ML20235G497

Affidavit of C Compton.* Affidavit Contending That State of Nh Radiological Emergency Response Plan Inadequate for Alerting Deaf & Hearing Impaired Residents of EPZ During Accident.Related Info Encl

ML20235G497
Person / Time
Site:	Seabrook
Issue date:	06/18/1987
From:	Compton C GALLAUDET UNIV., WASHINGTON, DC
To:
Shared Package
ML20235G482	List: ML20235G477 ML20235G497
References
OL, NUDOCS 8707140272
Download: ML20235G497 (12)

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1 AFFIDAVIT OF CYNTHIA COMPTON Cynthia Compton, being duly sworn, deposes and states:

1) My name is Cynthia Compton. I am Coordinator for the Assistive Devices Center at Gallaudet University in Washington, D.C. I hold an M.S. in the field of audiology and am an expert

, on devices and wireless systems for the hearing impaired. A copy of my resume, summarizing my qualifications, is attached.

2) I have reviewed those portions of the New Hampshire j Rao,.ological Emergency Response Plan ("RERP"), Revision 2, which ]

ostensibly provide for the notification of hearing impaired indi- {

viduals in the Seabrook emergency planning zone ("EPZ"), in the  !

event of a radiological accident at the Seabrook nuclear power plant. As discussed below, I have concluded that the RERP does 1 not demonstrate that sufficient or proper equipment is in place l to provide an adequate means for alerting the deaf and hearing j impaired EPZ residents of an accident at the Seabrook. nuclear -

power plant.

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3) The RERP does not specify how many tone-alert radios J will be distributed to each hearing impaired household. If the i radio's flashing light is not in the same room with the hearing impaired person, that person will have no way of receiving the alerting message. In order to insure notification, radios should be placed in at least three rooms in each house: the bedroom, the kitchen, and the room in which reading or television-watching ,

is done, j

4) Moreover, the RERP does not specify how bright the flashing light will be. Depending on such variable factors as the color of walls and'the color of the curtains in the hearing-impaired individual's home, one small flashing light may be  !

inadequate. l

5) A tone-alert rad o may be useless in waking a person with a severe hearing loss. The flashing light would not be visible to a sleeping person, and the tone would be inaudible. ,

In order for the radio to alert the sleeping person, it would  ;

have to be connected to the person's existing wake-up system, which might include a bed-shaker. .  ;

6) The RERP does not state whether the tone-alert radios are battery-operated. Tone-alert radios should have an indepen-dent power source so that they can perform their alerting func-tion during a power outage.

7) According to the af fidavit of Gary J. Ca t apano, dated June 11, 1987, labels will be affixed to tone-alert radios with instructions for the hearing impaired to follow if the tone-alert radio is activated. 1 2. P r eswm a bly , those instructions would refer the hearing impaired individuals to some source of informa-8707140272 PDR ADOCK O G{$f0$43 ppg G

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tion regarding the specific emergency response actions that ,

should be taken under the particular conditions of the radiologi-  !

j cal accident. Mr. Catapano provided no copy of those instruc-tions; nor were any included in the portion of the RERP that I reviewed. It is therefore impossible to determine how, other than by the assistance of neighbors, the State of New Hampshire plans to instruct hearing impaired individuals regarding what I emergency response measures they should take in a given accident l' scenario.

8) I am not-aware of any other means by which hearing impaired individuals could receive consistent and reliable l instructions during a radiological. emergency. Radio broadcasts would be ineffective for instructing a large portion of the hear-ing impaired population. Emergency instructions would be effec- l tive if broadcast on television with an open caption system run-ning text in big letters.across the bottom of'the screen. How-ever, in the event of a power loss, television broadcasting would not be possible.

Date: b~~Y Y ? iA fW JW -

Cyhthia Compton Signed and sworn to before me this [ 1 day of June,1987.

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NOTARY PUBLIC Q My commission expires 7)TUh /4 /FA'.

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CYNTHIA COMPTON 44fk!1DTfS' 7303 HILTON AVENUE TAKOMA PARK, MARYLAND 20912 (202) 651-5326 Emolovment GALLAUDET UNIVERSITY, Washington, DC l (Current) Coordinator- Assistive Devices Center Responsibilities include development and implementation of assistive devices project: budget management, protocol development, physical development of Center, clinical services, outreach, and consultation. Have lectured and consulted across the United States, as well as internationally, on assistive device technologies.

(1984 to Present)

Coordinator-Constanment Hearina Aid Procram Development of Hearing Aid Center and implementation of delivery system to Gallaudet and the surrounding Washington, DC communities. Maintenance of inventory.

Ongoing development of protocols interfacing clinical procedures with special needs for clients. (1979 to j Present) {

1 Suoervisina Audiologist Provision of diagnostic and rehabilitative services for the Gallaudet and Washington, DC area communities. Supervise services that include hearing aid fitting andorientation, and evaluation of assistive devices. (1978 to Present)

Emolovment G ALLAUDET UNIVERSITY, Washington, DC (Past) Adiunct Instructor-Dent of Communication Aris (1980)

JOHN F. KENNEDY MEDICAL CENTER, Robert Wood Johnson Jr. Rehabilitation Institute, Edison, New Jersey Clinical Audiologist Diagnosis and Rehabilitation of hearing impaired clientele of all ages. Multidisciplinary team evaluation of clients with suspected hearing impairment due to head trauma, stroke, etc. Implementation and analysis of neonatal hearing screening study. ENG testing and interpretation.

(1976 to 1977)

DOUGLASS COLLEGE / RUTGERS UNIVERSITY, New Brunswick, New Jersey Instructor of Audio;oav (1975 to 1976)

Accointments/ Audiological Consultant, WORLD GAMES FOR Committees _ THE DEAF. (1985 to Present)

Member, SELF HELP FOR THE HARD OF HEARING (SHHH)/ GALLAUDET TASK FORCE. (1986 to Present)

Member (Special Appointment), SHHH ASSISTIVE l LISTENING DEVICES (ALDS) NATIONAL COMMITTEE.

(1985 to Present) l Member, GALLAUDET COMMITTEE ON AGING. (1986 to Present) l Honors / Awards Co-Recipient of Gallaudet University Presidential Award which provided the funding for the development of the Assistive Devices Project. (1984 to 1986)

College for Continuin'g Education (Gallaudet)

Award to fund outreach services in the area of Assistive Devices. (1986)

Education B.A., Speech Pathology, Douglass College, Rutgers University,1973 (Magna Cum Laude)

M.S., Audiology, Vanderbilt University,1974 (Summa Cum Laude)

Post-Masters Coursework: 24 credit hours in the following areas: Human Services Administration; Human Development; Learning and Cognition; Statistics and Research Design. ,

C_ certification / American Speech Languaue-Hearing Association, I Licensure Certificate of Clinic.pl Comoetance. Audiolg.gy Maryland State Licensure, Audiology [

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l Professional American Speech-Language-Hearing Association Organizations District of Columbia Speech-Language-Hearing Associa!!on .

National Association of the Deaf Self Help for Hard of Hearing People (SHHH) I l

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Publication _g Fernandes, C.C. '(1987). Lights, Camera... Audio input! Hearing instruments. In press for. February 1987.

Fernandes, C.C'. (November / December,1986). New Portable Telephone Amplifier . Available.. SHHH. Washington, D.C.: Self Help for Hard of Hearing People.

Fernandes, C.C. and Brandt, F.D. (1986). Assistive Listening Devices: A Consumer-Oriented Summary. Washington, D.C.: Gallaudet Press.

Fernandes. C.C. (1986). Assistive Devices for Hearing-impaired People. In l R. Rozen (Ed.), Life and Work in the 21st- Century: .The Deaf Person of Tomorrow (pp. 173-184). Washington, D.C.: NAD.

Fernandes, C.C. (1986). Gallaudet's Assistive Devices Program. Hearing l Instruments, 37, 24-27.

Fernandes, C. (February 1985). An Assistive Devices Goes to Court.

Hearing Instruments, 30, p.10.

Fernandes, C. and Cooper, K.- (December 1983). L/ sing a Horn Mold with Severe to Profound losses. Hearing instruments,34, p. 6.

Fernandes, C. (1983). Advancement in Amplification System.c.

Communication Fact Sheet, National Information Center on Deafness, Gallaudet University. j Fernandes, C. and Cox, B.P. (1981). The Audiologic Evaluation (instructional videotape). Gallaudet Television Studio.

I Compton, C. (copyright 1975, Spokane ENT Clinic), You and' Your Hearing Aid.

Presentations /Workshoos Assistive Devices in the Workplace: .How to Use Technology to

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.Get .and Keep Your Job. Presented -at Career Center Workshop for Gallaudet Senior's, Gallaudet University, November 25, 1986.

Mahshie, J. and Fernandes, C. Deaf Individuals' Amplification Use and j Speech Feature Production and. Perception. Presented at American Detroit, Speech-Language-Hearing . Association Annual Convention, Michigan, November 22,1986.

Assistive Devices in. the Workplace, Presented at EPOC Supervisor ,

Workshop, Gallaudet University, November 6,1986.

Integrating the Assistive Devices Evaluation Into the Private Practice: Needs Assessment and Protocol. Presented at the

> Washington Speech and Hearing Society Annual Convention, Spokane, Washington, Ocotober 10, 1986.

The importance of Direct Audio input and Telecoil Circuitry in Hearing Aids. Presented at Washington Society of Audiology Annual Meeting, Spokane, Washington, October 9,1986.

t Setting Up an Assistive Devices Center: Some Considerations.

Presented at the 1986 SHHH Convention, Stanford University, Palo Alto, California, August 17-22, 1986.

Assistive Devices in the Nursing Home. Presented at workshop: When Hearing Fades: Responding to the Needs of a Special Population, Masonic Home, Freemont, California. Workshop sponsored by the Gallaudet Regional Center, Ohlone College. August 20,1986.

Coordinator and Presentor, First Annual Assistive Devices Workshop, Gallaudet University, Washington, D.C., July 14-16, 1986.

1 Assistive Devices for Children and Adults. Workshop presented to hearing-impaired consumers, parents and teachers of hearing-impaired students, Lihue Community Center, Lihue, Kaual, June 26,1986.

I Assistive Devices for Hearing-tmpaired People. Workshop presented to professionals and service providers working with hearing-impaired people, Hawaiian Telephone Company, Honolulu, Hawaii, June 25,1986. .

Communication and Alerting Devices for Hearing-impaired Persons. Workshop presented to hearing-impaired persons, their families and friends, Hawaii School for the Deaf and Blind, Honolulu, Hawaii, June 23, 1986.

Kaplan, H. and Fernandes, C., Assistive Devices for Deaf and Hard-of-Hearing People. Presented at the Annual Meeting of the Rehabilitations Engineering Society of North America, Minneapolis, Minnesota, June 23-26, 1986.

Fernandes, J. and Fernandes, C., Communication Education at a College for the Hearing-tmpaired. Presented at the Sixteenth Annual Convention of the Communication Association of Japan, Yatsushiro, Japan, June 14,1986.

Assistive Devices for Hearing-tmpaired people. Presented at the Vith Annual Spanish Seminar, International Center on Deafness, Gallaudet .

University, Washington, D.C., April 30, 1986. I Assistive Devices for the Hearing-impaired: Gallaudet's j Assistive Devices Program. Presented at Hearing Loss and Aging: j Responding to the Needs of a Special Population, National Academy, i Gallaudet University, Washington, D.C., April 8,1986.

l Assistive Devices for Children: Gallaudet's Assistive Devices l Program. Presented at CEC Annual Convention, New Orleans, Louisiana, l April 4,1986. l i

Assistive Devices for Hearing-impaired People. Presented at 1986 i NAD Forum, Las Vegas, Nevada, January 31, 1986.

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p .. . 4 Hearing Aid Selection, Fitting and Troubleshooting. Inservice lectures to Gallaudet Education Majors,1981 to present (bi-annually).

I Coping with Hearing Loss: Innovations in Technology and l Services at Gallaudet, guest speaker on Communication Plus radio talk show, WDJY (103 FM), March 30,1985.

Immittance Testing and Report Writing, Annual inservice Lecture j I

Series, Gallaudet University,1984 to present.

New Advances in Earmold Technology: Applications for the Deaf, NAD Convention, Baltimore, Maryland, July 5,1984. ,

Audiometric Interpretation. Inservices lecture to staff of Gallaudet University infirmary, January 25, 1984.

Testing the Severely to Profoundly Hearing-impaired person.

Lecture to visiting Vanderbilt University graduate students, November 3, 1983.

Assistive Listening Devices. Lecture to participants in Gallaudet University Elderhostel Program, June 17, 1983.

The Application of Killion vs. Standard 2mm Earmolds to the Gallaudet Population. Lecture to Audiology Discussion Group, DC Speech and Hearing Association, Gallaudet University, November 3,1982.

Speech Audiometry. Lecture to participants in International Seminar in Audiometry, Gallaudet University, Summer 1982, i

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i ROLE CONFLICT DURING NUCLEAR EMERGENCIES ADDENDUM l

l I , Donald J. Zeigler, do depose and say as follows:

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In rebutting the contention that the New Hampshire Emergency Response Plan does not make adequate provision for notification of 1 people with special notification needs, the Applicant has suggested that the Atomic Safety and Licensing Board should summarily dispose of New England Coalition on Nuclear Pollution Contention NHLP-4 because the following facts are not in dispute: (1) The EBS announcement will urge persons in the evacuation area to check on ,

neighbors with hearing impairments and assist them in understanding emergency instructions; (2) Additional text will be added to the

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emergency public information calendar, brochure, and telephone directory which instructs neighbors of the hearing impaired to personally verify that their neighbors understand any emergency 1

instructions issued. Given the tenets of role conflict theory, the experience at Three Mile Island, and the results of other studies of role conflict as summarized in my affidavit of April 13, 1987, it is highly unlikely that such procedures will gparantee the safety and welfare of the population with special'needs in the evacuation zone.

In essence, such a notification system puts'all neighbors of hearing impaired individuals in the role of emergency workers. In order for emergency plans to be effective, these neighbhors must be

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i depended upon to make sure that the neighbors have been duly notified of the emergency and that they understand what to do in response to emergency directives. Unfortunately, many of these neighhars will I

find themselves torn by the same role conflict that characterized

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emergency worker behavior during the accident at Three Mlle Island.

While the plans may assume that these neighbors w2.11 immediately I

attend to their role as notification and instruction agents, many will undoubtedly tend to their family responsibilities first. For some this will result in delayed response, making it extremely unlikely that notification can be accomplished within either 15 minutes or 45 minutes of the accident. For others, conflicting family and personal obligations will result in non-response, that is, abandonment of their roles as functionaries in an emergency

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l situation. Furthermore, two additional factors are also likely to work against the neighbor-notification-and-explanation system First, the people being asked to check on neighbors may also be hearing emergency broadcast messages that instruct them to remain inside with windows and doors closed. Such an instruction will conflict with their emergency roles as information disseminators particularly in light of the advice not to use telephones. Second, as distance between neighbors increases in rural areas of the evacuation zone, it is entirely possible that adults with family responsibilities will perceive themselves to have no time to carry out their responsibilities to hearing-impaired neighbors.

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l I do not therefore believe that the revised procedures in the New l Hampshire Radiological Emergency Response Plan are. sufficient to meet the requirements of NUREG-0654. l 1

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COMMONWEALTH OF VIRGINIA

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..pri2 The above described Donald J. Zeigler appeared before me and made oath that he had read the foregoing affidavit and that the statements set forth therein are true to the best of his knowledge.

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