ML20154C350

Testimony of G Wenger Re Rorem Contentions 1(a) & 1(b). Related Correspondence

ML20154C350
Person / Time
Site:	Braidwood
Issue date:	02/24/1986
From:	Wenger G Federal Emergency Management Agency
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ML20154C343	List: ML20154C340 ML20154C350
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OL, NUDOCS 8603050108
Download: ML20154C350 (31)

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@@MN.'3M 00CMETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COPIPllSSION

- BEFORE Tile ATOMIC SAFETY AND LICENSING BOARE MR -4 40 :30 FFICE 0: ~n .

. In the Matter of ) OCHETim; ( MpE BRANCS

)

COf.1MONWEALTIl EDISON COMPANY ) Docket Nos. 50-456

/

) 50-457 (Braidwood Station, Units 1 and 2 )

TESTIMONY OF GORDON WENGER REGARDING ROFEf1 CONTENTIONS 1(a) AND 1(b)

Q.1 Picase state your name, your occupation, and your qualifications to testify on behalf of the Federal Emergency Management Agency 1

(FEMA). l A.1 I am Gordon Wenger, Emergency Planning Specialist, with the Technological llazards Branch, FEMA, Region V. I have held this 1 position for the last six yet t . I am the Federal Team Leader for Radiological Emergency Preparedness Planning for Illinois and Indiana. I have participated in more than 50 exercises of nuclear power facilities, serving as evaluation team director or leader. I have reviewed radiological emergency plans , written exercise reports, interim findings and Regional Director's Findings for all six of the states in FEMA's Region V, namely, Illinois, In diana ,

flichigan, Minnesota , Ohio , and Wisconsin. A statement of my professional qualifications was attached as an exhibit to my prefiled testimony on Rorem Contention 1(a) for the hearing held October 29, 1985, and was bound into the. transcript following Transcript p. 518.

SeiBan888Elh6 T

Q.2 h' hat is the purpose of your testimony?

A.2 The purpose of,my testimony is to address Rorem Contentions 1(a),

including Offer of Proof Issues 2, 3, 4, and 6, and 1(b).

Contention 1 states:

1. Intervenor contends that an edequate emergency plan for the Braidwood Station should include the following:

(a) a program for informing the public within 10 miles of the Station of the means for obtaining instructions for evacuation or other protective measures in the event of a radiological emergency originatincr at the Station. ,

(b) assurance that institutions within 10 miles of the Station , such as nursing homes, can be evacuated or adequately protected in the event of a radiological emergency.

Offer of Proof Issues 2, 3, 4, and 6 states:

2. Applicant must develop and demonstrate its capability to provide, through scripts and/or other media information , substantive emergency information to adequately inform the public of energency information in the event of an accident at the Braidwood Station through all radio, TV or EBS stations in the ingestion pathway zone, so as to enable the public to effectively evacuate in the event of an emergency and to effectively re-enter the affected zone in the event of an emergency.

3. Applicant must demonstrate its capability to adequately inform residential and transient populations within the EPZ in the event of an emergency so as to enable the populations to effectively evacuate or shelter including development of the specific means and content of such communications to specific populations.

4. The program for notification of the public at the time of an accident is deficient in that it

provides no means of informing employers. In the EPZ as .to what actions they should take with respect to facility shutdown, sheltering, or the release of employee personnel in the event that evacuation is required.

6. Applicant's public - information .

program is .

deficient in that it fails to set out the means

by which the public will be informed during

an emergency of re-entry protective measures to be followed by the public in an emergency j and the content of such means with respect to information concerning decontamination and interdiction of foodstuffs, water supplies, i deiry and livestock, and field and garden crops.

, Q.3 What is the Illinois Plan for Radiological Accidents?

)

i A.3 The Illinois Plan for Radiological Accidents (IPRA) is a comprehensive document which sets out in detail the plan for

responding to any radiological emergency or accident which would happen in the state of Illinois. It is comprised of several volumes.

J

} The plan is both general, that is, state-wide, and specific, that is, tailored to deal with an emergency at each particular nuclear power station in Illinois. The IPRA is a record of the responsibilities l which have been assigned to various ~ officials of state and local government and utility companics.

Q.4 How was it developed?

A.4 Prior to the issuance of an operating license, the ' U.S. Nuclear Regulatory Commission (NRC) requires development of an emergency j plan to assure the safety of the public in the event of'an accident.

10 C.F.R. I 50.47. The content of emergency plans is spelled out -

I' in Appendix E to 10 C.F.R. Part 50. In addition, the NRC and the t__

Federal Emergency have published a guide , N UREG-0654 / FEMA-REP-1, Rev . 1, October 1980, " Criteria for Preparation o'f Radio- -

logical Response Plans and Preparedness in Support of Nuclear Power Plants." Each utility company seeking a license will develop a plan in close cooperation with state and local government officials. In this case, Commonwealth Edison Company (CECO) developed a plan for the Braidwood Station together with the State of Illinois, Will,

Kankakee and Grundy Counties, and various communities within-i 1

thore counties.

t Q.5 Where is the plan for Braidwood found?

]

, A.5 The IPRA is a multi-volume set. Volume One (Vol. I, June 1985)

I contains the State General Plan and refers to all of the 10 mile and 50 mile EPZs surrounding nuclear power plants in the State of Illinois. Volume Seven (Vol. VII, Preliminary, August 1985) contains the plan specific to the Braidwood Station offsite planning. In addition , there are Procedures (Vol. I February 3, 1982 and Vol.

VII August,1985) for the State and the Braidwood Station.

O.6 What parts of those volumes did you refer to in preparing this testimony? ,

A.6 This testimony concerns itself with certain aspects of the public information effort; therefore , the parts of .the IPRA which I have focused on deal with the dissemination of information before, during, and shortly after an accident.

o O.7 In general, what provisions does the IPRA make in that regard?

A.7 It , sets out the procedures to be followed in educating the public before an accident, for notifying public officials at the time of an accident , for activating the Prompt Alert and Notification System, and for delivering reliable information to the public on the protective actions they are expected to take.

0.8 Who are the individuals or officials who are called upon at these times?

O.8 First, the licensec, the operator of the nuclear power plant develops a public information brochure in cooperation with state and local government officials. The licensee then distributes the brochure, at least annually. This was discussed at the October 29, 1985 hearing.

At the time of an accident, the licensee is responsible for notifying the Illinois Emergency Services and Disaster Agency (IESDA). The IESDA will evaluate the licensee's recommendation and make the decision to notify the public and determine which sectors of the 10 mile EPZ are affected. The IESDA will notify the Grundy ,

Kankakee, and will County Sheriff's Dispatchers, as necessary, who will, in turn, notify the County ESDA Coordinators. Upon the decision by County officials to activate the Public Alert and Notification System, the coordinators will notify the County Sheriffs' dispatchers to activate the system. The County ESDA Coordinations will activate the Emergency Broadcast System (EBS). The IESDA will set up and operate the Joint Public Information Center. See

S Vol . I , Chap. 2, Sections E and F, and Vol. I, Chap. 8, of the IPRA. >

Q.9 What is the Joint Public information Center?

A.9 As the name implies, the Joint Public Information Center (JPIC) is a -

central location where public officials will provide information_ to the news media about the progress of an accident. Its function -is to

. provide timely , accurate , and essential information and to dispel l unfounded rumors. The JPIC does not take the place of the EBS, but supplements it, especially during the times when the situation is i essentially under control and information can be provided in a comprehensive and unhurried way.

Q.10 What is the Prompt Alert and Notifice. ion System?

J A.10 The Prompt Alert and Notificatio'. System (PANS) is the means by which government officials call the public'e attention to an emergency condition. Section IV.D.3 of 10 C.F.R. Part 50, Appendix E, statos:

[T]he design objective of the prompt public - i notification system shall be to have the capability.

to essentially complete the initial notification of the public within the plume exposure pathway- EPZ within about l'i minutes. The use of this _!

notification caprbility will range from the immediate l notification of tne public (within 15 minutes of the l time that State and local officials are notified that 1 a situation exists _ requiring urgent action) to the i more likely events where there is substantial time  !

available for the S_ tate and local governmental l officials to make a judgment whether - or not to activate the public notification system. l l

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The design of the PANS is within the discretion of the Applicant, subject to evaluation under criteria set forth in NUREG 0654 / FEMA-REP 1, Rev.t. and Guide for the Evaluation of Alert and' Notification Systems for Nuclear Power Plants, Appendix 3 FEMA-REP 10. A PANS typically uses sirens as the primary vehicle for alerting the public. Some systems, however, rely on tone-alert rsdios, direct dialing telephone systems, or " route alerting," that is, messages broadcast from emergency vehicles fitted with public address equipment. Many systems use some combination of these means. The PANS in the Braidwood EPZ uses sirens as the primary nicans of alerting the public and tone-alert radios and route alerting as backup means.

Q.11 What is the EPZ?

A.11 The neronym EPZ refers to the " Emergency Planning Zone." There arc actually two EPZs surrounding each nuclear power plant. The larger one is the ingestion pathway EPZ, which generally extends 50 miles out from the plant. The other is the plume exposure pathway EPZ, and that extends 10 miles from the plant unless special circumstances justify the identification of a smaller zone. Emergency planning is required only within the plume exposure pathway EPZ, which has a 10 mile radius in the case of the Braidwcod Station.

Throughout my testimony, I am referring to the 10 mile EPZ unless I l indicate otherwise, i

l Q.12 Once th: PANS is activated, how does the public know what actions to take?

A.12 The public information effort which takes place before an. accident, that is, distribution of brochures, educates the public to the need to tune its radios or televisions to, the Emgrgency Broadcast System (EBS). Appropriate messages will be broadcast very shortly after the . PANS is activated , and the messages will be repeated and updated as often as necessary.

J Q.13 Who decides which messages are appropriate?

A.13 This, too, is spelled out in 10 C.F.R. , Part 50, App. E. Section l 1 IV.D.3. Within 15 minutes after the power plant operator .dctermines  :

i that an energency exists, it must notify State officials. The State officials then evaluate the information provided by the utility and make e decision on activating the PANS. They decide whether to activate the entire system. This is a process of assessing the risk to each section of the EPZ, deciding if protective action is required and, if so, whether it should take the form of sheltering-in place or evacuation. The officials pay particular attention to the

characteristics of the plume if there has been a release of radioactive material. The' nature of the risks depends on many factors including weather, the duration of the release, the shape of the plume, the direction of the plume's movement, the materials released , and.

whether the release is in gaseous, liquid , or particulate form .

When those decisions have been made, messages are chosen from scripts in the -IPRA. These scripts are targeted for the particular

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^

3-sections of the EPZ affected by .the emergency, and they contain

, specific information about the protective action recommended by the i

4 governmental officials.

Q.14 What factors indicate sheltering-in place rather than evacuation?

A.14 If a release develops quickly, it is generally safer for . people to be ,

sheltered until the plume passes. Evacuation is preferred when there is enough time to move people out of the EPZ without exposing them to the plume.

i CONTENTION 1(a) ,

Q.13 What does Rorem Contention 1(a) state?

A.15 Contention 1(a) states

I

1. Intervenor contends that ~ an adequate i emergency plan for the Braidwood Station i should include the following:

(a) a program for informing the public within 10 miles of - the Station of the 4

means for obtaining instructions for evacuation or other protective - measures in the event of a radiological emergency-originating at the Station.

i

Q.16 In your testimony on Rorem Contention 1(a) for the October- 29,1985 hearing, you discussed the dissemination of safety information -prior to an accident at the nuclear power plant. You did not discuss, at

that time, the dissemination of such information at the time of an -

accident . Ilow is that accomplished at the . time of an accident?

A.16 There are three basic ways that this is done. First there is the PANS. Secondly, there is the EPS; and thirdly, there is the JPIC.

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The PANS in the Braidwood EPZ relies primarily on sirens to alert people to the existence of an emergency and the need to tune their radios or televisions to an EDS station. As discussed below in connection with Contention 3, some of the sirens and all of the route-alterting vehicles used in this PANS have the capability to deliver voice messages.

The EBS is activated by State and local officials, as discussed in my Answer 8, above. The EBS is the primary means of delivering scenario-specific information to the public at the time of an accident.

The EBS system uses pre-planned scripts to the fullest extent possible, but it also has the flexibility to carry particularized information as needed.

The JPIC is discussed above at my Annwer 9. It is the principal means by which State and local officials communicate information to the general news media.

Q.17 What is your conclusion about the effectiveness of these means of communicating safety information to the public at the time of 'n accident?

A .17 I find that they make adequate provision for the dissemination of this information.

Q.18 What is the basis for your conclusion?

A.18 The emergency response plan for Braidwood Station was tested in an exercise on November 6, 1985. I took part in the evaluation of the exercise. In addition, I took part in the evaluation of the plan by ,

the Regional Assistance Committee (RAC). The RAC found the plan to be adequate in that regard and 'I c'oncur.

OFFER OF PROOF ISSUE 2 Q.19 What does Rorem Contention 2 state?

A.19 Offer of Proof Issue 2 states:

Applicant must develop and demonstrate its capability to provide, through scripts and/or other media information, substantive emergency infor-mation to adequately inform the public 'of emergency information in the event of an accident at the Braidwood Station through all radio, TV or EDS stations in the ingestion pathway zone, so as to enable the pubHe to effectively evacuate in the event of an emergency and to effectively re-enter the affected zone in the event of an emergency.

Q.20 What is the scope of your testimony on this issue?

A.?0 I will address the dissemination of information at the time of an accident which will enable the public to evacuate the EPZ safely, as well as the dissemination of information after an accident which will enable the public to re-enter the EPZ safely.

Q.21 Where are these matters addressed in the IPRA?

A.21 Earlier in my testimony, at Answer 8, I identified the portions of the IPRA which deal with the use of the EBS and.JPIC at the time of an evacuation. Re-entry is addressed in Vol. I at Chapter 2, Section

5(g); Vol. VII, Chapter 1 Annex 1A, Section 1(d); and Vol .

VII-7-SOP-11.

Q.22 Who are the individuals or officials responsible for carrying out these procedures?

A.22 As explained earlier, the IESDA makes the decision whether to shelter or evacuate. The County Emergency Services and Disaster-Agency (ESDA) Coordinators activate the Emergency Broadcast System both when evacuation is ordered and at the time the IESDA determines that unrestricted re-entry is safe.

Q.23 What procedures or guidance are offered by the IPRA?

A.23 The IPRA identifies several delivery systems to disseminate emer-

. gency information.

The Braidwood Station public information brochure has been published and distributed to households, organizations, businesses, institutions , industries , individuals, and bulk quantities have been made available at locations which the public, including transients, ,

1 frequents . The brochure provides significant general emergency i

planning information which directs the attention of readers of actions-  !

to take for their protection. It also directs readers to the sources of more precise emergency information.

The IPRA Volume VII and SOPS contain prescripted messages which are to be read by officials over the EBS radio and TV stations and I

prescripted messages which are to r.ead to the media by information specialists at the JPIC.

The information to be read will recommend the protective actions to be taken based on the recommendations of the utility and the Illinois Department of Nuclear Safety (IDNS). The recommended protective actions would be dependent upon the classification of the accident and plant conditions.

The same delivery system used to notify the population of the emergency and advise them of the protective actions will be used to notify the population of the precautionary procedures to enter the affected evacuated area. The post accident information gathered by the IDNS will determine if re-entry would be restricted or unrectricted.

Vol. VII-7-SOP-11 is enth ely devoted to, and deals at length with, the procedures to be followed by local officials in allowing the public safely to re-enter the 10 mile EPZ. Once it has been determined that unrestricted re-entry is sa fe , the County ESDA Coordinators will initiate the broadcast EBS messages. At the same time, they will coordinate with the JPIC so that the same information is available to all the news media in addition to other than the EDS stations.

The scripts for the messages to be broadcast over the EBS and released to other new media through the JPIC are intentionally

general. It is expected that particularzing information will be added at the time of their dissemination so that they will be more complete and accurate. The scripts for the EBS announcements of unrestricted and restricted re-entry appear as Attachment D to Chapter II. Vol. VII-SOP.

Q.24 What provision is made for those people who may need to re-enter the EPZ after an evacuation has been ordered but before the general public is allowed to re-enter?

A .24 Fhere restricted re-entry is called for , State and local planning provides for emergency workers to enter the area only at the direction of supervisory personnel, and their authority is based on 1 the IDNS advisement.

t Those entering the area would be given a " stay time" dependent upon the measurements of radiation projected on an accumulated dose (time / radiation) . Dosimetry is in place for distribution to emergency workers along with record keeping cards. F.ecordings are made on a short-term periodic be sis , recorded, and the records must be submitted to the IDNS for evaluation.

Entry would be authorized and carefully controlled under the auspices of the local and State ESDAs and the IDNS. For example, if a kennel owner needed to return to the kennel in the evacuated area for care for the animals , that task might be assigned to I

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emergency workers solely or to the owner with emergency workers ass,isting.

Q.25 In what way has the adequacy of these procedures been verified?

A.25 During the November 6, 1985, joint radiological emergency exercise, the Applicant , State and local provernments effectively demonstrated the capability to efficiently implement the procedures and messages to inform the population of the simulated emergency through the several delivery systems devised by the applicant, State and local governments . FEMA had exercise evaluators at key locations to oversee the demonstration of disseminating emergency information to the affected population.

] O.26 What conclusion have you reached regarding Offer of Proof Issue 2?

A.26 The IPRA provides an efficient way of getting information to the i public promptly. More importantly, the content of the messages has been carefully thought out to protect the safety of the public.

OFFER OF PROOF ISSUE 3 Q.27 What does Rorem Offer of Proof Issue 3 state?

A.27 Offer of Proof Issue 3 states:

Applicant must demonstrate its capability to adequately inform residential and transient popu-lations within the EPZ in the event of an emergency so as to enable the populations to effectively evacuate or shelter including development of the specific means and content of such communications to specific populations.

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Q.28 What is the scope of your testimony regarding Issue 3?

A.28 My testimony will describe the ways in which officials will deliver information to the public at the time -of an accident. I will address the means used to target particular segments of the p gulation of the EPZ.

Q.29 Where are these matters addressed in the IPRA?

A.29 They are addressed in Vol. 1, Chapter ?, Sections E and F; Vol .

VII, Chapter 1, Section C; and Vol. VII-7-SOP-6, 8.

Q.30 Who are the responsible officials?

A.30 The Covernor of Illinois or his representative will first make a general announcement regarding the accident. The County ESDA's initiate the activatien of the PANS, as explained earlier. The County ESDA's are also responsible for the selections and broadcast of scenario-specific messages.

Q.31 What procedures or guidance is offered by the IPRA?

A.31 When the licensee notifies IESDA of the existence of an emergency, IESDA evaluates the situation and, if necessary, notifies the County Sheriffs' dispatchers to activate the system. The system includes sirens and appropriate announcements through those sirens with voice capability, and the mobile alerting as required. The prompt notification system will alert the public to tune to the EBS stations which are identified on page 15 of Vol. VII, Chapter 1, and in' the' public information brochure, for Braidwood Station. The scripts for-i L

the prompt notification announcements and the EBS broadcasts are included as Annex 1A to this Chapter, and Volume 7-SOP-8 Attach-ments C, D and E.

4 The prompt notification system will be targeted to specific populations. The 10 mile EPZ is divided into 16 sectors of 22.50 and each sector is divided into three zones. The first zone is from zero

to two miles from the power plant; and the second is from two to five miles from the plant; and the third is from five to ten miles.

The decision making process by which the IESDA determines when to notify the public of an accident includes a system for determining which of these sectors and zones are affected. The messages which are generated by this process are particularized in that only the affected areas - given specific route evacuation instructions in the event an evacuation is ordered. See Attachments C, D., and E to Vol. VII-7-SOP-8.

1 Generally speaking, the affects.1 population is that which is in the down-wind plume pathway EPZ. The population within the 2-mile i I

radius of the station will be evacuated prior to or simultaneously with any sector determined by field survey teams and the conditions l I

l of the nuclear power station during the accident.

Public notification of protective actions is based on distance and direction from the nucinar power station. Prescripted messages contained in IPRA Volume VII SOPS Braidwood 7-SOP-8 are by

1 l

i mile / sector combinations. The IESDA has written the EBS prescripted messages to use familiar landmarks (roadways ,

waterways , political boundaries, or other geophysical features) for easy identification by the public.

Q.30 Are there any special arrangements for the notification of the transient populction?

A.32 The transient population receives the emergency notification in much the same manner as the residential population. In addition to the mailing of the public information brochure which contains emergency preparedness information and instructions, the State and epplicant made bull; distribution to organizations , businesses, institutions ,

industries, and government agency and department offices and other

places where the public and transients frequent.

The brochure directs attention to sources for immediate emergency information . When the accident escalates to the point it becomes necessary to move a population, law enforcement personnel and other assigned personnel will be positioned at roadway junctions to direct traffic out of the area being evacuated and away from the plume to the reception and care centers.

The IESDA is studying the placement of signs in facilities where transients frequent which direct them, upon hearing the outdoor sirens or indoor tone-alert radios, to listen to the primary EBS radio station for specific instruction.

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G.33 Does the IPRA make any provisions for people who might not be near a radio or television?

A.33 This not specifically addressed by IPRA. However, the sirens in the recreational areas, where the situation is .most likely to occur, have the capacity to carry voice messages. This public address capability could direct individuals to the nearest official source of information. In addition, the routo-alerting component of the PANS has the same capability.

Q.34 In what way have you verified the adequacy of these procedures? ,

A.34 The emergency planning elements and procedures for notifying the resident and transient populations have been reviewed by the RAC and found to be adequate. The implementation of the procedures and messages was a part of the November 6,1985, joint radiological er"ergency exercise. i participated in the evaluation of this exercise. The implementation of the delivery system was found to be effective and adequate. The certification demonstration of the PANS is reheduled for testing in 1986.

Q.35 What conclusions have you come to with regard to the dissemination of information to the residential and transient populations of the EPZ at that the time of an accident?

A.35 I find, as did the RAC, that the provisions of the IPRA for the prompt notification of the public to be adequate. It is also my judgment that the plan can and will be implemented so as to give the public adequate information to allow safe evacuation or sheltering.

i h

OFFER OF PROOF ISSUE 4 Q.36 What does Horem Offer of Proof Issue 4 st&te?

A.36 Offer of Proof issue 4 states:

The Program for notification of the public at the time of an accident is deficient in that it provides no means of informing employers in the EPZ as to what actions they should take with respect to facility shutdown, sheltering, or the release of employee personnel in the event that evacuation is required.

Q.37 What is the scope of your testimony on Offer of Proof issue 4?

A.37 f.ly testimony will address the special attention that is given to major employees , that is, those with more than 25 employees. These employers are encouraged, but not required, to have plann in place for the sheltering or evacuation of their employees, This is not to suggest that no attention is given to smaller employers, but only that the logistics of evacuating or sheltering larger conecntrations of employees are more complex than is the care with smaller groups, i All groups of employees receive the same benefit from the prompt notification system as the general public.

Q.38 Where are these matters addressed in the IPRA?

A.38 Attachmentre F, G, and il to Vol. VII-7-SOP-8, contain a compre-hensive list of specia3 facilities, including major employers, within the 10 mjle EPZ. The list identifies the sector, zone, and community )

that a.ach facility is in, as well as the nace and phone number of an individuct to contact in the event of an emergency. At various )

places throughout this 7-SOP-8, there are references to the i

n.

~ ,

notifiestion of major employers. Seet: ens 4.1(E), 4,2(E), 3.1(E), '

5.2(D) . 6.1(E), 6.2(e) .

3 Q.39 Who are the responsible officials?

A.39 The notification of employers is carr*ed out by local officials. The sheriff and other 17eal law Enforcement officials are reeponsible for notification of major employers and tha recommendatica of protec. tit /p i

actions.

e 0,40 What procedures or guidance are pro 71ded by the IPRA?

A.40 Volunes I and VII and Volume VII SOPS of the IPRA contain the

planning and instructions to notify employers in the Braldwced  ;

I;uclear Power Station EPZ, IPRA Volume VII SOPS , 7-EOP-8 4 outlines the respons!bilitice and actions to be taken by designated

l officitis of the three counties in the 10-mile EPZ. The attachments F, G, H to 7-SOP-8 contain comprehensive lists of the special eeneerns and facilities. I have personally contacted some of the l special concerns and facilities, The local officials have the responsibility of notifying the public nnd structured groups and organizations, It is their responsibility- to notify them of the need to take protective action to protect the health and safety cf those individuals under their care and direction. The local officials cannot direct the employers on facility shutdown. Many industries and businesses have a set procedure 4

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which may require time and some manpower to accoritplish an orderly ceasing of operation.

Th IESDA and the IDNS conducted training for specific groups and

., organizations in the EPZ of the Braidwood Nuclear Power Station as thrt have done in all the other nuclear power stations in Illinois, i

The training consists of organization of planning and the structure for implementing planning. It provides good in-depth participation j and demonstration with respect to radiological exposure and

) protective octions. The training is open to any organized group of citi:: ens and officials on request. The State conducts the first and subseqcent annual training as a required by the IPRA. However, j training can be requested at any time.

i The structured Froups and organizations such as industries and

- businesses have, in most cases, emergency plans which cover a multitude of emergency situations. Among those emergencies is the I

need to evacuate the premises. Particularly in the case of employers, j cmployees have their own means of transportation to get to work,

, therefore there would be sufficient transportation to transport the work force from the crea in the event of a recommendation to evacuate.

The sheriff and other local law enforcement officials are charged with traffic control - responsibilitics. Roadblocks are planned to move i

traffic out of the affected sectors away from the plume. The t

1 evacuated employees would be directed to shelters if their domielle is in the affected sectors. '

If the recommend 9 tion to shelter is made, most of the buildings can be closed sufficiently to afford pK,tection to those who wotild be ,

housed inside. In some caces shelter areas exist within the buildings stich as basements and torn 9do shelters.

1 Q.41 Jn what way have you varifled the adequacy of the plant, regarding i major employers?

A.41 The IESDA has furnished me with records of the training which took place in the Braidwood EPZ in the fall of 1985, prior to the exercise. *

! I attendt.d scme of the training seesions in October 1985. I am l satisfied thM the training is good and is handled by competent instructor.w. In addition, I have pcrsonaUy contacted some of thesc

$ employers.

Q.41 What conclusion have you reached as to the notification of smployers in the event of an cr.ergency?-

A.42 Thc recommendations for protective actionn to employers are much the same as they are for the ger,eral public with respect to shelter-in-place or evacuate. The RAC reviewed the special concerns and facilities portion of the IPFA Draidwood Plans and found them to be adequate. I concur in this judgment. I find that the IPRA makes adequate provision for notifying employers for the I

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4 purpose of advising employees of protective actions to be taken in the; event of en emergency.

OFFER OF PilOOF JSSUE 6 Q.43 h' hat doce Rorem Offer of Proof Issue C state?

1 A.51 Offer of Proof issue 6 states:

Applicant's public infommtion progran is deficient in that it fails to s,et out the means by which the j public will be informed during an emergency of re-entry protective racasttres to be followed by tho ,

public in an emorEency and the content of such means will) respect to information concerning decontemination and intordiction of the foodstuffs, water supplies, dairy and livestock. and field arid garden crops.

J 4

Q.44 Uhat is the scope of your testimony regarding Offer of Proof Isp;ue 6? -

A.44 in my testicerty, I will describe the way in which the contamination cf food, water , and livestock is assessed and information on that l subject is communicated to the public. The issue of restricted and '

i unrestricted re-entry into the EPZ after an accident was discussed earlier under Contention 2. I would incorporate that discussion by reference rath6r than repeat it hero.

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! Q,0 L7hore is tho treatment of contaminated food , Water and livesteck discussed in the IPRA?

f' A.45 This issue is Lddrcssed in Chapters 2 and 6 of Volume I und in 1

Volume VII, 7-SOP-11, Sections 4 through 6, Attachments A throligh -

D, and several sections of the State SOPS Vol. I.

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. i Q.46 Who are the responsible officials?

A.46 The IDMS is responsible for all aspects of radiatiovi exposure,- ,

ineluding the dete$mination of when and under what restrictions it is 1 safe to reenter the EPZ. The Illinois Department of Agriculture i

(IDA) is responsible for the treatment of foodstuffs. The IESDA will i

furnish information to the news media through the JPIC. County

ESDAs will activate appropriate EBS messages.  ;

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j Q.47 What procedures or guidance cre offered by the IPRA?

2 A.47 Chapter 2 of Volume I of the IPRA is entitled Concept.of. Operations. i

! llection 5 deals with Parallel Actions , which include public  ;

information , radiation control, and re-entry. The . IDNS is j responsible for all aspecta of radiation exposure. Chapter 5 (Tech-l nical Functions), Section C.1 (Radiation Aspects of Technical .

Functions) gives a more detailed account of the role of .lDNS in this regard. Section 5,- Part (1), outlines the authority of the IDA to l

inspect , condemn, embargce, and confiscate unwholesome foodstuffs.

l The IDA wiD make such inspections and d$ terminations as called  ;

upon by the IDNS. ,

4 Prior to re-ent.ry, the IDA will monitor agricultural and horticultural l

products to assure that they. are safe for commercial distribution.

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The IDA will report its findinga to the IDNS. As stated in Section 5' i .

i (g), Chapter 2, Volume I, the IDNS will determine when and under r

what restrictions it is safe for the public to re-enter the affected ~

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area and public notification procedures will be implemented.

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The EDS scripts for the re-entry announcements are general. In the case of unrestricted re-entry, no enhancements on the subject of l foodstuffs are necessary. In a partially restricted re-entry, appropriate information will be added. It is accepted that much of the protective action instruction for re-entry will have to be developed as data le gathered from field surveys. Many varlobles f will enter into the determination for safe re-entry and the protective actions to be implemented.

0.48 What conclusion hsve you corne to with regard to protection of the public from contaminated foodstuffs?

• A 48I find that the plan makes adequate provisions for informing the ,

public concerning protectivo measures to be taken regarding food-I . tutis at the time of re-entry.

J COllTENTION__1(b)

Q.49 Ifhat does Eorem Contention 1(b) state?

A.49 Contention 1(b) states:

1. Intervenor contends that an adequate emergency pian for the Braidwood Station should include the following:

(b) assurance that institutions ' within 10 miles of the Station, such as nursing homes, can be evacuated or adequately protected in the event of a radiological emergency, i Q.50 What is the scope of your testimony regarding Contention 1(b)?

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A.50 I will testify about the provisions in the IPRA for the sheltering or ]

1 j' evacuation of the people in schools , institutions such as nursing l homes, and recreational areas.

h Q,51 Uhere are these matters addressed in the IPRA?

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A.51 Arrangemento for sheltering or evacuating these people are found in Volume I and VII of the IPRA and in the SOPS (Standard Operating l Procedures of Volume VII).

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Q.52 Who are the individuals or officials responsible for carrying out P

these procedures?

j A.50 Once - the IESDA recontrends either cheitering or evacuation, the chief elected official of each unit of local government is charged with -

the responsibility of notifying key staff and local or area ,

i l organization of the need to tako protective action.

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Q.53 What procedures or guidance for sheltering ere offered by the JPRA?

l A.53 In the documents referred to chove, particularly the Volume Vit l SOPS . the arrangements and responsibilities for implemeniing l

protective actions and the protective actions are h!ghlighted. For j cxample, if the' utility and State recommend shelter in place,

! institutions such as schools and nursing homes have trained personnel and plans to care for individttals at those locations. The -

i Standard Operatirig Procedures (7-SOP-10 of Volume VII) provide specific guidance for sheltering in such institutions. If the l shettering-in-place option is selected , educational institutions, f

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licensed day care centers, and senior centers would be advised to close doors, windows , and shut down air exchange systems which circulate or mix inside and outside air and implement specific instructions in the SOPS.

Q.54 Vlhat procedures or fruidance are provided by the IPRA for evacuation?

A.54 The Standard Operating Procedures of 7-SOP-10 of Volume VII provide specific guidance for the evacuation of institutions such as nursing homes, schools, licensed day care centers, and recreational areas.

If the order was given to implement evacuation procedures, responsible officials identified in the IPRA Volumes would implement the SOPS, evacuating that portion of the population in the plume exposure pathway of the EPZ. The Braidwood plan has detailed procedures designatingr by title the individuals responsible for giving the order to evacu ate , the points of contact at institutions the actions these points of contact are to take, and the coordination of the necessary materials, supplies and transportation. See Vol. VII Chapters 7-SOP-8, 7-SOP-9 and 7-SOP-10.

If nursing homes are to be evacuated, the residents might require special arrangements for transportation. . Another group of people in the Braidwood EPZ who have special needs are those who live alone or who may be alone during some portion of the day and have .a

physical or medical impairment or no transportation. Provisions are made for these groups of people in the IPRA. As part of the Braidwood plan, the Braidwood public information brochure has a section (6) which solicits submission of information from the public on people with special needs. The county and public social service agencies also gather this information. A list of the people with special needs has been compiled and is retained in confidentiality at the county ESDA office in each of the three counties. For each

! such person, special arrangements have been planned.

In the case of schools, school buses and drivers will be mobilized to transport students and school personnel from the school to designated congregate care shelter locations in accordance with 7-SOP-9 of the IPRA. Licensed day care facilities or nursery schools will evacuate in staff vehicles and additional school buses as needed. Specific instructions for nursery schools are included in IPRA's 7-SOP-P Attachment J.

Recreational areas require special treatment. Those livingr in mobile facilities in camp grounds and parks would be ordered to move from the area of potential risk. Patrons of recreational areas where no large permanent housing exists such as swimming areas, picnic grounds, hunting and fishing sites and golf courses, would be directed to leave the area of potential risk.

- Q.55 Have you in any way verified that these plans will be carried out?

A.55 Yes. During my visits in the 10 mile EPZ of the Braidwood I contacted a random sample of representative institutions and individuals to' discuss their implementation of emergency planning and response to an emergency at the Braidwood Station. I met with individuals representing schools , senior centers, nursing homes, business industry as well as, residents and visitors to recreational arens and ' found people to be cognizant of emergency planning matters. I also attenc'ed training sessions sponsored by IESDA and IDNS for emergency workers, municipal executives and police departments.

4 Q.56 What conclusion have you come to regarding Rorem Contention 1(b)?

A.56 I believe that the IPRA provides reasonable assurance that special concerns such as nursing homes, schools, and recreational areas are provided for in planning and can be protected or evacuated in the event of a radiological emergency.

I base my position on the comprehensive planning in the IPRA Volumes I and VII and the implementing SOPS to both volumes.

Schools and special concerns are addressed in those volume and instructions are given in Volume VII SOPS 9 (schools) and 10 (special concerns). Recreational areas are provided for by the sheriff in coordination with the county ESDA coordinator and _ the superintendent of schools, Volume VII, SOP 8.

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During my visits to the Braidwood area I have made contact with community leaders, businesspersons, and ' citizens and .have gained assurance of their knowledge of the emergency response to an accident at the Braidwood Station. I have also contacted several prsons by telephone using the information in the plans.

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