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{{#Wiki_filter:. _ _ _ . | {{#Wiki_filter:. _ _ _. | ||
d | d | ||
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M,lOf /,/h | a. | ||
M,lOf /,/h UNITED STATES OF ERICA | |||
sf | 'x X | ||
NUCLEAR REGULATORY :OMMISSION sf 2f | |||
'U,1 E | |||
BEFORETHEATOMICSAFETYAND{LICENSINGBOARD | |||
[$y., | [$y., | ||
c: | c: | ||
j In The Matter of | |||
) | |||
COMMONWEALTH EDISON COMPANY | g | ||
) | |||
) | |||
COMMONWEALTH EDISON COMPANY | |||
) | |||
Docket Nos. 50-454 OL i | |||
) | |||
50-455 OL | |||
) | |||
(Byron Nuclear Power Station, ) | (Byron Nuclear Power Station, ) | ||
Units 1 & 2) | Units 1 & 2) | ||
STIPULATION Intervenors, DAARE/ SAFE and the Rockford League of Women Voters, Commonwealth Edison Company, and the NRC Staff hereby agree and stipulate that the attached affidavits may | ) | ||
STIPULATION Intervenors, DAARE/ SAFE and the Rockford League of Women Voters, Commonwealth Edison Company, and the NRC Staff hereby agree and stipulate that the attached affidavits may be admitted as Intervenors' Exhibits in the hearing record subject to the following conditions and understandings: | |||
(1) Only those portions of the affidavits which are not marked through are being offered into evidence; (2) None of the witnesses sponsored by Intervenors has expertise in determining sheltering capabilities of specific structures; (3) Only those portions of the "Rockford League. | (1) | ||
Only those portions of the affidavits which are not marked through are being offered into evidence; (2) | |||
None of the witnesses sponsored by Intervenors has expertise in determining sheltering capabilities of specific structures; (3) | |||
Only those portions of the "Rockford League. | |||
l of Women Voters--DAARE/ SAFE Radiological Emergency Response Survey Ambulance Medical Services" which are attached hereto i | l of Women Voters--DAARE/ SAFE Radiological Emergency Response Survey Ambulance Medical Services" which are attached hereto i | ||
which the Board accepted during the hearings are being offered in evidence; i | which the Board accepted during the hearings are being offered in evidence; i | ||
hh569830512 DR M 05000454 O | |||
PDR | |||
4 | |||
COMMONWEALTH EDISON COMPANY BY | , (4) | ||
Those portions of the affidavits of Gary | |||
: Montel, J. | |||
Michael Maloney, Charles Lamb, David Miller, and David Turner for which there is a "13" noted in the margin are relevant only to Intervenor's amended contention 13. | |||
As such, this evidence is being offered only to identify the information which these witnesses desire to communicate to emergency planners. | |||
COMMONWEALTH EDISON COMPANY BY Date NRC STAFF By Date DAARE/ SAFE and ROCKFORD LEAGUE OF WOMEN VOTERS By Date | |||
~ | ~ | ||
w | I. | ||
w 4 :. | |||
4) | |||
Joint Intervenors' Exhibit 13 s | Joint Intervenors' Exhibit 13 s | ||
-) | |||
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 5 e | |||
e In the Matter of | ~ | ||
e In the Matter of | |||
) | |||
Docket Nos. 50-454 OL | ) | ||
) | |||
COI:MONXEALTH EDISON COMPANY | |||
(Byron Nuclear Power Station, | ) | ||
Units 1 & 2) | Docket Nos. 50-454 OL | ||
AFFIDAVIT OF PAUL HOLMEECK The attached statements, questions and answers, and exhibits constitute my testimony in the above-captioned proceeding. The testimony is true and accurate to the best of my knowledge, information, and belief. | ) | ||
50-455 CL | |||
) | |||
(Byron Nuclear Power Station, | |||
) | |||
Units 1 & 2) | |||
) | |||
AFFIDAVIT OF PAUL HOLMEECK The attached statements, questions and answers, and exhibits constitute my testimony in the above-captioned proceeding. | |||
The testimony is true and accurate to the best of my knowledge, information, and belief. | |||
Paul Holmbeck 1 | Paul Holmbeck 1 | ||
Subscribed and sworn to before me this | Subscribed and sworn to before me this day of | ||
, 1983 Notary Public | |||
\\ | |||
A ls - p ,.ie | A ls - p,.ie h,t.m | ||
'y TESTIMONY OF PAUL HOLMBECK ON EMERCENCY PREPAREDNESS: | |||
h,t.m TESTIMONY OF PAUL HOLMBECK ON EMERCENCY PREPAREDNESS: | |||
DAARE/ SAFE CONTENTION 3 - ROCKFORD LWV CONTENTIONS 19 AND 108 Affiant states that he has read and is familiar with the documents attached hereto. | DAARE/ SAFE CONTENTION 3 - ROCKFORD LWV CONTENTIONS 19 AND 108 Affiant states that he has read and is familiar with the documents attached hereto. | ||
e e | |||
Q. Please state your name. | Q. | ||
A. My Name is Paul Holmbeck. | Please state your name. | ||
Q. What is the purpose of this testimony? | A. | ||
A. The purpose of this testimony is to present the nature and results of my investigation into the adaquacy of | My Name is Paul Holmbeck. | ||
[ | Q. | ||
(" Byron Station") in support of DeKalb Area Alliance for Responsible Energy /Sinnissippi Alliance for the Environ =ent | What is the purpose of this testimony? | ||
{ | A. | ||
Voters ("Rockford LWV") Contentions 19 and 108 all of which address emergency preparedness. | The purpose of this testimony is to present the nature and results of my investigation into the adaquacy of | ||
Q. What is your educational background? | [ | ||
A. My higher education background consists of two years of study at Duke University. 1979-81 | Emergency Plans for the Byron Nuclear Generating Station | ||
Durir4 this last academic year (1981-82), I studied development (third world) economics and political theory at the University of Kent in Canterbury, Ergland. While at Dund | / | ||
(" Byron Station") in support of DeKalb Area Alliance for Responsible Energy /Sinnissippi Alliance for the Environ =ent k! | |||
r | |||
{ | |||
"\\"' | |||
("DAARE/ SAFE") Contention 3 and Rockford League of Women Voters ("Rockford LWV") Contentions 19 and 108 all of which address emergency preparedness. | |||
Q. | |||
What is your educational background? | |||
A. | |||
My higher education background consists of two years of study at Duke University. 1979-81 during which I studied primarily political science and economics. | |||
Durir4 this last academic year (1981-82), I studied development (third world) economics and political theory at the University of Kent in Canterbury, Ergland. | |||
While at Dund I was on the Dean's List during 1980 and again in 1981 and received Class Honors during 1981. | |||
My most | |||
) | |||
1 notnble work was a dissertation prepared at the University of Kent between April and July, 1982, on Dependency | |||
) | |||
Since 1980, I have also been trained in wi'1derness | Theories of Development. | ||
I am presently on a year's leave of absence from Duke. | |||
Wilderness Initiatives at Duke maintains rescue and evacuation procedures. | Since 1980, I have also been trained in wi'1derness emergency procedures concurrent with my role as a rock climbing and backpacking instructor. | ||
Fashioned and originally trained by North Carolina Outward Bound, Wilderness Initiatives at Duke maintains rescue and evacuation procedures. | |||
Those procedures include accident assessment by the instructor in the field, emergency communications and guidelines for the content of those communications; evacuation procedures including emergency transportation and protocols for calling in additional support from local rescue squads. | |||
I have contributed to the revision of these procedures and the developing of more effective and comprehensive exercises. | |||
Emergency operations in the wilderness also require flexibility to deal with changing condition of the victi= | Emergency operations in the wilderness also require flexibility to deal with changing condition of the victi= | ||
and varying environmental factors, (e.g., weather and 4 | |||
land characteristics). | |||
Careful calculations must be made as to the feasibility of evacuation and the costs and benefits gained from delayed evacuation of injured persons. | |||
I have also had the experience of coordinating a search and rescue exercise in North Carolina's Pisgah National Forest involving almost 100 emergency workers. | I have also had the experience of coordinating a search and rescue exercise in North Carolina's Pisgah National Forest involving almost 100 emergency workers. | ||
Search and rescue operations reguire special attention i | Search and rescue operations reguire special attention i | ||
w | w | ||
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e-w. | |||
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l e, | |||
to coordination and communications. | |||
Selecting the area over which the emergency response is to be carried out | |||
) | |||
includes the use of sectoring, routing of response groups and, of course, assuring the safety of emergency personnel. | |||
e | e | ||
~ | |||
e | e j | ||
i | |||
) | |||
l | l | ||
7 | 7 | ||
,e Q. | |||
Are ycu familiar with the term " protective cetion"? | |||
A. Yes, I am. A protective action or protective measure is | A. | ||
Yes, I am. | |||
any action taken to avoid er minimize the projected dose resulting from a release of radioactivity. Protective actions for the Byron Station include evacuationt | A protective action or protective measure is | ||
a | } | ||
following documents: | any action taken to avoid er minimize the projected dose resulting from a release of radioactivity. | ||
Protective l'f{I actions for the Byron Station include evacuationt I | |||
sheltering: access controls and food, water, and milk i((, | |||
a e | |||
control. | |||
Protective actions are described in the - | |||
following documents: | |||
EPA-520, 1-75-001 " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," | EPA-520, 1-75-001 " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," | ||
(" EPA-PAGs"): NUREG 0396-EPA, 520/1-78-016 " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants " and the International Atomic Energy Agency " Planning for Off-site Response to i | (" EPA-PAGs"): NUREG 0396-EPA, 520/1-78-016 " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants " and the International Atomic Energy Agency " Planning for Off-site Response to i | ||
| Line 117: | Line 173: | ||
("IAEA-planning"). | ("IAEA-planning"). | ||
I have read and am familiar with these documents. | I have read and am familiar with these documents. | ||
Q. Do you know what is meant by " sheltering" pursuant to the Illinois Plan for Radiological Accidents, ' Byron,' | Q. | ||
Do you know what is meant by " sheltering" pursuant to the Illinois Plan for Radiological Accidents, ' Byron,' | |||
I Volume VI, Preli=inary Revision O ('IPRA-Byron, Revision 0")? | I Volume VI, Preli=inary Revision O ('IPRA-Byron, Revision 0")? | ||
A. Yes, I do. Sheltering essentially means placing as much of a buffer between oneself and the plume of radioactive material as one can without leaving the affected area. | A. | ||
Yes, I do. | |||
Sheltering essentially means placing as much of a buffer between oneself and the plume of radioactive material as one can without leaving the affected area. | |||
<( - | |||
The degree of dose reduction afforded will be determined by the type of building in which shelter is sought, e.g., | The degree of dose reduction afforded will be determined by the type of building in which shelter is sought, e.g., | ||
by the construction materials used in the building and by the number of floors or walls between the plume and | by the construction materials used in the building and by the number of floors or walls between the plume and | ||
~ | |||
the paople cooking chaltar; cnd by the extent to which ventilation can be restricted in the building. | the paople cooking chaltar; cnd by the extent to which ventilation can be restricted in the building. | ||
Q. What must be done to translate this data into deter =ina-tions as to the value of sheltering as a protective measure? | Q. | ||
A. According to the EPA-PAGs and IAEA-Planning, the infor-mation on the proposed structures can be used to approxi-mate values'for the dose reduction through sheltering. | What must be done to translate this data into deter =ina-tions as to the value of sheltering as a protective measure? | ||
These approximate values are termed ' shielding factors' or ' reduction factors.' | A. | ||
Q. Have you gathered any data relevant to the determination of the adequacy of sheltering as a prescribed protective action?for p rt % a o Me | According to the EPA-PAGs and IAEA-Planning, the infor-mation on the proposed structures can be used to approxi-mate values'for the dose reduction through sheltering. | ||
A. Yes, I have. Directors, administrators, or superintendents at the following facilities have indicated to me that their buildings have no basement or windowless areas which could be used for sheltering their populations: | These approximate values are termed ' shielding factors' or ' reduction factors.' | ||
Explanitory portions of IAEA-Planning are attached to this Affidavit as Exhibit A. | |||
pJ nW popul +1on: | Q. | ||
Have you gathered any data relevant to the determination of the adequacy of sheltering as a prescribed protective O<m EE3! | |||
action?for p rt % a o Me A. | |||
Morris - Populawion | Yes, I have. | ||
3 | Directors, administrators, or superintendents at the following facilities have indicated to me that their buildings have no basement or windowless areas which could be used for sheltering their populations: | ||
1. | |||
T. | |||
Partial | White Pines Manor Nursing Home Oregon -pJ nW popul +1on: | ||
55 patients, 15 st (Bowes Affidav | |||
: p. 7). | |||
2. | |||
The Pinecres Manor Home or the Aging in Mt. | |||
} | |||
rv Morris - Populawion 112 patients, 40 staff (Montel Affidavi, | |||
9). | |||
3 The Oregon Annex High ool - population: | |||
80 Q A- | |||
: students, staff (la b A | |||
' davit, p. 6). | |||
rhM 4. | |||
The Og County Trainable Cen in Mt. Morris - | |||
pop ation: | |||
40 students, 17 staff. | |||
Partial | |||
) | |||
sement. | |||
(Id). | |||
5 Mt. Morric Elementary School - population: | |||
students, 26 staff (Turner Affidavit, p. 10). | 343 7 k students, 26 staff (Turner Affidavit, p. 10). | ||
6. | |||
Mt. Morris Junior High School - population: | |||
f 7 | 189 pl d students, 16 staff ( H ). | ||
f 7 | |||
I | Mt. Morris Senior High School - population: | ||
9 | 235 students, 25 staff ( H). | ||
e I | |||
8. | |||
iver Community Scho W ulation: | |||
Meridian Junior High School - population: | 413 stud sa (Mel mey affidavit, p. 10). | ||
9 Lorado Taft Field Campus - population 90 to 150 students, 30 staff (Interview with John Sanders, facility manager, Turesday, February 8, 1983). | |||
I students | k 10. | ||
Village of Progress - population: | |||
population: | 100 students, N | ||
The following camps and recreational areas host | 16 staff (Interviews with Robert Glazer, Executive Director, February 9 and February 17, 1983). | ||
transient populations which have no basement or windowless areas available to them: | 11. | ||
Byron Mary Morgan School - population: | |||
388 students 43 staff (Survey responses from Super-intendent Bill Brown, January 1983). | |||
12. | |||
Stillman Valley High School - population: | |||
462 students, 33 staff (Miller Affidavit, p. 10). | |||
13 Meridian Junior High School - population: | |||
341 | |||
) | |||
I students 20 staff ( g). | |||
fu 14. | |||
Highland Grade School and Early Childhood - | |||
population: | |||
417 students 20 staff ( g). | |||
The following camps and recreational areas host transient populations which have no basement or windowless areas available to them: | |||
) | |||
f f- | f f-Q 1. | ||
The Byron Dragway - population: | |||
500 to 1500 persons on weekends: 12,000 maximum. | |||
4060 to 5000 maximum reached three times per year. No Sheltering available. | No shelter whatsoever. | ||
with Connie Jeffry, December, 1982). | (Phone interview with Brenda VanHollen December, 1982: interview with owner Ron Leek cited in Byron FSAR 2.13 4.:) | ||
3 | 2. | ||
Grant Afflerbaugh, February 4, 1983 | Lake Louise - population: 2000 to 3000 persons: | ||
attached from Mr. Afflerbaugh, dated February 8, 1983, as Exhibit $$). | 4060 to 5000 maximum reached three times per year. | ||
No Sheltering available. | |||
(Intervievis with site Superintendent Roy Hayes January 14, January 26 | (Phone interview with Connie Jeffry, December, 1982). | ||
5 | 3 Castle Rock State Park - population: | ||
100 to 150 campers. Tents used as shelters; wooden buildir.gs, no basement. | up to 400 persons on weekends. | ||
House, office and barn in park. | |||
No sheltering facilities. | (Interview with site Superintendent. | ||
Grant Afflerbaugh, {{letter dated|date=February 4, 1983|text=February 4, 1983 letter}} attached from Mr. Afflerbaugh, dated February 8, 1983, as Exhibit $$). | |||
4. | |||
Lowden Memorial State Park - population: | |||
450 overnight ca=pers. | |||
Sheltering in vehicles only. | |||
(Intervievis with site Superintendent Roy Hayes January 14, January 26 and February 3, 1983). | |||
5 Camp McCormick Girl Scout ca=p - population: | |||
100 to 150 campers. | |||
Tents used as shelters; wooden buildir.gs, no basement. | |||
(Interviews with Director, Ruth Little, January 13 and February 4, 1983.) | |||
6. | |||
Oregon Park District - population: | |||
500 visitors. | |||
No sheltering facilities. | |||
(Phone interview with Tony Kubat January, 1983.) | |||
) | |||
7 Camp Em=aus - population: | |||
60 to 80 visitors | |||
3 maximum of 130 reached two wacks per year. | |||
} | |||
(Phone interview, December, 1982.) | (Phone interview, December, 1982.) | ||
S, | S, | ||
* 8. Lake LaDonna - population: | * 8. | ||
9 | Lake LaDonna - population: | ||
800 persons staying in tents or campers. | 1000 to 1600 visitors; as many as 3000 on holidays. | ||
(Phone interview with Lemont Gaston, February, 1983.) | |||
9 River Road Camping and Marina - population: | |||
800 persons staying in tents or campers. | |||
(Phone interview with owner, January, 1983.) | |||
10. | |||
Motosport Park - population: | |||
2000 spectators; 10,000 spectators twice per year. | |||
No shelters. | |||
(Phone interview with Joseph Vincer, December, 1982.) | (Phone interview with Joseph Vincer, December, 1982.) | ||
Q. Have you translated this data into reduction factors as explained earlier? | Q. | ||
A. Yes. After discussions with facility owners identified in the last question and administrators | Have you translated this data into reduction factors as explained earlier? | ||
\ | A. | ||
Yes. | |||
After discussions with facility owners identified in the last question and administrators I have generally located those facilities on the tables provided in IAEA-Planning on Representative Reduction Factors for Deposited Radioactivity (Table 1 in Appendix I, p. 49a, IAEA-Planning and Representative Reduction Factors for Cloud Source (Table 2 Id.). | |||
I have attached these tables tc this Affidavit as Exhibits B and C respectively Table II assigns a reduction factor of 1.0 from cloud source radioactivity to those populations which are outside or in vehicles (Exhibit C). | |||
In the Byron EPZ (3 mile radius), this would include thousands of persons at the Byron Dragway, the Motosport Park, the River Road h | |||
Camping and Marina. Lake Louise Castle Rock State Park, Lowden State Park, the Oregon Park District, and Lake | |||
\\ | |||
l | l | ||
y LaDonna have similar sheltering potential end are located in the Byron Station EPZ. The reduction factor for de- | y LaDonna have similar sheltering potential end are located in the Byron Station EPZ. | ||
The reduction factor for de-g | |||
posited radioactivity for these populations would range between 0 5 (vehicles) to 0 7 (outside) . | } | ||
According to IAEA figures, wood frame structures 1 | posited radioactivity for these populations would range between 0 5 (vehicles) to 0 7 (outside). | ||
E=maus, Lorado Taft Field Campus, and a number of other recreational structures and private homes are facilities of this nature. | (Exhibit B.) | ||
Knowledge that sheltering of at least 2908 school children will take place in structures without basements or windowless areas (listed above) will also be of imper-tance in determining the value of sheltering as a pro-tective action. As seen in Table 1, the reduction factor for deposited radioactivity is far superior in buildin6s with basements (0.03) than without (0.2), and in Table 2 the cloud source reduction factor for masonry structures without basements is about 0.6 while those with base-ments have a more favorable reduction factor of 0.4. | According to IAEA figures, wood frame structures 1 | ||
without basements have poor cloud source reduction facters (0 9) and moderate deposited radioactivity reduction factors (0.4). | |||
Camp McCormick Girl Scout Camp. Camp E=maus, Lorado Taft Field Campus, and a number of other recreational structures and private homes are facilities of this nature. | |||
Knowledge that sheltering of at least 2908 school children will take place in structures without basements or windowless areas (listed above) will also be of imper-tance in determining the value of sheltering as a pro-tective action. | |||
As seen in Table 1, the reduction factor for deposited radioactivity is far superior in buildin6s with basements (0.03) than without (0.2), and in Table 2 the cloud source reduction factor for masonry structures without basements is about 0.6 while those with base-ments have a more favorable reduction factor of 0.4. | |||
(Exhibits B and C, respectively) | (Exhibits B and C, respectively) | ||
Q. ave you made similar inquiries re5arding sheltering h | Q. | ||
poten 'al for the less-mobile populations in nursing | ave you made similar inquiries re5arding sheltering h | ||
poten 'al for the less-mobile populations in nursing rt.Dv" N | |||
homes? | homes? | ||
\\ | |||
A. Yes, I have. I have | A. | ||
Yes, I have. | |||
PAGs and the IAEA (Id.) | I have "stributed excerpts from the EPA-PAGs and the IAEA (Id.) | ||
- sheltering to nursin6 | |||
~ | |||
home administrators Thomas Bowes and r-x,Montel. | |||
_ s r | |||
) | |||
~ | |||
During | During onversationsinDecembmroflastyearan[the first two no ths of this year, they have exp ssed concern | ||
} | |||
about the feasib lity of sheltering. | \\ | ||
Both Mr. Montel and Mr. Bowes a e/ aware that ve' | about the feasib lity of sheltering. | ||
N *ther facility V | |||
can be restricted by turni | has basement or win wless areas in Ahich to shelter. | ||
r Both Mr. Montel and Mr. Bowes a e/ aware that ve'ntilatio N | |||
\\ | |||
till f' eel that, due to a rapid | can be restricted by turni off kitchen fans and shutting ! | ||
/ | |||
all particularly | ? | ||
tant consider | \\ | ||
doors and windows. | |||
N Q. Is there any consideration given in IPRA-Byron, Revision 0,l to administering potassium iodide to persons for whom a | They till f' eel that, due to a rapid l | ||
estrictiono\\ | |||
f ventilation would natural ventilation, | |||
\\ | |||
have to be engine ed. | |||
These are all particularly impor-t.%vacuation i | |||
tant consider ions in light of the fact t for a s e percentage of nursing home patien has been own to be infeasible (Affidavits of Bowes an s y | |||
M tel). | |||
N Q. | |||
Is there any consideration given in IPRA-Byron, Revision 0,l to administering potassium iodide to persons for whom a | |||
{, | |||
timely evacuation is not possible? | timely evacuation is not possible? | ||
A. No, there is not. | A. | ||
Q. According to Commonwealth Edison's Generic Generating Stations E=ergency Plan ("GSEP"), what document will be used as a basis for recommendations to off-site authorities for protective actions for the off-site public? | No, there is not. | ||
Q. | |||
According to Commonwealth Edison's Generic Generating Stations E=ergency Plan ("GSEP"), what document will be used as a basis for recommendations to off-site authorities for protective actions for the off-site public? | |||
k A. | |||
Section 6 3 1 of the GSEP states that the EPA report i | |||
EPA-520/1-75-001, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" (" EPA-PAGs"), | |||
will be used for this purpose. | will be used for this purpose. | ||
Q. According to NUREG 0654 FEMA Report 1. Revision 1, what document is to be used as a guideline for state and local authorities in establishing the capability for implement-ing protective measures including sheltering? | Q. | ||
According to NUREG 0654 FEMA Report 1. Revision 1, what document is to be used as a guideline for state and local authorities in establishing the capability for implement-ing protective measures including sheltering? | |||
/ | |||
s 1 | |||
A. | |||
Saction II.J.9 cf NUREG 0654 calls for ccmpliance with | |||
.k | |||
} | |||
EPA-520/1-75-001, PAGs. | |||
,,s Q. | |||
According to the EPA-PAGs, what are the prerequisites fcr a proper choice between sheltering and other protective measures? | |||
~. | |||
A. | |||
Planning. | |||
Planning is described in the EPA-PAGs as the gathering of information needed to select the optimum alternative in an immediate response (at 1.2). | |||
This will include an analysis of local conditions and constraints and any other factors necessary to determine the viability of each protective action (1.2-1 3). | |||
For sheltering this implies an assessment of the availability of shelterir areas as well as their shielding effectiveness and air changes per hour. | |||
s Q. | |||
Have you found any evidence that Com=onwealth Edison | |||
(" CECO") or IESDA planners have done the necessary site-specific investigation into the feasibility of sheltering as a protective action? | (" CECO") or IESDA planners have done the necessary site-specific investigation into the feasibility of sheltering as a protective action? | ||
A. No, I have not. Despite the fact that both the Applicant's GSEP (at 6 31) and Byron Annex to that plan include | A. | ||
sheltering as among the protective measures it could | No, I have not. | ||
recommend to off-site authorities in the event of an emergency, the Applicant has, to my knowledge, made no attempt to study the protective value of sheltering for | Despite the fact that both the Applicant's GSEP (at 6 31) and Byron Annex to that plan include sheltering as among the protective measures it could I{ | ||
recommend to off-site authorities in the event of an emergency, the Applicant has, to my knowledge, made no attempt to study the protective value of sheltering for I | |||
populations around the Byron plant. | |||
I have interviewed school officials, park rangers, nursing home administra-tors, and other special facility representatives and have h | |||
yet to hear of a single attempt by planners to investi6 ate i | |||
the availability of suitable sheltering facilities. | the availability of suitable sheltering facilities. | ||
va | va 3 | ||
Stats plannars htva been equally nsgligent. | |||
Volume 1 of the IPRA and the Byron volume of that plan indicate a range of protective actions which include sheltering (IPRA-Byron, Revision 0, VI (2), pp.11-12), but in my discussions and interviews I have found no indication that state planners have made the necessary determination of e | |||
I | |||
~ | |||
dose reductions possible through sheltering. | dose reductions possible through sheltering. | ||
Bowes (p. 6-7), Miller (p. 10), Turner (p. 10), Maloney (p. 10), and Lamb (p. 6). | My findings are further supported by Affidavits of Montel (p.2), | ||
Q. oes the IPRA-Byron, Revision 0, make provisions for | } | ||
pe | Bowes (p. 6-7), Miller (p. 10), Turner (p. 10), Maloney (p. 10), and Lamb (p. 6). | ||
Q. | |||
oes the IPRA-Byron, Revision 0, make provisions for D | |||
impaired due to such factors as institutional or other confinementas\ | U# | ||
pe ons without vehicles or those unable to transport pL D' | |||
thems ves in the event of an evacuation? | |||
2-4 A. | |||
No. | |||
The PRA-Byron, Revision 0, does not include means for protecting those persons whose mobility may be | |||
} | |||
impaired due to such factors as institutional or other confinementas\\ | |||
developed in NUREG 0654 II.J.10.d and | |||
\\ | |||
required by 10 CFR 50.47 (b) (10), which stipulates that 4 | |||
a range of protectiv\\ | |||
e' actions must be developed for the | |||
\\ | |||
plume exposure pathway EPZ for the public. | plume exposure pathway EPZ for the public. | ||
\\ | |||
The IPRA-Byron, Revision 0, designates school | The IPRA-Byron, Revision 0, designates school | ||
\\ | |||
buses, the Oregon police, and the Oregon Ambulance Service to evacuate those persons who do not have adequate or readily available transportation \.. IPRA-Byron, Revision 0, VI (2), pp. 124, 148, 164, 188, 208. 224: VI (2a), p. 27: | buses, the Oregon police, and the Oregon Ambulance Service to evacuate those persons who do not have adequate or readily available transportation \\.. IPRA-Byron, Revision 0, VI (2), pp. 124, 148, 164, 188, 208. 224: VI (2a), p. 27: | ||
( 2c ) , p . 19 : (2d ) , p . 17 | \\ | ||
( 2c ), p. 19 : (2d ), p. 17 (2e), p. 30s-(2f), p. 19: | |||
(2e), p. 30s-(2f), p. 19: | N VI (3), p. 3 | ||
N VI (3), p. 3 | '\\ | ||
) | |||
I. During an evacuation the use of schael buses as | \\ | ||
I. | |||
During an evacuation the use of schael buses as | |||
\\ | |||
vehicles for evacuation of the general public | vehicles for evacuation of the general public | ||
ca | ca 1 | ||
with ut transportation is incapable of affording i | |||
A. hrough interviews with School Super-i tendents Miller, Turner, and Maloney during February, 1983, and Ogle County | } | ||
m prom t and timely evacuation of that population. | |||
I | A. | ||
Assistant Superintendent Charles Hayes during\ sthe week of January 17, 1983, I | hrough interviews with School Super-i tendents Miller, Turner, and Maloney during February, 1983, and Ogle County | ||
of this t'estimony, that the number of school buses owned and operated by school districts are inadequate to effect a timely evac ation of schools in the EPZ. | \\ | ||
B. There are no posted school bus stops or routes and there.is no plan or provision to inform the public as to where they are to Coyreg3Te:15T t .._.'. . IFRA-BSTon, Revision O. VI (3),'p. 3 " Populations | I Assistant Superintendent Charles Hayes during\\ | ||
sthe week of January 17, 1983, I ermined, dalbitId(p ti en have d of this t'estimony, that the number of school buses owned and operated by school districts are inadequate to effect a timely evac ation of schools in the EPZ. | |||
B. | |||
There are no posted school bus stops or routes and there.is no plan or provision to inform the public as to where they are to Coyreg3Te:15T t.._.'.. | |||
IFRA-BSTon, Revision O. VI (3),'p. 3 | |||
" Populations | |||
\\ | |||
with Special Transport,ation Requirements." | with Special Transport,ation Requirements." | ||
5 The entire Sheltering Guide VI (3) | 5 The entire Sheltering Guide VI (3) | ||
\\ | |||
pp. 1-4, is attached to'$his Affidavit | pp. 1-4, is attached to'$his Affidavit | ||
\\ | |||
as Exhibit D. | as Exhibit D. | ||
C. School buses are considered unsafe for i | C. | ||
School buses are considered unsafe for i | |||
transportation of special facilities. | transportation of special facilities. | ||
\\ | |||
1) | |||
Interviews with Charles L,amb Director | |||
\\ | |||
of the Ogle County Educational Coop | of the Ogle County Educational Coop | ||
\\ | |||
during February.1983, indicated | during February.1983, indicated | ||
\\ | |||
that the students at the Mt.\. Morris a | that the students at the Mt.\\. Morris a | ||
r | \\ | ||
r Trainable Center cannot be safely evacuated in regular school bu\\ses. | |||
\\ | |||
i (Lamb Affidavit at 5) | i (Lamb Affidavit at 5) | ||
) | |||
indicated that he has a'pproximately | Interviews with Thomas Bowes, Administrator of the White Pines Nursing Home in Oregon,'during December,1982, and January,1983, indicated that he has a'pproximately c | ||
\\ | |||
15 persons for whom bus travel is unsa e. | 15 persons for whom bus travel is unsa e. | ||
(Bowes Affidavit at 4) 3) | |||
Inter i,ews with Gary Montel, | |||
\\ | |||
Administrator at Pinecrest Manor Home for the Aging during January | Administrator at Pinecrest Manor Home for the Aging during January | ||
\\ | |||
and Februar.y, 1983, indicated that | and Februar.y, 1983, indicated that | ||
-s bus travel would endanger the health | |||
\\. | |||
and safety of | and safety of thirty to forty s | ||
persons at his facility. | |||
(Montel i | |||
Affidavit at 6) '- | Affidavit at 6) '- | ||
? | |||
II. IPRA-Byron, Revision 0, plans {ortheevacuation | II. | ||
IPRA-Byron, Revision 0, plans {ortheevacuation | |||
\\ | |||
of homebound private residents are incapable of | of homebound private residents are incapable of | ||
\\ | |||
affording a prompt and timely evacuation of that | affording a prompt and timely evacuation of that | ||
\\ | |||
population. VI (3), pp. 2-3 | population. | ||
VI (3), pp. 2-3 (Exhibit D.) | |||
A. Lists of shut-ins are not available as stated at VI (3), pp. 2-3. \ \(Exhibit D.) | \\ | ||
A. | |||
3.) The CECO " polio list" is presently | Lists of shut-ins are not available as stated at VI (3), pp. 2-3. \\ (Exhibit D.) | ||
\\\\ | |||
3.) | |||
The CECO " polio list" is presently | |||
\\ | |||
kept in Dixon, too far (161. miles) | kept in Dixon, too far (161. miles) | ||
\\ | |||
away from the Ogle County EOC to be of timely use during an emer\gency. | away from the Ogle County EOC to be of timely use during an emer\\gency. | ||
\\ | |||
2) | |||
The plan claims that the Yellow h | |||
Bird Senior Citizens Center ma tains a list of shut-ins which is one | |||
g | g ssveral. lists for Ogle County. | ||
phone conversation with Jane Reid, D~ rector of the Yellow Bird Senior Citizens Center, dated F'ebruary 20, | phone conversation with Jane Reid, D~ rector of the Yellow Bird Senior Citizens Center, dated F'ebruary 20, | ||
\\ | |||
1983, revealed that the Yellow Bird I | 1983, revealed that the Yellow Bird I | ||
B. The IPRA-Byron, Revision 0, plan's reliance upon the Orego\n Police Department and the | Cente'r has the capability of com-piling \\ | ||
list for the Oregon area only. | |||
B. | |||
The IPRA-Byron, Revision 0, plan's reliance upon the Orego\\n Police Department and the | |||
\\ | |||
Oregon Ambulance Service for the trans- | Oregon Ambulance Service for the trans- | ||
\\. | |||
portation of nurs~ing home patients and homebound private \ residents is inadequate | portation of nurs~ing home patients and homebound private \\ residents is inadequate | ||
\\(E'hibit D.) | |||
and unworkable. | |||
x 1. | |||
Providing transportation to t e mobility impaired t | |||
is not a responsibility which is assigned to the Oregon Police Department or the. Oregon Ambulance | is not a responsibility which is assigned to the Oregon Police Department or the. Oregon Ambulance | ||
\\ | |||
Service in either the Oregon Participating Agencies su=maries, IPRA-Byron, Revision 0, | Service in either the Oregon Participating | ||
\\ | |||
Agencies su=maries, IPRA-Byron, Revision 0, | |||
VI (2) pp. 161-162, pp. 169-170, or the Annex 2c titled " Oregon Procedures" M (2c) | \\ | ||
VI (2) pp. 161-162, pp. 169-170, or the Annex 2c titled " Oregon Procedures" M (2c) | |||
: p. 13-16, | |||
\\ | |||
pp. 25-26; Figure G.2, e.l.cc, p. _97; the Oregon | pp. 25-26; Figure G.2, e.l.cc, p. _97; the Oregon | ||
\\ | |||
Agency Responsibility Matrix gives no' indication | Agency Responsibility Matrix gives no' indication | ||
\\ | |||
that transportation of homebound private residents | that transportation of homebound private residents | ||
\\ | |||
or nursing home patients will be provide'd by | or nursing home patients will be provide'd by | ||
\\ | |||
either the Oregon Police Department or the.0 regen Ambulance Service during evacuation. | either the Oregon Police Department or the.0 regen Ambulance Service during evacuation. | ||
I | IPRA-yron. | ||
I Revision 0, (2) pp.13-16,161-162; (2c)pp.\\25-26, 169-170, and Figure G.2, e.l.cc, p. 97 are | |||
v. | v. | ||
/4 t tached to this Affidavit es EY.hibits E F, | |||
an G, respectively. | |||
g 3. | |||
R. | The Oregon Police Department has five full-time and fo\\ur part-time officers with two squad cars charged ith the following responsibilities: | ||
~ | |||
no'ification, | R. | ||
i=ary responsibility for public | |||
control VI (2) p. 162. | \\ | ||
e no'ification, traffic and access t | |||
\\ | |||
control VI (2) p. 162. | |||
(Exhibit E. ) | |||
\\ | |||
b. | |||
standard operating procedures for law | |||
\\ | |||
enforcement and crime prevention | enforcement and crime prevention | ||
\\ | |||
activities VI (2c) p. 15 | activities VI (2c) p. 15 M. | ||
\\ | |||
c. | |||
provide transportation for shut-in | |||
\\ | |||
populationyfOgleCountyVI(3)p.3 (Exhibit D. ) | populationyfOgleCountyVI(3)p.3 (Exhibit D. ) | ||
3 | 3 The Oregon Ambulance Service has 20 volunteers and two ambulances and s charged with the i | ||
following responsibilitie's: | following responsibilitie's: | ||
R. assist Oregon Pol ce Department in | R. | ||
assist Oregon Pol ce Department in | |||
\\ | |||
notification of the.public, traffic and | notification of the.public, traffic and | ||
\\ | |||
access control if re' quested M (2c) | access control if re' quested M (2c) | ||
: p. 26. | : p. 26. | ||
(ExhibitF.)\\ | |||
\\ | |||
b. | |||
follow standard operati'ng procedures r | |||
for the fire prevention and emergency | for the fire prevention and emergency | ||
\\ | |||
medical services (Primary Agency M). | medical services (Primary Agency M). | ||
.\\ | |||
c. | |||
withlawenforcementVI(2)p\ | assist the Oregon Police Department withlawenforcementVI(2)p\\ | ||
97 (Lx.hibit G. ) | |||
\\ | |||
'\\ | |||
d. | |||
Provide transportation of both private residents and nursing home patie s in | |||
~ | |||
/' ~ | |||
t e EPZ who may not have adequate or readily available transportation VI (3) | t e EPZ who may not have adequate or Sg readily available transportation VI (3) | ||
: p. 3 (Exhibit D.) | |||
: p. 3 | 4. | ||
The nu=ber of mobility i= paired persons in the | |||
\\ | |||
EPZ for whom, according to the plan, the Oregon | EPZ for whom, according to the plan, the Oregon | ||
Police and the Oregon Ambulance Service must s | \\ | ||
provide transport, must be pieced together from various sources. | e Police and the Oregon Ambulance Service must s | ||
provide transport, must be pieced together from various sources. | |||
\\ | |||
population brings the figure to about | 1. | ||
There are thIree nursing homes in the | |||
's EPZ. | |||
Administrators of two of these facilities have indicated that abcut a third of their residents will require transport of greater sophistication than a regular bus (Affidavits of Montel, I | |||
pp. 4 and 6, and Bowes, pp. 2 and 4). | |||
This is a total of about 50. | |||
Adding one third of the other, nursing home's i | |||
population brings the figure to about 80. | |||
(A phone interview in January, | |||
\\ | |||
1983, indicated tha the Neighbors | 1983, indicated tha the Neighbors | ||
\\ | |||
Nursing Home in Byron had 94 residents.) | Nursing Home in Byron had 94 residents.) | ||
b. | |||
Jane Reid, the Director of the Yellow Bird Senior Citizens Center, s,tated in a {{letter dated|date=February 4, 1983|text=letter dated February 4, 1983}}, that her facility delivers meals to as many | |||
as 16 homebound persons each day 5.n Oregon alone. | \\ | ||
as 16 homebound persons each day 5.n Oregon alone. | |||
She also noted that 20-30 additional Oregon area elderly are pro- | |||
\\ | |||
vided with transportation to the center | |||
o n a daily basis. | o n a daily basis. | ||
These people have no 9) o her means of transportation. | |||
The le ter from Jane Reid is attached to this. affidavit as Exhibit H. | |||
JoycegAllen, R.N., | |||
of Allen Home Health c. | |||
\\ | |||
Agency,,Inc., responded to my inquiries | Agency,,Inc., responded to my inquiries | ||
\\ | |||
on the same day, February 4,1983 | on the same day, February 4,1983 She | ||
\\ | |||
reported that her agency cares for ten | reported that her agency cares for ten | ||
\\ | |||
patientsiptheEPZ,allofwhich i | patientsiptheEPZ,allofwhich i | ||
would require assistance. | would require assistance. | ||
The letter i | |||
from Ms. All'en is attached to this i | from Ms. All'en is attached to this i | ||
Affidavit as Exhibit I. | Affidavit as Exhibit I. | ||
\\ | |||
2. | |||
The Recional Health Survey (1978) by | |||
\\ | |||
Comprehensive Health Planning of North-i west Illinois, r.eported that 2 37, (497 persons in EPZ) of northwest Illinois residents have mobility limi- | Comprehensive Health Planning of North-i west Illinois, r.eported that 2 37, (497 persons in EPZ) of northwest Illinois residents have mobility limi- | ||
\\ | |||
tations. | tations. | ||
More significant is the 1.17 | |||
\\ | |||
who must either stay in bed all or most i | who must either stay in bed all or most i | ||
of the time or use a wheelchair or i | of the time or use a wheelchair or i | ||
walker in getting around Id. | walker in getting around Id. | ||
The table | |||
\\ | |||
from which this data is taken is attached i | from which this data is taken is attached i | ||
to this affidavit as Exhibit J. | to this affidavit as Exhibit J. | ||
Since | |||
\\ | |||
21.622 permanent residents live within | 21.622 permanent residents live within | ||
\\ | |||
the EPZ, approximately 238 are confined | the EPZ, approximately 238 are confined | ||
\\ | |||
to bed or home. | to bed or home. | ||
(Exhibit J.) | |||
\\ | |||
5 A member of the Oregon Ambulance Service Board | 5 A member of the Oregon Ambulance Service Board | ||
\\ | |||
) | |||
of Directors, Carl Swon, has indicated to me in interviews dated February 7, 14, 16 an 17 that | |||
/t o | |||
all f these tasks requested simultaneously would beyond the capabilities of the Oregon | |||
Ambulance \ Service. | -} | ||
Ambulance \\ Service. | |||
\\ | |||
A. | A. | ||
He as stated this in affidavit. | |||
He | b. | ||
The Oregon Mayor, Jim Barnes., who is | |||
~ | |||
N also an ambulance service member, read 5 | |||
s the Swon Affidavit on February 16 and | |||
concurred in Mr. Swon's assertions. | \\ | ||
concurred in Mr. Swon's assertions. | |||
\\ | |||
c. | |||
Mr. Swon indi'cated during those meetings i | |||
that about 4-6' ambulance service volun- | that about 4-6' ambulance service volun- | ||
\\ | |||
teers would remain,in the area to conduct emergency operations.,' Mr. Swon was not sure if he personally would stay or | teers would remain,in the area to conduct emergency operations.,' | ||
evacuate with his fa=ilh, | Mr. Swon was not sure if he personally would stay or ccY~ | ||
Q. Hav | evacuate with his fa=ilh, Q. | ||
or part-time personnel commented to you regarding the Q-availab | Hav otherpersonswithexperienceindealingwithvolunte5 | ||
Additionally, the willin\gness | ~ | ||
or part-time personnel commented to you regarding the Q-availab ty of these personnel during a radiological k | |||
nursing home and bus service personne'1. | M emergency? | ||
: p. 6.) | L A. | ||
Yes, individu s in key coordinating positions such as school superint ndents and ambulance service directors have indicated that they e unable to notify personnel when other employ =ent scatt'ars them throughout the county. | |||
Additionally, the willin\\gness of volunteer, part-time personnel to serve as emerg\\ency workers during a nuclear disaster at the Byron Station i not taken for granted by individuals with close personal knowledge of ambulance, | |||
\\ | |||
nursing home and bus service personne'1. | |||
(Affidavits of Bowes, p. 6 Miller, p. 6, Turner, pp 6-7, and | |||
: flaloney, | |||
: p. 6.) | |||
Others are certain that most volu er, part-time | |||
.1 personnel will no e available (Swon, p. 5: Lamb, p. 4). | |||
} | |||
Q. | |||
emergency planning effort in the Byron EP2. | Does the IPRA-Byron, Revision 0, rely on the availability of volunteer personnel? | ||
Fire Protection District and ambulance squad | /O A. | ||
ersonnel in Mt. Morris, Leaf River, Oregon an:1 Stillman Valley are entirely made up of volunteer | Yes. | ||
The contribution of volunteers to a number of essential emergency services, including notification of T-the public g ccess and traffic control, transport of the mobility impaired, emergency medical services, fire protection and law enforcement is the backbone of the emergency planning effort in the Byron EP2. | |||
Fire Protection District and ambulance squad ersonnel in Mt. Morris, Leaf River, Oregon an:1 Stillman Valley are entirely made up of volunteer | |||
\\ | |||
personnel: | personnel: | ||
-Or\\egon Fire Protection District (YPD) - | |||
24 v | 24 v nteers. | ||
VI (2), p. 315 | |||
\\ | |||
VI (2), p | -Oregon Kmbulance Service - 20 volunteers. | ||
VI (2), p 13 | |||
_) g j * * | |||
part-time volunteers. VI (2), p. 337 | -Mt. Morris FPD and Amburin~ce Squad - 28 | ||
\\ | |||
part-time volunteers. | |||
VI (2), p. 337 | |||
\\ | |||
-Leaf River FPD anti Ambulance Squad - 28 t | |||
30 part-time volunteers. VI (2), p. 323 B. Davis Junction. Holcomb and Linwood Fire Protec-tion Districts are entirely made | part-timevoluntee\\rs. | ||
VI (2), p. 328. | |||
\\ | |||
-Stillman Valley FPD and Ambulance Squad - | |||
30 part-time volunteers. | |||
VI (2), p. 323 B. | |||
Davis Junction. Holcomb and Linwood Fire Protec- | |||
\\ | |||
tion Districts are entirely made of volunteers. | |||
-Davis Junction FPD - 18 volunteers: | |||
\\ | |||
Holcomb and Linwood FPD - 42 volunteers. | Holcomb and Linwood FPD - 42 volunteers. | ||
VI (2), p. 345 | VI (2), p. 345 | ||
~ | |||
C. T | C. | ||
These nine il amen make up only 26f. (9 of 35) of the Byron F1 | T e are en2y nina full-time firamen in the g | ||
entire Z and these are all located in Byron. | |||
These nine il amen make up only 26f. (9 of 35) of the Byron F1 rotection Districts manpower. | |||
VI (2), p. 301. | VI (2), p. 301. | ||
D. | |||
Many part-time bus drivers have been volunteered or emergency work. | |||
Part-time bus drivers em oyed elsewhere will be difficult to contac in t e event of an emergency (Affidavits of Swon,\\p | |||
: 5. Miller, p. 6 Turner, pp. 6-7, Maloney, p. 6. Bowes, p. 6, and Lamb, p. 4). | |||
Of the school districts: | Of the school districts: | ||
-Oregon om= unity Unit (C.U.) #220 has 11 | |||
\\ | |||
part-time , bus drivers. VI (2), p. 309 | part-time, bus drivers. | ||
VI (2), p. 309 | |||
\\ | |||
-Mt. Morris | |||
.U. #261 has 11 part-time bus drivers. | |||
VI', 2), p. 339 | |||
-Leaf River C.F. #270 has 10 part-time bus drivers. | |||
VI (2, p. 333 (Interview February, 1983). | |||
-Meridian C.U. #223 has 29 part-time bus drivers. | |||
VI (2), p. 324. | |||
(Interview February, 1983). | |||
-Byron C.U. #226 has 15\\ bus drivers, seven | |||
\\ | |||
of which are teachers and available at | of which are teachers and available at | ||
\\ | |||
school and eight of which are part-time. | school and eight of which are part-time. | ||
VI (2), p. 307 Furthermore, many police personnel in the EPZ work on a part-time basis: | VI (2), p. 307 Furthermore, many police personnel in the EPZ work on a part-time basis: | ||
~ | |||
.L4 i | |||
e Mt. Morris Police D3partment employs 7 full time and 12 part-time employees. | |||
VI (2), | VI (2), | ||
343 | |||
-The Byron olice Department employs 8 full-time and 14 rt-time employees. | |||
VI (2), p. 303 g e | |||
s | |||
epartment employs 5 full-time and 4 part-time officers. | -The Oregon Police epartment employs 5 full-time and 4 part-time officers. | ||
VI (2), p. 317 | |||
%g | |||
Generally, the IPRA-Byron, Revision 0, fails to indicate the number of volunteer personnel who are necessary or available to perfor | -The Leaf River Police Dh artment had no resource summary. | ||
Generally, the IPRA-Byron, Revision 0, fails to indicate the number of volunteer personnel who are necessary or available to perfor the responsibilities assigned. | |||
The plans do not (1) assess the availability of volunteers during hours in which many are employed outsie the EPZ: | |||
(2) take into consideration inevitable personal conflicts in the responses of volunteers who have families in the EPZ: or (3) give consideration to the possibility that some volunteers who may perform well in non-nuclear disasters might refuse to participate in a nuclear dis-aster at the Byron Station. | (2) take into consideration inevitable personal conflicts in the responses of volunteers who have families in the EPZ: or (3) give consideration to the possibility that some volunteers who may perform well in non-nuclear disasters might refuse to participate in a nuclear dis-aster at the Byron Station. | ||
IESDA has failed to assemble data on. | IESDA has failed to assemble data on. | ||
to e=ergency notifications (2) the number of volunteers | (1) the work location of volunteers and time needed for their response i | ||
to e=ergency notifications (2) the number of volunteers | |||
-~-' | |||
with families in the EPZ: and (3) the number of volunteers who would refuse to respond at all to nuclear emergencies. | with families in the EPZ: and (3) the number of volunteers who would refuse to respond at all to nuclear emergencies. | ||
This data as noted by the Atomic Safety and Licensing Board in Zimmer | This data as noted by the Atomic Safety and Licensing Board in Zimmer Docket No. 50-358-06, June 21. 1982 | ||
g | g | ||
+. | |||
woulc} #indicats tha nasd to racruit additional parsonnel | woulc} #indicats tha nasd to racruit additional parsonnel | ||
/u; to provide adequate response on a 24-hour basis and give | |||
/ | |||
ocme assurances that assigned volunteers could and would - | ocme assurances that assigned volunteers could and would - | ||
h in fact - respond when needed. | h in fact - respond when needed. | ||
~ | |||
? | |||
, -, e-enP-aw= | |||
em | em | ||
. M e 8 MMW* | |||
9 | 9 | ||
-r' Q. | |||
Q. /re you faniliar with the nunber of eduentionc1 facilitier | /re you faniliar with the nunber of eduentionc1 facilitier | ||
) | |||
ituated within the plune exposure pathway of the enercene;. | |||
p1 nninc zone? | p1 nninc zone? | ||
A. Yes. The plume exposure pr.thway of the enercen.:y planninc , | A. | ||
Yes. | |||
The plume exposure pr.thway of the enercen.:y planninc, | |||
zone 'ncludes 19 elenentary, secondary, special: education 7 | zone 'ncludes 19 elenentary, secondary, special: education 7 | ||
co lece fSeilities. | |||
Q. Mave y:u investicat?d the adequacy of evc:aatier f_ans for the scho:Is referred te in the previcus ,uesti:nr? | d an Q. | ||
Mave y:u investicat?d the adequacy of evc:aatier f_ans for the scho:Is referred te in the previcus,uesti:nr? | |||
A. Yet, I have~. | \\ | ||
C. Har your investicetion allowed y:u t: | A. | ||
Yet, I have~. | |||
as to whether the resteetive scheci dirtricts .0:src73 & | C. | ||
sufficient nu .ber\of tures for a tinel ar.d crderi:- | Har your investicetion allowed y:u t: | ||
transportation of tt.eir students frcr the reh:01r t: | .t.ke conclusions | ||
\\ | |||
as to whether the resteetive scheci dirtricts.0:src73 & | |||
sufficient nu.ber\\of tures for a tinel ar.d crderi:- | |||
transportation of tt.eir students frcr the reh:01r t: | |||
O- | |||
\\ | |||
receivinc sites durir)g evacuation? | receivinc sites durir)g evacuation? | ||
\\ | |||
T A. | |||
Ccle County Educatienc1 Fervices | Yes. | ||
Assistant Surerir.ter. fen: | The school distri'ets possess no such rer:vr:er. | ||
Charles Hayes provided ..e | \\. | ||
Ccle County Educatienc1 Fervices Assistant Surerir.ter. fen: | |||
resources in an interview on\ | Charles Hayes provided | ||
..e d'ith a list of sch::1 tus | |||
Su.nerinten ents David Turner (Mt. Morris CO.nunity d | ( ]','~Lbv s | ||
Unit f 261), J. Michael "aloney (Leaf | ~- | ||
resources in an interview on\\ anuary 21, J | |||
199?. | |||
I have attached the list to this affi.avit as Exhitit E. | |||
i This list and subsecuent dir. cuss.ont with !:ho:1 | |||
\\ | |||
Su.nerinten ents David Turner (Mt. Morris CO.nunity d | |||
\\ui Unit f 261), J. Michael "aloney (Leaf River C:-.ur.ity | |||
\\s Unit #270), and David '' iller (Meridian Cor.nunity '.'r.it FZ:?' | |||
\\ | |||
\\ | |||
provided the following breakdown of stud r.t population and tus availability in the E?2 school di_tricts: | provided the following breakdown of stud r.t population and tus availability in the E?2 school di_tricts: | ||
esw | esw | ||
Number of | \\ | ||
Mt.'Xorris C.U. #261 | Number of Available Duses' School 31siciet Students Fuses Capacity Oregon C.U. *2 1,237 11 625 Meridian C.U. f22, 1,330 18 1,138 Byron C.U. #226 935 12 780 Mt.'Xorris C.U. #261 767 7 | ||
420 9 | |||
Leaf' River C.U. #270 41 7 | |||
O. | 462 Total 4,682 55 | ||
?,z25 | |||
-\\ | |||
O. | |||
How id school adninistrators respond to cuertione recard ' | |||
- ~ ~ | |||
ing th( feasibility of an evacuation durinc but trane-portation of children at the commencement or termination | ing th( feasibility of an evacuation durinc but trane-portation of children at the commencement or termination | ||
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of the school day? | of the school day? | ||
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A. | A. | ||
between those in transit and those 1ccated at each sch:o1 site. | (1.) | ||
(2.) The Mt. Morris Co..munity Unit f261, Meridian Community Unit f223 and Leaf River Com. unity Unit #272 school districts do not maintain the capatility to prc.;tly summon part-tine bus drivers who are empic ed elsewhere | School districts in the EFZ possess neither the cepability nor the nu=ber of buses necessary to afford 6-transportation for the evacuation of school children during such times of day. | ||
It has come to my attention that communication with school buses is insufficient or non-existent (affidavits of Miller, p. 5, and Maloney, N | |||
i pp. 5-6); and that multiple ' routes and trips will mean i | |||
that the school population will be widely dispersed between those in transit and those 1ccated at each sch:o1 site. | |||
(2.) | |||
The Mt. Morris Co..munity Unit f261, Meridian Community Unit f223 and Leaf River Com. unity Unit #272 school districts do not maintain the capatility to prc.;tly summon part-tine bus drivers who are empic ed elsewhere | |||
~, | |||
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a.g | |||
*mm. | |||
5 during the day (affidavits of Turner, Miller and Maloney). | |||
iD | iD The scho 1 superintendents have also asserted in intervie.:s | ||
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and in their affidavits that many bus drivers will not be available f r evacuation driving due to family; concerr.s. | and in their affidavits that many bus drivers will not be available f r evacuation driving due to family; concerr.s. | ||
5"I(,.b They have fu\rther stated that the number of bus drivers | 5"I(,.b They have fu\\ | ||
rther stated that the number of bus drivers | |||
i | \\ | ||
willingtopzr\cipatewilldeclinevitheachsuccessive | i willingtopzr\\cipatewilldeclinevitheachsuccessive 4 | ||
l trip (affidavits of Turner, pp. 6-7; Miller, p. 6; ar.f | l trip (affidavits of Turner, pp. 6-7; Miller, p. 6; ar.f and !:aloney, p. 6)\\ | ||
and !:aloney, p. 6)\ | (3.) | ||
(3.) | School superintendents have clearly stated in | ||
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i l | |||
that they have been denied en s.((,.b active role in er.erceney,iplanning. The su.r.erinterdents do not consider evacuatior. plans fer their facilities tc | interviews and affidavits that they have been denied en s.((,.b | ||
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active role in er.erceney,iplanning. | |||
The su.r.erinterdents do not consider evacuatior. plans fer their facilities tc | |||
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l be adequate or capable of implementati:n (cffidatits cf l | |||
Turr.er, ': iller and ?:aleney). | |||
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N 0 | |||
" hat, accordinc to IPEA-?yron,iRevision C, vill be the j | |||
etercency response rcle of the' Cele Ocur.ty Superir.ter. der. | |||
of Educational Services? | of Educational Services? | ||
A. The I?RA-Pyron, Revision 0, states thet the Ccle Cour.ty Superintendent of Educational Serv \'ces shall and dispatch bus resources from outside the effecte' | A. | ||
The I?RA-Pyron, Revision 0, states thet the Ccle Cour.ty Superintendent of Educational Serv \\'ces shall and dispatch bus resources from outside the effecte' osV' j | |||
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secter and fr:n outside the II. tc Feh ols and : t:<. c r | secter and fr:n outside the II. tc Feh ols and : t:<. c r | ||
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populatiens within the I??. which re.uire artistar.ee. | populatiens within the I??. which re.uire artistar.ee. | ||
I?R.'.-Eyron, Revision C, VI (3), p;. '? .\'; (I: :.i':it :} ; | I?R.'.-Eyron, Revision C, VI (3), p;. '?.\\'; (I: :.i':it :} ; | ||
i | i | ||
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l VI (2), p. 12/.; and a n:te at Fe: tion In the l | |||
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l Shelterir.c Guide are r.ttr.che? t0 this affid:vit as i | |||
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E.xhilit L. | E.xhilit L. | ||
I | I | ||
A7 C. In your investicatien Of the ade uccy of the 23F.:. :yron, h | A7 C. | ||
A. Yes, I w i 5': t | In your investicatien Of the ade uccy of the 23F.:. :yron, h | ||
(1.,% | Revision C, have you made any findincs relevr.nt to thir facet of the plan? | ||
A. | |||
Yes, I w i 5': t | |||
.make k. wn the f:ll;Yir.c: | |||
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have to be carried out by cor.mercial telephone lines | '. o u.. '. " | ||
(4.) 5.hool districts would te hard 7.e. esc' te evaru.-te sone sectors cf the ET7. even if | .e ".. e. i.. '. e...d a. r. '. v.- ".. '. | ||
W,f requirinc evacuati:n | have to be carried out by cor.mercial telephone lines as t'he putli: | ||
I | s r.otifie. | ||
d subject to overloa d (4.) | |||
5.hool districts would te hard 7.e. esc' te evaru.-te sone sectors cf the ET7. even if utual nid vere ta te rendered; e.g.- 'nd into the est or tcet/r;;t.. sert | |||
,.\\v'\\- | |||
W,f requirinc evacuati:n f Orecen an "t. | |||
" orris woul' d | |||
necessitate the evacuation of 959 school childrer. and abeat 400 institutionalir.ed trr.r.s :rta tion deper.d er.t persons rcre than the two school 64r.tricts carr;inc et: 7 M ':. | |||
I N | |||
n/. | n/. | ||
(5.) | (5.) | ||
Coordinat n he buc resources will require ad:'itienalgd>- | |||
i | i | ||
) | ) | ||
tine not accounted for i he CECO Evccuttion Time Esti.ates-k. | |||
Eyron. | Eyron. | ||
(6.) | (6.) | ||
the | 5.e cooperation of school superintendents outside | ||
High School, | \\ | ||
the E22 i not certain. | |||
i telephone conver | The Superintendent of Noche11e | ||
evacucting potentially | \\ L'.. v.- | ||
reported in a survey dated Janu ry 24, 199?, that he hv not been contacted by county or st | e High School, | ||
_ 12, Dr. Melvin Smith, stated to me in a | |||
(a.) The . perintendents of tvo Ccle C:unt" districtr outside the Ee. have esti=ated Ionc =ctili:stien tines. | \\ | ||
Dr. James Egan of | i telephone conver tion en February 4, 199?, that his district's buses wou - not be available for use in evacucting potentially aminatedareas.(Theodre Gapinski, Superintendent of restville Con. unity " nit F2M, | ||
two hours as necessary for mobilizati | reported in a survey dated Janu ry 24, 199?, that he hv not been contacted by county or st ECI. officials reccrdinctheEyronI..ercencyEesp:nseglan.[.A.632, s | ||
(b.) | (7.) | ||
Che ability of school districts outside the I?7 to assist in the transportation of students or the cenersi populace inside the E?2 is very licitad: | |||
on their willingness to enter a contaminated recien one or more times. | (a.) | ||
The. perintendents of tvo Ccle C:unt" districtr outside the Ee. have esti=ated Ionc =ctili:stien tines. | |||
b Dr. James Egan of ngs Consolidated Community l' nit y | |||
f144, stated in a sur y returned January 24, 199?, | |||
3 that one to two hours wo d be required to nobilize pernonnel sufficient to man | |||
.at district's availatle c wn, buses., In a survey returned Ja ary 24, 195?, The:d:re Gapinski of Forrestville Con: unity " nit #221, c i t e :' | |||
two hours as necessary for mobilizati of drivers. (EMJZ.) | |||
(b.) | |||
The availability of these bus drivers would depend h [# | |||
on their willingness to enter a contaminated recien | |||
) | |||
one or more times. | |||
s (c.) | s (c.) | ||
The distL os over which non-t'?Z school buses must travel will 1 it their ability to offer timely g | |||
: 3. lf 7 | |||
Q. Have | assistance in the tran port of I?2 school populations. | ||
Q. | |||
Have rovisions been made to evacuate those non-public (ow | |||
(1.) During t e weeks of January 3rd and February 7th, 1953, | \\without available transportation? | ||
school | |||
= | |||
% A. | |||
The schoo1 fac.ilities not incorporated as part of one g | |||
particular\\ chool district do not possess sufficient vehicles for timely and orderly evacuation. | |||
(1.) | |||
During t e weeks of January 3rd and February 7th, 1953, | |||
\\ | |||
I had two conversations with Jessie B. Hinkle, the Admin-istrative Director of the Oregon Day Care Center (OD00), | I had two conversations with Jessie B. Hinkle, the Admin-istrative Director of the Oregon Day Care Center (OD00), | ||
I have collected the | I have collected the ollowins information on that fceility: | ||
(a.) | (a.) | ||
The ODC0 has 42 students presently, but is | |||
licensed for and hhs previously utilized its capacity | \\ | ||
licensed for and hhs previously utilized its capacity | |||
The center has seven staff = enters, of which | \\ | ||
of 64 The center has seven staff = enters, of which | |||
\\ | |||
three to four are workihc at any one time. | three to four are workihc at any one time. | ||
(t.) | (t.) | ||
The OD00 owns no ve eles and has ne plan.- | |||
which would give staff access to any tus services | which would give staff access to any tus services | ||
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(c.) | during an energency. | ||
Stcff v icles, when available, are not sufficient to transpor nore than ten children. | |||
(c.) | |||
The OD"C serves families f on Cregon, Dixon and Mr. Morris. | |||
Parents are employed | |||
'n nany different areas around Osle County. | |||
If parer s' vehiclen are | |||
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.to be used to transport students during an exercency, so.e 4C-60 vehicles will begin arriving at or near the day care center. | |||
The CD00 is located on he corn =r of Second Etreet and East YashinCton Street (P.oute U } | |||
3 e | |||
d cc eral hundred foot fron the only eastern passece>:a" out f Oregon --- the 't.'ashington Street bridge. | |||
} | } | ||
_j (d.) | |||
There are no provisions in IIR/.-Syron, | |||
the Director of the Ccle Cour.ty Educctior.a1 Cooperative, a survey conplete | (* | ||
o r. t e =.~..=. '. u~ e n ~.~, | 0, for the notification or evacuation of Revisi the CDC. | ||
nunber of conversations with Charler 1a.-1, i | |||
(2.) | |||
Through the Director of the Ccle Cour.ty Educctior.a1 Cooperative, p. | |||
a survey conplete by Mr. Lanb, and the affidavit | |||
:.ich he | |||
'r. a.e su'...4.t*.c.'. | |||
o r. t e =.~..=. '. u~ e n ~.~,.. era. e '. r. a. c.e a...*.=.c..*.*..-'.., | |||
-~ | |||
is apparant that the OreCen J.nnex Figh Schoci in Oreccr. r.: | is apparant that the OreCen J.nnex Figh Schoci in Oreccr. r.: | ||
"orrir have vary the Ogle County Trainable Center in | |||
''t. | |||
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little he.e of self evncuati:r. (Lani r.ffidavit). | little he.e of self evncuati:r. (Lani r.ffidavit). | ||
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s | s timaly d ordorly Gvacuation la further hindered by the _] | ||
fact that he only route to the campus is also the only exit for ove 100 recreational vehicles and many more day visitors who fra uent Lowden State Park during the su==ertime. | |||
fact that | ~ | ||
4 (4.) | |||
su==ertime. | Through a survey d interviews (February 9th and f.s 17th, 1983) with Robert ser, director of the Village of Progress Inc., I have ascertained the following infer- | ||
4 (4.) | \\ | ||
of Progress Inc., I have ascertained the following infer- | mation on that facility's ability to self-evacuate. | ||
The | |||
mation on that facility's ability to self-evacuate. | \\ | ||
Village of Progress has about 10 students at the present time. | |||
The facility presently contracts with KAL Buslines Inc., for two buses, one ofN ich is available I | |||
Q. Hav | at the facility during the day. | ||
A. Yes, I have. W th input from Radiologist Dr. Celow Edwards and Dr. Jo n Hansen of Rockford, I adapted New York Public Interest | Q. | ||
Hav you investigated the availability of emergency medica facilities with trained staff, equipment, and written p tocols for responding to a radiological emergency at he Byron site? | |||
A. | |||
Yes, I have. | |||
W th input from Radiologist Dr. Celow Edwards and Dr. Jo n Hansen of Rockford, I adapted New b | |||
York Public Interest esearch Center ("NYPIRC") | |||
Radiological Emergency sponse Survey (developed by James L. Murphy MPH and Jo n E. Harriss MPH) to address the hospitals in the nine cou ty Regional Health Service Area of Northwestern Illinois. | |||
' ile the specifics of the survey were developed by those the Medical and public health professions, the para:e rs of the survey were determined by NUREG 0654 II (L and which address h | |||
the level of preparedness (in terms of equi | |||
.ent, training | |||
3x of p rsonnel and pre-establishsd protocols) required of 3 | |||
I also h | medica support facilities surrounding nuclear stations. | ||
Anthony Hospital 1 | I also h ed to determine from the survey the extent to which CECO and IESDA planners had assisted the hospitals surrounding the Byron Station in developing a compre-hensive regi,o al response plan. | ||
Hospitals were g nerally uncooperative. | A copy of the survey is attached to thi affidavit as Exhibit ff. | ||
The IHA, however, reco== ended th t the survey not be completed because .'.itigation invo | The survey was described by Dr. David Jeblonowski, ER Physician at St. | ||
The tabulated results of these surveys are | Anthony Hospital 1 Rockford as " thorough" and "a real eye-opener." | ||
Hospitals were g nerally uncooperative. | |||
In mid-December, I sent surve to all 15 hospitals in Illinois Region One which include all hospitals within 30 miles and some as far as 70 mil distant. | |||
Throughout January I made follow-up phone call, mailings and carried on a lengthly ca::paign to convine the Illinois Hospital Association (IHA) Survey Co==i tee to approve the survey. | |||
The IHA, however, reco== ended th t the survey not be completed because.'.itigation invo ing the hospitals could ensue. | |||
Despite this I receiv d four co :pleted surveys: | |||
from Rochelle Community Hos ital in Rochelle, Highland Hospital in Belvidere Sandwie Con = unity Hospi-tal in Sandwich, and Savanna City Hospita' in Savanna. | |||
The tabulated results of these surveys are resented in a table attached to this affidavit as Exhibi et. | |||
Of the respondents to my surveys | Of the respondents to my surveys | ||
---no hospital had staff training in the tr atment I | |||
of radiation injury and the decontaminatio of e | |||
~s s | |||
Patianto (though one nurse at hospital #2 had had 3 hours of hazardous materials trainin6 in an Jr course). | |||
---s if evaluations of staff preparedness to | |||
.ge a major radiological disaster (Imore than ma 5 | |||
5 vi tims) were "1" "3" and 2 "O's". | |||
---no hos ital reported having a decontamination | |||
: table, contamination showers or lead containers for dispo 1 of contaminated articles and only one has an solation room. | |||
---only two of e four has a radiation survey instrument. | |||
---three have writ n protocols for decontamination procedures but no e could claic to have practiced the procedures. | |||
While these respondents are approximat ly equal in size and possibley representative of the 12 | ---one of the four has protocol for dealing with a major radiological "saster (5 or = ore victics) but the plans have neve, been tested. | ||
One hospitals, the three Rockford Hospitals ha e received | ---self evaluations for fac ity preparedness for such a disaster (0-10 seal ) was two "O's" and two "2's." | ||
special attention. | ---none of the hospitals has eve been contacted by anyone from IESDA regarding the Byron E=ergency Response Plans and none are awar of any efforts to assign a support role to their acilities. | ||
While these respondents are approximat ly equal in size and possibley representative of the 12 | |||
. aller Region One hospitals, the three Rockford Hospitals ha e received j | |||
special attention. | |||
Throughout December, 1982, d | |||
3H J | 3H J | ||
uary, 1983 I cada attsspts to obtain information con rning the preparedness of these three hospitals via surve and interviews. | |||
Dr. Jeblonowski, Head Emergency Room phy ician at it. Anthony Hospital had completed the survey hen administrator Robert Flodin intervened. | |||
~ | |||
Likewise, Dr. | |||
eene at Rockford Memorial Hospital ("RMH") | eene at Rockford Memorial Hospital ("RMH") | ||
was essentially ooperative and discussed decontamination capabilities of th t facility with me during the week 6 | |||
of January 3 Admini trator William Dilts, however, did not see my inquirle regarding Radiological response capabilities as "any of ( | |||
was essentially | ) business." | ||
of January 3 | RMH is the f''' | ||
support medical facility des'gnated by CECO for the Byron | |||
of RMH preparedness is highly re | ( | ||
Keene and William Dilts indicated t | ~7 Station. | ||
Q. Have you investigated the availability of equipment and vehicles for transporting victims of a radiological accident to medical support facilities? | (GSEP Byron Annex BY 4-4). | ||
A. Yes, I have. | The present state s_,/ | ||
Q. Please describe how this investigation was carried out. | of RMH preparedness is highly re vent since both Dr. | ||
l | Keene and William Dilts indicated t me that there would be no enhancement of the RMH emergene facilities as a result of the letter of agreement with C o. | ||
Ambulance Medical Services" prepared by Comprehensive I | Q. | ||
Have you investigated the availability of equipment and vehicles for transporting victims of a radiological accident to medical support facilities? | |||
A. | |||
Yes, I have. | |||
Q. | |||
Please describe how this investigation was carried out. | |||
l A. | |||
Again, I adapted a NYPIRC survey to specifically address Ambulance medical services in the area surrounding the Byron Station. | |||
A copy of this survey is included with "Results of the Radiological Zmergency Response Survey: | |||
Ambulance Medical Services" prepared by Comprehensive I | |||
Health Planning of Northwest Illinois ("CHIPNI") which is | |||
33 attachcd to th2 offidavit of Joal Cowan. Executive Director as Exhibit B. I surveyed ambulance services | 33 attachcd to th2 offidavit of Joal Cowan. Executive Director as Exhibit B. | ||
December 22, 1982. Follow-up phone calls and visits were made during the weeks of January 3 and January 10 to encourage response. Roy Leslie received more than 20 calls from ambulance services about the survey and he, too, encouraged them to respond since he considered it to be a good exercise. | I surveyed ambulance services in the 9 counties of Northwestern Illinois since the Byron Station is just 7 miles from the center point of the region. | ||
In order to assure a timely collation of survey results, the study was terminated on January 31 and all raw questionaairs were given to Joel Cowen, Executive Director of CHPNI . | I obtained a comprehensive list of 72 ambulance services from Roy Leslie Emergency Medical Services Coordinator for Region 1 and mailed or hand delivered a copy of the survey to all 72 between December 20 and December 22, 1982. | ||
Q. What information did you obtain from the survey regarding the availability of equipment and vehicles for transport-ing victims of radiological accidents to medical support facilities? | Follow-up phone calls and visits were made during the weeks of January 3 and January 10 to encourage response. | ||
i | Roy Leslie received more than 20 calls from ambulance services about the survey and he, too, encouraged them to respond since he considered it to be a good exercise. | ||
Ambulance Medical Services" thoroughly evaluated these criteria from NUREc 0654 Chapter II, Section L. | In order to assure a timely collation of survey results, the study was terminated on January 31 and all raw questionaairs were given to Joel Cowen, Executive Director of CHPNI. | ||
I | Q. | ||
What information did you obtain from the survey regarding the availability of equipment and vehicles for transport-ing victims of radiological accidents to medical support facilities? | |||
i A. | |||
"Results of the Radiological Emergency Response Survey: | |||
Ambulance Medical Services" thoroughly evaluated these criteria from NUREc 0654 Chapter II, Section L. | |||
I refer to Cowen affidavit Exhibit B question 16 on page 9, questions 21-23 on page 10, and notes 8 and 9 on page 11. | |||
I The only EPZ ambulance service which did not respond to l | |||
( | ( | ||
l | l | ||
$f ' | |||
the survey was the Byron FPD. | the survey was the Byron FPD. | ||
I-2 hed=Esiva Tire Chief | |||
(BYA 4-4) as is requ | } | ||
Section B.9.Acco | Steve Walters on February 4 if his ambulances woul e | ||
Q. Did | used to transport contaminated individuals to supporting hospital. | ||
prepare .ess of a=bulance services to respond to a radiologic | He responded that he didn't | ||
A. Yes. A=ong other things, the survey results provide data N | . ov. | ||
.That hasn't been worked out yet." | |||
The on Fire Protection District is pamed in the Byro nnex to the CECO GSEP as g | |||
providing ambulance servi s for the Byron Station. | |||
(BYA 4-4) as is requ ed by NUREG 0654 Chapter II, Section B.9.Acco ing to IFRA-Byron, Revision 0, the Byron Fire otection District doesn't have any radiation survey instruments or protective equipment. | |||
IFRA-Byren, Rev ion O. Chapt. 2, p. 301, Byron Fire Protection strict Resource Summary is attached to this affidavit v v hibi t O -- | |||
ne Q. | |||
Did e survey address any other areas regardin6 the - | |||
prepare.ess of a=bulance services to respond to a radiologic emergency? | |||
A. | |||
Yes. | |||
A=ong other things, the survey results provide data N | |||
showing the inadequacy of training for ambulance Corps N | showing the inadequacy of training for ambulance Corps N | ||
members pursusant to'NUREG 0654, Chapt. 2. Section 0 and | members pursusant to'NUREG 0654, Chapt. 2. Section 0 and l | ||
\\ | |||
L. I refer to Cowen affidavit Exhibit B, questions 5-9 | L. | ||
I refer to Cowen affidavit Exhibit B, questions 5-9 N | |||
on pp. 6-7 and notes 1-5 on pp. 11-12. | |||
N The survey results indicate the almost total absence | N The survey results indicate the almost total absence | ||
\\ | |||
of protocols for responding to a' radiological accident | of protocols for responding to a' radiological accident | ||
\\ | |||
and no clearly defined roles for ambulance services, | and no clearly defined roles for ambulance services, | ||
\\ | |||
pursuant to NUREG 0654, Chapt. 2, Sections A and L. | pursuant to NUREG 0654, Chapt. 2, Sections A and L. | ||
refer here to Cowen affidavit Exhibit B, questions 14-19 | I Ns refer here to Cowen affidavit Exhibit B, questions 14-19 | ||
\\ | |||
) | |||
on pp. B-9 s | |||
g, Ac ording to IPRA, Volumo 1. Chapt.10 and IPRA-Byron, Rev*sion O. Chapt. 2, Section M, training is to | g, Ac ording to IPRA, Volumo 1. Chapt.10 and IPRA-Byron, Rev*sion O. Chapt. 2, Section M, training is to | ||
) | |||
be provided r personnel involved in emergency response functions. | |||
Accogding to IPRA-Byron, Revision 0 " Specific | |||
,t training for emer\\gency workers is performed oh a i | |||
continualbasisduring\\eplanningprocessakmunicipa th r | |||
ities in the EPZ of each nuclear power plant site in | ities in the EPZ of each nuclear power plant site in | ||
\\ | |||
Illinois." | Illinois." | ||
to ' Training Consideration' ( I (2), p. 381) attached to N | The page of IP | ||
this affidavit as Exhibit P. | -Byron, Revision 0, devoted to ' Training Consideration' ( I (2), p. 381) attached to N | ||
this affidavit as Exhibit P. | |||
from Volume I of IFRA which has yet'to be implemented | Thi's is clearly an excerpt | ||
in the Byron EPZ with regards to the ambulance services and the fire department rescue squads wh ch responded to | \\ | ||
the survey. | from Volume I of IFRA which has yet'to be implemented | ||
,' [f N | |||
in the Byron EPZ with regards to the ambulance services and the fire department rescue squads wh ch responded to | |||
A. Once the Ogl | \\ | ||
fled via Nucle | l the survey. | ||
f_- | |||
dependence on ec* ercial telephone:: and radio begins. | Q. | ||
Accordir,to the IFRA-Byron, Revision 0, how will primary response o anizations be notified? | |||
A. | |||
Once the Ogl County Sheriffs Teleco==unicator is noti-fled via Nucle Accident Reporting System ("NARS") the | |||
/ | |||
dependence on ec* ercial telephone:: and radio begins. | |||
C Both systems are sub'ect to overload. | |||
Carl Swon, Oregon Ambulance Servi Educatio..cl Director and employed for 20 years in telephone o==unication, expressed his opinion that the Fireband Fr uency is likely to over-load during an emergency evacua 'on. | |||
(Swon affidavit at 4). | |||
This frequency is used by very fire protection district and ambulance service (exce t Byron) in the EP2. | |||
The IFRA-Byron, Revision 0 'Commu " cations Network | The IFRA-Byron, Revision 0 'Commu " cations Network | ||
) | |||
Summary' VI (2) pages 277, 279, 281, 283 re attached to this affidavit as Exhibit Q. | |||
There are no ovisions | |||
gy m a | |||
Co==unic tions Network Summary' | t madoM th9 notifiention of Winnebago County officials and su officials are not included in the ' Radio D | ||
Emer, | \\ | ||
(Exhibit Q). | |||
Co==unic tions Network Summary' Emer, ncy notifications and communications with e | |||
carried out by' he Ogle County Superintendent of Educational Servi es must be by commercial telephone | local munic allties will be through commerciatl telephone | ||
lines. The Ogle C | ~ | ||
dependent on the integ | (VI (2), p. 9 All emergency communications to be f \\ | ||
Q. According to IPRA-Byron, Re ision 0, what co==unications systems will be relied upon | carried out by' he Ogle County Superintendent of Educational Servi es must be by commercial telephone lines. | ||
A. The IPRA-Byron, Revison 0, states | The Ogle C nty Superintendent has an on going role in coordinating transportation resources which is dependent on the integ ty of the local phone lines for hours after the pub 1'c is notified that a radio-logical accident has occu d. | ||
Q. | |||
According to IPRA-Byron, Re ision 0, what co==unications systems will be relied upon or mobilizing and main-taining communications with em rgency response personnel in the event of an accident at he Byron Station re-quiri.y their services for the i plementation of protective actions? | |||
A. | |||
The IPRA-Byron, Revison 0, states at communications between school ~ superintendents and f eld personnel will be =aintained by telephone or radio. | |||
o=mercial phone lines will be the only means by which s col superinten-dents Miller (Meridian C.U. #223), Turner (Mt. Morris C.U. #281) and Maloney (Leaf River C.U. #2 0) can notify bus drivers that they are needed for evacua on driving. | |||
(Affidavits of Miller, Turner and Maloney). | (Affidavits of Miller, Turner and Maloney). | ||
I | I It is suggerted at VI (2), p. 87 and 207 hat school superintendents David Miller and Michael caloney | ||
39 use | 39 use heir telephone or radio to comunicate with their | ||
} | |||
Maloney affidavit, | field personnel during emergency operations. | ||
Neither Mr. Miller nor Mr. Maloney have radios with which to com=un cate with his bus drivers (Miller affidavit, p. 5: | |||
Maloney \\ | |||
affidavit, p. 5). | |||
superintendent Turner of Mt. | |||
Morris C.U.'han radios for his buses but he is instructed (IPRA-Byron, Revision 0 VI (2), p. 223)nleave his base | Morris C.U.'han radios for his buses but he is instructed (IPRA-Byron, Revision 0 VI (2), p. 223)nleave his base | ||
\\ | |||
station and report to the Mt. Morris EOC. | station and report to the Mt. Morris EOC. | ||
According t | According t the ' Byron Superintendent of Schools Resource Summary'\\, uperintendent Bill Brown has three C.B. radios with which to com=unicate with his 15 buses. | ||
\\ | |||
VI (2), p. 307. | VI (2), p. 307. | ||
Continental Telepho,ne representative Charles Strand g | Continental Telepho,ne representative Charles Strand | ||
indicated to me in a February 7 phone conversation that | [p.7,, | ||
g indicated to me in a February 7 phone conversation that phone equipment is enginee\\red for average daily use. | |||
phone equipment is enginee\red | Use of capital outlays is an\\ efficient ' upper nineties.' | ||
Use of capital outlays is an\ efficient ' upper nineties.' | The IFRA-Byron, Revision 0, ha\\s no contingency plans | ||
The IFRA-Byron, Revision 0, ha\s | \\ | ||
in the event of an overload of telephone lines. | |||
telephone | \\ | ||
Q. | |||
Q. Are there guidelines for radiological emergency response N | Are there guidelines for radiological emergency response N | ||
plans in NUREG 0654 which concern planning outside of the EPZ? | plans in NUREG 0654 which concern planning outside of the EPZ? | ||
\\ | |||
A. Yes. Protective measures to be used for the ingestien | A. | ||
Yes. | |||
pathway are described, as are guidelines for the sitin6 and organization of host facilities. NUREG 0654 also recognizes (persuant to planning bases in 0396) that | Protective measures to be used for the ingestien | ||
\\ | |||
pathway are described, as are guidelines for the sitin6 and organization of host facilities. | |||
NUREG 0654 also recognizes (persuant to planning bases in 0396) that | |||
\\ | |||
one out of the four primary reasons for selecting a lO-mile radius EPZ was that ' detailed planning within | one out of the four primary reasons for selecting a lO-mile radius EPZ was that ' detailed planning within | ||
) | |||
10 miles would provide a substantial base for expansion of response efforts in the event that this proved ' | 10 miles would provide a substantial base for expansion of response efforts in the event that this proved ' | ||
yo ecessary.' | yo ecessary.' | ||
(p. 12, NUREG 0654 FEMA Rep. 1. Rev. 1). | |||
} | |||
states | T e debate over the size of the EPZ continues and I have att ched a brief summary of existing argument for ex-tending the EPZ as Exhibit R. | ||
NUREG 0654 clearly states at for the most serious accidents, protective | |||
~ g.~.. | |||
zones. | \\ | ||
as Exhibit S . | r actions would need to be taken outside the planning zones. | ||
Q. | J.<1 p. 11. | ||
NUREG 0654, pp. 11-12 are attached as Exhibit S. | |||
Q. | |||
In the event that, protective actions (evacuation, sheltering, control,of access and regress, radio-pro- | |||
\\ | |||
tective drugs) became,necessary beyond the EPZ, would | tective drugs) became,necessary beyond the EPZ, would | ||
\\ | |||
plans in place within 10 miles provide a base for the | plans in place within 10 miles provide a base for the | ||
\\ | |||
c,Y expansion of response efforts? | |||
A. | \\ | ||
L - | |||
A. | |||
No, because: | |||
cannot be expanded to provide | \\ | ||
\\ | |||
relies on permanently installed sirens and a mobile public address system. | 1. | ||
Notification procedures outlined in BYA 4-5 | |||
\\ | |||
tions in Rockford | cannot be expanded to provide r the prompt notification of the public beyond the 10-milesEPZ. | ||
no plans are in place to notify the more sp\arsely popu-lated rural areas. | The applicant | ||
\\ | |||
3 | relies on permanently installed sirens and a mobile No such sir \\ | ||
ens exist outside public address system. | |||
m - | the EPZ. | ||
The applicant's alternative \\ystem of mobile public address systems is impractical fo'r larger popula- | |||
\\ | |||
tions in Rockford Freeport. Dixon, Sterlihg and Rochelle: | |||
no plans are in place to notify the more sp\\arsely popu-lated rural areas. | |||
2. | |||
The applicant has developed no evacuation time estimates for areas outside the 10 mile EPZ for use\\ y those responsible for choosing protective actions. | |||
3 To the northeast and within the first 10-mile g | |||
\\, | |||
m | |||
.-.7~__. | |||
,.,r_ | |||
.y g- | |||
w | w incre ental expansion of the planning base is most of the ci of Rockford, Illinois. | ||
The Rockford area has a total pulation of about 204.000. | |||
Taking the popu-lation dis ibution by ca= pus sector, we find that the | |||
\\ | |||
Sector C (22)o withanortheastcenterline)pfpulation | Sector C (22)o withanortheastcenterline)pfpulation | ||
\\ | |||
within the first 10 miles stands at 1,577, while a | within the first 10 miles stands at 1,577, while a second10 miles \\ | ||
second10 | e adds 114,598 persons. | ||
This is an increase | |||
in population by a | \\ | ||
in population by a factor of 72 7 s | |||
\\ | |||
Si=ilarly, Sector G (southeast) has 261 persons | Si=ilarly, Sector G (southeast) has 261 persons | ||
\\ | |||
within 10 miles, and jumps to 11,528 within only an | within 10 miles, and jumps to 11,528 within only an | ||
\\ | |||
additional 10 miles. | additional 10 miles. | ||
This is a 44-fold increase. | |||
There is a clear ch nge from rural to urban areas. | There is a clear ch nge from rural to urban areas. | ||
Besides huge numerical ine eases, additional problems are caused by high density urban areas (e.g., traffic, heavy i | Besides huge numerical ine eases, additional problems are caused by high density urban areas (e.g., traffic, heavy i | ||
industry which must be shut doh , people dependent upon | industry which must be shut doh, people dependent upon | ||
\\ | |||
public transportation). | public transportation). | ||
Southwest Rockford is character-ized by all of these factors. | |||
s 4. | |||
No plans have been made for the relocation of persons outside the EPZ. | |||
Wisconsin Division of Emergency Government Deputy Administrator Gordon\\\\Reece has confir:ed | |||
\\ | |||
that no plans have been made to relocate Rockford | |||
\\ | |||
residents in Wisconsin. | residents in Wisconsin. | ||
5 | 5 Finally, the public outside the EPZ would be totally uninfor=ed as to the actions to be | ||
,aken (e.g., | |||
\\ | |||
sheltering, evacuation) in order to protect t'he=selves frc= | sheltering, evacuation) in order to protect t'he=selves frc= | ||
\\ | |||
radioactive effluents. | radioactive effluents. | ||
The emergency plans proposed by the state and the I | The emergency plans proposed by the state and the I | ||
applicant for the 10-mile EPZ fail to ' provide a sub- | |||
'fL | |||
/ | |||
/ | |||
stantial base for expansion of rosponsible efforts in the event that this proved necessary' (NUREG 0654, | stantial base for expansion of rosponsible efforts in the event that this proved necessary' (NUREG 0654, | ||
} | |||
: p. 12). | : p. 12). | ||
'/ | |||
Although Commonwealth Edison responded to a DAARE/ | Although Commonwealth Edison responded to a DAARE/ | ||
SAFE interrogatory as'follows: | SAFE interrogatory as'follows: | ||
"if evacuatiori or any | |||
*j other protec,tive,.m/ | |||
miles, they | easures became necessary beyond 10 | ||
/ | |||
miles, they ould be implemented as an extension of the measures anned for within the 10-mile area," such an expans' n is not feasible by present planning. | |||
x' i | x' i | ||
( ') | ( ') | ||
for the Plume Exposure Pathway Emergency Planning Zone | Q. | ||
Are you familicr with CECO's " Evacuation Time Estimates for the Plume Exposure Pathway Emergency Planning Zone | |||
1982, (" Evacuation Time Estimates - Byron")? | ) | ||
A. | of the Byron Nuclear Generating Station" dated December, 1982, (" Evacuation Time Estimates - Byron")? | ||
Q. | A. | ||
Yes, I am. | |||
Q. | |||
Have you read and studied the relevent regulations and ' | |||
guides for the preparation and evaluation of Evacuation Time Estimates? | guides for the preparation and evaluation of Evacuation Time Estimates? | ||
A. | A. | ||
Yes. | |||
I have read interalia 10CFR, Sections 50 34: 50.47: | |||
Q<. | Q<. | ||
50 57 and NUREG 0654, FEY.A-Rep. 1. Rev. 1. | 50 57 and NUREG 0654, FEY.A-Rep. 1. Rev. 1. | ||
Q. | I have read and studied 10 CFR, Section 50.47 (b) (10) and NUREG 0654, II. J. 8: II. J. 10 (i), (m), and Appendix 4. | ||
A. | Q. | ||
Has Evacuation Time Estimates - Byron been prept. red in accordance with these regulations? | |||
A. | |||
Certainly not. | |||
Evacuation Time Estimates - Byron fails to comply with NUREG 0654, Apprendix 4 because: | |||
1. | |||
The stu - does not translate population data into two subg ups: | |||
those using autos and those without autos (NURE0654 Appendix 4. II-A, | |||
: p. 4-2). | : p. 4-2). | ||
2. | |||
The stud does not give special attention to those house olds not having automobiles (Id II-A,p.4-3)N. NVehicle data was derived from | |||
\\ | |||
de=ographic data,'and the number of vehicles | de=ographic data,'and the number of vehicles | ||
\\ | |||
registered in Ogle and Winnebago Counties. | registered in Ogle and Winnebago Counties. | ||
N (Evacuation Time Estimates - Byron, p. 3-1) | N (Evacuation Time Estimates - Byron, p. 3-1) | ||
\\ | |||
Each household is then assu,med to represent | Each household is then assu,med to represent | ||
\\ | |||
) | |||
one vehicle because there are, numerically, enough to go around. | |||
(Id) | |||
N | |||
\\ | |||
3 The otudy doss not davolopa occurate estimates of transient pcpulations using local data such as peak tourist volumes and employment data of large factories (NUREG 0654, Appendix 4. II-B, | |||
as peak tourist volumes and employment data of large factories (NUREG 0654, Appendix 4. II-B, | : p. 4-3). | ||
: p. 4-3). | The study misrepresents normal and 1 | ||
seasonal transient populations. | |||
Table 3-4 | |||
Exhibit T. | .1 | ||
" Camps and Recreation Areas Within the Emergency Planning Zone" is attached to this Affidavit as Exhibit T. | |||
Numerous phone interviews and personal interviews with owners and representa-tives of camps and recreational areas conducted between December, 1982, and February, 1983, letters received from said spokespersons durirg February, 1983, and examination of the FSAR and a Department of Commerce and Community Affairs publication titled " Rock River Valley," dated June. 1982, have led me to conclude that the data presented in Table 3-4 is far from accurate. | |||
Table 3-4x sum =arizes the data collected during l | Table 3-4x sum =arizes the data collected during l | ||
my investigation of this issue. | my investigation of this issue. | ||
State Park, almost 800 at Lake Louise and as many as 1,100 at Lake LaDonna. | Table 3-4x is attached to this Affidavit as ExhibitU. | ||
Should an e=ergency occur on a summer weekend, decision makers using CECO time estimates would be overlooking 450 night time campers at Lowden i | |||
State Park, almost 800 at Lake Louise and as many as 1,100 at Lake LaDonna. | |||
During a holiday l | |||
weekend up to 2,300 mmte persons would enter the I | |||
roadway system at Lake LaDonna than CECO planners would have us believe. | |||
.? | |||
n~ | n 45 | ||
~ _.. | |||
4. | |||
The study dosa not indiento the critical assump- | |||
} | |||
tions which underlie the time estimates, e.g., | |||
peak transient versus off-peak transient (NURIG 0654, Appendix 4, IV-A, p. 4-7). | peak transient versus off-peak transient (NURIG 0654, Appendix 4, IV-A, p. 4-7). | ||
N 5 | |||
The study does not address the relative signifi-cance of alternative assumptions (M, IV-A, | |||
: p. 4-7). | : p. 4-7). | ||
6. | |||
e study does not make evacuation time estimates fo each special facility on an individual basis (M. | |||
attached as Exhibit V .) Schools are designated | I-C, p. 4-3: IV-B, p. 4-10). | ||
The Village of Progress and the Oregon Day Care Center are listed n Table 3-2 as schools. | |||
(Table 3-2 1.s | |||
\\ | |||
attached as Exhibit V.) | |||
Schools are designated | |||
\\ | |||
in Section 4.2 of the Evacuation Time Estimates - L: | in Section 4.2 of the Evacuation Time Estimates - L: | ||
Byron as | Byron as spec \\ | ||
ial facilities. | |||
attached as Exhibit V.) But evacuation time | (Section 4.2 is g | ||
(. o attached as Exhibit V.) | |||
estimates were not, calculated for Village of | But evacuation time g, r | ||
\\ | |||
estimates were not, calculated for Village of | |||
6-2 "Special Faciliti' | \\ | ||
r Progress and the Oregon Day Care Center. | |||
is attached as Exhibit X.) | (Table | ||
\\ | |||
7 | 6-2 "Special Faciliti'es Evacuation Time Esti=ates" s | ||
\\ | |||
School, The Ogle County Trainable \ | is attached as Exhibit X.) | ||
\\ | |||
7 The study does not describ,e special facilities' highly individualized means\\ of transportation (NUREG 0654 II-C, p. 4-3). | |||
he differing | |||
\\ | |||
l transportation capabilities of the Oregon Annex School, The Ogle County Trainable \\ | |||
enter The Lorado Taft Field Campus, White Pines Manor | |||
\\ | |||
Nursing Home, and Pinecrest Manor Home for the | Nursing Home, and Pinecrest Manor Home for the | ||
) | |||
\\ | |||
Thomas Bowes, (pp. 2-5), cary Montel, (p . 4-6), | Aging are well docu=ented in the Affidavits of Thomas Bowes, (pp. 2-5), cary Montel, (p. 4-6), | ||
'M s | |||
Gnd Chnr1 s Lamb, (pp. 3-5, 7-9). | |||
The public | |||
The insensitivit isbothgeneral(a.}ldistricts have mobilization and transportation problems | ) | ||
schools, to have varying transportation capatili-ties to which he time estimates are insensitive. | |||
The insensitivit isbothgeneral(a.}ldistricts have mobilization and transportation problems according to Affian\\ | |||
e. | e. | ||
ta Miller, Turner and Maloney) and specific (the Ore \\ | |||
gon Su it d | |||
a) | t of Schools can transport le\\ | ||
their evacuatio | per n en en ss than half his student population in one trip as \\eglained in this testimony at p. M ). | ||
b) | 8. | ||
The study does not consider the special facilities' highly individualized mobilization times for equipment and manpower (NUREG 0654, Appendix 4, IV-B, p. 4-9). | |||
source of transportation, the Oregon School District, | a) | ||
Og e County Jail inmates are, acccrding to th IFRA-Byron, Revision 0, to wait for non DZ holding center vehicles to drive to Ore on to pick them up, yet their evacuatio time is the sa=e for Oregon Bible Colleg students who can simply get into private ehicles and leave. | |||
(Table 6-2. Exhibit,.) | |||
b) | |||
Stra y enough, the Oregon Annex School and the White Pines Manor Nursing Home are le to mobilize vehicles and evacuate (5N4inutes)beforetheir | |||
\\ | |||
source of transportation, the Oregon School District, able to co=plete | |||
\\ | |||
itsevacuation(55mingtes). | itsevacuation(55mingtes). | ||
N | N | ||
7/ | 7/ | ||
.a | .a f | ||
c) a statsmant in Section 4.2 (Exhibit V) tha "The individual mobilization ti=e | |||
) | |||
estim tes for each special facility have be\\ | |||
facilities ev'acuation time (sic)" is | e combined with the travel time out of the plume exposure pathway EPZ to cale ate the total 5pecial | ||
\\ | |||
~, | |||
facilities ev'acuation time (sic)" is ( | |||
,1.r pure nonsense (. 4-7). | |||
No individual mobilization times have been calculated. | |||
If the special fac lities are arranged | If the special fac lities are arranged | ||
\\ | |||
in order of the distance required to travel out of the EPZ | in order of the distance required to travel out of the EPZ the total evacuation times line up 'accordingly. | ||
Mobilization times are a e | Mobilization times are a e stant, not avariable,factorintheEv\\acuation | ||
\\ | |||
Time Estimates. | Time Estimates. | ||
9 | 9 Th study does not use time of day considerations for ecial facilities: | ||
: p. 4-1 m) | (NUREG 0654. IV-B. | ||
night | : p. 4-1 m) te Pines Nursing Home has 15 staff on d +y during the day and three at SI> | ||
during the da'y.,but as few as three or fouratnight.\KontelAffidavit, pp. 6-7) | night Bowes Affidavit, pp. 5-6) | ||
..b b) | |||
Pinecrest anor has 40 staff on duty N | |||
during the da'y.,but as few as three or fouratnight.\\KontelAffidavit, pp. 6-7) | |||
Time of day is clearly a varia le to be considered | Time of day is clearly a varia le to be considered | ||
) | |||
in determining evacuation times. | |||
o | o 4'9 10. | ||
4'9 | Tho otudy dooo not une cron cp2cific waather characteristics (NUREG 0654. Appendix 4. IV-A. | ||
) | |||
pp. 4-6, 4-7). | |||
It is assumed in the Evacuation Time | It is assumed in the Evacuation Time j.,g' Estimates that there will be a 307 re'uction in d | ||
{ | { | ||
This assumption is based on Hwy. Research Record No. 321 (1970) titled "The Environ = ental | roadway capacity during adverse weath'er (p. 4-5). | ||
This assumption is based on Hwy. Research Record No. 321 (1970) titled "The Environ = ental Influence of Rain on Freeway Capacity." | |||
Allow me to quote the' FSAR on this, " Severe winter storms, those that produce snowfall in excess of six inches and often are accompanied by damaging glaze, are responsible for more damage in Illinois than any other form of severe weather." | Rain is not the major impediment to roadway travel in northern Illinois and there are no freeways in Ogle County. | ||
A snow or ice covered county road would have been a more appropriate case for study. | |||
Allow me to quote the' FSAR on this, " Severe winter storms, those that produce snowfall in excess of six inches and often are accompanied by damaging glaze, are responsible for more damage in Illinois than any other form of severe weather." | |||
(FSAR at 2 3 1.2 3.) | |||
These stems occur five times per year in the state and average 14.2 hours in length. | |||
g. | |||
The north-western area of Illinois, including the Byron Station, has the highest frequency in the state (144 storms over six inches in the last 60 years). | |||
M. | |||
The life of the plant then, may see over 70 such storms in addition to the two days glaze per year in Ogle County. | |||
M | |||
) | |||
Bad weather has other effects on Evacuation Time Estimates including: | |||
y 0) tha numbar of occidents increases dramatically thus slowing traffic: | |||
) | |||
b) snow removal duties will reduce the Ogle county Highway Deparment's and | |||
snow removal duties will reduce the Ogle county Highway Deparment's and | ,,'g the State Highway Departments ability to perform other tasks vitaIl to prompt 5 | ||
a evacuation, viz., notification of the public, access and traffic control (IPRA-Byron, Revision 0, VI (1)p. 27; VI (2) p. 120): and c) other emergency workers will be delayed in getting to their posts. | |||
the State Highway Departments ability | NUREG 0654.. | ||
to perform other tasks vitaIl to prompt a | states explicitly, | ||
evacuation, viz., notification of the public, access and traffic control (IPRA-Byron, Revision 0, VI (1)p. 27; VI (2) p. 120): and c) | "...a northern site with a high summer tourist popula-tion should consider rain, flooding, or fog as | ||
NUREG 0654. . | );. | ||
g the adverse conditions as well as snow with winter population estimates" (NUREG 0654 Appendix 4, pp. 4 4-7). | |||
Evacuation Time Estimates - Byron exhibits no such sensitivity to local conditions. | |||
11. | |||
The study does not identify the adverse weather a | |||
c. | c. | ||
frequency used. | frequency used. | ||
(Id, IV-A, p. 4-6) | |||
time (NUREG 0654, Appendix 4. IV-A, p. 4-6) in a format as exhibited in Table 2 (Id, 4-16) . | ~ | ||
12. | |||
The study does not present each of the evacuation time components alone, with the total evacuation time (NUREG 0654, Appendix 4. IV-A, p. 4-6) in a format as exhibited in Table 2 (Id, 4-16). | |||
A table of this nature would have forced | A table of this nature would have forced | ||
) | |||
the Evacuation Time Estimates - Byron authors to recognize other inadequacies of the docu=ent l | |||
bb | bb prosentcd haroin.- | ||
13 The study does not give consideration to the impact of peak populations including behavioral aspects ( H, IV-B, p. 4-10). | |||
13 | 14. | ||
e study does not make recommendations for I | |||
The study mentions the deployment of traffic control (p. 7 | act | ||
15 | .s that could be taken to significantly improve vacuation times. | ||
Q. Are there further inadequacies in the Evacuation Time Estimates which are not related to specific portions of NUREG 0654. Appendix 4, but which still threaten the document's credibility and reliability as a tool for decision makers during a radiological emergency? | ( M, IV-B, p. 4-10) | ||
A. Yes | (,. | ||
The study mentions the deployment of traffic control (p. 7 but this is hardly innovative. | |||
15 The study does not nelude comments resulting from a review of the aft by principal organi-zations (state and local) | |||
following assumptions which are not supportable: | NUREG 0654, Appendix 4, IV-B, p. 4-10) | ||
r ,n/ | Q. | ||
(Section 4.1 3 which contains the assumptions, is attached to this Affidavit as Exhibit Y .) | Are there further inadequacies in the Evacuation Time Estimates which are not related to specific portions of NUREG 0654. Appendix 4, but which still threaten the document's credibility and reliability as a tool for decision makers during a radiological emergency? | ||
a) | A. | ||
Yes there are. | |||
1. | |||
Evacuation Time Estimates - Byron makes the I~*F | |||
', ~, | |||
following assumptions which are not supportable: r,n/ | |||
(Section 4.1 3 which contains the assumptions, is attached to this Affidavit as Exhibit Y.) | |||
a) | |||
"All persons within the plume exposure pathway EPZ when instructed to evacuate, will leave." | |||
(p. 4-4) b) | |||
" People in the outer primary evacuation I | |||
) | |||
zones will not evacuate when an inner primary evacuation zone is the only | |||
{ | |||
^ | |||
frj | frj sen2 to be ovacuaied." | ||
(p. 4-5) c) | |||
" Traffic ruler and controls will be obeyed, only the proper travel lane will be used (not shoulders or opposite D'r flow lanes)... " | |||
flow lanes) . . . " | (p. 4-5) | ||
'/- | |||
relative significance of alternative assu=ptions (NUREG 0654. IV-A, p. 4-7). | Assumptions 1, 2 and 3 run contrary to expected human behavior and con =cn sense. | ||
d) | The plan should consider the relative significance of alternative J | ||
s (Based on this system, the ti=e to notify essentially 1007,of the full | assu=ptions (NUREG 0654. IV-A, p. 4-7). | ||
d) | |||
plu=e exposure pathway EP2 population /#p' | "The prompt public notification systcn, which utilizes sirens, will be used. | ||
s (Based on this system, the ti=e to notify essentially 1007,of the full plu=e exposure pathway EP2 population /#p' | |||
~ | |||
has been estimated to be 15 minutes)." | has been estimated to be 15 minutes)." | ||
(p. 4-5) | (p. 4-5) | ||
On the contrary, according to state plans, "Provisiens exist to warn 100f, of the population within the entire plume exposure EPZ within a 45 minute ti=e period." | On the contrary, according to state plans, "Provisiens exist to warn 100f, of the population within the entire plume exposure EPZ within a 45 minute ti=e period." | ||
As discussed in this testimony, | (IPRA, Volume I, Ch. 5, IPRA, Volu=e VI, Ch. 2, p. 10) e) | ||
"The people without cars will receive rides from either neighbors or designated public service vehicles." | |||
(p. 4-5) j / ;,$. | |||
As discussed in this testimony, | |||
[~ | [~ | ||
l | |||
) | |||
no adequate plans exist for the use of I public service vehicles in transporting | |||
cas o.; | |||
h'osabound rocidents or those without a vehicle at home. | |||
Relying on neighbors is a more realistic assumption but it is an assumption far ahead of public consciousness. | |||
I | |||
? | |||
Summer camps are only listed in | f) | ||
the IPRA-Byron, Revision O. | " Adequate transportation will be h | ||
a available for summer camps." | |||
Summer camps are only listed in the IPRA-Byron, Revision O. | |||
No provi- | |||
[ | [ | ||
sions have been made for their trans #t | |||
sions have been made for their trans #t portation. Ruth Little, Executive Director of the Rock River Valley Council of Girl Scouts, reported to me on January 13, 1983, that Ca=p McCormick, located in the EPZ, has about two cars for 90 campers. | '~ | ||
portation. | |||
and Lamb (p. 8) all deny this. | Ruth Little, Executive Director of the Rock River Valley Council of Girl Scouts, reported to me on January 13, 1983, that Ca=p McCormick, located in the EPZ, has about two cars for 90 campers. | ||
I | 2. | ||
The acuation Time Estimates - Byron falsely claim t have obtained mobilization and loading timec for ecial facilities from administrators of those faci ities (Exhibit 1/). | |||
IESDA officials are purported to ave obtained a 30 minute mobilization time ime required to obtain transportation and prepare to leave) from school officials. | |||
Affidavits bf school officials Maloney (p. 9), Miller (p 9 ). Turner (p. 9-10), | |||
and Lamb (p. 8) all deny this. | |||
Nursing ho=es were assigned the same mobil zation times. | |||
I Affidavits of Montel (p. 8-9) \\and Bowes (p. 8) aggressively deny the adequacy of these estimates | |||
\\ | |||
i RADIOLOGICAL EMERGENCY RESPONSE SURVEY AMBULANCE MEDICAL SERVICES 1. | |||
How many people are active members of your Ambulance Corps at this time? | |||
30-M11e | 30-M11e v | ||
e4 0-10 | .-4 Employed Region EPZ Radius a | ||
41+ | e4 0-10 6 | ||
o Mean | 1 5 | ||
19.0 | .S 11-20 11 1 | ||
Total | 5 C | ||
a | 21-30 13 2 | ||
11 5 | |||
30-M11e | 31-40 0 | ||
3 41+ | |||
3 y | |||
No. | o Mean 23.0 19.5 24.7 Median 19.0 19.0 24.0 Total 760 78 593 | ||
$a C | |||
30-Mile Region | 2. | ||
Yes | How many of these people are Emergency Medical Technicians (EMTs)? | ||
No | H a | ||
30-M11e 5 | |||
30-Mile Region | EMTs Region EPZ Radius 0- 5 4 | ||
Yes | 0 4 | ||
No | 6-10 13 3 | ||
No Response | 10 11-15 10 1 | ||
6 16-20 4 | |||
30-Mile Region | 0 3 | ||
Yes | 21+ | ||
No | 2 0 | ||
Don't Know | 1 Mean 11.7 10.0 11.0 Median 10.0 10.0 10.0 Total 387 40 265 | ||
No Response | % EMTs 50.9% | ||
51.3% | |||
N | 44.7% | ||
[t | 3. | ||
Some- | How many ambulances does your Ambulance Corps operate? | ||
None | No. | ||
Don't Know | 30-Mile Ambulances Region EPZ Radius 1 | ||
No Response | 12 1 | ||
9 2 | |||
19 3 | |||
13 3 | |||
1 1 | |||
4 1 | |||
1 Mean 1.7 1.8 1.8 Median 2.0 2.0 2.0 Total Ambulances 57 7 | |||
42 4. | |||
Is your Ambulance Corps part of the Police or Fire Department in your area? | |||
30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 24 72.7% | |||
3 75.0% | |||
20 83.3% | |||
No 9 | |||
27.3% | |||
1 25.0% | |||
4 16.7% | |||
5. | |||
Hava ycu er y:ur Corps had in-ccrvico training on emergincy rarpensa to itnizing rcdiatica injury cad /cr dscentamination procedures in the past five years? | |||
30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 9 | |||
27.3% | |||
10 25.0% | |||
dD 25.0% | |||
No 23 69.7% | |||
3 75.0% | |||
18 75.0% | |||
No Response 1 | |||
3.0% | |||
0 0.0% | |||
0 0.0% | |||
6. | |||
Have you or yEur Corps had any other training pertinent to an emergency response to above? | |||
30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 3 | |||
9.1% | |||
0 0.0% | |||
3 12.5% | |||
No 26 78.8% | |||
3 75.0% | |||
19 79.2% | |||
Don't Know 2 | |||
6.1% | |||
1 25.0% | |||
1 4.2% | |||
No Response 2 | |||
6.1% | |||
0 0.0% | |||
1 4.2% | |||
: 7.,/ How many Corps members are competent in the evaluation of exposure levels? | |||
) | |||
30-Mile N | |||
Region EPZ Radius | |||
[t | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Some-5 15.2% | |||
0 0.0% | |||
40 16.7% | |||
None 26 78.8% | |||
4 100.0% | |||
18 75.0% | |||
Don't Know 1 | |||
3.0% | |||
0 0.0% | |||
1 4.2% | |||
No Response 1 | |||
3.0% | |||
0 0.0% | |||
1 4.2% | |||
# Competent 19 0 | |||
18 | |||
% Competent 2.5% | |||
0.0% | |||
3.0% | |||
8./ How many Corps members are competent in the evaluation of decontamination and treatment of individuals exposed to ionizing radiation? | 8./ How many Corps members are competent in the evaluation of decontamination and treatment of individuals exposed to ionizing radiation? | ||
(I | (I N /* | ||
Some | g' 30-Mile Region EPZ Radius | ||
None | |||
No Response | ===Response=== | ||
No. | |||
No. | |||
No. | |||
Some 7 | |||
21.2% | |||
0 0.0% | |||
4@ 16.7% | |||
None 24 72.7% | |||
4 100.0% | |||
18 75.0% | |||
No Response 2 | |||
6.1% | |||
0 0.0% | |||
2 8.3% | |||
# Competent 33 0 | |||
22 | |||
% Competent 4.3% | |||
0.0% | |||
3.7% | |||
l 1 | l 1 | ||
l 9 9 How prcptred cra ysur Ambulcnca Corpa memb2rs to racptnd to e major radiologicci disantcr? | l.-- | ||
9 9 How prcptred cra ysur Ambulcnca Corpa memb2rs to racptnd to e major radiologicci disantcr? | |||
(0) | /p ' | ||
(1-4) | 30-Mile Ranking Region EPZ Radius 0 | ||
(5-8) | 21 3 | ||
(9 & 10) well prepared | 16 1 | ||
Total | 2 1 | ||
No Response | 1 2 | ||
4 0 | |||
30-Mile Hospital | 3 3 | ||
2 0 | |||
1 4 | |||
30-Mile Region | 1 0 | ||
24.5 | 1 5 | ||
0 0 | |||
30-Mile Region | 0 6 | ||
l 109 | 0 0 | ||
0 7 | |||
30-Mile l | " 1 0 | ||
163 | 1 8 | ||
D' | 1 0 | ||
Yes | 1 9 | ||
No | 0 0 | ||
Total | 0 10 0 | ||
0 0 | |||
30-Mile Region | Total 32 4 | ||
Yes | 24 No Response 1 | ||
No | Mean 1.1 0.3 1.2 Median 0.0 0.0 0.0 Rank Description No. | ||
Total | No. | ||
l | No. | ||
(0) not at all 21 65.6% | |||
3, 75.0% | |||
16 66.7% | |||
h 25.0% | |||
(1-4) not well prepared 9 | |||
28.1% | |||
1W 25.0% | |||
(5-8) generally prepared 2 | |||
6.3% | |||
0 0.0% | |||
2W 8.3% | |||
(9 & 10) well prepared 0 | |||
0.0% | |||
0 0.0% | |||
0 0.0% | |||
Total 32 100.0% | |||
4 100.0% | |||
24 100.0% | |||
No Response 1 | |||
10. | |||
To what hospital would you take patients who have been injured in a radiological emergency? | |||
30-Mile Hospital Region EPZ Radius 0 | |||
1 2 | |||
Rockford Memorial 2 | |||
St. Anthony 6 | |||
1 6 | |||
Nearest Rockfori Hospital 2 | |||
0 2 | |||
Sterling Community General-6 0 | |||
2 Rochelle Community 1 | |||
0 1 | |||
l Freeport Memorial 4 | |||
0 1 | |||
Kishwaukee Community 3 | |||
0 3 | |||
Sandwich Consnunity 1 | |||
0 0 | |||
Galena Stauss 1 | |||
0 0 | |||
Dixon KSB 2 | |||
0 2 | |||
Don't Know 1 | |||
1 1 | |||
No Response 4 | |||
1 4 | |||
Total 33 4 | |||
24 | |||
% Correct (R.'GI) 6.1% | |||
25.0% | |||
8.3% | |||
11. | |||
What in tha diattaco from th2 fcrthast point in y:ur crea to this hospital? | |||
30-Mile Region EPZ Radius Distance in Miles Distance in Miles Distance in Miles Mean Max. | |||
Min. | |||
Mean Max. Min. | |||
Mean Max. | |||
Min. | |||
24.5 55 2 | |||
35.0 45 25 23.9 55 2 | |||
12. | |||
What is the maximum number of trcuma or medical patients that your Ambulance Corps can transtiort at one time? | |||
30-Mile Region EFZ Radius Total Total Total Patients Mean Max. | |||
Min. | |||
Patients Mean Max. | |||
Min. | |||
Patients Mean Max. | |||
Min. | |||
l 109 3.3 8 | |||
1 18 4.5 8 | |||
2 82 3.4 8 | |||
1 13. | |||
What is the maximum number of non-ambulatory people that your Ambulance Corps can transport at one time? | |||
30-Mile l | |||
Region EPZ Radius Total Total Total People Mean Max. | |||
Min. | |||
People Mean Max. | |||
Min. | |||
People Mean Max. | |||
Min. | |||
163 5.1 16 2 | |||
25 6.3 12 4 | |||
143 6.2 16 2 | |||
l 14 Does your Ambulance Corps have a written protocol for radiological h | |||
emergency procedures? | |||
D' 30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 2 | |||
6.0% | |||
0 0.0% | |||
h 8.3% | |||
No 31 93.9% | |||
4 100.0% | |||
22 91.7% | |||
Total 33 100.0% | |||
4 100.0% | |||
24 100.0% | |||
15. | |||
Do you have a written protocol for an emergency response to accidents involving other injuries as well as radiation exposure? | |||
30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 4 | |||
12.9% | |||
1 20.0% | |||
4 17.4% | |||
No 27 87.1% | |||
4 80.0% | |||
19 82.6% | |||
Total 31 100.0% | |||
5 100.0% | |||
23 100.0% | |||
l No. Response 2 0 | |||
1 l | |||
I | I | ||
-8 | |||
30-Mile Region | 16. | ||
Yes | Do you have a written protocol for the transportation of patients contaminated in a radiological emergency? | ||
No | 30-Mile Region EPZ Radius | ||
Total | |||
===Response=== | |||
30-Mile Region | No. | ||
Yes | No. | ||
No | No. | ||
Total | Yes 3 | ||
Don't Know | 9.1% | ||
l@) 25.0% | |||
30-Mile Region | $1) 12.5% | ||
Yes | No 30 90.9% | ||
No | 3 75.0% | ||
Total | 21 87.5% | ||
Don't Know | Total 33 100.0% | ||
4 100.0% | |||
24 100.0% | |||
17. | |||
Do you have a written protocol for the evacuation of people dependent on others for mobility during a radiological emergency? | |||
30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 1 | |||
3.2% | |||
0 0.0% | |||
1 4.5% | |||
No 30 96.8% | |||
4 100.0% | |||
21 95.5% | |||
Total 31 100.0% | |||
4 100.0% | |||
22 100.0% | |||
Don't Know 2 | |||
0 2 | |||
18. | |||
Has your Ambulance Corps ever been contacted by anyone from ESDA regarding the Byron emergency response plan? | |||
30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 8 | |||
28.6% | |||
3(h100.0% | |||
7(h35.0% | |||
No 20 71.4% | |||
0 0.0% | |||
13 65.0% | |||
Total 28 100.0% | |||
3 100.0% | |||
20 100.0% | |||
Don't Know 5 | |||
1 4 | |||
1 Are you aware of any efforts to assign a support role to your ambulance (w/ | |||
service as a part of an integra:ed response to a radiological emergency? | |||
30-Mile | 30-Mile | ||
\\p Region EPZ Radius | |||
Yes | |||
No | ===Response=== | ||
No. | |||
Don't Know | No. | ||
No. | |||
Yes 1 | |||
3.4% | |||
0 0.0% | |||
1 4.5% | |||
No 28 96.6% | |||
2 100.0% | |||
21 95.5% | |||
Total 29 100.0% | |||
2 100.0% | |||
22 100.0% | |||
Don't Know 4 | |||
2 2 | |||
WV &LLo Howmanycfy}urAmbulnncoCorpamembarcwouldrocprndtocn M$ fM W f1 20. | |||
emergcncy rc ulti from o r:dirlegical rolcaca from tha Byron nuclear facility. | |||
30-Mile Region EPZ | |||
_ Radius Members Members Members Responding A m Responding Responding Ag Responding Responding Avg. | |||
Respondir 180 7.5 23.7% | |||
58 14.5 74.4% | |||
122 5.8 2 ).6% | |||
No Response: Region (8), EPZ (1), 30-mile radius (7). | |||
[ Considered to be members responding) e 21. | |||
Do you have any disaster cabinets containing the supplies necessary for treatment and decontamination in the event of a radiological emergency? | |||
30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 1 | |||
3.0% | |||
0 0.0% | |||
1 4.2% | |||
No 32 97.0% | |||
4 100.0% | |||
23 95.8% | |||
Total 33 100.0% | |||
4 100.0% | |||
24 100.0% | |||
22. | |||
Number of Ambulance Corps with protective equipment available for a radiological emergency. | |||
Equipment Type of Available Totally Not Don't Know/ | |||
Equipment or Partially Available No Response No. | |||
No. | |||
No. | |||
Gloves 6 | |||
18.2% | |||
17 31.5% | |||
10 30.3% | |||
Gowns 1 | |||
3.0% | |||
23 69.7% | |||
9 27.3% | |||
Masks 3 | |||
9.1% | |||
21 63.6% | |||
9 27.3% | |||
Shoe Coverings 1 | |||
3.0% | |||
23 69.7% | |||
9 27.3% | |||
l Head Coverings 1 | |||
3.0% | |||
23 69.7% | |||
9 27.3% | |||
Personal Dosimeters 2 | |||
6.1% | |||
22 66.7% | |||
9 27.3% | |||
Marked plastic bags as vaste containers 1 | |||
3.0% | |||
24 72.7% | |||
8 24.2% | |||
~ | |||
Blankets 11 33.3% | |||
10 30.3% | |||
12 36.4% | |||
23. | |||
Does your Ambulance Corps have any radiation survey instruments? | |||
30-Mile Region EPZ Radius | |||
===Response=== | |||
No. | |||
No. | |||
No. | |||
Yes 6 | |||
18.2% | |||
0 0.0% | |||
5 20.8% | |||
No 27 81.8% | |||
4 100.0% | |||
No | 19 79.2% | ||
Total 33 100.0% | |||
4 100.0% | |||
24 100.0% | |||
No | |||
Total | |||
2/14/83 h IN | 2/14/83 h IN | ||
O. f. | |||
en ee | si. | ||
a e o o | |||
o | |||
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SZ | ~ | ||
a. | |||
I{ | |||
a a o o | |||
a w e o o - | |||
9Z | a m | ||
a a o o | |||
SZ | o r | ||
VZ | .o. | ||
ZZ | OC | ||
_m e. | |||
g | 6Z | ||
- ~ | |||
m m - | |||
~ ~ | |||
u - | |||
SZ | |||
_ ~ > | |||
w | a a o a | ||
o 8 | |||
.o. | |||
. ~ | |||
- o ~ a a | |||
a o o | |||
o LZ | |||
~ - | |||
m | 9Z | ||
9] | -e | ||
w | = a 8 | ||
u | SZ | ||
z | .. ~ > | ||
a a o e | |||
o VZ a | |||
2 | = - | ||
o | |||
~ | |||
i.i ZZ | |||
-. ~ = | |||
. o o | |||
r. | |||
j e. ~ > | |||
a a e o | |||
g gg e | |||
17 | |||
= | |||
= o o | |||
o u. | |||
~. | |||
o a | |||
u b | |||
OZ | |||
- * ~ * | |||
= * | |||
~ : | |||
e c | |||
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a a o e | |||
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i APPENDIX 3 ROCKFORD LEAGUE OF WOMEN VOTERS - DAARE/ SAFE RADIOLOGICAL EMERGENCY RESPONSE SURVEY AMBULANCE MEDICAL SERVICES January, 1983 Please complete by January 10 and return to: | i APPENDIX 3 ROCKFORD LEAGUE OF WOMEN VOTERS - DAARE/ SAFE RADIOLOGICAL EMERGENCY RESPONSE SURVEY AMBULANCE MEDICAL SERVICES January, 1983 Please complete by January 10 and return to: | ||
| Line 1,633: | Line 2,890: | ||
Page 1 l | Page 1 l | ||
9 9, | 9 9, | ||
aggggg, _, __. > % ABOOT ADREABE:E C3PS 1. | |||
maese | Bat musty people ama active numbers of your W1mana Cbeps at this tWun? | ||
maese 2. | |||
mamme | Enr ammy of these people are Bumegency Medical hir-4 ann? | ||
mamme 3. | |||
:.= _. _ _ . | Rat many antavanc== dome your W1-Q:n:ps egurata? | ||
:.= _. _ _. | |||
r | r | ||
: 4. Is your W1- Corps 1: art of tbs Polica z Fire %-h in your arma? | : 4. Is your W1-Corps 1: art of tbs Polica z Fire %-h in your arma? | ||
cc | cc Yes No M30GR PIEPAIEDESS PCR A WCICIIIIICAL DE:R22CY 5. | ||
Yes | Have you z your Wi-Cceps numebers had in dce min 4m en the aw2r e to fr=4+45 radiaticn irrjury and/cu-M=- | ||
-.;-- e y- -- - e in the past E.vu years? | |||
Yes | Yes No Dcn't Axar | ||
+ | |||
If TES, plasse mia tbs chert bakar. | If TES, plasse mia tbs chert bakar. | ||
m 4n4 | m 4n4 5 3emmessen Temined m44 5 | ||
In Bours I | |||
t | t | ||
Page 2 | Page 2 e. | ||
6. | |||
* 1 - Ce ps members had any other m ini m | Enve you z your | ||
par *4 =a* to an energency respcase to imidM radiatica injucy and/w Wn=ticx0 Yes | * 1 - Ce ps members had any other m ini m par *4 =a* to an energency respcase to imidM radiatica injucy and/w Wn=ticx0 Yes No Dcn't Know S | ||
If g, planas 7 + | If g, planas 7 + the chart below, 1 | ||
of me=4niner | hm | ||
,[# ofN'l-Iangth of oates of me=4niner | |||
< >Ccrps Manters P'=4n4 7 e -minart In Ecurs I | |||
1 t | 1 t | ||
l | l 7. | ||
2 the best of y;ur knowledge, for many of your Amh' inex:e Ccrps T-2 ass cx:npetent in the evaluaticn of P m levels? | |||
gye | |||
nacer | , &f t | ||
t i | |||
l | p, ' | ||
manour | nacer Cnowledge, how many of your W1=nm Cccps k | ||
8. | |||
2 t N of wi in the evaluaticn of heation and aud:mes are w tre of individuals W tn 4~4dM radiaticze 1 | |||
l manour 9. | |||
2 the best af your Wit, how rw.1 are your Seem1= rice Cbrps ~-. Eu.- - 2 to a maje =44at=4~1 disaster? | |||
Ot:re than five perscms with radiatica injury?) | Ot:re than five perscms with radiatica injury?) | ||
CIK2Z (2EE NtMER 0 1 | CIK2Z (2EE NtMER 0 | ||
1 2 | |||
3 4 | |||
5 6 | |||
7 8 | |||
9 10 (Not at all Cbtally l | |||
prepared) | |||
Prepared) | |||
- 10 " | |||
.=. | |||
Page 3 4 | Page 3 4 | ||
NNN | NNN | ||
: 10. 12 h hospital iculd ymt taka #* sde have been luj , ' in a =44a14=1 emergency? | : 10. 12 h hospital iculd ymt taka #* sde have been luj, ' in a =44a14=1 emergency? | ||
Namp cc Hospital | Namp cc Hospital Iccatum | ||
: 11. itat is the distana frt:In the farthest scint in your area to ths.s hospital? | : 11. itat is the distana frt:In the farthest scint in your area to ths.s hospital? | ||
Miles | Miles | ||
| Line 1,683: | Line 2,952: | ||
l l | l l | ||
NLucer | NLucer | ||
: 13. 1ent is the | : 13. 1ent is the | ||
==r4== | |||
mm*=rr of A - - itatory m1= that your Astm 21ance Cbrps can. - -, _- i at cria time? | |||
l l | l l | ||
- 19 _ | |||
o | o l | ||
Page 4 i | |||
e. | e. | ||
: 14. Does your Ambulance Ccups have a written r M for M 4al @ 1 emergency e_- Am? | : 14. Does your Ambulance Ccups have a written r M for M 4al @ 1 emergency e_- Am? | ||
i Yes | i Yes No D:st't Know E | ||
If m , please include a copy of the rwd with this survey. | If m, please include a copy of the rwd with this survey. | ||
If ul5, plaase answer the | eMM questions. | ||
l If ul5, plaase answer the l | |||
14a. Have tbs deczzxtambaticus | 14a. Have tbs deczzxtambaticus p._ - > e ever been practiced? | ||
Yes | Yes No Don't Know If M, please - lata this table. | ||
Datas | Datas Ntzncer of Pa&-=nts 14b. In year estinacim, is this plan %=Na at this time, given l, | ||
your gresent resources? | |||
r no Doo e now ' | |||
Page 5 t | |||
I | I e. | ||
: | : 15. In the event of a -Ha191 anurgency, do you have a written 7-_- | ||
=1 for an emergency==pream to arv-idants involving other i | |||
indtacias as unil as radiatica egneurs? | |||
Yes | Yes No Etm'tDtniat 4 | ||
If 3, plasse include a copy of the r w M with this survey. | If 3, plasse include a copy of the r w M with this survey. | ||
If g, please ansume the *11-85 qu e==. | If g, please ansume the *11-85 qu e==. | ||
t | t | ||
( | ( | ||
15a. Bas this amargency responsa ,w -- L . ever been peaceitwi? | 15a. Bas this amargency responsa,w -- L. ever been peaceitwi? | ||
Yes | Yes No Dcn't Encw | ||
+ | |||
If Igs, please m i-tm this table. | If Igs, please m i-tm this table. | ||
marcers of Par- | |||
* pants 1 | * pants Datas ll 1 | ||
l 15b. In yzze estinst:!m, is this plan h=4h1= at this time, I | |||
given your 5xasant resources? | |||
l Yes | l Yes | ||
~ ' No Dm't Rz:w. | |||
Page 6 e | Page 6 e* | ||
: 16. Do you have a laitten ;- - -- - - - 1 for the ---- , =wtizz1 of patiants W nated in a M a1 T -1 | : 16. Do you have a laitten ;- - -- - - - 1 for the ----, =wtizz1 of patiants W nated in a M a1 T -1 emergency? | ||
Ees | Ees Ma Dca't show 4 | ||
If M, P | If M, P anan h a a:yy of the l | ||
If 3 , plaams ansume the M11 M5 questions. | w with this arvey. | ||
16a. Have the | r If 3, plaams ansume the M11 M5 questions. | ||
16a. Have the wi L:n 1 c_- *- - - = ever been W e Yes No D:It't Kncw 4 | |||
If g, plasse mi-tm the fh11=iry table. | If g, plasse mi-tm the fh11=iry table. | ||
Datas | Datas NLucer of Parmn=m i | ||
16b. .In your estWustica, is this plan fan =4hla at this time, | 16b..In your estWustica, is this plan fan =4hla at this time, given your frement resources? | ||
Yes No Dcn't Ebow 1 | |||
Yes | |||
l | l | ||
. l | |||
l l | l l | ||
l | l Page 7 l | ||
: 17. Do you have a deten swM fcr tte evacuatim of m1= 4At. | |||
en others fcr mobilityAMM a M 4a1 9 1 anurgency? | en others fcr mobilityAMM a M 4a1 9 1 anurgency? | ||
Yes | Yes No Dcn't Know 4 | ||
If 5, planas include a cxgy of the ed with this arvey. | |||
c If M, | c If M, plasse answer the A11M7 questicas. | ||
l 17a. anve the evacuatien m- - - - e ever been practiced? | l 17a. anve the evacuatien m- - - - e ever been practiced? | ||
l | l Yes No Dcn't Know I | ||
t l | |||
If TES, please 7 1-tm the M11 ~i-M table. | If TES, please 7 1-tm the M11 ~i-M table. | ||
l i | l i | ||
l l | l l | ||
Dates NLancer of Par-* nam:s i | |||
i l | i l | ||
17b. .In your as*4==tien, is this plan haible at this tim, gived | 17b..In your as*4==tien, is this plan haible at this tim, gived your DL zesources? | ||
ras | r ras No Dcn't xmow | ||
38- | Page 8 l | ||
e. | |||
T. P. gen *c7 Services and Disaster Agenc~r=~"a_*~4 ~ | |||
38- | |||
Byron emergency response pled? | * = b=== | ||
======4 by =v=. an. ch. | |||
*ha | |||
~6 Byron emergency response pled? | |||
. m. | |||
no e | |||
+ | |||
E m, plasse desacibe h = imolved in this W in tbs spoon below, t | |||
9 I | 9 I | ||
e e | e e | ||
e 9 | e 9 - - - - | ||
1 l | |||
l- | 1 l | ||
l-Page 9 19. | |||
I | Are_vou aware.of any efforts to assign a support role to your Ambulance Service as a part of an integrated response to a radiolo5ical emergency? | ||
I Yes No Don't Ebow | |||
+ | |||
If TES, please annuar the Fa11M7 questim s. | If TES, please annuar the Fa11M7 questim s. | ||
l 19a. Please -1=4" you rela in the space providad balcw. | l 19a. Please -1=4" you rela in the space providad balcw. | ||
(Tm-In Evacuation ,m- + m as well as hwcf treatment and | (Tm-In Evacuation,m- | ||
l l | + m as well as hwcf treatment and | ||
-- 5 -_ i ) Please he W +4r. | |||
l l | |||
-'c : | |||
i l | i l | ||
l l | l l | ||
1Sb. Have you ever had a for:ml d4-=4m of this role with your *1arr* Cceps W7 Yes | 1Sb. Have you ever had a for:ml d4-=4m of this role with your *1arr* Cceps W7 Yes No Dcm't Ebow 19c. 1b tbn best of your knowledge, given your r- - _4 and 6-46i is your *1=nrw Corps to ful-fill this rola in the event of a =44a191 energency re-sulting..from.a bre.ach of containnent at the Byron nuclear power plant? | ||
CDCIZ CNE NWBER 0 | CDCIZ CNE NWBER 0 | ||
1 2 | |||
e | 3 4 | ||
5 6 | |||
7 8 | |||
9 10 l | |||
(Nbt at all (Tbtally l | |||
Prepared) | |||
Prepared) i t | |||
e l | |||
I | |||
.~ | |||
Page 10 | Page 10 | ||
: 20. ils the best of you l'wwi@, how many of your Astulance Cbrps ammbecs would respond to an amargency resultizzy fmm a radio-logical release from the Syron nuclear facility? | |||
ammbecs would respond to an amargency resultizzy fmm a radio-logical release from the Syron nuclear facility? | WJ f'W (estimata) e 20s. | ||
WJ f'W (estimata) e 20s. Pisase 7 =4a | Pisase 7 =4a tbs basis for your answer. | ||
ECtEPMDE | 1 ECtEPMDE l | ||
l l | l l | ||
: 21. Do you have any disaster ah4n=ts care =4 nim the = r 14== -==vf for treatamat and '-- --- | |||
: 21. Do you have any disaster ah4n=ts care =4 nim the = r 14== - ==vf for treatamat and '-- --- | :"=+ dm in the event of a ad4a1=ical l | ||
t | emergency? | ||
l | t l | ||
: 22. Please indicata the znanbar (if any) of the +11M7 ruwdve equa.pnent that you have av=41=h1= in your =*siimex:es for use by your kv*=$1=rr= 0:rps members in the event of a =d4at=4=1 amer-gecy. (P1 mass antar 0 for ncme and D.K. for Das't Kbow.) | l Yes No | ||
Protective G1 cues Protective Gcams Protective M Prr*=r+4 | : 22. Please indicata the znanbar (if any) of the +11M7 ruwdve equa.pnent that you have av=41=h1= in your =*siimex:es for use by your kv*=$1=rr= 0:rps members in the event of a =d4at=4=1 amer-gecy. | ||
Protective Head Ccs-r4== | (P1 mass antar 0 for ncme and D.K. for Das't Kbow.) | ||
Protective G1 cues Protective Gcams Protective M Prr*=r+4 e Shom W== | |||
9 Protective Head Ccs-r4== | |||
Pm W Dosimeters Plastic Bags len:$ced As w<mi=4-i m n.,emin.r. | Pm W Dosimeters Plastic Bags len:$ced As w<mi=4-i m n.,emin.r. | ||
Blanients | Blanients. | ||
s Page 11 Q- | s Page 11 Q- | ||
t Yes | : 23. Does your Amda21ance Qurps have any radia ice an:voy ir-w | ||
-w? | |||
If _us, p, lease | t Yes No liiE M5Ei | ||
* n~4 | + | ||
If _us, p, lease -1= | |||
an | |||
* n~4 table. | |||
e i | e i | ||
Type | Type 9 of ment =rs c=1 et :m/ | ||
# of In-Data last WW Range stzunants Tasted to comrata Quo.h r.) | |||
l t | l t | ||
t I | t I | ||
: 24. M:uld you be U1147 to provida us with | : 24. M:uld you be U1147 to provida us with list of t.% names arxi pbcme mm*=rs of your Ambu.1ance Corps==*wes s that a uny ask a randem sample of than a few questicms? | ||
(Their snes muld r==1n ancmynous if they so desire.) | |||
Yes | ~ | ||
s2gnature | Yes No I have aneamlui this survey volunta ily and to the best of my ability. | ||
s2gnature Date l | |||
t}} | |||
Latest revision as of 01:29, 21 December 2024
| ML20023C715 | |
| Person / Time | |
|---|---|
| Site: | Byron |
| Issue date: | 05/12/1983 |
| From: | Holmbeck P DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE) |
| To: | |
| Shared Package | |
| ML20023C710 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8305170569 | |
| Download: ML20023C715 (73) | |
Text
. _ _ _.
d
-)
a.
M,lOf /,/h UNITED STATES OF ERICA
'x X
NUCLEAR REGULATORY :OMMISSION sf 2f
'U,1 E
BEFORETHEATOMICSAFETYAND{LICENSINGBOARD
[$y.,
c:
j In The Matter of
)
g
)
)
COMMONWEALTH EDISON COMPANY
)
Docket Nos. 50-454 OL i
)
50-455 OL
)
(Byron Nuclear Power Station, )
Units 1 & 2)
)
STIPULATION Intervenors, DAARE/ SAFE and the Rockford League of Women Voters, Commonwealth Edison Company, and the NRC Staff hereby agree and stipulate that the attached affidavits may be admitted as Intervenors' Exhibits in the hearing record subject to the following conditions and understandings:
(1)
Only those portions of the affidavits which are not marked through are being offered into evidence; (2)
None of the witnesses sponsored by Intervenors has expertise in determining sheltering capabilities of specific structures; (3)
Only those portions of the "Rockford League.
l of Women Voters--DAARE/ SAFE Radiological Emergency Response Survey Ambulance Medical Services" which are attached hereto i
which the Board accepted during the hearings are being offered in evidence; i
hh569830512 DR M 05000454 O
4
, (4)
Those portions of the affidavits of Gary
- Montel, J.
Michael Maloney, Charles Lamb, David Miller, and David Turner for which there is a "13" noted in the margin are relevant only to Intervenor's amended contention 13.
As such, this evidence is being offered only to identify the information which these witnesses desire to communicate to emergency planners.
COMMONWEALTH EDISON COMPANY BY Date NRC STAFF By Date DAARE/ SAFE and ROCKFORD LEAGUE OF WOMEN VOTERS By Date
~
I.
w 4 :.
4)
Joint Intervenors' Exhibit 13 s
-)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 5 e
~
e In the Matter of
)
)
)
COI:MONXEALTH EDISON COMPANY
)
Docket Nos. 50-454 OL
)
50-455 CL
)
(Byron Nuclear Power Station,
)
Units 1 & 2)
)
AFFIDAVIT OF PAUL HOLMEECK The attached statements, questions and answers, and exhibits constitute my testimony in the above-captioned proceeding.
The testimony is true and accurate to the best of my knowledge, information, and belief.
Paul Holmbeck 1
Subscribed and sworn to before me this day of
, 1983 Notary Public
\\
A ls - p,.ie h,t.m
'y TESTIMONY OF PAUL HOLMBECK ON EMERCENCY PREPAREDNESS:
DAARE/ SAFE CONTENTION 3 - ROCKFORD LWV CONTENTIONS 19 AND 108 Affiant states that he has read and is familiar with the documents attached hereto.
e e
Q.
Please state your name.
A.
My Name is Paul Holmbeck.
Q.
What is the purpose of this testimony?
A.
The purpose of this testimony is to present the nature and results of my investigation into the adaquacy of
[
Emergency Plans for the Byron Nuclear Generating Station
/
(" Byron Station") in support of DeKalb Area Alliance for Responsible Energy /Sinnissippi Alliance for the Environ =ent k!
r
{
"\\"'
("DAARE/ SAFE") Contention 3 and Rockford League of Women Voters ("Rockford LWV") Contentions 19 and 108 all of which address emergency preparedness.
Q.
What is your educational background?
A.
My higher education background consists of two years of study at Duke University. 1979-81 during which I studied primarily political science and economics.
Durir4 this last academic year (1981-82), I studied development (third world) economics and political theory at the University of Kent in Canterbury, Ergland.
While at Dund I was on the Dean's List during 1980 and again in 1981 and received Class Honors during 1981.
My most
)
1 notnble work was a dissertation prepared at the University of Kent between April and July, 1982, on Dependency
)
Theories of Development.
I am presently on a year's leave of absence from Duke.
Since 1980, I have also been trained in wi'1derness emergency procedures concurrent with my role as a rock climbing and backpacking instructor.
Fashioned and originally trained by North Carolina Outward Bound, Wilderness Initiatives at Duke maintains rescue and evacuation procedures.
Those procedures include accident assessment by the instructor in the field, emergency communications and guidelines for the content of those communications; evacuation procedures including emergency transportation and protocols for calling in additional support from local rescue squads.
I have contributed to the revision of these procedures and the developing of more effective and comprehensive exercises.
Emergency operations in the wilderness also require flexibility to deal with changing condition of the victi=
and varying environmental factors, (e.g., weather and 4
land characteristics).
Careful calculations must be made as to the feasibility of evacuation and the costs and benefits gained from delayed evacuation of injured persons.
I have also had the experience of coordinating a search and rescue exercise in North Carolina's Pisgah National Forest involving almost 100 emergency workers.
Search and rescue operations reguire special attention i
w
~-
~-
e w
w-",,-
--.--,,r,
-,,--,-m.-
e-w.
,e-
l e,
to coordination and communications.
Selecting the area over which the emergency response is to be carried out
)
includes the use of sectoring, routing of response groups and, of course, assuring the safety of emergency personnel.
e
~
e j
i
)
l
7
,e Q.
Are ycu familiar with the term " protective cetion"?
A.
Yes, I am.
A protective action or protective measure is
}
any action taken to avoid er minimize the projected dose resulting from a release of radioactivity.
Protective l'f{I actions for the Byron Station include evacuationt I
sheltering: access controls and food, water, and milk i((,
a e
control.
Protective actions are described in the -
following documents:
EPA-520, 1-75-001 " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents,"
(" EPA-PAGs"): NUREG 0396-EPA, 520/1-78-016 " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants " and the International Atomic Energy Agency " Planning for Off-site Response to i
Radiation Accidents in Nuclear Facilities" (1978)
("IAEA-planning").
I have read and am familiar with these documents.
Q.
Do you know what is meant by " sheltering" pursuant to the Illinois Plan for Radiological Accidents, ' Byron,'
I Volume VI, Preli=inary Revision O ('IPRA-Byron, Revision 0")?
A.
Yes, I do.
Sheltering essentially means placing as much of a buffer between oneself and the plume of radioactive material as one can without leaving the affected area.
<( -
The degree of dose reduction afforded will be determined by the type of building in which shelter is sought, e.g.,
by the construction materials used in the building and by the number of floors or walls between the plume and
~
the paople cooking chaltar; cnd by the extent to which ventilation can be restricted in the building.
Q.
What must be done to translate this data into deter =ina-tions as to the value of sheltering as a protective measure?
A.
According to the EPA-PAGs and IAEA-Planning, the infor-mation on the proposed structures can be used to approxi-mate values'for the dose reduction through sheltering.
These approximate values are termed ' shielding factors' or ' reduction factors.'
Explanitory portions of IAEA-Planning are attached to this Affidavit as Exhibit A.
Q.
Have you gathered any data relevant to the determination of the adequacy of sheltering as a prescribed protective O<m EE3!
action?for p rt % a o Me A.
Yes, I have.
Directors, administrators, or superintendents at the following facilities have indicated to me that their buildings have no basement or windowless areas which could be used for sheltering their populations:
1.
T.
White Pines Manor Nursing Home Oregon -pJ nW popul +1on:
55 patients, 15 st (Bowes Affidav
- p. 7).
2.
The Pinecres Manor Home or the Aging in Mt.
}
rv Morris - Populawion 112 patients, 40 staff (Montel Affidavi,
9).
3 The Oregon Annex High ool - population:
80 Q A-
- students, staff (la b A
' davit, p. 6).
rhM 4.
The Og County Trainable Cen in Mt. Morris -
pop ation:
40 students, 17 staff.
Partial
)
sement.
(Id).
5 Mt. Morric Elementary School - population:
343 7 k students, 26 staff (Turner Affidavit, p. 10).
6.
Mt. Morris Junior High School - population:
189 pl d students, 16 staff ( H ).
f 7
Mt. Morris Senior High School - population:
235 students, 25 staff ( H).
e I
8.
iver Community Scho W ulation:
413 stud sa (Mel mey affidavit, p. 10).
9 Lorado Taft Field Campus - population 90 to 150 students, 30 staff (Interview with John Sanders, facility manager, Turesday, February 8, 1983).
k 10.
Village of Progress - population:
100 students, N
16 staff (Interviews with Robert Glazer, Executive Director, February 9 and February 17, 1983).
11.
Byron Mary Morgan School - population:
388 students 43 staff (Survey responses from Super-intendent Bill Brown, January 1983).
12.
Stillman Valley High School - population:
462 students, 33 staff (Miller Affidavit, p. 10).
13 Meridian Junior High School - population:
341
)
I students 20 staff ( g).
fu 14.
Highland Grade School and Early Childhood -
population:
417 students 20 staff ( g).
The following camps and recreational areas host transient populations which have no basement or windowless areas available to them:
)
f f-Q 1.
The Byron Dragway - population:
500 to 1500 persons on weekends: 12,000 maximum.
No shelter whatsoever.
(Phone interview with Brenda VanHollen December, 1982: interview with owner Ron Leek cited in Byron FSAR 2.13 4.:)
2.
Lake Louise - population: 2000 to 3000 persons:
4060 to 5000 maximum reached three times per year.
No Sheltering available.
(Phone interview with Connie Jeffry, December, 1982).
3 Castle Rock State Park - population:
up to 400 persons on weekends.
House, office and barn in park.
(Interview with site Superintendent.
Grant Afflerbaugh, February 4, 1983 letter attached from Mr. Afflerbaugh, dated February 8, 1983, as Exhibit $$).
4.
Lowden Memorial State Park - population:
450 overnight ca=pers.
Sheltering in vehicles only.
(Intervievis with site Superintendent Roy Hayes January 14, January 26 and February 3, 1983).
5 Camp McCormick Girl Scout ca=p - population:
100 to 150 campers.
Tents used as shelters; wooden buildir.gs, no basement.
(Interviews with Director, Ruth Little, January 13 and February 4, 1983.)
6.
Oregon Park District - population:
500 visitors.
No sheltering facilities.
(Phone interview with Tony Kubat January, 1983.)
)
7 Camp Em=aus - population:
60 to 80 visitors
3 maximum of 130 reached two wacks per year.
}
(Phone interview, December, 1982.)
S,
- 8.
Lake LaDonna - population:
1000 to 1600 visitors; as many as 3000 on holidays.
(Phone interview with Lemont Gaston, February, 1983.)
9 River Road Camping and Marina - population:
800 persons staying in tents or campers.
(Phone interview with owner, January, 1983.)
10.
Motosport Park - population:
2000 spectators; 10,000 spectators twice per year.
No shelters.
(Phone interview with Joseph Vincer, December, 1982.)
Q.
Have you translated this data into reduction factors as explained earlier?
A.
Yes.
After discussions with facility owners identified in the last question and administrators I have generally located those facilities on the tables provided in IAEA-Planning on Representative Reduction Factors for Deposited Radioactivity (Table 1 in Appendix I, p. 49a, IAEA-Planning and Representative Reduction Factors for Cloud Source (Table 2 Id.).
I have attached these tables tc this Affidavit as Exhibits B and C respectively Table II assigns a reduction factor of 1.0 from cloud source radioactivity to those populations which are outside or in vehicles (Exhibit C).
In the Byron EPZ (3 mile radius), this would include thousands of persons at the Byron Dragway, the Motosport Park, the River Road h
Camping and Marina. Lake Louise Castle Rock State Park, Lowden State Park, the Oregon Park District, and Lake
\\
l
y LaDonna have similar sheltering potential end are located in the Byron Station EPZ.
The reduction factor for de-g
}
posited radioactivity for these populations would range between 0 5 (vehicles) to 0 7 (outside).
(Exhibit B.)
According to IAEA figures, wood frame structures 1
without basements have poor cloud source reduction facters (0 9) and moderate deposited radioactivity reduction factors (0.4).
Camp McCormick Girl Scout Camp. Camp E=maus, Lorado Taft Field Campus, and a number of other recreational structures and private homes are facilities of this nature.
Knowledge that sheltering of at least 2908 school children will take place in structures without basements or windowless areas (listed above) will also be of imper-tance in determining the value of sheltering as a pro-tective action.
As seen in Table 1, the reduction factor for deposited radioactivity is far superior in buildin6s with basements (0.03) than without (0.2), and in Table 2 the cloud source reduction factor for masonry structures without basements is about 0.6 while those with base-ments have a more favorable reduction factor of 0.4.
(Exhibits B and C, respectively)
Q.
ave you made similar inquiries re5arding sheltering h
poten 'al for the less-mobile populations in nursing rt.Dv" N
homes?
\\
A.
Yes, I have.
I have "stributed excerpts from the EPA-PAGs and the IAEA (Id.)
- sheltering to nursin6
~
home administrators Thomas Bowes and r-x,Montel.
_ s r
)
~
During onversationsinDecembmroflastyearan[the first two no ths of this year, they have exp ssed concern
}
\\
about the feasib lity of sheltering.
N *ther facility V
has basement or win wless areas in Ahich to shelter.
r Both Mr. Montel and Mr. Bowes a e/ aware that ve'ntilatio N
\\
can be restricted by turni off kitchen fans and shutting !
/
?
\\
doors and windows.
They till f' eel that, due to a rapid l
estrictiono\\
f ventilation would natural ventilation,
\\
have to be engine ed.
These are all particularly impor-t.%vacuation i
tant consider ions in light of the fact t for a s e percentage of nursing home patien has been own to be infeasible (Affidavits of Bowes an s y
M tel).
N Q.
Is there any consideration given in IPRA-Byron, Revision 0,l to administering potassium iodide to persons for whom a
{,
timely evacuation is not possible?
A.
No, there is not.
Q.
According to Commonwealth Edison's Generic Generating Stations E=ergency Plan ("GSEP"), what document will be used as a basis for recommendations to off-site authorities for protective actions for the off-site public?
k A.
Section 6 3 1 of the GSEP states that the EPA report i
EPA-520/1-75-001, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" (" EPA-PAGs"),
will be used for this purpose.
Q.
According to NUREG 0654 FEMA Report 1. Revision 1, what document is to be used as a guideline for state and local authorities in establishing the capability for implement-ing protective measures including sheltering?
/
s 1
A.
Saction II.J.9 cf NUREG 0654 calls for ccmpliance with
.k
}
EPA-520/1-75-001, PAGs.
,,s Q.
According to the EPA-PAGs, what are the prerequisites fcr a proper choice between sheltering and other protective measures?
~.
A.
Planning.
Planning is described in the EPA-PAGs as the gathering of information needed to select the optimum alternative in an immediate response (at 1.2).
This will include an analysis of local conditions and constraints and any other factors necessary to determine the viability of each protective action (1.2-1 3).
For sheltering this implies an assessment of the availability of shelterir areas as well as their shielding effectiveness and air changes per hour.
s Q.
Have you found any evidence that Com=onwealth Edison
(" CECO") or IESDA planners have done the necessary site-specific investigation into the feasibility of sheltering as a protective action?
A.
No, I have not.
Despite the fact that both the Applicant's GSEP (at 6 31) and Byron Annex to that plan include sheltering as among the protective measures it could I{
recommend to off-site authorities in the event of an emergency, the Applicant has, to my knowledge, made no attempt to study the protective value of sheltering for I
populations around the Byron plant.
I have interviewed school officials, park rangers, nursing home administra-tors, and other special facility representatives and have h
yet to hear of a single attempt by planners to investi6 ate i
the availability of suitable sheltering facilities.
va 3
Stats plannars htva been equally nsgligent.
Volume 1 of the IPRA and the Byron volume of that plan indicate a range of protective actions which include sheltering (IPRA-Byron, Revision 0, VI (2), pp.11-12), but in my discussions and interviews I have found no indication that state planners have made the necessary determination of e
I
~
dose reductions possible through sheltering.
My findings are further supported by Affidavits of Montel (p.2),
}
Bowes (p. 6-7), Miller (p. 10), Turner (p. 10), Maloney (p. 10), and Lamb (p. 6).
Q.
oes the IPRA-Byron, Revision 0, make provisions for D
U#
pe ons without vehicles or those unable to transport pL D'
thems ves in the event of an evacuation?
2-4 A.
No.
The PRA-Byron, Revision 0, does not include means for protecting those persons whose mobility may be
}
impaired due to such factors as institutional or other confinementas\\
developed in NUREG 0654 II.J.10.d and
\\
required by 10 CFR 50.47 (b) (10), which stipulates that 4
a range of protectiv\\
e' actions must be developed for the
\\
plume exposure pathway EPZ for the public.
\\
The IPRA-Byron, Revision 0, designates school
\\
buses, the Oregon police, and the Oregon Ambulance Service to evacuate those persons who do not have adequate or readily available transportation \\.. IPRA-Byron, Revision 0, VI (2), pp. 124, 148, 164, 188, 208. 224: VI (2a), p. 27:
\\
( 2c ), p. 19 : (2d ), p. 17 (2e), p. 30s-(2f), p. 19:
N VI (3), p. 3
'\\
)
\\
I.
During an evacuation the use of schael buses as
\\
vehicles for evacuation of the general public
ca 1
with ut transportation is incapable of affording i
}
m prom t and timely evacuation of that population.
A.
hrough interviews with School Super-i tendents Miller, Turner, and Maloney during February, 1983, and Ogle County
\\
I Assistant Superintendent Charles Hayes during\\
sthe week of January 17, 1983, I ermined, dalbitId(p ti en have d of this t'estimony, that the number of school buses owned and operated by school districts are inadequate to effect a timely evac ation of schools in the EPZ.
B.
There are no posted school bus stops or routes and there.is no plan or provision to inform the public as to where they are to Coyreg3Te:15T t.._.'..
IFRA-BSTon, Revision O. VI (3),'p. 3
" Populations
\\
with Special Transport,ation Requirements."
5 The entire Sheltering Guide VI (3)
\\
pp. 1-4, is attached to'$his Affidavit
\\
as Exhibit D.
C.
School buses are considered unsafe for i
transportation of special facilities.
\\
1)
Interviews with Charles L,amb Director
\\
of the Ogle County Educational Coop
\\
during February.1983, indicated
\\
that the students at the Mt.\\. Morris a
\\
r Trainable Center cannot be safely evacuated in regular school bu\\ses.
\\
i (Lamb Affidavit at 5)
)
Interviews with Thomas Bowes, Administrator of the White Pines Nursing Home in Oregon,'during December,1982, and January,1983, indicated that he has a'pproximately c
\\
15 persons for whom bus travel is unsa e.
(Bowes Affidavit at 4) 3)
Inter i,ews with Gary Montel,
\\
Administrator at Pinecrest Manor Home for the Aging during January
\\
and Februar.y, 1983, indicated that
-s bus travel would endanger the health
\\.
and safety of thirty to forty s
persons at his facility.
(Montel i
Affidavit at 6) '-
?
II.
IPRA-Byron, Revision 0, plans {ortheevacuation
\\
of homebound private residents are incapable of
\\
affording a prompt and timely evacuation of that
\\
population.
VI (3), pp. 2-3 (Exhibit D.)
\\
A.
Lists of shut-ins are not available as stated at VI (3), pp. 2-3. \\ (Exhibit D.)
\\\\
3.)
The CECO " polio list" is presently
\\
kept in Dixon, too far (161. miles)
\\
away from the Ogle County EOC to be of timely use during an emer\\gency.
\\
2)
The plan claims that the Yellow h
Bird Senior Citizens Center ma tains a list of shut-ins which is one
g ssveral. lists for Ogle County.
phone conversation with Jane Reid, D~ rector of the Yellow Bird Senior Citizens Center, dated F'ebruary 20,
\\
1983, revealed that the Yellow Bird I
Cente'r has the capability of com-piling \\
list for the Oregon area only.
B.
The IPRA-Byron, Revision 0, plan's reliance upon the Orego\\n Police Department and the
\\
Oregon Ambulance Service for the trans-
\\.
portation of nurs~ing home patients and homebound private \\ residents is inadequate
\\(E'hibit D.)
and unworkable.
x 1.
Providing transportation to t e mobility impaired t
is not a responsibility which is assigned to the Oregon Police Department or the. Oregon Ambulance
\\
Service in either the Oregon Participating
\\
Agencies su=maries, IPRA-Byron, Revision 0,
\\
VI (2) pp. 161-162, pp. 169-170, or the Annex 2c titled " Oregon Procedures" M (2c)
- p. 13-16,
\\
pp. 25-26; Figure G.2, e.l.cc, p. _97; the Oregon
\\
Agency Responsibility Matrix gives no' indication
\\
that transportation of homebound private residents
\\
or nursing home patients will be provide'd by
\\
either the Oregon Police Department or the.0 regen Ambulance Service during evacuation.
IPRA-yron.
I Revision 0, (2) pp.13-16,161-162; (2c)pp.\\25-26, 169-170, and Figure G.2, e.l.cc, p. 97 are
v.
/4 t tached to this Affidavit es EY.hibits E F,
an G, respectively.
g 3.
The Oregon Police Department has five full-time and fo\\ur part-time officers with two squad cars charged ith the following responsibilities:
~
R.
i=ary responsibility for public
\\
e no'ification, traffic and access t
\\
control VI (2) p. 162.
(Exhibit E. )
\\
b.
standard operating procedures for law
\\
enforcement and crime prevention
\\
activities VI (2c) p. 15 M.
\\
c.
provide transportation for shut-in
\\
populationyfOgleCountyVI(3)p.3 (Exhibit D. )
3 The Oregon Ambulance Service has 20 volunteers and two ambulances and s charged with the i
following responsibilitie's:
R.
assist Oregon Pol ce Department in
\\
notification of the.public, traffic and
\\
access control if re' quested M (2c)
- p. 26.
(ExhibitF.)\\
\\
b.
follow standard operati'ng procedures r
for the fire prevention and emergency
\\
medical services (Primary Agency M).
.\\
c.
assist the Oregon Police Department withlawenforcementVI(2)p\\
97 (Lx.hibit G. )
\\
'\\
d.
Provide transportation of both private residents and nursing home patie s in
~
/' ~
t e EPZ who may not have adequate or Sg readily available transportation VI (3)
- p. 3 (Exhibit D.)
4.
The nu=ber of mobility i= paired persons in the
\\
EPZ for whom, according to the plan, the Oregon
\\
e Police and the Oregon Ambulance Service must s
provide transport, must be pieced together from various sources.
\\
1.
There are thIree nursing homes in the
's EPZ.
Administrators of two of these facilities have indicated that abcut a third of their residents will require transport of greater sophistication than a regular bus (Affidavits of Montel, I
pp. 4 and 6, and Bowes, pp. 2 and 4).
This is a total of about 50.
Adding one third of the other, nursing home's i
population brings the figure to about 80.
(A phone interview in January,
\\
1983, indicated tha the Neighbors
\\
Nursing Home in Byron had 94 residents.)
b.
Jane Reid, the Director of the Yellow Bird Senior Citizens Center, s,tated in a letter dated February 4, 1983, that her facility delivers meals to as many
\\
as 16 homebound persons each day 5.n Oregon alone.
She also noted that 20-30 additional Oregon area elderly are pro-
\\
vided with transportation to the center
o n a daily basis.
These people have no 9) o her means of transportation.
The le ter from Jane Reid is attached to this. affidavit as Exhibit H.
JoycegAllen, R.N.,
of Allen Home Health c.
\\
Agency,,Inc., responded to my inquiries
\\
on the same day, February 4,1983 She
\\
reported that her agency cares for ten
\\
patientsiptheEPZ,allofwhich i
would require assistance.
The letter i
from Ms. All'en is attached to this i
Affidavit as Exhibit I.
\\
2.
The Recional Health Survey (1978) by
\\
Comprehensive Health Planning of North-i west Illinois, r.eported that 2 37, (497 persons in EPZ) of northwest Illinois residents have mobility limi-
\\
tations.
More significant is the 1.17
\\
who must either stay in bed all or most i
of the time or use a wheelchair or i
walker in getting around Id.
The table
\\
from which this data is taken is attached i
to this affidavit as Exhibit J.
Since
\\
21.622 permanent residents live within
\\
the EPZ, approximately 238 are confined
\\
to bed or home.
(Exhibit J.)
\\
5 A member of the Oregon Ambulance Service Board
\\
)
of Directors, Carl Swon, has indicated to me in interviews dated February 7, 14, 16 an 17 that
/t o
all f these tasks requested simultaneously would beyond the capabilities of the Oregon
-}
Ambulance \\ Service.
\\
A.
He as stated this in affidavit.
b.
The Oregon Mayor, Jim Barnes., who is
~
N also an ambulance service member, read 5
s the Swon Affidavit on February 16 and
\\
concurred in Mr. Swon's assertions.
\\
c.
Mr. Swon indi'cated during those meetings i
that about 4-6' ambulance service volun-
\\
teers would remain,in the area to conduct emergency operations.,'
Mr. Swon was not sure if he personally would stay or ccY~
evacuate with his fa=ilh, Q.
Hav otherpersonswithexperienceindealingwithvolunte5
~
or part-time personnel commented to you regarding the Q-availab ty of these personnel during a radiological k
M emergency?
L A.
Yes, individu s in key coordinating positions such as school superint ndents and ambulance service directors have indicated that they e unable to notify personnel when other employ =ent scatt'ars them throughout the county.
Additionally, the willin\\gness of volunteer, part-time personnel to serve as emerg\\ency workers during a nuclear disaster at the Byron Station i not taken for granted by individuals with close personal knowledge of ambulance,
\\
nursing home and bus service personne'1.
(Affidavits of Bowes, p. 6 Miller, p. 6, Turner, pp 6-7, and
- flaloney,
- p. 6.)
Others are certain that most volu er, part-time
.1 personnel will no e available (Swon, p. 5: Lamb, p. 4).
}
Q.
Does the IPRA-Byron, Revision 0, rely on the availability of volunteer personnel?
/O A.
Yes.
The contribution of volunteers to a number of essential emergency services, including notification of T-the public g ccess and traffic control, transport of the mobility impaired, emergency medical services, fire protection and law enforcement is the backbone of the emergency planning effort in the Byron EP2.
Fire Protection District and ambulance squad ersonnel in Mt. Morris, Leaf River, Oregon an:1 Stillman Valley are entirely made up of volunteer
\\
personnel:
-Or\\egon Fire Protection District (YPD) -
24 v nteers.
VI (2), p. 315
\\
-Oregon Kmbulance Service - 20 volunteers.
VI (2), p 13
_) g j * *
-Mt. Morris FPD and Amburin~ce Squad - 28
\\
part-time volunteers.
VI (2), p. 337
\\
-Leaf River FPD anti Ambulance Squad - 28 t
part-timevoluntee\\rs.
VI (2), p. 328.
\\
-Stillman Valley FPD and Ambulance Squad -
30 part-time volunteers.
VI (2), p. 323 B.
Davis Junction. Holcomb and Linwood Fire Protec-
\\
tion Districts are entirely made of volunteers.
-Davis Junction FPD - 18 volunteers:
\\
Holcomb and Linwood FPD - 42 volunteers.
VI (2), p. 345
~
C.
T e are en2y nina full-time firamen in the g
entire Z and these are all located in Byron.
These nine il amen make up only 26f. (9 of 35) of the Byron F1 rotection Districts manpower.
VI (2), p. 301.
D.
Many part-time bus drivers have been volunteered or emergency work.
Part-time bus drivers em oyed elsewhere will be difficult to contac in t e event of an emergency (Affidavits of Swon,\\p
- 5. Miller, p. 6 Turner, pp. 6-7, Maloney, p. 6. Bowes, p. 6, and Lamb, p. 4).
Of the school districts:
-Oregon om= unity Unit (C.U.) #220 has 11
\\
part-time, bus drivers.
VI (2), p. 309
\\
-Mt. Morris
.U. #261 has 11 part-time bus drivers.
VI', 2), p. 339
-Leaf River C.F. #270 has 10 part-time bus drivers.
VI (2, p. 333 (Interview February, 1983).
-Meridian C.U. #223 has 29 part-time bus drivers.
VI (2), p. 324.
(Interview February, 1983).
-Byron C.U. #226 has 15\\ bus drivers, seven
\\
of which are teachers and available at
\\
school and eight of which are part-time.
VI (2), p. 307 Furthermore, many police personnel in the EPZ work on a part-time basis:
~
.L4 i
e Mt. Morris Police D3partment employs 7 full time and 12 part-time employees.
VI (2),
343
-The Byron olice Department employs 8 full-time and 14 rt-time employees.
VI (2), p. 303 g e
s
-The Oregon Police epartment employs 5 full-time and 4 part-time officers.
VI (2), p. 317
%g
-The Leaf River Police Dh artment had no resource summary.
Generally, the IPRA-Byron, Revision 0, fails to indicate the number of volunteer personnel who are necessary or available to perfor the responsibilities assigned.
The plans do not (1) assess the availability of volunteers during hours in which many are employed outsie the EPZ:
(2) take into consideration inevitable personal conflicts in the responses of volunteers who have families in the EPZ: or (3) give consideration to the possibility that some volunteers who may perform well in non-nuclear disasters might refuse to participate in a nuclear dis-aster at the Byron Station.
IESDA has failed to assemble data on.
(1) the work location of volunteers and time needed for their response i
to e=ergency notifications (2) the number of volunteers
-~-'
with families in the EPZ: and (3) the number of volunteers who would refuse to respond at all to nuclear emergencies.
This data as noted by the Atomic Safety and Licensing Board in Zimmer Docket No. 50-358-06, June 21. 1982
g
+.
woulc} #indicats tha nasd to racruit additional parsonnel
/u; to provide adequate response on a 24-hour basis and give
/
ocme assurances that assigned volunteers could and would -
h in fact - respond when needed.
~
?
, -, e-enP-aw=
em
. M e 8 MMW*
9
-r' Q.
/re you faniliar with the nunber of eduentionc1 facilitier
)
ituated within the plune exposure pathway of the enercene;.
p1 nninc zone?
A.
Yes.
The plume exposure pr.thway of the enercen.:y planninc,
zone 'ncludes 19 elenentary, secondary, special: education 7
co lece fSeilities.
d an Q.
Mave y:u investicat?d the adequacy of evc:aatier f_ans for the scho:Is referred te in the previcus,uesti:nr?
\\
A.
Yet, I have~.
C.
Har your investicetion allowed y:u t:
.t.ke conclusions
\\
as to whether the resteetive scheci dirtricts.0:src73 &
sufficient nu.ber\\of tures for a tinel ar.d crderi:-
transportation of tt.eir students frcr the reh:01r t:
O-
\\
receivinc sites durir)g evacuation?
\\
T A.
Yes.
The school distri'ets possess no such rer:vr:er.
\\.
Ccle County Educatienc1 Fervices Assistant Surerir.ter. fen:
Charles Hayes provided
..e d'ith a list of sch::1 tus
( ]','~Lbv s
~-
resources in an interview on\\ anuary 21, J
199?.
I have attached the list to this affi.avit as Exhitit E.
i This list and subsecuent dir. cuss.ont with !:ho:1
\\
Su.nerinten ents David Turner (Mt. Morris CO.nunity d
\\ui Unit f 261), J. Michael "aloney (Leaf River C:-.ur.ity
\\s Unit #270), and David iller (Meridian Cor.nunity '.'r.it FZ:?'
\\
\\
provided the following breakdown of stud r.t population and tus availability in the E?2 school di_tricts:
esw
\\
Number of Available Duses' School 31siciet Students Fuses Capacity Oregon C.U. *2 1,237 11 625 Meridian C.U. f22, 1,330 18 1,138 Byron C.U. #226 935 12 780 Mt.'Xorris C.U. #261 767 7
420 9
Leaf' River C.U. #270 41 7
462 Total 4,682 55
?,z25
-\\
O.
How id school adninistrators respond to cuertione recard '
- ~ ~
ing th( feasibility of an evacuation durinc but trane-portation of children at the commencement or termination
\\
of the school day?
\\
A.
(1.)
School districts in the EFZ possess neither the cepability nor the nu=ber of buses necessary to afford 6-transportation for the evacuation of school children during such times of day.
It has come to my attention that communication with school buses is insufficient or non-existent (affidavits of Miller, p. 5, and Maloney, N
i pp. 5-6); and that multiple ' routes and trips will mean i
that the school population will be widely dispersed between those in transit and those 1ccated at each sch:o1 site.
(2.)
The Mt. Morris Co..munity Unit f261, Meridian Community Unit f223 and Leaf River Com. unity Unit #272 school districts do not maintain the capatility to prc.;tly summon part-tine bus drivers who are empic ed elsewhere
~,
\\
\\
a.g
- mm.
5 during the day (affidavits of Turner, Miller and Maloney).
iD The scho 1 superintendents have also asserted in intervie.:s
\\
and in their affidavits that many bus drivers will not be available f r evacuation driving due to family; concerr.s.
5"I(,.b They have fu\\
rther stated that the number of bus drivers
\\
i willingtopzr\\cipatewilldeclinevitheachsuccessive 4
l trip (affidavits of Turner, pp. 6-7; Miller, p. 6; ar.f and !:aloney, p. 6)\\
(3.)
School superintendents have clearly stated in
\\
i l
interviews and affidavits that they have been denied en s.((,.b
\\
active role in er.erceney,iplanning.
The su.r.erinterdents do not consider evacuatior. plans fer their facilities tc
.\\
\\
l be adequate or capable of implementati:n (cffidatits cf l
Turr.er, ': iller and ?:aleney).
\\
N 0
" hat, accordinc to IPEA-?yron,iRevision C, vill be the j
etercency response rcle of the' Cele Ocur.ty Superir.ter. der.
of Educational Services?
A.
The I?RA-Pyron, Revision 0, states thet the Ccle Cour.ty Superintendent of Educational Serv \\'ces shall and dispatch bus resources from outside the effecte' osV' j
\\
secter and fr:n outside the II. tc Feh ols and : t:<. c r
\\
populatiens within the I??. which re.uire artistar.ee.
I?R.'.-Eyron, Revision C, VI (3), p;. '?.\\'; (I: :.i':it :} ;
i
\\
l VI (2), p. 12/.; and a n:te at Fe: tion In the l
\\
l Shelterir.c Guide are r.ttr.che? t0 this affid:vit as i
\\
E.xhilit L.
I
A7 C.
In your investicatien Of the ade uccy of the 23F.:. :yron, h
Revision C, have you made any findincs relevr.nt to thir facet of the plan?
A.
Yes, I w i 5': t
.make k. wn the f:ll;Yir.c:
(1.,%
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have to be carried out by cor.mercial telephone lines as t'he putli:
s r.otifie.
d subject to overloa d (4.)
5.hool districts would te hard 7.e. esc' te evaru.-te sone sectors cf the ET7. even if utual nid vere ta te rendered; e.g.- 'nd into the est or tcet/r;;t.. sert
,.\\v'\\-
W,f requirinc evacuati:n f Orecen an "t.
" orris woul' d
necessitate the evacuation of 959 school childrer. and abeat 400 institutionalir.ed trr.r.s :rta tion deper.d er.t persons rcre than the two school 64r.tricts carr;inc et: 7 M ':.
I N
n/.
(5.)
Coordinat n he buc resources will require ad:'itienalgd>-
i
)
tine not accounted for i he CECO Evccuttion Time Esti.ates-k.
Eyron.
(6.)
5.e cooperation of school superintendents outside
\\
the E22 i not certain.
The Superintendent of Noche11e
\\ L'.. v.-
e High School,
_ 12, Dr. Melvin Smith, stated to me in a
\\
i telephone conver tion en February 4, 199?, that his district's buses wou - not be available for use in evacucting potentially aminatedareas.(Theodre Gapinski, Superintendent of restville Con. unity " nit F2M,
reported in a survey dated Janu ry 24, 199?, that he hv not been contacted by county or st ECI. officials reccrdinctheEyronI..ercencyEesp:nseglan.[.A.632, s
(7.)
Che ability of school districts outside the I?7 to assist in the transportation of students or the cenersi populace inside the E?2 is very licitad:
(a.)
The. perintendents of tvo Ccle C:unt" districtr outside the Ee. have esti=ated Ionc =ctili:stien tines.
b Dr. James Egan of ngs Consolidated Community l' nit y
f144, stated in a sur y returned January 24, 199?,
3 that one to two hours wo d be required to nobilize pernonnel sufficient to man
.at district's availatle c wn, buses., In a survey returned Ja ary 24, 195?, The:d:re Gapinski of Forrestville Con: unity " nit #221, c i t e :'
two hours as necessary for mobilizati of drivers. (EMJZ.)
(b.)
The availability of these bus drivers would depend h [#
on their willingness to enter a contaminated recien
)
one or more times.
s (c.)
The distL os over which non-t'?Z school buses must travel will 1 it their ability to offer timely g
- 3. lf 7
assistance in the tran port of I?2 school populations.
Q.
Have rovisions been made to evacuate those non-public (ow
\\without available transportation?
school
=
% A.
The schoo1 fac.ilities not incorporated as part of one g
particular\\ chool district do not possess sufficient vehicles for timely and orderly evacuation.
(1.)
During t e weeks of January 3rd and February 7th, 1953,
\\
I had two conversations with Jessie B. Hinkle, the Admin-istrative Director of the Oregon Day Care Center (OD00),
I have collected the ollowins information on that fceility:
(a.)
The ODC0 has 42 students presently, but is
\\
licensed for and hhs previously utilized its capacity
\\
of 64 The center has seven staff = enters, of which
\\
three to four are workihc at any one time.
(t.)
The OD00 owns no ve eles and has ne plan.-
which would give staff access to any tus services
\\
during an energency.
Stcff v icles, when available, are not sufficient to transpor nore than ten children.
(c.)
The OD"C serves families f on Cregon, Dixon and Mr. Morris.
Parents are employed
'n nany different areas around Osle County.
If parer s' vehiclen are
\\
.to be used to transport students during an exercency, so.e 4C-60 vehicles will begin arriving at or near the day care center.
The CD00 is located on he corn =r of Second Etreet and East YashinCton Street (P.oute U }
3 e
d cc eral hundred foot fron the only eastern passece>:a" out f Oregon --- the 't.'ashington Street bridge.
}
_j (d.)
There are no provisions in IIR/.-Syron,
(*
0, for the notification or evacuation of Revisi the CDC.
nunber of conversations with Charler 1a.-1, i
(2.)
Through the Director of the Ccle Cour.ty Educctior.a1 Cooperative, p.
a survey conplete by Mr. Lanb, and the affidavit
- .ich he
'r. a.e su'...4.t*.c.'.
o r. t e =.~..=. '. u~ e n ~.~,.. era. e '. r. a. c.e a...*.=.c..*.*..-'..,
-~
is apparant that the OreCen J.nnex Figh Schoci in Oreccr. r.:
"orrir have vary the Ogle County Trainable Center in
t.
\\
little he.e of self evncuati:r. (Lani r.ffidavit).
... 4. +.<z.e. r. e.. 4.,. '. '..".
C r. c.
a..-..*..*s^'.=..' .
..... a w-t....e c...
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.f
s timaly d ordorly Gvacuation la further hindered by the _]
fact that he only route to the campus is also the only exit for ove 100 recreational vehicles and many more day visitors who fra uent Lowden State Park during the su==ertime.
~
4 (4.)
Through a survey d interviews (February 9th and f.s 17th, 1983) with Robert ser, director of the Village of Progress Inc., I have ascertained the following infer-
\\
mation on that facility's ability to self-evacuate.
The
\\
Village of Progress has about 10 students at the present time.
The facility presently contracts with KAL Buslines Inc., for two buses, one ofN ich is available I
at the facility during the day.
Q.
Hav you investigated the availability of emergency medica facilities with trained staff, equipment, and written p tocols for responding to a radiological emergency at he Byron site?
A.
Yes, I have.
W th input from Radiologist Dr. Celow Edwards and Dr. Jo n Hansen of Rockford, I adapted New b
York Public Interest esearch Center ("NYPIRC")
Radiological Emergency sponse Survey (developed by James L. Murphy MPH and Jo n E. Harriss MPH) to address the hospitals in the nine cou ty Regional Health Service Area of Northwestern Illinois.
' ile the specifics of the survey were developed by those the Medical and public health professions, the para:e rs of the survey were determined by NUREG 0654 II (L and which address h
the level of preparedness (in terms of equi
.ent, training
3x of p rsonnel and pre-establishsd protocols) required of 3
medica support facilities surrounding nuclear stations.
I also h ed to determine from the survey the extent to which CECO and IESDA planners had assisted the hospitals surrounding the Byron Station in developing a compre-hensive regi,o al response plan.
A copy of the survey is attached to thi affidavit as Exhibit ff.
The survey was described by Dr. David Jeblonowski, ER Physician at St.
Anthony Hospital 1 Rockford as " thorough" and "a real eye-opener."
Hospitals were g nerally uncooperative.
In mid-December, I sent surve to all 15 hospitals in Illinois Region One which include all hospitals within 30 miles and some as far as 70 mil distant.
Throughout January I made follow-up phone call, mailings and carried on a lengthly ca::paign to convine the Illinois Hospital Association (IHA) Survey Co==i tee to approve the survey.
The IHA, however, reco== ended th t the survey not be completed because.'.itigation invo ing the hospitals could ensue.
Despite this I receiv d four co :pleted surveys:
from Rochelle Community Hos ital in Rochelle, Highland Hospital in Belvidere Sandwie Con = unity Hospi-tal in Sandwich, and Savanna City Hospita' in Savanna.
The tabulated results of these surveys are resented in a table attached to this affidavit as Exhibi et.
Of the respondents to my surveys
---no hospital had staff training in the tr atment I
of radiation injury and the decontaminatio of e
~s s
Patianto (though one nurse at hospital #2 had had 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of hazardous materials trainin6 in an Jr course).
---s if evaluations of staff preparedness to
.ge a major radiological disaster (Imore than ma 5
5 vi tims) were "1" "3" and 2 "O's".
---no hos ital reported having a decontamination
- table, contamination showers or lead containers for dispo 1 of contaminated articles and only one has an solation room.
---only two of e four has a radiation survey instrument.
---three have writ n protocols for decontamination procedures but no e could claic to have practiced the procedures.
---one of the four has protocol for dealing with a major radiological "saster (5 or = ore victics) but the plans have neve, been tested.
---self evaluations for fac ity preparedness for such a disaster (0-10 seal ) was two "O's" and two "2's."
---none of the hospitals has eve been contacted by anyone from IESDA regarding the Byron E=ergency Response Plans and none are awar of any efforts to assign a support role to their acilities.
While these respondents are approximat ly equal in size and possibley representative of the 12
. aller Region One hospitals, the three Rockford Hospitals ha e received j
special attention.
Throughout December, 1982, d
3H J
uary, 1983 I cada attsspts to obtain information con rning the preparedness of these three hospitals via surve and interviews.
Dr. Jeblonowski, Head Emergency Room phy ician at it. Anthony Hospital had completed the survey hen administrator Robert Flodin intervened.
~
Likewise, Dr.
eene at Rockford Memorial Hospital ("RMH")
was essentially ooperative and discussed decontamination capabilities of th t facility with me during the week 6
of January 3 Admini trator William Dilts, however, did not see my inquirle regarding Radiological response capabilities as "any of (
) business."
RMH is the f
support medical facility des'gnated by CECO for the Byron
(
~7 Station.
(GSEP Byron Annex BY 4-4).
The present state s_,/
of RMH preparedness is highly re vent since both Dr.
Keene and William Dilts indicated t me that there would be no enhancement of the RMH emergene facilities as a result of the letter of agreement with C o.
Q.
Have you investigated the availability of equipment and vehicles for transporting victims of a radiological accident to medical support facilities?
A.
Yes, I have.
Q.
Please describe how this investigation was carried out.
l A.
Again, I adapted a NYPIRC survey to specifically address Ambulance medical services in the area surrounding the Byron Station.
A copy of this survey is included with "Results of the Radiological Zmergency Response Survey:
Ambulance Medical Services" prepared by Comprehensive I
Health Planning of Northwest Illinois ("CHIPNI") which is
33 attachcd to th2 offidavit of Joal Cowan. Executive Director as Exhibit B.
I surveyed ambulance services in the 9 counties of Northwestern Illinois since the Byron Station is just 7 miles from the center point of the region.
I obtained a comprehensive list of 72 ambulance services from Roy Leslie Emergency Medical Services Coordinator for Region 1 and mailed or hand delivered a copy of the survey to all 72 between December 20 and December 22, 1982.
Follow-up phone calls and visits were made during the weeks of January 3 and January 10 to encourage response.
Roy Leslie received more than 20 calls from ambulance services about the survey and he, too, encouraged them to respond since he considered it to be a good exercise.
In order to assure a timely collation of survey results, the study was terminated on January 31 and all raw questionaairs were given to Joel Cowen, Executive Director of CHPNI.
Q.
What information did you obtain from the survey regarding the availability of equipment and vehicles for transport-ing victims of radiological accidents to medical support facilities?
i A.
"Results of the Radiological Emergency Response Survey:
Ambulance Medical Services" thoroughly evaluated these criteria from NUREc 0654 Chapter II, Section L.
I refer to Cowen affidavit Exhibit B question 16 on page 9, questions 21-23 on page 10, and notes 8 and 9 on page 11.
I The only EPZ ambulance service which did not respond to l
(
l
$f '
the survey was the Byron FPD.
I-2 hed=Esiva Tire Chief
}
Steve Walters on February 4 if his ambulances woul e
used to transport contaminated individuals to supporting hospital.
He responded that he didn't
. ov.
.That hasn't been worked out yet."
The on Fire Protection District is pamed in the Byro nnex to the CECO GSEP as g
providing ambulance servi s for the Byron Station.
(BYA 4-4) as is requ ed by NUREG 0654 Chapter II, Section B.9.Acco ing to IFRA-Byron, Revision 0, the Byron Fire otection District doesn't have any radiation survey instruments or protective equipment.
IFRA-Byren, Rev ion O. Chapt. 2, p. 301, Byron Fire Protection strict Resource Summary is attached to this affidavit v v hibi t O --
ne Q.
Did e survey address any other areas regardin6 the -
prepare.ess of a=bulance services to respond to a radiologic emergency?
A.
Yes.
A=ong other things, the survey results provide data N
showing the inadequacy of training for ambulance Corps N
members pursusant to'NUREG 0654, Chapt. 2. Section 0 and l
\\
L.
I refer to Cowen affidavit Exhibit B, questions 5-9 N
on pp. 6-7 and notes 1-5 on pp. 11-12.
N The survey results indicate the almost total absence
\\
of protocols for responding to a' radiological accident
\\
and no clearly defined roles for ambulance services,
\\
pursuant to NUREG 0654, Chapt. 2, Sections A and L.
I Ns refer here to Cowen affidavit Exhibit B, questions 14-19
\\
)
on pp. B-9 s
g, Ac ording to IPRA, Volumo 1. Chapt.10 and IPRA-Byron, Rev*sion O. Chapt. 2, Section M, training is to
)
be provided r personnel involved in emergency response functions.
Accogding to IPRA-Byron, Revision 0 " Specific
,t training for emer\\gency workers is performed oh a i
continualbasisduring\\eplanningprocessakmunicipa th r
ities in the EPZ of each nuclear power plant site in
\\
Illinois."
The page of IP
-Byron, Revision 0, devoted to ' Training Consideration' ( I (2), p. 381) attached to N
this affidavit as Exhibit P.
Thi's is clearly an excerpt
\\
from Volume I of IFRA which has yet'to be implemented
,' [f N
in the Byron EPZ with regards to the ambulance services and the fire department rescue squads wh ch responded to
\\
l the survey.
f_-
Q.
Accordir,to the IFRA-Byron, Revision 0, how will primary response o anizations be notified?
A.
Once the Ogl County Sheriffs Teleco==unicator is noti-fled via Nucle Accident Reporting System ("NARS") the
/
dependence on ec* ercial telephone:: and radio begins.
C Both systems are sub'ect to overload.
Carl Swon, Oregon Ambulance Servi Educatio..cl Director and employed for 20 years in telephone o==unication, expressed his opinion that the Fireband Fr uency is likely to over-load during an emergency evacua 'on.
(Swon affidavit at 4).
This frequency is used by very fire protection district and ambulance service (exce t Byron) in the EP2.
The IFRA-Byron, Revision 0 'Commu " cations Network
)
Summary' VI (2) pages 277, 279, 281, 283 re attached to this affidavit as Exhibit Q.
There are no ovisions
gy m a
t madoM th9 notifiention of Winnebago County officials and su officials are not included in the ' Radio D
\\
(Exhibit Q).
Co==unic tions Network Summary' Emer, ncy notifications and communications with e
local munic allties will be through commerciatl telephone
~
(VI (2), p. 9 All emergency communications to be f \\
carried out by' he Ogle County Superintendent of Educational Servi es must be by commercial telephone lines.
The Ogle C nty Superintendent has an on going role in coordinating transportation resources which is dependent on the integ ty of the local phone lines for hours after the pub 1'c is notified that a radio-logical accident has occu d.
Q.
According to IPRA-Byron, Re ision 0, what co==unications systems will be relied upon or mobilizing and main-taining communications with em rgency response personnel in the event of an accident at he Byron Station re-quiri.y their services for the i plementation of protective actions?
A.
The IPRA-Byron, Revison 0, states at communications between school ~ superintendents and f eld personnel will be =aintained by telephone or radio.
o=mercial phone lines will be the only means by which s col superinten-dents Miller (Meridian C.U. #223), Turner (Mt. Morris C.U. #281) and Maloney (Leaf River C.U. #2 0) can notify bus drivers that they are needed for evacua on driving.
(Affidavits of Miller, Turner and Maloney).
I It is suggerted at VI (2), p. 87 and 207 hat school superintendents David Miller and Michael caloney
39 use heir telephone or radio to comunicate with their
}
field personnel during emergency operations.
Neither Mr. Miller nor Mr. Maloney have radios with which to com=un cate with his bus drivers (Miller affidavit, p. 5:
Maloney \\
affidavit, p. 5).
superintendent Turner of Mt.
Morris C.U.'han radios for his buses but he is instructed (IPRA-Byron, Revision 0 VI (2), p. 223)nleave his base
\\
station and report to the Mt. Morris EOC.
According t the ' Byron Superintendent of Schools Resource Summary'\\, uperintendent Bill Brown has three C.B. radios with which to com=unicate with his 15 buses.
\\
VI (2), p. 307.
Continental Telepho,ne representative Charles Strand
[p.7,,
g indicated to me in a February 7 phone conversation that phone equipment is enginee\\red for average daily use.
Use of capital outlays is an\\ efficient ' upper nineties.'
The IFRA-Byron, Revision 0, ha\\s no contingency plans
\\
in the event of an overload of telephone lines.
\\
Q.
Are there guidelines for radiological emergency response N
plans in NUREG 0654 which concern planning outside of the EPZ?
\\
A.
Yes.
Protective measures to be used for the ingestien
\\
pathway are described, as are guidelines for the sitin6 and organization of host facilities.
NUREG 0654 also recognizes (persuant to planning bases in 0396) that
\\
one out of the four primary reasons for selecting a lO-mile radius EPZ was that ' detailed planning within
)
10 miles would provide a substantial base for expansion of response efforts in the event that this proved '
yo ecessary.'
(p. 12, NUREG 0654 FEMA Rep. 1. Rev. 1).
}
T e debate over the size of the EPZ continues and I have att ched a brief summary of existing argument for ex-tending the EPZ as Exhibit R.
NUREG 0654 clearly states at for the most serious accidents, protective
~ g.~..
\\
r actions would need to be taken outside the planning zones.
J.<1 p. 11.
NUREG 0654, pp. 11-12 are attached as Exhibit S.
Q.
In the event that, protective actions (evacuation, sheltering, control,of access and regress, radio-pro-
\\
tective drugs) became,necessary beyond the EPZ, would
\\
plans in place within 10 miles provide a base for the
\\
c,Y expansion of response efforts?
\\
L -
A.
No, because:
\\
\\
1.
Notification procedures outlined in BYA 4-5
\\
cannot be expanded to provide r the prompt notification of the public beyond the 10-milesEPZ.
The applicant
\\
relies on permanently installed sirens and a mobile No such sir \\
ens exist outside public address system.
the EPZ.
The applicant's alternative \\ystem of mobile public address systems is impractical fo'r larger popula-
\\
tions in Rockford Freeport. Dixon, Sterlihg and Rochelle:
no plans are in place to notify the more sp\\arsely popu-lated rural areas.
2.
The applicant has developed no evacuation time estimates for areas outside the 10 mile EPZ for use\\ y those responsible for choosing protective actions.
3 To the northeast and within the first 10-mile g
\\,
m
.-.7~__.
,.,r_
.y g-
w incre ental expansion of the planning base is most of the ci of Rockford, Illinois.
The Rockford area has a total pulation of about 204.000.
Taking the popu-lation dis ibution by ca= pus sector, we find that the
\\
Sector C (22)o withanortheastcenterline)pfpulation
\\
within the first 10 miles stands at 1,577, while a second10 miles \\
e adds 114,598 persons.
This is an increase
\\
in population by a factor of 72 7 s
\\
Si=ilarly, Sector G (southeast) has 261 persons
\\
within 10 miles, and jumps to 11,528 within only an
\\
additional 10 miles.
This is a 44-fold increase.
There is a clear ch nge from rural to urban areas.
Besides huge numerical ine eases, additional problems are caused by high density urban areas (e.g., traffic, heavy i
industry which must be shut doh, people dependent upon
\\
public transportation).
Southwest Rockford is character-ized by all of these factors.
s 4.
No plans have been made for the relocation of persons outside the EPZ.
Wisconsin Division of Emergency Government Deputy Administrator Gordon\\\\Reece has confir:ed
\\
that no plans have been made to relocate Rockford
\\
residents in Wisconsin.
5 Finally, the public outside the EPZ would be totally uninfor=ed as to the actions to be
,aken (e.g.,
\\
sheltering, evacuation) in order to protect t'he=selves frc=
\\
radioactive effluents.
The emergency plans proposed by the state and the I
applicant for the 10-mile EPZ fail to ' provide a sub-
'fL
/
/
stantial base for expansion of rosponsible efforts in the event that this proved necessary' (NUREG 0654,
}
- p. 12).
'/
Although Commonwealth Edison responded to a DAARE/
SAFE interrogatory as'follows:
"if evacuatiori or any
- j other protec,tive,.m/
easures became necessary beyond 10
/
miles, they ould be implemented as an extension of the measures anned for within the 10-mile area," such an expans' n is not feasible by present planning.
x' i
( ')
Q.
Are you familicr with CECO's " Evacuation Time Estimates for the Plume Exposure Pathway Emergency Planning Zone
)
of the Byron Nuclear Generating Station" dated December, 1982, (" Evacuation Time Estimates - Byron")?
A.
Yes, I am.
Q.
Have you read and studied the relevent regulations and '
guides for the preparation and evaluation of Evacuation Time Estimates?
A.
Yes.
I have read interalia 10CFR, Sections 50 34: 50.47:
Q<.
50 57 and NUREG 0654, FEY.A-Rep. 1. Rev. 1.
I have read and studied 10 CFR, Section 50.47 (b) (10) and NUREG 0654, II. J. 8: II. J. 10 (i), (m), and Appendix 4.
Q.
Has Evacuation Time Estimates - Byron been prept. red in accordance with these regulations?
A.
Certainly not.
Evacuation Time Estimates - Byron fails to comply with NUREG 0654, Apprendix 4 because:
1.
The stu - does not translate population data into two subg ups:
those using autos and those without autos (NURE0654 Appendix 4. II-A,
- p. 4-2).
2.
The stud does not give special attention to those house olds not having automobiles (Id II-A,p.4-3)N. NVehicle data was derived from
\\
de=ographic data,'and the number of vehicles
\\
registered in Ogle and Winnebago Counties.
N (Evacuation Time Estimates - Byron, p. 3-1)
\\
Each household is then assu,med to represent
\\
)
one vehicle because there are, numerically, enough to go around.
(Id)
N
\\
3 The otudy doss not davolopa occurate estimates of transient pcpulations using local data such as peak tourist volumes and employment data of large factories (NUREG 0654, Appendix 4. II-B,
- p. 4-3).
The study misrepresents normal and 1
seasonal transient populations.
Table 3-4
.1
" Camps and Recreation Areas Within the Emergency Planning Zone" is attached to this Affidavit as Exhibit T.
Numerous phone interviews and personal interviews with owners and representa-tives of camps and recreational areas conducted between December, 1982, and February, 1983, letters received from said spokespersons durirg February, 1983, and examination of the FSAR and a Department of Commerce and Community Affairs publication titled " Rock River Valley," dated June. 1982, have led me to conclude that the data presented in Table 3-4 is far from accurate.
Table 3-4x sum =arizes the data collected during l
my investigation of this issue.
Table 3-4x is attached to this Affidavit as ExhibitU.
Should an e=ergency occur on a summer weekend, decision makers using CECO time estimates would be overlooking 450 night time campers at Lowden i
State Park, almost 800 at Lake Louise and as many as 1,100 at Lake LaDonna.
During a holiday l
weekend up to 2,300 mmte persons would enter the I
roadway system at Lake LaDonna than CECO planners would have us believe.
.?
n 45
~ _..
4.
The study dosa not indiento the critical assump-
}
tions which underlie the time estimates, e.g.,
peak transient versus off-peak transient (NURIG 0654, Appendix 4, IV-A, p. 4-7).
N 5
The study does not address the relative signifi-cance of alternative assumptions (M, IV-A,
- p. 4-7).
6.
e study does not make evacuation time estimates fo each special facility on an individual basis (M.
I-C, p. 4-3: IV-B, p. 4-10).
The Village of Progress and the Oregon Day Care Center are listed n Table 3-2 as schools.
(Table 3-2 1.s
\\
attached as Exhibit V.)
Schools are designated
\\
in Section 4.2 of the Evacuation Time Estimates - L:
Byron as spec \\
ial facilities.
(Section 4.2 is g
(. o attached as Exhibit V.)
But evacuation time g, r
\\
estimates were not, calculated for Village of
\\
r Progress and the Oregon Day Care Center.
(Table
\\
6-2 "Special Faciliti'es Evacuation Time Esti=ates" s
\\
is attached as Exhibit X.)
\\
7 The study does not describ,e special facilities' highly individualized means\\ of transportation (NUREG 0654 II-C, p. 4-3).
he differing
\\
l transportation capabilities of the Oregon Annex School, The Ogle County Trainable \\
enter The Lorado Taft Field Campus, White Pines Manor
\\
Nursing Home, and Pinecrest Manor Home for the
)
\\
Aging are well docu=ented in the Affidavits of Thomas Bowes, (pp. 2-5), cary Montel, (p. 4-6),
'M s
Gnd Chnr1 s Lamb, (pp. 3-5, 7-9).
The public
)
schools, to have varying transportation capatili-ties to which he time estimates are insensitive.
The insensitivit isbothgeneral(a.}ldistricts have mobilization and transportation problems according to Affian\\
e.
ta Miller, Turner and Maloney) and specific (the Ore \\
gon Su it d
t of Schools can transport le\\
per n en en ss than half his student population in one trip as \\eglained in this testimony at p. M ).
8.
The study does not consider the special facilities' highly individualized mobilization times for equipment and manpower (NUREG 0654, Appendix 4, IV-B, p. 4-9).
a)
Og e County Jail inmates are, acccrding to th IFRA-Byron, Revision 0, to wait for non DZ holding center vehicles to drive to Ore on to pick them up, yet their evacuatio time is the sa=e for Oregon Bible Colleg students who can simply get into private ehicles and leave.
(Table 6-2. Exhibit,.)
b)
Stra y enough, the Oregon Annex School and the White Pines Manor Nursing Home are le to mobilize vehicles and evacuate (5N4inutes)beforetheir
\\
source of transportation, the Oregon School District, able to co=plete
\\
itsevacuation(55mingtes).
N
7/
.a f
c) a statsmant in Section 4.2 (Exhibit V) tha "The individual mobilization ti=e
)
estim tes for each special facility have be\\
e combined with the travel time out of the plume exposure pathway EPZ to cale ate the total 5pecial
\\
~,
facilities ev'acuation time (sic)" is (
,1.r pure nonsense (. 4-7).
No individual mobilization times have been calculated.
If the special fac lities are arranged
\\
in order of the distance required to travel out of the EPZ the total evacuation times line up 'accordingly.
Mobilization times are a e stant, not avariable,factorintheEv\\acuation
\\
Time Estimates.
9 Th study does not use time of day considerations for ecial facilities:
(NUREG 0654. IV-B.
- p. 4-1 m) te Pines Nursing Home has 15 staff on d +y during the day and three at SI>
night Bowes Affidavit, pp. 5-6)
..b b)
Pinecrest anor has 40 staff on duty N
during the da'y.,but as few as three or fouratnight.\\KontelAffidavit, pp. 6-7)
Time of day is clearly a varia le to be considered
)
in determining evacuation times.
o 4'9 10.
Tho otudy dooo not une cron cp2cific waather characteristics (NUREG 0654. Appendix 4. IV-A.
)
pp. 4-6, 4-7).
It is assumed in the Evacuation Time j.,g' Estimates that there will be a 307 re'uction in d
{
roadway capacity during adverse weath'er (p. 4-5).
This assumption is based on Hwy. Research Record No. 321 (1970) titled "The Environ = ental Influence of Rain on Freeway Capacity."
Rain is not the major impediment to roadway travel in northern Illinois and there are no freeways in Ogle County.
A snow or ice covered county road would have been a more appropriate case for study.
Allow me to quote the' FSAR on this, " Severe winter storms, those that produce snowfall in excess of six inches and often are accompanied by damaging glaze, are responsible for more damage in Illinois than any other form of severe weather."
(FSAR at 2 3 1.2 3.)
These stems occur five times per year in the state and average 14.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in length.
g.
The north-western area of Illinois, including the Byron Station, has the highest frequency in the state (144 storms over six inches in the last 60 years).
M.
The life of the plant then, may see over 70 such storms in addition to the two days glaze per year in Ogle County.
M
)
Bad weather has other effects on Evacuation Time Estimates including:
y 0) tha numbar of occidents increases dramatically thus slowing traffic:
)
b) snow removal duties will reduce the Ogle county Highway Deparment's and
,,'g the State Highway Departments ability to perform other tasks vitaIl to prompt 5
a evacuation, viz., notification of the public, access and traffic control (IPRA-Byron, Revision 0, VI (1)p. 27; VI (2) p. 120): and c) other emergency workers will be delayed in getting to their posts.
states explicitly,
"...a northern site with a high summer tourist popula-tion should consider rain, flooding, or fog as
);.
g the adverse conditions as well as snow with winter population estimates" (NUREG 0654 Appendix 4, pp. 4 4-7).
Evacuation Time Estimates - Byron exhibits no such sensitivity to local conditions.
11.
The study does not identify the adverse weather a
c.
frequency used.
(Id, IV-A, p. 4-6)
~
12.
The study does not present each of the evacuation time components alone, with the total evacuation time (NUREG 0654, Appendix 4. IV-A, p. 4-6) in a format as exhibited in Table 2 (Id, 4-16).
A table of this nature would have forced
)
the Evacuation Time Estimates - Byron authors to recognize other inadequacies of the docu=ent l
bb prosentcd haroin.-
13 The study does not give consideration to the impact of peak populations including behavioral aspects ( H, IV-B, p. 4-10).
14.
e study does not make recommendations for I
act
.s that could be taken to significantly improve vacuation times.
( M, IV-B, p. 4-10)
(,.
The study mentions the deployment of traffic control (p. 7 but this is hardly innovative.
15 The study does not nelude comments resulting from a review of the aft by principal organi-zations (state and local)
NUREG 0654, Appendix 4, IV-B, p. 4-10)
Q.
Are there further inadequacies in the Evacuation Time Estimates which are not related to specific portions of NUREG 0654. Appendix 4, but which still threaten the document's credibility and reliability as a tool for decision makers during a radiological emergency?
A.
Yes there are.
1.
Evacuation Time Estimates - Byron makes the I~*F
', ~,
following assumptions which are not supportable: r,n/
(Section 4.1 3 which contains the assumptions, is attached to this Affidavit as Exhibit Y.)
a)
"All persons within the plume exposure pathway EPZ when instructed to evacuate, will leave."
(p. 4-4) b)
" People in the outer primary evacuation I
)
zones will not evacuate when an inner primary evacuation zone is the only
{
^
frj sen2 to be ovacuaied."
(p. 4-5) c)
" Traffic ruler and controls will be obeyed, only the proper travel lane will be used (not shoulders or opposite D'r flow lanes)... "
(p. 4-5)
'/-
Assumptions 1, 2 and 3 run contrary to expected human behavior and con =cn sense.
The plan should consider the relative significance of alternative J
assu=ptions (NUREG 0654. IV-A, p. 4-7).
d)
"The prompt public notification systcn, which utilizes sirens, will be used.
s (Based on this system, the ti=e to notify essentially 1007,of the full plu=e exposure pathway EP2 population /#p'
~
has been estimated to be 15 minutes)."
(p. 4-5)
On the contrary, according to state plans, "Provisiens exist to warn 100f, of the population within the entire plume exposure EPZ within a 45 minute ti=e period."
(IPRA, Volume I, Ch. 5, IPRA, Volu=e VI, Ch. 2, p. 10) e)
"The people without cars will receive rides from either neighbors or designated public service vehicles."
(p. 4-5) j / ;,$.
As discussed in this testimony,
[~
l
)
no adequate plans exist for the use of I public service vehicles in transporting
cas o.;
h'osabound rocidents or those without a vehicle at home.
Relying on neighbors is a more realistic assumption but it is an assumption far ahead of public consciousness.
I
?
f)
" Adequate transportation will be h
a available for summer camps."
Summer camps are only listed in the IPRA-Byron, Revision O.
No provi-
[
sions have been made for their trans #t
'~
portation.
Ruth Little, Executive Director of the Rock River Valley Council of Girl Scouts, reported to me on January 13, 1983, that Ca=p McCormick, located in the EPZ, has about two cars for 90 campers.
2.
The acuation Time Estimates - Byron falsely claim t have obtained mobilization and loading timec for ecial facilities from administrators of those faci ities (Exhibit 1/).
IESDA officials are purported to ave obtained a 30 minute mobilization time ime required to obtain transportation and prepare to leave) from school officials.
Affidavits bf school officials Maloney (p. 9), Miller (p 9 ). Turner (p. 9-10),
and Lamb (p. 8) all deny this.
Nursing ho=es were assigned the same mobil zation times.
I Affidavits of Montel (p. 8-9) \\and Bowes (p. 8) aggressively deny the adequacy of these estimates
\\
i RADIOLOGICAL EMERGENCY RESPONSE SURVEY AMBULANCE MEDICAL SERVICES 1.
How many people are active members of your Ambulance Corps at this time?
30-M11e v
.-4 Employed Region EPZ Radius a
e4 0-10 6
1 5
.S 11-20 11 1
5 C
21-30 13 2
11 5
31-40 0
3 41+
3 y
o Mean 23.0 19.5 24.7 Median 19.0 19.0 24.0 Total 760 78 593
$a C
2.
How many of these people are Emergency Medical Technicians (EMTs)?
H a
30-M11e 5
0 4
6-10 13 3
10 11-15 10 1
6 16-20 4
0 3
21+
2 0
1 Mean 11.7 10.0 11.0 Median 10.0 10.0 10.0 Total 387 40 265
% EMTs 50.9%
51.3%
44.7%
3.
How many ambulances does your Ambulance Corps operate?
No.
30-Mile Ambulances Region EPZ Radius 1
12 1
9 2
19 3
13 3
1 1
4 1
1 Mean 1.7 1.8 1.8 Median 2.0 2.0 2.0 Total Ambulances 57 7
42 4.
Is your Ambulance Corps part of the Police or Fire Department in your area?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 24 72.7%
3 75.0%
20 83.3%
No 9
27.3%
1 25.0%
4 16.7%
5.
Hava ycu er y:ur Corps had in-ccrvico training on emergincy rarpensa to itnizing rcdiatica injury cad /cr dscentamination procedures in the past five years?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 9
27.3%
10 25.0%
dD 25.0%
No 23 69.7%
3 75.0%
18 75.0%
No Response 1
3.0%
0 0.0%
0 0.0%
6.
Have you or yEur Corps had any other training pertinent to an emergency response to above?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 3
9.1%
0 0.0%
3 12.5%
No 26 78.8%
3 75.0%
19 79.2%
Don't Know 2
6.1%
1 25.0%
1 4.2%
No Response 2
6.1%
0 0.0%
1 4.2%
- 7.,/ How many Corps members are competent in the evaluation of exposure levels?
)
30-Mile N
Region EPZ Radius
[t
Response
No.
No.
No.
Some-5 15.2%
0 0.0%
40 16.7%
None 26 78.8%
4 100.0%
18 75.0%
Don't Know 1
3.0%
0 0.0%
1 4.2%
No Response 1
3.0%
0 0.0%
1 4.2%
- Competent 19 0
18
% Competent 2.5%
0.0%
3.0%
8./ How many Corps members are competent in the evaluation of decontamination and treatment of individuals exposed to ionizing radiation?
(I N /*
g' 30-Mile Region EPZ Radius
Response
No.
No.
No.
Some 7
21.2%
0 0.0%
4@ 16.7%
None 24 72.7%
4 100.0%
18 75.0%
No Response 2
6.1%
0 0.0%
2 8.3%
- Competent 33 0
22
% Competent 4.3%
0.0%
3.7%
l 1
l.--
9 9 How prcptred cra ysur Ambulcnca Corpa memb2rs to racptnd to e major radiologicci disantcr?
/p '
30-Mile Ranking Region EPZ Radius 0
21 3
16 1
2 1
1 2
4 0
3 3
2 0
1 4
1 0
1 5
0 0
0 6
0 0
0 7
" 1 0
1 8
1 0
1 9
0 0
0 10 0
0 0
Total 32 4
24 No Response 1
Mean 1.1 0.3 1.2 Median 0.0 0.0 0.0 Rank Description No.
No.
No.
(0) not at all 21 65.6%
3, 75.0%
16 66.7%
h 25.0%
(1-4) not well prepared 9
28.1%
1W 25.0%
(5-8) generally prepared 2
6.3%
0 0.0%
2W 8.3%
(9 & 10) well prepared 0
0.0%
0 0.0%
0 0.0%
Total 32 100.0%
4 100.0%
24 100.0%
No Response 1
10.
To what hospital would you take patients who have been injured in a radiological emergency?
30-Mile Hospital Region EPZ Radius 0
1 2
Rockford Memorial 2
St. Anthony 6
1 6
Nearest Rockfori Hospital 2
0 2
Sterling Community General-6 0
2 Rochelle Community 1
0 1
l Freeport Memorial 4
0 1
Kishwaukee Community 3
0 3
Sandwich Consnunity 1
0 0
Galena Stauss 1
0 0
Dixon KSB 2
0 2
Don't Know 1
1 1
No Response 4
1 4
Total 33 4
24
% Correct (R.'GI) 6.1%
25.0%
8.3%
11.
What in tha diattaco from th2 fcrthast point in y:ur crea to this hospital?
30-Mile Region EPZ Radius Distance in Miles Distance in Miles Distance in Miles Mean Max.
Min.
Mean Max. Min.
Mean Max.
Min.
24.5 55 2
35.0 45 25 23.9 55 2
12.
What is the maximum number of trcuma or medical patients that your Ambulance Corps can transtiort at one time?
30-Mile Region EFZ Radius Total Total Total Patients Mean Max.
Min.
Patients Mean Max.
Min.
Patients Mean Max.
Min.
l 109 3.3 8
1 18 4.5 8
2 82 3.4 8
1 13.
What is the maximum number of non-ambulatory people that your Ambulance Corps can transport at one time?
30-Mile l
Region EPZ Radius Total Total Total People Mean Max.
Min.
People Mean Max.
Min.
People Mean Max.
Min.
163 5.1 16 2
25 6.3 12 4
143 6.2 16 2
l 14 Does your Ambulance Corps have a written protocol for radiological h
emergency procedures?
D' 30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 2
6.0%
0 0.0%
h 8.3%
No 31 93.9%
4 100.0%
22 91.7%
Total 33 100.0%
4 100.0%
24 100.0%
15.
Do you have a written protocol for an emergency response to accidents involving other injuries as well as radiation exposure?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 4
12.9%
1 20.0%
4 17.4%
No 27 87.1%
4 80.0%
19 82.6%
Total 31 100.0%
5 100.0%
23 100.0%
l No. Response 2 0
1 l
I
-8
16.
Do you have a written protocol for the transportation of patients contaminated in a radiological emergency?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 3
9.1%
l@) 25.0%
$1) 12.5%
No 30 90.9%
3 75.0%
21 87.5%
Total 33 100.0%
4 100.0%
24 100.0%
17.
Do you have a written protocol for the evacuation of people dependent on others for mobility during a radiological emergency?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 1
3.2%
0 0.0%
1 4.5%
No 30 96.8%
4 100.0%
21 95.5%
Total 31 100.0%
4 100.0%
22 100.0%
Don't Know 2
0 2
18.
Has your Ambulance Corps ever been contacted by anyone from ESDA regarding the Byron emergency response plan?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 8
28.6%
3(h100.0%
7(h35.0%
No 20 71.4%
0 0.0%
13 65.0%
Total 28 100.0%
3 100.0%
20 100.0%
Don't Know 5
1 4
1 Are you aware of any efforts to assign a support role to your ambulance (w/
service as a part of an integra:ed response to a radiological emergency?
30-Mile
\\p Region EPZ Radius
Response
No.
No.
No.
Yes 1
3.4%
0 0.0%
1 4.5%
No 28 96.6%
2 100.0%
21 95.5%
Total 29 100.0%
2 100.0%
22 100.0%
Don't Know 4
2 2
WV &LLo Howmanycfy}urAmbulnncoCorpamembarcwouldrocprndtocn M$ fM W f1 20.
emergcncy rc ulti from o r:dirlegical rolcaca from tha Byron nuclear facility.
30-Mile Region EPZ
_ Radius Members Members Members Responding A m Responding Responding Ag Responding Responding Avg.
Respondir 180 7.5 23.7%
58 14.5 74.4%
122 5.8 2 ).6%
No Response: Region (8), EPZ (1), 30-mile radius (7).
[ Considered to be members responding) e 21.
Do you have any disaster cabinets containing the supplies necessary for treatment and decontamination in the event of a radiological emergency?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 1
3.0%
0 0.0%
1 4.2%
No 32 97.0%
4 100.0%
23 95.8%
Total 33 100.0%
4 100.0%
24 100.0%
22.
Number of Ambulance Corps with protective equipment available for a radiological emergency.
Equipment Type of Available Totally Not Don't Know/
Equipment or Partially Available No Response No.
No.
No.
Gloves 6
18.2%
17 31.5%
10 30.3%
Gowns 1
3.0%
23 69.7%
9 27.3%
Masks 3
9.1%
21 63.6%
9 27.3%
Shoe Coverings 1
3.0%
23 69.7%
9 27.3%
l Head Coverings 1
3.0%
23 69.7%
9 27.3%
Personal Dosimeters 2
6.1%
22 66.7%
9 27.3%
Marked plastic bags as vaste containers 1
3.0%
24 72.7%
8 24.2%
~
Blankets 11 33.3%
10 30.3%
12 36.4%
23.
Does your Ambulance Corps have any radiation survey instruments?
30-Mile Region EPZ Radius
Response
No.
No.
No.
Yes 6
18.2%
0 0.0%
5 20.8%
No 27 81.8%
4 100.0%
19 79.2%
Total 33 100.0%
4 100.0%
24 100.0%
2/14/83 h IN
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15 _
i APPENDIX 3 ROCKFORD LEAGUE OF WOMEN VOTERS - DAARE/ SAFE RADIOLOGICAL EMERGENCY RESPONSE SURVEY AMBULANCE MEDICAL SERVICES January, 1983 Please complete by January 10 and return to:
Public Health Preparedness Survey 3004 Imperial Oaks Rockford, IL 61111
Page 1 l
9 9,
aggggg, _, __. > % ABOOT ADREABE:E C3PS 1.
Bat musty people ama active numbers of your W1mana Cbeps at this tWun?
maese 2.
Enr ammy of these people are Bumegency Medical hir-4 ann?
mamme 3.
Rat many antavanc== dome your W1-Q:n:ps egurata?
- .= _. _ _.
r
- 4. Is your W1-Corps 1: art of tbs Polica z Fire %-h in your arma?
cc Yes No M30GR PIEPAIEDESS PCR A WCICIIIIICAL DE:R22CY 5.
Have you z your Wi-Cceps numebers had in dce min 4m en the aw2r e to fr=4+45 radiaticn irrjury and/cu-M=-
-.;-- e y- -- - e in the past E.vu years?
Yes No Dcn't Axar
+
If TES, plasse mia tbs chert bakar.
m 4n4 5 3emmessen Temined m44 5
In Bours I
t
Page 2 e.
6.
Enve you z your
- 1 - Ce ps members had any other m ini m par *4 =a* to an energency respcase to imidM radiatica injucy and/w Wn=ticx0 Yes No Dcn't Know S
If g, planas 7 + the chart below, 1
hm
,[# ofN'l-Iangth of oates of me=4niner
< >Ccrps Manters P'=4n4 7 e -minart In Ecurs I
1 t
l 7.
2 the best of y;ur knowledge, for many of your Amh' inex:e Ccrps T-2 ass cx:npetent in the evaluaticn of P m levels?
gye
, &f t
t i
p, '
nacer Cnowledge, how many of your W1=nm Cccps k
8.
2 t N of wi in the evaluaticn of heation and aud:mes are w tre of individuals W tn 4~4dM radiaticze 1
l manour 9.
2 the best af your Wit, how rw.1 are your Seem1= rice Cbrps ~-. Eu.- - 2 to a maje =44at=4~1 disaster?
Ot:re than five perscms with radiatica injury?)
CIK2Z (2EE NtMER 0
1 2
3 4
5 6
7 8
9 10 (Not at all Cbtally l
prepared)
Prepared)
- 10 "
.=.
Page 3 4
NNN
- 10. 12 h hospital iculd ymt taka #* sde have been luj, ' in a =44a14=1 emergency?
Namp cc Hospital Iccatum
- 11. itat is the distana frt:In the farthest scint in your area to ths.s hospital?
Miles
- 12. What is the =v4== mh of mjor tratma er M4-1 patsants that l
your m1 anew Corps can enM at cme tima?
l l
NLucer
- 13. 1ent is the
r4
mm*=rr of A - - itatory m1= that your Astm 21ance Cbrps can. - -, _- i at cria time?
l l
- 19 _
o l
Page 4 i
e.
- 14. Does your Ambulance Ccups have a written r M for M 4al @ 1 emergency e_- Am?
i Yes No D:st't Know E
If m, please include a copy of the rwd with this survey.
eMM questions.
l If ul5, plaase answer the l
14a. Have tbs deczzxtambaticus p._ - > e ever been practiced?
Yes No Don't Know If M, please - lata this table.
Datas Ntzncer of Pa&-=nts 14b. In year estinacim, is this plan %=Na at this time, given l,
your gresent resources?
r no Doo e now '
Page 5 t
I e.
- 15. In the event of a -Ha191 anurgency, do you have a written 7-_-
=1 for an emergency==pream to arv-idants involving other i
indtacias as unil as radiatica egneurs?
Yes No Etm'tDtniat 4
If 3, plasse include a copy of the r w M with this survey.
If g, please ansume the *11-85 qu e==.
t
(
15a. Bas this amargency responsa,w -- L. ever been peaceitwi?
Yes No Dcn't Encw
+
If Igs, please m i-tm this table.
marcers of Par-
- pants Datas ll 1
l 15b. In yzze estinst:!m, is this plan h=4h1= at this time, I
given your 5xasant resources?
l Yes
~ ' No Dm't Rz:w.
Page 6 e*
- 16. Do you have a laitten ;- - -- - - - 1 for the ----, =wtizz1 of patiants W nated in a M a1 T -1 emergency?
Ees Ma Dca't show 4
If M, P anan h a a:yy of the l
w with this arvey.
r If 3, plaams ansume the M11 M5 questions.
16a. Have the wi L:n 1 c_- *- - - = ever been W e Yes No D:It't Kncw 4
If g, plasse mi-tm the fh11=iry table.
Datas NLucer of Parmn=m i
16b..In your estWustica, is this plan fan =4hla at this time, given your frement resources?
Yes No Dcn't Ebow 1
l
. l
l l
l Page 7 l
- 17. Do you have a deten swM fcr tte evacuatim of m1= 4At.
en others fcr mobilityAMM a M 4a1 9 1 anurgency?
Yes No Dcn't Know 4
If 5, planas include a cxgy of the ed with this arvey.
c If M, plasse answer the A11M7 questicas.
l 17a. anve the evacuatien m- - - - e ever been practiced?
l Yes No Dcn't Know I
t l
If TES, please 7 1-tm the M11 ~i-M table.
l i
l l
Dates NLancer of Par-* nam:s i
i l
17b..In your as*4==tien, is this plan haible at this tim, gived your DL zesources?
r ras No Dcn't xmow
Page 8 l
e.
T. P. gen *c7 Services and Disaster Agenc~r=~"a_*~4 ~
38-
- = b===
======4 by =v=. an. ch.
- ha
~6 Byron emergency response pled?
. m.
no e
+
E m, plasse desacibe h = imolved in this W in tbs spoon below, t
9 I
e e
e 9 - - - -
1 l
l-Page 9 19.
Are_vou aware.of any efforts to assign a support role to your Ambulance Service as a part of an integrated response to a radiolo5ical emergency?
I Yes No Don't Ebow
+
If TES, please annuar the Fa11M7 questim s.
l 19a. Please -1=4" you rela in the space providad balcw.
(Tm-In Evacuation,m-
+ m as well as hwcf treatment and
-- 5 -_ i ) Please he W +4r.
l l
-'c :
i l
l l
1Sb. Have you ever had a for:ml d4-=4m of this role with your *1arr* Cceps W7 Yes No Dcm't Ebow 19c. 1b tbn best of your knowledge, given your r- - _4 and 6-46i is your *1=nrw Corps to ful-fill this rola in the event of a =44a191 energency re-sulting..from.a bre.ach of containnent at the Byron nuclear power plant?
CDCIZ CNE NWBER 0
1 2
3 4
5 6
7 8
9 10 l
(Nbt at all (Tbtally l
Prepared)
Prepared) i t
e l
I
.~
Page 10
- 20. ils the best of you l'wwi@, how many of your Astulance Cbrps ammbecs would respond to an amargency resultizzy fmm a radio-logical release from the Syron nuclear facility?
WJ f'W (estimata) e 20s.
Pisase 7 =4a tbs basis for your answer.
1 ECtEPMDE l
l l
- 21. Do you have any disaster ah4n=ts care =4 nim the = r 14== -==vf for treatamat and '-- ---
- "=+ dm in the event of a ad4a1=ical l
emergency?
t l
l Yes No
- 22. Please indicata the znanbar (if any) of the +11M7 ruwdve equa.pnent that you have av=41=h1= in your =*siimex:es for use by your kv*=$1=rr= 0:rps members in the event of a =d4at=4=1 amer-gecy.
(P1 mass antar 0 for ncme and D.K. for Das't Kbow.)
Protective G1 cues Protective Gcams Protective M Prr*=r+4 e Shom W==
9 Protective Head Ccs-r4==
Pm W Dosimeters Plastic Bags len:$ced As w<mi=4-i m n.,emin.r.
Blanients.
s Page 11 Q-
- 23. Does your Amda21ance Qurps have any radia ice an:voy ir-w
-w?
t Yes No liiE M5Ei
+
If _us, p, lease -1=
an
- n~4 table.
e i
Type 9 of ment =rs c=1 et :m/
- of In-Data last WW Range stzunants Tasted to comrata Quo.h r.)
l t
t I
- 24. M:uld you be U1147 to provida us with list of t.% names arxi pbcme mm*=rs of your Ambu.1ance Corps==*wes s that a uny ask a randem sample of than a few questicms?
(Their snes muld r==1n ancmynous if they so desire.)
~
Yes No I have aneamlui this survey volunta ily and to the best of my ability.
s2gnature Date l
t