ML20235M887

Commonwealth of Ma Testimony of G Daines on Inadequacies of Seabrook Plan for Commonwealth of Ma Communities Re Special Populations in Epz.*

ML20235M887
Person / Time
Site:	Seabrook
Issue date:	02/21/1989
From:	Daines G HAZARD MANAGEMENT GROUP, MASSACHUSETTS, COMMONWEALTH OF, PINELLAS COUNTY, FL
To:
Shared Package
ML20235K640	List: ML20235K637 ML20235K717 ML20235M764 ML20235M805 ML20235M819 ML20235M827 ML20235M834 ML20235M848 ML20235M855 ML20235M887 ML20235M893 ML20235M906 ML20235M956 ML20235M984
References
OL, NUDOCS 8902280479
Download: ML20235M887 (15)

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l UNITED STATES OF AMERICA

_ ' NUCLEAR REGULATORY COMMISSION I ATOMIC SAFETY AND LICENSING BOARD.

Before the Administrative Judges:

Ivan W. Smith, Chairman Dr. Richard F. Cole Kenneth A. McCollom

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In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)

OF.NEW HAMPSHIRE, EI AL. )

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(Seabrook Station, Units 1 and 2) ) February 21, 1989

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COMMONWEALTH OF MASSACHUSETTS TESTIMONY OF GUY DAINES ON THE INADEQUACIES OF THE SPMC AS IT PERTAINS TO SPECIAL POPULATIONS IN THE EMERGENCY PLANNING ZONE i

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8902280479 890221 PDR ADOCK 05000443 T PDR , )

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.s Q. Please " state.your name, position, and business address.

A. My name is Guy Daines, I am director of' civil emergency services for Pinellas County, Florida. .The address is 400

, South Fort Harrison Avenue, Clearwater, Florida 34616. I am also a director for Hazard Management' Group, a consulting firm located at 2308 Carrick Court, Tallahassee, Florida.

Q. In brief, what will your testimony be about?

A. I will testify as an expert witness on the inadequacies of the SPMC as they pertain to the.Special Needs Population in the EPZ. I will specifically address inadequacies of the SPMC as they are raised regarding JI Contentions 46, 48, 49, 50, and 51.

I will testify that I disagree with the FEMA findings of adequacy on evaluation criteria that pertain to the Special Needs Population. I will testify that the lack of procedures will result in a communications and resource i

overload and that planning must be engaged in to deal with that eventuality. I will testify that the Plan does not provide for the staffing and resources that will be necessary to support and assist the Special Needs Population in the event of an evacuation from the Massachusetts EPZ. l i

Q. Can you please state briefly your professional experience i and credentials.

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4' A. 'At the present time I am Director'of Civil Emergency Services for Pinellas County Florida, and I have been in

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that position since March, 1987. .In that capacity, I am responsible for all 911 and dispatching services for a county of approximately 830,000 people. I am responsible for the emergency management function which is a division within my department and also I am responsible for all emergency medical services within the county.

Prior to that, I was the Director of Emergency Management

-for Pinellas County. I was in that position from May of 1979 until February of 1987. In that. capacity, I was responsible for all emergency planning for the county to include the preparation, the response, and the recovery operations. I coordinated'the county emergency response during the sinking of the U.S. Coast Guard ship " Blackthorn" and the Skyway Bridge disaster. I developed all hurricane evacuation plans and the implementation guides and recovery guides that go along with those plans for the county. I l

also developed the first all system exercise for a county l of this size in Florida. ,

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I was responsible for the response operations during l

l Hurricane Elena in August 1985. That included the l

L evacuation of between 350-400,000 residents in pinellas County, the evacuation of three hospitalt and nineteen l

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nursing homes, and-the sheltering of-114,000 evacuees. 'I' also coordinated _the recovery effort after Hurricane Elena~ I developed and equipped a' state-of-the-art county emergency operations center.

Prior to.my'being-with Pinellas County, I was in the Udited

. States Army, and while in the United States Army,.I had several' assignments that put me in an assignment with emergency planning responsibilities. During'theLperiod July 1970 to. June 1973, _ I was Chief of. Japan Ground Self-defense Force, the Liaison Division and Chief of Operations. Division for United l States Army Japan 9th Corp.

I was responsible for-all planning with the' Japanese Ground Staff Office and.the' United States Embassy in Tokyo. That included United States' military support for disaster

- operations in the Kanto Plains (Tokyo)_ area. 'I was

- responsible and-developed plans for the draw down of the-United States Army units and facilities in both Japan and Okinawa after the phase down of U.S. operations in .,

Vietnam. I was also responsible for the development of the United States Army-Japan input to the National Joint I

Strategic Operations Plan.

Prior to going to Japan, I was a Plans Officer in the Plans Division of G3, Headquarters, United States Army 24th Corp.

in Vietnam. I was responsible for planning combat operations for a tactical U.S. Corp. which consisted of two

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L: a United States Army divisions and one Marine division. I-assisted-in the development of contingency. plans for the withdr-awal of 24th Corp. from Vietnam.

Before to going.to Vietnam, I was an inspector in the'

-Inspections Division of the Office of the Inspector General, United States Army Europe and 7th Army in Germany, and it.

was my responsibility to inspect all classified contingency plans in connection with the United States Army forces in Germany as part of their I.G. inspection.

I am currently writing a chapter called " Disaster Planning, Training and Exercising" in a book titled Princioles and Practice of Emeroency Management. That book is being done ,

1 for-the International Cities Management Association, and is i

being compiled through the University of Denver. )

Q. llave you had an opportunity to review the evaluation of the  !

SpMC made by FEMA in December of 1988 as that evaluation certains to Special Needs Population?

A. Yes I have. Specifically, I have reviewed evaluation  ;

criterion J.10.D which reads as follows: j "Means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement. These means shall include 4 notification, support, and assistance in implementing l protective measures where appropriate." '

i I have also reviewed the FEMA finding in connection with that {

evaluation criterion and FEMA's conclusion that the SpMC is l adequate as it pertains to the Special Needs Population.

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.Q. Do you agree with that finding and evaluation?

A. No I do not. I do not believe the the SpMC provisions for the Special Needs-population are adequate.

O. Could you please state what particular problem you see in connection with that finding as it pertains to the Special Needs population in the Massachusetts EpZ.

A. I reviewed the Seabrook plan and particularly have looked.

at all those portions of it that pertain to special

. population requirements. In meeting that need, it appears that with the SpMC's provisions for notifying, assisting, and supporting.the resident Special Needs population, NHY ORO has taken steps to compile a list of this population by mail in card. However, I think that the thing NHY ORO is overlooking, is the hesitancy of the population to self-identify. This problem has become very apparent to those of us who deal in evacuation planning. When you get involved in the special needs planning, you find that only a very small number of the people that are out there who require assistance during an evacuation, will self-identify and actually become a part of your list. I think basically that members of this population do not want you to know, or anyone to know, that they have some type of impairment. It is very difficult to get that population on any accurate list. As an example, in pinellas County in 1980-1981 it j

was estimated that we had 12-15,000 persons who would have some type of special need during an evacuation. However, the highest number of persons that we had ever had on our '

list was only 3,000. We revised that list after Hurricane j l

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Elena. Yet I know that there are many thousands more out' 1

there.that are not on our list. The population.that is not I l

on thi list will absolutely kill you during an evacuation.

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Q. Now when you say'the Resident.Special Needs population, to I whom are you referring?

A. Special needs residents are people who reside in their.own homes but have some kind of special need that will require assistance in the event of an emergency situation. The purpose of the lists for such persons is to identify to the  ;

government or some agency the population who will need assistance during an evacuation.

Q. -In reference to your list down in pinellas County, how did you gorabout gathering the names of persons on that list?

A. There were several methods we used. One was that we published information for use during an evacuation and distributed 350-400,000 to households throughout the county.

Additionally, one time per year in utility bills we put out information with a phone number on it that allows persons to call in on a voluntary basis to register. We also use newspaper, radio, and television spots to make people aware of the Special'Needs Registration program. i Q. Do you use other sources beside those that you just identified to help you put those lists together? l A. We go to home health care agencies and also use the Florida Department of Health and Rehabilative Services. Those organizations provide services to the elderly and persons in their own homes who need some type of assistance. We go to

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l-organizations 1such as that.to try~to get'them,~through their-programs,1to see if they have persons.who shouldibe registered

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and placed'on our list.

Q.- Are the means thatzyou use to establish your lists in Pinellas County significantly different'then those..

procedures that you have identified as being used in the Massachusetts EPZ by the New Hampshire Yankee-Off-site.

Response l Organization?

A. Well, I1think our effort'is much more extensive,'and:I think we have had a great deal of' experience since we:have:

been involved for eight to nine years'in trying to'ident'ify that population.. I have not seen any evidence of efforts by NHY ORO to work with home health-care agencies.to see, through those programs, how many persons are out there that may need to be on their list. But I think the primary difference is through the experience that.we have gained-in working in this area over the past eight to nine years.

Despite our efforts, we know there'is'a significant number of people out there who are not on our list. The problem-exists not just in Pinellas County. It is in any area where you are dealing with the Special Needs Population.

You have to recognize that you are dealing with persons who do not want to be on your list. They do not want someone to know that they may be impaired in someway. There is a concern that the list may be passed on to someone

<that may come in and rob them, beat them up, or whatever.

Q. Please describe any experience that you have had and any difficulties or problems that have come to light as a result l

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of thaE experience that relates to having resident special needs-lists that do not include the full population in-a given geographic area.

A. During Hurricane Elena, we conduct'ed as far as we can

, determine the largest medical evacuation in the history of the country with nineteen nursing homes and three hospitals being moved. That was all done on a pre-planned basis with every facility knowing where they were going, how many-buses they were going to get, and that worked out extremely well.

We also had our registration list for those people that were in the homes, and we attempted to go and get them. We found two things occurred. In some communities many of the people that were actually registered on our list were only using us as a back up. We dedicated rosources to go pick them up and found they were not there. In contrast, in other communities a high percentage, up to 90% plus, of the people on their lists were there and were picked up. The communities with the high percentage of use were communities that had worked with the persons on their lists in a continuous and ongoing way so that the persons on their lists trusted them.

I The second thing we learned and the one that really hurt us was the special needs population not on our list started l

calling every response agency in Pinellas County. They

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1 made calls to the Sheriff's Department; to police, fire, )

and emergency operation centers. These people called every

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response agency theyocould find in the1telephoneLbookLandL in addition called 911. 'It resulted was a' tremendous:

impact on our resources because:in;many: cases we found that

'one person would. call ~three or;four agencies. . It onded up.

with'the 911~ system being overloaded with people requesting

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. assistance.- It caused our' EMS' units to run.1,000 calls

-during a two: day period and our ambulance-resources in the l county ranoan additional 1,000; emergency' calls. The majority of these were:the. people that required. assistance during, evacuation. We ended up with about 500.of those.

persons being taken to local hospitals and another 279 persons taken to nursing homes.

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They caused a serious problem within our system because we were.not aware that they'were there and when the emergency occurred, suddenly.it was likeithey popped out of the woodwork and placed tremendous demandr, on our resources, f

We were not prepared for it at'that time.

Q. Since that. time, have you made adjus'tments in your emergency planning?- )

.l A. Well, what I think happened was not.just in this county.

We finally recognized the fact tnat the people on our list were just the tip of the iceberg. We had not previously, i 1

in our emergency plans, recognized this and made any provision for that large number of people who call in that i

need for assistance at the last minute. We have since '

adjusted to that and other counties are adjusting to that throughout Florida.

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I What we have done is to establish a phone number that can be called that in turn provide access to resources that j J

we have set aside that are separate from those that are going out to nursing homes and hospitals, and separate from those that are going out to the persons registered on the ]

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list. Those resources are available to assist in providing !

service and assistance to the people that we do not already know about.

Q. In your review of the SpMC and its procedures and resources 3 under that plan, have you seen any indication that a similar allocation has been made to the unregistered special needs population?

A. The plan is oriented to the evacuation of special needs facilities and the persons on the registered list. Where there is a reference to a phone number to call for 4 information and assistance, there does not appear to be any provision for providing such assistance. There is no indication as to what person is responsible to handle those calls within the emergency response organization. There is no indication that there is any transportation allocated to support the unregistered special needs population. So, there appears to be a breakdown in the plan once you get passed the phone call for assistance.

Q. In the reference you have mentioned or in another provision of the plan, is there any indication as to how many phone calls that one phone number can handle and respond to?

A. Ne there is not. There is also no evidence of any TDD for the hearing impaired as part of that communications system that supports the emergency operation center. You see no evidence that the number is going to go into a single phone

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or-a switchboard where one person'would route the call. If they..are doing that, it may be bad. -This occurred during Hurritane David in Dade County, Florida, where persons e

requiring assistance during evacuation were given the emergency operation center phone number. It totally locked up the phone system at the EOC.

Q. Have you identified any problems in connection with Special Needs Population under the SPMC?

A. Well another problem that I have with the plan is the lack of staff to assist the Special Needs Population. When you are dealing with a special needs population, you are' dealing-with people that need assistance. From what I see in the SPMC, NHY ORO has bus drivers responding with vehicles to locations to pick up the Special Needs Population. What we have found is that additional persons are needed on those vehicles to provide assistance. Normally,-we try to put an EMT or paramedic on that vehicle because many of these people have some type of medical problem and it is very difficult for that bus driver, as one individual, to assist them in getting out of the home and into the bus.

So the lack of staffing on the buses is of concern. It is going to be very difficult to have only one person on a bus l

going around to pick up people that you know ahead of time have some type of special need. It may also be very difficult for the Special Needs Population to walk to the bus and to board the bus.

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Q. Do your concerns extend to those people have identified themselves as ambulatory and able to have a curbside pick up?

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A. Yes. I still feel it is advisable to provide someone with l 1

some medical experience or background on that bus to assist.

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Q. In considering the loading the elderly or other special {

needs ambulatory populations onto school buses, how many people have you found are needed to do that kind of loading procedure?

A. I base my observations on this point from experience, because I watched the loading door of school buses used during a nursing home evacuation where we had a large number of L

personnel to help. We used firemen from five different fire departments to evacuate a 120-bed nursing home. The first step on a school bus is extremely high. Elderly people, who are included in the special needs population, find it very difficult to raise their leg up and then pull themselves into the bus because of that high first step. You wo"1d normally have to have, at a minimum, three people to assist each I person getting into that bus. Now that is two people, one on each side, to assist each person by raising them up, and one within the bus to help them to get in the bus. Now there may be ways to get around it, such as ramps and other things that can be constructed. However, when you just pull up to evacuate a facility, you should think about the number of people it will require to load the type of person being evacuated onto the type of vehicle used.

Q. In connection with nursing homes or other special facilities that have not planned or exercised for evacuations ahead of time, have you had any experience as to whether they would typically need additional staff to support them in the event of an evacuation?

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-A. I have normally found that if a nursing home evacuates'or'a medical facility evacuates, without prior planning'and

-exercising, it becomes~very difficult for that facility to e

comp 1e'te the' evacuation on their own. They are going _to )

need outside help. -:

Q. So in terms of a planning recommendation, do you believe that it is advisable.for a response organization to have additional personnel available to make such a response?

A. -You have two options. One is to devote the time, the training and the exercising to. allow the' medical facilities-to do it on there own. If for whatever reason, certain facilities can not, will not, or has not had' proper training and exercising,. recognize that fact and include in your plan.a capacity to provide the additional resources

.that will be needed to evacuate those facilities.

Q. So to the extent that there-are Special Needs Facilities in the EPZ that have not-trained or exercised, what would your recommendation be?.

A. If they have not trained or exercised ahead of time, I would strongly suggest that.that fact be recognized.and resources allocated to allow them to conduct an evacuation by providing assistance. The SPMC does not provide any additional resources to be available for evacuating Special Needs Facilities other than providing transportation.

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b 9TATEMENT OF QUALIFICATIONS -!

• Guy E. Deines, a CRG Associate, is currently the Director of the {

Department of Civil Emergency Services, for Pinellas-County, Florida. There, he is responsible for the budgeting and management of 11 Fire Districts, and the budgeting and contract management of 17 Emergency Medical Services Districts. As Director, Mr. Daines develops and implements all County Emergency Operations Plans, and is responsible for the county-wide 911 Program and the activities of the Pinellas County Emergency operations Center.

He is also an Instructor for the Federal Emergency Management Agency's course on " Evacuation Planning and Response Actions Simulation."

From May 1979 to February 1987, Mr. Daines was the Director of Emergency Management Administration and Operations Coordinator for the Department of Civil Emergency Services in Pinellas County, Florida. There he developed the Pinellas County Hurricane Evacuation Implementation Guide and Recovery Implementation Guide, including a step-by-step decision-making process for hurricane evacuation, which utilizes state-of-the-art hurricane planning, response and detailed procedures for recovery operations. He also initiated and coordinated the first all-systems Pinellas County Hurricane Evacuation Exercise; coordinated the first all-systems Pinellas County Hurricane Evacuation Exerciset and developed and equipped a state-of-the-art County Emergency operations Center.

While at the Department of Civil Emergency Services, he was responsible for Eoc activation.and response operations during Hurricane Elena, which included the evacuation of almost 400,000 Pinellas County residents, the concurrent evacuation of three hospitals (all patients) and 19 nursing homes (2,860 patients),

and the sheltering of 114,000 evacuees. )

l Mr. Daines also coordinated the development and implementation of the first Pinellas County Hazardous Material Response Team, and coordinated County emergency response, in support of the St. (

Petersburg Incident command Post during the Jones chemical Fire, l Which resulted in the evacuation of approximately 8,000 residents.

1 Mr. Daines earned his M.A. in Management from Webster College in i St. Louis and his B.S. in Commerce (Business) from Eastern  !

Kentucky University. He is a retired U.S. Army Lieutenant '

Colonel.

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