“The majority of emergency responders feel vastly underprepared and under-protected for the consequences of chemical, biological, or radiological terrorist attacks,” says a RAND study issued Aug. 20, 2003.
In trying to anticipate their response to terrorism, emergency workers “felt they did not know what they needed to protect against, what protection was appropriate and where to look for it,” the report says. The groundbreaking RAND study, which is one of the most in-depth ever conducted of emergency workers, is based on interviews with 190 first responders from 83 organizations around the nation.
An attack, or an accident for that matter, can happen. Therefore we need emergency plans that will provide a ‘reasonable assurance’ that those likely to be impacted can be protected. Currently, planning does not provide assurance. On August 1, 2002, Governor Pataki of New York commissioned an independent review by James Lee Witt Associates [James Lee Witt was the Director of FEMA under President Clinton] to evaluate the ability of Indian Point’s off-site emergency plan to protect the public from a release of radiation from the plant. Because every state’s plans must meet the same federal rules and guidelines, plans are similar state-to-state. Therefore lessons learned from NY are applicable here. The Witt Report  was released on January 10, 2003. The review’s conclusions are decisive, irrefutable and inescapable. With regard to the aproblemsa associated with the emergency plan, Witt Associates states that “…it is our conclusion that the current radiological response system and capabilities are not adequate to overcome their combined weight and protect the people from an unacceptable dose of radiation in the event of a release from Indian Point, especially if the release is faster or larger than the design basis release.”
The assumptions underlying planning do not respond to present day circumstances.
- Plans assume that data regarding the status of plant conditions, radiological release and weather are reliable, accurate and timely. There is no automated, real-time monitoring of radioactive releases from the stacks and major egress routes at Pilgrim, VT Yankee or Seabrook hooked to MDPH, MEMA, and local communities. The state is dependent on the licensee’s reports and accuracy of the licensee’s equipment. Local communities are dependent on the state’s interpretation of those reports. The state sends a team to take samples and sends those samples back to state labs for analysis. However that takes time – too much time.
- Plans do not include emergency response plans [evacuation and sheltering] for residents outside the 10-mile EPZ. This is not reasonable. A core melt at Pilgrim, VT Yankee and Seabrook were calculated by the federal government  to result in the following. PEAK FATAL RADIUS (MILES)
Pilgrim = 20 ML; Seabrook = 20 ML; VT Yankee =15 ML PEAK INJURY RADIUS (MILES)
Pilgrim = 65 ML; Seabrook = 65 ML; VT Yankee =35 ML PEAK CANCER DEATHS
Pilgrim = 23,000; Seabrook = 6,000; VT Yankee = 17,000 Academic research, Dr. Donald Zeigler, after Three Mile Island and in NY showed that people living well beyond 10-miles evacuated – the shadow evacuation. If their evacuation is not planned for, they will effectively place a ‘cork in the bottle’ and those in the core will not be able to evacuate in a timely fashion.
- Plans do not consider the possible additional ramifications of a terrorist caused release; fast breaking accident from another cause; or, accident with considerable radiation release.
- The NRC has stated that a significant release can occur within two hours from the start of some accidents and a terrorist strike could shorten that time.
Precisely how long does MA assume that there will be between activation of the plan and radiological release? How long does the state assume that it will take to evacuate the 5-mile radius and the 10-mile radius?
- Pilgrim, VT Yankee, Seabrook’s spent fuel pools contain many times more high level radiation than was released in the Chernobyl accident – an amount sufficient to contaminate an area 3 times the size of Massachusetts
- Plans appear based on the premise that people will comply with official government directions rather than acting in accordance with what they perceive to be their best interests (example, plans assume parents/guardians will not go to schools to pick up their children); plans do not consider the reality and impacts of spontaneous evacuation from inside and outside the EPZ.
- Plans assume that wind direction remains fairly constant. Therefore personnel (police for example) and busses for the transportation dependent are assumed to be available from one part of the EPZ to another part of the EPZ in an emergency depending on direction of wind. Instead, they should be exclusively dedicated for each area.
- Coastal winds especially are variable so that you can not simply evacuate one sector and not others. Weather changes often suddenly, everywhere.
- Plans assume emergency workers will respond, even those without protective gear. The DPW who are expected to clear roads do not have protective gear, neither do police or other emergency workers. When their dosimeter badge maxes out, they are instructed to leave for monitoring and decontamination, out of town. Who will do their job? This is especially important when the state and towns are under severe fiscal restraint and staffing has been cut across the board.
- Planning assumes that response exercises designed to test the plans are accurate measures of readiness.
- Exercises are of limited use in identifying inadequacies and improving subsequent responses
If the Emergency Call is to Evacuate
- How long? The plan assumes that those outside the 10-miles will not evacuate – that there will not be a ‘shadow evacuation.a Not true. Academic research, Dr. Donald Zeigler, after Three Mile Island and surveys done in NY showed that people living well beyond 10-miles evacuated – the shadow evacuation.
- Not planning for the inevitable shadow evacuation will mean that those in the core will not be able to make a timely evacuation – a cork will be placed in the bottle.
- Transportation dependent – bussing school children and those without cars in an evacuation. In order for the EPZ towns to have “reasonable assurance” all towns should see, annually, the contracts between the state and bus/van providers, the transportation work sheets and the matrixes. Only in this way can each town be certain that the following is in order: number busses available during off business hours and business hours, their capacity, number drivers agree to come, trained and have pagers so that they can be contacted off-hours in a timely fashion, communication capability on busses, where they are dispatched from, estimated mobilization time. This is the information that each town needs. Transportation providers must be mobilized at the Alert Stage of an accident – defined as sent out and to arrive on location. If plans wait until a later stage of an accident, they will arrive too late. If the accident de-escalates, the busses can be called off and at worse a real-time response drill can be achieved.
- Location Reception Centers: they are within the peak injury radius, how can we assume that the public can be decontaminated there? Exactly how far are Pilgrim, Seabrook, VT Yankee’s EPZ Reception Centers and Host Schools from the reactor?
- How many evacuees can they handle? The plan assumes that only one in five (20%) will go to the Reception Centers.
- Where are the others supposed to get monitored and decontaminated?
- How is the state going to prevent those people from contaminating other areas, if they arrive in ‘clean’ areas ‘dirty?’
The plan assumes that children will be evacuated from school before parents and the general public learn about the accident. – What about cell phones and pagers?
- Monitoring School Children: The plan says that it is the state’s call whether the children will be monitored for contamination or whether they will simply go straight to the host school. This assumes that the state’s information on dose and weather, which is based on the licensee’s reports, is 100% accurate. Better safe than sorry when it comes to children’s health. It would make sense to require that children are monitored automatically when evacuated for a radiological emergency.
- KI is not stockpiled at the Reception Centers Federal studies indicate that at 25 miles from the site 80% of exposed children will develop thyroid cancer/disease and it is more aggressive in younger children. KI must be administered before or shortly after exposure. It must be in place. Therefore doesnat it make sense to ask that KI be stockpiled at the Reception Centers?
- Hospitals The number of hospitals identified to treat contaminated and injured is inadequate. Issues not adequately addressed include, for example: availability of radiation monitors; decontamination capability (bladders to collect contaminated water so as not to contaminate local supply); capability to isolate contaminated from rest of hospital population; stockpiles of potassium iodide. If Emergency call is to shelter: sheltering may be short or extend to up to a few days
- Town Shelters: The EPZ town shelters have not been analyzed for dose reduction capability – inclusive of their interior spaces.
- Schools as shelters when school is in session: Plans now call for schools to be used by the public – even when school is in session. However when there is a call to shelter, the state recommends locking doors and shutting windows and ventilation to keep contamination out. If the public comes to the school and opens the door to either shelter or get their children, radiation will enter and harm those inside. It makes more sense to have a lock-down at the schools if the emergency call is to shelter. Sheltering instructions for the public: The instructions imply that one type of building is as good as another and that spaces inside each building are equally protective. This is not true. Therefore it makes sense to give the public more accurate and detailed instructions and place those instructions in the Emergency Calendar and media. For example, windows do not protect against radiation. Therefore folks should be instructed to go to an interior space or to sit below window level.
- Does the plan say that men and women of childbearing age are permitted to opt out of volunteering in an emergency? If so, what percentage do they represent among the teachers, EMT’s, police, emergency workers, bus drivers, nurses? How many are left? What about replacements and are they set up?
- How many are trained and agreed to participate in each town department? Is this number ascertained, annually? Where is the data for the public to see?
- Do all emergency workersor town employees expected to play a roll by notifying or assisting citizens out-of-doors have protective gear – KI, dosimeters, 3M masks, clothing to cover body and masking tape to seal cuffs?
Emergency Response Tests As pointed out by James Lee Witt, former Director of FEMA, in a report for the State of New York, today’s plans and tests of emergency plans are not adequate to meet today’s threats.  Review of Emergency Preparedness at Indian Point and Millstone, James Lee Witt Associates, LLC, Washington DC, January 2003.  Calculation of Reactor Accident Consequences, U.S. Nuclear Power Plants (CRAC-2), Sandia National Laboratory, 1982. aPeaka refers to the highest calculated values – it does not mean worst case scenario. This is due to uncertainties in the meteorological modeling acknowledged by Sandia. The model only considered one year’s worth of data and does not model for precipitation beyond a 30-mile radius. This is significant because the highest consequences are predicted to occur when a radioactive plume encounters rain over densely populated area. Peak Early Fatalities are deaths that result within the first year. Peak Early Injuries are radiation-induced injuries occurring in the first year that require hospitalization of other medical attention such as sterility, thyroid nodules, vomiting and cataracts. Peak Cancer Deaths are predicted to occur over a lifetime. However, this is not the case with leukemia which is assumed to have occurred within the first 30 years following the accident.