ML20093A525
| ML20093A525 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/02/1984 |
| From: | Chavez D, Morrison P DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | Bielawski A ISHAM, LINCOLN & BEALE |
| References | |
| NUDOCS 8407100603 | |
| Download: ML20093A525 (13) | |
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Sinnissippi Alliance L
for the~ Environment" 326 North Avon Street Rockford, Illinois 61103
'84 JA -9 A10:27 Mr. Alan Bielawski 4g,,
.3 Isham, Lincoln & Beale s uce Suite 5200 July 2,1994 Three First National Plaza Chicago, II.
60602
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.kd - YS, f Re:
Byron Station Stipulated Emergency Planning M ff[
Co==itments F, G,
H, T.
J.
K. L.0v. and 7
Dear Alan:
In accordance with Section 4(d) of the Stipulation, dated March 30,1983, signed by the parties to the Byron Operating Li-cense Proceedings, Intervenors DAARE/ SAFE and the Rockford League of Women Voters hereby respond to Commonwealth Edison's notifica-tion to Intervenors, dated June 13, 1984, of Commonwealth Edison's belief that it has satisfied Commitments F, G, H, I, J, K, L,0,Y, and Z.
Please find set forth in the attached pages Intervenors responses to each Commitment notification.
Very truly yours, b b.\\
D en d b q n ece_-
tw legal representative, on benali or Rockrora DAARE/ SAFE League of Women Voters cc:
Judge Smith Judge Callihan Judge Cole Richard Rawson Jane Whicher e407100603 840702 Paul Holmbeck PDR ADOCK 05000454 O
PDR Erie Jones O
Sheriff Brooks g@
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COMMITMENT F Demonstrate that the transient nooulation figures used in the study are r' oresentative e
of conditions which are likely to exist dur-ing an evacuation.
Response
Intervenors disagree that Commonwealth Edison has satisfied Com-mitment F based on it's response letter dated June ll,1984.
The transiant population figures used in the study are not reoresentative of conditions which are likely to exist during an evacuation.
Many of the population figures are inaccurate and underestimate the transiant population at various sites.
Further, the figures oresented fail to adequately indicate the range of population at locations whose attendence varies greatly: seasonally and throughout the year.
The figures cresented minimize population at those locations by presenting low range figures.
I Additionally, some locations indicated figures presented were outdated by several years and that they have recieved no recent contact from Com-monwealth Edison or the State of Illinois.
Table 3-3, note one of the Time Estimate Study incorrectly implies that the data presented therein was taken in January 1984.
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i COMMITMENT G Demonstrate that the principal assumptions used in developing the estimates are stated and defensible.
Recponse:
The information provided by Commonwealth Edison to the Intervenors in a letter response dated June 13, 1984 fails to orovide sufficient in-formation to allow the Intervenors to cetermine whether Commitment G has been satisfied.
f The following documents cited in Edison's resoonse letter to suo-ort various assumptions have not been provided to Intervenors: " Evac-1 uation Planning in Emergency Management," D.C. Heath and Comoany, 1981:
" A Perspective on Disaster Planning," Russell R. Dynes, E.L. Quarante111, Disaster Researth Center, The Ohio State University and Gary A. Kreos, College of William and Mary,1972; " Evacuation Risks-An Evaluation",
EPA.
I Moreover, said response letter is deficient on it's face to the extent that the statements cited as support for assumotions are not sub-stantive support.
Intervenors are undergoing efforts to verify that all orincioal as-sumptions used in developing the estimates are stated and defansible.
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COMMIT'ENT H Demonstrate that specific recommendations for actions that could significatntly improve evacuation time -have been con-sidered where feasible, or that such consideration is not warranted.
Response
The information provided by Commonwealth Edison to the Intervenors in a letter response dated June 13, 1984 fails to orovide sufficient in-formation to allow the Intervenors to determine whether Commoitment G has been satisfied.
Intervenors have engaged an expert witness to evaluate and to con-duct an independent assessment of the Time Estimate Study, and to anal-yze whether further specific recommendations are warranted.
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COMMITMENT I Demonstrate that comments with respect to the evacuation study from the principal emergency response organizations (Tilinois ESDA and Ogle County ESDA) have been solicited and that the study takes these comments into consideration.
Response
Intervenors disagree that Commonwealth Edison has satisfied Com-mitment I' based on it's response letter dated June 13, 1984.
Commitment I requires three items to be accomolished in order to be satisfied.
First, Edison should demonstrate that comments with resoect to the Time Estimate Study were solicited from Il. ESDA and Ogle County ESDA.
Edison fails to have provided Intervenors with any direct evid-ence of said solicitation but has instead chosen to orovide indirect evidence by way of identically worded letters from Il. ESDA and Ogle County ESDA, dated June 12, 1984 and June 11, 1984, resoectively.
Secondly, Commitment I requires that Edison demonstrate that s7ec-ific comments were in fact obtained from these urincioal emergency res-ponse organizations.
No evidence of any specific comments from the rev ponse organizations has been provided.
In fact, the general wording of the above-referenced letters suggests that no such comments were actually made.
Thirdly, Commitment I req'uires that Edison demonstrate that the specific comments were taken into consideration in the Time Estimate Study.
Having no evidence of the specific comments, it is imoossible to identify what comments may have been taken into consideration in the Time Estimate Study.
r COMMITMENT J Demonstrate that the assumotions regarding the avail-ability of autos to permanent residents are justified and that public transport-dependent oooulations have been considered in devising the estimates.
Response
The information provided by Commonwealth Edis;n t, the Intervenors in a letter response dated June 13, 1984 fails to orovide sufficient in-formation to allow the Intervenors to determine whether Commitment J has been satisfied.
Standard Operating Proceedure 6-SOP-8 fails to orovide information as to the method to be used to transport residents who will not have access to automobiles for evacuation.
6-SOP-8 provides no information or assessment as to the assembly locations for individuals, bus routes to be operated, frequency of bus runs, number of buses to be used, and provisions for residents who cannot reach assembly coints without assist-ance.
Moreover, said response letter is deficient on it's face to the extent that transportation of said individuals without vehicles is not considered in devising the estimates.
Intervenors are undergoing efforts to verify that the assumotions regarding the availability of autos to permanent residents are justif-led.
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COMMITMENT K l
f Demonstrate that there are no inconsistencies i
between the study and applicable nortions of IPRA i
and GSEP which would significantly imoact the rel-iability 'of the estimates.
Response
Intervenors disagree that Commonwealth Edison has satisfied Com-i mitment K based on it's response letter dated June 13, 1984.
Said response is deficient on it's face to the extent that Intervenors identify inconsistencies in the study, IPRA, SOP's, GSEP, while verifying other Commitments.
Intervenors have engaged an expert witness to evaluate and con-duct an independent assessment of Time Estimate Study and to identify inconsistencies which would significantly impact the reliability of estimates.
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COMMITMENT L Demonstrate that an Annex to the Evacuation Time Esti-mates Study has been developed which presents specific evacuation feasibility analyses for appropriate special facilities such that there is reasonable assurance that in the event of an evacuation of a special facility the health and safety of its residents can be adequate pro-tected.
Response
The information provided by Commonwealth Edison to the Intervenors in a letter response dated June 13, 1984 rails to provide sufficient in-formation to allow the Intervenors to determine whether Commitment G has been satisfied.
Intervenors have engaged an expert witness to evaluate and to con-duct an independent assessment of the Time Estimates Study, to analyze whether there is reasonable assurance that in the event of an evacuation of a special facility the health and safety of its residents can be adeq-uately protected.
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CO?MITMENT 0 Demonstrate that, home patients is necessary for in the event evacuation of home-bound and nursing those individuals whose medical needs require spec-ial care, there is reasonable assurance that adeq-uate facilities to safely transport and host these individuals are available.
Response
The information provided by Commonwealth Edison to the Intervenors in a letter. response dated June 13, 1984 fails to orovide sufficient in-i formation to allow the Intervenors to determine whether Commitment G has been satisfied.
Intervenors are undergoing efforts to verify that adecuate facilit-eeSe lesAto safely transport and host homsbcund and nursing home natients whose medical needs require special care in the event evacuation is nec-essary.
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COMMITMENT Y Demonstrate that IPRA includes adequate provisions to ef-
'factua't1 the evacuation of recreation areas with identif-
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lable transport-dependent populations such that there is reasonable assurance that the health and safety of these individuals in adequately protected.
Response
The information provided by Commonwealth Edison to the Intervenors in a letter response dated June 13, 1984 fails to orovide sufficient in-Y has formation to allow the Intervenors to determine whether Co:nmitment boen satisfied.
Intervenors are undergoing efforts to verify that IPRA includes adequate provisions to effectuate the evacuation of reacreational areas i
with identifiable transport-dependent populations.
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c-COMMITMENT Z Demonstrate that IPRA includes reasonable provisions to effectuate the evacuation of transport-dependent individuals.
Response
Intervonors disagree that Commonwealth Edison has satisfied Com-mitment Z based on it's response letter dated June 13, 1984.
Standard Operating Proceedure 6-SOP-8 fails to provide information as to the method to be used to transport residents who will not have a access to automobiles for evacuation.
6-SOP-8 provides no information or assessment as to the assembly locations for individuals, bus routes to be operated, frequency of bus runs, number of buses to be used, and provisions for residents who cannot reach assembly points without as-sistance.
Additionally, 6-SOP-12, Byron Station EPZ Public Information Brochure Cards Maintenance, fails to provide for the identification of those individuals who cannot reach assembly points without assistance i
in a timely manner.
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eE Sinnissippi Alliance L V for the Environment 326 North Avon Street Rockford, lilinois 61103 i.
n rnce Mr. Alan Bielawski 0-
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Isham, Lincoln & Beale Suite 5200 July 2,1984 Three First National Plaza a n. :. _ ;u. - 9 '
u c-Chicago, II.
60602 Re Byron Station Stipulated Emergency Planning Commitment S
Dear Alan:
Intervenors disagree that Commonwealth Edison has satisfied Com-mitment S based upon it's response letter dated April 16, 1984 and reply of May 10, 1984.
The Stipulation dated March 30, 1984 and the course of the neg-iotations which led to the signing of the Stipulation, didnnot des-ignate Commitments Q-T as Public Information Brochure Commitments.
These Commitments concerned public informaion.
Insofar as the bro-churo may serve as an appropiate mechanism to be used by Edison to in meet these Commitments,,Intervenors do not object to its use.
How-ever, the exclusive use of the brochure as presently composed fails to satisfy Commitment S by demonstrating "that the public has receiv-ed and will continue to receive on a periodic basis accurate infor-mation regarding special measures with respect to handicapped indiv-iduale."
As Intervenors indicated previcusly, the brochure merely disclos-Commonwealth Edisons mechanism for identifying handicapped individuals.
Sincerely years, cc:
Service List i5h 1* p
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21.~ 2::02.';CE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION.
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BEFORE THE ATOMIC S AFETY AND LICENSING "dQARD, -p g.g
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In the Matter of
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EhANCH
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Docket Nos. 50-454 COMMONWEALT5i EDISON CO.
50-455 Byron Station, Units 1 and 2
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July 2, 1984 CHANGE OF ADDRESS NOTICE Effective July 2,1984, olease change my service ad-dress in this oroceeding from 326 N. Avon St., Rockford, II.,
61103, to 528 Oregory St., Rockford, Il., 61108.
Also, as of July 6,1984, m2r teleohons number will be (815) 962-0413.
Thank you for your attentiot to this matter, Sincerely yours, ihnt AtM k DAARE/ SAFE cc:
Service List e
.