ML20092P744

Responds to Util 840607 Notification to Intervenors of Belief That Util Has Satisfied Stipulated Emergency Planning Commitments M,N,P,U,V & W.Related Correspondence

ML20092P744
Person / Time
Site:	Byron
Issue date:	06/24/1984
From:	Chavez D, Morrison P DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:	ISHAM, LINCOLN & BEALE
References
OL, NUDOCS 8407090329
Download: ML20092P744 (9)

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1. W Sinnissippi Alliance m mr., TF foriiie Environment, ,

326 North Avon Street RockfardJJilif1bic6T403 '3 20:e

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Mr. Alan Bielawski ~~ % '

Isham, Lincoln & Beale Suite 5200 June 24, 1984 Three First National Plaza r;r-Chicago, II. 60602 F;ia:'. 5 t;,,, , .,p g g Re: Byron Station Stipulated Emergency Planning

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Commitments M, N, P,U,V,W Deer Alan:

In accordance with Section 4(d) of the Stipulation, dated March 30,1983, signed by the parties to the Byron Operating Li-cense Proceedings, Intervenors DAARE/ SAFE and the Rockford League of Women Voters hereby respond to Commonwealth Edison's notifica-tion to Intervenors, dated June 7,1984, of Commonwealth Edison's belief that it has satisfied Commitments M, N, P, U, V, and W.

Please find set forth in the attached pages Intervenors responses to each Commitment notification.

l Very truly yours, )

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on oenali of Rockford 4M 1611th legal representative, League of Women Voters DAARE/ SAFE cc: Judge Smith Judge Callihan Judge Cole Richard Rawson Jane Whicher s/@ '

Paul Hol= beck Erie Jones Sheriff Brooks 8407090329 840624 k' .

PDR ADOCK 05000454 ,

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1 COMMITMENT M Demonstrate that IPRA includes adequate provisions for alternative protective actions, in the event evacuation of homebounds and nursing home patients is infeasible. .

Response

The information provided by Commonwealth Edison to the Interven-ors in a letter response dated June 7,1984, fails to provide suffic-ient information to allow the Intervenors to determine whether Commit-ment M has been satisfied. Moreover, said response letter is defic-1ent on it's face to the extent that nursing home Dosimetry Control Officiers have yet to receive DC0 training from the Illinois Depart-ment of Nuclear Safety, as per Edison's modification letter of June 12, 1984.

On information and belief Intervenors state that at least one nursing home director and his staff (Pinecrest Manor) have not rec-eived operational and radiological training, as per Edison's response letter.

Intervenors are undergoing efforts to verify that IPRA includes adequate provisions for alternative protective actions, in the event ovacuation of homebounds and nursing home oatients is infeasible.

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COMMITMENT N Demonstrate that there has been an assess-ment of the number and location of special transport-dependent individuals and that this information is available to Ogle County emergency response officials.

Response

Intervenors disagree that Commonwealth Edison has satisfied Com-mitment N based on it's response letter dated June 7,1984. Edison's letter refers only to the Mobility Impaired Transportation List main-tained by Ogle Emergency Services and Disaster Agency (ESDA). Howw 1

over, Ogle County 6-SOP-8, the Standard Operating Procedure entitled I

" Byron Station EPZ Sheltering and Evacuation-General Population", re-l quires a second mobility impaired list be maintained by Yellowbird Senior Citizens Center and that the two lists be cross-referenced in the event of an emergency in order to identify special cransport-dep-endent individuals. Commonwealth Edison's response letter fails to >

l refer to the mobility impaired list to be maintained by the Yellowbird Senior Citizens Center. Moreover, on information and belief, Inter-f venors state that no such mobility impaired list is currently maintain-ed by Yellowbird, and further, that Commonwealth Edison has failed to contact Yellowbird with regard to said list. The assessment referred I

to in Edison's response letter is not complete.or accurate. ,

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COMMITMENT P Demonstrua that adequate radiological emergency response training has been made available and retraining will be made available to all response organizations and individ-uals who may be called upon to assist in an emergency, viz.,

directors and coordinators of the response organizations; first aid and rescue personnel; medical support personnel; and those otEer off-site organizations identified in IPRA having mutual aid agreements or arrangements with local agencies.

Response

The information provided by Commonwealth Edison to the Interven-ors in a letter response dated June 7, 1984, fails to provide suffic-ient information tio allow the Intervenors to determine whether Commit-uent P has been satisfied. Specifically the fifteen training manuals upon which Commonwealth Edison's response letter relies have not been provided. These manuals have been requested by the Intervenors through standing orders since August 1983. Moreover, said response letter is deficient on it's face to the extent that local officials have yet to receive Re-entry Procedures training (6-ERT-15) from the Illinois Emer-gency Services and Disaster Agency (IESDA), as per Edison's notificat-ion.

With respect to the training sessions, from information provided in the response letter Intervenors are unable to determine which ~per-sonnel attended which training sessions. More importantly, the Emerw gency Worker Training and the Dosimetry Control Officer Training' given to ~ emergency workers and DCO's by the Illinois Department of Nuclear Safety is inadequate to the extent that the instruction in radiation instrumentation recieved by said ' personnel utilized outdated and in-adequate dosimetry equipment and that more sensitive dosimetry equip-ment and accompanying instruction has not been provided to all emer-gency personnel to date. The Emergency Worker Training was the only i i 9

Paga 2 training session Intervenors were given notice of and oermitted to at-tend.

On information and belief Intervenors state that contrary to -

Edison's July 15, 1983 Reply to Intervenors Findings of Fact and Con-clusions of Law regarding Emergency Planning, the training sessions for volunteers have not "provided state planners an occortunity to as-cess the willingness of individual volunteers to carry out their as-signed responsibilities, during a radiological emergency." (Also see Initial Decision, p. 401, entered January 13, 1986) Based on the Oct- -

ober 1983 Emergency Workers Training session attended by Intervenors Commonwealth Edison clearly has failed to orovide reasonable assurance that response organizations will be canable of effectively imolementing the IPRA-Byron. i i

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l COMMITMENT U Demonstrate that there are adequate resources and procedures to effectuate notification by Edison of State and County emergency response organizations, and for notification of emergency personnel by these organizations.

Response

The information provided by Commonwealth Edison to the Interven-ors in a letter response dated June 7,1984, fails to provide suffic-ient information to allow the Intervenors to determine whether Co:mnit-ment U has been satisfied. Interrenors are undergoing efforts to ver-l ify the dependability and the time response of the communication sys-tems to be utilized in a radiological emergency as set forth in Com-mitment U.

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COMMITMENT V i Demonstrate that adequate communications capabilities exist for the Ogle County emergency response organization.

Response

Intervenors disagree that Commonwealth Edison has satisfied Com-mitment V based on its response letter dated June 7,1984. Edison's letter refers to the Ogle County-wide school bus communication system which school districts both within and outside the Byron EPZ partici-pate in and rely upon. On information and belief Intervenors state that no such system is currently operational, or has been procured to date.

Intervenors are undergoing efforts to verify the dependability and the time response of all other communication systems to be util-ized in a radiological emergency as set forth in Commitment V.

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l C0K4ITMENT W (a) Edison agrees to contact and make its personnel with knowledge of the Byron emergency plan available to the mayors of Rochelle, Dixon and Rockford to discuss emer-In order to aid these offic-gency planning for Byron.ials in identifying concerns, Edison will send the m of Rochelle, Dixon and Rockford the following informat-ions (i) a description and explanation of protective and pa-rallel actions to be taken during an emergency; (ii) a description and explanation of what would be re-quired of each of the cities if they were design-ated as a host for evacuees; (idi) a description and explanation of measures to be taken by the state for the ingestion exposure path-way;

' (iv) relevant information on the planning bases for IPRA; and (v) the complete procedure for protection and parallel actions to be followed by the city of Oregon.

a (b) Demonstrate that the Byron Station public information bro-chure has been made available to the mayors of Rockford, e Rochelle and Dixon.

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(c) Edison further agrees to critically review any material, plans or proposals about protection action submitted to

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(d) Edison further agrees to demonstrate that it has develop-ed an adequate procedure to assure that as new mayors of

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T, these communities take office they will be provided with ,

the information described above and that Edison will make its personnel available to discuss emergency planning issues.

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l$ Response-Intervenors disagree that Commonwealth Edison has satisfied Con >-

Said let-mitment W based on its response letter dated June 7,1984.

' l; ter is deficient on its face in that Edison has failed to allow the

=5 y mayors of Rochelle, Dixon, and Rockford adequate time to respond to its May 29, 1984 letter and specifically fails to infona the Mayors in said letter of its agreement to critically review any material,

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Pago 2 plans or proposals about protection action submitted to them by the Mayors.

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