ML20071H883

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Affidavit of JW Baer Re Reed Contention 13 on Organizations Requiring Sops.Functional Procedures Will Provide Adequate Instructions to Organizations Assigned Emergency Response Role
ML20071H883
Person / Time
Site: Callaway Ameren icon.png
Issue date: 05/13/1983
From: Baer J
ENERGY CONSULTANTS, INC., UNION ELECTRIC CO.
To:
Shared Package
ML20071H409 List: ... further results
References
ISSUANCES-OL, NUDOCS 8305250511
Download: ML20071H883 (13)
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. UNITED, STATES OF AMERICA C; '

NUCLEAR REGULATORY COMMISSION: .

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In'the Matter of )

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UNION ELECTRIC COMPANY ) . Docket No. STN 50-483 OL

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AFFIDAVIT OF JOHN W. BAER ON REED CONTENTION 13 (ORGANIZATIONS REQUIRING SOPS) l County of Dauphin )

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L- Commonwealth of Pennsylvania )

JOHN W. BAER, being duly sworn, deposes and says as fol-lows:

1.. I am an emergency planning specialist with the Emer-gency Planning Department of Energy Consultants, Inc., ("ECI").

ECI provides nuclear emergency response planning services to utilities, industry, state and local governments. My business

' address is 2101-North Front Street, Harrisburg, Pennsylvania j  : 17110. :A statement of'my relevant experience and professional qualifications is attached as Exhibit "A". I h ve reviewed the ,

.offsite radiological emergency ~ response. plans, both state and ,

. local,. for the. Call'away Plant. In.1983, I have been~ assigned

by Union ElectriciCompany to assist in the revision of state w

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PDR. 8305203. PDR ADOCK.05000483.

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and local plans to meet the technical comments provided from the FEMA review to date. I have personal knowledge of the matters stated herein and believe them to be true and correct.

2. The purpose of this affidavit is to respond to Reed Contention 13 (Organizations Requiring SOP's), which asserts

-that the absence of standard operating procedures (" SOP's") for l county, city and other specified local agencies establishes that each organization and suborganization (as defined in Appendix 5, NUREG-0654) having an operational role in the emergency response efforts have not specified their individual concept of operations and its relation to the total effort as required in NUREG-0654,Section II.A.1.b.

3. NUREG-0654 planning criterion A.1.b provides, "Each organization and suborganization having an operational role shall specify its concept of operations, and its relationship to the total effort."
4. The county offsite emergency response plans for each of the four counties in the Callaway Plant emergency planning zone ("EPZ") establish the concept of operations for local emergency response organizations. ANNEX A of each of the county plans defines the role of each participating organiza-tion, and assigns to the organization its respective responsi-bilities and tasks. These responsibilities are illustrated by the Primary and Support Responsibility Chart attached to ANNEX A. The chart is organized by individual emergency response

- onfesweehen--and-by-emergency response function. ANNEX A thus

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establishes the concept of operations for each response organization, and establishes the relationship of each organi-zation_to the total effort. The Primary and Support Responsibility Chart for Callaway County /Fulton is submitted with this affidavit as Exhibit "B".

5. ECI is working with local officials, private agencies and Union Electric Company in developing the implementing procedures for each of the county plans. These procedures are identified in Appendix 3 of each of the county plans. The im-plementing procedures will be employed during an emergency to guide individual emergency response actions. They are specific to the emergency functions that are identified in ANNEX A of the county plans. Appendix 3 of each of the four county plans is attached as Exhibit "C".
6. The functional approach to implementing procedures has decided advantages over development of implementing procedures for each individual organization having an assigned emergency role. Specifically, functional implementing proce-dures have the following advantages:
a. Specific emergency actions that must be taken to implement the plans are explained succinctly without undue repetition and confusion. .
b. The procedures can be readily accessed by emergency response personnel who are responsible for a particu-lar emergency function. The procedure will thereby

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serve as a practical field guide during actual emergency operations.

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c. The functional approach to procedures ensures that
all identified emergency functions are covered by procedures.
d. Fewer-procedures are required. A single procedure will apply to several response agencies. For example, the Radiological Exposure Control procedure applies to all emergency response personnel who would be assigned to this function within an affected area.

The functional procedure avoids the problem of fragmented repetition of emergency tasks for each individual organization and reduces the volume of paper that would have to be managed.

e. Functional procedures will apply to local government agencies as well as to outside (public and private) organizations that have been assigned an emergency role. All organizations and personnel with a responsibility for a specific emergency function will be reading the same procedure, thereby ensuring uniformity of approach and avoidance of potential conflicts and confusion.
f. Each procedure will clearly identify the response organizations that have a responsibility for the particular function. Consequently, response organi-zations will be aware of the other. organizations and participants that share responsibility for a particu-lar function. The relationship of each organization i

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s to! the total effort therefore will- be further 14 -

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g. The timing of specific emergency actions.within a functional 1 area.will be made clear. The actions to 4 be'taken by each organization will be arranged

, sequentially in the procedure by emergency-clas-sification level.

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'h. Resource listings will be consolidated. A list of.

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'all resources that are available to support a par-ticular emergency function will be appended to the e

procedure. This will avoid fragmentation of resource listings organization by organization, and will facilitate mobilization of required resources at the .

proper time during an emergency.

. i. Functional procedures will provide-a sound basis for emergency worker training. - Procedures that are specific to individual organizations are not con-ducive to a comprehensive training program.

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Functional procedures, cui the other hand, will

- provide the means to-structure a training program that'will address all elements of the emergency -

organization and will stress organizational relation-

[ ships.

7. The functional procedures identified:in Appendix.3 I' wi11'contain. instructions for emergency response personnel

. I g , about how an emergency function is to be carried out, by.whom-c; '

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it is to be done,'when it is to be done, and with what resources. For example, the Radiological Exposure Control procedure will contain the following elements:

a. How dosimetry will be acquired by emergency workers.
b. Which emergency personnel will be issued specific types of dosimetry,
c. Who will be responsible for distribution.
d. How dosimetry will be calibrated.
e. How and when dosimeters will be read and recorded.

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f. How and to whom readings will be reported. i
g. How and by whom control measures will be implemented to prevent excess exposures.
h. List of resources showing the location, number, and types of radiological equipment that will be available to support this function.
8. If procedures were to be developed for individual organizations rather than by function, instructions, such as those specified for Radiological Exposure Control, would have to be repeated throughout numerous organization procedures. A single procedure could conceivably contain a multiplicity of emergency action instructions. This would lead to certain confusion and delay in implementation of emergency functions.

With functional procedures, an individual organization would need only to refer to those procedures for which it has been assigned an operational role.

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9. Mr. Reed refers'in Contention 13(B) to cities in need of1 SOP's.,.However, none of these-cities have functional
responsibilities in the event of an emergency at the Callaway Plant. In Contention 13(C), Mr. Reed refers to SOP's for

-hospitals, ambulance districts, volunteer fire departments, bus companies, trucking companies and school-districts. Hospital and ambulance procedures will be prepared by Radiation p Management Corporation. Membersfof the volunteer fire depart-

. ments will. utilize functional-procedures applicable to the function to which they are assigned,.e.g., access and traffic j control. Schbol plans are currently in preparation, and will include. functional procedures, as necessary, for school-and bus personnel. Finally, to the extent trucking companies-are i called'upon and need to know-information not otherwise known to them.as a part-of their normal activity, they will be governed 4 by the Impediment Removal procedure. See Exhibit "C" (Appendix 4

3).

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10. In my judgment, the functional procedures identified

! in Appendix 3 will provide-adequate instructions to organiza-

-tions that have'been assigned an emergency response role. The

procedures relate directly to the emergency functions for which i' .
responsibilities have been assigned to individual organizations li in the county _ plans. The procedures.will define emergency

' actions;to be taken, will identify the organizations that may be called upon to perform this function, and will establish the

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timing for'particular emergency' actions. Consolidated resource l'

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lists appended to the procedures will facilitate mobilization of resources when they are needed. The identification of the procedures listed in Appendix 3, taken together with the concept of operations established in the county plans, meet

. planning criterion A.1.b-of NUREG-0654.

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John W. Baer Subscribed and sworn to beforg me this /3 4( day of May, 1983.

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Notary Public 8 My Commise#4gp jit g, C .

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- .A Exhibit A

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1 John W. Baer i

Education 1970 Graduate Level Study.

American University '

Washington, D.C.

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, '1966 Bachelor ~of Science - Political -Science Western Maryland College -

Westminster, Maryland 4

Experience 1981-to Present Energy Consultants, Inc.

. Harrisburg, Pennsylvania Planning / Training Specialist. Develop On-Site Radiological Emergency Responso Plan for Arizona Public Service Company, Phoenix, Arizona. Assist l_

- with development of Off-Site Radiological Emergency Response Plans for State and local governments. '

- Developed and sought agreements for Louisiana State .

Agency emergency procedures in support of the Louisiana Power and Light. Company's Waterford 3 Nuclear Power Station. Development of lesson ' plans for training of State, county and local personnel in support of Radiological Emergency Response Plans.

Assisted with development of lesson plans for offsite r

emergency response training for Rochester Gas and Electric and Louisiana Power . and Li ght. Conduct training. of State, -county and local - emergency response personnel .in support' of Radiological l J

Emergency Response Plans.

1978 to 1980 Southcentral Regional Planning Council- '

Harrisburg, Pennsylvania Director. Directed . an eight . county planning and

< evaluation program for the ' Commonwealth of Pennsylvania. Assisted local communities- 'and ,

gtsernments in planning and development of 1

, communications systems 'and automated information systems for use in criminal -justice system and in supporti of emergency response organizations.

Developed and ' revised training ' courses in Data-

. Analysis for use' by Planning and Operational o.

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John W. Baer .

Page 2 personnel at the State and local government level.

Assisted with delivery of six thi rty-five hour training sessions for Criminal Justice personnel from a ten State region. Developed and conducted practical group exercises for course participants.

1973 to 1978 Southcentral Regional Planning Councii Harrisburg, Pennsylvania Planner. Assisted local communities and governments

- in planning and development of a range of Criminal Justice Programs and of Criminal Justice System Communications and Automated Information Systems.

1971 to 1973 Lord Fairfax Planning District Commission Front Royal, Virginia Planner. Performed general planning tasks, including ~

Criminal Justice and Emergency Response Planning for a five county region of Northern Virginia.

1966'to 1968 U.S. Department of Defense Fort Meade, Maryland' Security Specialist. -

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, _.,_ ,C'ALLAWAY COUNTY /FULTON CON E!1 TION 13 APPENDIX 3 BAER AFFIDAVIT - EXHIBIT C LIST OF IMPLEMENTING PROCEDURES SECTION OF PLA1:

TO BE IMPLEMENTED NUMBER TITLE BY'THE PROCEDURE l- Access and Traffic Control Annex I - Tab 2 2 Radiological Exposure Control Annex J 3 Emergency Notification Annex A, Annex D 4- Transportation Annex I - Tab 1 Annex K 5 Impediment Removal Annex I - Tab 2

'6 Public Alert / Protective Action Annex D, Annex L Instructions'

-7 . Protective Action Decision Annex I, Annex _J Making Annex L ,

8 Jail Evacuation Annex I Tab 3 9 Security Annex G, Annex I - Tab 3 10 Public Information- Annex F 4

11. Communications and. Message Control Annex E 12 EOF Liaison Annex B 13 Plan Maintenance Basic Plan VI 14 Emergency Equipment Control, ' Annex E, Annex G 13 Radioprotective Drugs Administration Annex J 16- EOC Operations
  • Annex A,-Annex G, j-Basic Plan V 172 Exercises and Drills Implementation Annex M and Assessment" I

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APPENDIX 3 w- LIST OF IMPLEMENTING 1-ROCEDURES SECTION OF PLAN i TO BE IMPLEMENTED  !

NUMBER TITLE BY THE PROCEDURE 4

'l Access and Traffic Control Annex I - Tab 2 2 Radiological Exposure Control Annex J Emergency Notification Annex A, Annex D 3 ,

4 Transportation Annex I - Tab 1 Annex K 5 Impediment Removal Annex-I - Tab 2 6 Public Alert / Protective Action Annex D, Annex L Instructions 7 Protective Actian Decision Making Annex I, Annex J Annax L 9 Security Annex G, Annex I - Tab 3 9 Public Information Annex F 10 Comunanications and Message Annex E Control

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11 EOF Liaison Annex B 12 Plan Maintenance Basic Plan VI 13 Emergency Equipment Control Annex E, Annex G 14' Radioprotective Drug Adminis- Annex J tration 15 EOC Op'erations Annex A, Annex G Basic Plan V' 16 Exercises and Drills:- Annex M Impiamentation and Assessment

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