ML20028G220

Affidavit of El Duncan Re Emergency Info Brochure.Brochure Violates Keep It Simple Stupid Principle. Method of Brochure Distribution Faulty.Certificate of Svc Encl.Related Correspondence

ML20028G220
Person / Time
Site:	Waterford
Issue date:	01/26/1983
From:	Eric Duncan AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 8302070532
Download: ML20028G220 (4)

Text

• '

. . , -- +

.323 7

??~ ggbE0g>GO p yDENCE ,

h UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSId86 g Before the Atomic Safety and Licensing Board 9', - . . .

In the Matter of )

in jd h"

) Docket No. 50-382 LOUISIANA POWER & LIGHT CO. )

) January 26, 1983 (Waterford Steam Electric Station )

Unit 3)

AFFIDAVIT OF EARL L. DUNCAN GQNGEBU1Ng 105 EMEBGEUQY INEgBMBIlgN BBgGHUBE

1. Please describe your educational and professional background.

60swgtz My educational and professional background was described in my aff.4 davit previously furnished to the Board.

2. Have you examined the preliminary draft of LP&L's emergency evacuation plan?

60swfCs Yes, I have.

3. Would you please give your professional opinion of this br 7chure?

80swett This is an apparently fragmented Emergency dvacuation Plan published by LP&L. Final comment must await the completed product. It consists of a " safety information" sheet and a piece of paper labelled

" color sketch", which displays a map which does not correspond to the map on the " safety information". It is not clear which map will be printed on the final brochure. The brochure cannot be definitively evaluated until LP&L presents a final product showing which map will be used and what the special needs card will say. Both maps are deficient as presented. The special neers card must be evoluted together with the brochure.

Criticism from Joint Intervenors has resulted in some improvement on the original brochure, but major deficiencies remain.

Personnel in the Army involved in Plans, Operations, and Training are given a small card with the acronym KISS printed on it. KISS is " Keep It Simple Stupid." This brochure violates this principle. After studying the material listed above, I am confused.

The evacuatien plan should be pocket sized and be hand-delivered to residents and new arrivals in the area by personnel who are able to explain the hazards of radiation and evacuation procedures. When mailed, the. plan will probably end up in the garbage can. Delivery by an individual will give the recipient an opportunity to,ask questions and to feel that he is e part of the evacuation plan.

The brochure takes a "Pollyanna Approach" as to who would be affected by a nuclear accident. The ten mile radius is questionable. This failure to " level" with the public concerning the danger of a nuclear accident not only undermines public confidence in the evacuation plan, but also indicates that LP&L does not regard a nuclear accident as ser qps business.

The only section of the brochure which educates the pub. em * 'wQy they must evacuate is contained in a small portion of one of the 16 panels of the evacuation plan brochure. The material contained in this panel which would warn the public that a nuclear accident at Waterford 3 will be a B302070532 830126 PDR ADOCK 05000302 n G PDR gSQ3 -

i

$$$? "

thy r

danger to them is printed in small single spaced type, the least conspicuous type in the entire brochure. LPLL's Pollyanna approach is shown in the statements that "sometimes you must be careful how much of this radiation enters your body." This statement is misleading to the public and will be recognized as LP&L propaganda by some people. It encourages less knowledgable residents not to take a nuclear accident and evacuation seriously.

The statement that "your house or other buildings can often be a good shelter" from too much radiation leads people to believe that they will probably not need to evacuate. The statement that in an emergency you "may" have to do certain things is not accurate. In an emergency residents "will" have to do something.

These types of statements show that LP&L is more interested in its public relations image than an ef f ective evacuation plan. The public should be informed of the dangers of exposure to radiation by a simple direct statement in conspicuous type - Excessive exposure to radiation can cause injury, cancer, or death. This statement informs the public why they should evacuate.

The inclusion of all four categories of nuclear power plant emergencies is questionable. As the public will not be requires to do anything in an ' unusual event", this material does not belong in an evacuation brochure - Remember the KISS principle. It would be preferable to describe emergencies in simpler terms such as red alert - requiring evacuation and yellow alert - stand-by, take precautions, but don't evacuate yet.

The description of the plant and the bold print discussing radiation are irrelevant to the brochure as in the statement that the NRC and the EPA have determined that "you will most likely not have to do anything."

People have a natural reluctance to leave their homes even in an emergency. The brochure's Pollyanna approach to radiation and nuclear power plant accidents will encourage people to belive that they de not need to evacuate. The logistics of evacuation are dif ficult enough r. hen everyone is cooperative; evacuating a population forcibly is far more difficult and is a different matter.

The " Protective Action Sectors" is limited to the extent that people can follow written instructions; illiterates ar.d persons with limited education will not be able to follow these instructions. Only individualized instructions can determine whether these oersons understand the instructions well enough to follow them correctiv in any emergency.

The chart for the 16 sections around Waterford 3 is too complicated for the' general public, especially those wi th less than an 8th orade education. These residents and other people who have poor reading ability will not be able to understand where they are supposed to go in an evacuation. Each individual in the evacuation area should be persontily furnished a map showing instruction for his zone alone, It would bo preferable to use line rcute maps for each area with the -

information in graphics and colors. Psrsons in the evacuation area should be issued a checklist of what supplies they will need if evacuated from the danger area. A state or parish agency would keep a carrent und updated list of persons reeedina transportation. Some may not have telephones, requiring individual attention to their evacuation. It is confusing that the brochure

---

'w o hnnac nnt be used, while the evacuation plan requires certain

- a- a----.

k . .

e for school children to be evacuated to a different locations than their

. parents is not practical. This will cause mass confusion. The brochure fails i to state where medical facilities, doctors and nurses, and first aid l stations will be located. It makes no reference to the provisions for

obtaining prescription drugs. These deficiencies undermine confidence in the

[ evacuation plan and cause people to Jisregard other information and g instructions in the brochure.

2 In my experience an evacuation plan must speak directly - remember j KISS - and to the educational level of all persons executing it. The LP&L a

brochure ignores these fundamental principles.

! In summary, the method of distributing the brochure is f aulty and I will result in most persons within the evacuation area being unf amiliar with j

the contents of the brochure and the procedures they, their children, and r relatives are expected to follow during an emergency evacuation. A large '

L percentage of those persons who do not immediately discard or misplace the i brochure will not be able to understand the brochure or what they are

! expected to do because the information and instructions contained in the brochure are presented in a confusing manner. Illiterates, non-English speaking people and those with low reading skills will not be able to road

the brochure at all. These are serious flaws in any educational materials and instructions. They are inexcusable when they are contained in evacuation instructions. There is no margin f or error when the lives and health of so many people depends upon effective communication of information. Any evacuation plan which depends to any substantial degree upon the mailing of this brochure to residents in the evacuation area will result in large numbers of persons not evacuating the area or being injured by exposure to radiation or other means because of the inadequacy of this brochure.

I recommend strongly that a small-scale unannounced trial or practice evacuation be undertaken in an area of the parish where the educational level is lower than average. Following this trial run, the brochure should be amended and rewritten, incorporating lessons learned in the trial evacuation. It is not acceptable proceduro to publish an evacuation plan and then not conduct at least a small scale unannounced practice evacuation to determine whether the plan in the evacuation pamphlet will work.

Furthermore, it is not acceptable educational procedure to present an unfinished product as the LP&L pamphlet I have reviewed.

lI i .

• KETED 00f.W c C UNITED STATES OF AMERICA NUCLEAR RE6ULATORY COMMISSION Before the Atomic Safety and Licensing Board *03 b in the Matter of ) ..

I Docket No. 50-382 -- CT U 1 '

LOUIS!ANA P0uER & LI6HT CD. ) 'ff' N 31.'SEp"eiC~;

) February 1,1983 FilGH (Waterford Steas Elect'ic Station )

Unit 3)

Dear Sirt this is to certify that a copy of the enclosed Aff adavit of Earl L. Duncan concernina the Energency Information Prochure has been placed in First Class sail on February 1,1983 to the ersons on the attached 5

• ice list.

'ch (1)Sheldon J. Wolfe Chairsan Atomic Safety and Licensing Board U.S.NuclearReulatoryConsission Washington, D.C 20555 (2)Dr.HarryForesan Administrative Judge University of Mint.esota.

ninneapolis, MN 55455 (3)Dr. Walter Jordan Adsinistrative Judge 891 West Cuter Drive Oak Ridge, TN 37830 (4)Sherein E. Turk Office of the Executive Legal Director U.S.Netlear Re ulatory Consissien Washington, DC 0555 (3)Atosit Safety and Licensing Board Panel U.S Nuclear Regulatory Ccesission Washin; ton, DC 20555 (6)Atocic Safet and Licensing Aepeal Board U.S. Nuclear R atory Cornission Washington, DC 555 (7) Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Cossission Washington,DC20555 (8)Pruce Churchill Sha1, Pittsan Potts & Trcuridge 1900 M Street Washington, DC 20036 (9) Brian Cassidy Federal Esergency Managesent Agency 442 J.W. McCorsack Boston, MA 02109 [

l ,

l l