ML20063N258

Affidavit of El Duncan Re Emergency Info Brochure.Brochure Shows No Understanding of Target Population or Subgroups within Target Population.Method of Distributing Brochure Is Faulty

ML20063N258
Person / Time
Site:	Waterford
Issue date:	09/11/1982
From:	Eric Duncan JOINT INTERVENORS - WATERFORD
To:
Shared Package
ML20063N253	List: ML20063N252 ML20063N258 ML20063N264 ML20063N269
References
NUDOCS 8209200136
Download: ML20063N258 (10)

Text

m UN:TED STATES OF AMERICA 00(,KETED NUCLI.AR REGULATORY COMMISSION UWFC HEFORE Tile ATOMIC _ SAFi?l'Y AND I,1CIMSING DOAlm p .00

• • • • • • • • • • • • • • • • • • • • ************,**************** E In the Matter of )

)

LOUISIANA l'0WEl'. & LIUl!T CO. )

Docket 50-382

)

(Waterford Steaa Electric Station, )

unit 3) )

AFF II >AVI I' OF EA RL 1, . DUNCAN CONCERN I3 Tile EMERGIWCY INFORMATION BROCIIURE

1. Please dcscribe your edtcational and professional background.

Answer. I was a member of the 43rd F.A. Battalion, 8th Infantry Division in 1941-1942. I serted as a non-conmissioned officer responsible for wire and radio coniunications for a howitzer battery. My battery was the only unit in the 8th Division Artillery that passed the Anny Ground Forces proficicncy test the first time it was given.

I graduated from Field Artillery Officer Candidate School in 1942.

I was ordered to the North African Theater of operations and assigned to l

I the 1st U.S. Infantry Division Artillery.

'I served as a forward observer with various infantry companies of the 1st U.S. Infantry Division and as executive officer of a 155 howitzer battery respont.ible for training, efficiency of operations, accuracy of firing of howitzers, and welftre of gun crews.

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I was rerponsible for training troops in survey procedures, communications, l

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laying of guns, survival, and procedures used during amphibious landings.

I received the Silver Star for gallantry in action.

I served as a forward oteserver and executive officer of a howitzer battery during the Allied lancing and campaign in Sicily.

I served as Motor Transportation Officer responsible for training mechanics and drivers operating under stressful conditions during this campaign.

I returned to Great Britain to prepare for the Omaha Beach Landing in Normandy. I received intensive training conducted in gas warfare (i.e., nerve ges and biologicn1 warfare) and landing on heavily defended beaches. This training involved embarking and debarking men and equipment for combat on the beaches. Perfection was required in logistics in order to offload men and equipment ready for operations under hostile conditions.

Af ter break out of the Allied forces during Operation Cobra the key to the rapid march across France to liachen, Gennany was striking the enemy uneupectedly which depended upon successful logistical planning and the ability to adapt to changing circumstances.

I participated in five campaigns with the 1st U.S. Infantry Division on the European mainland. Following the war I graduated from the Adjutant Genaral School at Fort Oglethorpe, Georgia. I trained and supervised Army and Air Force recruiting personnei in southwest Georgia for five years.

I was ordered to the newly activated 1st Armored Division at Fort Hoad, Texas. I served as act7ng executive officer in planning and executing training in Field Artillery Tactics and Techniques. My unit participated in classified activities involving nuclear weapons. I received cl,1ssified training in nuclear warfare planning execution and effects of nuclear explosions.

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I served as Acting Exect.tive Officer and Adjutant of the 7th Field Artillery Battalion,1st Cavalry Division, far East Command. I par ticipated in writing plans and operations at Non-Combatant Evacuation Orders (NEO).

! was involved in tap tecret plans involving redeployment of units from Korea if and when the Innistice was signed.

I served under the XVI /amy Corp. as liason officer between the Cavalry Division and the gover nor of Yamaquata Prefecture, 1952-1954.

I served as Labor Liason Officer in charge of labor relations with approximately 2,000 Japanese workers. I supervised Claims Officers and _

made recommendations to the commanding gereral on the disposition of - .

Japanese Citizens' claims against the American government.

While serving in Japan (1952-1954) I was' involved in plans and operations of redeploying troops from Korea. I monitored the writing m and practice of the Non-Combatant Evacuation Order. The NE0 was anended when practical exercise.; showed a lack of understanding of the plan by participants and to accorrodate changes in transportation availabil;ity.

I was assigned to the 4th Army, San Antonio, Texas in 1955 with an Abilene, Texas duty station. During my tenure as commanding officer this station moved from the least successful recruiting station (tenth of ten) in the 4th Army to number one in recruiting for regular anny and reserve e n l i s'tmen t. My duty station rema'.ned first in the 4th Anny during my tenure as conmanding officer.

In 1957 I was as;igned ;o the U.S. Army Europe in Heidelberg, Germany (US4REUR). I assisted in the plannsrq and monitoring of NE0 practice alerts held at unannounced timas each m i ht Sy U.iAREUR. These plans were changed as practice exercises discle..a ... in conriunications and logistics.

Simple line road maps were substi;uted for more detailed roads when necessary.

J I was involved in briefing non-conbatants within 10 days of arrival in USAREUR, ir.cluding during the Berlin crises. I monitored military police check points and control of tiaffic for NE0 practice exercises. I assisted in writing top secret contingency plans and briefing newly arrived officers on the plans.

Units in which I served received the French Fourragere and the Belgian innrrage're for gallantry in action.

Follcwing my return to the United States in 1960 I served as Plans and Operations Executive Officer and Commanding Officer in the 2nd Infantry Division Artillery Battalion. I was involved in planning and evacuation

, of civilians when flooding occurred in Columbus, Georgia. I retired from the.U.S. Army as a major in 1961.

From 1961-1963 I completed 4 years of college in 2 years, graduating cum laude receiving a B. A. with a major in history from the University of

. Southern Mississippi. I taught United States llistory and Political Science it Aiken fligh School in Aiken, South Carolina for two years.

I taught a te~lephone and switchboard control office installation and relair course at the United States Anny Signal School, Fort Gordon, Georgia for one year. I was then assigned to the Staff and Faculty Development Division. I graduated from ard/or participated in courses and seminars on Collective Training Analysis and Design, Individual Analysis Design, and in tne development, implenentation, validation and evaluation of training material for use by the armed services worldwide. I participated in and conducted seminars on the above and on Communications Skills, Technical Priting Conference Techniques, Conducting Self-Paced Group Excercises, Dar ic Management, and Advanced Manageraent Techniques. At the Signal Schuol I supervised and trainea civilians and military personnel in

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tcchniques of critiquinq civilian and military instructors on an uninnounced basis. I supervised ani conducted quality control survey of management irstructors and materials used in teaching stucents attending the U.S. Army Signal School, Fort Gordon.

I made recommendations to the Dorananding General on discrepancies ir training procedures that could not be resolved at a lower level of cermand. I participate 1 in seninars on development and implementation of training in which consultants from colleges under contract to the arned forces and students from training and dnctrine command service schools also participated.

I served on the D2partment oP the Army Proposal Evaluation Panel on the p'!rc' lase of mini computers 'or the anned services. I coordinated centract work of the Human Resources Research Organization personnel.

I served as chainaan of the oormnittee which wrote regulations on how to develup materials for teaching nilitary personnel .

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2. Have you eamined th3 preliminacy draft of LP&L's emergency evacuation plan?

Answer. Yes, I Fave.

3. Would you please give your )rofessional opinion of this brnchure?

Answer. This is an ipparently fragmented Emergency Evacuation Plan putlished by Louisiara Power and Light Company. Further comment must awai t the cumpleted product. It consists of the 1982 Information Brochure, Emcrgency Action Plan, Protective Action Sectors, The Region Within 50 Miles of Waterford 3, The Pegion Within 10 Miles of Waterford 3 The Area Within 5 Miles of Waterford 3, a fragmented description of area and plant, and an incomplete and complicated glossary with additional infonnation on How Waterford 3 Works.

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 /iolates this principle. After studying the material listed above, I am confused.

The brochure seems to show io understanding of the target population or subgroups within the tarjet population. There are differences in ethnic backgrounds, education,1nd other facets of the people living within the evacuation area. It shovs little comprehension that there are various personality types living in the danger area, i .e., how different people will react to the knonn and u1known.

A good plan mast have short sentences with an action verb, for easier comprehension . The evacaation ilan 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 a part of the evacultion plan.

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Nuclear Emergency plans shouid not be consolidated with other plans.

Nuclear dangers are unique and :,hould be deal t with appropriately.

The brochure takes a "Pollyanna Approach" as to who would be af fected by a nuclear accident. Persons familiar wi'.h nuclear reactors would not and do not believe the s~:atemen: that Al and A2 (nearest " ground zero")

would be the only danger area. The ten mile radius is questionable. This failJre to " level" with the pubiic r.oncerning the danger of a nuclear accident not only undermines public confidence in the evacuation plan, but also indicates that LPSL does not regard a nuclear accident as serious business.

The " protective Action Sectors" is limited to the extent that peuple can follow written instructions: illiterates and persons with limited education will not be able to follow the instructions. Only individualized instructions can detennine whether these per;ons understand the instructions well enough to follow them correctly in any emergency.

It would be 9 referable to use line route maps for each area with the iniormation in graphics and color. Persons in the evacuation area should be issued a checklist of what s;pplies they will need if evacuated from the danger area. A state or parish agency whould keep a current and updated list of persons needing transportation. Some may not have telephones, requiring individual att2ntion to tneir evacuation. It is confusing that the brochure suggests th)t phon 3s not be used, while the evacuation plan requires certain persons to fenJ for themselves in obtaining transportation out c f the danger area.

It is important that persons from the same geographical areas be evacuated to tLe same location. The brochure's plan, which apparently calls for schoci children to be evacuated to a different location than their parents l

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m is rot practical . This will caase mass confusion. The brochure fails te state where medichl f acilities, doctors and nurses, and first aid stations will be located. It makes no reference to provisions for obtaining prescription drugs. These deficiencies undenuine confidence in the evacuatica plan and cause people to disregard other infonnation and instructions in the brochure.

Tne plant description and llaa Waterford 3 Works doesn't have anything to oc with the evacuation plan. This type of extraneous material is only confLsing and creates the impression that the brochure is only LP&L propaganda and thus can be thrown away.

In my experience an evacuation plan must speak directly - remember " KISS" -

and to the educational level of all persons executing it. The LP&L brochure igneres these fundamental principles.

In summary, the nethod of distributing the brochure is faulty and will result in most persons within the evacuation area being unfamiliar with the coatents of the brochurt and procedures they, their children, and relatives ara expected to follow during an emergency evacuation. A large percentage of those persons who do not imitediately discard or misplace the brochure will not be able to read or understand the brochure or what they are expected to do in an emergency because its reading level is too advanced, it is written only in English, and the infoniation and instructions contained in the brochure ara presented in a conftsing manner. These are serious flaws in any educational materials ard instructions. They are inexcusable when they are coitained in evacuation instruc tions which must be followed correctly under extremely stressful concitions. There is no irargin for error when the lives and health of so many people depencs upon effective communication of infonnation.

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

! procedure 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 such as the LP&L pamphlet I have reviewed.

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