ML20212A728
| ML20212A728 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/25/1986 |
| From: | Cassel D BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES |
| To: | Stello V, Taylor J, Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| CON-#386-129 2.206, NUDOCS 8607290112 | |
| Download: ML20212A728 (28) | |
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Business and Professional People for the Publidistprest Chicago, Illinois 60602 Telephone: (312) 6415570 j
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DOCU' 'I]"'p' BY FEDERAL EXPRESS Mr. James L. Taylor Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 95 23[fh7k!
Mr. Victor Stello t ~
PHOD. L UTIL FAC...s
--.-f Executive Director for Operations U.S. Nuclear Regulatory Commission M.
Ob Washington, D.C.
20555 Re: Emergency petition to prohibit imminent resumption of operations of LaSalle Nuclear Station
Dear Sirs:
Pursuant to 10 CFR 2.206, the Village of Seneca, Illinois, hereby requests that you institute a proceeding under 10 CFR 2.202 to revoke Commonwealth Edison Company's operating license for the LaSalle Nuclear Station, for failure of the licensee to comply with 10 CFR 50.54(q) and (s) and Appendix E thereto, which require the licensee to maintain in effect an emergency plan which provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
In addition,because the LaSalle Station, presently shut down, is expected to resume operations on or about August 1,
- 1986, and because there does not presently exist an offsite emergency plan adequate for notification and evacuation of Seneca's approximately 2,100 citizens in the event of an accident, the Village of Seneca herebyrequests that you direct the licensee not to resume operations at LaSalle unless and until an adequate emergency plan exists.
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Mr. Jcmes L. Taylor Mr. Victor Stello July 25,1986 Page 2 i
The basis for this 2.206 petition is as follows.
The Village of Seneca is located within the Emergency Planning Zone for LaSalle, approximately three miles from the plant.
Until June 17, 1986, the Village was a participant in the plant's offsite emergency plan, formally known as the Illinois Plan for Radiological Accidents -
LaSalle.
Annex 3E of the Plan, setting forth the responsibilities of Seneca Village officials prior to the '7111 age's withdrawal, is attached as Exhibit A hereto.
On June 1, 1986, LaSalle 2 experienced a feedwater transient that resulted in a low reactor water level, and the licensee declared an Alert.
(See NRC IE Information Notice 86-47, June 10, 1986.)
However, Seneca officials were not notified of the Alert until nearly 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after the incident began.
This delay in notification caused the Mayor and Village Commissioners to review the adequacy of the LaSalle emergency plan as it relates to Seneca.
After looking into the matter, the Village concluded that the plan is not workable.
On June 17, 1986, Mayor Anderson wrote a letter (Exhibit B hereto) to NRC
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Regional Administrator Keppler formally withdrawing from the plan and explaining:
The basis of my decision to formally withdraw participation is that I am convinced that the plan is not feasible for our Village and its more than 2,100 1
residents in the event of an emergency.
Nor do I believe the Plan, in view of all its shortcomings and problems, can be made to work for our Village.
Mr. Keppler referred Mr. Anderson's letter to FEMA for review.
During June 17 to July 22, a number of meetings were I
held in which Mayor Anderson explained Seneca's concerns to various representatives of NRC Region III.
On July 21, 1986, FEMA informed NRC Region III that in FEMA's view, Seneca's withdrawal from the olan would have no significant impact on FEMA's approval of the plan, although the plan would have to be amended.
I On July 22, 1986, Mr. Keppler met with Seneca Mayor Anderson and expressed the view that he had no choice but to accept FEMA's position.
At that meeting or sooner, Mayor Anderson delivered a document (Exhibit C hereto) entitled " Issues" summarizing the concerns Mayor Anderson had previously communicated orally to NRC representatives on various occasions.
Mr. James L. Taylor Mr. Victor Stello Page 3 This 2.206 petition should be granted for the following reasons:
- 1. There is good reason to believe that the LaSalle offsite emergency plan will not, in fact, result in timely and effective notification and evacuation of Seneca's 2,100 residents, in the event of a serious accident, whether or not the Village participates in the plan.
These reasons appear mainly in points 5,6,7, and 8 of the " Issues" document.
For example:
. Siren notification will not likely be effective (point 6).
The single two lane road leaving Seneca could not accomodate the necessary traffic in the event of an emergency (point 7E).
The plan relies on the assumption that volunteer personnel would, in fact, go to and stay at their posts regardless of radiation levels and wind directions, rather than take their families away to a safer location (points 7F;.
and 8).
2.
In theory, perhaps state or county governments could replace Seneca Village officials in carrying out emergency notification and evacuation procedures.
However, neither state nor county officials have advised Seneca of any measures actually
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taken to replace Seneca in carrying out the plan.
FEMA's approval, as communicated to NRC Region III on July 21, is based on the legal powers and potential future actions of state and county governments.
It does not even attempt to demonstrate that any measures have, in fact, been taken to ensure timely and effective notification and evacuation of Seneca residents
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in the event a serious accident were to occur in the near future at LaSalle.
3.
The NRC's responsibility, pursuant to applicable statutes, NRC regulations and the Memorandum of Understanding Between NRC and FEMA Relating To Radiological Emergency Planning and Pre-paredness, does not permit the NRC to simply adopt FEMA's acceptance of an emergency plan without review or question.
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Mr. Jamss L. Taylor Mr. Victor Stello Page 4 Under the Memorandum of Understanding, NRC responsibilities include, among others:
"3. To review the FEMA findings and determinations as to whether offsite plans are adequate and can be implemented. "
"4. To make readiological health and safety decisions with regard to the overall state of emergency preparedness (i.e., integration of emergency preparedness onsite as determined by the NRC and offsite as determined by FEMA and reviewed by NRC) such as assurance for continued operation,.., or for taking enforcement actions, such as shutdown of operating reactors."
NRC review - not merely acceptance - of FEMA findings is required because the NRC, not FEMA, has " final decisionmaking authority to determine whether emergency preparedness is adequate
... " County of Rockland v. NRC, 709 F.
2d. 766,770 (2d Cir. 1983).
"The (Memorandum of Understanding) and the enabling legislation found in the ERA make clear that the Commission is ultimately responsible for making the crucial decisions with respect to emergency preparedness at nuclear facilities.
The Commission's authority is broad - it may shut down a nuclear plant or take additional enforcement accion if not satisfied with emergency preparedness." Id.
At most, FEMA's findings constitute a " rebuttable presumption".
See 10 CFR 50. 47 (a)(2).
Where, as here, responsible local officials assert that mamy of their constituents cannot hear or understand emergency sirens, that many of the local volunteers relied upon to notify and evacuate residents would likely flee in the event of a serious nuclear accident, and that local roads cannot accomodate the potential traffic, the presumption is rebutted, at least until a careful, thorough review of the actual realities of the situation demonstrates that the emergency plan could and would, in fact, work.
The NRC should now conduct precisely such an inquiry into the LaSalle plan.
Until it is complete, LaSalle should not be permitted to resume operations, because there is no reasonable assurance that, in the event of a serious nuclear accident at LaSalle, Seneca's residents would be timely and effectively notified and evacuated to a safer place.
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a Mr. James L. Taylor Mr. Victor Stello Page 5 In view of the anticipated August 1, 1986 resumption of operations at LaSalle, I would appreciate your advising me of the status of your review by not later than close of business, Tuesday, July 29, 1986.
(I have this date orally advised NRC Region III Administrator James Keppler of this 2.206 petition, and I understand that, this afternoon, he advised officials in Washington to expect it.)
Sincerely, b
Douglass W. Cassel, Jr.
Robert Guild Attorneys for Village of Seneca Encl: (1) Illinois Plan for Radiological Accidents -
LaSalle, Annex 3E, Seneca (2) June 17,1985 letter from Seneca Mayor Wayne Anderson to NRC Region III Administrator James Keppler (3) " Issues" cc: NRC Commissioners NRC Region III Administrator James Keppler NRC Docketing Michael I. Miller, Counsel for Commonwealth Edison Co.
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- ILLINOIS PLAN FOR RADIOLOGICAL ACCIDENTS - LASALLE ANNEX 3E SENECA REV. 1, 12/85 v
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j 12/85 Annex 3E Seneca Procedures Table of Contents Seneca Procedures Seneca Mayor....................... I Seneca ESDA Coordinator................
5 Seneca Fire Department Chief..............
7 Seneca Police Dispatcher................
9 Seneca Police Department Chief.............
11 Seneca District #160 and #170 School Superintendents..............
13 Seneca Ambulance Service President...........
15 Brookfield Township Supervisor.............
17 Manlius Township Supervisor.............. 19 v
F CoasTmoLLEDCOPY mEPeocuCTces PROM.8ITED T
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SENECA MAYOR Upon receiving notification of an incident at the LASALLE COUNTY STATION from the SENECA POLICE DISPATCHER, the SENECA MAYOR will perfom the following tasks:
IF NOTIFICATION OF UNUSUAL EVENT OR ALERT CLASSIFICATION
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1.
Review the most current NARS fom and be prepared to brief municipal officials.
2.
Determine if the EOC is to be activated at the Alert Classifi-cation by referring to item 9 (Recomended Protective Actions) on the NARS fom and implement the appropriate action as indicated below:
a.
If letter A is indicated under item 9 on the NARS fom, the Seneca EOC should not be activated.
v b.
If letter B is indicated under item 9 on the NARS form, proceed to the EOC and implement 3-509-1, "LaSalle/Grundy County Emergency Operations Center (E0C) Activation and Operation".
Instruct the SENECA POLICE DISPATCHER to have municipal officials report to the E0C.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY CLASSIFICATION 3.
Report to the SENECA EOC and activate the E0C, if not previo-~
usly activated.
4.
Review the most current NARS form and confer with municipal department heads on the situation.
5.
Review department assignments and responsibilities:
a.
ESDA COORDINATOR coordinate the evacuation of the general population, transient populations, and special concerns, coordinate requests for assistance, assist in notification of news media, coordinate public notifi-
- cation, coordinate re-entry activities, coordinate decontamination of village equipment, ensure distribution of dosimetry (instant-read dosimeter (s) and TLD card),
radiation exposure records and KI.
KI tablets will be administered on a voluntary basis only upon the recom-mendation of IDNS.
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FIRE PROTECTION DISTRICT - perform regular fire protec-tion and emergency medical services, assist with public notification, assist with traffic and access control, and conduct decontamination of village equipment.
c.
POLICE DEPARTMENT - perform regular law enforcement and crime prevention activities, implement traffic and access control, and provide for public notification.
d.
SCHOOL SUPERINTENDENTS coordinate evacuation of the general population, transient populations, faculty, staff and school students using school buses, e.
AMBULANCE SERVICE perform regular emergency medical services, assist in public notification and traffic and access
- control, as requested.
Coordinate for the notification and care of the mobility impaired.,
f.
HIGHWAY COMMISSIONERS - maintain clear roads and provide barricades for use in traffic and access control.
6.
Establish communications with the LASALLE COUNTY EOC and consult with the LASALLE COUNTY ESDA C0ORDINATOR.
7.
Coordinate with the LASALLE COUNTY ESDA COORDINATOR and the SENECA ESDA COORDINATOR to make hourly situation status reports to the LASALLE COUNTY EOC.
8.
Review the evacuation sectors and routes, and traffic and access contrni posts with the SENECA ESDA COORDINATOR and the SENECA POLICE CHIEF.
9.
Coordinate the preparation of press releases with the LASALLE COUNTY ESDA COORDINATOR and the SENECA ESDA COORDINATOR.
10.
Authorize the SENECA ESDA COORDINATOR to contact the LASALLE COUNTY ESDA COORDINATOR at the LASALLE COUNTY E0C to request assistance, as required.
11.
In the event of an evacuation, direct the SENECA ESDA C00RDI-NATOR and the DISTRICT #160 and #170'SCH00L SUPERINTENDENTS to I
coordinate the transportation of the general population, transient populations and special concerns in accordance with 3-50P-8, "LaSalle County Station EPZ Sheltering and Evacuation 1
- General, Population".
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In the event of an evacuation, direct the DISTRICT #160 and
- 170 SCHOOL SUPERINTENDENTS to coordinate the transportation of faculty, staff and school students in accordance with 3-SOP-9, "LaSalle County Station EPZ Sheltering and Evacuation
- Schools".
13.
Ensure that the' AMERICAN RED CROSS and other appropriate agencies are providing proper social services at Congregate Care Shelters and other required areas.
IF NOTIFICATION OF RE-ENTRY 14.
Instruct the SENECA ESDA COORDINATOR and the DISTRICT #160 and
- 170 SCHOOL SUPERINTENDENTS to coordinate the transportation of returning evacuees from Congregate Care Shelters in accord-ance with 3-SOP-11. "LaSalle County Station EPZ Re-entry".
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SENECA ESDA COORDINATOR Upon receiving notification of an incident at the LASALLE COUNTY STATION from the SENECA POLICE DISPATCHER, the SENECA ESDA COORDINATOR will perform the following tasks:
IF NOTIFICATION OF UNUSUAL EVENT OR ALERT CLASSIFICATION 1.
Contact the SENECA MAYOR for a briefing or report to the SENECA EOC, as directed by the SENECA POLICE DISPATCHER.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY CLASSIFICATION 2.
Report to the SENECA E0C ar.d confer on the situation with the SENECA MAYOR.
3.
Review the most current NARS form.
4 Ensure that all departments distribute or obtain dosimetry (instant-read dosimeter (s) and TLD card), radiation exposure v
records and KI for all emergency personnel, and maintain a Dosimetry Control Log where appropriate. Distribute dosimetry and KI to all personnel within the SENECA E0C and have each complete a radiation exposure record.
KI tablets will be administered on a voluntary basis only upon the recomendation of IDNS. Maintain a Dosimetry Control Log (see Annex 1A).
5.
Review evacuation sectors and routes, and traffic and access control posts with the SENECA MAYOR and the SENECA POLICE CHIEF.
6.
Coordinate with the DISTRICT #160 and #170 SCHOOL SUPERINTEND-ENTS to review the affected sectors and detennine which schools are in,volved.
7.
Coordinate the preparation of press releases with the LASALLE COUNTY ESDA COORDINATOR and the SENECA MAYOR.
8.
Coordinate the systematic notification of the public for the protective actions of information, take shelter, or evacu-ation.
9.
Monitor and record the progress of all SENECA departments responding to the emergency.
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Direct requests for' assistance to the LASALLE COUNTY ESDA l
C0ORDINATOR at the LASALLE COUNTY EOC, as the need arises.
11.
Coordinate with the SENECA MAYOR to make hourly situation status reports to the LASALLE COUNTY EOC.
12.
Coordinate with the LASALLE COUNTY ESDA COORDINATOR to notify transient populations, which cannot be notified by the SENECA POLICE DEPARTMENT, of the reco:enended protective actions in accordance with 3-50P-8, "LaSalle County Station EPZ Shelter-ing ard Evacuation - General Population".
13.
In the event of an evacuation, coordinate with the LASALLE COUNTY EfDA COORDINATOR for the transportation of the general populaticn, transient pcpulations and special concerns to Congregaf.e~ Care Shelters in accordance with 3-SOP-8.
14.
In the event of an evacuation, coordinate with t'he LASALLE COUNTY SHERIFF'S DEPARTMENT for the transportation of home-bounds in accordance with 3-SOP-10. "LaSalle County Station EPZ Sheltering, Evacuation and Re-entry - Special Concerns".
IF NOTIFICATION OF RE-ENTRY 15.
Coordinate decontamination of village equipment by the SENECA FIRE DEPARTNENT with the assistance of IDMS.
16.
Coordinate with the LASALLE COUNTY REGIONAL SUPERINTENDENT OF SCHOOLS and the DISTRICT #160 and #170 SCHOOL SUPERINTENDENTS fer the transportation of returning evacuees from Congregate Care Shelters in accordance 'with 3-SOP-11 "LaSalle County Station EPZ Re-entry".
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- 17. Ensure collection of all dosimetry and radiation exposure records by each department.
r#1ect dosimetry and radiation exposure records from perssute) within the SENECA EOC ar.d forward all TLDs, radiati X <<pos re records and copies of the Dosimetry Control Logs to Ne N LLE COUNTY ESDA COORDINATOR.
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iids SENECA FIRE DEPARTMENT CHIEF Upon receiving notification of an incident at the LASALLE COUNTY STATION from the SENECA POLICE DISPATCHER, the SENECA FIRE CHIEF will perform the following tasks:
IF NOTIFICATION OF UNUSUAL EVENT OR ALERT CLASSIFICATION 1.
Contact the SENECA MAYOR for a briefing or report to the EOC, as directed by the SENECA POLICE DISPATCHER.
Place personnel and resources on standby, if requested.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY CLASSIFICATION 2.
Report to the SENECA EOC and receive a briefing from the SENECA MAYOR.
3.
Review the most current NARS fom.
v 4.
Initiate the department call list and notify department personnel to assemble at the SENECA FIRE STATION.
5.
Ensure that all emergency personnel obtain dosimetry (instant-read dosimeter (s) and TLD card), radiation exposure records and KI from the SENECA ESDA COORDINATOR prior to entering an exposure pathway.
KI tablets will be administered on a voluntary basis only upon the recomendation of IDNS.
6.
Follow nomal operating procedures for fire prevention and emergency medical services.
7.
When requested, assist the SENECA POLICE DEPARTMENT in the systematic notification of the public for the protective actions of information, take shelter, or evacuation.
IF NOTIFICATION OF RE-ENTRY 8.
Conduct decontamination of village equipment in coordination with the SENECA ESDA COORDINATOR and the assistance of IONS.
9.
Ensure that department personnel return dosimetry and radiation exposure records to the SENECA ESDA COORDINATOR.
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SENECA POLICE DISPATCHER Upon receiving notification of an incident at the LASALLE COUNTY STATION from.the LASALLE COUNTY SHERIFF 'S DISPATCHER, the SENECA POLICE DISPATCHER will perform the following tasks:
j 1.
Complete a NARS form.
Call the LASALLE COUNTY SHERIFF'S DISPATCHER to verify the information, then photocopy a suffi-cient number of copies for distribution to SENECA officials.
I IF NOTIFICATION OF AN UNUSUAL EVENT OR ALERT CLASSIFICATION 2.
Implement 3-SOP-2, "LaSalle County Station EPZ Initial Notifi-cation and Mobilization for an Unusual Event", Attachment F, or 3-SOP-3, "LaSalle County Station EPZ Initial Notification and Mobilization for an Alert", Attachment F, as applicable.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY' CLASSIFICATION v
3.
Implement 3-SOP-4, "LaSalle County Station EPZ Initial Notifi-cation and Mobilization for Site Area Emergency", Attachment F, or 3-SOP-5, "LaSalle County Station EPZ Initial Notifica-tion and Mobilization for General Emergency", Attachment F, as applicable.
4.
At the direction of the SENECA POLICE CHIEF, dispatch all available squad cars and incoming police officers, to notify the public via mobile PA of the appropriate protective action message of information, take shelter, or evacuation.
(see Annex 1A).
5.
Make periodic status reports to the SENECA EOC.
6.
Advise all citizens calling in to tune their radios to WCMY (1430 AM) or WRKX (95.3 FM) for further information.
IF NOTIFICATION OF RE-ENTRY 7.
Upon receipt of re-entry notification, call the LASALLE COUNTY SHERIFF'S DISPATCHER to verify the information and notify the SENECA MAYOR.
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SENECA POLICE DEPARTMENT CHIEF Upon receiving notification of an incident at the LASALLE COUNTY STATION from the SENECA POLICE DISPATCHER, the SENECA POLICE CHIEF will perfom the following tasks:
IF NOTIFICATION OF UNUSUAL EVENT OR ALERT CLASSIFICATION 1.
Contact the SENECA MAYOR for a briefing or report to the EOC, as directed by the SENECA POLICE DISPATCHER.
Place personnel and resources on standby, if requested.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY CLASSIFICATION 2.
Report to the SENECA EOC and receive a briefing from the SENECA MAYOR.
3.
Review the most current NARS fom.
v 4.
Initiate the department call list and notify personnel to assemble at the SENECA POLICE STATION.
5.
-Ensure that all emergency personnel obtain dosimetry (instant-read dosimeter (s) and TLD card), radiation exposure records and KI from the SENECA ESDA COORDINATOR prior to entering an exposure pathway.
KI tablets will be administered on a voluntary basis only upon the reconnendation of IDNS.
6.
Review the evacuation sectors and routes, and traffic and access control posts with the SENECA MAYOR and the SENECA ESDA C0ORDINATOR.
7.
Provide for the systematic notification of the public for the protective actions of infomation, take shelter, or evacuation by directing squad cars and other assisting departrients to broadcast the appropriate mobile PA warning message (see Annex 1A and 3-50P-6, "LaSalle Station EPZ Prompt Notification System"),asrequested.
8.
Follow departmental procedures for law enforcement and crime prevention activities.
9.
In the event of a protective action reconnendation of take shelter or evacuation, provide and maintain traffic and access control in accordance with 3-SOP-7, "LaSalle County Statierr
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EPZ Traffic and Access Control".
Make requests for manpower and equipment, as required.
IF NOTIFICATION OF RE-ENTRY 10.
Provide and maintain orderly traffic control.
11.
Ensure that department personnel return dosimetry and radia-tion exposure records to the SENECA ESDA COORDINATOR.
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SENECA DISTRICT #160 and #170 SCHOOL SUPERINTENDENTS Upon receiving notification of an incident at the LASALLE COUNTY STATION from the SENECA POLICE DISPATCHER, the DISTRICT #160 and #170 SCHOOL SUPERINTENDENTS will perfonn the following tasks:
IF NOTIFICATION OF ALERT CLASSIFICATION 1.
Contact the SENECA MAYOR for a briefing or report to the SENECA EOC, as directed by the SENECA POLICE DISPATCHER.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY CLASSIFICATION 2.
Report to the SENECA EOC and receive a briefing from the SENECA MAYOR.
3.
Review the most current NARS form.
4.
Coordinate with the LASALLE COUNTY REGIONAL SUPERINTENDENT OF v
SCHOOLS and the SENECA ESDA COORDINATOR to review affected sectors and detemine the schools which are involved.
5.
Ensure distribution of dosimetry (instant-read dosimeter (s) and TLD card), radiation exposure records and KI to all emergency personnel who may be entering an exposure pathway.
KI tablets will be administered on a voluntary basis only upon the recommendation of IDNS.
Assign a department person to maintain the Dosimetry Control Log (see Annex 1A).
6.
Coordinate with the LASALLE COUNTY REGIONAL SUPERINTENDENT OF SCHOOLS and the KLINE BUS COMPANY PRESIDENT to detemine the availability of the school bus drivers, buses and the assembly time required.
7.
Direct the appropriate protective actions for the following respective schools:
a.
Seneca Township High School (District #160) b.
Circuit Breaker School (District #160) c.
Seneca C.C. School (District #170) 8.
If take shelter has been recommedned, coordinate with the LASALLE COUNTY REGIONAL SUPERINTENDENT OF SCHOOLS and the KLINE BUS COMPANY PRESIDENT to place school bus drivers on call or standby, as the situations warrants.
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If evacuation has been reconnended, coordinate with the LASALLE COUNTY REGIONAL SUPERINTENDENT OF SCHOOLS and the KLINE BUS COMPANY PRESIDENT to mobilize the school buses and drivers at the affected schools.
10.
In the event of an evacuation, coordinate with the LASALLE COUNTY REGIONAL SUPERINTENDENT OF SCHOOLS and the KLINE BUS COMPANY for the transportation of faculty, staff and school students within affected sectors to Congregate Care Shelters in accordance with 3-SOP-9, "LaSalle County Station EPZ Sheltering and Evacuation - Schools".
Inform the SENECA ESDA COORDINATOR of the status of school evacuation.
11.
In the event of an evacuation, coordinate with the LASALLE COUNTY REGIONAL SUPERINTENDENT OF SCHOOLS and the KLINE BUS COMPANY PRESIDENT for the transportation of the general population, transient populations and special concerns within affected sectors to congregate care shelters in accordance with 3-50P-8, "LaSalle County Station EPZ Sheltering and Evacuation - General Population".
12.
Direct school personnel to assist the AMERICAN RED CROSS personnel at Congregate Care Shelters, if needed.
IF NOTIFICATION OF RE-ENTRY 13.
Coordinate with the LASALLE COUNTY REGIONAL SUPERINTENDENT OF SCHOOLS, the KLINE BUS COMPANY PRESIDENT and the SENECA ESDA COORDINATOR for the transportation of returning evacuees from Congregate Care Shelters, in accordance with 3-50P-11. "La-Salle County Station EPZ Re-entry".
14.
Ensure collection of all department dosimetry and radiation exposure records.
Turn in all TLDs, radiation exposure records and a cop:v of the Dosimetry Control Log to the SENECA ESDA COORDINATOR.
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v SENECA AMBULANCE SERVICE PRESIDENT Upon receiving notification of an incident at the LASALLE COUNTY STATION from the SENECA POLICE DISPATCHER, the SENECA AMBULANCE SERVICE PRESIDENT will perform the following tasks:
IF NOTIFICATION OF ALERT CLASSIFICATION 1.
Contact the SENECA MAYOR for a briefing or report to the SENECA E0C, as directed by the SENECA POLICE DISPATCHER.
Place personnel and resources on standby, if requested.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY CLASSIFICATION 2.
Report to the SENECA EOC and receive a briefing from the SENECA MAYOR.
3.
Review the most current NARS form.
v 4.
Initiate the department call list and notify personnel to assemble at the SENECA FIRE AND EMERGENCY SERVICES 8UILDING.
5.
Ensure that all emergency personnel obtain dosimetry (instant-read dosimeter (s) and TLD card), radiation exposure records and KI from the SENECA ESDA COORDINATOR prior to entering an exposure pathway.
KI tablets will be administered on a voluntary basis only upon the reconsnendation of IDNS.
6.
Follow departmental procedures for emergency medical services.
7.
Assist the SENECA POLICE. DEPARTMENT in notification of the public, and traffic and access control, if requested.
8.
Coordinate with the LASALLE COUNTY ESDA COORDINATOR for the notification and care of the mobility irrpaired.
IF NOTIFICATION OF RE-ENTRY 9.
Ensure that department personnel return dosimetry and radia-tion exposure records to the SENECA ESDA COORDINATOR.
v III(3E)
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Losasse ctunty 12/85 v
BROOKFIELD TOWNSHIP SUPERVISOR Upon receiving ~ notification of an incident at the LASALLE COUNTY STATION from the SENECA POLICE DISPATCHER, the BROOKFIELD TOWNSHIP SUPERVISOR will perfom the following tasks:
IF NOTIFICATION OF ALERT CLASSIFICATION 1.
Contact the SENECA MAYOR for a briefing or report to the SENECA EOC, as directed by the SENECA POLICE DISPATCHER.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY CLASSIFICATION 2.
Report to the SENECA EOC and receive a briefing from the SENECA MAYOR.
3.
Review the most current NARS fom.
4.
Initiate the department call list and notify personnel to assemble at the BROOKFIELD HIGHWAY GARAGE.
5.
Ensure that all emrgency personnel obtain dosimetry (instant-read dosimeter (s) and TLD card), radiation exposure records and KI from the SENECA ESDA COORDINATOR prior to entering an exposure pathway.
KI tabl'ets will be administered on a voluntary basis only upon the reconnendation of IDNS.
6.
Maintain clear roads by providing equipment to remove snow, debris, disabled vehicles, etc.
7.
Provide and deliver barric'ades for use in traffic and access control, as requested by the SENECA POLICE CHIEF.
IF NOTIFICATION OF RE-ENTRY 8.
Remove barricades from traffic and access control posts.
9.
Ensure that department personnel return dosimetry and radia-tion exposure records to the SENECA ESDA C0ORDINATOR.
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L MANLIUS TOWNSHIP SUPERVISOR -
Upon receiving notification of an incident at the LASALLE l
COUNTY STATION from the SENECA POLICE DISPATCHER. the MANLIUS TOWNSHIP SUPERVISOR will perform the following tasks:
IF NOTIFICATION OF ALERT CLASSIFICATION 1.
Contact the SENECA MAYOR for a briefing or report to the SENECA EOC, as directed by the SENECA POLICE DISPATCHER.
IF NOTIFICATION OF SITE AREA EMERGENCY OR GENERAL EMERGENCY CLASSIFICATION 2.
Report to the SENECA E0C and receive a briefing from the SENECA MAYOR.
3.
Review the most current NARS form.
4.
Initiate the department call list and notify personnel to V
assemble at the MANLIUS TOWNSHIP HIGHWAY COM4ISSIONER'S home.
5.
Ensure that all emergency personnel obtain dosimetry (instant-Tead dosimeter (s) and TLD card), radiation exposure records and KI from the SENECA ESDA COORDINATOR prior to entering an exposure pathway.
KI tablets will be administered on a voluntary basis only upon the recommendation of IDNS.
6.
Maintain clear roads by providing equipment to remove snow, debris, disabled vehicles, etc.
7.
Provide and deliver barricades for use in traffic and access control, as requested by the SENECA POLICE CHIEF.
IF NOTIFICATION OF RE-ERTRY 8.
Remove barricades from traffic and access control posts.
9.
Ensure that department personnel return dosimetry and radia-tion exposure records to the SENECA ESDA COORDINATOR.
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III(3E)
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"A Communsey With A Plan"
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C.PETERSON DARLENE Esitsa
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, c,"a *.,7u VILLAGE OF SENEC A uluH,,c.,,
Fabise H.ste & Saleep WAYNE A. ANDERSON, MAYOR I'**""
ULLIAN G. FRICKE Depomnent of Pubhc Affairs EllTE L LEICH simu a P=bue '. _-
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caAIG C055 Seneca, Illinois 61360 Pubine Property June 17, 1986 l
Mr. James Keppler Regional u=inistrator U. S. Nuclear Regulatory Ceaum.
Region 3 799 Roosevelt Road Glen Ellyn, 11. 60137 Dear Mr. Keppler
'Jhis letter' is to notify you that the Village of Seneca f-11y withdraws it's agreement to participate in the Illinois Plan for Radioactive Accidents, IaSalle-Yolume 3 and likewise withdraws from any and all participation in C- _ w M th Edison's Energency Plan for Radiological brgencies at the IaSalle Station Nuclear Plant.
i b basis of my decision to formally withdraw participation is.that I as convinood that the plan is not fossable for our Village and it's more than 2,100 residents in the event of an emergency. Nor i
do I believe the plan, in view of all of it's shortoonings and problems, can be made to work for our Village.
Absent a valid emergency plan, I do not believe Conunonwealth Edison can properly maintain it's operating lioense for Tahlle, pursuant to X CPR 50 54 (Q) an4 (S) and Appendix E thereto. I therefore request ht you do not authorise resumption of operations at IaSalle Station, which as you know, is presently shut h, unless and until a valid emergency plan is developed.
Mr. Keppler, I very much appreciated hearing fras you this afternoon, and I appreciate your personal commaitment ht you would not allow resumption of operations at IaSallt station, without first meeting persanally with me at Seneos.
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By copy of this letter, I am likewise notifying the agencies' listed below of ar concern.
Since ly,
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Village of Senean WAA/dk oon red. m rg. Manas nt Agency James O'Connor, mai m, Com. Bd.
Gov. James R. 'Jhompson Att'y. Gen. Neil Hartigen II. Energ. Servioes & Dinaster Agemoy II. Dept. of Nuclear Safety Richexd Haller, LaSalle, Co. Board William Waters, Grundy Co. Board Mayor John Knutson, Marseilles Mayor Frank Heimer, Ransom Mayor Robert Hines, Grand Ridge Sen. Jerome Joyce Rep. Ray Christenson 9
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bXH/8 W d ISSUES 1.
An open policy by the Utility and NRC on all information and data requested by local governments and public affected by the location of the Utility. Absolutely nothing should be held back or secretive.
'Ihe plant was constructed in our midst and affects our lives and property. Included in this should be all pertinent data and infor-mation as it regards the leak rate. Likewise, all data, including perhaps, independent inspection of the soundness of the containment structure.
2.
'Ihe NBC should have representatives at the plant 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> out of every week, rather than just 5 days a week on the " day shift".
3.
A code of ethics for the NRC, ESDA, and FDIA.
A.
Members of these agencies should not be hired from a Utility, and likewise barred from leaving the agency and becoming employed, on the board, or holding stock in a Utility. Basically, members of these agencies should be wholly loyal to the people they are hired to represent.
Certainly, they should not be placed in a position where their loyalties huma questionable, or for that matter, fall prey to special interests. Presently, it appears as these agencies " sleep in the same bed" as the Utility.
4.
Radiation monitors should be strategically placed within each comunity located within the potentially affected radius of the plant. 'Ihese monitors should be paid for by the Utility and checked by independents who would also be compensated by the Utility, but through the affected Villages.
5.
In the event of an " alert", or in same cases an " unusual incident",
direct notification should be made to the affected Villages and
'Ibwnships. Allow the local governments to determine what action, if any, should be taken. 'Ihere is absolutely no reason why valuable time should be lost by the Utility determining if, and when, they would like to make notice. Furthermore, so much time is wasted in the Utility notifying the State, the State in turn " mulling-over" the data, and notifying the county level. Again, the county level " mulls-over" and then makes contact with local officials. Give us imediate notification and allow us to make the decision!
6.
In addition to the sirens, additional notification systems should be implemented in the Villages and Townships, if possible. For example, i
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cablo override rystems for communities on cab 12.
It is our opinion that the sirens could possibly lend scme assistance, however, sirens have a tendancy of creating more confusion and causing chaos than not. Too many times, the sirens only lend people to stand around and ask the question "what's going on, is it the real thing or what should I do"?
7.
We are extremely lacking in education of department heads, emergency personnel and the total ccxtmunity.
A.
'Ihere should be a fully illustrated presentation on the " worst possible scenario" for heads of local govern-ment and their department heads. 'Ihis presentation should start with what would be the occurence at the Utility, how it would escape the containment, and the distance and speed the contamination would travel. Ebrthermore, it should explain what, if anything, one would see or feel. Likewise, it should carry all the way through to the after effects of the contamination and how it would affect people and property.
B.
Eriuc.te business and industry frcm their plants and business's, and how the people should frca that point, fall into the full scale evacuation.
C.
Investigate the possibility of locating fully trained, full tbne nuclear emergency people within ccximunities. 'Ibese people could coordinate and control the evacuation. Like-wise, in the absence of volunteer's showing-up, these people should man the evacuation.
.D.
A full scale education of the connunity on the potential of a disaster should be taken by the Utility and the government agencies. Presently, the Utility has been same what successful in the past in getting the ccurnunity to
" buy" it's ideology on the fact that nothing would or could happen. 'Ihis truly impedes local government and emergency people to take seriously any evacuation. On one hand the Utility and the agencies are asking the ccatuunity to accept the plan and likewise the burden of making the plan effectual, however, their ideology works against successful implementation of same.
E.
ESDA and the NBC should take a long, hard look of the geography of the area. I would call attention to Senecas' single route through the certmunity, which includes the business district, and that all arterial streets empty onto this single two lane route. Furthermore, a mobile hczne park and other rural subdivisions to the south of Seneca would also use this single route going north by northeast to Yorkville. Add to this, the fact that in certain times of the year, Woodsmoke Ranch which is located approximately one to one and one-half miles north of Seneca, could have as many as 6,000 campers c,ver a weekend. 'Ihese people would also be evacuate 1 onto this single two lane road-way northbound. 'Ihere is no possible way such an evacuation could be effective. In addition, there is no direct access l
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F.
Manpower and equipnent is a grave question. Most of the connunities involved operate their emergency servises by volunteers. hho is to guarantee that the volunteers will show up. Likewise, most of these volunteers have full time jobs outside of the ccnnunity.
How can an evacuation work, especially one of this size, absent the necessary manpower and equipnent. It should also be pointed out that the Villages' are highly dependent on their fire districts for the majority of the manpower and equipnent. However, these fire districts are also rsponsible for the rural areas, which include townships bordering their perimeters. %erefore, in the rural areas, it will be necessary for emergency personnel to go almost
door to door". mis will slow down the evacuation plan almost to a " crawl".
8.
More money for the ESDA department. Presently, monies for ESDA
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in Tah11e county have been allocated at approximately 25 cents per person within the co.oorate limits. 2 erefore, citing Seneca as an example, we receive approximately $600.00 per year. Of this
$480.00 of this goes to the ESDA coordinator, which leaves very little left for equignent, training and participation in the Utility expenses of the ESDA office and dispatch. B erefore, we are digging into the general fund for additional expenses.
Add to that the fact that the ESDA coordinator is also, in essence, coordinating evacuation fr a the rural areas through Seneca. We are.not receiving money for rural involement.
In addition, ESDA monies are used to cover required drills. In these cases, the local government is asked to pay all costs and expenses related to the drill, then place a claim for reimbursement. mis is certainly not equitable for the ccanunity as we do not have the funds to become a " loan organization". Likewise, very often all of the expenses incurred are not reimbursed.
We were told by Illinois ESDA, that in the case of a disaster, local officials would remain at the EOC throughout the duration of the disaster, his included remaining in the EOC, with windows and doors taped by masking tape, until orderly return of the population i
could be made. mis is rediculous!
It's unbelievable to assume that anybody is going to remain in the EOC. Ebrthermore, there are no provisions such as stores of food, haMing and etc. in the EDC. Who would pay for such stores?
We do not feel it would be the taxpayers duty to cczne up with the additional monies to provide all of the inadequacies for this program. %e Utility was placed here through a PR blitz by the Utility. Werefore, responsability of seeing to these itens should be up to the Utility.
It would seem ludicrous to ask the taxpayers to carry this burden. 'Ib do so, wuld be analogous to be blind-folded and tied to the post, and then asked to supply the bullets
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9.
There seems to be a conflict between ESEA and the NRC on the radiation contamination area. ESta has planned for a 10 mile area, and NRC representatives had stated a 50 mile area should be considered in light of Chernobyl. Should this be the case, should the plan be amended to remove the current sites of approximately 25 miles, to a 50 mile site.
- 10. The nulaar industry should not have " limited liability". They should be held 100% liable for their actions to effect first rate construction of plants, i=wv able management and comunity Concern.
A.
If local governments are to be made a part of evac-uation and drills, the Utility should provide protection to these local governments as " additional insureds".
B.
If they cannot provide " additional insured", they should provide indemnification clauses.
C.
Clear, concise explanations in writing, how claiment's would collect for property in a worst possible scenario?
Likewise, for hnelily injury or fatalities. There should be p w gi. payment with no argument or need for negoti-ation.
D.
1(eep Federal government and Federal judges out of claims and settlements. We would expect guarantees of prmpt handling of all claims.
E.
Who evaluates one's property or bodily injury claim?~
2at proof of loss, if any will be demanded? m o has the authority to pay or who is required to approve payment?
F.
Did Nuclear Insurers of America appraise the total property value in a 10 mile area of the plant, 20 mile area? If so, what is the value? If not, why?
G.
Where there any statistics prepared or considered as it regarded potential loss of life in a " worst possible scenario"?
H.
In the event of the current 560 million dollars being depleted, is there currently other availabel monies? If not, is Congress expected to come up with more money?
If so, how long could one expect that to take?
I.
In the event the cap is exausted, what happens? Is' payment based on dollar for dollar or are we asked to take a percentage of our total loss?
J.
As people tw= more aware, or reluctant to locate near a nuclear reactor, what provisions or coverage is there for loss of value of property? Ioss of business? If the Utilities location in the interest of it's profit has an
adverse effect on exinting property and busines, should they not be acccnntable?
- 11. With radiation, radium, radon and etc. in our comunities, has sme agency been created whose responsibility would be coordinating effects on the population? It is important that such an agency i
be created as individual agencies such as the EPA and the NRC continue to talk in allowable levels that affect their individual requirements. It appears that we do not communicate these allowable levels to one another. 'Iberefore it appears such an agency is W.
- 12. In any evacuation, serious or a " fluke", will nuclear insurers' or the Utility pay for all food, motel expenses, automobile expense, loss of wages, business down-time, liability claims by
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or against individuals or local governments and other unusual or incidental expenses? Imediately, if so, provide this in writing in contract form.
- 13. Will the Utility, NRC, ESDA, FDR, and Nuclear Insurer's of America agree to a public forum?
- 14. It should be pointed out that the residents in the Villages and townships in the affected area had a cmfortable and secure, and safe, way of life for many generations. Now, due to the location of the Utility in our midst, we are asked to change our life con-siderably, as well as subject ourselves and families to an extreme risk. Gone is the time that we could return to our homes from a days work to the safety and security of our h m e.
We are now asked to live under the threat of having to imediately evacuate at any given minute of a day. 'Ibe evacuation is given, should we receive adequate warning, have adequate notification, adequate manpower and equipnent to evacuate. 'Ihus, should any of these things fail we fall victim to a disaster created in the interest of someone else's profit motive. 'Ihis risk, in the interest of another's profit, seems extremely selfish and certainly un-neighborly. 'Ibere must be other alternatives to this risk.
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