ML20082P262

Supplemental Discovery Response Consisting of Status Rept: Planning for Accident at Perry Nuclear Plant, by Perry Legal Defense Fund.Certificate of Svc Encl.Related Correspondence

ML20082P262
Person / Time
Site:	Perry
Issue date:	12/05/1983
From:	Lodge T SUNFLOWER ALLIANCE
To:	CLEVELAND ELECTRIC ILLUMINATING CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8312080161
Download: ML20082P262 (36)

Text

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.' December 1, 1983

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'83 EC -7 A 0 :42 NUCLEAR REGULA'IORY C044ISSION , _ , , . ,,_

Before the Atomic Safety and Licensing Board W ... .':".G

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m. ED tiCH In the Matter of ) Docket Mos. 50-440-OL 50-441-OL CLEVELAIO ELECTRIC ILLUMINATING )

COMPANY, et. _al.

(Perry Nuclear Power Plant, Units 1 and 2) )

)

SUNFLOWER ALLIAIG'S SUPPIDENTAL DISCOVERY RESPOISE Now comes intervenor Sunflower Alliance, by and thru.gh counsel, and seasonably updates the discovery requests cf Applicant and Staff by transmittal herwwith a copy of " Status Report: Planning for an Accidst at the Perry Nuclear Power Plant", by the Perry legal Defense Fund, to each individual named on the Attached " Service List."

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ikxige F' l

Terry (( dor Sunflower Alliance Counsel

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CERTIFICATION I hereby certify that a copy of the foregoing "Supplanental Discovery Response" and its ctcccnpanying docunent were served upon

-d each of the parties named on the Attached " Service List" this 'l W day of December, 1983 via regular U.S. Mail, postage prepaid.

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'83 DEC -7 N0 :42 CF::!i '3' ..~>^

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.ERANCH Status Report:

PLANNING FOR AN ACCIDENT AT THE PERRY NUCLEAR POWER PLANT BY THE

-PERRY LEGAL DEFENSE FUND 1983 e

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TABLE OF CONTENTS I. Introduction 1 II. Concept of Emergency Preparedness 1 III. Radioactive Exposure Pathways 2 IV. Health Effects of Radiation Exposure 4 V. Protective-Action Guidelines 8 VI. Economic Impact of an Accident 10 VII. Response of the Perry Plant in an Accident 11 VIII. Response of the Counties in an Accident 15 IX. Survey Response and Analyses . 25 X. Quotes from various Surveys 30 XI. References 32 4

FACTS AND FIGURES s

Map of the Emergency Planning Zone ,3 Table 1: Action-and Health Effects Versus Exposure Path.ays 5 Table 2: Sensitivity of Various Tissues to Cancer Induction by Radiation 6 Table 3: Protective Action Guidelines for Whole Bcdy and Thyroid Exposure to Airborne Radioactive Materials 9 Table 4: Private Sector Employment Losses from an Accident 12 at the Perry Plant Table 5: Employment Effects on Manufacturing from a Nuclear Plant Accident 13 Table 6: Representative Shielding Factors from Gamma Cloud Source 16 Table 7: 1980 Populations in 10-Mile Zone of Lake, Ashtabula, and Geauga Counties 18 Table 8: Transportation Dependent Population 22 Table 9: School Bus Driver Survey Response 23 Table 10: Fire Chief Survey Response 29 f

. 4, I. INTRODUCTION The radioactivity in a nuclear power plant such as Perry poses a constant threat to the health and safety of people and animals living in the I

vicinity of the plant. If this radiation was released to the environment by means of an inadvertent release or by an accident, the power plant operators and surrounding communities must be equipped to respond. The havoc at Three-l Mile Island in 1979 underscored the necessity of having a workable, well-designed plan to respond to such emergencies.

Since the TMI accident, regulations have been enacted which attempt to set up guidelines for local community response to a radiological emergency.

For the Perry Nuclear Power Plant draf t plans have been developed for Ashtabula, Geauga, and Lake Counties, as well as the Power Plant itself. This report will analyze those plans, as well as explore the fundamental precepts of emergency planning. Although this is a cursory view of the emergency plans it provides a basis for further questions as to the " Nuclear Future" with which we may be forced to live.

II. CONCEPT OF EMERGENCY PREPAREDNESS Emergency planning is known as the last layer of the defense in depth concept which keeps radiation in the nuclear plant from escaping to the environment. In laypersons' terms, it is the last action which can be taken to assure that exposure to radiation will be minimized. When all the redundant safety systems of the plant fail, it is imperative thoc emergency preparations work to keep the residents within a 50-mile radius from the plant from direct exposure to the radiation. Ideally, emergency plans should keep exposure to a minimum.

Hazards of the Perry Plant which emergency plans seek to avoid are the result of the radicactive utanium fuel used in nuclear power. The fuel is

2 irradiated when neutrons split the uranium during the fission reaction. Heat given off from this split is used to boil water, creating steam which turns an electrical generating steam turbine. Water must flow through the reactor core to remove the heat from the reactor. If there is no water, or some other heat absorbing material, the fuel will heat up as the reaction continues.

When the fuel is heated the radioactivity is released from the reactor core.

This is where the greatest hazard of nuclear power generation exists. Should the reactor core heat up and the fuel melt you get what is known as the China syndrome (the intense heat will melt through the earth's crust).

A buildup of radioactivity in the reactor core or reactor building must be released at some time. In some accident scenarios, the release can occur through some break in the reactor's coolant piping. Once the release occurs, it is only a matter of time before it reaches the atmosphere. The NRC has estimated the time of radioactive release as anywhere between one-half hour to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> (NUREG 0654, p. 11).

III. RADIOACTIVE EXPOSURE PATl! WAYS Emergency planning concerns itself with two different modes of ' radio-active exposure. The first mode is exposure to the body and inhalation.

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This is called the Plume Exposure Pathway because the radioactivity .me. .a airborne and travels in a plume in the direction of the wind conditions at the time of the accident. This particular area of exposure presents the most immediate danger since the radioactivity can be quickly absorbed in the human body. Scientific research has determined the 10-mile zone around a nuclear plant to be the Plume Exposure Fathway. The map on page 3 shows the 10-mile zone for the Perry Plant. This area is to be evacuated in case of a nuclear accident, but only if the county officials determine evacuation is necessary and prudent.

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The second mede of exposure is that of ingestion of the radioactivity from contaminated sources.

The Ingestion Exposure Pathway is an area which measures a 50-mile radius from the Perry Plant.

Contaminated vegetablet, water, or milk from around the plant presents serious health hazards for indivicuals living within 50 miles from the plant.

Since the contaminated water and land cannot be used, questions as to the economic impact of the agricultural and industrial community arise.

(These questions will be discussed in Section VI. ) Furthermore, the prolonged exposure to individuals in the area increases the amount of health effects of a release of radioactivity.

Table 1 further distinguishes the source of radioactive exposure and their health effects.

l IV.

HEALTH EFFECTS OF RADIATION EXPOSURE Dangers associated with radiation exposure due to a nuclear plant accident ' divide into two general categories:

(a) latent genetic and (b) chronic-somatic.

The chronic-somatic effects are those arising from a 100 Rem l or more exposure according to NRC documents t (NUREG/CR-ll31, Examination of Offsite Radiological Emergency Protective Measures for Nuclear Reactor "

Accidents Involving Core Melt, p. 25, 1978).

Rapid fatality or prolonged cancer can occur.

Exposure of this magnitude is a result of direct contact with highly irradiated material or gas.

(For more specific effects .to radiation exposure,- see Table 2 on page 6.)

The lO-mile Plume Exposure Pathway is i; designed to reduce the possibility of this type of exposure [

Individuals who h J

receive this much radiation will suffer immediately followinguch s exposure, 5{

El unlike the latent-genetic effect which occurs over time and iswidespead. more i A NRC document compared the two health hazards of radioactivity in '

this way:

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ACTION AND HEALTH EFFECTS VERSUS EXPOSURE PATHWAYS Public Health Exposure Pathway Response Time Action Available Effects Air - Particulate Minutes - Hour . Protective (P) Delayed Gas Minutes - Hour Protective Rapid Fatality, Early, and Delayed Water - Particulate Rainout Hour - Day Protective Delayed Fallout Minutes - Hour Protective Delayed Immersion Day Protective & Delayed, Early, Restorative (P&R) & Rapid Fatality Food - Milk Day - Month P&R Delayed Drinking Water Hour - Month P&R Delayed Beverages Day - Month P&R Delayed Foodstuffs Day - Month P&R Delayed Soil.- Resuspension Day Restorative Delayed Direct Minutes - Days P&R Early, Delayed,

& Rapid Fatality Direct - Facility Minute P&R Rapid' Fatality, Early, & Delayed Air Minute - Hour Protective Rapid Fatality, Early, & Delayed Water ' Hour P&R Delayed, Rapid Fatality, &

Early Sources " Manual of Protective Action Guides and Protective Action for Nuclear Incidents", EPA 520/1-75-001, September, 1975, rev. June, 1980, p. 1.16.

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TABLE 2 SENSITIVITY OF VARIOUS TISSUES TO CANCER INDUCTION BY RADIATION Spontaneous Relative Sensitivity Incidence to Radiation Site or Type of Cancer of Cancer Induction of Cancer Remarks Major radiation-induced cancers Female breast Very high High Puberty increases sensitivity Thyroid Low very high, especially Low mortality females Lung Very high Moderate Leukemia Moderate very high Especially myeloid type Alimentary tract Hign Moderate to low Especially in Colon Minor radiation-induced cancers Pharynx Low Moderate '

Liver and Biliary tract Low Moderate Pancreas- Moderate Moderate Lymphomas Moderate Moderate Kidney.and Bladder Moderate Low Brain and nervous system Low Low Salivary glands Very low Low Bone /ery low Low Skin High Low Sites or tissues in which maginited of radiation-induced cancer is uncertain Larynx Moderate Low Masal sinuses Very low Low Parathyroid. Very low Low Ovary Moderate Low Connective tissues Very low Low sites or tissues in which radiation-induced cancer has not been observed Prostate Very high Absent?

Uterus and Cervix Very high Absent?

Testi Low Absent?

Mesentory and Mesothelium Very low Absent?

Chronic lymphatic leukemia Low Absent?

Source: 1980 BEIR Report.

. 7 "In contrast to early somatic effects, both latent cancers and genetic effects are random phenomenon whose probability of occurrence for a given ' individual is a function of the dose received by that individual. Consequently, these effects may be observed at long distance from the reactor where a small dose might still be received by large numbers of people.." (Source: NUREG/CR 1131, " Examination of Offiste l Radiological Emergency Protective Measures for Nuclear Reactor  !

Accidents Involving Core Melt", 1978, p. 25.)

In a 1982 memorandum from Roger M. Blond to the Reactor Risk Branch of the NRC addressing the basis of the Emergency Planning Zones stated:

"Even with a source term (value of radiation release from a plant accident) reduction of a factor of 100 there could be early fatalities and injuries out to about one and five miles respectively. With respect to the detectability of latent cancer fatalities, such releases would generate statis-tically detectable cancer in the exposed population for many tens of miles." (Emphasis and bracketed material added.

(Source: Memorandum for Ronald M. Scroggins, Director, Administration and Resource Control Staff, Office of Nuclear Regulatory Research, from Roger M, Bond, Reactor Rick Branch, Division of Risk Analysis, Office of Nuclear Regulatory Research, January 28, 1982.)]

This statement acknowledges the cancers of people exposed to radiation from a plant accident, yet not evacuated since they live more than 10 miles from the plant.

Various radionuclides may be released from the nuc~ pcwer reactor.

They all have different levels of radioactivity and absorb in humans at different rates. Some of the several hundred radioisotopes include cobalt 60, strontium 90, iodine 131, xenon 133, cesium 137, and plutonium 239.

According to the Reactor Safety Study, WASH 1400, a release 'from the power plant may occur from one-half hour to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> after the accident. If the release were to take place one-half hour after the accident, it is highly unlikely that any evacuation will be effective. In fact, exposure to the radioactivity would be great since people will be trying to evacuate, or gather in a central building at the same time the radioactive release occurs.

8 V. PROTECTIVE ACTION GUIDELINES The Envitonme7tal Protection Agency was responsible for developing guidelines for determining how much radioactivity can be released from a' plant accident before any action is taken. Protective Action Guidelines, or PAGs for short, are divided into two categories: whole body and thyroid.

Table 3 shows the number of Rem exposure which is determined by a dose estimate and is the level at which a Protective Action (i.e., evacuation or' sheltering) is initiated. A projected dose is obtained from power plant sources (the Utility). Some information may be obtained from outside the Perry Plant but this means waiting until the radiation is dispersing into the _ community before knowing the proper protective action to take. There-fore, actions taken in a nuclear power plant accident are based on scant, unbiased information.

The NRC realizes the problem with information flow for determining a dose estimate. The decision to take a particular action will have to be based upon human judgments, not scientific data like they want us to think. The EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, September, 1975, rev. June, 1980, p. 1.8 stated:

"In addition, the decision will likely be made under difficult emergency- .

conditions probably with little detailed information available." From i

this sound information a decision must be made which will protect the public, and according to the-reports, be most cost-effective.

A decision to evacuate will have to be made with limited knowledge of the type and amount of radioactive release. Also, projections as to the estimated dose individuals will receive will be calculated on meteorolo-

_gical ~ models which contain a lot of variation in their predictions. The agency responsible for preparing the system for estimating dose projections is the Nctional Oceanic and Atmospheric Agency. In one report discussing

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i TABLE 3 PROTECTIVE ACTION GUIDES FOR WIIOLE BODY EXPOSURE TO AIRBORNE RADIOACTIVE MATERIALS Population at Risk Projected Whole Body Gamma Dose in Rem Projected Thyroid Dose General Population 1-5 *

• 5 - 25 Emergency Workers 25 125 Life-saving Activities 75 None

• When ranges are shown, the lowest value should be used if there are no major local constraints populations. in providing protection at that level, especially to sensitive Local constraints may make lower values impractical to use, but for in no caseaction.

protective should the higher value be exceeded in determining the need ,

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. Source:

Incidents,Manual of ProtectiveSeptember, EPA 520/1-75-001, Action Guides and 1975, Protective rev. Action for Nuclear June, 1980, p. 2.3, 2.5.

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10 the model for estimating dose they wrote that the "... output information must then be judged within that framework of uncertainties. As pointed out by c rawford, et al., 1978, these accuracy statements are largely based upon scientific judgment; there is not enough data upon which to base a statistical estimate of the reliability of airborne effluent concentration.

Thus, each stage of calculations will have its associated uncertainties."

(Emphasis added.) Not only will the informatica which the National Oceanic and Atmospheric Agency depend upon be suspect, but the result of their own calculations will be " uncertain". It is from these uncertainties that human lives will depend. Furthermore, the admission of trouble at PNPP and its extent is dependent solely upon CEI which has a SS billion vested interest in not arousing a public alarm. I VI. ECONOMIC IMPACT OF AN ACCIDENT An accident would have far reaching economic effects on the surrounding counties. These costs will be in several categories. Agricultural costs will result from the inability to utilize the farmland which is contaminated to grow crops. The length of time land must lay fallow will vary depending upon the amount of radioactivity but, will be unusable for at least a year.

Since crops can concentrate radioactive materials in the land by their uptake of nutrients from the soil, the ground must be free from radioactivity below the surface as well as on top of the ground. Grazing animals will not be allowed to eat the crops grown on the contaminated soil because they too will concentrate the radioactivity in their bodies. They will have to feed from outside sources. Furthermore, water will have to be transported into the contaminated zone and kept from ,the radioactivity so the etnimals can use it. All of these necessary actions are costly and could render the agricultural community bankrupt.

11 .,

A Nuclear Regulatory Commission study in of a serious nuclear plant accident 1982 estimated the effects 4 and 5.) on the economic community.

Specifically, they looked into th (See Tables the Perry Plant. e effects on the area surrounding Agricultural would lose all production for mor industry within 21 miles from the plant e than one year the Potential Impacts of a (NUREG/CR 2591,

" Estimating loss would extend for Nuclear Reactor Accident" 1982, p. ,

89.) Crop These 271 miles from the plant, effects are and last at least one year.

astronomical. Questions the burden from these losses, individualremain as to who will bear minating, or the farmers, Government? Cleveland Electric Illu-Thus far, there is insurance, that an individual farme no protection, such as r can get.

Another more significant is in economic impact of a nuclear plant the industrial sectors. accident The NRC study found that for more than one year in Lake loss of employment 21,466 County would be persons, and 76,558 persons, in Ashtabula in Geauga 40,165 persons.

breaks down Table the losses 4 further of employinent.

is affected by an In the area accident the losses of which employment bscause of the wide variety of would be significant economic factors.

tha decrease in the importing of These factors include goods to the in supply of resources 'into the area, radioactive area, decrease What and other complex economic variable s.

is clear is that an accident at consequene.es which are likely to reshapthe Perry Plant would have fa r reaching living within 50 miles from the pla e the economic base for many reside

n. t nts VII.

RESPONSE OF THE PERRY CCIDENTPLANT IN AN A In order to obtain a license to operate must make an a nuclear power plant, CEI plans'must Emergency Response Plan for the plant site.

follow the These onsite plans of regulations of the NRC the Counties, State, and coordinate well with the and Federal organizations.

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I TABLE &

PRIVATE SECTOR EMPLOYMENT LOSSES FROM AN ACCIDENT AT Ti!E PERRY NUCLEAR POWER PLANT 1978 Figures Direct Losses in the Industry Physically-Affected Area Agriculture 9,000 Mining 1,000 Construction 15,000 Nondurables manufacturing 27,000 Durables manufacturing 72,000 Transportation, communication & utilities 14,000 Wholesale trade  ; ,000 Retail trade 58,000 Finance, insurance & real estate 14,000 Services 57,000 Total .288,000 Source: "Ectimating the Potential Impacts ofa Nuclear Reactor Acci-dent", NUREG/CR2591, 1982, p. 94.

9 TABLE 5 - ?

EMPIDYMENT EFFECTS ON MANUFACTURING FROM A NUCLEAR PIANT ACCIDENT Number of Employees Affected More Than One Year Industry Name Lake County Geauga County Ashtabula County Paints and allied products 187 Miscellaneous chemical products 223 -

20-99 Paving and roofing materials 62 - -

l Fcbricated rubber products 1,094 2,180 _ 100-249 Miscellaneous plastics products 250-499 1,265 2,500-2,499 Blankoooks and bookbinding 100-249 i

Blast furnace and basic steel products 100-249 -

1,000-2,499 l Iron and steel foundries 100-249 - -

l Nonferrous rolling and drawing 100-249 - - l l Nonferrous foundries 342 -

100-249 Miscellaneous primary metal products 171 - -

Metal cans and shipping containers - -

20-99 Cutlery, hand tools, and hardware 500-499 l

500-999 w Fabricated structural metal products 250-499 -

20,-99 Screw machine products, bolts, etc. ,1,040 140 100-249 Metal forgings and stampings 904 -

250-499 Miscellaneous fabricated metal products 980 20-99 444 Conetruction and related machinery 4,265 - -

Meta'. working machinery 1,493 236 516 Special industry machinery 783 100-249 -

Miscellaneous machinery, except electrical 1,252 58 20-99 Electrical industrial apparatus 334 100-249 -

General industrial machinery 100-249 - -

!!ousehold appliances - -

20-99 Electrical lighting and wiring equipment 250 20-99 100-249 Miscellaneous electrical equipment and supplies 20-99 -

500-999 Motor venicles and equipment 891 -

500-999 Aircraft and parts 20-99 - -

Measuring and controlling devices 1,000-2,499 250-499 -

Musical instruments 500-999 250-499 -

Miscellaneous manufacturers 246 - -

Miscellaneous non-metallic mineral producte 129 - 100-249 Total manufacturing sector 27,395 6,202 13,506 Source: " Estimating the Potential Impacts of a Nuclear Reactor Accident," NUREG/CR-2591, 1982, p. 92.

14 occurs, the utility has 15 minutes in which to contact all of the counties j 1

as well as the state.

The Shift Supervisor is the first to become aware of the impending or exisiting problem with the plant. According to the plan for the Perry Plant, "The Shift Supervisor shall declare an appropriate emergency classifi-cation whenever, in his judgment, the plant status warrants such a declara-tion." (" Emergency Plan for Perry Nuclear Power Plant Units 1 & 2,

p. 4-2.) Any offsite dose projections come from the Shift Supervisor.

This means that the action taken is dependent upon the judgment of the Shift Supervisor. It,is possible that it will take quite some time before the Shift Supervisor has enough information to make this judgment.

An emergency condition at the plant is determined by a control room alarm or instrument. Once the control room notifies the Unit Supervisor and Shift Supervisor of the emergency, several actions must be taken.

The Perry Plan prioritizes the Shift Supervisor's activities as:

1. Ensure the safe operation of the plant;

2. Ensure that immediate notification requirements are met;

3. Dispatch Radiation Monitoring Teams;

4. Perform additional emergency actions as time and ccndi-tions permit.

It is required that the notification of offsite organizations such as the Counties and State governments be within 15 minutes of the accident. This means that the Shift Supervisor will either have to ensure the safe opera-tion of the plant within 15 minutes, as is assumed by the plan's prioritiza-tion, or make an alteration in the plan. This change, will either delay the safe operation of the plant or delay the time of notification of the

. authorities. As is generally known, a person's actions in a state of crisis

15 are altered and unpredictable. One person in charge of organizing the plant staff, notifying the authorities, and making judgments as to the

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protection action recommended seems to be insufficient.

Relying on the action of CEI employees to advise of an emergency and the appropriate response by the Counties may have some problems. First, the notification of the organizations offsite is dependent upon the Shift Supervisor, who has many functions in an emergency. Secondly, there is some conflict of interest between the calling of an emergency condition by CEI and the bearing of the cose of the County response by CEI. It would be advantageous for CEI to minimize the significance of the accident to avoid having to pay the cost of an evacuation. Furthermore, in light of the nuclear industry's concern with public image, it would not be unlikely to initiate an emergency unless the accident was severe. This would eliminate the possibility of early evacuation or some other response.

VIII. RESPONSE OF THE COUNTIES IN AN ACCIDENT Federal regulations require the development of Emergency Response Plans by various organizations situated around the Perry Plant. These plans must be functional to assure that proper response to an accident will result in a given circumstance. Any County which is within the 10-mile-zone must be able to provide its residents with a " safe" means of avoiding excessive exposure to radioactive releases from the power plant. Lake, Ashtabula, and Geauga Counties are required. to draw up these plans according to federal guidelines. The Federal Emergency Management Agency (FEMA) is responsible to review the plans and give their recommendation to the NRC. This must occur prior to the nuclear plant's full-scale start-up (low level testing may go on prior to the acceptance of the plan).

The plans are a series of communication, technical, and organizational listings which together are supposed to make a smooth operating emergency re-

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TABLE 6 REPRESENTATIVE SHIELDING FACTORS FROM GAMMA CTOUD SOURCE 1

~$?ructure of Loc 1 tion Shielding Factor Representative Range ,

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Vehicles l.0 Wood-frame house (no basement) , g O.9 s.

I  ! 3 Basement of wood house ' l O.6 0.1-0.7 i

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Masonry. House (no basement) 0.6 0.5 .7 Basement of masonry house -

0.4 0.1-0.5 Large office or industrial building 0.2 0.1-0.3 '

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Notes:

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. 1. The r stio of the dose received inside the structure to

< the dose that would be received outside the structure.

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2. A wood-frame house with bri'ck or stone veneer is

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approximately equivalent to a masonry house for shielding purposes.

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3. This range is mainly due to different wall materials

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4. The shield'ng i factor depends on where the personnel vi

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So:Jrce: SAND 77-1725 (unlimited release).

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Severt.' factors go into plans. the preliminary stages of the working Cooper g on and Agreement Since the 10-mile zone process should be crosses t%ree a Counties, the consensus agreement. decision-making Counties to The plans individually decide on require, however, the emergency.

Although the proper response to an cnd the plans use similar lan y radiological .

type of emergency, different guage in defining tha measures in Counties may choose extent prot'cting e

their to take different call for an residents.

evacuation while For instance, Ashtabula and Lake County might Geauga Counties to seek shelter in their homes.

different One or advise peaple could lead to two County's response serious which is as to the raisconceptions nature of the accident. in the other County (ies)

The County residents may In this circumstance, chao nevertheless choose to s would result.

zational assistance the County i evacuate without the organi-The plans lack s supposed to provide.

inter-county dacision-making. cohesion, which would Although the Counties assist in the cre put are separate in the same jurisdictions, situation if there is an they making body would accident, facilitate orderly steps and one decision-time is of the essence 'so .

In a nuclear plant is reached, accident, could have a delay in the decided respons e, s,erious effects if a rocsivas. on consensus the amount of exposure a person Another area of plcn of Lake cooperation between the County.

3ransported Individuals living in Counties is found in the by a bus institutions who require an ambulance. cannot be

!tanda, includes The Lake the use of County plan, as it ambulances from adjacent hoir evacuation. Again, Counties if the Counties do not agree to aid in 4 is'_unlikely they will commit vehi l on the same response, 1

\

c es to aid the County.

./ _s ~ - - - - - Since a 4]o@AMm

18 TABLE 7 POPULATIONS IN lO-MILE ZONE OF LAKE, ASl! TABULA, AND GEAUGA COUNTIES Counties # of People Ashtabula County Geneva 7,100 Geneva on the Lake 960 Geneva Township 3,800 Harpersfield Township 1,100 Total Ashtabula County 12,960 Geauga County Thompson Township 1,800 Total Geauga County 1,800 Lake County Fairport 3,197 Grand River 599 Madison 1,998 North Perry 299 Painesville 17,384 Perry 1,399 Townships Concord 9,691 Leroy 2,198 Madison 16,185 Mentor 7,000 Painesville 13,388 Perry -

4,796 Total Lake County 78,634 Total of All Counties 93,394 Source: Emergency Plan for Perry Nuclear Power Plant Units 1 & 2.

)..

19 in one County does not cross jurisdictional lines, other Counties may chocse not to assist them in any way. Questions as to who will pay the ambulance corps to cover their insurance are not answered either.

The plans also depend upon many Nolunteer organizations to fulfill the vital response requirements. For instance, school bus drivers are asked to drive not only students from school but also individuals who do not own cars. The plan states that if the school bus drivers do not volunteer, then fire department personnel will drive the buses. However, most of the fire department personnel are also volunteers and may not parti-cipate in the evacuation. Health hazards associated with these cctivities may be great and many bus drivers and firefighters may choose to leave the area and take their families and/or themselves to a safe place. Further-more, fire department volunteers are not trained in driving a school bus in normal conditions let alone an emergency. Part IX analyzes a survey of various organizations involved with the plan and will answer some of these questions.

Moving over 93,000 people living within a 10-mile concentration is going to take proficiency which a well-regimented population will find hard to accomplish, let alone a populatio'n filled with children and elderly.

Evacuation of the Population At school is where the problems begin. The plans allow any parent who chooses to pick up his/her child in case of an accident to do so as long as they sign a release form. The situation can be pictured. It is likely that many parents.will choose to pick up their children. This is because the school buses will not take them home, but till take them to a recsption center where a parent may pick them up. A pcrent will be much more satisfied knowing that the child is safe with them, than . to travel to a location to find them. Therefore, the amount of cars in the school

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parking lots will cause traffic problems and delays.

are The school buses in the school lots and parents' cars are in the parking lots. Parents must dons so.find their child (ren) and sign a release if they have not already The buses will have a hard time getting out of the lots, and further panic will complicate things.  !

Inside the buses will be another problem.

The plans call for the suspension of load limits of 66, and allow 80 in a bus.

on bus driver surveys.) (See Section IX This means children will be standing in the aisl es while the bus is travelling.

Furthermore, the students may be panicked or.d the situation will only be worsened with overcrowding of th

_Home e buses.

At home several steps are taken before evacuating .

If one works outside the home they will return home before the evacuation.

If anyone works cutsida the lO-mile zone but I lives within the zone they must pass the lp3rimater check.

This is because once an evacuation is declared, no one

$utsida the 10-mile Jive thnre. zone will be allowed' back into the zone unless they Perhaps this means someone working outside the r zone must have c eof that they live inside the zone to get home.

till ba delayed, at This group of workers i the perimeter, and, therefore, Bien. delayed in their evacu-t (l cutsideOnce everyone is at their home, the plan calls for the closing of i vents and windows e homa. to avoid radioactive particles from entering i Then, one should lock up the home.

kan also. All " valuables" should be How to tha individual. one collects their valuables in a short time is left i Clothes should be taken' also in case you are not (o to ' return for a long time.

On the way out of the door, everyone is i icd to put a green card in the front window to let the police know the

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house is evacuated. (The utility is responsible for sending out these grcen cards.) If there is not a green card in the window, the police are required to go to the door and be sure the house is empty. In a situation such as a nuclear plant accident, residents in the 10-mile zone are asked to maintain a composure similar to going on a vacation.

Individuals Without Cars and Nursing Home Residents Individuals and families who do not own a car (approximately 3,212 people, as indicated in Table 8), or have some means of evacuating, are to go to central locations to be picked up by a bus. Of course, there has to be enough bus drivers to volunteer to pick them up. The plan does not require the drivers to commit themselves to driving in the evacuation prior to the Emergency Response Plan evaluation by FEMA. In any event, the plan does have provisions for transporting the earless population.

It is almost certain this group of people will be the last to be evacuated since the biases will be busy picking up children from school first if the

- accident occurs during the day. If the accident occurs at night the drivers are asked to nevertheless drive to pick up the earless individuals. This will take time because drivern will have to get their buses, fuel them and find the route they are to take. In the final analysis, the earless population will be the last to be evacuated.

A subgroup of the earless population is those individuals who live in nursing homes and other institutions. These individuals (estimated at 1,735, as indicated in Table 8) will also be evacuated by bus. The number of residents at nursing homes in the evacuation zone is substantial and orderly evacuation is necessary. How bus drivers will respond to carrying such individuals is much different than children. These individuals must also be transported to facilities which can acccanodate them. Here again

'it is unclear who will absorb the high cost of relocating these individuals

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TABLE 8 TRANSPORTATION DEPENDENT POPULATION i l

l Zone Area Non-Auto Institutional School Total 1 51 0 0 51 2 402 40 4,600 5,042 3 389 420 4,300 5,109 4 1,203 800 5,800 7,803 5 128 0 800 928 6 240 0 700 940 7 799 475 3,000 4,274 3,212 1,735 19,200 24,147 Source: Emergency Plan for Perry Nuclear Power Plant Units 1 & 2.

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with such special needs. Hospitals will also have to be evacuated if the situation arises. These underlying problems are not directly addressed in any of the Counties' plans.

Bus Drivers and Protection

, Any individual who is going to be exposed to the radicactivity must have to protect themselves - from er; osure which could lead to health effects, bus driver is going to be " protected", according to the Counties' plans, by monitoring the amount of radiation exposure the driver has already received. By wearing the dosimeter the driver can tell how much radiation they have been in contact with. Of course this does not take into account the differing exposure to different parts of the body. The dosimeter is placed in one location. Also, this "after the iact" type protection will do noching for a driver exposed to high concentraticns. Firefighters and police, on the other aand, are going to be equipped with respirators and protective clothing. This will help reduce their exposure to the radioacti-vity. Bus drivers will not have this typ'e of protection. Being on a bus does not do anything for their protection from the radiation. Table 6, which is from the CEI Emergency Response Plan for Perry, discloses the protection from the vehicle. According to the table, the bus driver will be exposed to the same amount of radiation inside the bus as outside the bus. A serious problem exists as to the protection of bus drivers and has not been the concern of the Counties' plans.

Traffic Control i'

Once the evacuation is underway, the problem of traffic control and congestion is left to the police department. They are to control the flow of traffic and respond to any assorted problems. One of the problems is that of stalled cars in the road. The police must call tow trucks in

• co get the cars removed so traffic will flow. It remains to be seen how

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a tow truck will bypass a traffic jam to get to the stalled car, let alone tow it out of the way. If the weather conditions are bad, like a snowstorm, the problems are further complicated.

Also, it is imperative that your s car has enough gas to get you out of the zone and to your destination. If you do not have enough gas, then what do you do? The answer is not known.

If you are exposed to radioactivity, the contamination must be handled properly. Hospitals in the area are supposed to obtain equipment and training for handling large numbers of contaminated individuals. Thus far the equipment has not been perchased and the planned capacities of the proposed

facilities are far from adequate. According to the TEMA's informe.1 review

, of the County plan of Lake County, "There is no evidence that the hospital (Lake County Memorial Hospital East or West) has the capacity for evaluation of radiation exposure or uptake." Also, rescue workers have to be trained in handling contaminated individuals so as not to injure themselves. No plan for the training has yet been implemented.

'The concept of a Radiological Emergency Response is sound. In case of a nt; clear plant accident and release of radioactivity, people whose

, lives are endangered must be equipped to respond. This means leaving the area of possible radiation exposure. However, in the type of society we live in today the practicalities of havirig an effective response are ques-tionable. A concentration of more than 93,000 people in an area limits l

the possibility of an evacuation because it is dependent upon so many vari-ables. The emergency plans can attempt to alleviate the problem on paper, but do nothing when it comes time to take action.

IX. SURVEY RESPONSE AND ANALYSIS

.In July of 1983 the Perry Legal Defense Eur ci initiated a eurvey of several key institutions and organizations involved with the evacuation

26 TABI.E 9 SCHOOL BUS DRIVER SURVEY RESPONSE

• Know of plan Know of Plan Not Questions Asked & Answered _& Will Drive & Will Not Drive Drive Drive Do have information on radioactive hazards 50% 75% 25% 20%

Volunteer without pay' 100% 0% 87.5% 0%

Will make several trips into the 10-mile zone 100% 0% 87.5% 0%

Will pick up individuals withcut automobiles 100% 0% 87.5% 0%

Will drive in summer 100% 0% ---- ----

Drive if emergency -

not in school hours 100% 0% 100% 0%

Have a family you will assist in evacuation 50% 100% 75% 60%

Of total responses answered & unanswered -

surveys 4% 8% 16% 10%

i

• Thirty-one did not know of plan and did not respond to survey questions.

S a

27 .

conflict becomes acute in crisis situations. Seventy percent of the bus drivers who said they would drive, also said they have f amilies they will have to evacuate. Unfortunately, the Emergency Response Plans do not account for this conflicting area and assume the bus driver will do their work

-- making several bus trips -- prior to evacuating their families.

l The County plans suggest a bus capacity of 88 persons, which exceeds all state-imposed limits. The survey asked the bus drivers how many students should be on a bus in such an emergency. The responses ranged from 40-80 with an average of 60.5 pupils. This is a far cry from 88, and has a lot more credibility coming from the bus drivers.

One last finding of the surveys which was purely fortuitous was the finding of multi-organizational affiliations. For instance, one bus driver was also a firefighter and Emergency Medical Technician for an ambu-lance. Plan developers included this individual in three resources --

bus driver, firefighter, and ambulance operator. No questions on the survey illicited this response, but the response was written in. There is now an undefinable amount of persons being relied upon to perform many functions.

Bus drivers are the most important link to an evacuation, since approximately 24,000 people without trancportation must be moved out of the 10-mile evacuation zone. The survey indicated several deficiencies in the plan which must be addressed'if the evacuation is to be successful.

One alternative to bus drivers operating the buses is the use of firefighters. The County plans, include the use of firefighters to drive buses which school bus drivers will not drive. Surveys distributed to fire chiefs included the question of using firefighters to drive buses.

Eighty percent of the fire chiefs responding to the survey felt the firefighters should not be driving buses. Firefighters' qualifications for driving buses in an emergency were their experience driving fire trucks

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the same as a fire truck or car. Precautions are unique to buses and without familiarity with them the safe operation of the bus is called into question.

The majority of firefighters are volunteer and will have to be mobil-ized in case of an emergency. Of the Yire department responses from the fire chiefs, only one indicated that the firefighters have agreed to participate in the evacuation plan. Firefighters have many roles in the evacuation plan. In order to rely on their services for carrying out the plan, the County officials must get a commitment from the fire departments.

Futherinore, it must be determined whether the individuals are also affili-ated with any of the other response organizations (i.e., ambulance, bus driver, police) to determine the exact number of personnel. Table 10 has other areas of questioning the survey addresses.

The police surveys reported consistent feelings that the plans are workable on one condition. The condition is that they receive all of the equipment necessary to carry out an evacuation. The police departments

' are attempting to get Cleveland Electric ' Illuminating to purchase all of the equipment. So far, as of this printing, there has been no purchase of equipment.

Ambulance corps surveys revealed that none of the responding companies have procedures for a radiological emergency. Also, none have been contacted about the Ambulance corps role in the evacuation. The plans of all three counties identify the need of ambulances in the evacuation of elderly, handicapped, hospital patients (if the hospital is evacuated), and any emergencies occurring during the evacuation. The need for cooperation in the evacuation planning is a minimum foundation which cannot be over-stated. However, as in the case with bus drivers, no . communication between the developers of the evacuation plans and the ambulanco corps participants

29 .,

TABLE 10 FIRE CHIEF SURVEY RESPONSE

• Yes 3 N/A

>l:f evacuation plan? 80% 20%

.r. feasible? 40% 20% 40%

! hrefighters agreed

r.icipate? 20% 80%

_: thsy drive bus? 20% 80%

rey qualified? 60% have driver's license 20% 20%

and/or drive fire trucks ts ,on trainin9? Not yet

- vehicles to

_7:rt psople needing i assistance? 20% 40% 40%

unity to comment? 60%

40%

.:sfighters'know of i 3 plan? 60% 40%

>: 3.9% of the fire chiefs surveyed. responded.

e S

= "-**9*-w--'--e- e g- --7p, , . , , , , , , . , , , _ , _ _ , , , _ _ , _

, 30 .

were made. This leads to misconceptions about various roles the organizatier.s are to play.

The response, or lack of it, was very disheartening. Especially in the case of nursing homes where no surveys were completed. There is a need to openly confront the issues of the Emergency Plans. A recogniticn of the practical deficiencies and inadequacies must be addressed before it is too late. The licensing process of the Perry Plant will not bring l to light these deficiencies unless the various emergency response . organiza-tions and agencies engage in a dialogue. The Perry Legal Defense Fund surveys succeeded in precipitating the Emergency Plan inadequacies. There must now be some confrontation of the issues in a public forum.

X. QUCyrES FROM VARIOUS SURVEYS When asked, "Would you drive a bus in an ernergency ? " the written comments were:

"As of right now I would. But, two to 10 years from now 1 don't know if I would. Depending upon if I'm expecting .

or if I have a family at that time."

"I have my own family and elderly parents to consider. I am igainst that Perry Plant, and don't want to see it in peration. "

"It was my understanding only Perry drivers would be driv-ing."

i i "Would be glad to help."

t One person, in analogizing evacuation planning in a nuclear accident with nuclear war stated:

" Remember the bomb shelter, this is just another scare tactic."

Another comment read:

"Who 'will pay to replace contaminated equipment? The consumer, of course. They'll (CEI) just go to the PUCO (Public Utilities Commission of Ohio) well again, and the PUCO better get this message loud and clear, the well is dry. This plant is obsolete."

31 .

"If there is an accident, I feel no one will be alive to tell about it."

"I'll be busy getting my family out. When all the utility execs and their families and the NRC and their families move into the shadows of the cooling towers of a nuclear plant, call me, and I'll help them get out, not until then. I will volunteer in any natural disaster, not man-made with such a wide area for human error."

e 9

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REFERENCES

1. NUREG 0396. Planning Basis for the Development of State and Local j Government Radiological Emergency Response Plans in Support of Light l Water Nuclear Power Plants, December, 1978.

2. NUREG 0654. Guidelines for Preparation and Evaluation of Radiolo-gical Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, 1980.

3. EPA 520/1-75-001. Manual of Protective Action Guides and Protective 1

-Actions for Nuclear Incidents, September, 1975, revised June, 1980.

I

4. NUREG/CR-ll31, Examination of Offsite RadiologicalEmergency Protective Measures for Nuclear Reactor Accidents Involving Core Melt, 1978.

5. 1980 Report on Biological Effects of Ionizing Radiation.

6. John Gofman, Radiation and Human Health, 1980.

7. WASH 1400, Reactor Safety Study, 1975.

8. NUREG/CR 2591, " Estimating the Potential Impacts of a Nuclear Reactor Accident," 1982.

9. NUREG/CR 2723, " Estimates ' of the Financial Consequence of Nuclear l Power Reactor Accident," Saudir, 1982.

I 1

10. Code of Federal Regulations. Section 10, part 50; Section 44, sub-chapter E, chapter 1, part J50; Section 44, part 351.

11. Emergency Plan for Perry Tuclear Power Plant Units 1 & 2.

l

12. Ashtabula County Radiological Emercency Response Plan.

13. Lake County Radiological Emergency Response Plan.

14. Geauga County Radiological Emergency Response Plan.

SERVICE LIST Peter B. Bloch, Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20553 Dr. Jerry R. Kline Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Glenn O. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

- Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Colleen P. Woodhead, Esq.

i Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jay Silberg, Esq.

1800 M Street, N.W.

Washington, D.C. 20036 4 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Susan L. Hiatt 8275 Munson Road Mentor, Ohio 44060 Christine N. Kohl, Chairman Atomic Safety and Licensi.ng Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. John H. Buck Atomic Safety and Licensing Appeal Board ,

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gary J. Edles, Esquire Atomic Safety and Licensing Appeal Board U.S.' Nuclear Regulatory Commission

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