NUDOCS 8705060356
Download: ML20234A752 (11)
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{{#Wiki_filter:1 ( l TOWN OF PLYMOUTH COMMITTEE ON NUCLEAR MATTERS REPORT TO THE SELECTMEN ON THE PLYM0UTH RADIOLOGICAL EMERGENCY RESPONSE PLAN 1 I March, 1987 

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         ,THE COMMITTEE ON NUCLEAR MATTERS i

MEMBERS: Grace M. Healy, Chair Charles W. Adey, Vice-Chair i Ann Waitkus Arnold Theodore L. Bosen Marie P. Fehlow Kenneth T. Holmes Kathleen M. Leslie Anthony V. Lonardo John P. Rooney James W. Ryan f Howard E. Shetterly l I ( SUBCOMMITTEE MEMBERS: l Ann Waitkus Arnold l Kenneth T. Up1mes 1

TOWN OF PLYMOUTH THE RADIOLOGICAL EMERGENCY RESPONSE PLAN INTRODUCTION-As one of its tasks, the Cor.mittee on Nuclear Matters assumed respon-sibility for a review of the Plymouth Radiological Emergency Response Plan (RERP). The following is the result of research undertaken by the sub-committee, and of the deliberations of the entire committee. In order to determine Plan adequacy and feasibility, information was sought from many sources. Subcommittee members reviewed written materials: other Emergency Response Plans (ERP); Federal Emergency Management Agency (FEMA) Regulations; reports on the adequacy of various RERP's; testimony of public interest groups, and one available s ect ion of Secretary Barry's report. Subcommittee members also contacted, in person and by telephone, representatives from: (1) Local, Regional and State Civil Defense Offices, (2) FEMA, (3) various Town Offices; (4) State Office of Handicapped Affairs; and (5) Boston Edison.

SUMMARY

CONCLUSIONS AND RECOMMENDATIONS deficiencies in the Plymouth RERP. Moreover, these There are deficiencies are serious enough, in the Committee's judgment, to preclude 

    "... reasonable assurance that adequate protective measures can and will be taken (by the Town and State) in the event of a Radiological Emergency."

There is reason to believe that as things stand now, the Selectmen cannot fulfill their legal responsibility, particuhrly during a Radiological ' Emergency, ".... to provide for the health and safety of persons and their property ...." The Plymouth RERP is a " paper" plan, essentially untested relative to mobilization of some of the essential personnel. As long as it is untested, difficult questions can remain unanswered and difficult decirrions can be avoided . This is a situation unacceptable to the members of the committee. Thus, we respectfully urge Selectmen to assign tasks and timelines to appropriate personnel and/or offices to ensure accomplishment of the following: A. Comprehensive revision of the Plymouth RERP.

1. Correction of outdated information.
2. Elimination of specific deficiencies noted below.
3. Complete specification of implementation procedures.
4. Specification of procedures for ongoing updating and ,

coordination with lo al, area, and state plans. B. Appointment of a full-time Civil Defense Director, with staff as needed, with adequate interim headquarters, and with long-term plans for location in one of the new Town buildings. C. Development c! funds for emergency preparedness from federal._ state and utility sources. Appointment of liaison for same.) l

D. Full Town participation in a. comprehensive drill prior to Pilgris's coming back on-line. (While actual citizen evacuation may not be feasible, full participation must at least include all responsible personnel being in-place and carrying out assigned tasks.) Coordination of agencies, their services and lines of responsibility - local, state, federal levels must be tested. , i The Committee further recommends that eli deficiencies be remedied and all recommendations be implemented prior to reactor start-up. There was one dissenting opinion expressed concerning the above. The objection relates to making total task accomplishment a condition for reactor start-up when longer time may be required for some tasks. The dissenting opinion does not represent disagreement on deficiencies or recommendations, but on timelines. In all cases there is agreement on need and urgency for action. ' i i SPECIFIC DEFICIENCIES AND RECOMMENDATIONS Following are specific deficiencies found by the Committee on Nuclear Matters and some - commended corrective measures; they have been grouped in eight categories: (a) Advance Information, (B) Notification and Communication Systems, (C) Evacuation Routes, (D) Evacuation Time Estimates, (E) Transport of Dependent Populations. (F) Reception Ctaters and Public Shc1ters, (G) l' Medical Facilities, and (H) Radioprotective Drugs. A. ADVANCE INFORMATION DEFICIENCIES:

1. Inadequate public information in Emergency Preparedness Zone (EPZ).
2. Lack of multi-lingual inf o rmat ion (Italian, Portuguese, Spanish, Japanese).

l 3. Inadequate dis t ribution of Emergency Preparedness Info rmation (EPI) brochures. l l 4. No information for people without access to transportation.

5. No information about staging areas (pick-up points).
6. Tourist and transient information inadequate or non-existent.
7. No educational effort outside the Town of Plymouth.

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ADVANCE INFORMATION (Continued) REC 0 EMENDATIONS:

1. Implement a comprehensive, ongoing public educational program through news ads, cable TV programs, radio: public service announcements , and informational packets included in utility bills. Include an outreach.

program for non-English speaking people in these activities. (multi-lingual), with ' maps

2. Develop emergency info rmation posters explaining:
                                               - Location of Public Transportation
           - Protective Actions
           - Evacuation Routes                 - Local Radio Station of EBS
           - Location of Public Shelters       - Staging Area Locations.
3. Post Emergency Information Posters in public locations:

Hotels, motels, restaurants, gas stations, phone . booths, recreation facilities, tourist sites, informational centers, theaters, airports, bus stations,. trolley cars, and all public buildings.

4. Develop survey to identify special populations:
a. Non-English speaking people.
b. Transport dependent groups:
                  -.15% of Plymouth households have no car;
                  - 50% of households have one car, but one half of workers have jobs outside of Plymouth.
c. Special needs people: -
                   - Federal regulations require notification - of . "all segments - of society."
                   - Deaf and hard-of-hearing people must be identified. beforehand so they can be alerted by appropriate means.
5. Distribute updated pamphlets semi-annually to:
             - General public and all recommended locations in #3 above.
             - Multi-lingual pamphlets should be available in the same places.~

l 1 l i I l 3 1 i I

B. NOTIFICATION AND C9MMUNICATION SYSTEMS DEFICIENCIES:

1. Siren System  !
a. The siren system is not' equipped to confirm that all sirens have-been sounded during an exercise. There are no provirions ' for determining which sirens are not working.

Present siren system does not warn hearing-impaired' persons. No b. alternate plan exists to notify this segment of the population.

2. Radio Communications
a. Departm, t of Public Works radio equipment used for Civil Defense is unreliable and inadequate.
b. Present system for notifying local officials is unreliable.
c. Plymouth County radio network (Sheriff's) is- inadequate /

inef f icient . RECOMMENDATIONS: ALL PROCEDURES FOR NOTIFICATION OF AN ACCIDENT AT PILGRIM I SHOULD BE REVIEWED. )

1. Investigate the "hard-wire" system or other alternatives that confirm ,

siren activation. Alert officials who will dispatch personnel to areas  ! with defective sirens to activate sirens manually and to warn public from vehicles and loudspeakers. i

2. Develop procedures to confirm activation of every siren. Specify numbers of vehicles and personnel required for-#1 above.
3. Test sirens weekly on the same day and at the same time.
4. Identify hearing inpaired people and install-telecommunication devices.
5. Provide closed captioning for the Emergency Broadcasting System. 3
6. Install tone alert radios in every school bus, transport vehicle, and l' l other vehicle specially licensed to transport childrun,-the elderly,-and handicapped persons in the Emergency Preparedness Zone.
7. Upgrade Plymouth County Radio network hardware. Test the hardware on-a l l

regular basis. l 1 l l 4 1 __d ____.___m. _ _ _ _ _ _ . - . _ _ _ - _ _ - _ _ _ - _ _ _ _

C. EVACUATION ROUTE 2 - LIMITED ACCESS AND' EGRE!!S DEFICIENCIES:

1. Proposed routes (Routes 3 and 44) are completely ' inadequate . for effective handling of anticipated volume of traffic. Traffic is already jammed due to the heavy volume of tourists in the suumer months , and during heavy winter storms, or when roads are under construction or '

repair.

2. Voluntary evacuation (Evacuation Shadow Phenomenon) is not taken into.

account. RECOMMENDATIONS: The following are not remedial; they simply address wcirsening of the problem.

1. New development along evacuation routes should require ' an impact study The by developers with specifications set by appropriate Town Offices.

study should be reviewed by the Planning Committee.

2. Prior to approval of road construction / repair (along evacuation routes) the appropriate Town Of fice must make an impact assessment and develop alternative routes.

D. EVACUATION TIME ESTIMATES DEFICIENCIES:

1. Present time estimates are based on outdated information and have major .j flaws.
2. Evacuation Time Estimates (ETE) is baced on several questionable assumptions:
a. It assumes .nere will be no mass voluntary evacuation _ not in plann a'. coundaries (shadow-phenomenon) as occurred at Three Mile Iaiand, which could cause major route blockage and back-ups.
b. It assumes that emergency personnel vill remain in place and not evacuate with their families,
c. It assumes that communities outside the Ten Mile E2Z have developed adequate plans- to augment evacuation and sheltering efforts, although Massachusetts Civil Defense Agency (MCDA)' states no such plan exists.
d. It assumes the timely presence of State Police and National Cuard.
3. Large discrepancies exist between Boston Edison and the Nuclear Regulatory Commission (NRC) ETE's.

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l l e l EVACUATION TIME ESTIMATES (Continued) . i

4. Panic' and traffic' disorder have not been adequately considered: 1
a. Blocking of cross streets
b. Disregard of traffic signals
c. Driving in left hand lane
d. Abandoned vehicles
e. Driver confusion -
f. Failure of traffic control <

Accidents

g.  !
               ' These considerations plus inef fective traf fic control could result in more than a 50% . reduction in traffic flow, which would ' mean the evacuation time could be more than doubled.,

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5. No ' adequate estimates for time required to evacuate non-car-owning people dependent on public transport.

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6. Estimates of the number of vehicles at public beaches is inadequate.
7. Estimates required by federal regulations are lacking. l
a. Separate times for adverse weather - fog, rain, flooding , snow, i storms. -{
b. Day versus night, workday versus weekend, peak transient versus non-peak trans.ient, and evacuation versus non-evacuat ion in adjacent sectors.
c. Separate estimates for "special population ' groups"_ on an l
                 " institution by institution" basin      (e.g.,  schools, hospitals, nursing homes, correctional facilities) i RECOMMENDATIONS:

i

1. The new Boston Edison Company (BECo) ETE's mu'st:-
a. be based on realistic assumptions,
b. include all specific time estimates required by FEMA,
c. take into account mass voluntary evacuation consequences,
d. address previously stated shortcomings;
2. The new ETE must be completed prior to plant operstion.
3. Documentation should be provided by BECo to assure the ETE's provide a workable means to evacuate all residents of the EPZ based on a wide range of accident scenarios.

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 .A.

E. PLANS TO TRANSPORT DEPENDENT POPULATION .I (People without , access to cars, school children and children .in day cars, hospital and nursing ' home residents, handicapped persons , -. campers , persons in correctional institutions.)  ; i DEFICIENCIES:

1. . Numbers of vehicles needed and sources for them have not been analyzed..

I

2. No contracts or letters of agreement have been. signed with MBTA, bus
             . companies, drivers, ambulance companies, and other . entities . providing                                                                  ;

public transportation and personnel support for the plan.- j There are no particular plans for evacuating handicapped people. This  !

3. J segment'of the population,has not_even been identified.

4 Plans call for ' individuals to . make arrangements with Iccal CD for transportation. Local CD will then contact MCDA Area II for assistance; however, the Area II plan does not contain information on how to procure-additional transportation.

5. Schools - There are no separate plans or procedures for each school and i day care center. Bus companies and drivers have not signed agreements to perform during an evacuation. The ' school plan lacks detailed pro-cedures.. Estimated time to mobilize National Guard for schools is three hours, and Guardsmen may not be familiar with road network.

1 RECOMMENDATIONS:

1. Conduct a survey to determine transportation needs of all people -l l

dependent on public transportation- in all sectors of EPZ. Provide i specific and separate information for summer /non-summer, weekday / weekend populations.

2. Document available resources and resource needs, such as transportation contractors, trained personnel, drivers trained in emergency response procedures, speci2) care personnel and equipment for disabled persons.
3. Obtain written agreements with transportation contractors and drivers.

Develop specific, adequate plans to evacuate each dependent group, such  :

4. '

as the population in nursing homes, hospitals, . schools, et,mp s , residential homes, correctional institutions, day care centers. .

5. Provide for special needs population -

physically and mentally handicapped people:

a. Provide notification in advance of special evacuation procedures for disabled people;
b. Plan for delivery of necessary services during an emergency with trained assistance for each handicapped -person designated beforehand;
c. Provide beepers, backup personnel for vacation times, special equipment and medications.

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1 i l' i F. RECEPTION CENTERS AND SHELTERS  ; 

                                                                                    .\
     .Bridgewater State College and Taunton State Hospital)

DEFICIENCIES: 1

1. There are no clearly defined functions for the reception centers and shelters, i
2. There are no letters of agreement, or contracts with reception centers. j (Who provides what and who pays?)  ;
3. There - are no adequate plans, equipment, supplies or personnel to implement purposes for reception centers. (Such as contamination-monitering, decontamination, congregate care, ...)
4. Public shelter locations are not identified.
5. Adequate plans for public shelters are non-existent (personnel, I supplies, etc.)

1

6. Resettlement and/or reentry plans have not been fo'mulated.

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7. The option of shelt ering in private homes versus evacuation is not addressed. ,

i I RECOMMENDATION': S i

1. Define specific and separate functions for public shelters and reception centers.
2. Specify conditions for which sheltering in private homes might be preferable to evacuation.
3. Conduct survey of potential shelters adequate to accommodate peak summer populations.
4. Identify and contract for an adequate number of reception centers and public shelters to accommodate EPZ population.  ;
5. Provide adequate plans for equipment, supplies and personnel for centers and shelters. i 8

l G. EDICAL FACILITIES DEFICIENCIES:

1. There are inadequate plaar for treating large numbers of victims of radiation exposure.
2. The two hospitals listed in the Plan (Jordan and St. Luke's) can treat only a limited number of people with radioactive contamination.

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3. One hospital is within the EPZ and could be simultaneously receiving and I evacuating patients.

RECOMMENDATIONS:

1. Clearly determine response capacity of Jordan and St. Luke's Hospitals. l l

l 2. Identify all possible referral hospitals outside EPZ.

3. Document capacity, types of care and provisions available at referral  !

hospitals outside EPZ.

4. Obtain signed agreements with referral hospitals.

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5. Develop procedures for transportation of patients outside the EPZ. .

I H. RADIOPEOTECTIVE DRUGS PRESENT POLICY: The Massachusetts Department of Public Health does not advise distribu- l tion to the general public of Potassium Iodide (KI) as a radioprot ective drug. RECOMMENDATION: That the Department of Public Health provide for the distribution of Potassium Iodide or a proven alternative to the general Plymouth population prior to reactor start-up. In conclusion, the Committee notes, once again, that the deficiencies identified berein and the recommendations made relative to the Plymouth RERP are by no means exhaustive or all-inclusive. Those listed are, however, serious enough that, were they not to be addressed, the selectmen might be unable to "... provide for the health and safety of persons and their property ..." during a radiological emergency. Hence, the Committee respect-fully urges the Selectmen to give immediate attention to the matters con-tained in this report. Even after the current revision of the RERP and the implementation of recommendations, regular monitoring by the Town will be needed so that improvements in the plan may be made as they become necessary. 9}}

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