ML20039G199

Direct Testimony of Hd Gideouse Addressing ZAC-ZACK, D Fankhauser & Mentor Contentions.Related Correspondence

ML20039G199
Person / Time
Site:	Zimmer
Issue date:	01/12/1982
From:	Gideouse H ZIMMER AREA CITIZENS - ZIMMER AREA CITIZENS OF KY
To:
References
ISSUANCES-OL, NUDOCS 8201150376
Download: ML20039G199 (10)

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In the Matter of  : Docket No. 50-358-OL THE CINCINNATI CAS & ELECTRIC  : APPLICA .

COMPANY, et al.  : OPERMlh (wm. H. Zimmer Nuclear Pawer RECEtV.5D yd Station)  :

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5- muuun a 14C y DIRECT TESTIMONY OF HENDRIK D. GIDEONSE ADD 'O THE AREA CITIZENS-ZIMMER AREA CITIZENS OF KENTUCKY, DA F - , AND -

MENTOR CONTENTIONS, AS CONSOLIDATED AND INDIVIDUAL RESENTED, CONTENTIONS 4(12), 20X, 20, 20b, 20C, 20e. 20f, 20g, 21, 21b, 21c, 21d, 21e, 23, 24, 25, 34, 36, 36B, 36C, 36D, 36E, 36F, 36G, and 36H

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County of Clermont)

I, Hendrik D. Gideonse, 3535 Holly Lane, Cincinnati, Ohio 45208, present this testimony in connection with the licensing hearing for Zimmer Nuclear Power Station, Unit 1. I currently serve as Vice Provost for Academic Planning at the University of Cincinnati, a one year assignment with :esponsibility for develop-ing a system of academic planning for the University. I have served as Dean of Education for nearly ten years at U.C. , also holding the tenured rank of Professor of Education and Policy Science. Immediately prior to coming to the University I was an Adjunct Professor of Policy Science with the State 'iniver-sity of New York at Buffalo. P'olicy Science is the field of study which ex-plores the application of knowledge to matters of public policy.

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I received my Bachelor of Arts at Amherst College as a political science major in 1958. In 1959 and 1963, respectively, I was awarded a master's and

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then a doctoral degree in education by Harvard University. The social sciences backgrounds acquired at Amherst and Harvard provided the grounding for seven and a half years of administrative experience in the Federal Government, six of which were spent as Director of Planning and Evaluation for the research pro-grams of the United States Office of Education and one year as a professional staf f member on the Executive Reorganization and Government Operations. I have published extensively in my professional field of education and have also written on the nature of behavioral and social science, long range futures, planning, generallv, and the management and evaluation of governmental prcgrams and public policy. The expertise I brir.g to this hearing includes public sector planning, including policy science, a knowledge of behaviocal and social science, organizat ional development, and the management of complex enterprises.

In recent months I was invited by CORVA, the Central Ohio River Valley Health Planning Organization, to chair its Radiation Safety Task Force. Of several different tasks which we might have taken on, we chose to focus on the radiation safety measures being taken in connection with the projected opening of the Zimer Power Station and to examine provisions being made for radiation safety requirements associated with present and projected transportation of radioactive materials through the area. In that capacity I and the members of the Task Force have spent substantial amounts of time receiving testimony from a wide variety of expert and experien'ced witnesses on various aspects of radiation

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safety in connection with the potential hazards of nuclear power facilities and the transportation of radioactive materials. In addit ion, I have completed a single reading of the Ohio, Kentucky, Clermont County, and Campbell County

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4 Radiological Emergency Plans and paged through the plans of Bracken and Pendle-ton Counties which are, as you know, very similar to that developed for Campbell County. The extent and nature of deliberations of the Task Force are important background for the comments I wish to make and I have appended to this affi-davit, therefore, a copy of all materials growing out of the Task Force's work.

Based on the above expert ise and experience, I bring several perspectives to the evaluation of emergency prepetedness in connection with the projected licensure and operat ion of ZPS-1. These are:

1. Observations about the nature of the problems for which preparation is being undertaken.

2. Important limiting factors in planning, involving requirements for substantial and widespread human nctions.

3. Knowledge of planning processers requisite to the eventual effectiva engagement of large numbers of people at widely dispersed locations.

Each of these matters is treated below. They are then related to the admitted contentions respecting emergency planning and monitoring reviewed in the December 11,1981, " Memorandum for the Parties and Part icipants."

1. Nature of the Problems On the surface, the nature of the problems being dealt with in connection with radiat, ion emergency plans is quite clear. The primary aim is to prevent or, fciling thct, to reduce to the greatest possible extent, exposure of the public to any conceivable radiation hazards that might arise from an accident at 2

Zitmer Power Station. To that end, virtually everything addressed in the State and County plans is relevant.

1 It seems apparent, however, that the primary aim of protecting the public against potential hazards of radiation cannot be undertaken without recognizing the deep public apprehensions about such matters. In other words, public anxiety and fear about radiation and its dangers must be recognized explicit ly -

. as a key underlying factor in any planning undertaken because not to do so is to run serious risks of undercutting plan implementation at some later date.

If anything is to be learned about the Three Mile Island experience, and there are many things to be sure, one of them is that there are and will be seriout and insistent emotional factors that will emerge and that must be addressed in the planning and in plan implementation.

Addressing such needs must be accomplished in two ways, first, by conduct-ing the planning and the identification of response requirements so as to reduce to the greatest extent possible the emergence of problematical emotional factors and, second, building into the plans suitable and appropriate means of co'ping with those factors, that willy-nilly, do emerge despite advance preparation.

! The importance of such considerations was underscored in the test imony we ,

heard in connection with our Radiation Safety Task Force deliberations. Making this point , however, requires an observation about dif fering perspectives about-planning. In the present case (preparing for the possibilities of an accident involving i stationcry nuclear power generating facility) several different forms of rationality could be identified from the testimony the Task Force heard

and the discussion we engaged in. Physicians were prepared to say' that they knew what was or was not reasonable by way of preparation and emergency

, responses, and all that was necessary was to ask them and follow their advice.

Engineers made a different. kind of claim: give them the specifications and a period of time to examine the matter (usually that also seemed to mean off somewhere else), and they would come up with an optimal solution.

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Political leaders recognized a different kind of rationality altogether, that having to do with "what would sel: 2eoria,'" meaning some recognit ion that negotiation and dealing with the realities of public awareness would almost assuredly be part of the " rat ional" solut ion from their perspect ives. Governmental planning types of the civil service rather than elected variety tend to focus on the realities of undertaking the inter-agency and multi-jurisdictional interactions necessary for such a complex and geographically dispersed activity. To this must be added a fifth type of rationality, that possessed by individual citizens at precise points of time when their actions may be necessary to accomplish the intended aim of the preparedness plans as applied to them.

The task of preparedness planning must be viewed, then, as orchestrating a variety of different kinds of rationality, some of which may be or appear to be mutually contradictory and some of which will almost certainly be off putting to proponents of others.

A specific example of this principle applied to Zimmer would be the extent to which the emergency preparedness plans systematically undertake to address the establishment and maintenance of public trust in the authorities. Public trust is [n important precursor to acceptance of emergency preparedness plans and vital to the continuing ' expectation that the public will taka those steps

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the authorities direct them to in the event of an actual emergency. Public trust is generated by truthfulness, sensibleness, absence of confusion in

, performance of responsibilities, clear messages, and the provision of explana-tions that hold water. to justify recommendations that appear to be against one's

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1 own direct intuit ion. A good illustration of a plan element that does not appear to engender public trust is the delineation of evacuation routes which are far longer than necessary and actually appear to require travel within or across the plume when alternate' routes are plainly available.

2. Important Limiting Factors in Planning Human Action Some of these have already been mentioned. Dif ferent conceptions of rationality are abroad. Af fective considerations, emotions and anxiety must be anticipated and accomodated. Large numbers of people will.be expected, indeed, required, to undertake actions for which they will have had little practice and probably quite ILnited and infrequent awareness.

There are others, however. In any operation involving human action, Murphy's Law -- if something can go wrong, it will -- is almost certain to find expression. What this means is that effort must be undertaken to imagine how things might go wrong and to develop contingency plans to deal with those circumstances should they develop. Such thinkiiig is fully evident in th'e engineering of the plant itself. Backup systems exist in the event of the failure of primary systems. Defensive measures are primary, secondary, and t e rt ia ry. Analogues of such thinking for the requisite human actions in the event of a,n emergency also need to be developed and scheduled for implementation as required.

A specific example of this principle would be preparing for the possibility that parents will disobey instructions to stay, of f the phones and

, not to come to schools to retrieve their children. What will school and civil authorities do in such a circumstance? How can the busing plans be guaranteed if the roads and walk-ways are clogged with vehicles and adults?

3. Planning Processes Involving People It is widely known in planning that genuine involvement in planning pro-cesses is the most certain way of assuring effect ive implementat ion. Involve-ment does not mean simply receiving a copy of a document and finding where one is listed in it with instruct ions what to do under what circumstances. Th at is a plan, but probably only an imperfectly implementable one. Involvement is the only way of guaranteeing that the variables known by all the dif ferent kinds of participants can be identified and factored into the plan. In other words, involvement is not merely a cosmetic feature, but a vital inst rument of eventual ef fectiveness by tapping into what people know.

Ef fective and efficient involvement, however, in an act ivity as complex and far-reaching as preparing for a radiological emergency will entail a variety of compromises. Not everyone can be involved in the same way. For certain classes l of stakeholders in preparedness planning, all must be engaged. Examples would l

be hospitals, fire departments, life squads, police departments and so on. For 1

other classes of stakeholders, like the general public, involvement must be on a 1

l representat ive basis. The impo rt ant considerat ion, however, is guaranteeing the availability of the various perspectives to the planning processes and assuring they have been fully accoaodated.

Involvement is one prerequisite of effective planning. A second is 1

thinking through the requirements of proposed actions to' assure that enabling conditions have been met. We have all seen plans that look fine on paper that

/ turn out not to work, not because of any failure of logic in the plan, but because important precursors to ef fective implementation have been in-sufficiently considered.

A specific example would be assuring the availability of important classes of volunteers. Preparing them for their roles is one thing. ' Assuring that they present themselves at the needed time requires a prior step, that each volunteer has made sufficient preparations as an individual to provide for his or her immediate family without his or her direct involvement so that conflict ing loyalty does not get decided, as it otherwise must, for family rather than

" volunt eer funct ion.

The three perspectives or conditions described above support a number of the contentions raised. These include the following contentions listed in the left column. In the following right column opposite the content ions are some, but not a11, illustrations of deficiencies I have observed.

4(12) " Circle of Safety" -

Reading level inappropriately high; Education of Public implicit message that reading it is waste of time; mode of delivery suggests unavailability at time of ,

need; compromises prospective implementation of plan.

20X Include portions of Brown Public route of travel will be into County In Plume Exposure Brown County despite plan which Pathway EPZ requires longer distances of 36C Alternate Evacuation Routes. travel that may intersect plan unimplementable.

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20(b)(5)-(8) Communications with schools Almost certain likelihood, based on past emergency experience, that parents will clog phone lines I

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. i compromising implementat ion of plans for evacuation or take shelter.  ;

20(c)(i)-(3) Adequacy of Roads There are serious unresolved doubts [

20(c)(5)-(14) Adequacy of Roads about discrepancies in evacuation ,

20(g)(1) Inclement Weather time estimates of dif ferent j 36B Ten Defects in Stone and agencies. That lack of resolution Webster Evacuation Plan raises doubts about the adequacy i of the planning and the implementa- l tion of those plans. ,

i 20(e)(5)-(15) Police and Fire Persunnel Emergency preparedness plans depend 20(e)(1)-(3) Availability of School Bus on availability of many dif ferent Drivers kinds of volunteer personnel.

24(1)-(10) Medical Facilities and Training them is not sufficient; Treatment precursor planning to assure uncon-flicted emergency responses because of prior planning for their families is crucial. Plan as presented incomplete; likely im-plementation thus compromised.

21(c)(1)-(4) School Buses Insufficient' precursor planning 21(d)(1)-(4) Evacuation of Schools during regarding important volunteers plus [

Busing Periods insufficient contingency planning ,

21(3)(1)-(3) Availability of School Bus for parents not following their re-Drivers quested roles (i.e. , no phone calls and no appearance at schools) con-stitute inadequate planning and com-promise implementation of plans, especially in light of insufficient l buses to accoup1ish evacuation in l t ime . Awareness of insufficient

. buses will stimulate parental be havior.

i Some of public will know of blockme 21(b)(2) Potassium Iodide for Ch ildren agent and its distribution in 24(1)-(10) Medical Facilities and Tennersee. Non provision in EPZ in Treatment Ohio is a gap in planning on its l

36F Storage and Distribution face as well as an apparent flaw of Potassium Iodide which will undercut public trust and confidence in all other emergency preparedness procedures.

,34 Use of Standard Operating All these contentions if left un-Precedures '

will raise doubt- in the minds of 36 , Defects in Kentucky and the public about adequacy, complete-Campbell County Plans ness, appropriateness, or wisdom of 36G Evacuation of Those in the planning undertaken to date.

Need of Assistance Some plans are not yet available, 23(1)-(5) Education of Public some have implicit conflicts, some 20X Inclusion of Brown County are little better than " propaganda" l

36C Alte aate Evacuation Routes ex e rc i.c es . All this undercuts 20(e)(3)-(15) Police and Fire Personnel public confidence in authorit ies, increasing likelihood of subst itu-tion of individual judgment over planned responses. Recult is com-promised implementat ion of plans be-cause of inadequacy, confusion, therefore, jeopardizing of public health and safety.

For these reasons regarding the above listed contentions it is my judgment, as an expert, that the emergency plans, as arsfted, are inadequate and, further-more, they would prove to te unimplement able given the condit ions that obtain in the EPZ's and the adequacy of the preparat ion undertaken to date.

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Subscribed by in my presence and sworn to me this day of January,1982. [

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