ACE Video/Blog – Part 7
April, 2013

ACE ANALYSIS OF:
Exelon’s Evacuation Time Estimate (ETE) For Limerick Nuclear Plant’s Plume Exposure Pathway Emergency Planning

ACE requested a copy of Exelon’s most recent 12/12 “Evacuation Time Estimate” (ETE), hoping to find ways to improve on unprotective evacuation plans for Limerick Nuclear Plant. Unfortunately, after careful review of Exelon’s ETE, we are more concerned than ever. This report confirms that safe and timely evacuation is an illusion.

This plan will result in extended radiation exposures, further jeopardizing health and safety for millions in the Greater Philadelphia Region, in the event of a Limerick Nuclear Plant radiation accident / meltdown.

Exelon’s ETE is self-serving fiction based on unrealistic, unworkable suppositions, assumptions, inconsistencies, and inaccuracies, with fact-free spin and illogical conclusions. Exelon’s letter accompanying its ETE concludes with: “There are no commitments in this letter”. That disclaimer speaks volumes.

Exelon’s ETE is a logistic fantasy that is clearly not either realistic or feasible. NRC officials for Limerick had not even evaluated Exelon’s ETE as of the NRC meeting 3-21-13. Any elected official in the region who reviews Exelon’s ETE objectively, should be alarmed. Exelon’s 12/12 ETE should be rejected by elected officials and NRC.

Elected and agency officials knew in 1980 that the population density around Limerick made safe evacuation impossible. They should have stopped Limerick construction. Since 1980, the region’s population soared, making an impossible situation far worse. It’s long past time for elected officials and NRC to protect the public’s health and financial interests, instead of Exelon’s profits.

Based on the impossibility of safe evacuation, NRC can and must shut Limerick down before it melts down.

OF GREATEST CONCERN: CHILDREN
More Than 65,000 Children In Limerick’s 10-Mile Evacuation Zone (Attending Over 230 Schools and Day-Cares) Could Be Transported To Reception Centers Just Outside Limerick’s 10-Mile Evacuation Zone.
Reception Centers Would Likely Still Be In Limerick’s Radioactive Plume.

MOST CHILDREN COULD BE TRANSPORTED TO RECEPTION CENTERS STILL IN LIMERICK’S RADIOACTIVE PLUME .

TO HAVE ANY HOPEOF MINIMIZING RADIATION EXPOSURE FOR OUR CHILDREN, RECEPTION CENTERS FOR EVACUEES SHOULD BE PLANNED AT LEAST 50 MILES AWAY BASED ON EVIDENCE FROM CHERNOBYL AND FUKUSHIMA.

• Based on evidence from Fukushima and Chernobyl meltdowns, Limerick Nuclear Plant’s 10-mile evacuation zone must be increased to at least 50 miles to keep vast numbers of children from unnecessary radiation exposure and the many health harms, including cancers, that would result from a Limerick Nuclear Plant radioactive accident / meltdown.

• Exelon’s ETE for Limerick, Unnecessarily Exposes Far Too Many Children To Limerick’s Radioactive Plume For Far Too Long. Reception centers are not far enough outside the 10 mile EPA. Most would still be in Limerick’s radioactive plume. Many mass care centers planned for Limerick evacuees could also still be impacted by Limerick’s radiation.
­
Evidence from Chernobyl and Fukushima meltdowns prove evacuating children just beyond 10 miles is negligent. NRC evacuated U.S. citizens that were within 50 miles of the Fukushima meltdowns.
­Children far outside Fukushima’s 12-mile evacuation zone experienced radiation sickness symptoms.
­Children over 40 miles away have radiation in their bodies at doses 20 times above recommended safety limits. Vast numbers of Chernobyl children, far distances from the meltdown, experienced devastating diseases and disabilities, especially leukemia, other cancers, and heart problems. See ACE Blog #4 about what really happened at Fukushima and Chernobyl www.acereport.org

• Exelon’s ETE plus ACE’s school mapping of Limerick’s 10-mile evacuation zone show there are over 230 schools, pre-schools, and day-care centers. It is difficult to account for all public and private pre-schools, day-cares, and schools. Most day-cares and pre-schools have no emergency plans.

• Some school districts straddle the 10-mile EPZ radius. That creates a different set of problems.
­For example, parents of Methacton School District students believe that all of the school district is in the evacuation plan because all schools in the district are included on Exelon’s mailed evacuation brochure. However, Exelon’s ETE, which most parents won’t see, places Methacton High School outside Limerick’s evacuation zone. This causes confusion for school district officials, parents, teachers, and students.

SCHOOL BUSES

 IT APPEARS EXELON’S ETE GROSSLY OVERESTIMATES SCHOOL BUSES AND CERTIFIED DRIVERS AVAILABLE FOR EVACUATION.

• Over 65,000 children would need to be evacuated.
• All children are assumed to be evacuated from all schools simultaneously. However, in reality, there are not enough school buses or certified drivers to evacuate all children from all schools simultaneously.
• We can only conclude that thousands of children would be left behind. Currently, many school busses make two separate trips every day – 1 trip for Elementary and 1 trip for Secondary Schools Within Districts. This fact is not addressed in Exelon’s ETE. Currently, public school districts are also responsible for bussing private school students. This factor is also not addressed. Complicating the problem, many bus drivers admit they wouldn’t return for a second trip.

DISCREPANCY:

1,224 ESTIMATED BUSES NEEDED (Page 1-9)
1,388 CHARTED BY SPECIFIC SCHOOLS (Pages 6-18 to 6-22)

PROBLEMS BEYOND THE 164 – BUS SHORTFALL:
• NO buses or drivers are planned for the schools and day-cares missed by Exelon’s ETE.
• Availability of certified licensed school bus drivers assumed in Exelon’s ETE is questionable at best.
• Assumed vehicle availability along with perfectly modeled traffic patterns make this ETE unworkable to protect children in a Limerick radiation accident / meltdown.
• Residential students from the Hill School and Ursinus College (possibly well over 1,000) are not even included in Exelon’s Time Estimate.

DISCREPANCY:

WHY SUCH A HUGE DISPCREPANCY WITHIN EXELON’S ETE?
­ Page 6-17 Itemized Total 1,706 Vehicles Needed For Hospitals, Nursing Homes, Retirement Communities and Other Special Facilities
­ Page 1-9 Their narrative total for the current study shows 442 vehicles needed

EXELON’S ETE ESTIMATES FOR AMBULANCES AND VANS:

 1,706 AMBULANCES and VANS NEEDED
(To Assume That Such A Large Number Would Be Available Simultaneously Defies Logic.)

EXELON’S ETE CONVERSELY CLAIMS:

 ONLY 442 AMBULANCES AND VANS ARE NEEDED (PAGE 1-9),

EXAMPLES FROM THE ITEMIZED LIST OF 1706
 Pottstown Hospital – ETE Lists 332 Ambulances / Vans Needed
 Phoenixville Hospital – 82 Ambulances and Vans

Pottstown Hospital Is Within 1 Mile Of Limerick. Phoenixville Hospital Is Also Within The 10-Mile Zone. Both Would Need To Be Evacuated Immediately.
Exelon’s ETE says 332 Ambulances / Vans would be available for Pottstown Hospital, and 82 would be available for Phoenixville Hospital.
­ Where would all these Ambulances / Vans, and Drivers come from to evacuate simultaneously?
­ There is no medical reception center specified in Exelon’s ETE to accommodate large numbers of patients requiring specialized care. Where would so many patients from several hospitals and nursing homes be evacuated to?
­ Some patients could become highly radioactive during an extended evacuation and be rejected by hospitals or other facilities, as the radioactive people were in Japan.

EXAMPLES FROM THE ITEMIZED LIST OF 1706 ALSO INCLUDE:
 Montgomery County Rehabilitation Center – 330 Ambulances and Vans
 Veterans Center – 146 Ambulances and Vans

INCONSISTENCY WITH PRISONS

Montgomery County Prison – 100 Vans and Buses (1,200 Inmates)
­ Where will all these prisoners go? There is no destination designated for these prisoners.

Graterford Prison Would NOT Be Evacuated. Instead Graterford Prisoners And Guards Are Supposed To Shelter In Place.
­ There is no mention of what will happen with guards and other prison employees.
­ How will prisoners sustain themselves if all employees evacuate?

Exelon’s ETE States 1,706 Ambulances and Vans Would Be Available Simultaneously To Evacuate In A Timely Manner.

 ACE’s CONCLUSION:
To assert that 1,706 ambulances and vans would be available simultaneously is beyond irresponsible.

OTHER CONCERNS:

EXELON’S ETE UNDERESTIMATES TRANSIT-DEPENDENT POPULATION:

Exelon’s ETE drastically underestimated people without cars in places like Pottstown, Royersford, and Collegeville.

• Exelon’s ETE Listed Only 4500 People (.015% of 292,061 Population) As Transit Dependent Population Determined To Be Within Limerick’s 10 Mile Evacuation Zone By Exelon’s Report (Section 5.3 on Page 5-3)
­4,500 is .015% of the estimated 292,061 population, a gross understatement of what could be a significant need.
­ Exelon’s report unbelievably suggests that 99.985% of people in Limerick’s 10-mile evacuation zone would have access to vehicles to evacuate.
­ Exelon’s ETE requires 150 Bus Trips To Evacuate People With No Transportation (Page 1-9).
 ACE CONCLUSION: This defies logic!

EXELON’S ETE MUNICIPAL PICK-UP POINTS ARE UNREALISTIC
• The ETE required residents to call township, borough, or local officials to find out schedule of pick up points.
­ People who work for boroughs and townships are likely to want to evacuate immediately with their families, not man phones.
­ PROBLEM: The list of municipal pick-up points that are in Exelon’s mailed brochure for Montgomery County are all in Pottstown. What happens to people in Royersford and Collegeville? If they have no transportation, how do they get to Pottstown?
­ If the radiation accident / meltdown occurs from a natural disaster like an earthquake, contacting officials could become impossible because of loss of power.

EXELON’S ETE TELEPHONE SURVEY THAT WAS THE BASIS FOR DETERMINING RESIDENTIAL VEHICLE AVAILABILITY WAS NOT REPRESENTATIVE.

• Telephone Survey On Residential Vehicles Available For Evacuation (Appendix B – Pages 1-7)
­ The sample was too small to make valid conclusions.
 Only .001 % of residents responded.
 Only 317 responses were analyzed out of 292,000 total households.
 Approximately 64% of the 317 were 55 years old or older.

- Survey Questions Failed To Accurately Identify Residential Vehicle Needs
 Survey questions were centered on who in the family is working, how many vehicles they have, how long it would take to get to work and home, and what shift people worked.
 ETE surveyors should have asked if that resident would have another vehicle available if other family members didn’t come home.
PROBLEMS:
 Questions were omitted concerning household vehicles used by workers who were teachers or healthcare workers required to stay with students or patients by Exelon’s ETE.
 Teachers would go to host center with students. Health care workers are expected to stay with patients or shelter in place.
 Prison workers would be required to evacuate with prisoners or shelter in place with them.

ETE’S BLINKING LIGHTS AT INTERSECTIONS COULD CONTRIBUTE TO CONFUSION, CONGESTION,AND ACCIDENTS.

• Blinking Lights – (Page 4-2)
Exelon’s ETE Requires Manual Override of Traffic Lights by Undesignated Officials, supposedly to alleviate bottleneck points. In reality, under emergency conditions, a blinking signal would not alleviate congestion, but instead contribute to confusion, increased congestion, and accidents.

CONFUSION CREATED BY EXELON’S ETE HINDERS SAFE LIMERICK NUCLEAR PLANT EVACUATION

• Traffic Congestion – (Page E-3)
The ETE fails to assume worst case scenarios where traffic is stopped all together by adverse weather conditions or traffic accidents. At the most it assumes that the worst case scenario would add only 160 minutes due to adverse winter weather.

• Traffic Estimates for Employees of Many Businesses Were Excluded From Total Vehicle Estimates (Appendix A, Page 6 of 13)
­ For example: Under the list of major employers, many businesses which contribute to traffic congestion are excluded, including diners, restaurants, convenience stores.
­ Examples: Costco, Wawa and Turkey Hill Convenience Stores, Gas Stations, Banks, Car Dealers, Movie Theaters, Restaurants, Library
­ Numbers of vehicles from these businesses would clearly affect roadway congestion and traffic patterns during evacuation.

• Recreation and Shopping (Appendix A Page 8 of 13)
­ Estimates for numbers of people at shopping centers appear to be substantially underestimated.
­ Some parks have been overlooked. For example, Manatawny Park, Riverfront Park in Pottstown, Manderach Park in Limerick, and other local parks.

• Train Traffic – Possible Complications Not Addressed
­ There seem to be NO specific plans addressing train traffic for some of which carries hazardous materials, that goes through the Limerick site.
­ Would train traffic be stopped to facilitate evacuation?

Problems Created By Exelon’s ETE Faulty Assumptions:

• The worst problem of all is that this report places little priority on limiting radiation exposure to evacuees.
• Exelon’s ETE covers a 16-hour evacuation period (Appendix D – Maps of Average Speed by Hour for Road Network Pages 1-16.
• Each hour of exposure to Limerick’s radiation during an accident / meltdown critically impacts the health of residents, especially fetuses and children.

• Exelon’s ETE is a shameless sham that satisfies a regulatory requirement with little regard for reality. Exelon’s ETE includes 100 pages of filler devoted to the unrealistic expectation that its assigned speed limits will be maintained during evacuation on the roads listed and that volumes of traffic will not be exceeded. (Appendix C – Roadway Network Data Table – Pages 1 to 100)

• Exelon’s ETE allows too much time to elapse between public notification and actual evacuation.
­This is about radiation exposure. Yet, initial notification could bypass residents until a response work force is brought in. People living near Limerick would be exposed to radiation the whole time, as long as that takes. (Section 5.2 – Page 5-3) The ETE time lapse warning process means the last 10% to 20% of the population learns too late that an evacuation order has been given.

• Time estimates are based on Exelon’s self-serving proposition that there will be no deviations from the plan. Survival instincts will compel people to flee in ways not anticipated in this ETE.

• Exelon assumes school, hospital, and other employees are going to abandon their loved ones to get on buses and ambulances and follow this plan to the letter. Exelon requires people to abandon their natural instincts to care for their families.

ACE Conclusions:

Exelon’s Self-Serving ETE Is Unworkable, Unprotective, and Irresponsible.

Exelon’s ETE confirms that Exelon still has no plan to safely evacuate the millions of people surrounding Limerick Nuclear Plant.

Exelon hasn’t produced an evacuation plan that ensures safe, timely evacuation from within 10 miles of Limerick Nuclear Plant.

Therefore, it is impossible to produce a plan for a 50-mile evacuation zone, which Fukushima has proven is minimally necessary to protect public health and safety..

To prevent unnecessary environmental devastation and health harm for millions, Limerick Nuclear Plant should close as soon as possible to prevent such a catastrophe from happening in the first place.

To Better Understand What We Could Face After A Limerick Radiation Accident / Meltdown, See ACE Video Blog At www.acereport.org – Part 4, For The Truth About Consequences Of Chernobyl and Fukushima Meltdowns.

Major Problems With Limerick’s Current Evacuation Plan:

1. A broad range of extremely dangerous radionuclides would be released in the radiation plume from a Limerick accident/meltdown. Yet, Exelon’s ETE is not based on radiation exposure risk. Emergency workers are not required to practice for a radiological event. This ETE shows why vast numbers of people would be harmed, why Limerick must close to prevent this unnecessary risk, and why even after Limerick is closed we must have truly effective evacuation plans.

2. NRC Should Require Exelon To Notify The Public Immediately In The Event Of A Limerick Nuclear Accident / Meltdown. Radiation Releases Could Start Within The First 1/2 Hour.
• PROBLEM: Radiation is invisible. You can’t smell it, taste it , feel it, or see it.
• NRC should not allow Exelon to wait hours or days. It took 3 days before officials told people to evacuate after TMI.
• Radiation sickness symptoms that would occur within 1 to 24 hours would mimic flu-like symptoms (nausea, vomiting, diarrhea, headache, fever). People wouldn’t realize it was from radiation exposure.
• Exelon’s track record suggests the public won’t be notified until Exelon can no longer hide the accident and can manipulate the messaging. For example, Exelon waited 23 days to notify the public about the 3-19-12 radioactive spill into the drinking water for almost 2 million people from Limerick to Philadelphia.
• Likely, there wouldn’t be an explosion. Increasing radiation could be pouring into our air and water, poisoning us and our life support systems, and go undetected by us. Radiation is invisible and odorless. We can’t see, smell, taste, or feel radiation.
• Radiation exposure symptoms within 1 to 4 weeks could also mistaken for other problems (dizziness, disorientation, weakness, fatigue, bloody vomit and stools, infections, poor wound healing, low blood pressure, and hair loss).
• Long-term radiation damage, such as tumors and cancer, could take years to develop.
• To minimize disaster, immediate evacuation is imperative and the public must heed the first warnings. This statement was made after Fukushima by Michael Chertoff, previous Homeland Security director.

3. Evidence proves Limerick Nuclear Plant’s radiation plume would travel far beyond our current 10-mile evacuation zone, yet:
• NRC is inexplicable and negligently refusing to expand Limerick’s evacuation zone to 50 miles as they did for U.S. citizens in Japan after Fukushima meltdowns.
• NRC is also refusing to expand our ingestion pathway zone from 50 to 100 miles, even though soil, food, water, buildings, animals, and people have documented to be radioactive far beyond 50 miles in Japan.

4. Evidence from actual meltdowns shows most people would be evacuating to centers inside highly radioactive areas, even though they go outside the 10 mile evacuation zone from Limerick.
• Children are the most impacted victims, far more vulnerable to impacts of radiation than adults.
• Children should be moved as far as possible, at least 50 miles away from Limerick in a radiation accident / meltdown.

5. A massive population would be trying to move on over-crowded roads where there would likely be bottlenecks and accidents that would extend the time people are forced to be exposed to Limerick’s radioactive plume,
• There would be widespread chaos, fear, and anxiety.
• Bus Drivers, first responders, and police would face enormous challenges as they attempt to manage and control certain chaos and gridlock on virtually every road in the region.

ACE talked to vast numbers of people in the community. Below are concerns expressed by some of them.
Many people do not realize what would be expected of them.

For example, ACE found most people would expect to evacuate with their families. However, workers at many institutions will be expected to remain behind to care for children, the elderly, prisoners, or patients.
• Health care staff would be expected to remain at their facilities to assist in the care and supervision of patients.
• Teachers would be expected to travel with their children to the locations just outside the 10-mile zone – likely still in the radioactive plume.
• Some prison workers would be expected to shelter in place with the prisoners.
• Municipal office workers in the heavily populated towns (where many people have no cars, like Pottstown, Royersford, Phoenixville, etc.) would be expected to remain in the building for hours, taking calls directing people to locations to wait for buses to evacuate them. Buses likely won’t even come for many.
• Pre-school workers would be expected to remain with the children until parents get there to pick up their children. That could take hours or may be impossible due to chaos.

Assumptions that just won’t work in reality:

• By the time people are notified, they will already have been exposed to radiation releases. Radiation can start escaping in the first 1/2 hour after an accident, but Exelon is not required, and likely won’t, immediately notify the public. People remained unnecessarily exposed far too long before being told to evacuate from Chernobyl and Fukushima.
• Hospitals would be unprepared and unable to treat so many victims of radiation sickness. Some victims could become so radioactive they would be turned away from hospitals and emergency care facilities outside the evacuation zone, as happened in Japan.
• Evacuation plans for schools assume parents will not rush to pick up their children. That just isn’t realistic. Most parents say that is just what they will do.
• Some school plans are contradictory. One school sent home a letter stating parents couldn’t pick up their children, but also told parents where to wait when picking them up.
• Most school bus drivers say that even if they could transport their first load of children to reception centers, they wouldn’t and couldn’t come back for the second.
• Emergency responders may be out in radioactive plumes for hours.
• There are not enough qualified drivers for school buses, ambulances, and other emergency vehicles, even if there were enough vehicles (which there are not).
• There are conflicts of roles for police officers, bus drivers, and first responders. They face challenges of whether to save themselves and their families or stay and save others. This becomes most difficult with a nuclear accident spewing radiation into the air.

CONTACT ALL ELECTED OFFICIALS

URGE ALL OFFICIALS TO:

1. DEMAND THAT LIMERICK NUCLEAR PLANT CLOSE AS SOON AS POSSIBLE TO PREVENT A MELTDOWN

UNTIL LIMERICK CLOSES DEMAND:

2. IMMEDIATE NOTIFICATION OF LIMERICK RADIATION ACCIDENT

3. EVACUATION ZONE EXPANDED TO 50 MILES

4. INGESTION PATHWAY ZONE EXPANDED TO 100 MILES