ML20154N495
| ML20154N495 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/12/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#186-448 OL, NUDOCS 8603170334 | |
| Download: ML20154N495 (200) | |
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ORIGINAL 0 UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-456 OL 50-457 OL COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 and 2) e u .
LOCATION: JOLIET, ILLINOIS PAGES: 885 - 1058 DATE: WEDNESDAY, MARCH 12, 1986 0
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-- ACE-FEDERAL REPORTERS, INC.
Official Reporters 444 North Capitol Street Washington, b.C. 20001 8603170334 860312 (202)347-3700 PDR ADOCK 0500 6 NATIONWIDE COVERACE
/
886 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
__________________x 5 :
In the Matter of: :
6 : Docket No. 50-456 OL COMMONWEALTH EDISON COMPANY : 50-457 OL 7 :
(Braidwood Station, Units 1 :
8 and 2) :
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 9
10 Will County Court House Courtroom #405 11 14 West Jefferson Street Joliet, Illinois 60431
. 12 Wednesday, March 12, 1986 13 14 The hearing in the above-entitled matter reconvened 15 at 9:00 A. M.
16 BEFORE:
17 JUDGE HERBERT GROSSMAN, Chairman 18 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 19 Washington, D. C.
20 JUDGE RICHARD F. COLE, Member, Atomic Safety and Licensing Board 21 U. S. Nuclear Regulatory Conmission Washington, D. C.
i 22 JUDGE A. DIXON CALLIHAN, Member, 23 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 24 Washington, D. C.
L 25 APPEARANCES:
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887 1 On behalf of the Applicant:
2 GEORGE L. EDGAR, ESO.
THOMAS SCHMUTZ, ESQ.
3 DONALD J. SILVER MAN , ESO.
Newman & Holtzinger, P.C.
4 1615 L Street, N.W.
Suite 1000 5 Washington, D.C. 20036 6 On behalf of the Nuclear Regulatory Commission Staff:
7 STUART TREBY, ESQ.
8 ELAINE I. CHAN, ESO.
U. S. Nuclear Regulatory Commission 9 7335 Old Georgetown Road Bethesda, Maryland 20014 10 H. JOSEPH FLYNN, ESO.
11 Federal Emergency Management Agency Washington, D.C.
12
, On behalf of the Intervenor:
13 MS. BRIDGET LITTLE ROREM, 14 117 North Linden Street P.O. Box 208 15 Essex, Illinois 60935 16 17 18 19 20 21 22 23 24
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ELTRESB 1BDEZ 2 JANA S. PAIROW 3 LAWRENCE D. BUTTERFIELD, JR.
4 CROSS EXAMINATION BY MS. ROREM: 888 5
6 GORDON WENGER 7 DIRECT EXAMINATION BY MR. FLYNN 919 8 CROSS EXAMINATION BY MS. ROREM 932 9 REDIRECT EXAMINATION BY MR. FLYNN 970 10 RECROSS EXAMINATION BY MS. ROREM 978 11 996 12 13 JANA S. FAIROW 14 LAWRENCE D. BUTTERFIELD, JR.
15 CROSS EXAMINATION BY MS. ROREM 16 (Continuing.) 1004 17 CROSS EXAMIN ATION BY MR. FLYNN 1017 18 REDIRECT EXAMINATION BY MR. EDGAR 1021 19 RECROSS EXAMINATION BY MS. ROREM 1038 20 21 22 23 24 25 Sonntag Reportina Service,___Ltd.
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b 1 JUDG E GROSEMAN : Good morning, ladies and 2 gentl emen.
3 Tne third day of hearing on the emergency planning 4 of B raidwood is now bef ore us.
5 We ended the second day with Ms. Ror em cross 6 examining Applicant's panel of witnesses, and that panel 7 is still on now, and Ms. Ror em may continue with her 8 examina tion.
9 MS, ROREM: Thank you.
10 BY MS. ROREM:
11 Q Mr. Butterfield, could you please explain what the
's 12 monitoring system is at the plant and off site in terms d 13 of numbers, first of all?
14 A (WITNESS BUTTERFIELD) Do you mean numbers of q(stems 15 and number of detectors?
16 Q Number of detectors, pl ease.
17 A (WIT!!ESS BUTTERFIELD) I am sor ry . I don' t know the 18 number of detectors.
19 Q Okay. So you don' t know at how many locations outside 20 of the plant boundaries they may be?
21 A (WITNESS BUTTERFIELD) The B raidwood Annex to the G SEP 22 indicates the locations of the various kinds of 23 detectors we have, including the continuous air monitors 24 and the thermoluminescent dosimeters and other items s- 25 such as that that we have in the vicinity.
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1 I can ref er to that and count them for you --
2 0 Okay.
3 A (WITNESS BUTTERFIELD) -- but they were in the G SEP 4 Annex.
5 0 Okay. Could you tell me whether these are stationary, 6 whether all parts of these systems are stationary?
7 A (WITNESS BUTTERFIELD) The question is the systems that 8 are described in the Annex are stationary.
F They are permanently installed.
10 They may change; but when they change, we then 11 inf orm the government through normal channels that we F
12 have changed thei r location.
13 So that every six months to a year, this program is 14 updated or may be updated, but they are fixed in 15 position and do not move f rom day-to-day or week to 16 week.
17 Q All right. Do the monitors themselves move? In other 18 wor ds , do they monitor f rom one direction only, do they 19 change directions and monitor f rom dif f erent directions, 20 and do they rotate or something so or do they monitor il all di rections at the same time?
22 MR. EDG AR : Obj ection on the grounds of 23 rel ev ance.
24 I hate to see any nexus between these questions and u- 25 any contention that's been admitted here.
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1 MS. ROREM: I would like to point out that 2 it's important to understand how -- which way a 3 radioactive plume may be traveling in order to 4 ef f ectively evacuate school buses and recreational 5 areas, and to tell these people which directions to go 6 or how to change direction in the course of an ongoing 7 accident.
8 JUDG E G ROSSMAN : Okay. To the extent, then, 9 that you are able to tie this in to the special 10 f acilities, we will allow questions.
11 MS. ROR EM : Thank you.
12 A (WITNESS BUTTERFIELD) The continuous air monitors pull 13 what is considered to be a representative air sample 14 f rom the area, so it would be direction independent.
15 The thermoluminescent dosimeters, which are simply 16 radiation-measuring devices, solid state 17 raciation-measuring devices, would also see the 18 representative area and would not be -- would be set up 19 not to be particularly direction dependent, so they 20 would be independent of di rection.
21 BY MS. ROR EM:
22 Q So -- so evaltiating how the di rection of a plume may be 23 changing in dependent upon looking not j ust at an 24 individual monitor, but at a system of monitors; is this i 25 cor r ect ?
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1 A (WITNESS BUTTERFIELD) We do not -- no, it is not 2 correct.
3 We do not defend upon these systems to tell us 4 where the plume is traveling during the course of 5 ascent.
6 In the first place, we have continuous monitoring 7 systems to determine -- to determine wind conditions, 8 speed and direction. That's why we have the s
9 environmental towers at all of our towers.
10 Both the State of Illinois and commonwealth Edison 11 will send personnel out into the field, during the 12 course of an accident, to monitor f or radioactivity, to 13 take samples and to pull air smmples.
14 Part of this evaluation will determine the plume 15 loca tion.
16 If we assume a change in the wind conditions or 17 wind direction, then they would be expected tc expand 18 thei r area of surveying, so that they can see if, in 19 fact, the plume is going somewhere.
20 0 But the wind monitor is at the plant?
21 A (WITNESS BUTTERFIELD) Yes, ma' am.
22 O In the wind -- are the wind conditions ever dif f erent 23 five or ten miles f rom the plant than they are at the 24 pl ant ?
25 A (WITNESS BUTTERFIELD) In terms of speed, they may be Sonntag_Repor ting _ Service ,...Ltd.___ -
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1 subj ect to some local terrain conditions; but, in 2 gener al, the winds are not uniqu e in one location close 3 to another one or r.earby.
4 Q So you have modeled this plan on an assumption that the 5 wind direction at the center that -- of the EPZ -- that 6 is, at the plant site -- determines that the conditions 7 will be consistent throughout the EPZ ?
8 A (WITNESS BUTTERFIELD) Yes.
9 Q Could you please explain what meteorological basis you 10 hav e f or that?
12 We are now getting into a totally diff erent subj ect 13 matter.
14 JUDG E G ROSSMAN : Sustained.
15 MS. ROREM: I don' t believe it is a diff erent 16 subj ect matter, because I need to know how they can --
17 if the -- if the wind changes in one part of the EPZ, 18 you will -- but not at the plant, you will not have any 19 indication of that, will you?
20 JUDGE GROSSHAN : Excuse me.
i 21 Ms. Rorem, why is this relevant to the special l
22 f acilities ? Is there something peculiar about the 23 special facilities?
24 It appears as though you are trying to attack the
(_- 25 enti re plan.
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1 MS. ROREM: Excuse me. I am not.
2 The specific thing I am concerned about is changing 3 buses -- changing directions on buses which may have no 4 radio capability, and whether or not these people will 5 know if they don' t have an escape ability, are these --
6 are they -- are they -- all right.
7 Even if they do have radio capability, if the 8 people determining which direction they are to evacuate 9 are not aware of wind changes, will they be sending 10 school buses through a contaminated area?
11 JUDG E G ROSSMAN : Ms. Ror em, what difference
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12 does it make whether they are school buses or any other J
13 bus or any other vehicle?
14 If the determination is made at the plant, it's the 15 same for every vehicle evacuating residents of that 16 zone.
17 There is nothing peculiar about the buses as to the 18 location where the determination is made as to wind 19 di rection.
20 In other words, there may be some dif rerence with 21 regard to communication with buses and with vehicles 22 that ordinarily carry radios, but as to where the 23 determination is made of the wind's direction, there 24 isn' t any dif f erence, as f ar as I see.
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J l some questions; but I can' t see that you are doing 2 anything but attacking the plan in general rather than 3 anything r elated to the special facilities.
4 So why don' t you ask another question; but the 5 obj ection to that prior one is sustained.
7 MS. ROREM: Could I ask some procedural 8 questions?
9 JUDG E G ROSSMAN : Cer tainly.
10 MS. ROREM: I understand what it is you are 11 saying; but I don' t understand why questions must be s 12 restricted simply -- since the -- because of the way the d 13 question -- the Contention is phrased, I don' t 14 understand why I am limited to only asking about things 15 that are unique to the evacuation of those f acilities.
16 JUDG E G ROSSMAN : And the reason is, we are 17 not trying to deprive you of your day in court.
18 As to any matter that you might have wanted to 19 raise with regard to emergency planning, that meets the 20 Commission's requirements as f ar as contentions; but it l
21 is late in the day now, and there was a certain time and 22 certain times in which you were to apprise the other F
l 23 parties of the matters that were to be heard at the l
24 (o
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1 hav e f iled, would be heard; and it would be unf air to 2 them and unf air to the Board to have everyone sit here 3 and discuss what you might think are legitimate issues, 4 and perhaps are, but are not part of the case.
5 The case has already been delimited.
6 MS. ROREM: I understand that.
7 But I -- but I f eel that the way the Contention 8 reads , it -- it leaves that open.
9 Because discovery took place last April, before 10 there ever was a plan, it was -- my answers to discovery 11 were very vague because I didn' t have the plan.
L 12 If -- but I f elt that Contention 1(b) was accepted 13 in its entirety earlier on and that, you know, that I 14 wasn' t required to do of f er of proof on -- on 1(b) .
15 JUDG E G ROSSMAN : Yes, but other things have 16 occurred since the Contention was accepted, and one of 17 those things was a requirement f or prefiling testimony; 18 and you have prefiled nothing, so that, re ally , the 19 subj ect matters that you ought to be examining on now 20 are the material f acts that you stated in your of f er of 21 proof, or matters actually raised in the prefi' ed 22 testimony by the other sides -- that is, Staf f and 23 Applicants -- or matters that would reasonably be 24 anticipated would be the subj ect of your cross ja 25 examination; in other words, things that are so directly Sormt a g_R epo r_ti ng_S ervice ,_L t d. -
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1 related to 1(b) that Applicant and staff could 2 reasonably anticipate should be the subj ect matter of 3 their prefiled testimony and would be the subj ect matter 4 of your cross examination.
5 otherwise, you haven' t put them on notice.
6 They are not prescient, where they can read your 7 mind, and they should have a reasonable notice as to the 8 subj ect matter that would be heard.
9 MS. ROREM: So you a re obj ecting because I --
10 you are sustaining the obj ection --
11 JUDG E GROSSMAN : I am sustaining the 12 obj ection.
13 MS. ROREM : -- be ca us e I -- be ca us e I hav e 14 not let them know what the specific concern is, but not 15 because the subj ect matter is not unique to the special 16 f acilities ?
17 JUDG E GROSSMAN : No, that's not exactly 18 correct.
19 MS. ROREM: Okay.
20 JUDG E GROSSMAN : To the extent that these 21 matters are unique to the special f acilities, th ey ,
, 22 perhaps, could anticipate that this would be the subj ect l 23 of your examination, both crocs examination and, 24 pe r haps, rebuttal.
25 But to the extent that it is a general area --
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1 well, there are c number of obj ections; but to the 2 extent that they could anticipate that it would be the 3 subj ect matter of your examination, they are on notice.
4 Now, if the topic is also not related to the 5 special f acilities, it may be outside the contentions 6 that you have; but if you could fit it under Contention 7 1(b), then perhaps it would fit under that Contention; 8 but, nev er thel ess, then you would have j ust the notice 9 probl em.
10 MS. ROREM : Okay. I know it's late in the 11 day for this, and obviously it won' t apply to me.
12 How should I -- should I have prefiled something?
13 JUDG E GROSSMAN : W ell, ce r tai nly, the other 14 parties are as entitled to know what your case is as you 15 are entitled to know what their cases are, and they 16 prefiled the testimony and indicated what their case is.
17 N ow , the deadline f or filing the prefiled testimony 18 was only about two weeks ago or two-and-a-halt weeks 19 ago; and to the extent that you have suoj ect matter now 20 you wish to raise, you could have prepared two weeks 21 earlier and then put them on notice.
22 MS. ROREM: But would I have done this, in 23 terms of these are things that I wish to know, because I 24 don' t cransider that testimony.
25 I' m sor ry, I dont underntand the terminology.
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1 JUDG E G ROSSMAN : Well --
2 MS. ROREM: In other words --
3 JUDG E G ROSSMAN : W ell, if the matters are so 4 directly related to the Contention as one would 5 reasonably anticipate would be covered in testimony 6 offered on that Contention, speaking of Contention 7 1(b) --
8 MS. ROREM: U h- hu h.
9 JUDG E GROSSMAN : -- then I think the parties 10 were on notice that that subj ect matter would be 11 inqui red i nto --
12 MS. ROREM: Well --
13 JUDG E GROSSMAN : -- and may examine on that.
14 But they are entitled to whatever notice you were 15 entitled to; and if they don' t have notice or they can' t 16 reasonably anticipate that the matters would be covered, 17 then those matte.r are not proper for hearing now.
18 You may proceed.
19 MS. ROREM : Okay.
.J JUDG E G ROSSMAN : If you wish to take a f ew 21 minutes now.
22 MS. ROREM : No.
23 JUDG E G ROSSHAN : Okay. Fi ne.
24 MS. ROREM: I -- I guess I see it as being 25 directly related, and I don' t understand wry it's not.
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1 If I see -- I see that, in order to evacuate school 2 childr en, recreational areas and so f orth, it la 3 important to understand the entire idea of has decisiona 4 are made about where -- where evacuation needs to take 5 place and which direction those people need to evacuate.
6 That depends upon the monitoring system; and it 7 also is an important aspect of it, to change directiona 8 if -- if the winds changes.
9 I know that is not specifically particular to those 10 f acilities, but in order -- the way the Contention 11 reads, I don' t see where I am limited to only the inaues
/ 12 that are specific to those particular institutions.
13 MR. EDG AR : The Contention reads, "In terma 14 of assurance that institutions can be evacuated or 15 adequately protected. "
16 It 's pl ain -- Ha. Ror em mentioned her discovery.
17 The fact la she never updated it.
18 If she had other things in mind, that would have 19 been one vehicle for putting un on notice.
20 But she in trying to go into the whole monitoring 21 program, which in a subj ect totally apart.
22 MS. ROEEM: I' m going to get into the 23 nonitoring program only to the extent that it la an 24 important part of the decision making on evacuation f or 25 sheltering.
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1 1 JUDG E G ROSSMAN : In this case, we are running j 2 both afoul of the Contention requirement and the Notice I
3 req ui rement, because what you are raieing now is not ,
4 particular to the special facilities. It applies l 5 equally to any kind of evacuation; and, ther ef or e, does 1
6 not really fit under this contention. l l
7 MS. ROREM: Even though it is part of I l
8 evacuating those special facilities? )
9 JUDGE GROSSMAN: Yes, because it's attacking 10 the general provision f or determining wind direction, 11 which applies equally to school buses and to other
~s 12 vehicles evacuating persons f rom the zone. l
-] 13 There is nothing peculiar to the special f acilities l
l 14 with regard to any suggested def ect in the plan.
15 In other words, Ms. Rorem, we are not going to 16 allow you to attack the entire plan because of alleged i 17 deficiencies in the plan that could also af f ect school 18 buses.
19 The enti re plan, if there are any deficien:les, 1
20 would af fect school buses as well as any other vehicle, )
21 which, under your interprotation, means that everything l l
22 is subj ect to attack, notwithstanding that your ,
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l 23 contentions are not phrased that way. l 24 MS. ROREM: My Contention says, "Intervenor q
x_) 25 contends that an adequate emergency plan f or the l
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1 Braidwood Station should include the following:
2 B, an assurance that institutions within 10 miles 3 of the station, such as nursing homes, ca n be " -- th er e 4 were other things - "can be evacuated or adequately 5 protected in the event of a radiological emergency."
6 I don' t see where -- I don' t see where the wording 7 of my Contention limits what I -- the scope of what I 8 ask f or. I am -- I want those people evacuated saf ely.
9 Now, if it happens that other people are af f ected 10 by that as w ell, that's not something that my -- my 11 wording limits.
g 12 My wording wants those people evacuated saf ely, and
~)
13 if those people being evacuated saf ely is dependent upon 14 the monitoring system, I f eel I have the right to 15 discuss the monitoring system.
16 JUDG E G ROSSMAN : Okay. Well, we have made 17 our determination, then, that that would not be 18 I4rmitted here.
19 MS. ROREM: Okay.
20 BY MS. ROREM:
l 21 Q Ms. Fai row, I would like to discuss the issue of 22 sheltering special facilities, and I am about to get 23 into -- is there a best situation f or sheltering special l
l 24 facilities?
q s) 25 A (WITNESS FAIROW) What do you mean by "a best
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1 situation"?
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2 Q Are there structures which are more easily used as -
3 shelters than others or do some shelters provide more j 4 adequate protection than others?
5 A (WITNESS FAIROW) Do you mean sheltering' in place or 6 relocating and shelters outside?
7 Q I mean sheltering in place. ,
8 I am talking about sheltering in general. -
9 JUDGE COLE: Sheltering as compared to 10 evacuation?
- 11 MS. ROREM: Yes.
e^g 12 A (WITNESS FAIROW) Yes, definitely. There are some types J
13 of buildings that are better shelters than others.
14 For instance, a brick building would be better than 15 a wooden building; but I don' t know the comparisons.
16 BY MS. ROREM:
17 Q Did you do studies on each of the special facilities in 18 which sheltering in place might be required in the EPZ?
19 A (WITNESS FAIROW) The State did not do any studies that 20 I am awar e of .
21 Q Did Commonwealth Edison do any studies of which you are 22 aware of ?
23 A (WITNESS FAIROW) Not that I am aware of.
24 Q So you do not know whether some of the f acilities in a
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1 sheltering f acilities than others?
2 A (WITNESS FAIROW) - mn' t make the j udgment right now.
3 Q Might it be the case that some of the f acilities in 4 which shelters will take place are better sheltering 5 facilities than others?
6 A (WITNESS FAIROW) That is possible.
7 0 Might it be the case that there would be other buildings 8 in a town which would provide shelter than the 9 facilities in which sheltering will take place?
10 , WITNESS FAIRON: Could I have that question 11 read back, pl ease.
12 JULJ E G ROSSMAN : Read it back, pl ease.
/
13 (The question was thereupon 14 read by the Reporter.)
15 A (WITNESS FAIROW) That's possible.
16 BY MS. ROREM:
17 Q But sheltering will take place, according to the plan, 18 in the f acility in which people are already located; 19 correct?
20 A (WITNESS FAIROW) In most ca ses, the reason f or a 21 shelter in place recommendation is that it is -- it 22 would be better at the time for persons to take shelter 23 chan to evacuate.
24 By evacuating, they may be more exposed to more 1
25 radiation than by J ust staying inside.
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904 1 If that was the case, moving them to another 2 building in the town would cause greater danger than 3 leaving them just under shelter in the building th'at l 4 they are in. '
5 0 With how much warning time woul'd this be the case?
6 A (WITNESS FAIROW) That's something' that is situation 7 spe cif ic.
8 0 If a decision has been made that sheltering is the 9 protective action recommended, but there is no -- there 10 are no radiological releases as of yet, are people 11 endangered by leaving a special f acility ?
12 A (WITNESS FAIROW) You are saying there is a take 13 shelter recommendation, but no relecse of radioactivity ?
14 Q Correct.
15 A (WITNESS FAIROW) They are in most danger by leaving the 16 spe cial facility then. ,
17 Q So it might be a better situation f or people to be 18 relocated in another structure, correct, in this 19 ci rcumstance ?
20 MR. EDG AR : In respect to recreational creas?
21 MS. ROREM: I ' m -- no. It's with respect to 22 any special f acilities.
23 I am not talking -- in f act, I wasn' t even thinking 24 about recreational areas.
25 WITNESS FAIRON: Could I have the question read S o nnt_a g_ Rep _o ttin g _S e ry_1. c c ,_L t d .
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2 (The question was thereupon 3 read by the Reporter.)
4 A (WITNESS FAIROW) It may be beneficial.
5 It would depend upon the situation.
6 BY MS. ROREM:
7 Q Does the plan make any provisions f or that 3 recommendation?
9 A (WITNESS FAIROW) Not specifically; but that would be 10 something that would be decided by DNS, pr oba bly, based 11 on the condition in an area and --
N 12 Q Has -- excuse me.
13 A (WITNESS FAIROW) -- the plan is made flexible enough 14 that it can be applied to dif f erent situations.
15 We can' t plan f or every situation that may occur.
16 Q Has DNS, to your knowledge, done any studies on other 17 structures which may provide more adequate sheltering 18 than the -- the f acilities in which people will be for 19 sheltering in place?
20 A (WITNESS FAIROW) Not to my knowledge.
21 0 To your knowledge, does DNS have any plans to do any 22 studies of this natur e?
23 A (WITNESS FAIROW) I don' t know.
24 0 But you have not done any studies of this nature?
25 A (WITNESS FAIROW) No.
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! 906 1 Nor has -- neither the State nor Commonwealth Edison has {
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2 done any? l 3 A (WITNESS FAIROW) Not that I am aware of.
4 0 Why should parents not go to schools -- schools to pick 5 up their children to take shelter, as has been 6 recommended?
7 A (WITNESS FAIROW) The school staf f, the principal, 8 supe rint ende nt, are -- have specica instructions as part 9 of IPRA to f ollow, in the case of both the take shelter 10 and evacuate, to take care of those children.
11 The -- there is no need f or the parento to go 12 there, the children are being taken care of, and in some 13 cases, in a take shelter situation, there may be some --
14 some radiation involved already, if, as I mentioned 15 sarlier, there is a case where sheltering may be chosen 16 over evacuation.
17 0 Will the parents know that there is a radiation danger?
!.8 A (WITNESS FAIROW) They are told in the take shelter
.19 messages not to enter an af f ected area if they are not 20 in that af tected area.
21 Q I am not talking about that.
22 What we are talking about, we are within the EPZ, 23 we are in the af tected area.
24 We are in an area which has been told to take 25 shel ter.
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l 907 1 Are the parents told that there is a radiation 2 danger?
3 A (WITNESS FAIROW) The take shelter messages do say that 4 you should not evacuate at this time.
5 0 That's not .aat I asked.
6 Do the parents know there is a radiation danger?
7 Are they told?
8 A (WITNESS FAIROW) By whom; how ?
9 Q By either EB S messages -- by D3 S messages. ,
1 10 A (WITNESS FAIRQi) The EB S messages say, "Do nct evacuate j 11 at this time. You may be exposing yourself 12 unnecessa rily to unnecessa ry danger. "
13 Q That does not explain what I am asking.
14 Are they told that they are exposing themselves or 15 their children to radiation danger if they go to a 16 s chool, pick their child up and go back home?
17 MR. FLYNN : Your lionor, I believe this 18 question has been asked several times and the answer has 19 already been given.
20 The question is: What inf ormation does the ESB 21 mes sage co nv ey , and Ms. Fairow has already given that 22 answ er .
23 JUDG E G ROSSMAN : Ms. Fa j r ow , is your answer 24 complete as to what the message is that's given?
25 WITNESS FAIROW : Yes.
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l 908 1 JUDG E GROSSMAN : It's already been t rswer ed.
2 Ms. Ror em , I think you have the answer that you 3 want here, so there is no reason to pursue it.
4 MS. ROR EM: I' m sor ry .
5 I am trying, on the basis of your previously 6 sustaining an obj ection by Mr. Edgar, to figur e out how 7 to go after other things.
8 BY MS. ROREM:
9 Q If there is not any radiation release, but sheltering in 10 place has been recommended, what do the Da s messages 11 say ?
12 A (WITNESS FAIROW) The basic EB S message for take 13 shelter says the same.
14 In either case, there may be situation-specific 15 inf ormation added by the county ESDA coordinator.
16 Inf ormation related to a release or wratever would 17 most likely be added by DNS, if there was a need.
18 Q So there is no -- so -- so parents listening would not 19 be told that there was no radiation danger; the message 20 would be the same?
21 A (WITNESS FAIROW) As I said, the county ESDA 22 coordinator could add situation-specific inf ormation it 23 needed; and DNS would provide that type of inf ormation 24 if it was necessary.
25 Q If there is no radiation danger because there has been Sonnt a g_R epo r ti nLS er v i ce , .. L td.. ._ _
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i 909 1 no release yet, why would it be dangerous f or a parent 2 to go to the school, pick up his child and take him home 3 to shelter him?
4 A (WITNESS FAIROW) If there is no release and it's a 5 take shelter, you want to know abat the danger to the 6 parent would be?
7 There would be none.
8 Q So it would not be unacceptable for a parent to wish to 9 pick up his child and shelter him at home?
10 A (WITNESS FAIRON) It would not be unacceptable f or a 11 parent to wish to do that; that's true.
12 0 would he in any way be prohibited f rom picking up his 13 child? ,
14 A (WITNESS FAIROW) I think that would depend a lot upon 15 school policy and what the normal procedures are for 16 parents picking up students and, you know, releasi ng 17 them to their parents or whoever would come to pick up 18 the child.
19 0 Do the schools have any legal authority to stop parents 20 from picking up their children?
21 MR. FLYNN : Obj ection.
22 It calls f or a legal conclusion.
23 JUDG E G ROSSMAN : Overruled.
_, ~ _
24 The witness can answer what she knows about that.
25 A (WITNESS FAIROW) I am af raid I don' t know that.
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1' 1
1 BY MS. ROREM:
2 Q Why would the DB S messages, which state that -- why 3 would EB S messages -- in what way would the u3 S messages 4 give parents the feeling that their children were being l 5 adequately cared f or in the school situation? l l
6 A (WITNESS FAIROW) The EBS messages tell the public that 7 there is no need to go to schools to pick anyone up, 8 because they are being taken care of by the personnel at 9 that f acility.
10 0 In what ways are they being protected?
11 A (WITNESS FAIROW) The principals and superintendents 12 have procedures to f ollow in the event of a take shelter 13 or evacuation; and the -- the school of ficials would 14 follow those procedures to either shelter or evacuate, 15 whichever was indicated to them.
16 Q If the school facilities were not a structure which was 17 provided or which provided the maximum protection f rom 18 radioactive contamination, would it be sensible for a 19 parent to j udge that he should pick up his child and 20 bring him home?
21 MR. EDG AR : That's been asked and answered.
22 MS. ROREM: No. I am saying a completely 23 different thing. It's a dif terent question.
24 JUDG E G ROSSMAN : We will allow this answer;
- 25 but I think you are flogging a dead horse here.
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911 1 We are going over and over again on the same 2 ground; but you may answer that last question.
3 WITNESS FAIRON: May have it read back, pl ease .
4 (The question was thereupon 5 read by the Reporter.)
6 A (WITNESS FAIROW) Well, the schools are prepared to take 7 care of the students in this situation.
8 Whether it is sensible for a parent to judge if 9 the -- the building as is is adequate f or shelter, I 10 don' t know if most parents can make that determination; 11 but I belicyc it would be a parent's inclination, 12 whether sensible or not, to want to go there.
13 BY MS. ROR EM:
14 0 Would you please describe what you -- would you please 15 describe how transients in recreational areas have been 16 provided with inf ormation concerning possible 17 radiological danger ?
18 MR. EDG AR : I ob3 cct to that question.
19 It's cumulative and redundant. That's in the 20 direct. l 1
1 21 JUDG E GROSSMAN : Yes; and it was asked 22 yesterday, al so.
23 MS. ROR EM : All right.
~
- 25 MS. ROR LM : All right. I' m sor ry. It was Sonntag_ Reporting.Servico,_.Ltd. ________ _ _ _ ____
Genev a, Illinois 60134 (312) 232-0262
912 1 asked yesterday; but I was trying to -- trying to 2 re-establish something.
3 BY MS. ROREM :
4 0 If -- hae aggressive has either the State or 5 Commonwealth Edison been in providing copies of the 6 brochure to transients in recreational areas?
1 7 A (WITNESS BUTTERFIELD) The distribution of the 8 brochures f or recreational areas which have persons -- j 9 it's a club where people perhaps will live in the area, 10 would receive them either through the recreational area 11 where we provide multiple copics or could receive them 12 at home through their normal distribution if they live 13 within the EPZ.
14 Now, to be sure that we get these brochures to all 15 of the recr eational areas at the time that we expect 16 peopic will be attending those areas, we make -- excuce 17 me -- we make a distribution in the late spring of the 18 year, to be sure that the areas are -- in f act, are open 19 and there will be someone there to take them and put 20 them -- they are available f or distribution or f or pick 21 up by the persons that are attending.
22 0 Is that number of brochures available limited?
23 A (WITNESS BUTTERFIELD) As opposed to unlimited, yes; 24 but the actual number that we give them, we ask how many 25 they would like. We will provide whatever number they Sonntag_Repor ting. Scryice, _ Ltd. _. .. ___ _ _ _ _
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1 ask for.
2 Otherwise, we will make an estimate of what we 3 think that they will use.
4 0 If they need more copies, they -- and they request them, 5 you will give them to them?
6 A (WITNESS BUTTERFIELD) Yes, ma' am.
7 0 When people enter the State recreational f acilities, are 8 they given a copy --
9 A (WITNESS BUTTERFIELD) It is my --
10 0 -- of the brochure?
11 A (WITNESS BUTTERFIELD) It is my understanding that they 12 are made available.
13 They are not handed them, each one individually.
14 0 So someone must ask f or a copy of the brochure in order 15 to obtain it?
16 A (WITNESS DUTTERFIELD) No. It is my understanding that 17 they are availabic at the sites f or pick up. They would 18 be sitting in the stand or on the location where they 19 could pick them up out without having to ask f or them.
20 0 Do all trannients pass by a place where these brochures 21 are readily available?
22 A (WITNESS BUTTERFIELD) I don' t know.
23 0 What other kinds of inf ormation are provided at the same 24 place where the brochures are available?
\
25 A (WITNESS DUTTERFIELD) At this time there are no other Sonntag_Repor ting..Ser vice, _ Ltd._ _ .. __ _ _ _
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1 provisions made.
2 O So the brochures have their own little stand or whatever 3 in State recr eational areaa?
4 A (WITNESS BUTTERFIELD) That's my understanding.
5 0 Are they at each and every entrance to the State 6 recreational arcan?
7 A (WITNESS BUTTERFIELD) I don' t know.
8 Q So a transient could enter a State recreational area and 9 not go by a main of tice and would not obtain a copy of 10 the brochure?
11 A (WITNESS BUTTERFIELD) That's possibic.
12 Q How of ten would this happen?
13 A (WITNESS BUTTERFIELD) I don' t know.
14 Q Have either Edison or the State done any studica on 15 which entrances are used to State f acilities?
16 A (WITNESS BUTTERFIELD) Commonwealth Edison has not.
17 A (WITNESS FAIROW) The State has not done any studicas 18 but I am sure there are a limited number of accesa 19 pointa to the State parka in the area.
20 0 If there are a limited number of accenoca -- access 21 places to the state parks, are you saying that, at each 22 of these accesa placca, the brochure would be provided?
23 A (WITNESS FAIRO1) No, that's not what I said.
24 0 Well, the answer was i rrelevant.
25 Most of these brochures are not directly seen by
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1 transients, are they?
2 A (WITNESS FAIROW) I think it depends if -- if the 3 people in those recreational areas also live within the ,
4 EPs, _and it also depends if they go into the clubhouse 5 or office or whatever.
6 Q Let's talk about the State recreational parks, and let's 7 assume that people are not f rom within the EPZ.
8 They have not received a copy of the brochure at 9 hom e, hav e they ?
10 A (WITNESS FAIROW) Not if they are not within the EPZ.
11 Q They do not know that they are in an EPZ for a nuclear ,
12 pl ant, do they?
13 A (WITNESS FAIROW) Some may know and some may not.
14 Q But no inf ormation is provided f or them within the EPZ 15 to tell than that they are within the EPZ for a nuclear 16 plant? -
17 A (WITNESS FAIROW) Only the brochure is provided to the 18 f acility.
( 19 Q But they have no reason to search to find a brochure if
! 20 they do not know that they are -- that they are within 21 the area of an EPZ for a nuclear plant?
22 A (WITNESS FAIROW) I suppose that's correct.
23 Q Do most transients pass by an of fice in a f acility? "
- 24 A (WITNESS FAIROW) I don' t know that f or sur e.
25 Q So the distribution of inf ormation about concerning I b i i l Sonntag_ Reporting Serv. ice,_Ltd. [
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1 evacuation and sheltering in a radiological unergency in 2 not necessarily available to all transients in 3 recr eational areas, is it?
4 A (WITNESS FAIROW) It is available at the recreational 5 area; but not all people within that area may see it 6 while they are there.
7 Q Is it readily at hand?
8 A (WITNESS FAIRGI) It is at hand in the of tice or 9 clubhouse.
10 Q Wha t -- in there a copy available f or each transient or 11 each transient f amily that enters a State park or 12 recreational facility in the EPZ ?
13 A (WITNESS FAIROW) I don' t believe so.
14 A (WITNESS BUTTERFIELD) I would like to add to that, I 15 believe that, in f act, there are copies available, and 16 at the time that they run out or would get low, if the 17 park personnel call us, we will replace and r eplenish 18 that supply.
19 So f rom that point of v iew , there would be one 20 available f or everyone who wanted one.
21 0 Isn' t it true that most locationu have at most 50 22 brochures on hand?
23 A (WITNESS BUTTERFIELD) I don' t know.
24 0 Why do n' t y ou kn ow ?
25 A (WITNESS BUTTERFIELD) Becauue I do not go out and hand l
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1 them out to the personnel.
2 People under my direction do that.
3 0 But you are stating that they are at hand, so --
4 A (WITNESS BUTTERFIELD) Yes.
5 0 -- so, ther ef or e, you must have some idea of -- as to 6 how many there are?
7 A (WITNESS BUTTERFIELD) No.
8 0 liow many persons visit the Kankakee State Park 9 recreational f acility on a busy weekeno in the summer ?
10 A (WITNESS BUTTERFIELD) Of f hand, I don' t know.
11 We have those nwnbers f rom the surveys and things.
12 I would have to look that up. I don' t know 13 offhand.
14 Q It's more than 50 persons, inn' t it?
15 In it -- la it more than 507 16 I am trying to avoid those thingo.
17 In it more than 50 pe opl e?
16 A (WITNESS BUTTERFIELD) I would annume that it 10, 19 ce r tai nly .
20 Q So that it there are not more than 50 brochuren on a 21 weekend, there are not brochuren f or each pornon who 22 entern the Kankakee River State Park, are there?
23 A (WITNESS BUTTERFIELD) Given the annumptiona you have 24 given me, that would be correct.
25 Q So unicou you have on hand, per weekend, in the Kankakeo Sonntag Repor ting. Service, Ltd.
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1 River State Park or some other State park, the number of 2 brochurca which is the name au the number of tranciento 3 or the number of transient vehicles which enters the 4 park, transienta do not have the material ready --
S readily at hand, do they ?
6 A (WITNESS BbTTERFIELD) The oppor tunity for a transient 7 -- each and every transient f amily to pick one up would 8 not be there; that la cor rect.
9 MS. ROREM: Could I have a manent, pl eanc ?
10 JUDG E G ROSSMAN : Cer tainly .
11 By the w ay , Mo. Rorem --
12 MS. ROR EM : Yes.
13 JUDG E G ROSSMAN : --
if you wich for un to 14 take a reccou now, that would be agreeable to un.
15 MS. HOREM: Okay. We can do that.
16 JUDG E G ROSSMAN : A 10-minute recesa, then.
17 ( Whe r eupo n, a reccou was had, af ter which 18 the hearing r enumed no f ollown s) 19 JUDG E G ROSSMAN : Back on the r ecord.
20 D aring the r econo, we have diucovered at that Mr.
21 Wenger iL having a back problem and might not be able to 22 laut the whole day; ou we have decided, with the 23 agr ecaent of all the pa r tien, to have him take the utand 24 now, and then, af ter his tentitaony han been completed, 25 to r esume with Applicant' n [>anel .
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1 Mr. Wenger has already been sworn; so that he is 2 now available for examination.
3 Does staf f have any preliminary examination with 4 him in addition to -- oh, you haven' t yet of f er ed his ;
5 testimony; so Mr. Flynn will proceed.
6 MR. FLYNN : Yes. Thanks, your Honor. i 7 GORDON WDiG ER t 8 called as a witness by counsel for the Federal Dnergency 9 Management Agency, having previously been duly sworn by the 10 Chairman, was examined and testified as f ollows:
11 DIRECT EXAMINATION 12 BY MR. FLYNN :
13 Q Will you state your name, please? j 14 A I am Gordon Wenger. My residence is in Michigan, ,
t 15 Cer esco, Michigan, 12,700 11-Mile Road. l 16 Q By whan are you employed and what is your post?
17 A I am employed by the Federal Emergency Management i i
18 Agency, and my position is Emergency Management !
19 Spe cialist. '
t 20 Q You have in f ront ot you a document which is entitled, [
e l 21 " Testimony of Gordon Wenger Regarding Rotem Contentions l f
1(a) and 1(b)."
l 22 23 Are you f amiliar with that document?
24 A Yes, I am.
~_) 25 Q llow does it happen that you are f amiliar with it? !
l l Donntag Repor ting _ Serv. ice Ltd. i l Genev a, Illinois 60134 l l (312) 232-0262 I I t
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1 A It's testimony on my behalf for presentation.
2 0 llave you read it?
3 A Yes, I hav e.
4 0 I have. handed copies of this document to the other 5 partica to this proceeding and the Board and the Court 6 Reporter.
7 It happens that there are some changen in the 8 version that I have j ust distributed in the course of 9 this hearing, changea f rom the pre-filed version of the 10 testimony; and I would like you to go through the 11 document and point out where those changen are and what 12 they are.
13 Let's start on Page 5.
14 In this caso, the change in obvioun, because it' a 15 in a type -- dif f erent type stylen; but can you explain 16 the natur e of the change?
17 A 11r . Fly nn, I don' t have a copy of that my coli.
18 MR. EDG AR : Could we have it m1rked f or 19 identification, just f or once of ref er ence.
20 would that be possible?
21 JUDG E G ROSSMAti It's going to be submitted 22 tor inclusion in the text of the tranucript, no I don' t 23 think it's necessa ry.
24 liR . EDG AR : All right. Fine.
25 BY HR. FLYllli s
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1 Q Do you see the paragraph or the portion of the paragraph 2 that begins, quote, "At the time of the accident,"
3 unquote?
4 A Yes.
5 0 Can you explain what the nature of the change that was 6 mace there is?
7 A In writing this initially, and then, when it was 8 prepared and sent to me, in reading it, it w asn' t cl ear, 9 and to put it ir. better terms and be more precise, we 10 re-worded that pa rt.
11 Q Thank you.
12 Now, turning to Page 7.
13 A Yes.
14 Q Spe cif ically , I direct your attention to the concluding 15 paragraph of Answer 10.
16 Can you explain what change was made in that 17 paragraph?
18 A well, an it states, in pa r t, educaten the public to the 19 need to tune radios or televisions to the Emergency 20 Broadcast System.
21 Televisions are not in the primary Emergency 22 Broadcaut Syst em.
23 0 I think you have got a littic bit ahead of me there.
24 You are ref erring to Anuwer 12?
25 A Yes.
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1 O In Answer 12, we deleted the phrase, "or tel ev isions. "
2 A That's cor r ect.
3 0 Can you go back to the top of the page, the concluding 4 paragraph of Answer 10, the last sentence.
5 A I have that bef or e me.
6 I have no alteration to that.
7 0 I am ref erring to the acntence that says, "The PAN S in 8 the B raidwood EPZ unca airena as the primary means of 9 alerting the public anu mobile public alerting as a 10 backup means. "
11 A (No Response. )
12 JUDG E G ROSSMAN : The witneau' a problem in 13 that it is in the name type, and there in no indication 14 that there la any change; no unican he comparea it with 15 the prior testimony --
16 MR. FLYNN : W3th the permionion of the Boa rd, 17 it will speed thinyJ Up if I am allowed to lead the la witness her e.
19 JUDG E G ROSSMAN : Fine.
20 BY MR. FLYNN :
21 0 ' believe we deleted ref erence to tone-alert radion.
22 A Yes.
23 J What was the reason f or that?
24 A Decause at thin tisac we have no indication f rom the 25 Sta t e, f rom the utility, that tone-aler ted r adios will Lonntag.Repor ting Service, Ltd. _
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1 be used in the EPZ.
2 Q tiow , please turn to Page 9.
3 Will you point out the change at the bottan of the 4 page there?
5 A The change at the bottom of the page in to delete the 6 words, "or televisions," and that's f or the name reason 7 as I presented on Page 7.
8 Q liow , turn to Page 10, and explain the change at the top 9 of Page 10.
10 A The change there in: Route alerting at this point la 11 not a pa rt of the means of notifying the public; no the 12 worcing in " mobile public alerting," which in a ayatem 13 that could be incorporated in the absence of airena, if 14 they happen to f ail.
15 0 Could you explain bLiefly what the dif f er ence in between 16 mobile public alerting and route aler ting?
17 A W ell, route alerting is a part of the Prompt Alert and 18 tiotif ication Systua; in other words, route alerting 19 would ao a turt of the outdoor ai ren system.
20 .n thin case, we ref er to mobile public alerting, 21 which would be emergency vehiclea >nich have speaker 22 systeau and whien could be driven through the area, and 23 it would be it it in basically nccenuary to supplement 24 the primary outdoor warning ui ren cyctua.
25 Q liow , turn to Page 12.
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J 1 A Yes.
2 Q Answer 22.
3 Can you explain the changen in Annwer 227 4 A We clarifled that answer. In place of the acronym, 5 "IESDA," we used the word, " Governor"; and in the last 6 part of that Answer 22, the correct term should have 7 been "IDNS" in place of "IESDA. "
8 Q Now, Page 14.
9 A Yes.
10 Q The top of the page, the last part of Annwer 23, which 11 was the change there?
o i 12 A The dropping of the word, " Chapter, Roman II," no it 13 would be " Attachment D to volume VII-7-SOP-11."
14 Q So that comen out, " Volume Roman VII danh Arabic numeral 15 7 dash SOP dash 11"?
16 A Yes.
17 Q Now, turn to Page 16.
18 A Yes.
19 Q Annwer 31, there are three changen, two of than in the 20 first contence.
21 Could you explain those first?
22 A All right.
23 On Annwer 31, f or gr eater clarity, we changed the i 24 acr ony m, "IESDA" to "the Stato," in the firnt 1ine of n
J 25 Answer 31, and on the second line.
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925 3 i 1 Q Now, in the last f ull line of that page, there are some 2 changes in the ref erence to the IPRA.
3 Can you explain those?
4 A Yes.
5 Next to the last line, we changed that it would be 6 under Annex, an Arabic 1 instead of Roman I, so it's now 7 Annex 1A; and inserted between " Volume" and 7-SOP-8, we 8 inserted Roman VII to show that it was Volume 7.
9 Q Okay. Now turn to Page 17 7 10 A Pardon me, Mr. Flynn if, I may .
11 Q Yes.
12 A Co'J1d we go back to Answer 297
)
13 0 Yes.
14 A Yes, Answer 29, to clarify, we have changed where it 15 naya, They are addrenned in Volume 1. We have changed 16 that f rom Arabic one to Roman I.
17 Q Thank you.
18 Now we are on Page 17.
19 A Yes.
20 0 In the 6 th line there in a change.
21 A Yes.
22 Scratching "IESDA," the acronym, to road, "Sta te. "
23 Q Then in the next paragraph there are several changen. ;
l l 24 Beginning with the second centence, " Population m; 25 within the two-mile radius. "
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1 A Yes; to continue what you j ust stated.
2 " Radius of the station will be" and incert the 3 words, "ahel ter ed or ", and then it would continuo, 4 "ovacuated prior to or simultaneously with any", and it 5 would be "soctor s, " pl ur al, " determined by the field 6 survey teams and" insecting "or. "
7 0 So that comes out, "and alach or"?
8 A That 10 co r r ect.
9 Q Now turn to Pago 18.
10 A Yon.
11 Q The last pa ragraph of Answ er 32.
12 A Yes.
13 To be consistent with our changen in the preceding, 14 we have deleted, on the third lino, the phrane, "or 15 indoor tone-al or t radion. "
16 0 N ow , turn to Page 19.
17 A You.
18 Q The laat contence of Answer 33.
19 A To be consintent, what we have changed in the pre:cding, 20 the contence then reada, "In adcition, the," and we have 21 ucratched "routo" and mndo it " mobile public alerting. "
22 0 N uw , look at Page 27, Annwer 51.
23 A You.
24 The change there, once again, the conuintoney, au 25 we did on the torcyoing, in to ucratch the acronym, l _Lonntag Repor ting Service, Ltd.
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t 1 "IESDA, " and make it "Sta te. "
! l l
2 Q Thank you. ;
i
- 3 I would represent to you that the -- that an errata t
4 sheet was served on the Board and the parties bef ore the j 5 reconvening of this hearing, and that the -- the errors
! 6 which were identified in the errata sheet have been l l :
7 incorporated into the version of the prepared testimony i l 8 which you have bef ore you. l l
9 Now, I think I have already asked you this, but let l
- 10 me ask you again. l
! I i 11 Have you read this?
l i 12 Yes, I have.
] A 13 0 With the changes that you and I have identified, do you 14 endorse this testimony today?
i 15 A 1 do, yes.
l l 16 MR. FLYNN : I move that the testimony, which I t j 17 has been endorsed by Mr. Wenger, be incorporated into 18 the record as if read.
f l 19 JUDG E G ROSSMAN : Any obj ection, Ms. Rorem? !
l 20 MS. H0 HEM: Yes.
21 First of M1, just f or the sake of consistency, 22 might I point out that, on Page 18, Question 33, it l l
23 talks about the IPRA making any provisions f or people l l
24 who might not be near a radio or television. t 25 Do you wish to strike " television" f rom that?
l t
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1 Tile WITNESS: N o.
2 MS. ROREM: Okay. Other than that, I do 3 obj ect to the -- to accepting this testimony in its 4 enti r ety .
5 I would like to of ter a motion to atrike certain 6 parts of thin testimony.
7 J UDG E G ROSSMAN : Fine.
8 MS. ROREM: Specifically, Question 24 and 9 Answer 24, because they are outside the acope of thin 10 contention. They are outside the ucope, because the 11 contents has to do with inf ormation given to persona, 12 not with the provisions, not provisionn that are made 13 f or peopi c, but with inf ormation that la given to them.
14 JUDG E CROSSHAN Mr. Fly nn?
15 MR. FLYNN: If Hu. nor ua repr esentu that that 16 in not pa rt of thin hearing and she does not intend to 17 addr eau that, I have no obj ection to that question and la antwer being atricken f rom the r ecord.
19 JUDG E GROSSHAN : Mr. Edgar?
i 20 MR. EDG AR : W el .' , it's a matter of 21 organization; but re-entry messagen are within the ucope 22 of Otf er of Proof Innue No. 6, that deain with re-entry 23 mensayou.
24 If we underutand that the distinction that Mt.
25 Ror ua drawn, which in between inf ormation or meubagen on l
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1 the one hand, and implementing actiona on the other, 2 then I would have to probica with it, ao long as we 3 temain consistent.
4 JUDG E G ROSSMAN : Well, we will allow Mr.
5 Flynn to withdraw that question and answer because of 6 the obj ection, but we will ask the Reporter to include 7 the entire document, if it in adnitted, including that 8 part. We will order that it it be atricken, but it la 9 only there f or ref erence purposes, in the eventuality 10 that it may be needed in the f uture.
11 MR. FLYNN : Your lionor --
12 J UDG E G ROSSMAN : Ma. Rotun?
13 MS. HOREM: I hav e -- there la another 14 question and ancwer I would like deleted as well.
15 J UDG E G ROSSMAN : Ther e in another question, 16 but not related to thin.
17 Mr. Fly nn.
18 MR. FLYNN: I will be happy to def er to Mo.
19 Rorca at thin time.
20 Go ahead.
21 MS. ROREM: I would like Question and Answer 22 26 also stricken, be ca use th ey a r e -- it' u a -- ther e 23 are -- it's a -- the ancwcr in -- the question and 24 answer are vague and ambinuous and don' t really of f er 25 any testimony.
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7.
1 J UDG E G ROSSMAN : Ms. Ror em , it's a coniclusion ,
2 of an expert witness, for whatever it's worth, and I 3 think we will overrule that obj ection.
4 MS. ROREM: Might I go ahead now?
5 JUDG E GROSSMAN : llave you concluded your 6 obj ections?
7 MS. ROREM: Those are the only two obj ections 8 I have.
9 MR. EDG AR : The Board didn' t hear f rom me on 10 the question of whether the -- I have no obj ection to 11 admission of the testimony.
^T 12 I don' t think the Board has ruled yet.
)
13 JUDG E G ROSSMAN : No, we have not.
14 Mr. Flynn?
15 MR. FLYNN : I havo one other thing, your 16 lionor .
17 I neglected to point out that one of the original 18 questions in the pr e-filed testimony was omitted f rom 19 the current version, and that la the original Question 20 41.
21 Let me addreas a question to Mr. Wenger.
22 BY MR. FLYNN:
23 Q Can you explain wir/ it in that the original Question 41
! 24 han been deleted?
m.- 25 A We f elt the original question, in the tentimony that was Scnntag Reporting _ Service,_Ltd..-
Geneva, Illinois 60134 (312) 232-0262
931 1 prepared, wasn' t directly answered, and really serves no 2 pur po se.
3 Q We are at a little disadvantage in that we don' t have 4 the text of the original. question bef ore us.
5 Do you remember what the subj ect matter was?
6 A I have it.
7 Q Okay. Rather than read the entire question and answer, 8 can you paraphrase it f or us?
9 A It was asking how I made a verification, and my response 10 did not -- was not directed to that question, which made 11 the answer somewhat meaningless.
)
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12 MR. FLYNN : Thank you.
13 At this point I would re -- I would submit the 14 testimony, and, as I understand it, there are no 15 obj ections other than the one Ms. Ror em has already 16 voiced.
17 JUDG E G ROSSMAN : Mrs. Ror em, do you have any 18 obj ection, based on the deletion of Paragraph -- of 19 Question and Answer 41?
20 MS. ROREM: N o.
21 JUDG E G ROSSMAN : Of the original?
22 MS. ROREM: Original ?
23 JUDG E GROSSMAN : Therefore, we now admit the
! 24 pre-tiled testimony, with the exception of Question and H,
'/
.__ 25 Answer --
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Geneva, Illinois 30134 l (312) 232-0262 r
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
COMMONWEALTI! EDISON COMPANY ) Docket Nos. 50-456
) 50-457 ,
(Braidwood Station, Units 1 and 2 )
TESTIMONY OF GORDON WENGER REGARDING ROREM CONTENTIONS 1(a) AND 1(b)
Q.1 Plear.c state your name, your occupation, and your qualifications to testify on behalf of the Federal Emergency Management Agency (FEMA).
A.1 I am Gordon Wenger, Emergency Planning Specialist , with the Technological Hazards Franch, FEMA, Region V. I have held this position for the last six years. 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 , Indiana ,
Michigan, 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.
x_j
,j Q.2 What 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:
. Intervenor contends that an adequate 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 originating at the Station.
(b) assurance that institutions within 10 s miles of the Station , such as nursing 3
homes, can be evacuated or adequately
- protected in the event of a radiological s emergency.
J 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 emergency 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 J emergency so as to enable the populations to effectively evheuate or shelter including development of the specific means and content of such communications to specific populations.
- 4. The procrAm 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 and the content of such means with respect to information concerning decontamination and interdiction of food stu ffs , water supplies ,
dairy and livestock , and field and garden crops.
Q3 What is the Illinois Plan for P.adiological Accidents?
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.
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 which have been assigned to various officials of state and local government and utility companies.
O.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 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 s
in Appendix E to 10 C.F.R. Part 50. In addition, the NRC and the
O Federal Emergency Management Agency have published a guide, NUREG-0654 / FEMA-REP-1, Rev . 1, October 1980, " Criteria for Preparation of Radiological 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, Wi'1, Kankakee and Grundy Counties, and various communities within those counties.
Q.5 Where is the plan for Braidwood found?
A.5 The IPRA is a multi-volume set. Volume One (Vol. I, June 1985) 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 Draidwood 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.
Q.6 What perts 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 IPEA which I have focused on deal with the dissemination of information before, during, and shortly after an accident.
O
6 Q.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.
s Q.8 Who are the individuals or officials who are called upon at these times?
A.8 First, the licensee, 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 m least annually. This was discussed at the October 29, 1985 hearing.
j At the time of an accident, the licensee is responsible. ~for classify 1rg the accident and then for notifying the Illinois Emergency Services and Disaster Agency (TPAnM. and the Illinois Department of Nur'lom- Safety ODtis) . The IIES will evaluate frem a technical pcayective the -licensco's information and m - - +rdations. It then reports its analysis to the Governor. Takirg into account the IDNS analysis, the Governor will direct IESDA to inplment
-apprcpriate protective actions. For exanple, in the event of an accident which. warrants a general energency declaration, the Governor will direct IESDA to'ippIstnent the oee r ciate action for that arv Wnt classification.
includfiry hamfnirs whMT acetors of the EPZ are affected.
The IESDA will notify ~the~Grundy , -
Kankakee, and Will County Sheriff's Dispatchers, who will, in turn, notify the County ESDA Coordinators. Upon the decision by County officials to activate the Prompt Alert and Notification System, the coordinators will notify the County Sheriffs' dispatchers to activate the system. The County ESDA Coordinators will activate the i
Emergency Broadcast System (EBS). The IESDA will set up and y
'] operate the Joint Public Information Center. See Vol. I, Chap. 2, Sections E and F, and Vol. I, Chap. 8, of the IPRA.
f
- 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 unfounded rumors. The JPIC does not take the place of the EDS, but supplements it, especially during the times when the situation is essentially under control and information can be provided in a comprehensive and unhurried way.
Q.10 What is the Prompt Alert and Notification System?
A.10 The Prompt Alert and Notification System (PANS) is the means by
'T which government officials call the public's attention to an emergency d
condition. Section IV.D.3 of 10 C.F.R. Part 50, Appendix E, states:
[T]he design objective of the prompt public notification system shall be to have the capability to essentially complete the initial notifier. tion of the public within the plume exposure pathway EPZ within about 15 minutes. The use of this notification capability will range from the immediate notification of the public (within 15 minutes of the time that State and local officials are notified that a rituation exists requiring urgent action) to the more likely events where there is substantial time available for the State and local governmental officials to make a judgment whether or not to activate the public notification system.
The design of the PANS is within the discretion of the Applicant, subject to evaluation under criteria set forth in NUREG 0654/FEf.1A-REP 1, Rev.1. and Guide for the Evaluation of Alert and a
d Notification Systems for Nuclear Power Plants, Appendix 3 FEP1A-REP
(
l O 10. A PANS typically uses sirens as the primary vehicle for alerting the public. Some systems, however, rely on tone-alert radios ,
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 means of alerting the public and mobile public alerting as a backup means.
Q.11 What is the EPZ?
A.11 The acronym EPZ refers to the " Emergency Planning Zone." There are 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 pathwey EPZ, which has a 10 mile radius in the case of the Braidwood Station.
Throughout my testimony, I am referring to the 10 mile EPZ unless I indicate otherwise.
Q.12 Once the PANS is activated, how does the public know what actions to take? ,
A.1? 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 o. . . . . _ _ _ _ . . _ to the Emergency Droadcast System
h (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.
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 IV.D.3. Within 15 minutes after the power plant operator determines that an cmergency crists, it must notify State officials. The State officials then evaluate the information provided by the utility and make a decision on activating the PA!!S. They decide whether to activate the entire system. This is a prccess 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 sections of the EPZ affected by the emergency, and they contain specific information about the protective action recommended by the governmental officials.
_g_
G 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 then to the plume.
CONTENTION 1(a)
Q.15 What does Rorem Contention 1(a) state?
A.15 Contention 1(a) states:
- 1. Intervonor contends that an adequate 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 originating at the Station.
O.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. Hou 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 EBS; and thirdly, there is the JPIC.
The PANS in the Braidwood EPZ relles primarily on sirens to alert people to the existence of an emergency and the need to tune their radios or-televisions to an EBS station. As discussed below in
connection with Offer of Droof Issue 3, some of the sirens and all of wk \ ~%h the route-alterting vehicles used in this PANS have the capability to deliver voice messages.
The EBS is activated by State and 10."1 officials, as discussed in my Answer 8, above. The EDS is the primary means of delivering
~
scenario-specific information to the public at the time of an accident.
The EDS systen 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 Answer 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 an 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 *he plan by O
the Regional Assistance Committee (RAC). The RAC found the plan to be adequate in that regard and I concur.
OFFER OF PROOF ISSUE 2 Q.19 What does Rorem Offer of Proof Issue 2 state?
A.10 Offer of Proof Issue 2 states:
Applicant must develop and demcnstrate 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 througrh all radio, TV or EDS 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.
Q.20 What is the scope of your testimony on this issue?
A.20 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.
O
Q.22 Who are the individuals or officials responsible for carrying out these procedures?
G. u ewe 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 elFSDA EONS determines that unrestricted re-entry is safe.
Q.23 What procedures or guidance arc offered by the IPRA?
A.23 The IPRA identifies several delivery systems to disseminate emer-gency information.
The Draidwood 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, frequents . The brochure provides significant general emergency 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 emergenev information.
The IPRA Volume VII and SOPS contain prescripted messages which are to be read by officialc over the EBS radio and prescripted messages which are to read to the media by information specialists at the JPIC.
O
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 recommender' 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 informatict. Tathered by the IDNS will determine if re-entry would be ret tricted or unrestricted .
O Vol. VII-7-SOP-11 is entirely 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 safe , the County ESDA Coordinators will initiate the broadcast EDS 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 EDS 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 tinnouncements of
unrestricted and restricted re-entry appear as Attachment D to ChapteHI, Vol. VII-SOP,. ,,
Q.24 What provision is made for those people who may need tc, re-enter the EP" after an evacuation has been ordered but before the general public is allowed to re-enter?
A.24 Where 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 the IDMS advisement.
Those entering the area would be given a " stay time" dependent upon the measurements n' radiation projected on an accumulated dose (tine / radiation) . Dostuetry is in place for distribution to emergency workers along with record keeping cards. Itecordings are made on a short-term periodic basis , 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 night be assigned to emergency workers solely or to the owner with emergency workers assisting.
O
. O 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 governments effectively demonstrated the capability to efficiently implement the procedures and messages to inform the population of the simulated emergency through the several delivery cystems 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.
Q 26 What conclusfor $. ave you reached regarding Offer of Proof Issue 2?
A.26 The IPRA provides an efficient way of getting information to the public promptly. Plore importantly, the content of the messages has been carefully thought out to protect the safety of the public.
OFFF" OF PROOF ISSUE 3 Q.27 What does Rorem Offer of Proof Issue 3 state?
A.27 Offer of Proof Issue 3 states:
Appliennt must demonstrate its capability to adcquately 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.
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
O the means used to target particular segments of the population of the EPZ.
Q.29 Where are these matters addressed in the IPRA?
A.29 They are addressed in Vol. I, Chapter 2, Sections E and F; Vol .
VII, Chapter 1, Section C; and Vol. VII-7-SOP-G, 8.
Q.30 Who are the responsible officials?
A.00 The Governor of Illinois or his representative will first make a general announcement regarding the accident. The County ESDA's initiate the activation of the PANS, as explained earlier. The County ESDA's a;c also responsible for the selections and broadcast of scenario-specific messages.
Q.31 What procedures or guidance is offered by the IPP.A?
A. G L A.31 When the licensee notifies +EGDA of the existence of an emergency, 4L Gh_ .
-IEfrDA 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 EDS stations which are identified on page 15 of Vol. VII, Chapter 1, and in the public information brochure, for Braidwood Station. The scripts for the prompt notification announcements and the EDS broadcasts are w
included as Annex :!A to this Chapter, and Volume,37-SOP-8 Attach-ments C, D and E.
I
- O The prompt notificatien 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 mi.as from the plant; and the third is from five to ten miles.
4&
The decision making process by which the-lESDA 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.
D Generally speaking, the affected population is that which is in the down-wind plume pathway EPZ. ,The population within the 2-mile
% tk. .a c <
radius of the station will be evacuated f prior to or ninultaneously
,(f with any sector determined by field survey teams and/the conditions of the nuclear power station during the accident.
Public notification of protective actions is based on distance and direction from the nuclear power station. Prescripted messages contained in IPRA Volume VII SOPS Braidwood 7-SOP-8 are by mile / sector combinations. The IESDA has written the EDS prescripted messages to use familiar landmarks (roadwayr:,
waterways, political boundaries, or other geophysical feat ures) for easy identification by the public,
O R.32 Are there any specini arrangements for the notification of the transient population?
A.32 The transient population receives the ccorgency 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 applicant made bulk distribution to organizations, businesses , institutions, industries, and government agency and department offices and other placer 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 transien's fregu nnt which direct them, upon hearin g the outdoor sirens cr-indcetune~ alert radios, to listen to the primary EDS radio station for specific instruction.
Q.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. liowever, the sirens in the recreational areas, where the situation is most likely to occur,
O have the capacity to carry voice messages. This public address capability could direct individuals to the nearest official source of w v e\ rNm information. In addition, the route-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 emergency exercise. I participated 1:1 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 scheduled for 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.
9 1
G OFFER OF PROOF ISSUE 4 Q.36 What does Rorem Offer of Proof Issue 4 state?
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.
O.37 What is the scope of your testimony on Offer of Proof Issue 4?
A.37 My testimony will address the special attention that is given to major employers , that is , those with more than 25 employees. These employers are encouraged, but not required, to have plans 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 concentrations of employees are more complex than is the case with smaller groups.
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 Attachments F, G, and 11 to Vol . Vil-7-SOP-8, contain a compre-hensive list of special facilities , including major employers, within the 10 mile EPZ. The list identifies the sector, zone, and community that each facility is in, as well as the name and phone number of an individual to contact in the event of an emergency. At various places throughout this 7-SOP-8, there are re ferences to the
notification of major employers. Sections 4.1(E), 4.2(E), 5.1(E),
5.2(D), 6.1(E), 6.2(e) .
O.39 Who are the responsible officials?
A.39 The notification of employers is carried out by local officials. The sheriff and other local law enforcement officials are responsible for notification of major employers and the recommendation of protective actions.
Q.40 What procedures or guidance are provided by the IPRA?
A.40 Volumes I and VII and Volume VII SOPS of the IPRA contain the planning and instructions to notify employers in the B raidwood Nuclear Power Station EPZ. IPRA Volume VII 7-SOP-8 outlines the D responsibilitics and actions to be taken by designated officials of the three counties in the 10-mile EPZ. The attachments F, G, II to 7-SOP-8 contain comprehensive lists of the special concerns and facilities . I have personally contacted some of the special concerns and facilities.
The local officials have the responsibility of notifying the public and structured groups and organizations. It is their responsibility to notify them of the need to take protective action to protect the health and safety of 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 D
S which may require time and some manpower to accomplish 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 they have done in all the other nuclear power stations in Illinois.
The training consists of organization of planning and the structure for implementing planning. It provides good in-depth participation and demonstration with respect to radiological exposure and protective actions. The training is open to any organi:ed group of citizens and officials on request. The State conducts the first and subsequent annual training as a required by the IPRA. l'ow ever ,
g training can be requested at any time.
The structured groups 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 need to evacuate the premises. Particularly in the case of employers, employees have their own means of transportation to get to work, therefo-e there would be sufficient transportation to transport the work force from the area in the event of a recommendation to evacuate.
The sheriff and other local law enforcement officials are charged with traffic control responsibilities. Roadblocks are planned to move traffic out of the affected sectors away from the plume. The
I evacuated employees would he directed to shelters if their domicile is in the affected sectors.
If the recommendation to shelter is made, most of the buildings can be closed sufficiently to afford protection to those who would be housed inside. In bomo cases shelter areas exist within the buildings such as basements and tornado shelters.
Q.41 What conclusion have you reached as to the notification of employers in the event of an emergency?
A.41 The recommendations for protective actions to employers are much the enme as they are for the general public with respect to shelter-in-place or evacuate. The RAC reviewed the special concerns and facilities portior. of the IPRA Braidwood Plans and found them to be adequate. I concur in this judgment. I find that the IPRA makes adeauate provision for notifying employers for the purpose of advising employees of protective actions to be taken in the event of an emergency.
OFFER OF PROOF ISSUE 6 Q.42 What does Rorem Offer of Proof Issue 6 state?
A.42 Offer of Proof Issue 6 states:
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 anergency of re-entry protective measures to be followed by the public in an anergency and the content of such means with respect to information concerning S deconticlination and interdiction of the foodstuffs,
. O water supplies, dairy and livestock, and field and garden crops.
Q.4 3 V,' hat is the scope of your testimony regarding Offer of Proof Issue 6?
A.43 In my testimony, I will describe the way in which the contamination of food, water, and livestoci: is assessed and information on that subject is communicated to the public. The issue of restricted and unrestricted re-entry into tne EPZ after an accident was discussed earlier under Offer of Proof Issue 2. I would incorporate that discu;ision by reference rather than repeat it here.
Q.44 Where is the treatment of contaminated food , water and livestock
- discussed in the IPRA?
A.44 This issue is addressed in Chapters 2 and 5 of Volume I and in Volume VII, 7-SOP-11, Feetions 4 through 6, Attachments A through D, and several sections of the State SOPS Vol. I.
Q.45 Y'ho are the responsible officials?
A.45 The IDNS is responsible for all aspects of radiation exposure, including the determination of when and under what restrictions it is safe to reenter the EPZ. The Illinois Department of Agriculture (IDA) is responsible for the treatment of foodstuffs. The IESDA will furnish information to the news media through the JPIC. County ESDAs will activate appropriate EBS messages.
x
. O Q.46 What procedures or guidance are offered by the IPRA?
A.46 Chapter 2 of Volume I of the IPRA is entitled Concept of Operations.
Section 5 deals with Parallel Actions , which include public information, radiation control, and re-entry. The IDNS is responsible for all aspects of radiation exposure. Chapter 5 (Tech-nical Functions) , Section G.1 (Radiation Aspects of Technical Functions) gives a more detailed account of the role of IDNS in this regard. Section 5, Part (1), outlines the authority of the IDA to inspect, condemn , embargo, and confiscate unwholesome foodstuffs.
The IDA will make such inspections and determinations as called upon by the IDNS.
Prior to re-entry, the IDA will monitor agricultural and horticultural products to assure that they arc safe for commercial distribution.
The IDA will report its findings to the IDMS. As stated in Section 5 (g), Chapter 2, Volume I, the IDNS will determine when and under what restrictions it is safe for the public to re-enter the affected aren and public notification procedures will be implemented.
The EDS scripts for the re-entry announcements are general. In the case of unrestricted re-entry, no enhancements on the subject of 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 is gathered from field surveys. Many variables
h will enter into the determination for safe re-entry and the protective actions to be implemented.
Q.47 What conclusion have you come to with regard to protection of the public from contaminated foodstuffs?
A.47 I find that the plan makes adequate provisions for informing the public concerning protective measures to be taken regarding food-stuffs at the time of re-entry.
CONTENTION 1(b) 0.48 What does Rorem Contention 1(b) state?
A .48 Contention 1(b) states:
- 1. Intervenor contends that an adequate
- emergency plan 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.
Q.49 What is the scope of your testimony regarding Contention 1(b)?
A.40 I will testify about the provisions in the IPP.A for the sheltering or l
l evacuation of the pecple in schools , institutions such as nursing homes, and recreational areas.
Q.50 Where are there matters addressed in the IPRA?
. O A.50 Arrangements for sheltering or evacuating these people are found in Volume I and VII of the IPRA and in the SOPS (Standard Operating Procedures of Volume VII).
Q.51 Who are the individuals or officials responsible for carrying out these procedures?
Mah_
A.51 Once the -iE8DA recommends either sheltering 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 organization of the need to take protective action.
Q.52 What procedures or guidance for sheltering are offered by the IPRA?
A.52 In the documents referred to above, particularly the Volume VII SOPS, the arrangements and responsibilities for implementing protective actions and the protective actions are highlighted. For example , if the utility and State recommend shelter in place, institutions such as schools and nursing homes have trained personnel and plans to care for individuals at those locations. The Standard Operating Procedures (7-SOP-10 of Volume VII) provide specific guidance for sheltering in such institutions. Il the sheltering-in-place option is selected , educational institutions, licensed day care centers, and scritor centers would be advised to clore doors, windows, and shut down air exchange systems which circulate or mix inside and outside air and implement specific instructions in the SOPS.
l
. O Q.53 What procedures or guidance are provided by the IPRA for evacuation?
A.53 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 procedu res ,
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 designating 7 by title the individuals responsible for giving the order to evacuate, the poin ts 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 night require special arrangements for transportation. Another group of people in the Braidwood FPZ who have special needs are those who live alone l or who mav be alone during some portion of the day and have a l
phycical or medical impairment or no transportation. Provisions are made for these groups of people in the IPRA. Ao 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 cervice
. O 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 scht,el 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-EOP-D Attachment J.
Recreational areas require special treatment. Those living 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.54 llave you in any way vcNie, that these plana will be carried out?
A.54 Yes. During my v@ 1
- ie 10 mile EPZ of the Braidwood I contactcd a random sample of representative institutions and indivkfuals 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,
businesses , industry as well as, residents and visitors to recreational areas and found people to be cognizant of emergency planning matters. I also attended training sessions sponsored by y IESDA and IDNS for emergency workers, municipal executives and police departments.
Q.55 What conclusfon have you cor'e to regarding Rorem Contention 1(b)?
A.55I believe that the IPRA provides reasonable assurance that special conce:ne 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 tmergency.
s I base my position on the comprehensive planning in the IPRA Volumes I and VII and the implementing SOPS to both volumes.
Fehools and special concerns are addressed in those volumes and instructions are given in Volurae VII SOPS 9 (schools) and 10 (special concerns). Recreational arans are provided for by the sheriff in coordination with the county ESDA coordinator and the superintendent of schools, Volume VII, SOP S.
During my visits to the Braidwood area I have made contact with community leaders, businesspersons, and citizens and have 6 ined assurance of their knowledge of the emergency response to an accident at the Draidwood Station. I have also contacted several perscns by telephonc using the information in the planc.
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1 JUDG E COL E: 24.
2 JUDGE GROSSMAN : -- 24, which will 3 nevertheless be included in the transcript f or ref erence 4 pur po ses.
5 MR. FLYNN : Okay.
6 JUDGE GROSSMAN : You may proceed, Mr. Fly nn.
7 MR. FLYNN : I have nothing f urther at this 8 time.
9 The witness is available f or cross examination.
10 JUDG E GROSSMAN : Ms. Ror em ?
11 MS. ROREM: Thank you.
^m 12 CROSS EXAMINATION :
13 BY MS. ROREM:
14 O Mr. Wenger, on Page 3, do the pages f ollow the same all 15 the way through on either copy ?
16 I am using the new testimony.
17 A Yes.
18 Q Page 3.
19 Question 3 and Answer 3, you have stated that -- in 20 the last sentence -- that the IPRA is a record of the 21 responsibilities which have been assigned to various 22 of ficials af state and local government and utility 23 compa nien.
24 In that cor rect ?
25 A Yes.
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1 Q In what way are there provisions f or insuring that these 2 responsibilities are clearly understood by each and 3 every public of ticial?
4 A I don' t believe I stated there are prov .sions. I say, 5 it's a record of res ponsibiliti es.
6 Q Okay. In what way does IPRA provide f or a record -- I 7 believe that's my question -- if IPRA is a record of 8 res ponsibilities, how was it assured that each and every 9 public of ticial, who has duties and responsibilities 10 under IPRA, is adequately inf ormed?
11 A Due to the planning process that's taken place and the 12 involvement of these organizations, there is reasonable 13 assurance that it will be carried out.
14 0 Are you saying that -- that -- that means meetings and 15 training sessions are adequate to assure that all of 16 these public of ticial are adequately trained?
17 A The training and exercising that takes place, there is 18 reasonable assurance that they are adequately trained.
19 0 But the exercises are limited, ar e they not -- I am not 20 supposed to say -- the excise is limited in any way?
21 A Could you expand upon what you mean by " limited"?
22 0 When an exercise takes place, are public of ficials aware 23 that the exercise is to take place?
24 A There is some spontaneity to the exercise program, in 25 that they are not given inf ormation ahead of time as to Son _nt aMepo_r ti ng_S er.y_ ice ,_Ltd.
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1 the date and time; but they -- a specific date and time; 2 but they have a f ramework of ref erence for when the 3 exercise will take place.
4 Q So they are on alert that, at some point in a given 5 amount of time, there will be an exercise conducted?
6 A They are sensitiz ed to this, yes.
7 0 So that they don' t plan to go on vacations during this 8 time or leave the area?
9 A I cannot say that.
10 0 If there is an accident,' these same public of ficials are 11 not aware that an accident will take place, are they?
12 JUDG E GROSSMAN : Excuse me, Ms. Ror em.
13 What contention are we on now?
14 MS. ROREM: I think this is somewhat general; 15 but it's dealing with the specific.
16 When I think about public of ficials, I think about 17 thei r duties and responsibilities in terms of evacua ting 18 spe cial f aciliti es.
l 19 Mr. Wenger --
20 JUDG E GROSSMAN : So we are on the 21 subcontention dealing with special f acilities?
22 MS. ROREM: Yes.
23 JUDG E GROSSMAN : You are going to connect l
24 this up to special f acilities then?
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/
25 MS. ROREM: Nell --
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1 JUDG E GROSSMAN : If you are not, then, you 2 k now , there is no point to going into this.
3 MS. ROREM: Whether or not school of ficials 4 are prepared f or handling an accident will matter a 5 great deal and will depend to a large extent about --
6 upon the activity of the public of ficials who may 7 contact them and to have to know what their duties and 8 responsibilities are.
9 JUDGE GROSSMA:1: If you are doing this in the 10 context of contacts with school officials and you are 11 going to tie that in, we will allow you to go ahead; but 12 to the extent you don' t tie it in, re ally , is j ust going 13 to waste our time here, and you certainly won' t be able 14 to ref er to it in your proposed findings, so you are on 15 notice for that; but you can rephrase your last 16 question, because the witness had trouble with it 17 anyway, and so did we.
18 BY MS. ROREM:
19 Q Are cchool of ficials some of the public of ficials who 20 are involved in exercises?
21 A Yes.
22 O Are these school of ficials aware of the f act that an 23 exercise will take place?
24 A To the same degree as governmental of ficials are.
25 Q Okay. Isn' t it true that, if there is an exercise which S o n nt a g_R epo rli n g_S e r v_ ire ,_L t d ,_ __
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'l evacuates schools, that school of ficials have to be 2 maare of it?
3 MR. EDG AR : I obj ect to the form of the 4 . question. It's an "isn' t that true?"
5 JUDGE GROSSMAN : Ov er r uled.
6 Would you please repeat the question, Mr. Reporter.
7 Do you want the' question?
8 THE WITNESS: I do, yes.
9 (The record was thereupon 10 read by the Reporter.)
11 A And the answer to that is yes.
m 12 BY MS. ROREM:
1 s-13 Q' Are -- is every part of the plan which may involve 14 school of ficials, exercise -- in an exercise -- in other 15 words, are there parts of the plan -- I' m sor ry. I 16 don' t mean to ask compound questions, but I r ealiz e I 17 asked an ambiguous one.
18 Are there parts of the plan which are -- which !
19 involve schools and school officials -- which are never 20 exercised in an -- in an exercise?
- 21. A I can' t answer that, when you say "never. "
22 Q Are all parts of the plan -- for instance, has there l.
1
[ 23 ever been the evacuation of an entire school?
24 A No, not f or a nuclear power plant demonstration. i,
(> 25 Q And not f or IPRA; correct?
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1 A I don' t know.
2 The reason I state I don' t think so, I am speaking 3 only to a nuclear power plant demonstration.
4 IPRA covers more than a nuclear power plant 5 mal function, it covers transportation accidents.
6 I am not involved with that, I am involved with the 7 nuclear power plant f unction.
8 Q Okay. With regard to nuclear power plants, there are 9 parts of the plan -- for instance, the evacuation of an 10 entire school -- which have never been exercised; 11 correct?
12 A Not correct.
13 Maybe I don' t understand the question thoroughly.
14 I am trying not to be overly technical.
15 Could the question please be rephrased to me?
16 JUDGE GROSSMAN: Could you repeat that, Mr.
17 Reporter.
18 (The question was thereupon 19 read by the Reporter.)
20 A (Continuing. ) With regard to the entire evacuation of 21 the school, that is correct, they have never been 22 exercised.
l l 23 BY MS. ROREM:
l l 24 Q Are there any other instances where parts of the plan t
) 25 which might involve schools or school of ficials have not l
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1 been exercised?
2 A I don' t think I can answer that question.
3 JUDGE GROSSMAN : There are no other instances 4 that you can think of; is that the reason wly you can' t 5 answer that?
6 THE WITNESS: The question is conf using to me.
7 JUDG E GROSSMAN : Per haps you can rephrase it 8 in some way that he could understand it, Ms. Ror em.
9 MS. ROREM: I' ll try .
10 JUDG E GROSSMAN : Let me ask you a question.
11 Are there any other items, with regard to the 12 schools, other than entire evacuations, that have not 13 been exercised, to your knowledge?
14 THE WITNESS: N o.
15 MS. ROREM: Okay.
16 BY MS. ROREM:
17 Q Have the responsibilities of school bus drivers during 18 re-entry ever been exercised?
19 MR. EDG AR : Obj ection on relevance.
I 20 Ms. Ror em herself moved to strike the testimony of 21 Mr. Wenger having to do with implementing actions during 22 re- ent ry .
23 Contention or Of f er of Proof Issue 6 deals with the 24 contents of r e- ent ry mes se.ge s.
L 25 Now, that question gets into implementing actions Sonntag_Repor. ting . Serv. ice , _Ltd...- _
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1 during r e-entry.
2 If we are to accept Ms. Ror em's own motion to 3 strike and act consistently, that question is 4 obj ectionable.
5 MS. ROREM: I withdraw the question.
6 JUDGE GROSSMAN : I beg your pardon?
7 MS. ROREM: I withdraw the question.
8 JUDG E GROSSMAN : Mr. Wenger, might there be 9 some other elements of the plan, with regard to the 10' schools, that have not been exercised, that you 11 currently don' t remember or are unaware of ?
T 12 THE WITNESS: I can' t think of any.
w) Fine.
13 JUDG E G ROSSMAN :
14 BY MS. ROREM:
15 Q Mr. Wenger, have you ever sheltered an entire school 16 during an exercise?
17 A Has the State of Illinois or the local communities ever 18 shelter ed?
19 0 Yes.
20 An entire school?
21 A An entire school population?
22 0 Yes.
l 23 A During an exercise?
l l 24 Q Yes.
p
(_) 25 A Not to my knowledge.
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1 Q Would you say those are the t wo maj or - responsibilities 2 for school of ficials under IPRA, to shelter and to 3 evacuate?
4 A No.
5 Q Why wouldn' t you say that?
6 A Because school of ficials have a responsibility to 7 coordinate busing activities to transport people f rom 8 the af f ected area.
9 JUDG E GROSSMAN : Isn' t that part of the 10 evacuation?
11 THE WITNESS: Yes.
12 JUDG E G ROSSMAN : Well, considering that part
'~
13 of the evacuation, wouldn' t the two main f unctions of 14 the school officials then be to evacuate and to shelter?
i
. 15 THE WITNESS: In that sense, yes.
I 16 BY MS. ROREM:
17 Q On Page 10, Question and Answer 18, concerning the 18 Emergency Response Plan f or Braidwood Station exercise,
! 19 you say that the RAC f ound the plan to be adequate in j 20 that regard and you concur.
j 21 Could you tell me what were some of your criticisms 22 of that exercise?
23 HR. FLYNN : Obj ection.
I 24 J UDG E G ROSSMAN : I am conf used.
25 MR. FLYNN : Excuse me.
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1 The exercise concerned a lot more than -- well, I 2 am not sur e which.
3 JUDG E GROSSMAN : First of all, are we on the 4 right question and answer here?
5 MS. ROREM: 10 and ll.
6 MR. FLYNN : The -- the context of Question le 7 is Contention 1(a) , and is more involved than the 8 exercise.
9 The question is restricted to the parts of the 10 exercise and the exercise review that pertain only to 11 question 1(a) . I would agree that it's permissible, but 12 to the extent that it courses the entire exercise, I 13 would say say it's overly broad and i rrelevant.
14 JUDG E G ROSSMAN : What question are we on, Ms.
15 Ror em,17 and 18?
16 MS. RORU4: It's at the bottom of Page 10.
17 JUDG E GROSSMAN : I thought you had said 18 Question 10.
19 MS. ROREM: Oh, I' m sor ry .
20 JUDG E GROSSMAN : It may be my f ault, but w e 21 are on Question 18 now, and I will have the Reporter 22 read back the question you posed and the obj ection by 23 Mr. Fly nn.
24 (The record was thereupon 25 read by the Reporter.)
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942 1 1 JUDGE GROSSMAN : Ms. Ror em, we will sustain 2 the obj ection.
3 If you want to make your question more specific 4 with regard to the contention, we might possibly allow 5 it.
6 BY MS. ROREM:
7 0 Mr. Wenger, what were some of your criticisma concerning 8 sheltering of any special facilities?
9 A I still don' t have enough inf ormation to answer that 10 question.
11 Are you addressing the exercise or the RAC's review
'N 12 of the plan?
13 0 I am -- I am -- th e R AC' s r ev iew , in your criticisms of 14 the exercise, have you any criticisms of the exercise --
15 A of the exercise?
16 0 -- as regards sheltering?
17 MR. FLYNN : Same obj ection.
18 Your lionor, Contention 1(a) deals with a program 19 for inf orming the public f or means of obtaining 20 instructions f or evacuation and other protective 21 measures.
22 The question was addressed to evacuation itself, 23 rather than the means of inf orming the public.
l 24 MS. ROREM: Excuse me. I f eit I also could q
x_1 25 discuss any criticisms -- criticisma he might have had
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?. of the exercise as regards Contention 1(b) .
2 JUDG E G ROSSMAN : If I understand this, you 3 are saying now that is related to Contention 1(b)?
4 MS. ROREM: No. It might be related to both 5 parts of the contention.
6 JUDG E GROSSMAN : Well, with regard to 7 Contention 1(a), could you point to any material f acts 8 that you have indicated in your off er of proof that this 9 relates to?
10 MS. ROREM: Not the question about sheltering 11 special facilities, but if I were to restructure the 12 question and ask about public inf ormation --
13 JUDG E GROSSMAN : Well, if you are withdrawing 14 the question and posing another, we will rule on the 15 other question.
16 MS. ROREM: I guess what I am asking:
17 Is it permissible for me to ask what criticisms he 18 might have had of the exercise in regard to Contention 19 1(b)?
20 JUDGE GROSSMAN: If you are relating this 21 question to 1(b).
l 22 MS. ROREM: I guess I would like to ask 23 questions on both 1(a) and 1(b) with regard to the 24 exe r ci se. i 25 JUDG E G ROSSMAN : Well, Ms. Ror em, if there is i
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1 an obj ection to your question, that it is going beyond 2 the scope of what we have here, and you oppose the 3 obj ection on the grounds that it's under 1(a) and 1(b),
4 we will examine both 1(a) and 1(b).
5 Appa r ently , the obj ection is valid with regard to 6 1(a).
7 Now, you are saying that your question is alco 8 related to 1(b) , and we will rule on that.
9 MS. ROREM: Yes, yes. The question as it 10 originally was posed, I understand, is too broad and 11 includes matters both outside of 1(a) and 1(b); but in 12 Mr. Flynn's obj ection, he mentioned that I should be 13 talking about 1(a) .
14 JUDG E G ROSSMAN : No, you can fit it in under 15 either 1(a) or 1(b).
16 MS. ROREM: Yes.
17 JUDG E G ROSSMAN : But it doesn' t fit under one 18 of th en.
19 MS. ROREM: Okay.
20 JUDG E GROSSMAN : Just ref er to the other one 21 that you think this fitc in.
22 MS. ROR EM : That's what I did.
23 JUDG E GROSSMAN : So I didn' t waste any time, 24 you did say it fits under both, and we decided it t
25 doesn' t fit under 1(a), and now we will consider that it Sonntag_R epot ti ng_ Serv. ice, _ Ltd.___ . _ . _ ._
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1 might fit under 1(b) .
2 MS. ROREM: I am conf used.
3 JUDG E G ROSSMAN : It appears as though, if 4 you' re ref erring to 1(b) , that the question is a proper 5 one.
6 Do you understand the question now, Mr. Wenger?
7 Tile WITNESS: No; but I think I need counsel 8 with my attorney first.
9 JUDG E GROSSMAN : You wish to conf er with your 10 counsel?
11 Tile WITN ESS: Yes.
12 JUDG E GROSSMAN : Fine. Why don' t you?
13 MR. EDG AR : I have lost -- in there a 14 question pending? I am co nf use d --
15 JUDG E G ROSSMAN : There is a -- we will have 16 the Reporter read it again.
17 (The record was thereupon 18 read by the Reporter.)
19 JUDG E COLE: The ancwor is going to be too 20 f ar away question f rom the question.
21 J UDG E G ROSSMAN : Okay. We are going to 22 overrule -- I am sor ry -- we are going to sustain the 23 obj ection, and -- let's go.
24 Are we back on the record?
l 25 Tile R EPO RT ER : Yea, si r.
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1 JUDG E GROSSHAN : -- because that is still too 2 broad a question.
3 If it's directed towards sheltering with regard to 4 institutions, such as nursing homes or schools, then we 5 will entertain such a question.
6 So, Ms. Rotem, will you please restate a question 7 for the witness.
8 In other words, if you are going to ask him about 9 all the inadequacies with regard to sheltering, but not 10 directed toward special f acilities, it's too broad f or 11 us.
3 12 MS. ROREM: The question that was asked just 13 bef ore that did say of special facilities.
14 JUDG E GROSSMAN : Okay. But rather than 15 having to incorporate two questions --
16 MS. ROREM: Yes.
17 JUDG E GROSSMAN : -- into one, why don' t you 18 state another question f or the witness.
19 BY MS. ROREM:
20 0 Wer e there any criticismo, on either RAC's part or your 21 part, of the exercise as regards sheltering or l
22 evacuation of any special f acilities?
I 23 A No.
24 Q Thank you.
s
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1 either your part or RAC's part, of the public 2 inf ormation associated with the exerciae?
4 That's too broad.
5 That doesn' t relate down into the of f er of proof, 6 material tacts.
7 JUDG E GROSSHAN: W ell, let's change that 8 question with regard -- to add to it, the limitation as 9 to any of the areas covered in the material facts stated 10 by Ms. Roram in her reply to Applicant and Staf f's 11 motions.
12 Have you acen the material f acts stated by Ma.
13 Ror em as being in inaue in this proceeding, in that 14 document entitled, " Reply to Applicant and NRC Staf f 15 Motions f or Summary Dispositions on Of f er of Proof 16 Issues"?
17 THE WITNESS: I have seen that.
18 JUDG E G ROSSMAN : You have?
19 THE WITNESS: Yes.
20 JUDG E GROSSMAN: N ow , if you take the 21 question in the context of having to relate to any of 22 these material inauca, were ther e any such?
23 Can you ancwcr the question?
24 THE WITNESS: The question, if I recall, was 25 any dincrepancica in the public inf ormation lion nt a g Jt epo r ti ng _ Ser v ice , _ Ltd. ___ . _ _ _ _ _
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1 demonstration during the Braidwood exercise?
2 JUDG E GROSSMAN : Yes.
3 JUDG E COLE: Although the question didn' t 4 have the word " demonstration" in it, I think that would 5 be implied.
6 Just use the term, "public i nf ormation. "
7 THE WITNESS: Give me a moment to ponder 8 that, because within a short period of time we had 9 another exercise, and so I can clarify the two.
10 I don' t recall any that were of a serious 11 magnitude.
12 BY MS. ROREM:
13 Q But there were come criticisms?
14 A Yes; but I don' t think they are r eally relevant, in that 15 it was like the placement of a tabic at the entrance for 16 security measures and those things; but as to getting 17 out of inf ormation, no.
18 0 Wer e ther e any criticisms of the substance of the 19 inf ormation provided during the exercise --
20 A I don' t r ecall.
21 0 --
of the public inf ormation during the exercise?
22 A I don' t r ecall any.
23 0 Does that mean that you don' t know or that there were 24 none?
' 25 I don' t believe ther e wer e any.
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1 Q Do you -- but you don' t really know one way or the other 2 whether there were or not?
4 Asked and answered.
5 A I cannot be.
6 JUDG E GROSSMAN : It has been, Ms. Rorcm; and 7 when you asked f or a negative like this, it's impossible 8 to give any turther answer. The witness can only 9 testify as to what he knows.
10 BY MS. ROR EM:
11 Q Okay. Mr. Wenger, on Page 11, Question and Answer 20.
12 Af ter an accident occurs, do you f eel that the 13 inf ormation which is given to the public is adequate to 14 inf orm them of radiological hazards which might be 15 encountered by them on r e-entry ?
16 A I cannot conclude that, because there is -- there are 17 general statements which will be read; but addi tional 18 inf ormation will be a result of the accident itself, 19 what further the ESDA and IDNS of ficials may deem 20 necessary to inf orm the public.
21 Q How will they inf orm the public?
22 A There are two mechanisms, one being through the 23 Emergency B roadcast Sy st em , and the other being through 24 the -- what is known as the News Media Center, or 25 ref erred to as the JPIC, Joint Public Inf ormation Sonntag_Hepotting_ScrV.ico,_Ltd. _ ____
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1 Center.
2 O When you ref er to the DB S stations, are you ref erring to 3 the prescripted messages only?
4 A For re-entry, f ollowing an accident?
5 0 Yes.
6 A Which I think you are ref erring to in 7-SOP-ll?
7 0 Yes.
8 A Dependent upon if it's restricted re-entry or general 9 r e- ent ry , those are the messages -- the general message 10 will be read, but other inf ormation will be availabic.
11 Q But those are the only messages that have been developed 12 to date, then?
13 A In that hard form, yes.
14 But that does not preclude any other inf ormation 15 being developed, and there is provisions in IPHA f or 16 doing that.
17 0 The inf ormation that -- in the prescripted messages --
18 does not speak about radiation, does it?
19 A I am f amiliar with those messages, but I would have to 20 read them to be that specific.
21 At this point, that's a f air statement, I believe.
22 THE WITNESS: That's okay. Please excuse me.
23 MS. ROREM: That's f ine.
24 THE WITNESS: I have a muncle spacm.
- 25 That's okay. I will be okay.
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1 JUDG E COLE: Her e. Let's raise that 2 microphone up.
3 (Indica ting. ;
4 THE WITNESS: Thank you.
5 MS. ROREM: If the witnean would like to take 6 a br eak, I am mor e than willing to do so.
7 JUDG E G ROSSMAN : He's always welcome to ask 8 for a break, if you pref er, but I think you prefer to go 9 on.
10 THE WITNESS: I would like to proceed so we 11 can accomplish all we possibly can; okay?
12 MS. ROR EM : Okay.
13 BY MS. ROR EM:
14 0 Have any proceduren been developed f or dissemination of 15 inf ormation concerning radiological dangers to the 16 public bef ore r e-entry or during r e-entry into the EPZ ?
17 A Could you restate that, pl ease ?
18 0 Have any procedures been developed f or disseminating 19 inf ormation to the public about radiological dangers 20 upon -- bef or e or upon r e-entry into the EPZ ?
21 A Yes.
22 0 would you describe those procedures?
23 A That's quite a task, and that's getting a little bit out 24 of my area of expertine; but I would have to say that in 25 provided f or in the IPRA to Volume 1. which in the State SDn nt a g_R epo r_ti ng_S cr v.i ce , _ Lt d. __
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1 general plan. There are the SOPS, which largely cover 2 the activities of the IDNS.
3 Q They describe them gene 6 J.ly, don' t they ?
4 A They are characterized in a general way; and they will 5 be, once again, with gr eater specificity, at the -- at 6 the latter part of an accident.
7 As you state in re-entry recovery phases, there is 8 the latitude within those plans to expand those SOPS or 9 the announcements, and it's drawing on the knowledge and 10 the wisdom of the Illinois Department of Public Ilealth 11 and the Illinois Depattment of Agriculture, other State
'N 12 agencies, which serve as counsel and advisors to IDNS.
~)
13 Q Are there plans specifically in IPRA, or dealing with 14 any factual inf ormation to be given, besides that which 15 will be given via EBS messages or through the media 16 center?
17 A It's hard f or me to draw that conclusion.
18 I guess I would have to say at this time, no, there 19 are no f actual, hard-copy documents, other than the two 20 that we have mentioned already, to make the public aware 21 of it.
22 Q Thank you.
23 Mr. Wenger, on Page 18, Question and Answer No.
l 24 32, deals with the transient population, ano the v3
-m. ) 25 inf ormation which the transient population receives.
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q
~-) i 1 You state that Applicant made bulk distribution to 2 or ganiz ations, busines se s, et cetera.
3 Do you know the size of these bulk distributions?
~
4 A I know the size of that distribution to the extent that 5 I was provided a printout by the State of Illinois of [
6 the number of copies made available to specific 7 addresses and organizations, yes.
8 I do not have that with me.
9 Q Do you know what the general number of copies delivered 10 to any location were, such as businesses or --
'll A When reviewing that document, I recall numbers like 200, t
12 100, 50.
13 Q We are talking about businesses.
l 14 Did the numbers of brochures made available roughly 15 correspond to the number of unployees at those t 16 businesses? l 17 A No. -
t 18 Q Do you Pnow what any basis was f or determining that it
[
19 wasn' t necessary to distribute the number of brochures .,
20 adequate to cover all employees?
'21 A As I recall, in reviewing the material that was provided f 22 me, which was -- there was an explanation and a cover [
23 letter, it indicated a bulk distribution was made, 24 memory serves me cor rect, in so many -- the idea is that 25 discussions were held with the people at those l
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1 locations, and it was indicated by that busincas the 2 number of copies they felt would be necessary, and it 3 indicated, I believe, if any mor e copies w er e necessa ry ,
4 they could be contacted, the Illinois ESDA would get 5 them to them.
6 I think it --
7 0 200 --
8 A Excuse me.
9 0 200 was the upper limit on the number of -- of copies 10 you recall being distributed to any one location?
11 A Well, it broke it down in this manner :
12 It said that every addressee and every service user 13 mailing was maue, and then the bulk distribution, and it 14 listed recr eational locations, mo t el o, county of fices, 15 ESDA offices and such, and it gave numbera.
16 I can' t be certain that 200 was the upward number.
17 Now that you mention it, the number 500 comen to 18 mind 19 0 Do you remember at what location that it comen to mind?
20 If it doesn' t come to mind at any particular 21 location --
22 A No.
23 And the question might be: "W hy not?" W ry don' t I 24 look at that more closely.
25 I guess I base that on experience with thin State Sonntag_Repor ting Service , _Ltd.- ._
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1 and with the utility, there being other power plants, 2 and knowing what is taking place, how they go about the 3 business of distribution, and f or the f act that I had 4 visited Personal Products and talked with people there, 5 and I asked the question, and it happened to be bef ore 6 any bulk distribution was made, if they had received 7 copies, and no, they hadn' t at that point; but empl oy ees 8 had made indication that they had received these in the 9 mail; so my judgment would be that people who work 10 there, there is a good chance many of those people would 11 have copies, plus what might be made available through
~3 12 the empl oy er, is my rationale f or f eeling it was
)
13 provided f or and covered.
14 Q So you -- but you do not know the same inf ormation about 15 transients who would be at various locations within the 16 EPZ, either at recreational f acilities or passing 17 through?
18 A The transients receiving them or the distribution to 19 that location where they frequent?
20 0 The distribution to the locations.
21 A W ell, once again, I have the addresses; and I can' t i 22 recall exact numbe r s. I have visited some of those 23 locations; and that was, of course, last October.
24 0 Could you tell me what some of the locations you visited m) 25 were?
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1 A I drove along both sides of the river. I believe it's 2 ref erred to as Kankakee State Park, and went into some 3 of those areas. I guess it's on the north side of the 4 river, drove in.
5 Of course, in the f all, there were limited people 6 there, but I was looking f or the things that ycu are 7 asking about.
8 Of course, the brochure was not -- as I recall --
9 not distributed at that time.
10 0 Why was it not?
11 It had been distributed to the --
12 A Early October, late Set.t ember?
13 Q It had been delivered to the general public in time f or 14 the -- well, when was it ths: you were along the 15 Kankakee River State Park?
16 A It's in my mind it was mid September.
17 Q So y ou didn' t -- so you haven' t been through these areaa 18 or stopped at any any of these places since the 19 distribution of bulk quantities has been made?
20 A I have -- I have been through the area when the exercise 21 took place.
22 0 But you said you stopped at locations.
23 That stopping --
24 A Not.
25 Q That stopping was bef ore the distribution was made?
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1 A Yes.
2 I wanted to become mor e -- more f amiliar, on a 3 personal contact basis, with your area.
4 0 Could you tell me why, in Question 33, at the bottom of 5 that page, you leave " television" in there?
6 Is that because of the media center, use of 7 tel ev ision, per haps?
8 A Well, maybe a little explanation, in a general manner.
9 The Emergency B roadcast System in this area are two 10 principal stations, let's call them primary.
11 When the call is made f rom the county or f rom the 12 State to the E3 S station to give them inf ormation f or 13 broadcast, they are the two stations that will do your 14 other stations in the area. Radio, FM, AM, and 15 television will be monitoring them, and they will pick 16 up that same inf ormation and rebroadcast it; so those 17 would be secondary to where it says, "Does IPRA make any 18 provisions f or people who might not be near radio or 19 tel evision?" The assumption is t Maybe this is not 20 initially f or the initial, primary message. That's wly, 21 when you questioned that, I f el t I should leave it in.
22 0 Okay. But not every person who might not be near a 23 radio or television would be in a rec area, would they?
24 A (No Response.)
25 0 Your question discussed that the situation was most S90Dta.g_RcpoLtinLScrv. ice,_ Ltd _ _
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1 likely to occur in rec areas.
2 A I think the doubling up of your question has conf used me 3 a little bit.
4 0 I' m sor ry.
5 I didn' t want to make you lean over to read.
6 A No; that's all right.
7 Could you give me the question again? Piecemeal 8 it.
9 Q Excuse me. I' m sor ry. I am feeling f or your back.
10 Not -- it -- is it true that not all people who are 11 no t -- no, this is -- I am getting conf used.
12 Not all people who are away f rom a radio or 13 television will be in a rec area; is this correct?
14 A Yes, that's true.
15 Q On Page 20, Question -- Question and Answer 37, can you 16 tell me how enployers are encouraged -- I' m sor ry -- to 17 have plans in place regarding the sheltering and 18 evacuation of their employees?
I 19 A CECO, Commonwealth Edison Company, and Illinois 20 Emergency Services, are quite visible at the State level 21 and in the community, and they are called upon to make 22 presentations; and there are local of fices, of course, 23 with CECO there is a district office, and with ESDA 24 there is a county organization, and it's very active.
- 25 JUDG E COLE: I' m sor ry .
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1 What was that first acronym you were using?
2 THE WITNESS: Ceco, which is the acronym for 3 Commonwealth Edison Company.
4 JUDG E COL E: I' m sor ry .
5 A (Continuing. ) What I am getting at is:
6 Maybe, by a secondary f actor, they are made aware 7 of what's taking place in the communities; and the ESDA 8 organizations are eager to make presentations, make 9 materials, br ochur es, publications available. It isn' t 10 only in light of nuclear power plants, but it's 11 tornados; so in these discussion there are many dangers 12 that a community f aces, and they meet with civic
'~
13 or ganiz ations, and there is a prompting to become 14 involved and to make planc f or em er ge nci es.
15 BY MS. ROREM:
16 Q But is there a specific campaign carried on by either 17 ESDA or the State or Commonwealth Edison to encourage 16 empl oy er s --
19 A Yes.
20 0 -- to?
21 A Yes.
22 0 Is there a specific program?
23 A Yes.
24 Q Can you describe that program?
25 A The ESDA and the IDNS have an ongoing training program Sonntag ReppLtinglerylce,_Ltd.
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1 by regulation, according to NUREG, that they must 2 provide for a program of training and retraining.
3 0 But how does this program encourage employers to have 4 plans f or a f acility?
5 A The program is made known through meetings and 6 organizations which people attend, encouraging and 7 soliciting this training program.
8 It is, to a large degree, mandatory for emergency 9 or ganiz ations, but it's made available for any groups of 10 pe opl e, or ganiz ations, employ er s, to r equest this 11 inf ormation and training.
12 Q But it's made available.
13 That's dif f erent than having a program specifically 14 aimed at encouraging employers.
, 15 A It's not mandatory.
l 16 Q Has it been requested by all the maj or employers in the 17 EPZ ?
18 A It has not been requested by all the maj or employers in 19 the EPZ.
20 Q On Page 23, it's Question and Answer 40, the second para 21 -- actually the first f ull paragraph at the top of the 22 page, you stated that, "If the recommendation to shelter 23 is made, most of the buildings can be closed 24 suf ficiently to af f ord protection f or those who are to
_- 25 be housed inside. "
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1 You mean most of the buildings, in a specific way, 2 to an employer, or do you mean that in terms of overall, 3 most of the buildings?
4 A I can' t dif f erentiate between what you asked.
5 0 Okay. If an employer might have five or six buildings 6 in which work is going on, and you might mean that most 7 of those buildings can be closed suf ficiently, or you 8 might mean, with this statement, that most of the 9 buildings in the EPZ, which house employees, could be 10 closed suf ficiently, 11 Do you understand the dif f erence?
12 A I understand your question.
13 My concluding that was: If you had a maintenance 14 garage that did not have doors that closed, you couldn' t 15 shelter and protect inside f rom what we hoped to 16 accomplish.
17 If there were some of those maintenance buildings, 18 those people could be brought into other buildings.
19 What I am saying is that, according to the 20 regulations, the guides, NURDG 06 54, is that by closing 21 windcas, maybe even curtains, closing doors, turning off 22 ventilation systems that mix air or bring in f resh air, 23 those kinds of things can be done suf ficiently to 24 protect people.
25 0 Are you saying that j ust about any structure can provide SonntaaReppLting_SerXice,_Ltd.
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96 2 1 adequate shelter af ter taking certain simple 2 pr ecautions?
3 A You changed my words.
4 0 I am asking if you are saying that.
5 A I am saying "most. " Most of the buildings can be closed 6 s uf f iciently .
7 0 All right. Are there any employers who have only one 8 building?
9 A That I do not know.
10 Q Are there any?
11 A I --
~
12 O Are there any employers that have only one building 13 which may not be a shelterable building?
14 A That I do not know.
15 I am not responsible for conducting a survey of 16 those. I would have to def er that to the State.
17 Q Do yoa know if any surveys have been done to determine 18 that?
19 A Going back in the experience of the approach to this 20 total planning in and around a nuclear power plant, I 21 feel that it had been done, and by chance, by the NRC.
22 I think they, along with the utility, look at existing 23 structures to see what the structural base is, and I 24 draw that experience f rom Byron Station, that, you know, 25 it was a question. There had been some survey conducted Ronntag__Repor ting Rervice,ltd.
Geneva, Illinois 60134 (312) 232-0262 1
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1 as to the shelterability in an area.
2 Q But do you know if any specific study had been done f or 3 Braidwood by the State or Edison?
4 A No.
5 Q On Page 29, the second f ull paragraph, you discuss 6 recr eational areas.
7 Are you assured that all persons who are hunting or 8 fishing or golfing or bicycling will be -- or on f oot --
9 reached with messages?
10 A Fy sel f, my agency, the RAC, we have reasonable assurance 11 that will be accomplished.
12 Not absolute assurance.
13 Q Would someone meimming, f or example, be able to hear the 14 si rens?
15 A The anbwer to that question -- it isn' t really an answer 16 yes or no. I can' t address that specifically, if they 17 were under water or above water or splashing.
18 But let me add to this.
19 It isn' t only sounding the fixed si ren, but there 20 is a respcnsibility on the part of the DNR or the 21 Sheriff's patrol that might be waterborne, or of the 22 Corps of Engineers, if it's in the area of the pool, 23 that they will go out on the water and clear the water, 24 notify peopl e. If it's a swimmer in the water, indicate 25 to that person there is a problem, get to shore right Son nt as_Repo r timg_S ery_i ce ,_L td .
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1 aw ay.
2 0 Mr. Wenger, how are you assured that transients in the 3 area will know what to do on the basis of public 4 inf ormation that is given to them?
5 A The -- our assurance is f rom the planning f or the Prompt 6 Alert Notification System, pagers or radio equipment 7 that State parks and other recreational-type parks of 8 that nature will have; the public inf ormation brochure; 9 basically those.
10 0 Mr. Wenger, if a transient is not in a recreational 11 area, how does he know -- how does he know what to do in 12 the event of a nuclear accident?
4 13 A I think there is an awful lot to be considered here, 14 because my feeling would be, you know, to be more 15 specific, as to what phase of the accident, what 16 cl as sifica tion, immedi at ely, since somebody on 17 Interstate 55, traveling south, and they enter into the 18 EPZ, and there is has been a warning by siren, I think 19 they would hear it.
20 If not, or if it happened at some point in time, 21 there is going to be a blockade; and as people come up 22 to this blockade, it will be said that you can' t enter.
23 You are di rected to dif f erent directions.
24 0 Let's assume that someone is within the EPZ already and
/
_- 25 the warning sirens go of f.
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1 What do the EB S messages tell him, if he has a 2 radio?
3 A EB S messages would indicate that there has been an 4 accident at the station, at the power plant, and tnat 5 mor e direct inf ormation will follow.
6 Usually that announcement comes f rom the State.
7 Then the county makes available site specific 8 inf ormation, that people located in certain geographic 9 location by -- listed by geographic f eatures, rivers, 10 roads, et cecera, are -- if it becomes necessary to 11 ev acua te, are to leave that area. Evacuation routes are 12 discussed or are announced, and care locations 13 designated.
14 0 If a person -- if there is not an evacuation 15 recommenda tion, how is a transient to shelter?
16 A (No Response.)
17 0 If there is no evacuation recommendation, but there is a 18 sheltering recommendation, how is a transient to 19 shelter ?
20 A I have to think about that a moment.
21 I am thinking of a case that -- well, the -- they 22 would hear the siren, because as a protective action, it 23 would be announced that there has been an accident and 24 that the recommendation is f or sheltering.
) 25 You are to stay indoors, close windows, all that Son nt a g R ep_o_rlimg_Ec rXi ce2_L td.
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1 kind of thing; and I think a person in a car, or where 2 ever they may be, could comprehend that. they must get to 3 some location to gain this protective measure, which 4 could be in a public building. I think that would 5 accommodate people who are mobile.
6 0 If they are not near a place of business, is it 7 recommended that they knock on the nearest door and ask 8 for entrance?
9 A N o, it is not recommended.
10 0 Is anything really recommended at all to the transient?
11 A W ell, in the respective telling them to get under cover
~T 12 -- protection, into a sheltered area, but there is --
J 13 pardon me -- not a recommendation to enter a certain 14 buildi ng, but it's -- the generic senses of : "Take 15 ,
,tective cover. "
16 0 The recommendation, as it's -- as it is contained in EB S 17 messages, doesn' t it say, "Go to your place of 18 residence" or -- it doesn' t say anything that is 19 specific to someone who might be in transit and not near 20 a place of -- not near a public building?
21 A I don' t recall.
22 0 Does it --
23 A I don' t recall that it says, "Go to your residence. "
24 Q Let's go back to the equipment then.
q x_/ 25 On 7-SOP-8, do you have a copy of the Standard Son ntaa R epor ti_ng_Ect.y_ise,_._Ltd.
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1 Operating Procedures with you?
2 A Yes.
3 Q Attachment C, Sectors A, B, C, Page 4 of 11. There are 4 others that would work, too.
5 A SOP-7 -8 , Attachment C, Sectors A, B, C, Page --
6 Q Page 4 of 117 7 A -- Page 4 of 11.
8 Q It's a take shelter recommendation --
9 A Yes.
10 0 -- correct?
11 A Yes.
l~ 12 O Okay. The last pa ragr aph --
13 A Yes.
14 Q --
states, "Do not, I repe at, do not evacuate at this 15 time. You may unnecessarily subj ect yourself to 16 radiation by evacuating now. If you are not inside at 17 this time, immediately proceed to your home, your place 18 of work or to the home or business of a f riend or l
19 rel ativ e. "
20 Is that correct?
21 A That's what I read, yes.
22 Q There is no general instruction to -- as to what to do 23 if you are in the -- you know, someplace that is not 24 near one of these places, is there?
25 A If you were r emotely located, that's cor rect.
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'l Q If you read that, you would think that you should go to 2 your home or your place of work, whichever the closest 3 place is; correct?
T4 A~ If that was read over the BB S, and I heard that, that 5 would be my first action.
6 Q But if you were not f rom the Emergency Planning Zone, 7 and you were traveling through it, this message read L 8 over the radio does not tell you what you should do, 9 does it?
10 A W ell, it goes on to say, "Once inside, stay there unless i
11 you receive instructions to do otherwise. "
<- 12 Q Well, it says, "Once you are inside," assuming you mean
^'
13 your home, your place of work or so f orth, it does not 14 have a general catch all for if you are in a vehicle or 15 in --
16 JUDG E G ROSSMAN : Ms. Rorem, I think we are at 17- the point of being argumentative here.
18 I think we all understand what it says and does not l
19 say by now.
L 20 MS. ROREM: Okay. Thank you.
21 BY MS. ROREM:
22 Q You said earlier that if a person was within a rec area 23 and did not hear the voice-activated sirens, that there 24 would be some staf f person or of ficial who would notify 25 them about what they should do; is that correct?
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1 A Yes.
2 0 And did you assume that these staf f people or 3 recr eational enployees would have pagers?
4 A W ell, I think " assumption" may not be an appropriate 5 word here, because contained in the SOP is a listing of 6 vehicles and radio devices and people that carry them, 7 and ancillary type items f or communication and 8 conducting thei r day-to-day business and emergency 9 busi nes s.
10 Q But you are not saying that every recreational - person 11 who works in a recreational place within the EPZ has a 12 pager?
13 A I have no verification of that.
14 HS. ROREM: That's all, Mr. Wenger.
15 Thank you very much.
16 JUDG E G ROSSMAN : Mr. Edgar?
17 MR. EDG AR : I have no questions.
18 JUDG E GROSSMAN : Mr. Fly nn?
19 MR. FLYNN : I have a f ew questions on 20 redi r ect.
21 I think we can probably tinish by noon.
22 JUDG E GROSSMAN : Pardon?
23 MR. FL YNN : I think we can probably finish by 24 noon.
25 JUDG E GROSSMAN : Yes, fine. I would like to.
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1 REDIR ECT EXAMIN ATION 2 BY MR. FLYNN :
3 Q Mr. Wenger, when you were asked the last series of 4 questions abouc transients, you started to make some 5 distinction among transients in dif f erent situations.
6 Can you elaborate a little bit?
7 Can you tell us what the dif f erent situations might 8 be that transients would find themselves in?
9 For exmmple, one of them that you mentioned was 10 someone driving through the EPZ.
11 What are the others?
, ; 12 A W ell, there would be people traversing the area.
13 There is I-55. Interstate 55 is a maj or artery.
14 There would be people traversing that, and there 15 are other maj or roads in the vicinity of the station.
16 The -- I hav e a l it tl e pr obl em. You talk about 17 recreational areas.
18 I guess I have to think a lot and diff erentiate.
19 In my part of the country it is a little bit 20 different.
21 But recreational areas involve hunting, camping.
22 Transients, that would be people that may live 23 within the EPZ and maybe people that live in the State l
24 of Illinois, it may be people traversing the area 25 stopping of f there f or the night, lodging; business Sonntaq R epo r ti ng_S er v_ipe , Ltd.
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.i 1 people coming into the community, for many, many 2 pur poses, teachers, or whatever the case may be.
3 There could be a lot of transient people.
4 Q So, then, these tranients might already be inside a 5 building when the sirens sound; is that right?
6 A I would j udge the largest percentage would be in that 7 case.
8 0 Let's look at some of the other categories separately.
9 Let's start with the transients who might be in a 10 car at the time the siren sounds.
11 Now, you mentioned Route 55.
)
J 12 If someone were in a car on Route 55 at the time 13 the siren sounds and didn' t hear it our didn' t get in on 14 the EB S message, how long would you estimate that the 15 person would be inside the EPZ?
16 How long would it take to get through it?
17 A W ell, on Interstate 55, I guess at the legal speed 18 limit, of about 40 minutes, that would be -- I guess 50 19 miles per hour,10 miles,10 miles, 20 miles, goes right 20 by the station; so maybe 40 minutes' time, if they were 21 just driving straight on through.
22 0 Would that person encounter any roadblocks in that 23 period of time?
l 24 A W ell, if the si rens j ust had sounded, and he had heard i 25 th em , he could; but my judgment would be, traveling at i
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1 that speed, that distance, he would be halfway through 2 the EPZ. He had been headed out anyway, and continue.
3 If he didn' t hear it, the sounding of the sirens 4 and the 03 S messages are not simultaneous, but very 5 close to it; so as the siren goes off, the EB S messages 6 are given shortly af ter; so as people tune to that Das
- 7. -- designated DB S station, they begin to hear the 8- announcements.
9 The secondary stations or other stations are 10 monitoring, and they would pick up on it immediately; so 11 I would think a time period of, f rom the sirens until c3 12 maybe that secondary message,10 minutes maybe, because
~
13 I am thinking of the concept that, people traveling 14 through the area are people living in the area.
15 If you took a survey or sample, they are not all 16 going to be tuned to an EB S station, they are going to 17 be on other stations. It will have to work its way 18 through the system and hear it on the station they are 19 on if they don' t hear the siren.
20 0 Let's consider the situation where someone is in a car, 21 a transient, and his designation is not someplace in 22 EPZ, but he hears the message that he ought to take 23 s helter.
! 24 I take it this is similar to, say, a si ren sounding n
s_) 25 for a tornado, f or example; is that right?
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1 A Yes.
2 0 What would you expect that person to do once he receives 3 that message?
4 A Once he hears the siren?
5 Q No, once he hears the message that he should take 6 s hel ter .
7 A I would think a person would have to act upon their good 8 J udgment.
9 If they were like the f ellow on Interstate 55, and 10 he's headed south, he might be halfway through. Ile will 11 be better off to keep going.
12 If he was entering into the area, he might want to 13 be more attentive to the matter, as to not to drive into 14 it.
15 Pulling off at an exit and asking inf ormation, or 16 diverting his route of traf fic shortly af ter the sirens 17 are sounded, the roadblocks would be put up, so he is 18 going to, by some manner, run into thoce, but maybe not 19 by radio channels, but at some point he would run into 20 those.
21 Q If the transient pulls of f at an exit and goes to, say, 22 a f ast-f ood restaurant, would that be adequate shelter?
23 A G ener ally, I would roy it could be, yes.
24 Q If he were to go to the lobby of a hotel or a motel, 25 would that be adequate shelter?
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J l A It can be made adequate, yes.
2 0 What has to be done to make that be adequate shelter?
3 A Closing windows, ai r transf er systems, buttoning up; 4 basically, in other words, becoming in an envelope of 5 contained air.
6 Q Is the inf ormation that you j ust gave me contained in 7 the EB S messages --
8 A Yes.
9 Q -- let's talk about a dif f erent group of transients now.
10 Let's talk about the ones who are in recreational areas.
11 Let's talk in particular about people who may not
^ 12 have transportation.
x 13 Now, the first thing I want to ask you ist i
14 In your j udgment, what is the likelihood that the
(
15 message to take shelter will reach people in the 16 recreational areas?
17 A The voice siren announcement.
18 Q Excuse me. Let me explain the question.
19 We have already established, through Ms. Ror em's 20 cross examination, that there is a possibility that some 21 people may not reach the message, and we went on at 22 great length about how attempts are made to communicate 23 that message.
24 What I am asking you to assess now is a probability 25 or a likelihood thac someone will be missed by all of Son nt a g R epo Lt_i ng_Sgryv_ic e ,_.htA Genev a, Illinois 60134 (312) 232-0262
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2 A Relatively small, very minute.
3 Q Now, the next question is:
4 Once the message is communicated, how will that 5 person get to shelter it he has no car or motorcycle or 6 some transportation?
7 A The supervisory people, the people in charge at that 8 location, will be aware that there are people without 9 tr anspor tation.
10 He then is to contact the municipal or county 11 emergency operations center and give this inf ormation
'S 12 and request assistance which, at that time the county or J
13 municipal coordinator will coordinate with officials and 14 they will make buses available to pick up these people 15 at designated locations.
16 Q So what you are saying, in effect, is that the 17 recreational areas would essentially be evacuated even 18 though the general recommendation is f or shelter?
19 A Yes, that's the plan.
20 Q You were asked a question in Ms. Ror em's cross 21 examination about whether the Nuclear Regulatory l 22 Commission had made a survey of enployers.
l 23 Does the Nuclear Regulatory Commission have any i
i 24 responsibility for of f site activities?
l p._/ 25 MS. ROREM: Excuse me.
l l
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976 1 I didn' t ask whether the NRC had --
2 JUDG E GROSSMAN : Excuse me.
3 If . you have an obj ection, say it.
4 MS. ROREM: I obj ect.
5 JUDGE GROSSMAN : Yes.
6 On what grounds?
7 MS. ROREM: That I didn' t ask if the NRC had.
8 made a survey of employers.
9 JUDG E G ROSSMAN : What did' you ask?
10 MS. ROREM: I asked if the State or 11 Commor1 wealth Edison had made a survey of suployers.
12 JUDGE GROSSMAN : Do you recall, Mr. Flynn, 13 what you asked him?
14 MR. FLYNN: I will rephrase the question.
15 JUDG E G ROSSMAN : Pardon?
16 MR. FLYNN: I will rephrase the question.
17 JUDG E G ROSSMAN : Fine.
18 BY MR. FLYNN:
19 Q You were asked, I believe, if the State or the Applicant 1
20 had made a survey; and in your answer you made reference 21 to the Nuclear Regulatory Commission.
'22 Do you renember that?
23 A Yes, I do.
24- Q Okay. My question is:
'25 Does the NRC have any of fsite responsibilities?
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1 A The NRC does have of f site responsibilities, yes.
2 0 In what respect?
3 A It's that threading of the network, onsite to offsite, 4 to local of ficials, of communication and coordination; 5 giving the message classifications, the plant status, 6 over to the State and local governmental j urisdictions.
7 Q But would it be the role of the NRC to make such a 8 surv ey ?
9 A To the best of my knowledge, I believe it is; because 10 when the NRC goes on inspections, pa rt of thei r 11 responsibility is to check with -- my experience has 12 been -- with the Sherif f, to see the point established 13 of communication f rom the technical support center, but 14 that would be the limit of it.
15 0 Would the NRC have any role or any responsibility to 16 survey structures or houses to determine their 17 suitability for sheltering?
18 A I guess I am not certain. I am relating back to 19 testimony at Byron, and the NRC expert witness there --
20 who I served j ointly on a panel with -- and we got into 21 some cf the same inf ormation; and I was thinking that he 22 had ref erenced that they had studied that, studies had 23 been done, maybe not specific to Byron, but maybe 24 specific to structures.
25 It isn' t clear in my mind to give you a definite R onntag_R epo r_ti ng _S ervice , _ Ltd-Geneva, Illinois 60134 (312) 232-0262
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2 Q Okay. Or. the subj ect of sheltering --
3 MR. FLYNN : Excuse me. I will withdraw that.
4 I ma thinking to Miss Fairow's testimony rather 5 than yours, so it's not proper r edirect examina tion.
6 I have no other questions.
7 JUDG E GROSSMAN : Yes, Ms. Ror em.
8 RECROSS EXAMINATION 9 BY MS. ROREM:
10 Q Mr. Flynn asked you, Mr. Wenger, about -- no, no, excuse 11 me.
12 In response to a question asked by Mr. Flynn, you 13 responded that recreational area personnel, the managers 14 or whatever, will be aware that there are those without 15 transportation in their areas or on their -- in their 16 f acilities.
17 Can you tell me how they will be aware that there 18 are people without transportation?
19 A I think there probably are two -- two examples.
20 One would be the State park that you and I had 21 discussed pr eviously, and the other would be, I believe, 22 like a privately owned club, recr eational club.
23 When the inf ormation is made available to these 24 pe opl e, then their responsibilities in State parks, N
25 Federal parks and such, the responsibility is the S on nt a g_kepo r_ti n g _Re r vic e ,_L t d ,
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3 Now, on a private club I think this gets a little 4 bit different, because you can make the inf ormation 5 known to the person who owns or who is in charge. It is 6 unto them to notify those people that are customers; and 7 by announcing and saying there is a problem at the 8 pl ant, the recommendation is that you evacuate this 9 loca tion, it would appear as though you will have people 10 that say, "I can' t. I don' t have anything. I was 11 dropped of f her e. "
12 I guess that's how you would begin to make a 13 determination. "I have so many people here that don' t 14 have transportation. "
15 Q Doesn' t that assume that there will be people right 16 there -- at some of these large recreation areas, 17 privately owned, do the managers of those f acilities 18 know how many people come in and leave?
19 A Oh, I would think they have --
20 0 Do they keep track of all of them all the time?
21 A I would think they had r ecords.
22 It's a business, prof it-making business.
23 Q So they are --
24 A Projections.
25 0 So there are people who come in every -- all the time?
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980 1 A I presume they charge, and that's a sort of a record 2' keeping.
f 3 Q Are you saying that all of these recreational clubs, 4 which are large recreational areas, in the EPZ, charge 5 admission so that they are aware of how many people have 6- come in?
7- A They do not charge admission, so they are aware of how 8 many people come in. I believe there is a membership.
9 0 But isn' t the membership that might be present at the
-10 recreational club variable; in other words, on one day, 11 20 people might be there; on another day,' 600 people es 12 maybe there; is this true?
d Yes, that's possible; but --
13 A 14 Q So that the manager --
15 JUDGE GROSSMAN: Ms. Ror em, we are getting 16 close to interrupting the witness; so let him finish his 17 answ er s.
18 MS. ROREM: I' m sor ry. Excuse me.
19 A (Continuing. ) You have capacities.
20 It seems reasonable and logical that they would 21 keep track of how many enter so they don' t exceed the 22 capacity, which would be a violation of a regulation,
! 23 saf ety-wise.
24 BY MS. ROREM:
l~). 25 But is it reasonable to expect that a club owner will h_/ Q l
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1 know exactly how many people are in his park on any 2 given day?
3 A thybe not exactly, but within some numerical value.
4 Q Is it reasonable to expect that the club owner will keep 5 track of where all of these people are at any given time 6 on any given day?
7 A If they are at his business, his location, he ' s 8 accountable and r esponsible f or those people, 9 liabl e-wise.
10 He doesn' t know where each individual is, but he 11 knows of people that are there, as to an approximate 12 number.
)
13 0 But he has no control over their behavior, does he, as 14 individuals ?
15 A W ell, I think the civil disobedience shows us that.
16 I think he does.
17 You are speaking of a membership. I think that 18 there would be rules of an organization or club.
19 If there are rules, you are to abide by those; if 20 not, you are subj ect to r emoval, I would j udge, or some 21 corrective action or indication to you.
22 Q But is it incumbent upon a person who is in a 23 recreational club to let the manager of such a club know 24 where he is at all times?
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t 1 and acres and acres large.
2 A When you enter onto those pr emises, and those grounds 3 are made available to you, no, I don' t think he's 4 responsible to know where each individual is going; but 5 there are areas to -- to travel into, to recreate, 6 whatever you are going to do; but he has a 7 responsibility for those people on that ground, liabl e 8 for their health and saf ety.
9 otherwise, it would be -- what's the term I am 10 thinking of ?
11 Q But if they leave temporarily and then come back, he may 12 not be aware of this; is this correct?
13 A If they leave his premises and then return?
14 0 Yes.
15 A Possibly not.
16 Q Do you have any idea of or are you considering that 17 there are a number of enpl oy er s -- enployees of such a 18 recr eational facility or are you depending upon one 19 person to have knowledge of how many people have come 20 and gone?
21 A I think it amounts to designated or responsible 22 enploy ees.
23 If someone is a gate person or admission collector 24 on --
25 Q Do all of these recr eational facilities have gate Sonntas_Repor_ ting _Remice,_Ltd.
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2 A That I do not know.
3 Q Do any of them use -- have a key system?
4 A Like a plastic card you put in?
5 (Indica ting. )
6 Q No. I mean like a key for a padlock.
7 A I don' t know that f or a f act.
8 I have to, within reason, judge that there is some 9 way to enter, because if it's a men.bership, it's 10 controlled.
11 0 Then, if the membership enters by means of keys, it may 12 be the case that there is no one who knows -- that knows 13 that members are with -- on the grounds of a 14 recreational facility; is this true?
15 A That's possible.
16 But you -- you have to be aware of your property 17 and your liability.
18 You have got to be accountable for people using 19 your f acility.
20 0 Mr. Wenger, are you f amiliar with any of the 21 recreational f aciliti es, private recreational 22 f acilities, within the EPZ of Braidwood?
23 A To some degree, yes.
24 0 Which ones; with which ones are you f amiliar?
25 A You will have to help me. You are from the area.
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1 From the Village of Braidwood, as you exit to the 2 south, you cross railroad tracks. I believe there is a 3 stop sign or traf fic signal.
4 You turn lef t, and there is a party store on the 5 corner, and right next to it ther e is a club.
6 Now, when I visited this area, they were closed, 7 but I asked questions about that, I looked around as I 8 could, and there are i ron gates there, that's true, but 9 there is also a booth f or people to drive by.
10 Q Did you see that -- that this was the only method of 11 entry into this f acility?
12 A I do not know that f or a f act.
13 But if you will permit me, the reason, because it's 14 co ntr olled, either by key or lock, it j ust isn' t 15 authoriz ed ingress and egress, it's a controlled 16 situa tion.
17 0 But do -- all right.
18 Might it be the case that all members are given 19 keys with which they may enter?
20 A Yes.
21 Q And would they necessarily be going by someone who was a 22 gate keeper?
23 A I don' t know that f or sur e.
24 Q Mr. Wenger, are you at all f amiliar with the South 25 Wilmington Spor tman's Club?
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1 A No.
2 Q Are you f amiliar with any of the clubs whose primary 3 purpose is hunting?
4 A No.
5 I might have to correct myself.
6 There is a DesPlaines prairie in the 10 mile EPZ of 7 B raidwood.
8 Q That' s --
9 A If it is, yes, I am f amiliar with it, because of Dresden 10 and the --
11 0 That's not a privately-owned club.
12 A -- waterf owl ref use.
13 Yes, I have studied that very closely.
14 0 Okay. I am sor ry. I was ref erring to the 15 privately-owned r ecr eational clubs, so that --
16 A I am not that f amiliar with them in that way, no.
17 Q If someone is within the f acility, one of these places, 18 and there is no one around, no one who is in charge, and 19 they hear, through the si ren, voice-activated sirens or 20 the EB S messages, there is nothing in either of those 21 which would instruct this person to -- as to make a 22 phone call to someone or to get -- what -- to w hom --
23 from whom they should obtain assistance, is there?
24 A I can' t -- I can' t testify to that.
25 Once again, because when you are a member of an Ron ne a g _ Reporting _Servlce,_Ltd.
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h 1 organiz ation, there are rules and regulations, and if 2 you have a key and you can enter on .the premises any 3 time you wish, there are certcin things you have to 4 assume a responsibility for _ yourself, and there are bulk 5 distributions of brochures made available, and I would 6 think, o eing a member, you certainly should be made as
7 aware of this as you would f or tornados or other 8 distructive ef fects of nature.
9 'Q But 'there is nothing in the EB S message which tells 10 someone what to do, is there?
11 A That's an ambiguous question.
-(
- )
12 If it's shelter, it does tell them to take shelter.
13 MR. FLYNN : Your Honor, I think we are 14 getting a little f ar afield here.
15 We are no longer talking about transients, we are 16 talking about people who are members of private clubs.
17 The residents of the EPZ already have the 18 brochures.
19 MS. ROREM: Excuse me.
20 Many, many, many of the members of these clubs are 21 transients in that they live in Chicago or they live in 22 the suburbs of Chicago, and they are members of a club 23 which they go to on -- on -- at some other time.
24 They don' t live within the EPZ necessarily.
O ss) 25 JUDG E G ROSSMAN : Okay. That appears to be Sonntaa Repc r ting Serv ice, _ _ LA_d.
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1 true, Ms. Ror em.
2 It also appears that we are going over ground that 3 you have already covered.
4 THE WITNESS: This sounds a little bit 5 f amiliar with testimony that was given on the 29th of 6 October, about the brochures, availability , to people 7 such as yourself.
8 JUDGE GROSSMAN : Pl ease , let's not volunteer 9 too much now.
10 (Laughter.)
11 JUDG E GROSSMAN : Just respond to the 12 questions and we will have a much more focused hearing.
13 MS. ROREM: Mr. Wenger, I have no f urther 14 questions.
15 Thank you.
16 JUDG E G ROSSMAN : Mr. Edgar?
17 MR. EDG AR : I have no questions.
18 MR. FLYNN : I have nothing f urther.
'19 JUDG E GROSSMAN : Judge Cole has one or two 20 questions.
21 J UDG E OOL E: Just a couple of questions, Mr.
22 Wenger.
23 On Page 5 of your testimony, Question 8, in the 24 last paragraph on Page 5, the second sentence of that 25 paragraph, it states, "Upon the decision by county e
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1 officials to activate the Prompt Alert and Notification 2 Sy st em, the coordinators will notify the County 3 Sheriff's dispatchers to activate the system. "
4 Do you see that, sir?
5 THE WITNESS: Yes, si r.
6 JUDG E COL E: N ow , on Page 8, in response to 7 Question 13, that second sentence of the answer of 13 on 8 Page 8, it states that the State official then evaluate 9 the inf ormation provided by the utij ity and make a 10 decision on activating the Prompt Alert Notification 11 Sy st em , and that seems to me to contradict what it 12 states on Page 5.
13 Who makes the decision to activate the Prompt Alert 14 and Notification System, the county or the State, or 15 what is wrong with the way it's stated on Page 5 and on 16 Page 8?
17 THE WITNESS: It does need clarification.
18 The Governor is the person with ultimate 19 responsibility for ordering the activation of the 20 sy st em , at the guidance provided him by the ESDA and the 21 IDNS.
22 The actual pushing of the button to activate the 23 system is done by a designated person at the county, 24 usually in the County Sheriff's of fice.
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1 want to order the county, they are self-governing to a 2 large degree; so the Governor -- it's in the form of a 3 recommenda tion, but a very strong recommendation, that 4 sirens be sounded and the county of ficials go along with 5 that. They have the order to do it and the wisdom and 6 guidance they are given f rom the syst em.
7 JUDG E COL E: Could the county activate the 8 sy st em on thei r ow n, upon their own decision?
9 THE WITNESS: They could, 10 JUDG E COL E: All right, si r. Thank you.
11 You were asked some -- I want to change subj ects 12 now.
13 You were asked some questions about evacuations at 14 schools; and the specific question you were asked: there 15 have been no complete school evacuations in the drills.
16 Do you know why that has not been done, si r?
17 THE WITNESS: Yes.
18 It's been indicated to me by the State. I think it 19 has sound r easoning; and that is, you are speaking of 20 large numbers of school children; and when you involve 21 the application of something like this, the liability 22 Just mounts tr emendously. There is a responsibility, 23 liability .
24 The State of Illinois has conducted limited 25 demonstrations. They go through parental consent.
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1 Children -- I speak of children in the broad sense, 2 of upper elementary through high school, at various 3 times, that are selected. They have been bused out of 4 the area to another school, a designated school, to test 5 the system on a limited basis; but as to the complete 6 evacuation of the school, it is a horrendous 7 responsibility.
8 JUDG E COL E: Do you think a test of the 9 complete evacuation of a school would be necessary in 10 order to demonstrate the capability to do so?
11 THE WITNESS: That's a real tough question to
, 12 answ er.
r 13 You might prove one thing, but involve yourselt 14 with something outside of this whole consept of planning 15 for a nuclear power plant.
16 I don' t know, to balance it out, how much or what 17 could be gained by a total demonstration. I am not 18 certain, though.
19 Total inv olv em ent, certainly it gets more people 20 inv olved, entire staf f, a lot of mobilization of 21 resources; but there is reasonable assurance at this 22 point that should they follow their plans as they are 23 designed, that it should work quite well.
24 JUDG E COLE: Are there any particular skills 25 ne cessa ry , in the evacuation of the school, that would
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1 not be demonstrated otherwise, without the drill?
2 THE WITNESS: Immediat ely, I can' t think of 3 any; because they go through drills f or tornados, so you 4 are getting the staf f involved, and you do need skills 5 regardless of what the group of people you have got to 6 keep calmness about them; and when school is over at the 7 end of the day, you have the implementation of busing, 8 and kids are very eager to leave, so it's along the same 9 line, but not with the same intensity.
10 JUDG E COL E: All right, si r.
11 Thank you.
12 You were asked some questions about criticisms of 13 the inf ormation dissemination system.
14 Do you r ecall that, sir?
15 THE WITNESS: Yes.
16 JUDG E COL E: With respect to criticisms of the 17 inf ormation dissemination system, what parties, persons 18 or groups would criticize the inf ormation dissemination 19 sy stem?
20 For example, your agency, FEMA, the Residents 21 Advisory Committee, NRC, what groups would legitimately 22 c riticiz e, would be in the position to legitimately 23 criticiz e -- just criti ciz e, legitimate or otherwise --
24 criticize inf ormation dissemination during a drill?
25 THE WITNESS: During an exercise?
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1 JUDG E COL E: Or in the plan.
2 THE WITNESS: In the review of the plan?
3 JUDG E COL E: Or based upon a review of the 4 pl an.
5 THE WITNESS: It would be the agencies which 6 serve as members to the Regional Assistance Committee.
7 There are eight of them.
8 JUDG E COL E: All right.
9 Now, I guess I used that acronym wrong. I said 10 Residents Advisory Committee.
11 What does RAC mean?
12 THE WITNESS: Regional Assistance Committee.
13 JUDG E COLE: Committee, Regional Assistance 14 Committee. Okay.
15 Can you tell me very quickly about the Regional 16 Assistance Committee?
17 THE WITNESS: It's comprised of principal 18 agencies that have responsibility in an emergency 19 situation; and in the plan overview or the evaluation, 20 when we are at certain levels of exercises, there are 21 tw o l ev el s, one is a partial participation, which is a 22 scaled-down investigation; the other would be a full 23 participation, which is everything, or ga niz atio nal-wise, 24 coming to bear.
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1 are very much involved in making assessments and 2 evaluation f or the FEMA, who is the evaluating body 3 offsite.
4 When we meet in our RAC meetings, everyone has a 5 say-so, and we get a consensus on position of the RAC as 6 a body as to the plans; so there are -- I could name 7 those agencies f or you, but they are principal agencies 8 within the Federal government that oversee this, and the 9 Chairman -- the chair position is held by FEMA f or 10 of f site planning.
11 JUDG E COLE: All right, sir. Thank you.
12 What other groups or agencies would be in a 13 position to comment on the -- comment or criticize -- on 14 the inf ormation dissemination plan or exercise?
15 THE WITNESS: Federal Department of Int erior ,
16 U. S. Department of Interior; the Nuclear Regulatory 17 Commission; FEMA; Department of Energy, to name a f ew of 18 th em. There are others that I can think about.
19 JUDG E COLE: Are you provided with their 20 critici sms?
21 THE WITNESS: In the case of the power plant 22 for the State of Illinois, yes, I personally am provided 23 with those.
24 JUDG E COL E: All right, sir.
25 Could it be said that if there were maj or Rnn nt-ng Reporting _SeEVICQ,_Ltd.
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1 criticisms of the inf ormation dissemination, either 2 actually as contained in the written plan or as 3 perf ormed in the exercise, you would have that 4 inf ormation?
5 THE WITNESS: Yes, si r, I would say.
6 JUDG E COL E: So that when you make a statement 7 that there were no maj or criticisms as f ar as you know, 8 you say that with some reasonable degree of confidence?
9 THE WITNESS: Yes, si r. Yes, sir.
10 JUDG E COLE: Thank you.
11 Just another question, sir.
12 On Page 21, Question 39, the first sentence in 13 Answer 39, "The notification of employers is carried out 14 by local of f ici als. "
15 What do you mean by " local" there?
16 THE WITNESS: Local of ficials in the 17 governmental bodies, the county or municipal of ficials.
18 JUDG E COLE: Is the responsibility spelled out 19 in the plan as to what of ficials have responsibility 20 over what areas?
21 THE WITNESS: The SOP specify these people by 22 ti tl e.
23 J UDG E COL E: All right, sir.
24 Thank you.
25 JUDG E G ROSSMAN : Mr. Fly nn, re- r edi r ect ?
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1 MR. FLYNN : I have nothing f urther.
2 JUDG E GROSSMAN : Ms. Ror em, any ?
3 JUDG E CALLIH AN : I have some.
4 JUDGE GROSSMAN : Oh, I' m sor ry.
5 JUDG E CALLIH AN : Mr. Wenger, on the matter of 6 transients, would you consider an automobile with its 7 windows closed and outside air supply closed, adequate 8 for sheltering?
9 THE WITNESS: I rent a lot of vehicles, and 10 no, I wouldn' t, because some air systems apparently 11 remain open all the time anyway.
12 You yos can' t close them of f.
13 JCOG E CALLIH AN : An entirely unr elated 14 question.
15 There was, in our knowledge, the first week of 16 Nov embe r , 19 85, an exercise.
17 Han there been yet issued by your agency a final 18 report on that exercise?
19 THE WITNESS: At the time of my departur e f rom 20 my of fice on Monday, no, sir.
21 JUDG E COL E: Is there or do you have a 22 schedule f or it?
23 THE WITNESS: Ye s , si r.
24 JUDG E COLE: When do you expect it to be 25 issued?
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1 THE WITNESS: I would anticipate it -- the
)
f 2 procedure is that, coming here on Tuesday, I was handed
}
3 a letter of the State's response.
4 I must evaluate that and make recommendations.
5 The procedure then is a letter prepared to my 6 headquarters in Washington.
7 They then will work with that position paper and 8 cover memo and send it to NRC. Then this becomes final.
9 I would j udge two weeks.
10 JUDG E CALLIH AN : That's like the first of 11 April?
12 THE WITNESS: Yes, si r.
13 JUDG E CALLIH AN : Thank you very much.
14 That's all I have.
15 JUDG E GROSSHAN: Now, Mr. Fly nn, any 16 re- redi rect ?
17 MR. FLYNN : No, si r, your Honor.
18 JUDG E GROSSMAN : Ms. Rorem, any recross on 19 the basis of the Board questions?
20 MS. ROREM: Yes, one, one area.
21 RECROSS EXAMINATION 22 BY MS. ROREM:
23 0 Mr. Wenger, you were asked by Judge Cole whether there 24 were any particular skills in the evacuation of a school 25 that would not be demonstrated in an exercise, you S onnt a g_R epo r.ti ng_S e rLi c e , _L t d . _ _ _
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W' 997 y f 1 indicated that you couldn' t recall any; is that correct?
2 A I understand this question to be Were there any skills 3 that might be brought to bear in an evacuation that 4 wouldn' t be covered in the normal day activity or the 5 normal routine, anything diff erent? And I believe my 6 comment was no. I gave examples of what takes place.
7 0 okay. Taking your understanding of that question, then, 8 in the normal routine, is it -- would the -- would the 9 school, through calling up bus drivers and school staf f 10 and getting them to assemble the children --
11 A Yes.
N 12 0 -- and getting them to assemble at the school site on
~)
13 short notice --
14 A Yes.
15 0 -- in what situation would that be the case?
16 A You have severe snow storms in the area. There is the 17 -- in the morning, there is responsibility to bring in 18 substitute teacheru. That's done on short notice in 19 many cases.
20 I have talked with Mr. Scott Flynn, Superintendent 21 in Wilmington, and we have discussed the same thing as 22 an issue that I wanted him to addresa to me.
23 0 Are there any other emetgency situations which would 24 require the total mobilization of the schools' 25 resourses, like a nuclear accident?
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1 A Tornado requires total school inv olvement. You are not 2 going to evacuate. That's touch-and-go on evacuation; 3 but you are calling upon teachers to maintain control 4 and get students to locations f or sheltering, or if 5 there is time, on buses.
6 0 But you don' t have a particular need f or, for instance, 7 bus drivers, in a tornado?
8 A No; but in a snowstorm you do, and you may have to call 9 th em.
10 My experience has been, in reserching this, that 11 bus drivers are not f ull-time bus drivers, they work 12 elsewhere; or it may be on a contract basis; so that bus 13 drivers know that, when they take the j ob, that they can 14 be called at most any time.
15 If a snowstorn comes on at 11:00 o' clock, they are 16 notified, come and get the kids then. Those people may 17 have to leave work to come and get the kids to become 18 enployed as a bus driver, to ca r ry out the 19 res po nsibil ity .
20 So that's the short term mobilization of bus 21 drivers.
22 0 Are there any other emergencies which would require the 23 issuing of dosimeters?
24 A I am at a loss f or a response, because you wouldn' t 25 issue dosimeters to schoolchildren or teachers in the S o n nt a g_H epo r.t i ng _ S e rri c e ,_L t d .
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1 school.
2 O To school of ficials?
3 A To school of ficials?
4 0 To school of ricials or school staf f.
5 THE WITNESS: Could you ask your question 6 again?
7 JUDG E GROSSMAN : Do I understand what you are 8 say ing, Mr. Wenger, is even in a nuclear emergency, you 9 would not issue those to school of ficials?
10 THE WITNESS: I don' t think that quantity 11 exi st s, or that's not in planning.
12 It's f or people who will be bound in the EPZ, in 13 the plume or wocking as an emergency worker.
14 The idea is f or other people to get them out.
15 BY MS. RORD4:
16 0 Are you saying that dosimeters will not be issued to bus 17 drivers?
18 A I did not say that.
19 There is a possibility for that, because of bus 20 drivers, by chance, having to leave the area and return 21 to the area, round trip, to continually move people out.
22 There may be a decision at some point to issue 23 dosimeters.
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24 0 Don' t they , in f act, or aren' t they of f ered a course by 25 the State which teaches them how to une dosimeters?
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1 A Yes.
2 0 Isn' t that f or the purpose of planning f or a nuclear 3 emergency ?
4 A Yes; becuase that's all those instruments will measure.
5 0 Are there any other school emergencies which would 6 require that school bus drivers are -- become f amiliar 7 with assigned routes to congregate-care centers?
8 A Are there any other emergencies that they would 9 experience that would assign them to evacuation routes 10 for nuclear energencies?
11 Q No.
12 Okay.
13 A I' m sor ry if I misunderstood you.
14 I understood you to say that that couldn' t be 15 correct.
16 Q Are there any other school emergencies which would 17 require that school bus drivers become f amiliar with 18 assigned routes to congregate-care centers?
19 A If you willl permit me, I know that when bus dribers 20 start the school, they usually run them over these 21 routes to give them f amiliarity; but there isn' t another 22 enregency that would involve them of driving that route.
23 0 llow do you know that they run these bus drivers over the 24 routes so that they can become f amiliar with then?
o s 25 A W ell, I understand this is a procedure that school Son nt ag_I$ cpor ti nL S erV ice, _L td. _ _
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1 l 1 districts have pr etty will adopted.
2 Q Which school districts? To which do you ref er? i 3 A The point, I have not addressed that in Braidwood; but 4 in the other stations this has come up, specif ically 5 Byron.
6 Q Okay. We are speaking specifically to Braidwood.
l 7 Can you say that the bus drivers are taken over the 8 routes at the beginning of the year in order to assume 9 f amiliarity with them?
l 10 A Memory doesn' t serve me.
11 I can' t answer that question.
12 Q Okay.
13 A I apologize. I conf used with with another location.
l 14 MS. ROREM: Thank you very much.
15 JUDG E G ROSSMAN : Mr. Edgar?
! 16 MR. EDG AR: May I have a moment to conf er?
17 JUDG E GROSSMAN : Cer tainly .
t 18 (There followed a discussion 19 outside the record.)
20 MR. EDG AR : We have no questions.
21 JUDG E G ROSSMAN : Mr. Fly nn, on the area 22 covered by Ms. Ror em?
(
i 23 MR. FLYNN : I have no questions.
l 24 JUDG E GROSSMAN : Fine.
25 The witness is then excused.
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1 J UDG E G ROSSMAN : Thank you very much f or 2 testifying f or us again.
3 THE WITNESS: Thank you f or bearing with me.
4 (Witness excused.)
5 JUDG E GROSSMAN : We will return at a quarter 6 to 2:00, 7 We are in recess.
8 (Whereupon the hearing was continued 9 to the hour of 1: 45 o' clock P.M.)
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 ------------------x 5 In the Matter of: :
- Docket No. 50-456 OL 6 COMMONWEALTH EDISON COMPANY : 50-457 OL 7 (Braidwood Station, Units 1 and 2) :
8 ------------------x 9 Will County Court House Courtroom #405 10 14 West Jefferson Street Joliet, Illinois 60431 11 Wednesday, March 12, 1986
- )
13 The hearing in the above-encitled matter reconvened 14 at 1:45 p.m.
15 PRESENT:
i 16 As before.
17 18 JUDGE GROSSMAN: We are back in session.
19 Miss Fairow and Mr. Butterfield have resumed the 20 stand, and Miss Rorem is going to continue with her 21 cross examination.
22 JANA S. FAIROW 23 LAWRENCE D. BUTTERFIELD, JR.
24 recalled as witnesses by counsel for the Applicant, having
) 25 been previously duly sworn by the Chairman, were examined and Sonntaa Reportino Service, Ltd.
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1 testified further as follows:
2 CROSS EXAMINATION 3 (Continued) 4 BY MS. ROREM:
5 0 Miss Fairow, in your prefiled testimony, on Page 14, 6 Quection and Answer 19, you state that, " Inclusion of 7 nonessential information in the messages which does not 8 appreciably assist the public in taking prompt and 9 appropriate protective action would hamper the overall 10 effectiveness of the emergency response."
11 Is that correct?
s 12 A (WITNESS PAIROW) Yes.
13 0 By this do you mean instructions such as respiratory 14 protection?
15 A (WITNESS FAIROW) That could be included in something 16 nonessential for all particular situations.
17 0 Is there information which might be necessary to help 18 protect the public f rom radiological contamination 19 during an evacuation which would be added to the 20 pre-scripted messages?
21 A (WITNESS PAIROW) If the determination is made by the 22 Department of Nucler.r Safety that information such as 23 that needs to go out to the public, that could be added 24 -- it would be added to the message.
25 0 And how long might that information be in the Sonntaq Reporting Service, Ltd.
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1- pre-scripted messages?
2 There is sometimes a line or two left.
3 Is that intended to indicate the length of a 4 response -- or I mean, the length of an addition to the 5 message? ;
6 A (WITNESS FAIROW) I'm not sure what 'line or two" 7 you're speaking of.
8 0 Okay. At the end of some of the -- I will have to find 9 one -- pre-scripted messages, there is a typewritten 10 line which says, you know, that information may be 11 included here specific to the instance or whatever that m 12 is.
)
13 Does that in any way indicate the length of the 14 material which might be added to the message?
15 A (WITNESS FAIROW) No, that's no indication of -- that 16 the message length -- the additional message length is 17 limited in any way.
18 0 Okay. So the message length would be whatever it needed 19 to be to give the information to the public so as to i 20 enable evacuation; is this correct?
l 21 A (WITNESS FAIROW) The information would be complete l
22 enough to give the public the instructions but concise 23 as to not get into -- to make it too lengthy.
l 24 Q So it would be -- are you saying that it would be D
n_) 25 information only; that is, instructions only?
l l
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1 A (WITNESS FAIROW) As opposed to what?
2 Q As opposed to educational information on the nature of a 3 radiological problem.
4 A (WITNESS FAIROW) DNS would make the determination on 5 what the public would need to know to carry out specific 6 instructions.
7 Q And do you think that -- all right. I'm -- in your 8 answer, where you say, " Inclusion of nonessential 9 information in the messages which does not appreciably 10 assist the public," what do you mean by that?
- 11 Maybe I can get it that way.
>g 12 What do you mean? What would be " nonessential
'^~
13 information"?
14 A (WITNESS FAIROW) It could be a variety of things that '
15 might only take place in certain situations.
16 In those situations the information could be added, 17 such as specific instructions for the put.ic regarding '
l 18 respiratory protection or specifics on sheltering 19 techniques that aren't always necessary. ;
- 20 0 Okay. You mean these are -- these are nonessential in 21 some cases, but they are essential in others?
1
! 22 A (WITNESS FAIROW) That's true.
I 23 If they're not essential in all -- in all ;
24 situations, it wouldn't be added in the -- the specifics
/
3 25 would be added as necessary. j Sonntag Reporting Service,_Ltd. ,
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e 1007 1 0 Okay. What would these specifics consist of?
2 This is what I want to know.
3 Would they consist -- yes, what would these 4 specifica consist of?
5 A (WITNESS FAIROW) That's hard to say. It would depend 6 on the situation.
7 Q Could they include educational information about the 8 radiological hazard as well as instructive information?
9 A (WITNESS FAIROW) That's possible, and that is a i 10 determination that DNS would make at the time.
11 0 What do you know about this determination?
' 12 A (WITNESS FAIROW) I know it's DNS' responsibility to 13 analyze radiological consequences, and they have 14 procedures to do that.
15 I cannot speak for DNS as far as what their 1 16 procedures say or make any judgments on their expertise.
I 17 MS. ROREM: Mr. Grossman, we seem to have the i 18 same problem which we had yesterday, where I believe 19 that my of f er of proof material facts contained
- 20 information which was specific in terms of its -- the 21 desire to elicit certain information, and the Applicant 22 has put on witnesses -- a witness; Mr. Butterfield has 23 remained silent -- who is begging off the question and 24 saying that that's -- this information is the 25 responsibility of DNS.
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1008 1 MR. EDGAR: Your Honor, that's --
2 JUDGE GROSSMAN: What in particular in your 3 material facts are you asking about which you cannot 4 elicit an answer?
5 MS. ROREM: To an extent, in the material 6 facts listed in Offer of Proof Issue 2, No. 1 and No. 3.
7 In discussing the EBS messages and what would be 8 contained in them, which is instruction as to actions to 9 take and so forth, it may become important in a 10 radiological emergency to give instructions concerning 11 radiological protection to people who are in 3 12 recreational areas or people who are in situations where
~) 13 they are going to have to be outside.
14 I feel that it's proper that I am able to discover 15 what additional information might be provided in the 16 EBSs -- EBS messages.
17 JUDGE GROSSMAN: If you ask about a specific 18 situation, you may well get a responsive answer; but 19 you're asking general questions about what won't be 20 contained in a message.
21 Well, you know, there's a world of information 22 outside, and I'm not sure that your question is limited 23 enough in order to get any kind of response.
! 24 But if you have a particular in mind that relates q
,m) 25 to your statement of material facts, I think you ought l
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1 to ask those -- that specific question.
2 MS. ROREM: Okay.
3 BY MS. ROREM:
4 0 Will there be information included in the EBS messages 5 regarding radiolejical -- regarding respiratory 6 protection if such respiratory protection may be 7 necescary?
8 A (WITNESS FAIROW) If DNS feels that respiratory 9 protection is necese,ry, they will add it to the EBS 10 messages and inform the public.
11 0 And what would that message be -- consist of?
3 12 A (WITNESS FAIROW) Again, I don't know the specific
') 13 language that DNS would use.
14 0 Then how do you know that they will include such 15 messages?
16 A (WITNESS PAIROW) If the public needs to know, they 17 will use the EDS system and go through their county 18 representative in the county EOC to add that to the 19 county EDS message.
20 0 Is -- but you don't know that DNS will definitely 21 recommend any particular course of action with regard to 22 information about respiratory protection, do you?
l 23 MR. EDGAR: Your lionor, I object to this.
I 24 This is rehashing old ground.
v my 25 JUDGE GROSSMAN: Okay.
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0 1 It appears as though you've gotten a responsive 2 answer that that group has a responsibility for 3 determining whether additional information should be 4 supplied in that message and will make that 5 determination on a situation-specific basis.
6 Now, what further information you want is very hard 7 to understand from the questions that you've raised.
8 BY MS. ROREM:
9 0 Is it correct that sheltering or evacuation messages may 10 contain additional information about respiratory 11 protection?
12 A (WITNESS FAIROW) It is possible if it's needed.
13 0 And at this point you have no idea what information IDNS 14 might issue as regards respiratory protection?
15 MR. EDGAR: Objection; asked and answered.
16 BY MS. ROREM:
17 0 In general, would the material which would be included 18 in the EBS messages be designed to instruct individuals 19 or would there be explanatory material?
20 A (WITNESS FAIROW) It depends again on the determination 21 made by DNS.
22 If they feel that an explanation is required, they 23 will add it.
24 0 Okay. Not with regard to radiation materials, would 25 information about sheltering or evacuation -- if an Sonntaq Reporting Service r Ltd.
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1 individual found himself in a situation which was not 2 outlined by the EBS nessage, would there be more 3 information forthcoming to him that would be more 4 specific and explain instead of instruct?
5 A (WITNESS FAIROW) Additional EBS messages would be --
6 would be sent out following the initial one with an 7 update of information or -- or a repeat of the same 8 information if there has been no change.
9 Again, we cannot know what every individual is 10 doing out there and provide information on what each 11 particular individual should do.
12 They -- people have to use a little common sense in 13 emergency situations.
14 0 And on what is that common sense based?
15 JUDGE GROSSMAN: I don't think that that 16 question can be responded to.
17 MS. ROREM: Okay. Excuse me, excuse me.
18 DY MS. EOREM:
19 0 would it possibly help people to respond to an emergency 20 more responsibly if they were provided with explanatory 21 materials or a little more background information on the 22 nature of the radiological hazard?
23 A (WITNESS FAIROW) The EDS messages are designed to give 24 basic emergency information to instruct individuals and 25 groups on what to do because of a particular emergency.
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1 Beyond that, if we were aware of a certain group or 2 of people that were in a particular area, we could 3 provide additional instructions for them.
4 As far as providing informational material, as 5 opposed to instructional, I -- I don't think it would 6 app 'ciably help getting the public out of an affected 7 area.
8 0 Why not?
9 JUDGE GROSSMAN : Well, the question has been 10 answered in the prefiled testimony that you just 11 referred to, and I don't think that yeu can get anything
-s 12 that's more responsive.
13 I think we're wasting time on this area.
14 BY MS. ROREM:
15 0 In your response to Question 19 on Page 14, you say that 16 this inf ormation "would hamper the overall ef f ectiveness 17 of the emergency response."
16 How would it hamper the overall effectiveness of 19 the emergency response?
20 A (WITNESS FAIROW) Giving unnecessary information would 21 delay the reaction time to the essential emergency 22 information that we're providing.
23 0 Is it possible there are people who would use that 24 information to react more quickly?
25 A (WITNESS FAIROW) I don't know that.
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1 0 Let's go to a specific situation and suppose that a 2 parent has a child at a campground within the EPZ and, 3 just to not complicate things, let's make the parent 4 within the EPZ also.
5 What would the parent do, given the EDS message, if 6 evacuation were required?
7 A (WITNESS FAIROW) Do you mean that both the child and 8 the parent are within the aff ected area of the EPZ?
9 0 Yes, I do.
10 A (WITNESS FAIROW) The parent could go to the 11 recreational area and pick up the child.
12 If that's not the case, the child will be taken 13 care of, because as part of the plan, the recreational 14 areas are covered by sirens both electronic and -- or 15 both the tone alert and the PA capability on the sirens, 16 and they are provided for also in being notified by 17 county -- county or municipal officials by telephone of 18 a problem or of the protective action.
19 If they need assistance in evacuating, they will 20 make this request to the county or the municipal EOC, l
21 and then they will be provided with transportation 22 assistance from the recreational area.
23 0 When you say that a parent could go to the recreational l 24 area to pick up his child, do you mean that he would be 25 allowed to go or that he would be likely to go?
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1 A (WITNESS FAIROW) I suppose both: He would be allowed, 2 in that he is already within the affected area so be 3 would not run into traffic and access control posts; and 4 he would be likely to.
5 0 Would this be contradictory to what the EDS message 6 which he receives has told him to do?
7 A (WITNESS FAIROW) The EDS messages say, "Do not enter 8 an affected area," and they say, "Do not go to schools 9 or nursing homes."
10 0 They don't cover this situation; correct?
11 A (WITNESS FAIFOW) I would have to look at an EBS L 12 message again to make sure, but I believe that's 13 correct.
14 MR. EDGAR: Can we have the plan?
15 (Indicating.)
16 A (WITNESS FAIROW) (Continuing.) As I said, the schools 17 and nursing homes are covered and it tells people not to 18 enter, so this situation is not covered by the 19 evacuation message.
20 BY MS. ROREM:
21 0 So from what you are saying, is it true that a parent in 22 this situation would either choose to go and pick up his 23 child or choose to let the rec area evacuate his child?
24 JUDGE GROSSMAN: Miss Rorem, we've had an 25 answer to that. I don't think that we're getting l
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J 1 anything profitable out of this.
2 The message speaks for'itself. The witness has a 3 number of times indicated also what the message says and 4 has indicated to what situations the message applies.
5 I don't see that we're doing anything. We're not 6 supposed to be writing a brief now on the implications 7 of what the witness has said.
8 What she has said I think is perfectly clear.
9 Everybody understands what's covered and what's said, 10 and so there's nothing further that you can ask about 11 that would help us.
es 12 BY MS. ROREM:
)
13 Q On Page 22 of your prefiled testimony, on Answer 32, you 14 state that -- well, the question is whether the 15 pre-scripted take-shelter and evacuation messages 16 provide sufficient information to deter individuals from 17 going to or calling schools and nursing homes.
18 You answered, "Yes. The messages state that school 19 children and nursing home residents are being well 20 attended to by trained personnel, that there is no need 21 to go to such locations, and clearly warn against entry 22 into the affected area."
23 Is that correct?
24 A (WITNESS FAIROW) Yes.
q x_) 25 0 In what way do they cover those persons who are already Sonntaa Reportina Service, Ltd.
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1 within the affected area?
2 A (WITNESS FAIROW) If they are inside or outside of the 3 affected area, it states that they should not go to 4 schools or nursing homes.
5 It doesn't distinguish there, but neither person 6 should go to the schools or nursing homes.
7 0 Okay. I'm trying to recall exactly the place in which I 8 was this morning when we switched from Mr. Wenger.
9 If a parent has a child in school and he is within 10 the affected zone, if the child is in school and the bus 11 is not at school, is it reasonable to expect that if an lx 12 evacuation action is recommended, that the parent will 13 go to school to pick the child up rather than having him 14 wait for the bus?
15 A (WITNESS FAIROW) It may be expected that a parent 16 would go, but they are instructed not to.
17 The schools have specific instructions for caring 18 for those children, including mobilizing the buses to 19 get them there.
20 So it is advised -- the parents are advised not to 21 go there.
22 0 So what do you think will happen if the buses are eight 23 miles away and the parents is two blocks away?
24 MR. EDGAR: Objection; asked and answered.
m
_j 25 JUDGE GROSSMAN: Sustained.
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1 MS. ROREM: I have no further questions of 2 this witness.
3 JUDGE GROSSMAN : Mr. Flynn?
4 MR. FLYNN: Thank you.
5 CROSS EXAMINATION 6 BY MR. FLYNN :
7 Q Miss Fairow, I'd like to ask you some questions on the 8 subject of sheltering and the adequacy of structures for 9 sheltering.
10 This morning you were asked a series of questions 11 about whether certain structures were more suited for l- 12 sheltering than other structures, and you indicated that 13 that might very well be the case.
14 Now, my question concerns special facilities; 15 schools and nursing homes in particolar.
16 Are those buildings themselves adequate for 17 sheltering-in-place in the situations where 18 sheltering-in-place is the recommended protective l 19 action?
20 A (WITNESS FAIROW) For our purposes, which is to keep 21 airborne contamination from getting inside special 22 facilities to the residents or the school children 23 there, we have gone to schools and the nursing homes and 24 developed specific ventilation checklists for those
_J 25 facilities to follow in the event of a take-shelter Sonntag Reportino Service, Ltd.
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O 1 recommendation.
2 So we're talking about two things as far as our 3 purposes that -- the adequacy of a building for our 4 purposes and the structural adequacy of the building.
5 JUDGE GROSSMAN: I don't think you completed 6 the answer. The question asks whether they would be 7 adequate, then.
8 A (WITNESS FAIROW) (Continuing.) They are adequate.
9 We've gone through to make sure we can shut off systems 10 bringing outside air into the buildings.
11 BY MR. FLYNN:
L 12 O Are the operators of those f acilities, the schools and 13 the nursing homes, made aware of what it is they need to 14 do to shut out the radioactivity?
15 A (WITNESS FAIROW) We have actually gone and talked to 16 the school people to get their specific instructions for 17 this.
18 In many cases they specify rooms to go to to shut 19 off fans and switch boxes to go to to shut off systems.
20 0 So I take it from all of that that even though there 21 might be a more ideal structure to shelter the school 22 children and the nursing home residents, still it really 23 isn't necessary to go to that extent?
24 A (WITNESS FAIROW) No.
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1 moving the people out of that building, we might as well 2 completely evacuate them f rom the area completely.
3 0 Is the capacity of buildings such as schools and nursing 4 homes to shelter people taken into account when the 5 decision is made whether to shelter or evacuate?
6 A (WITNESS FAIROW) Structurally the adequacy or the 7 ventilation adequacy?
8 0 The ventilation adequacy.
9 A (WITNESS FAIROW) Since we have gone through and gotten 10 all of the instructions for this, we know that they all 11 have the ventilation adequacy; so it -- it isn't a p~ 12 concern.
13 0 I'd like to turn to a different subject now, and that is 14 something that was brought up in yesterday's 15 examination. The subject is the arrangements the towns 16 have made for backup people when the primary people are 17 not available to take telephone calls.
18 To summarize what I remember of your testimony, we 19 were talking about the mayors of towns, we were talking 20 about the chief elected officials in counties, and we 21 were also talking about fire chiefs and sheriffs.
22 But I think the concern was primarily with the 23 smaller towns.
24 Your testimony related that these people are x,f 25 generally available either by telephone or through Sonntaa Reportina Service, Ltd.
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1 pagers or, if they're not, that they have alternates who 2 are available.
3 Does this system serve a purpose other than 4 preparedness f or a radiologica1 ' emergency?
5 A (WITNESS FAIROW) The people that respond to a 6 radiological emergency are generally the people who 7 would respond to any type of emergency.
8 0 can you give us some examples of what those emergencies 9 might be?
10 A (WITNESS E AIROW) Fires, tornadoes, floods, chemical 11 incidents.
!, 12 0 Of the ones that you' ve mentioned, my own guess would be 13 that fires would probably be the most common, 11 Would that be your judgment?
J5 A (WITNESS FAIROW) Yes, I would expect so.
16 0 In your experience, do these towns ever allow themselves 17 not to have anyone available to respond to fires?
18 A (WITNESS FAIROW) No.
19 In one way or another, they cover their area, 20 whether it be by their own personnel or with mutual-aid 21 agreements with other areas or other surrounding 22 communities.
23 0 And do those arrangements also serve to see that someone 24 is available in the event of a radiological emergency?
25 A (WITNESS FAIROW) Yes.
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1 MR. FLYNN: Thank you. I have no other 2 questions.
3 JUDGE GROSSMAN: Redirect?
4 HR. EDGAR: Yes.
5 REDIRECT EXAMINATION 6 BY MR. EDGAR:
7 Q Miss Fairow, yesterday you were asked questions about 8 the radio capabilities for the buses in the EPZ, and you 9 indicated that you were not certain if all had radios.
10 Have you obtained any additional information in 11 that area?
L- 12 A (WITNESS FAIROW) Yes.
13 Buses for the most part do have radios; and in 14 addition, it is common practice -- but also something 15 that would be decided at the time if there was a need --
16 to escort these buses out of the EPZ.
17 That escort would be provided generally by law 18 enforcement personnel.
19 0 You were asked questions about the phone capability at 20 the Essex Elementary School.
21 If indeed the phones at the Essex Elementary School 22 were inoperable, how could the school officials there 23 gain access to the municipal EOC?
24 A (WITNESS FAIROW) The municipal EOC is within
_J 25 approximately three blocks of the school, so that it Sonntag Reportino Service, Ltd.
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1 would be easy to send someone there on foot.
2 0 Earlier yesterday you were asked questions about 3 officials designated under IPRA who might have dual 4 roles within IPRA.
5 How many of these people would occupy dual rolen?
6 A (WITNESS FAIROW) As far as dual -- the dual roles 7 being a public official and an official at a 8 recreational area, there are three people that have dual 9 roles of that sort.
10 0 And do you have any plans to talk to those people to 11 assure or to confirm their awareness of those roles?
L 12 A (WITNESS FAIROW) We have spoken to them about being
~'
13 public officials and officials -- or contact persons at 14 a recreational facility, and we could easily speak to 15 them again regarding that dual role.
16 0 In terms of backups within EOCs, if there are not enough 17 people to provide the functions within a municipal EOC 18 -- or a county EOC, for that matter -- what do the 19 officials in ci,arge of the EOC do?
20 A (WITNESS FAIROW) If neither the official nor the 21 alternate can be contacted, the officials that are 22 present in the EOC would attempt to cover for the 23 official who isn't available.
24 If they need f urther assi stanc s, they go to the 25 county EOC; and the county will prcvid additional Sonntag Reporting Service, Ltd.
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1 assistance as necessary.
2 If the county, in turn, needs assistance, they go 3 to the State.
4 0 Now, is there any experience with this situation you've 5 described in regard to Braidwood?
6 A (WITNESS FAIROW) Yes.
7 During the Braidwood exercise in November,-the 8 mayor of Essex was not available; and the other 9 officials took over his duties and performed quite 10 adequately.
11 0 Now, similarly, if individuals who are responsible for 12 recreational areas did not have enough people to perform 13 their functions in an emergency, what would they do?
14 A (WITNESS FAIROW) The recreational facilities would 15 contact either the county or municipal ~0Cs and request 16 assistance from there.
17 0 You were asked questions concerning the situation in 18 which a principal of a given school might also be the 19 superintendent for a series of schools and might be 20 off-site at the time of an emergency.
21 What provisions are made under IPRA for that 22 circumstance?
23 A (WITNESS FAIROW) Whether at the school or at a 24 different location, that principal is responsible for 25 performing the protective action at that school.
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1 He has instructions as part of the IPRA SOPS; and 2 he could -- would ensure that those activities in his 3 instructions are performed, whether he would go actually 4 to the school or call the school.
5 0 All right. Earlier today you were asked about 6 discussions or studies that you have done in regard to 7 sheltering capabil. sy for schools and nursing homes.
8 Have you done any surveys of sheltering capability 9 at schools and nursing homes?
10 A (WITNESS PAIROW) We have talked to the schools and 11 nursing homes and prepared ventilation checklists to 12 ensure that they can shut down the systems that bring in 13 air from the outside.
14 0 And where are these ventilation checklists to be found?
15 A (WITNESS FAIROW) They are part of each school's 16 instructions contained in SOP-9.
17 0 You were asked questions -- I believe Mr. Butterfield 18 was asked questions about brochure distribution in 19 regard to recreational areas and other special 20 facilities.
21 When you've distributed or made bulk distribution 22 of a brochure to these areas, what instructions, if any, 23 have you given tne recipients of the brochure?
24 A (WITNESS BUTTERFIELD) We developed a procedure for the 25 use by the people who delivered these bulk distributions Sonntag Reporting Service, Ltd.
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1 -- or made the bulk distributions.
2 They were instructed to make the distribution to 3 someone of responsibility at each location; to be 4 familiar with this brochure and then discuss the 5 brochure with the responsible individual; encourage 6 them, if they were an employer, to have it available or 7 give it to their employees; understand what it was 8 about.
9 If it was a motel, we asked that they put them in 10 the motel rooms.
11 If it was another type of facility, we would ark 12 them to provide it -- or if it was a recreational area 13 -- provide it in a conspicuous place for people coming 14 in.
15 Q Now, how were the display locations at particular 16 facilities determined?
17 A (WITNESS BUTTERFIELD) They were determined by the 18 individual operators of these facilities.
19 We encouraged them to put them in a conspicuous 20 location.
21 Q And how would the operators know where to put things?
22 A (WITNESS BUTTERFIELD) Well, in our discussion of the 23 usefulness of these brochures, it became -- we tried to 24 impress on them the importance that they be available
) 25 and, therefore, they should be put where people can --
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1 can pick them up, the visitors or the transients.
2 0 Do you believe that the operator of the facility is in 3 the best position to know what the best location is?
4 A (WITNESS BUTTERFIELD) Yes.
5 0 All right. You were asked questions about airborne 6 radi oa ctivity . Judge Callihan asked some later in the 7 day. There were questions about airborne radioactivity 8 and educational information in EBS messages.
9 Have you considered whether additional information 10 concerning airborne radiation might -- of an educational 11 nature might be included in the brochure?
12 A (WITNESS BUTTERFIELD) Yes, I have.
13 Q And what are the results of that consideration?
14 A (WITNESS BUTTERFIELD) I have developed reveral 15 sentences which could be put into the public brochure of 16 an educational nature.
17 0 And what are those sentences?
18 A (WITNESS BUTTERFIELD) I'm reading from Section 8 of 19 the Braidwood Emergency Information Public Information 20 Brochure.
21 At the end of the last paragraph on that page, I 22 was considering the addition of the following two 23 sentences.
24 Let me start by saying this paragraph discusses if
) 25 a plant accident were to occur, there would be people Sonntag Reporting Service, Ltd.
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1 that would be getting detailed readings; that if it were 2 expected that it would expose people to more than 1,000 3 millirems off-site, the State would call for protection 4 of the public.
5 I would propose to add the following two sentences:
6 "The most probable form of radiation which would be 7 found beyond the plant boundaries would be contained in 8 a cloud or plume.
9 "This cloud would move in the prevailing wind 10 direction and would dictate the areas for potential 11 shelter or evacLation recommendations."
f 12 O Now, are you authorized to commit Commonwealth Edison to '
13 include that in the next scheduled issuance of the 14 brochure?
15 A (WITNESS BUTTERFIELD) Yes.
16 0 And will you commit Commonwealth to do that?
17 A (WITNESS BUTTERFIELD) Yes.
18 MR. EDGAR: We have no further questions, 19 your Honor, at this time.
20 JUDGE GROSSMAN : Miss Fai row, would there ever 21 be a recommendation for sheltering in the event that 22 there was no radiological release?
23 WITNESS FAIROW: That is possible.
24 JUDGE COLE: Yesterday Miss Rorem asked you
_j 25 several questions about recreation areas, and on the Sonntaa Reportina Service, Ltd.
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1 transcript, at Page 739 and 740 -- I'll just read the 2 question on 739 that Mrs. Rorem asked you: "Could you 3 tell me specifically which recreation areas have sirens 4 which are equipped with this capability?"
5 To that you responded: "It would be easier to tell 6 you the ones that do not." Then you listed three that 7 did not have the public address capability.
8 Now, when you responded with respect to recreation 9 areas, what did you mean by " recreation areas"; all 10 recreation areas or just those operated by local or 11 State or federal governments or what?
12 What did you mean when you answered the question?
13 WITNESS FAIROW: What do we mean in general 14 by " recreational areas"?
15 JUDGE COLE: Yes.
16 WITNESS FAIROW: We covered areas that are 17 used for camping or daytime use. There are State parks 18 identified in the plan. There are city parks with 19 playground-type equipment.
20 It covers a wide variety of recreational-type 21 facilities.
22 JUDGE COLE: For example, one facility that 23 was mentioned once or twice today was the Wilmington 24 Sportsmen's Club.
25 Is that considered a recreation area?
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1029 1 WITNESS FAIROW: Yes.
2 JUDGE COLE: So that is equipped with sirens 3 with the PA capability?
4 WITNESS FAIROW: Yes.
5 JUDGE COLE: Okay. The three that you 6 mentioned -- I'll read them off: Forsythe Woods, Godley 7 Park District and the Island Park District in 8 Wilmington.
9 Is that correct?
10 WITNESS PAIROW: Those are the three.
11 JUDGE COLE: Are you familiar with those h 12 three recreation areas?
L 13 WITNESS FAIROW: I have been to two of the 14 three.
15 JUDGE COLE: Could you tell me something 16 about them as to their size and location relative to the 17 nuclear plant at Braidwood?
18 WITNESS FAIROW: Forsythe Woods is about 19 seven miles from the station. It is, I think, mostly 20 picnicking-type activities. It is part of the Will 21 County Forest Preserve system, so the Forest Preserve 22 system has procedures for sending out their Forest 23 Preserve police to provide notification within that 24 area.
/
I 25 The Wilmington Island Park District is in downtown Sonntaa Reportino Service, Ltd.
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l 1030 1 Wilmington. It is a playground type with a baseball 2 diamond 'and swings and playground-type equipment. It is 3 covered by the sirens, the tone -- alert tone sirens 4 that cover the City of Wilmington.
5 JUDGE COLE: How large is the Wilmington 6 Island Park; three baseball fields equivalent in size?
7 WITNESS FAIROW: Total size, I would say 8 probably that.
9 JUDGE COLE: Okay.
10 WITNESS FAIROW: The Godley Park District is 11 very small at present. They have a few pieces of 12 playground equipment and a pavilion. It is within two 13 miles of the station.
14 The Wilmington Island District -- Park District is 15 approximately five to six miles from the station.
16 JUDGE COLE: How large is the Godley Park 17 District facility; about a baseball field size?
18 WITNESS FAIROW: One baseball field.
19 JUDGE COLE: Do each of these facilities have 20 anybody stationed there during the daytime hours?
21 WITNESS FAIROW: The Godley Park District and 22 Wilmington Park District do not, and I don't really know 23 for sure about Forsythe Woods.
24 JUDGE COLE: Okay. Thank you.
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1 capability, how does one utilize the public address 2 capability of these sirens at the recreational areas?
3 WITNESS FAIROW: Usually the panel for 4 activating the sirens are in a sheriff's dispatch area, 5 and they have the instruments there to activate both 6 types of sirens.
7 For the public address sirens, they dial in a 8 certain dial code that activates a particular siren.
9 They can activate the PA capability individually or as a 10 group.
11 JUDGE COLE: So at the location where they
(- 12 activate the warning siren, they could -- they do have
~
13 the capability to hook in the public address system?
14 WITNESS FAIROW: That's correct if it is an 15 electronic siren. The electronic sirens have the voice 16 capability and the tone capability.
17 JUDGE COLE: Could they then book in the 18 Emergency Broadcasting System or how would they put a l
19 voice across?
20 How is that hooked in?
21 WITNESS FAIROW: There is a microphone there 22 in the sheriff'c dispatch center where they would read 23 the pre-scripted message for the PA capability on the 24 sirens.
f 25 JUDGE COLE: Is that the case with all of Sonntaa Reportina Service, Ltd.
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1 those recreation facilities with the p'ablic address 2 capability?
3 WITNESS FAIROW: If they are individually 4 activated from that? Is that --
5 JUDGE COLE: Yes.
6 WITNESS FAIROW: Yes.
7 JUDGE COLE: Okay. Thank you.
8 WITNESS FAIROW: I should note that the siren 9 system is still under development, but that will be the 10 case when they are all installed and the systems are 11 operable.
12 JUDGE COLE: That's the plan for the method 13 of operation?
14 WITNESS FAIROW: Correct.
15 JUDGE COLE: All right. Thank you.
16 That's all I have. Thank you very much.
17 JUDG E G ROSS MAN : Back to ths question of a 18 recommendation for sheltering when there is no actual 19 release, why -- under what circumstances would such a 20 recommendation be made?
21 WITNESS FAIROW: Can I refer that to you?
22 WITNESS P' TTERFI"LD: Sure.
23 In the generating station's emergency plan, I 24 believe I said yesterday there is that requirement under lh 25 a general emergency condition to shelter zero to two l
1 l
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1 miles, shelter two to five and prepare five to ten.
2 That is the immediate reaction to a general 3 emergency which could occur without an off-site release 4 of radiation.
5 JUDGE GROSSMAN: I see. Is that basically on 6 the expectation that there could be an imminent release?
7 WITNESS BUTTERFIELD: Yes.
8 JUDGE GROSSMAN: Okay.
9 JUDGE CALLIH AN : In your experience in 10 warning systems for emergencies in general --
11 specifically, radiological -- what experience have you 12 encountered?
13 What kind of events have you provisioned for 14 announcement for the need of evacuation or whatnot?
15 Have you had any experience locally, to your 16 knowledge?
17 WITNESS FAIROW: I think usually when a siren 18 system is used other than in this case, it would be for 19 a tornado, which wouldn't require an evacuation.
20 But they could also be used in the case of a 21 chemical incident, where an evacuation could be 22 recommended there.
23 JUDGE CALLIH AN : And where there is such, 24 whether it's weather or chemical or transportation or Ih 25 whatnot, in what detail are the characteristics of the Sonntaa Reparting Service, Ltd.
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1034 1 event -- postulated event given over the public address 2 system or over the radio system?
3 WITNESS FAIROW: In the event of a tornado, 4 the radio station would be broadcasting a tornado watch 5 or warning, whatever the case would be.
6 Also, if it was some type of chemical incident, 7 information would be provided on the radio, also.
8 JUDGE CALLIHAN: To take the latter for a 9 moment, would, for example, the complete name of the 10 chemical be given in your emergency words?
11 WITNESS FAIROW: I don't think it would need 12 to be. In most cases, it probably wouldn' t mean 13 anything to the public.
14 JUDGC CALLIH AN : Can you carry that over to a 15 radiological event and would you consider at all 16 describing in detail, as Mr. Butterfield did for me 17 yesterday, the type of radiation and the radionuclides 18 which might be in the plume?
19 WITNESS FAIROW: For the same reasons, the 20 need for that inf ormation isn't really there for the 21 public.
22 They don't understand it, and it would probably 23 serve to confuse and frighten them so much that they 24 wouldn't be able to carry out the directions given by h 25 the message. l l
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l 1035 1 JUDGE CALLIH AN : Are you a proponent, 2 therefore, of some concise statement that there may be 3 or there is a potential hazard and one should evacuate 4 or shelter or whatever with some expedition and let it 5 go at that?
6 WITNESS FAIROW: I think that is what we've 7 strived for, and I think that the general public 8 believes enough in their governmental officials that 9 they will take them at their word that, "If there is an 10 emergency, we should do something about it."
11 JUDGE CALLIHAN: And to go to the extreme, 12 then, you don't recormend including a junior course in 13 health physics in your emergency announcement?
14 WITNESS FAIROW: I don't believe it's 15 necessary.
16 JUDGE CALLIH AN : Coming now to special 17 facilities -- schools and so forth -- are parents or 18 responsible people, people responsible for the 19 well-being of progeny -- are they physically and/or 20 legally barred from going to the location of their 21 children?
22 WITNESS FAIROW: I think it would depend 23 where the children are. I think maybe -- and it also 24 depends on the authorities there.
h 25 If it, for instance, is a school, the school may Sonntag Reporting Service. Ltd.
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1 have certain policies to discourage, if not forbid, 2 people from picking up their children for, you know, 3 reasons that, for instance, you want to make sure it's a 4 parent that is picking up the child and so forth.
5 JUDGE CALLIHAN: Would some guidance along 6 those lines be included in the radio station 7 announcement?
8 WITNESS FAIROW: There is a statement in the 9 EBS messages that there is no need to go to schools and 10 nursing homes to pick up students because they are being 11 taken care of.
12 JUDGE CALLIH AN : But I thought you said a 13 moment ago that there was a local option as to whether 14 such picking up might be permitted.
15 WITNESS FAIROW: We discourage them, but it is 16 actually the school's decision if a parent does go l l
17 against our advice and go to the school. l 18 JUDGE CALLIH AN: Would your announcement of 19 an impending event -- might your announcement of an 20 impending event direct parents to go to some site if 21 that were the local option?
22 WITNESS FAIROW: Yes. That is -- that could 23 be part of thct situation-specific information that 24 could be added to the message.
lh 25 JUDGE CALLIH AN : Does that override your Sonntaa Reporting Service, Ltd.
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1 recommendation, the State's recommendation, the 2 brochure's recommendation?
3 WITNESS FAIROW: Well, again I think it 4 depends on the situation, and the messages can be 5 altered to -- to meet the situation.
6 JUDGE CALLIH AN: How are the changes, 7 potential changes, in evacuation routes -- due to 8 weather, road conditions and so forth -- made known to 9 the people to be evacuated or the people doing the 10 evacuating?
11 WITNESS FAIROW: We have designated 12 evacuation routes in the EBS messages; but if for some 13 reason those would need to be changed, that information 14 would be provided through the EBS messages.
15 That would be one type of situation-specific 16 inf ormation that might need to be changed.
17 JUDGE CALLIH AN: And is this what -- in my 18 words, at any rate -- might be a supplement to the 19 prescribed statement?
20 WITNESS FAIROW: That's correct. It could be 21 a supplement.
22 WITNESS BUTTERFIELD: Excuse me, Judge.
23 Could I add something to that, please?
24 I looked in the EBS messages here, and I picked one h 25 out of 7-SOP-8; and it's the same, I believe, for all of Sonntag Reporting Service, Ltd.
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1 them.
2 At the end of the message, it tells the people in 3 the message where the schools are being relocated to; so 4 it gives them a place where they are going.
5 JUDGE CALLIH AN : What are some of the 6 characteristics of potential sheltering structures that 7 you explored and evaluated in judging if a structure is 8 suitable for sheltering?
9 WITNESS PAIROW: One thing we looked at was 10 if they actually can shut off outside air to the inside.
11 Part of the instructions is to shut windows and doors.
12 Then they vary in detail, but generally it's to 13 shut off air-conditioning systems and heating systems; 14 shut your windows and doors.
15 JUDGE CALLIH AN : Thank you very much.
16 JUDGE GROSSMAN: Miss Rorem, recross?
17 MS. ROREM: Yes.
18 RECROSS EXAMINATION 19 BY MS. ROREM:
20 Q Miss Fairow, you stated that you wouldn't go to the 21 trouble to move school children in a -- to a building 22 which might be more suitable f or sheltering, and you 23 responded that you may as well go to the trouble to 24 evacuate completely.
k 25 Is that true?
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1 A (WITNESS FAIROW) Yes.
2 O Could you tell me why -- in what way going to the 3 trouble to move children to another building in the same 4 town is as dif ficult as evacuating them completely?
5 A (WITNESS FAIROW) I don't think it's a matter of 6 dif ficul ty .
7 It -- when we shelter-in-place, we shut down 8 systems bringing in outside air so that the airborne 9 contamination doesn't get inside the building.
10 If there is that contamination and there is a need 11 to move them to a different building, then we are 12 exposing them.
13 So they're better off beir.g in a building where all 14 the ventilation systems are shut down than to be moved 15 to another building.
16 0 If a take-shelter action has been set in motion and 17 there is no radiological release and it is a situation 18 -- well, all right -- and there's no radiological 19 release, would you be endangering children if you moved 20 them to another location?
21 A (WITNESS FAIROW) If there is not a releace, no.
22 0 Okay. If there is not a release but there is a 23 take-shelter varning and evacuation is actually not 24 recommended because of the fact that it is a 25 quick-developing radiological situation, would you be Sonntag Reportino Service, Ltd.
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1 putting them to the same trouble if you moved them to 2 another location as if you completely evacuated them?
3 A (WITNESS FAIROW) I'm not sure I understand the 4 question.
5 MS. ROREM: I'm not sure to what extent I can 6 say some of this because it's falling outside the 7 premise of what she said in her cross examination.
8 JUDGE GROSSMAN : Well, no. This was reopened 9 by me and the Board questioning.
10 But it's my understanding, f rom the testimony that 11 we heard, that if there is no actual release, there is 12 the imminence of a release and those are -- that's a 0 13 situation in which sheltering would be recommended in 14 the event there is no release.
15 Apparently the concept is that because of the 16 imminence of a release, there should not be removal to 17 another shelter.
18 Now, if that's incorrect in any way, please let us 19 know right now.
20 Is that a correct understanding of why you would 21 not recommend removal to another shelter when there is a 22 shelterirc recommendation made?
23 WITNESS FAIROW: That's correct. I 24 MS. ROREM: Okay.
h 25 BY MS. ROREM:
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1 Q Does where the location of a f acility which might be a 2 better location for shelter matter?
3 A (WITNESS FAIROW) Not really.
4 0 For example, if it were merely a matter of moving 50 5 children across the street to another location, it would 6 not -- it would not be recommended?
7 A (WITNESS FAIROW) Again, that's a determination that's 8 going to have to be made on a case-by-case basis.
9 It -- there are a lot of factors that would enter 10 in.
11 0 Dut if there was no release and none were expected for 12 some time, would it make a difference?
13 A (WITNESS FAIROW) If none -- if no release was expected 14 for some time, I suppose you could go across the street 15 50 feet.
16 0 And would this be more -- less trouble than evacuating 17 completely?
18 A (WITNESS FAIROW) If there is -- if you know there is a 19 period of time before that release occurs, you'd have 20 time to evacuate.
21 JUDGE GROSSMAN: Miss Rorem, I think you're 22 passing each other in the night here.
23 I think you are assuming that the staff of that 24 f acility would not in any event shelter the students h 25 across the street.
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1 I believe that the witness does not understand that 2 premise; that when there is -- it's my understanding 3 that she's saying when there is a sheltering 4 recommendation, that the staf f of the school might well 5 shelter the children in the facility across the street.
6 Is that a correct understanding?
7 WITNESS FAIROW: They may choose to do that 8 if -- if there is no release occurring.
9 MS. BOREM: Fine. Then she agrees with what 10 I was trying to ask.
11 MR. EDGAR: The record will speak for itself, 12 I think.
13 JUDGE GROSSMAN: Pardon?
14 MR. EDGAR: I think the record will speak for 15 itself.
16 JUDGE GROSSMAN : Yes.
17 Okay. It was my observation that your questions 18 were asked on the assumption that the staff of a school 19 or any other facility could not itself take the 20 residents or the inhabitants of that f acility to 21 anyplace other than that f acility itself.
22 But if I was incorrect, then the record will speak 23 for itself.
24 MS. ROREM: That's fine, then.
) 25 BY MS. ROREM:
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1 Q When you discussed adequately shutting down ventilation 2 systems, does it matter -- does the amount of draf t that 3 can come through windows or ventilation systems make any 4 difference?
5 A (WITNESS FAIROW) Make any difference to what?
6c Q To whether or not a facility can be adequately protected 7 or whether it can adequately shelter people inside.
8 A (WITNESS FAIROW) I suppose if there were cracks in the 9 windows where air could come through, it would be a 10 problem.
11 0 What if there were cracks in the -- I'm not talking 12 about cracks in the glass but drafts around a window 13 area.
14 Then even with the windows shut, radioactive 15 contamination, airborne particulates, could come through 16 the window; correct?
17 A (WITNESS FAIROW) I suppose so.
18 0 And when you did your evaluation of all of the schools 19 in the EPZ and nursing homes, did you look at the -- did 20 you do a site-specific determination of the adequacy of 21 the air ingress for each structure?
22 A (WITNESS FAIROW) For the most part, we talked to the 23 janitorial-type people who are familiar with the furnace 24 and that type of thing and discussed with them, you
) 25 know, what our aim was to make sure they understood why Sonntaa Reportino Service, Ltd.
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1 we were looking for the specific information.
2 0 Did you ask about air drafts around windows?
3 A (WITNESS FAIROW) I don't know that for sure.
4 0 And the shelter capabilities of those structures varied 5 individually; right?
6 WITNESS FAIROW: Could I have that question 7 read back?
8 (The question was thereupon read by the 9 Reporter.)
10 A (WITNESS FAIROW) The sheltering capability, as f ar as 11 structurally, may vary; but that isn't something we were 12 concerned with.
13 We were concerned with ensuring that we wrote down 14 instructions for shutting down furnaces, 15 air-conditioning, windows, that type of thing.
16 MS. ROREM: Okay.
17 BY MS. ROREM:
18 0 You stated that in small communities, it was always the 19 case that someone would respond to fires; is this 20 correct?
21 A (WITNESS FAIROW) I believe I said someone would always 22 respond whether f rom that community or through a 23 mutual-aid agreement.
24 0 But that "someone" is not necessarily one of the people
) 25 who is responsible under IPRA for implementation of Sonntag Reporting Service, Ltd.
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1 duties?
2 .A (WITNESS FAIROW) You're asking me if whoever responds 3 to a fire is -- is responsible in some way under IPRA?
4 0 What I'm saying is that the person who responds is not 5 necessarily someone who is responsible under IPRA.
6 A (WITNESS FAIROW) Not in every case.
7 0 Okay. When speaking of officials who have dual roles, 8 you said -- you identified three.
9 Were those -- was that three in the entire EPZ?
10 A (WITNESS FAIROW) Three in the entire EPZ that have a 11 dual role as a public official and as a contact person 12 for a recreational facility.
13 0 Could you tell me where those three people are located?
14 A (WITNESS FAIROW) One of the persons serves as the fire 15 chief and as ESDA coordinator in Braidwood. He's also 16 our contact person for the Braidwood Recreational Club.
17 The other two are frcm the Village of Essex.
18 One is the mayor of Essex. He also serves as the 19 manager, I believe, of the South Wilmington Sportsmen's 20 Club.
21 The other is the fire chief of Essex, who serves as 22 the maintenance manager at the South Wilmington 23 Sportsmen's Club.
24 0 You were asked about what responsible officials in the 25 recreation areas would do in terms of calling in and so Sonntaa Reporting Service, Ltd.
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1 forth.
2 What about the recreational areas where no one is 3 in charge?
4 A (WITNESS FAIROW) The municipality or the county would 5 send some type of emergency personnel out there to 6 assist those people in the area to ensure that they are 7 being evacuated from tne area.
8 0 Have you identified the areas where there is no one in 9 charge on an everyday basis?
10 A (WITNESS FAIROW) I believe we have.
11 But regardless of our identification, at the time 12 of an incident, that -- each recreational facility will 13 be called by a governmental official.
14 If they cannot reach someone by phone, an emergency 15 response person will be sent to the location.
16 0 Judge Callihan asked you about other events which might 17 require implementation of the EBS system and asked 18 whether educational information would be included on 19 messages in those circumstances.
20 Are any of those circumstances which may occur 21 discussed in any other educational format?
22 A (WITNESS FAIROW) Do you mean such as a brochure?
23 0 Is inf ormation -- is educational information included 24 in, for example, the school system on what happens in a h 25 tornado?
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1 A (WITNESS FAIROW) Just recently -- I believe last week 2 was Tornado Awareness Week, and information was provided 3 to the media so that they could broadcast information.
4 Some schools performed their own tornado drills, 5 and our agency and the ESDA agencies at the county level 6 go out and do programs as requested on tornadoes.
7 0 And information on the nature of an accident was 8 included in this Tornado Awareness Week, was it not?
9 A (WITN ESS FAIROW) Information regarding tornadoes and 10 what to do in the event of tornadoes were in materials 11 that were distributed.
- 12 0 Were children also told what a tornado is and how it 13 acts?
14 A (WITNESS FAIROW) It is possible.
15 0 Is there anything comparable to informing school 16 children about the nature of a radiological accident?
17 MR. EDGAR: Objection. Now we' re getting 18 into a section -- a subject which was not covered in 19 redirect; that is, educational programs in schools 20 concerning Braidwood emergency planning.
21 It's outside the scope of redirect.
22 JUDGE GROSSMAN : Well, it is my recollection 23 that the questions by Judge callihan related to only the 24 EBS messages, but nevertheless I think we can get the 25 final answer here on this area.
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1 Miss Fairow?
2 WITNESS FAIROW: Could I have the question 3 read back, please?
4 (The question was thereupon read by the 5 Reporter.)
6 A (WITNESS FAIROW) There are no programs that we have 7 put on for school children in particular that I am aware 8 of.
9 WITNESS BUTTERFIELD: I would like to add 10 that Commonwealth Edison has a public speaking bureau 11 that goes out and makes -- or has programs available to 12 go to schools, other organizations or whatever and talk 13 about our nuclear power activities.
14 If questions come up concerning accidents, they 15 would probably be answered at that time.
16 Now, this is offered. If anyone takes advantage of 17 it, that's their privilege.
18 MS. ROREM: I have no further questions.
19 Thank you.
20 JUDGE GROSSMAN : Mr. Flynn?
21 MR. FLYNN : I have no further questions.
22 JUDGE GROSSMAN: Mr. Edgar?
23 MR. EDGAR: No further questions, your Honor.
24 JUDGE GROSSMAN : Does that, Mr. Edgar, lh 25 complete you case?
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1 MR. EDGAR: That's correct.
2 JUDGE GROSSMAN: Okay. I believe that you 3 have -- that all of your exhibits have been admitted.
4 MR. EDGAR: Yes, si r .
5 JUDGE GROSSMAN: Fine.
6 Mr. Flynn, I believe you've completed your case, 7 too, with your witnesses; is that correct?
8 MR. FLYNN : That's correct.
9 JUDGE GROSSMAN : Okay.
10 Miss Rorem, then it's your case in chief now -- oh, 11 I'm sorry.
12 (Laughter.)
13 The witnesses are excused. Thank you very much for 14 your testimony.
15 (Witnesses excused.)
16 MS. ROREM: Mr. Grossman, I regret to say 17 that the witness whom I wished to have served with a 18 subpoena has remained out of town and could not be 19 contacted.
20 JUDGE GROSSMAN: I hope not because of the 21 imminence of your service of the subpoena.
22 Nevertheless, I take it, then, you have no further 23 case.
24 MS. ROREM: I have no further case at this h 25 time.
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1 JUDGE GROSSMAN: Fine.
2 Mr. Edgar?
3 MR. EDGAR: I have a few logistics matters 4 that I'd like to bring up if this is the right time.
5 JUDGE GROSSMAN: Yes, certainly.
6 I was only going to say that we would follow the 7 rules as far as briefing goes, unless there's any 8 objection.
9 MR. EDGAR: That was one thing. We don't 10 have any problem with that at all.
11 We are considerir.g filing early, and we wouldn't 12 have a problem with that if we could maintain the 13 intervals constant, you know, between people's filings.
14 We would pay the penalty, but everybody else vould 15 keep their response intervals constant.
16 JUDGE Gh0SSMAN: I forget now what the rules 17 say, and I intended to look at it.
18 But is it based -- are intervenors and staff 19 responses based on service of your initial proposal?
20 MR. EDGAR: I believe so, but let me confirm 21 it. I don't want to -- I have the same problem you do:
22 I haven't looked in a while.
23 The intervals are based on the date of close of the 24 record, to be accurate. Everybody --
lh 25 JUDGE GROSSMAN: Yes, but what I was saying Sonntag Reporting Service, Ltd.
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1051 1 iL: After your response has been filed, do the 2 subsequent -- or your proposed findings, do the 3 subsequent filings depend upon service of yours?
4 MR. EDGAR: I -- I can't say that's true, 5 your Honor.
6 As I -- I'm perhaps reading it literally, but let 7 me -- I just lost it.
8 JUDGE GROSSMAN: Sure.
9 Why don' t we take a --
10 MR. EDGAR: Here it is. The Applicant files 11 30 days after the record is closed. Then the other 12 parties file within 40 days, and the staff files within 13 50 days. Then there's a five-day reply.
14 JUDGE GROSSMAN: So they do not depend on 15 your filing?
16 MR. EDGAR: No, si r, but that's -- you know, 17 they need mine to respond.
18 JUDGE GROSSMAN: Yes, okay.
19 If you want to informally get any commitment, I 20 think you can attempt to; but I'm sure no one -- at 21 least, the next one is not going to come in in any 22 shorter time than the rules provide, so we will follow 23 the rules as far as this goes.
24 MR. EDGAR: Well, the rea r. I'm suggesting
) 25 it -- and I think there is a good reason -- is the Board SQnntag_Reportina Service, Ltd.
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1 has a much larger set of hearings in front of it.
2 We thought if we would be willing to take the 3 burden of filing quickly, that would put the case in a 4 package and give the Board and the parties the freedom 5 to then meet the larger question, and we think it makes 6 sense.
7 I would like to urge the Board to consider that 8 from -- it's gratuitous in a sense, but I think it makes 9 some practical sense in the overall reach of this case.
10 JUDGE GROSSMAN: The Board agrees with that, 11 and we'd like to hear f rom the other parties as to 12 whether they would be amenable to having the time 13 shortened, with the understanding that they would have 14 at least as much time f rom your filing --
15 MR. EDGAR: Right.
16 JUDGE GROSSMAN : -- as they would under the 17 rules.
18 First, Mr. Treby?
19 MR. TREBY: The staff does not concur with 20 that suggestion. The staff is not going to be awaiting 21 the Applicant's proposed findings before it begins its 22 proposed findings.
23 On the other hand, unlike the Applicant, we do not 24 have two separate law firms taking the two separate I 25 portions of this case.
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1 The same people who are working on this matter for 2 the staff are also busily involved in discovery 3 activities and other activities which are going on in 4 the QA area.
5 The staff would like what the regulations require; 6 that is, the 50 days in which to file its proposed 7 findings.
8 MS. ROREM: Could you explain the mechanics 9 of this a little more so I am aware of exactly what is 10 happening?
11 JUDGE GROSSMAN: Oh, okay.
12 Actually, I think it's academic now because I don't 13 think that we're going to change the rules.
14 Under the rules, when the record is closed, 15 Applicant has 40 days to file its --
16 JUDGE COLE: 30.
17 JUDGE GROSSMAN: 30 day s -- I' m sor ry -- to 18 file its proposed findings.
19 You would then have -- you would have 40 days f rom 20 the closing of the record, which means 10 days after 21 Applicant; and staff would have 50 days.
22 The question before us was Mr. Edgar had suggested 23 shortening his time from 30 days to something other than 24 that, and we were inquiring whether then the other
) 25 parties would also agree to shortening their time, with Sonntes_ Reporting Service, Ltd.
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1054 1 the understanding that they would have Mr. Edgar's 2 filing earlier.
3 But the point is staff still wants the 50 days for 4 the good reasons that Mr. Treby has stated, and 5 presumably you would, too. So we're not going to --
6 MS. ROREM: Ohay.
7 JUDGE GROSSMAN : -- arrange for anything 8 else.
9 Now, the only question is when we close the record, 10 and we're definitely going to close it on this issue 11 notwithstanding that we have the Quality Assurance 12 issues before us.
13 I would assume that we would close the record when 14 we expect the transcript to come in if it is mailed out 15 to us or by -- why don't we agree on Monday?
16 Is that agreeable to staff or is there any reason 17 why the record should be closed any sooner or later than 18 that?
19 MR. TREBY: I believe the record can be 20 closed now. We've heard all the witnesses, and I don't 21 see what the need to wait for --
22 MR. EDGAR: We'll accept that.
23 MR. TREBY: -- anything further.
24 I would like to make one other comment, since we I 25 were talking about the proposed findings.
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l 1055 1 Unfortunately, I don't know the name of the case, 2 but I think there has been some case law that failing to 3 file proposed findings carries certain penalties with 4 that.
5 JUDGE GROSSMAN: I didn't hear the last part.
6 I'm sorry.
7 MR. TREBY: Failure to file proposed findings 8 carries certain penalties with it. I would like to 9 indicate that on the record.
10 JUDGE GROSSMAN: Okay, fine.
11 You' re put on notice, Miss Rorem, as to what Mr.
12 Treby has suggested: When it's due, it's due.
13 If that's a paraphrase of Yogi Berra, I don't know.
14 (Laughter.)
15 I see no reason why we shouldn't close the record 16 now, especially since Mr. Edgar, who is up first, is 17 willing to shorten his time.
18 So we'll consider it closed, unless there's any 19 further business with regard to this.
20 MR. EDGAR: I have two items.
I 21 I assume that the record is closed. Also, the 22 parties can file motions to correct the transcript, 23 presumably.
24 JUDGE GROSSMAN : Yes.
k 25 MR. EDGAR: The second thing: I've been Srnntas_ Reporting Service, Ltd.
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1 asked to inquire of the Board whether the Board has any 2 thoughts as to where, in terms of location, the QA 3 hearings will be held.
4 Commonwealth is trying to do some planning. If the 5 Board has any advice in terms of location, it would be 6 greatly appreciated.
7 JUDGE GROSSMAN: We have not yet found a 8 place.
9 We have attempted to, and we've even discussed it 10 this week. We started a few weeks ago.
11 Presumably, the location would be in Joliet, but we 12 just don't know where in Joliet.
13 JUDGE COLE: It might very well be that all 14 the principal parties might be in the Chicago area, so 15 we might not exclude that.
16 JUDGE GROSSMAN: Miss Rorem, do you object to 17 doing it that way?
18 MS. ROREM: Yes, because I'd like an 19 opportunity to discuss it with my attorneys in the 20 matter.
21 JUDGE GROSSMAN : Sure.
22 JUDGE COLE: I was just saying that the 23 lawyers representing the parties would be in the Chicago 24 area, so we certainly wouldn't want to exclude it, h 25 although, all other things being equal, Joliet would be Sonntag Reporting Service, Ltd. - - ~ ~
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1057 1 the place to conduct the hearings because of its 2 proximity to the plant.
3 MR. TREBY: In the search for a location, the 4 staf f would respectf ully request that we have f acilities 5 so that each of the parties have their own separate 6 area.
7 While we don't mind sharing some area with Miss 8 Rorem during this hearing, we expect that there will be 9 a number of other counsel involved in the QA thing.
10 Just the logistics of having the various papers and 11 necessary support staff and attorneys would require that 12 each party have its own counsel table.
13 JUDGE GROSSMAN: We've done the best we can.
14 MR. TREBY: We appreciate that.
15 JUDGE GROSSMAN: There's one other item with 16 regard to this particular hearing.
17 There's one exhibit, Miss Rorem, that you 18 identified but did not .ove into evidence.
19 I believe it's already part of something that is in 20 the record; is that correct?
21 It's the Final Environmental Statement.
22 Do we have that?
23 MR. EDGAR: Your lionor, I don't believe that 24 the Final Environmental Statement is in this record.
k 25 There weren't any environmental contentions, and this SonntA9_Reporti no S e rvica,_Ltd.
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1 was used only for cross examination.
2 JUDGE GROSSMAN: Well, is there any reason why 3 you want this in the record, Miss Rorem?
4 MS. ROREM: I believe that the line of 5 questioning I was attempting to develop had been stepped 6 on --
7 (Laughter.)
8 -- so to speak, and I don't think it's relevant.
9 JUDGE GROSSMAN: That's fine. I just wanted 10 to point it out to you.
11 Okay. That apparently concludes all the business 12 that we have with regard to this hearing.
D 13 The record is then closed, and the next time we see 14 any of the parties will be at the next hearing with 15 Quality Assurance.
16 (Which were all the proceedings had and 17 testimony taken in the above-entitled 18 matter at the time and place aforesaid.)
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NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER I
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: COMMONWEALTH EDISON COMPANY (Braidwood Station, Units 1 and 2)
DCCKET NO.: 50-456 OL; 50-457 OL PLACE: JOLIET, ILLINOIS DATE: tlEDNESDAY, MARdH 12, 1986 were held as herein appears, 'and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commissicn.
(sigt)
(TYPED) 31800 L. S0nnt09 Nancv J. Ho79 Official Reporter Reporter's Affiliation
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