ML20071H436
Text
..
UNITED STATES OF AMERICA
' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND~ LICENSING BOARD In the Matter of
)
)
UNION ELECTRIC COMPANY
-)
Docket No. STN 50-483 OL
)
(Callaway Plant, Unit 1)
)
AFFIDAVIT OF' WALTER M.
CLARK ON REED CONTENTION 1 (STAFFING - SHERIFF'S OFFICE)
County of Callaway
)
)
ss.
State of Missouri
-)
WALTER M.
CLARK, being duly sworn, deposes and says as follows:
1.
I am the Emergency Management Director for Callaway i
County and the City of Fulton, Missouri.
My business address is 510 Market Street, Fulton, Missouri 65251.
A summary of my
~
professional qualifications and experience is attached hereto as Exhibit "A".
I have personal knowledge.of the matters stated herein and believe them to be true and correct.
I make this affidavit in response to Reed Contention 1-(Staffing -
Sheriff's Office).
8305250304 830520 PDR ADOCK 05000483 C
_-..q
4 h
q 2.
The Callaway Plant, owned by Union Electric Company, is located in Callaway County, Missouri.
3.
I perform the function of Emergency Management Director for Callaway County and the City of Fulton on a part-time basis.
Since March 15, 1982, I have worked with Union Electric Company planners, Union Electric Company consultants, the State Emergency Management Agency and local agencies in the development of the Callaway County /Fulton Radiological Emergency Response Plan (the "Callaway/Fulton Plan").
4.
Reed Contentien 1(A) describes the sheriff's personnel requirements which Mr. Reed believes are necessary for the Montgomery County Sheriff to perform the duties assigned to him in the four county emergency response plan and the Montgomery County Standard Operating Procedures.
Contention 1(B) states that the manning shortages set forth in Contention 1(A) are applicable in the other three counties -- Callaway, Gasconade and Osage -- located in the Callaway plume exposure pathway emergency planning zone ("EPZ").
The four-county emergency response plan has been replaced with separate plans for each of the four counties in the'EPZ.
I have therefore adapted my affidavit to the functions-now assigned to law enforcement in-the Callaway/Fulton Plan.
5.
Callaway County (including the City of Fulton)-has a population of approximately 15,300 who live within the EPZ. _
l I.
- The population'of the City.of Fulton, all of which is in the l
EPZ, is approximately-11,000.
Also, Callaway County is i
.approximately 264 square miles.
See attached Exhibit "B" (map c
j of EPZ).
While Callaway County has the benefit of the availability of law enforcement personnel from the City of Fulton's police department, the fact remains that in the event
~
of'a radiological emergency at the Callaway Plant, the demands 4
that would be placed upon the sheriff and police departments of Callaway County and'the City of Fulton can be expected to be greater than the demands placed upon.the sheriffs' offices of the other counties in the EPZ.
6.
The purpose of this affidavit is to establish that there will be a sufficient number of law enforcement personnel 1
available to work in Callaway County in the event of r. radio-logical emergency at the Callaway Plant, through the use of regular full-time law enforcement personnel plus sheriff's patrol volunteers and State agencies.
In reaching the conclu-sions set forth in this affidavit, I have consulted with the Callaway County Sheriff and the Fulton Chief of Police.
7.
Three unstated and' unexplained assumptions' underlie Mr. Reed's analysis of sheriff manning needs which are contrary.
to accepted emergency planning practices..These assumptions are (1) that an eight hour shift would be used for emergency
. workers during a radiological emergency at the Callaway Plant;
.(2) that all normal-law enforcement functions would continue
-3
.I
1 4
1 during a radiological emergency at the Callaway Plant; and (3) that only regularly employed law enforcement personnel would be j
available to fulfill emergency functions assigned to the sheriff's office in the Callaway/Fulton Plan.
All three of these assumptions are unreasonable.
i 8.
In my 25 years of experience working in the field of emergency preparedness, the common and accepted practice is for emergency workers, including individuals performing law J
enforcement functions, to work a twelve hour, not an eight hour, shift (at a minimum) during emergencies of all kinds.
In 1
my opinion, individuals can perform satisfactorily on a twelve hour shift.
In fact, rotating three shifts of personnel can create unnecessary confusien and lack of continuity in perform-ing jobs under what are often complex and rapidly changing circumstances.
9.
It is also unreasonable and inconsistent with actual emergency operations to assume that regular law enforcement personnel are required to be available during an emergency to perform all of their normal, routine functions.
Priorities change during an emergency.
Routine law enforcement activi-4 ties, such'as traffic ticketing, become unimportant and can 1
even hinder necessary emergency activities, e.g.,
evacuation.
Thus, it would be totally counterproductive to prevent regular law enforcement' personnel from engaging'in needed emergency activities during an emergency at the Callaway Plant just "in 4
_4_
case" it might be decided to perform a routine function. 'The availability of law enforcement personnel adequately covers this contingency, along with the emergency-related needs for law enforcement which arise in the event of a radiological emergency.
10.
The Missouri State Highway Patrol and the Missouri State National Guard have committed to respond and satisfy needed law enforcement functions in the event of a radiological emergency at the Callaway Plant.
See attached Exhibits "C" and "D"
(letters of agreement).
The Highway Patrol will have 8 individuals available within one hour and 16 individuals available within two hours from the time of notification.
The National Guard has committed and previously demonstrated the ability in other kinds of emergencies to provide 120 trained guardsmen within a four to six hour period after notification.
A Missouri National Guard Military Police unit is located in Fulton.
Another MP unit is located in Columbia.
There are other Guard units in Jefferson City.
11.
The Callaway County sheriff's office consists of 19 full-time employees (a sheriff, 7 sheriff's deputies, 4 radio dispatchers, 3 clerical personnel and 4 jailers who are deputies).
There also are 3 part-time radio dispatchers and 4 part-time jailers.
The Sheriff's Reserve organization consists of 30 active members.
The City of Fulton police department consists of 29 full-time employees (the Chief of Police, 22 policemen, 4 radio dispatchers and 2 clerical personnel). l i
j 12.
In Contention 1, Mr. Reed identifies the following functions'which require law enforcement personnel:
(i) dispatching; (ii) relaying messages; (iii) EOC security; (iv) manning vehicle impound. lots; and (v) manning traffic control points.
Mr. Reed is correct that, in the event of a radiolog-ical emergency at the Callaway Plant, for Callaway C'ounty and i
the City of Fulton on each shift there would be a need for two individuals to receive and transmit law enforcement messages using the dispatch system (including receipt and verification of messages from the plant; requesting assistance from other law enforcement agencies; conducting notification of response i
j agencies and special facilities; and informing emargency j
response organizations of the location of access and traffic i
control points); one individual to hand carry messages between l'
the dispatcher and the sheriff or other authorized individual; one individual to provide security for the emergency operation's i-
{
center ("EOC"); and a law enforcement officer to man'each of j
the vehicle impound lots, which will be no more than four in, i
l the County.
See Reed Contention 1(A)(3), (4), (5) and (7).
In i
addition, there would be a need for one member of law enforce-ment to man each of the 41 access and/or traffic control points.
This individual would be appropriately assisted'by a non-law enforcement person, e.g.,
55 volunteer firemen available in the County / City.
In my opinion, in addition to the individuals assisting the officers at the traffic / access control points,Lthe.two radio dispatche~s nee'd not be law.
mm-~
enforcement personnel, although-they would be required to know how to work'the radiocommunications eqpipment.
Also, the communications messenger need not be a member of law enforce-ment or otherwise technically trained (beyond the instructions routinely provided to messengers) to carry out his assigned responsibilities.
Thus, 46 positions on each shift would have to be filled by law enforcement personnel (41 at access / traffic control points, 1 at EOC and a maximum of 4 at impound lots).
13.
I agree with Mr. Reed's view that activating the warning system, which will be initiated from the EOC i
Communication Center, does not create a need for any additional personnel.
I would add that similarly, the function of notifying the Presiding Judge / Mayor of any emergency condition at the Callaway Plant would not require any additional person-nel, as this function could be performed easily by the individual manning the 24-hour Emergency Conmmunications Center.
14.
The Sheriff and Chief of Police will personally coordinate the activities of their respective law enforcement personnel and will coordinate any necessary impediment removal activities, through the dispatchers, which may be taking place in their respective jurisdictions.
They will also initially
. identify the access and traffic control points which need to be activated, given the particular pathway of the plume.
i
- l-I t-L.'
~
15.
After an evacuation, the 41 law enforcement personnel no longer needed,to man traffic control points will provide security within the EPZ by patrolling the area.
In the course of their patrol, these individuals will be able to locate stranded motorists and protect property.
16.
To perform law enforcement-related functions in the EPZ during a radiological emergency, Callaway County and the City of Fulton have available to them 29 full-time law enforce-ment personnel (excluding the Sheriff, the Chief of Police and the jailers), 8 full-time radio dispatchers and 5 full-time laymen (clerical personnel) from the sheriff's office and the police department.
In addition, there are 30 members of the Sheriff's reserve.
Thus, there would be no shortfall of personnel on the first shift, and a shortfall of 60 individuals (33 law enforcement personnel and 27 laymen for traffic and access control) on the second shift.
See attached Exhibit "E" (law enforcement manning chart).
17.
If one were to factor in Mr. Reed's highly conserva-tive 10% reserve requirement for each shift, a total of 99 rather than 90 individuals would be required each shift in Callaway County and the City of Fulton.
See Exhibit "E".
Conservatively assuming the entire shortfall consisted of law enforcement personnel, not messengers, dispatchers or laymen for traffic control points, 9 additional law enforcement personnel-would-kH>-needed cach-shi-f t=.- See-Exhibit "E".
There T ?-.
___-____z______-_____--_-__
would still be no manning shortages on the first shift because 1
l of the availability of the Sheriff's reserve.
On the second
~.
shift, again assuming a 10% reserve for that shift, there would be a shortfall of 78 members of law enforcement.
(Nine members of the Sheriff's reserve personnel previously available for the second shift would now be working on the first shift, plus nine more members of law enforcement would be the " reserve" for the second shift.)
18.
After one hour, 8 State Highway Patrolmen would become available to perform l'aw enforcement functions in the EPZ.
In two hours, 8 more State patrolmen would arrive in the area.
Within four to six hours after their notification, 120 National Guardsmen would be available to perform necessary law enforcement. functions.
4 19.
In summary, I am satisfied that there is an adequate supply of individuals available with law enforcement training who are committed to providing emergency law enforcement services in Callaway County and the City of Fulton in the event of a radiological emergency at the Callaway Plant.
20.
Finally, while I am confident that adequate law enforcement personnel are availabie, I would like to mention the fact that the full scale exercise required by NRC to be conducted prior to the plant's exceeding 5% power will serve to j
identify any personnel shortfalls and enable local and State
_g.
+_-~r
government to take any additional steps necessary to ensure that sufficient law enforcement personnel are available.
Walter M.
Clark Subscribed and sworn to before me this /6 day of May, 1983.
doamuY )
?W N6tiary Public~ ' '~
SUSAN K. EAL> MMS NOTA:1Y PU"2LIC, CALL.WAY CO.,MO My Commission expires vr warenos xn.ws 04-04 86 {.
Exhibit A WALTER M. CLARK Qualifications & Experience Twenty four (24) years of employment with the State Emergency Management Agency and fifteen months (15) as Director of the Callaway County /Fulton Emergency Management Agency.
Started employment with Missouri Civil Defense Agency in November 1955.
The name was later changed to Disaster Planning and Opera-tions, Civil Defense and more recently changed to State Emergency Management Agency.
My first staff position title was Service Chief.
Responsibilities included coordination of several programs including local emergency plan development, police reserve training, federal surplus property coordinator, and editor of monthly newsletter.
From 1962 to 1975 I held various positions in the state office including:
Chief, Resources Management Division Plans and Operations Officer Community Shelter Planning Officer All required providing assistance in the development of state and local emergency operations plans and frequent public speaking.
During disasters in the state I usually was delegated the additional duty of Disaster Coordinator for the office.
From December 1974 to January 1976 I was self-employed as a Governmental Programs Consultant, assisting counties, cities, and other units of local government with federally funded projects.
January 1976 to January 1981 - Rejoined the SEMA office and held the following positions:
Administrative Assistant Nuclear Civil Protection Planner Deputy Director March 15, 1982 to present - Part time Emergency Management Director for Callaway County and City of Fulton January 1, 1981 to present - Self-employed co'nsultant i
Professional Training Law Enforcement - University of Missouri Resources Management - DCPA Staff College Radiological Instructor - University of Missouri j
Community Shelter Planning - DCPA Staff College
]
Fallout Shelter Analysis - DCPA Staff College Served on Callaway County R-III Board of Education for 11 years, 1
5 of which as President of Board.
Developed the schools first
" Board Policies Handbook" and " School Emergency Plan."
t D
i EXHIBIT "B"
d
.-1 i
I W
(
M EMERGENCY PLANNING ZONE (EPZ) BOUNDARY MAP ec l
c3 ff N
O a
I
.w 1
m I-:
i
=
I a
e 0
.c gh lj, g
g 0
a m
'9L M
s 3
x (r!!,.. -.
,,,. i a
/
g
/
\\
4 1 g
'N
)
!N"
\\'.,,,,,,,...v'
~
d l
i g
3 c
]
i g\\ l
(
)
s k
~%
7 e
8
/
8 s;;
1 i
m ;;
F
=
_._.-j s
1 i
8
/
h l
[, -l' s'
s
,f
/
r
,i
/
s a
,xa s
5 x-
\\
r j
=
o 3
~;
}
n, i 10(
y s
a s
~ er x,
I s., e 1,5 0
x
/
=
x s
s u
x
,r
'i
- w i e 3
i = n.v
~
b s'
g' Q
Q
~
^
I
/,-
,'.,' $ x
-p-r,x-_'
l
,m,, _
c s
g, x
-s i
a e
~ < w
/
o
~ 1<n aA
~
,/
?'
e u
GE m
x 1 -
v~m 37 ;
/
l d
_,x r
e -e
- s i
1l k f
%~
' n.
D s
" i O
n w,, n w n;
m
-- -, us yh g
i
~.y'
' ' 's s x-i r
_,- 7
'y',- M'
'x [\\f@
/
\\
=
u 7
~ - _,,,
k'
,' ; l
\\
',,f v
h ^x i
w se 3
,. n = z,
s~
~
y
'\\
/
x
/
/
x l h s' 4
, J-,l h'
W I'
\\-
n 1
t \\.
l q ~ ; --
\\ x,
=
/
r
, f; i,';
f.!
w C
x t
El A 's
, i, ;
m' l k
(
l s
.m xx
~
s ~
E'
~?
N h
f nsx y
L' c
n'~
r
~
)
1 a
p d
l
,,[
C 0
s e
u
/
. y.--.
,m f
1 o
u, y
i i
i -m 1
i y.. j y
y y
}k. i R
~'L
- cD '
"j y
N
- , r'
[
j I
s-m e
'f g
e4 x
\\
C a
x 3
p' i
m
(
11 p
I (l
~
i i
l l
c Exhibit C Christ:ph;r S. Bond Edw:rd D. Dani:1 Governor Diraur 8'
DEPARTMENT OF PUBLIC SAFETY MISSOURI STATE HIGHWAY PATROL 9s9101%,,k H. J. Hoffman, Superintendent d
1510 East Elm Street
'b Malling Address:
?
$b$ ]$$3 Q
Box $48 Jenersoa City, Missouri 65102 Telephone 314 751-3313 March 9, 1983 A
- n 7,.z tA" Mr. William R. Beaty, Director State Emergency Management Agency Post Office Box 116 Jefferson City, Missouri 65102
Dear Mr. Beaty:
Pursuant to previous discussions between this office and M. A. Stiller, Manager, Nuclear Safety and Emergency Preparedness, Union Electric Company, this letter confirms that the Missouri State Highway Patrol can make avail-able the following State Highway Patrol personnel to support emergency operations within the ten mile radius of the Callaway Nuclear Power Plant:
Within one (1) hour of notification by proper authorities, eight (8) a.
uniformed State Highway Patrol officers can be available to support emergency operations of any of the four counties in an affected area.
b.
Within two (2) hours of notification, an additional eight (8) uniformed State Highway Patrol officers (a total of sixteen) can be available to support emergency operations in any of the four counties in an affected area.
It is understood that support provided by the Missouri State Highway Patrol to any of -the affected jurisdictions in the event of an accident at the Callaway Plant will be in accordance with the State Highway Patrol SOP con-tained within Annex A of the Missouri Nuclear Accident Plan.
Sincerely,
$Y W
H
. HO Superint ndent
Exhibit D
.C reitog,.5er S. Ilond Chrries M. Kiefner Ugivernor M:jor (;eleral. M OA RNG
^di" " "*"""'
DEPARTMENT OF PUBLIC SAFETY
"' ~
HEADQUARTERS MISSOURI NATIONAL GUARD
+.
Office of the Adjutant General 1717 Industrial Drive
..d '.12 ;{.,
Jefferson City, Missouri 65101 2
Phone 314 - 7512321 2
.x kg h
January 6, 1983
~3I 8s
.3 v-
'Gs Union Electric Company Attention:
Mr. M. A. Stiller Post Office Box 620 Fulton, Missouri 65251
Dear Sir:
This correspondence is in regard to your letter, dated November 10, 1982, and in accordance with the Missouri Nuclear Accident Plan, dated June 1982.
Assumptions in the use of the Missouri National Guard are:
a.
Missouri National Guard personnel will not be assigned missions in areas where the possibility of dangerous levels of radiation exists.
b.
The Missouri National Guard will respond to a nuclear power plant emergency as declared by the Governor with available personnel and resources.
c.
That a civilian authority is designated as a point of contact prior to the National Guard being assigned a mission.
d.
That missions be assigned by civil authorities, but the execution to include the number of personnel and equipment to be used, will be determined by the Missouri N'ational Guard.
The Missouri National Guard will provide support as follows:
a.
One hundred twenty Guardpersons will be available for traffic control and. assist in local radiation survey.
Personnel will be furnished
~
from the following units:
Headquarters, Missouri Army National Guard (Jefferson City) ll75th Military Police Company (Boonville and Moberly)
Headquarters and Headquarters Battery, 1st Battalion, 128th Field Artillery (Columbia) 1035th Maintenance Company (Jef ferson City)
\\
Service Battery, 1st Battalion, 128th Field Artillery (Mexico) j Headquarters and Headquarters Detachment, 735th Maintenance Battalion (Jefferson City) b.
The expected response time for the designated units is six hours after the initial notification.
Guardpersons that would be used for surveying personnel and c.
equipment for radioactive contamination to include themselves will receive initial training and annual refresher training.
d.
Air Evacuation would be performed by helicopters from Jefferson City.
Normally, during working bours reaction time to Readsville and Mineola would be two hours.
During non-duty hours, response could be up to four hours.
The Missouri National Guard has been called to State Emergency Duty 22 times in the past five years.
The response time was between four and six hours, primarily dependent on unit members traveling to Armories and preparing vehicles for Operations under adverse weather conditions.
Sincerely, e
f _'-
as s_
CHARLES M. KIEFNER Major General, MOARNG The Adjutant General s
e
ta' y ;+j p
_-p y -
+
y-
~
?
7-e r s
e,
.s
e
.4 d
- 'a,
r
/
7 i
~/
,fs
's.
)
o
^]
y/
r.
/
y e,
l y
'n y-1
']
~
r
$.. y s
T
?J EMNIDIT "H"
I.AW ENFORCEMENT MANNING CilART J #'
CALLAWAY COUNTY /FULTON LAinF.H VOH LAW ENFORCEMEll?
HF.SSF.MGER1 DISPATCilEltS Tj A CONTROL.
s Traffic / Access EOC Impound control Security lots i>
1 ural (1) Law Enfoscement-Ra1ated Maximum r
- NEms Functions per Shift 41 1
4 1
'l' 41
_} 0,,
/
(2) County / City personnel available on first shift Deputies / Policemen (total 29)*
29 Sheriff's reserve (total 30) 12 1
4 Clerical personnel (total 5) 1 Dispatchers (total 8) 2 Firemen (total 55) 41 (3) TOTAL County / City person-nel available on first shift 41 1
4 1
2 41 (4) TOTAL SHORTFAI.L on first 1UrAI. S Escr-shift 0
0 0
0 0
0 FAIJ.: 0 (5) County / City personnel available on second shift Sheriff's reserve
. (total 30) 13 Clerical personnel (total 5) 1 i
Dispatchers I
(total 9)**
2 Firemen (tptal 55) 14 1
(6) TOTAL County / City per-i sonnel available on second shift 13 0
0 1
2 14
'MM'AI. !atuer-(7) TOTAL SHORTFALL 20 1
4 0
0 27 FMJ.: 60 l
on second shift Excludes Sheriff, Chief of Police, an.1 jailers Excludes part-time dispatchers l