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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20149M2951996-11-29029 November 1996 Exemption from Requirements of 10CFR50.60 Re Safety Margins Recommended in ASME Boiler & Pressure Vessel Code Case N-514 TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20044A8111990-06-27027 June 1990 Comment Opposing Closure of Lpdr of Rockford Public Library ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20214X1871987-06-11011 June 1987 Order Imposing Civil Monetary Penalty in Amount of $25,000 Based on Four Severity Level III Violations Noted During 860721-0808 Insp ML20205Q1711987-04-0202 April 1987 Order Imposing Civil Monetary Penalty in Amount of $25,000. App Re Evaluations & Conclusions Encl IR 05000812/20100311987-02-26026 February 1987 Order Imposing Civil Monetary Penalty in Amount of $100,000 Based on Violations Noted During Insps on 850812-1031 ML20210T7321987-02-11011 February 1987 Unexecuted Amend 6 to Indemnity Agreement B-97 Substituting Item 3 of Attachment to Indemnity Agreement in Entirety W/ Listed License Numbers,Effective 870130 ML20209J3251987-01-30030 January 1987 Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl ML20213G4381986-10-24024 October 1986 Unexecuted Amend 5 to Indemnity Agreement B-97,substituting Item 3 of Attachment to Agreement in Entirety W/Listed License Numbers,Effective on 861106 ML20211B0841986-08-0505 August 1986 Transcript of 860805 Meeting Between Region Iii,Computer Interference Elimination & Util in Redmond,Wa Re Plant as-built Drawing Review.Pp 1-200 IR 05000506/20070221986-05-0202 May 1986 Order Imposing Civil Monetary Penalty in Amount of $25,000 for Violations Noted During Insp on 850506-0722.Violations Noted:Failure to Establish Radiological Safety Procedures & to Adequately Train Personnel ML20138C7301985-12-0909 December 1985 Order Imposing Civil Penalty in Amount of $25,000 Per 850606 Notice of Violation & Proposed Imposition of Civil Penalty.Licensee May Request Hearing within 30 Days of Date of Order ML20205E8741985-10-28028 October 1985 Exemption from GDC 4 of 10CFR50,App a Requirement to Install Protective Devices Associated W/Postulated Pipe Breaks Primary Coolant Sys.Topical Rept Evaluation Encl ML20102A2981985-01-0707 January 1985 Petition Requesting Aslab Grant Intervenor Appeal & Order Further Hearings on Safety of Plant ML20099L2581984-11-27027 November 1984 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20099G5381984-11-23023 November 1984 Supplemental Appeal Brief in Response to Intervenor 841106 Supplemental Brief on Appeal & in Support of ASLB 841016 Supplemental Initial Decision Authorizing Issuance of Ol. Certificate of Svc Encl ML20100K0411984-11-22022 November 1984 Submits Concerns Re Safety of Local Residents in Event of Accident & Excessively High Cost of Projected Operation of Facility ML20107H7841984-11-0606 November 1984 Supplemental Brief on Appeal of ASLB 841016 Supplemental Initial Decision Granting Authority for Issuance of Ol. Decision Should Be Reversed.Certificate of Svc Encl ML20140E4081984-10-31031 October 1984 Executed Amend 1 to Indemnity Agreement B-97,deleting Items 2A & 3 in Entirety ML20098G8841984-10-0202 October 1984 Joint Statement of RW Manz & W Faires Re Findings 3-11 Through 3-17 of NRC 830930 Integrated Design Insp Rept. Certificate of Svc Encl ML20098G8681984-10-0202 October 1984 Answer to Intervenor Motion to Reopen Record Re Bechtel Independent Design Review.Motion Should Be Denied ML20098G8901984-10-0202 October 1984 Joint Statement of Kj Green & RW Hooks Re Integrated Design Insp ML20098G8911984-10-0202 October 1984 Joint Statement of Cw Dick & EM Hughes Re Independent Design Insp ML20098G8821984-10-0101 October 1984 Affidavit of Kj Green Re Integrated Design Insp Concerning Mechanical Engineering Work ML20098G8741984-10-0101 October 1984 Affidavit of Br Shelton Re Integrated Design Insp ML20098G8881984-09-29029 September 1984 Affidavit of RW Hooks Re Integrated Design Insp Concerning Structural Design ML20098G8831984-09-28028 September 1984 Affidavit of W Faires Re Findings 3-15 & 3-16 of NRC 830930 Integrated Design Insp Rept ML20098G8811984-09-28028 September 1984 Affidavit of Cw Dick Re Independent Design Review ML20098G8791984-09-28028 September 1984 Affidavit of RP Tuetken Re Readiness for Fuel Loading ML20098G8781984-09-28028 September 1984 Affidavit of RW Manz Concerning Findings 3-11 Through 3-14 & 3-17 of NRC 830930 Integrated Design Insp Re Westinghouse ML20098G8871984-09-28028 September 1984 Affidavit of EM Hughes Re Idvp ML20098G8851984-09-27027 September 1984 Affidavit of Rl Heumann Re Costs of Delay in Startup & Operation of Unit 1 ML20098E2371984-09-24024 September 1984 Reply to Intervenor 840918 Proposed Supplemental Initial Decision.Certificate of Svc Encl ML20097E7221984-09-13013 September 1984 Agreed Motion for Time Extension Until 841101 to File Petition for Hearing Re Emergency Planning Commitment W ML20097C5311984-09-12012 September 1984 Motion to Reopen Record to Include Plant Design as Issue. Supporting Documentation & Certificate of Svc Encl ML20097B7791984-09-10010 September 1984 Proposed Supplemental Initial Decision Re Reinsp Program. Certificate of Svc Encl ML20096A6391984-08-30030 August 1984 Rebuttal Testimony of RW Hooks Re Validity of Info in Attachment 7 to Stokes Testimony Concerning Design Assumption for Plant.Stokes Info Inapplicable to Plant. Related Correspondence ML20096A6191984-08-30030 August 1984 Rebuttal Testimony of B Erler Re Stokes Allegations Concerning Evaluations of Discrepancies in Calculated Actual Stress Performed by Sargent & Lundy.Related Correspondence ML20096A6261984-08-30030 August 1984 Summary of Rebuttal Testimony & Testimony of ML Somsag, Eb Branch,D Demoss,Mr Frankel,Bf Maurer & Jk Buchanan Re Plant QC Inspector Reinsp Program & C Stokes Allegations Re Welds.Related Correspondence ML20096A6441984-08-28028 August 1984 Notice of Withdrawal of Appearance in Proceeding.Related Correspondence ML20112D5271984-08-24024 August 1984 Applicant Exhibit A-R-4,consisting of Feb 1984 Rept on Bryon QC Inspector Reinsp Program ML20112D5031984-08-24024 August 1984 Applicant Exhibit A-R-5,consisting of June 1984 Suppl to Rept on Bryon QC Inspector Reinsp Program ML20112D7441984-08-23023 August 1984 Intervenor Exhibit I-R-1,consisting of Undated List of Teutken Safety Category Insp Types ML20112D7511984-08-21021 August 1984 Staff Exhibit S-R-1,consisting of 840813 Instruction for Walkdown of Cable Tray Hanger Connection Welds ML20112D4641984-08-21021 August 1984 Intervenor Exhibit I-R-11,consisting of Undated Chronological Date Listing of Util Responses to Interrogatory 12.VA Judson to Mi Miller Re Interrogatory 12 & Supplemental Responses Encl 1999-03-02
[Table view] Category:TRANSCRIPTS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20209J3251987-01-30030 January 1987 Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl ML20211B0841986-08-0505 August 1986 Transcript of 860805 Meeting Between Region Iii,Computer Interference Elimination & Util in Redmond,Wa Re Plant as-built Drawing Review.Pp 1-200 ML20096A6261984-08-30030 August 1984 Summary of Rebuttal Testimony & Testimony of ML Somsag, Eb Branch,D Demoss,Mr Frankel,Bf Maurer & Jk Buchanan Re Plant QC Inspector Reinsp Program & C Stokes Allegations Re Welds.Related Correspondence ML20096A6191984-08-30030 August 1984 Rebuttal Testimony of B Erler Re Stokes Allegations Concerning Evaluations of Discrepancies in Calculated Actual Stress Performed by Sargent & Lundy.Related Correspondence ML20096A6391984-08-30030 August 1984 Rebuttal Testimony of RW Hooks Re Validity of Info in Attachment 7 to Stokes Testimony Concerning Design Assumption for Plant.Stokes Info Inapplicable to Plant. Related Correspondence ML20094P7721984-08-17017 August 1984 Summary of Testimony & Direct Testimony of CC Stokes on Reinsp Program.Related Correspondence ML20094R1021984-08-17017 August 1984 Transcript of CC Stokes 840817 Deposition in Chicago,Il. Pp 1-173.Vol Ii.Related Correspondence ML20094P5991984-08-16016 August 1984 Direct Testimony of CC Stokes Re Engineering Evaluations Performed & Use of Engineering Judgement by Sargent & Lundy. Suggests Need for Independent Engineering Analysis of Safety Significance of Reinsp Program.Related Correspondence ML20094P6311984-08-14014 August 1984 Summary of Testimony & Testimony of Ds Kochhar on Contention 1 Re Reinsp Program.Certificate of Svc Encl.Related Correspondence ML20094P6831984-08-13013 August 1984 Summary of Testimony & Testimony of Wh Bleuel on Contention 1 Re Reinsp Program.Resume Encl.Related Correspondence ML20094P6951984-08-13013 August 1984 Summary of Testimony & Testimony of EP Erickson on Contention 1 Re Reinsp program-inspector Qualification & Work Quality.Resume & Certificate of Svc Encl.Related Correspondence ML20093L4881984-07-30030 July 1984 Summary of Testimony & Testimony of Eb Branch Re Contention 1 (Reinsp Program,Work Quality).Related Correspondence ML20093L1811984-07-30030 July 1984 Summary of Testimony & Testimony of KT Kostal on Contention 1 Re Capacity of Sys Control Corp Supplied Components to Carry Design Loads.Related Correspondence ML20093L2721984-07-30030 July 1984 Summary of Testimony & Testimony of Ak Singh on Contention 1 Re Evaluations of Discrepancies in Cable Tray Hanger Connections,Solid Bottom Tray Welds & Ladder Tray Weld Connections.Related Correspondence ML20093L2051984-07-30030 July 1984 Summary of Testimony & Testimony of Ld Johnson on Contention 1 Re Adequacy of Sys Control Corp Supplied Main Control Boards.Related Correspondence ML20090E5521984-07-17017 July 1984 Testimony of Eb Branch Re Job Responsibilities,Educ Background & Work Experience.Related Correspondence ML20090A7981984-07-0909 July 1984 Testimony of Gf Marcus Re Pittsburgh Testing Lab Source Insp of Equipment & Components Supplied by Sys Control Corp ML20090A8121984-07-0909 July 1984 Testimony of Bf Maurer Re Analysis of Structural Adequacy of Main Control Panels Designed & Fabricated by Sys Control Corp ML20092P7921984-07-0202 July 1984 Summary of Testimony & Testimony of ML Somsag Re QA Inspector Reinsp Program for Hunter Corp.Related Correspondence ML20092P7891984-07-0202 July 1984 Summary of Testimony & Testimony of Rv Laney on Contention 1 Re Work Quality.Related Correspondence ML20092P7951984-07-0202 July 1984 Summary of Testimony & Testimony of Ak Singh on Contention 1 Re Reinsp Program,Work Quality.Related Correspondence ML20092P7941984-07-0202 July 1984 Summary of Testimony & Testimony of LO Delgeorge on Contention 1 Re Reinsp Program,Inspector Qualification & Work Quality.Related Correspondence ML20092P5541984-07-0202 July 1984 Summary of Testimony & Testimony of Dl Leone on Contention 1 Re Reinsp Program for Work Quality ML20092P5551984-07-0202 July 1984 Summary of Testimony & Testimony of R French on Contention 1 Re Reinsp Program ML20092P7781984-07-0202 July 1984 Summary of Testimony & Testimony of Wj Shewski on Contention 1 Re Reinsp Program,Inspector Qualification.Related Correspondence ML20092P7811984-07-0202 July 1984 Summary of Testimony & Testimony of Jm Mclaughlin on Contention 1 Re Reinsp Program,Work Quality.Related Correspondence ML20092P7871984-07-0202 July 1984 Summary of Direct Testimony & Testimony of RP Tuetken Re Reinsp Program.Related Correspondence ML20092P7851984-07-0202 July 1984 Summary of Testimony & Testimony of Wb Behnke on Contention 1 Re Overview of Quality Program,Work Quality. Related Correspondence ML20092N4971984-06-29029 June 1984 Testimony of Bg Treece on Issues 5 & 6 Re Cable Overtensioning,As Limited by ASLB 840608 Order.Related Correspondence ML20092N4911984-06-29029 June 1984 Summary of Direct Testimony of Jo Binder on Issues 5 & 6 Re Cable Overtensioning,As Limited by ASLB 840608 Order.Related Correspondence ML20092K7691984-06-26026 June 1984 Summary of Testimony of J Hansel on Contention 1 Re Reinsp Program.Prof Qualifications Encl.Related Correspondence ML20205H8901983-08-10010 August 1983 Public Version of Transcript of 830810 in Camera,Ex Parte Hearing in Rockford,Il.Pp 7,585-7,610 ML20205H8941983-08-10010 August 1983 Public Version of Transcript of 830810 in Camera,Ex Parte Hearing W/Ofc of Investigations in Rockford,Il.Pp 7,611.1- 7,611.71 ML20205H8841983-08-0909 August 1983 Public Version of Transcript of 830809 in Camera,Ex Parte Hearing in Rockford,Il.Pp 7,304-7,405 ML20080B3051983-08-0303 August 1983 Testimony of RP Tuetken Re Util Reinsp Program of Work Performed by Contractor Insp Personnel Prior to NRC Region III Mar,Apr & May 1982 Insps.Appropriate Steps Taken to Remedy Problems ML20080B3091983-08-0303 August 1983 Testimony of Aw Koca Re General Nature of Hatfield Inspector Training & Certification Program.Certification of J Hughes Described ML20080B2951983-08-0303 August 1983 Testimony of Ma Stanish Re Recertification of Qa/Qc Inspectors Subsequent to NRC Region III Mar,Apr & May 1982 Special Team Insps.Reinsp Program Implemented to Review Work Performed by Inspectors Before NRC 1982 Insp ML20023C7151983-05-12012 May 1983 Testimony of P Holmbeck Re Investigation Into Adequacy of Emergency Plans Re Emergency Planning Contentions.Util Made No Attempt to Study Protective Value of Sheltering Populations Around Plant ML20204F5721983-04-26026 April 1983 Transcript of 830426 Hearing in Rockford,Il.Pp 5,964-6,156 ML20069M4791983-04-25025 April 1983 Handwritten Testimony of J Hughes Re Qa/Qc at Facility ML20069K5691983-04-21021 April 1983 Testimony of Ld Butterfield Re Steam Generator Tube Integrity.Proposed Steam Generator Mods Would Minimize Tube Wear Due to Flow Induced Vibration.Related Correspondence ML20069K5631983-04-21021 April 1983 Revised Testimony of Tf Timmons Re Steam Generator Tube Integrity (Flow Induced Vibration Phenomenon).No Significant Tube Wear Will Be Experienced in Steam Generators Due to Flow Induced Vibration.Related Correspondence ML20073J6691983-04-18018 April 1983 Testimony of Jl Murphy on Rockford League of Women Voters & Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Consolidated Emergency Planning Contentions 3 & 13.Related Correspondence ML20073K4461983-04-18018 April 1983 Rebuttal Testimony of Levine Re Rockford League of Women Voters Contentions 8 & 62 & Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 2a on Public Risk.Related Correspondence ML20073G4241983-04-11011 April 1983 Testimony of Ee Jones Re State of Il Emergency Svc & Disaster Agency Responsibilities Concerning Emergency Planning for Nuclear Facilities & Intervenor Amended Emergency Planning Contention ML20073G4051983-04-11011 April 1983 Testimony of Jc Golden Re Amended Emergency Planning Contention ML20073G4121983-04-11011 April 1983 Testimony of Dl Smith Re Resources Available for Transport & Treatment of Contaminated Injured Persons.Resume Encl 1999-03-02
[Table view] Category:DEPOSITIONS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20209J3251987-01-30030 January 1987 Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl ML20211B0841986-08-0505 August 1986 Transcript of 860805 Meeting Between Region Iii,Computer Interference Elimination & Util in Redmond,Wa Re Plant as-built Drawing Review.Pp 1-200 ML20096A6261984-08-30030 August 1984 Summary of Rebuttal Testimony & Testimony of ML Somsag, Eb Branch,D Demoss,Mr Frankel,Bf Maurer & Jk Buchanan Re Plant QC Inspector Reinsp Program & C Stokes Allegations Re Welds.Related Correspondence ML20096A6191984-08-30030 August 1984 Rebuttal Testimony of B Erler Re Stokes Allegations Concerning Evaluations of Discrepancies in Calculated Actual Stress Performed by Sargent & Lundy.Related Correspondence ML20096A6391984-08-30030 August 1984 Rebuttal Testimony of RW Hooks Re Validity of Info in Attachment 7 to Stokes Testimony Concerning Design Assumption for Plant.Stokes Info Inapplicable to Plant. Related Correspondence ML20094P7721984-08-17017 August 1984 Summary of Testimony & Direct Testimony of CC Stokes on Reinsp Program.Related Correspondence ML20094R1021984-08-17017 August 1984 Transcript of CC Stokes 840817 Deposition in Chicago,Il. Pp 1-173.Vol Ii.Related Correspondence ML20094P5991984-08-16016 August 1984 Direct Testimony of CC Stokes Re Engineering Evaluations Performed & Use of Engineering Judgement by Sargent & Lundy. Suggests Need for Independent Engineering Analysis of Safety Significance of Reinsp Program.Related Correspondence ML20094P6311984-08-14014 August 1984 Summary of Testimony & Testimony of Ds Kochhar on Contention 1 Re Reinsp Program.Certificate of Svc Encl.Related Correspondence ML20094P6831984-08-13013 August 1984 Summary of Testimony & Testimony of Wh Bleuel on Contention 1 Re Reinsp Program.Resume Encl.Related Correspondence ML20094P6951984-08-13013 August 1984 Summary of Testimony & Testimony of EP Erickson on Contention 1 Re Reinsp program-inspector Qualification & Work Quality.Resume & Certificate of Svc Encl.Related Correspondence ML20093L4881984-07-30030 July 1984 Summary of Testimony & Testimony of Eb Branch Re Contention 1 (Reinsp Program,Work Quality).Related Correspondence ML20093L1811984-07-30030 July 1984 Summary of Testimony & Testimony of KT Kostal on Contention 1 Re Capacity of Sys Control Corp Supplied Components to Carry Design Loads.Related Correspondence ML20093L2721984-07-30030 July 1984 Summary of Testimony & Testimony of Ak Singh on Contention 1 Re Evaluations of Discrepancies in Cable Tray Hanger Connections,Solid Bottom Tray Welds & Ladder Tray Weld Connections.Related Correspondence ML20093L2051984-07-30030 July 1984 Summary of Testimony & Testimony of Ld Johnson on Contention 1 Re Adequacy of Sys Control Corp Supplied Main Control Boards.Related Correspondence ML20090E5521984-07-17017 July 1984 Testimony of Eb Branch Re Job Responsibilities,Educ Background & Work Experience.Related Correspondence ML20090A7981984-07-0909 July 1984 Testimony of Gf Marcus Re Pittsburgh Testing Lab Source Insp of Equipment & Components Supplied by Sys Control Corp ML20090A8121984-07-0909 July 1984 Testimony of Bf Maurer Re Analysis of Structural Adequacy of Main Control Panels Designed & Fabricated by Sys Control Corp ML20092P7921984-07-0202 July 1984 Summary of Testimony & Testimony of ML Somsag Re QA Inspector Reinsp Program for Hunter Corp.Related Correspondence ML20092P7891984-07-0202 July 1984 Summary of Testimony & Testimony of Rv Laney on Contention 1 Re Work Quality.Related Correspondence ML20092P7951984-07-0202 July 1984 Summary of Testimony & Testimony of Ak Singh on Contention 1 Re Reinsp Program,Work Quality.Related Correspondence ML20092P7941984-07-0202 July 1984 Summary of Testimony & Testimony of LO Delgeorge on Contention 1 Re Reinsp Program,Inspector Qualification & Work Quality.Related Correspondence ML20092P5541984-07-0202 July 1984 Summary of Testimony & Testimony of Dl Leone on Contention 1 Re Reinsp Program for Work Quality ML20092P5551984-07-0202 July 1984 Summary of Testimony & Testimony of R French on Contention 1 Re Reinsp Program ML20092P7781984-07-0202 July 1984 Summary of Testimony & Testimony of Wj Shewski on Contention 1 Re Reinsp Program,Inspector Qualification.Related Correspondence ML20092P7811984-07-0202 July 1984 Summary of Testimony & Testimony of Jm Mclaughlin on Contention 1 Re Reinsp Program,Work Quality.Related Correspondence ML20092P7871984-07-0202 July 1984 Summary of Direct Testimony & Testimony of RP Tuetken Re Reinsp Program.Related Correspondence ML20092P7851984-07-0202 July 1984 Summary of Testimony & Testimony of Wb Behnke on Contention 1 Re Overview of Quality Program,Work Quality. Related Correspondence ML20092N4971984-06-29029 June 1984 Testimony of Bg Treece on Issues 5 & 6 Re Cable Overtensioning,As Limited by ASLB 840608 Order.Related Correspondence ML20092N4911984-06-29029 June 1984 Summary of Direct Testimony of Jo Binder on Issues 5 & 6 Re Cable Overtensioning,As Limited by ASLB 840608 Order.Related Correspondence ML20092K7691984-06-26026 June 1984 Summary of Testimony of J Hansel on Contention 1 Re Reinsp Program.Prof Qualifications Encl.Related Correspondence ML20205H8901983-08-10010 August 1983 Public Version of Transcript of 830810 in Camera,Ex Parte Hearing in Rockford,Il.Pp 7,585-7,610 ML20205H8941983-08-10010 August 1983 Public Version of Transcript of 830810 in Camera,Ex Parte Hearing W/Ofc of Investigations in Rockford,Il.Pp 7,611.1- 7,611.71 ML20205H8841983-08-0909 August 1983 Public Version of Transcript of 830809 in Camera,Ex Parte Hearing in Rockford,Il.Pp 7,304-7,405 ML20080B3051983-08-0303 August 1983 Testimony of RP Tuetken Re Util Reinsp Program of Work Performed by Contractor Insp Personnel Prior to NRC Region III Mar,Apr & May 1982 Insps.Appropriate Steps Taken to Remedy Problems ML20080B3091983-08-0303 August 1983 Testimony of Aw Koca Re General Nature of Hatfield Inspector Training & Certification Program.Certification of J Hughes Described ML20080B2951983-08-0303 August 1983 Testimony of Ma Stanish Re Recertification of Qa/Qc Inspectors Subsequent to NRC Region III Mar,Apr & May 1982 Special Team Insps.Reinsp Program Implemented to Review Work Performed by Inspectors Before NRC 1982 Insp ML20023C7151983-05-12012 May 1983 Testimony of P Holmbeck Re Investigation Into Adequacy of Emergency Plans Re Emergency Planning Contentions.Util Made No Attempt to Study Protective Value of Sheltering Populations Around Plant ML20204F5721983-04-26026 April 1983 Transcript of 830426 Hearing in Rockford,Il.Pp 5,964-6,156 ML20069M4791983-04-25025 April 1983 Handwritten Testimony of J Hughes Re Qa/Qc at Facility ML20069K5691983-04-21021 April 1983 Testimony of Ld Butterfield Re Steam Generator Tube Integrity.Proposed Steam Generator Mods Would Minimize Tube Wear Due to Flow Induced Vibration.Related Correspondence ML20069K5631983-04-21021 April 1983 Revised Testimony of Tf Timmons Re Steam Generator Tube Integrity (Flow Induced Vibration Phenomenon).No Significant Tube Wear Will Be Experienced in Steam Generators Due to Flow Induced Vibration.Related Correspondence ML20073J6691983-04-18018 April 1983 Testimony of Jl Murphy on Rockford League of Women Voters & Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Consolidated Emergency Planning Contentions 3 & 13.Related Correspondence ML20073K4461983-04-18018 April 1983 Rebuttal Testimony of Levine Re Rockford League of Women Voters Contentions 8 & 62 & Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 2a on Public Risk.Related Correspondence ML20073G4241983-04-11011 April 1983 Testimony of Ee Jones Re State of Il Emergency Svc & Disaster Agency Responsibilities Concerning Emergency Planning for Nuclear Facilities & Intervenor Amended Emergency Planning Contention ML20073G4051983-04-11011 April 1983 Testimony of Jc Golden Re Amended Emergency Planning Contention ML20073G4121983-04-11011 April 1983 Testimony of Dl Smith Re Resources Available for Transport & Treatment of Contaminated Injured Persons.Resume Encl 1999-03-02
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20209J3251987-01-30030 January 1987 Transcript of 870130 Commission Discussion/Possible Vote on Full Power OL for Facility.Pp 1-72.Supporting Viewgraphs Encl ML20211B0841986-08-0505 August 1986 Transcript of 860805 Meeting Between Region Iii,Computer Interference Elimination & Util in Redmond,Wa Re Plant as-built Drawing Review.Pp 1-200 ML20096A6261984-08-30030 August 1984 Summary of Rebuttal Testimony & Testimony of ML Somsag, Eb Branch,D Demoss,Mr Frankel,Bf Maurer & Jk Buchanan Re Plant QC Inspector Reinsp Program & C Stokes Allegations Re Welds.Related Correspondence ML20096A6191984-08-30030 August 1984 Rebuttal Testimony of B Erler Re Stokes Allegations Concerning Evaluations of Discrepancies in Calculated Actual Stress Performed by Sargent & Lundy.Related Correspondence ML20096A6391984-08-30030 August 1984 Rebuttal Testimony of RW Hooks Re Validity of Info in Attachment 7 to Stokes Testimony Concerning Design Assumption for Plant.Stokes Info Inapplicable to Plant. Related Correspondence ML20094P7721984-08-17017 August 1984 Summary of Testimony & Direct Testimony of CC Stokes on Reinsp Program.Related Correspondence ML20094R1021984-08-17017 August 1984 Transcript of CC Stokes 840817 Deposition in Chicago,Il. Pp 1-173.Vol Ii.Related Correspondence ML20094P5991984-08-16016 August 1984 Direct Testimony of CC Stokes Re Engineering Evaluations Performed & Use of Engineering Judgement by Sargent & Lundy. Suggests Need for Independent Engineering Analysis of Safety Significance of Reinsp Program.Related Correspondence ML20094P6311984-08-14014 August 1984 Summary of Testimony & Testimony of Ds Kochhar on Contention 1 Re Reinsp Program.Certificate of Svc Encl.Related Correspondence ML20094P6831984-08-13013 August 1984 Summary of Testimony & Testimony of Wh Bleuel on Contention 1 Re Reinsp Program.Resume Encl.Related Correspondence ML20094P6951984-08-13013 August 1984 Summary of Testimony & Testimony of EP Erickson on Contention 1 Re Reinsp program-inspector Qualification & Work Quality.Resume & Certificate of Svc Encl.Related Correspondence ML20093L4881984-07-30030 July 1984 Summary of Testimony & Testimony of Eb Branch Re Contention 1 (Reinsp Program,Work Quality).Related Correspondence ML20093L1811984-07-30030 July 1984 Summary of Testimony & Testimony of KT Kostal on Contention 1 Re Capacity of Sys Control Corp Supplied Components to Carry Design Loads.Related Correspondence ML20093L2721984-07-30030 July 1984 Summary of Testimony & Testimony of Ak Singh on Contention 1 Re Evaluations of Discrepancies in Cable Tray Hanger Connections,Solid Bottom Tray Welds & Ladder Tray Weld Connections.Related Correspondence ML20093L2051984-07-30030 July 1984 Summary of Testimony & Testimony of Ld Johnson on Contention 1 Re Adequacy of Sys Control Corp Supplied Main Control Boards.Related Correspondence ML20090E5521984-07-17017 July 1984 Testimony of Eb Branch Re Job Responsibilities,Educ Background & Work Experience.Related Correspondence ML20090A7981984-07-0909 July 1984 Testimony of Gf Marcus Re Pittsburgh Testing Lab Source Insp of Equipment & Components Supplied by Sys Control Corp ML20090A8121984-07-0909 July 1984 Testimony of Bf Maurer Re Analysis of Structural Adequacy of Main Control Panels Designed & Fabricated by Sys Control Corp ML20092P7921984-07-0202 July 1984 Summary of Testimony & Testimony of ML Somsag Re QA Inspector Reinsp Program for Hunter Corp.Related Correspondence ML20092P7891984-07-0202 July 1984 Summary of Testimony & Testimony of Rv Laney on Contention 1 Re Work Quality.Related Correspondence ML20092P7951984-07-0202 July 1984 Summary of Testimony & Testimony of Ak Singh on Contention 1 Re Reinsp Program,Work Quality.Related Correspondence ML20092P7941984-07-0202 July 1984 Summary of Testimony & Testimony of LO Delgeorge on Contention 1 Re Reinsp Program,Inspector Qualification & Work Quality.Related Correspondence ML20092P5541984-07-0202 July 1984 Summary of Testimony & Testimony of Dl Leone on Contention 1 Re Reinsp Program for Work Quality ML20092P5551984-07-0202 July 1984 Summary of Testimony & Testimony of R French on Contention 1 Re Reinsp Program ML20092P7781984-07-0202 July 1984 Summary of Testimony & Testimony of Wj Shewski on Contention 1 Re Reinsp Program,Inspector Qualification.Related Correspondence ML20092P7811984-07-0202 July 1984 Summary of Testimony & Testimony of Jm Mclaughlin on Contention 1 Re Reinsp Program,Work Quality.Related Correspondence ML20092P7871984-07-0202 July 1984 Summary of Direct Testimony & Testimony of RP Tuetken Re Reinsp Program.Related Correspondence ML20092P7851984-07-0202 July 1984 Summary of Testimony & Testimony of Wb Behnke on Contention 1 Re Overview of Quality Program,Work Quality. Related Correspondence ML20092N4971984-06-29029 June 1984 Testimony of Bg Treece on Issues 5 & 6 Re Cable Overtensioning,As Limited by ASLB 840608 Order.Related Correspondence ML20092N4911984-06-29029 June 1984 Summary of Direct Testimony of Jo Binder on Issues 5 & 6 Re Cable Overtensioning,As Limited by ASLB 840608 Order.Related Correspondence ML20092K7691984-06-26026 June 1984 Summary of Testimony of J Hansel on Contention 1 Re Reinsp Program.Prof Qualifications Encl.Related Correspondence ML20205H8901983-08-10010 August 1983 Public Version of Transcript of 830810 in Camera,Ex Parte Hearing in Rockford,Il.Pp 7,585-7,610 ML20205H8941983-08-10010 August 1983 Public Version of Transcript of 830810 in Camera,Ex Parte Hearing W/Ofc of Investigations in Rockford,Il.Pp 7,611.1- 7,611.71 ML20205H8841983-08-0909 August 1983 Public Version of Transcript of 830809 in Camera,Ex Parte Hearing in Rockford,Il.Pp 7,304-7,405 ML20080B3051983-08-0303 August 1983 Testimony of RP Tuetken Re Util Reinsp Program of Work Performed by Contractor Insp Personnel Prior to NRC Region III Mar,Apr & May 1982 Insps.Appropriate Steps Taken to Remedy Problems ML20080B3091983-08-0303 August 1983 Testimony of Aw Koca Re General Nature of Hatfield Inspector Training & Certification Program.Certification of J Hughes Described ML20080B2951983-08-0303 August 1983 Testimony of Ma Stanish Re Recertification of Qa/Qc Inspectors Subsequent to NRC Region III Mar,Apr & May 1982 Special Team Insps.Reinsp Program Implemented to Review Work Performed by Inspectors Before NRC 1982 Insp ML20023C7151983-05-12012 May 1983 Testimony of P Holmbeck Re Investigation Into Adequacy of Emergency Plans Re Emergency Planning Contentions.Util Made No Attempt to Study Protective Value of Sheltering Populations Around Plant ML20204F5721983-04-26026 April 1983 Transcript of 830426 Hearing in Rockford,Il.Pp 5,964-6,156 ML20069M4791983-04-25025 April 1983 Handwritten Testimony of J Hughes Re Qa/Qc at Facility ML20069K5691983-04-21021 April 1983 Testimony of Ld Butterfield Re Steam Generator Tube Integrity.Proposed Steam Generator Mods Would Minimize Tube Wear Due to Flow Induced Vibration.Related Correspondence ML20069K5631983-04-21021 April 1983 Revised Testimony of Tf Timmons Re Steam Generator Tube Integrity (Flow Induced Vibration Phenomenon).No Significant Tube Wear Will Be Experienced in Steam Generators Due to Flow Induced Vibration.Related Correspondence ML20073J6691983-04-18018 April 1983 Testimony of Jl Murphy on Rockford League of Women Voters & Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Consolidated Emergency Planning Contentions 3 & 13.Related Correspondence ML20073K4461983-04-18018 April 1983 Rebuttal Testimony of Levine Re Rockford League of Women Voters Contentions 8 & 62 & Dekalb Area Alliance for Responsible Energy/Sinnissippi Alliance for Environ Contention 2a on Public Risk.Related Correspondence ML20073G4241983-04-11011 April 1983 Testimony of Ee Jones Re State of Il Emergency Svc & Disaster Agency Responsibilities Concerning Emergency Planning for Nuclear Facilities & Intervenor Amended Emergency Planning Contention ML20073G4051983-04-11011 April 1983 Testimony of Jc Golden Re Amended Emergency Planning Contention ML20073G4121983-04-11011 April 1983 Testimony of Dl Smith Re Resources Available for Transport & Treatment of Contaminated Injured Persons.Resume Encl 1999-03-02
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Text
V Joint Intervenors' Exhibit 19 o
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD c
In The Matter of )
)
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL
) 50-455 OL
)
(Byron Nuclear Power Station, )
Units 1 & 2) )
AFFIDAVIT OF DAVID MILLER 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.
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, u /f/f -
l ,,3 David Miller
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Subscribed and sworn ~ to before me this ' day of ./ o , . . , 1983.
. . -L : - . - w 's . J. - -
Notary Public G
t
TESTIMONY OF DAVID MILLER ON EMERGENCY 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 as Exhibits A, B, C, D, E, and F.
Q. Please state your name, present occupation and present position.
A. My name is David Miller. I am the Superintendent of Schools for the Meridian Community Unit 4223 (" Meridian C. U.").
Q. Briefly state your educational and professional qualifications.
A. I received a Bachelor of Science degree in Education from Illinois State University in 1955 and a Master of Science degree in Educational Administration from Northern Illinois University in 1966. I have been a school superintendent for 25 years and have served in this capacity for the Meridian C. U. for 16 years.
1 Q. To which contention is this testimony addressed?
/$( Dmergency Preparedness: DaKalb Area Alliance for Responsible Energy /Sinnissippi Alliance for the Environment ( " DAARE/S AFE" )
v'(\
l yp- y Contention 3, and Rockford League of Women Voters ("Rockford G# LWV") Contentions 19 and 108.
Q. Which Meridian C. U. schools are located within the 10-m ile plume exposure pathway Dmergency Planning Zone ("EPZ" ) for
, the Byron Nuclear Generating Station (" Byron Station")?
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A.
Highland Grade School, Meridian Junior High School,.and Stillman Valley High School are all located in Stillman Valley, 5 to 6 miles east-northeast of the Byron Station.
Q. What prelimin,ary or final emergency plans are you familiar with?
A.
The Illinois Bnergency Services and Disaster Agency ("IESDA")
sent to me an initial draf t of the school superintendent's portions of the Illinois Plan for Radiological Accidents, Volume VI " Byron" ("IPRA-Byron, Draft"). These included an initial notification diagram; flow diagrams for command and coordination, protective actions, and parallel actions; responsibility matrices; and procedures for my role in the emergency plan. The IPRA-Byron, Draft, was dated December 1982 and accompanied by a cover letter dated November 29, 1982, from Mr. David L. Sm i th , IESDA Chief of Operations, Byron Dmergency Plan. The school superintendent's portion of IPRA-Byron, Draft, and cover letter are attached to this affidavit as Exhibit A.
DAARE/ SAFE and Rockford LWV provided me with the school superintendent's portions of the Illinois Plan for Radiological Accidents, Volume VI, " Byron," Preliminary Revision O ("IPRA-Byron, Revision 0"). The school super-intendent's portions of IPRA-Byron, Revision O, are also dated December 1982 and attached to this af fidavit as Exhibit B.
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. I have also examined Commonwealth Edison's document titled " Evacuation Time Estimates Within the Plume Exposure Pathway Duergency Planning Zone for the Byron Nuclear Generating Sthtion" (Evacuation Time Estimates-Byron),
which is based on the feasibility and the official execution of these IPRA-Byron, Revision O, plans and procedures.
Section 4.2 titled "Special Facilities Time Estimate Methodology and Assumptions" and Section 6.2 and Table 6. 2 titled "Special Facilities Evacuation Times" are attached to this affidavit as Exhibits C and D, respectively.
Q. Did the IESDA solicit any information from you regarding the number of students to be evacuated and the resources available to you in conducting an evacuation?
A. Yes. My limited contact with planners has consisted I primarily of fact finding on their part. I responded to a " request for information" from Assistant Ogle County Superintendent of Educational Services, Charles Hayes.
A copy of Mr. Hayes' letter dated September 10, 1982, is attached to this affidavit as Exhibit E. Mr. Hayes had asked that I provide him with the number of students and staff at each Meridian C. U. school, and the number of vehicles to which I have access. I also received a visit from two IESDA representatives during the week of December 6.
They asked essentially the same questions as Mr. Hayes.
According to these gentlemen and to Mr. Hayes (Id.), these figures were to be used by IESDA and Commonwealth Edison in planning for an emergency at the Byron Station.
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-4 Q. Did the IESDA solicit your opinions as to the adequacy of the IPRA-Byron, Draft?
A. Yes. In the cover letter from David L. Smith dated gg November 29, A982, was a request for a " timely review" of the IPRA-Byron Draf t (Exhibit A). I received the IPRA-Byron, Draft, midweek and was expected to critique the plan by the next week. Though this was not a sufficient length of time for me to formulate a thorough analysis of the IPRA-Byron, Draft, I did offer my preliminary thoughts.
But the idea was clearly to assign a role to me rather than design one around my actual capabilities. I raised, for i
example, questions regarding communications equipment which have yet to receive attention. I have been allowed very little input into Dmergency Planning around the Byron Station, j Q. What are your primary concerns regarding the emergency roles for which you are given responsibility in the IPRA-Byron, Revision O? \h A. Generally these concerns are: (a) procedures for and modes of carrying on emergency communications; (b) logistical difficulties of transportation plans (e.g. not enough buses, availability of drivers, communications with vehicles);
(c) the liability of my school district and its employees for damages caused or injuries sustained by Ogle County citizens (including school district employees) while ,
i energency workers are carrying out or failing to carry out
! responsibilities as outlined in IPRA-Byron, Revision 0; (d) complications involved with the relocation of evacuees, l
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(e.g. where to go and how to reunite families); (e) the inadequacy of sheltering in place; and (f) the financial burden.
Q. With whom, accordin' to the IPRA-Byron, Revision O, must you maintain communicati s during an emergency?
A. The Ogle County Sup intendent of Educational Services, the Fire Protection Distric Chief, school administrators at Stillman Valley High School Mer:dian Junior High School, and Highland Grade School (Exh1 it B).
Q. Are there any other com nication capabilities which are assumed but not stated directly?
A. Yes, I must be in con at with all field personnel (bus drivers).
Q. What communications stems do you presently have available for such communications?
A. I have only commercial *selephcne lines.
Q. Will these lines be sh{ficient in an emergency?
A. No. Should an overload of telephone lines occur, I would have no means of ceiving or disseminating in forma tion .
I would not be notifi of the progression of the emergency l situation. For example, may be left completely in the 1
l dark if an initial order for protective action, e.g. for sheltering, is changed to an orc r for an evacuation.
With regard to the disseminati n of information, efforts to keep school administrators breast of the situ-ation or to summon bus drivers by means o telephone will also depend on the integrity of the commercial 7 hone lines.
. Q. Do you have the capa ility to evacuate your entire student
A. No, I do not. Meridian C. U. has twenty buses. Of these, two can be expect to be out of the area at any one time, and two more are loca ed in Monroe Center. The remaining buses would have a capac1 of 1,006. The Meridian School District's student populatio in the EPZ stands at 1,135.
Thus at least two to three buse would need to return for a second trip. Three additional ses would be needed if adult school personnel are to be eva ated by bus.
Q. What other factors determine the availability of transportation?
A. Certainly the ability to mobilize drivers, which is dependent upon their willingness to serve as emergency workers.snd their availability. rm o , La; ir.. . .11 bz diffic"'* *^ :ememmm mu vo w e e- 'hcy m ; ; rt time employens a_n d "crk :Ir~ hara A"rinc -theJay - ".nd notification of drivers, as 7 pointed tyut earlier,4s dependent ution' thd
- n_1 ^ phone -system which mould be overleaded during-an amer -
gency. Once contacted, drivers may, understandably, choose to evacuate with their own f amilies. And it is clearly the case that the number of willing drivers will decline with each successive trip.
Q. Approximately how much tim would be required to mobilize l
personnel sufficient to man a available buses?
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A. At least thirty min es would be required. This estimate assumes that everyone be easily contacted which, for reasons stated above, is no the case. At night, on week-ends, during, holidays, or over ummer recess, hours would be required.
O. What are your concerns about the liability of your school district and its employees for damages caused or injuries sustained during the execution of responsibilities assigned to you in IPRA-Byron, Revision O?
A. The Meridian C. U. is insured for the transportation it provides to the students of the Meridian C. U. only. The gg transportation of students from other districts [IPRA-Byron, Revision O, (VI) (3), pp. 3-4, attached to this affidavit as Exhibit F] and the transportation of the general populace during an evacuation [(VI) ( 2d ) , page 17, and (VI) (2),
page 188, Exhibit B] are activities for which we are not insured. I, personally, would place myself in legal jeopardy
by ordering bus drivers or other staff to assist in emergency activities. Should any Meridian C. U. employees receive unacceptable internal or external doses of radiation while carrying out my instructions, who is liable? And who is liable for the families of emergency workers whose prompt evacua' tion would be hindered by the delay in availability of family vehicles?
O. llave you made any attempts to clear up this matter via IESDA officials?
A. Ye s , I expressed my concerns to IESDA officials who visited us the week of December 6, 1982. )
They indicated that they (
would "look into" the matter. But no information has been forthcoming. "
I am also a re through personal contact that Mr. Maloney, Leaf R er Superintendent, has phoned several times and has been wait g for written information as to the school's legal liabilit' s.
Q. What information have you been given on relocation?
\3 A. None. 4iha u ela..; de co.;L ;_... t : rter 2t th: Scrd: M
- he ten -4to enz. i an --t %,. . .ummm J,. chi >r - "411 t; tchen, cr 5:u-th;y -.11 bc .suu.imd"-rith
O. What portions of Commonwealth Edison's Evacuation Time Estimates-Byron have you seen?
A. I am f amiliar with Section 4.2 "Special Facilities Time Estimate Methodology. and Assumptions," pp. 4-6 and 4-7, and Section 6.2 "Special Pacilities Evacuation Times," as well as Table 6-2 where these time estimates are found.
(See Exhibits C and D, respectively.)
O. Briefly, what is'tQe methodology used?
A. The total evac tion time for Meridian C. U. is 51 minutes.
The total evacuatio time is divided into mobilization time and travel time. bilization time is assumed to be 45 minutes (15 to notify me, 0 minutes to mobilize drivers, drive to the schools, and prepar students for departure).
The travel time out of the EPZ is the minimal: six minutes.
. Q. Are these accurath%qstimates?
A. No, since 30 minu s is the absolute minimum amount of time necessary to mobilize rivers. Furthermore, since more than one trip will be required, he mobilization and travel times must reflect the time require o drive to the sheltering area, unload, return to the schoo , and again travel out of the EPZ.
Q.
Did the document state the source of these mobilization and loading times for your schools?
A.
Yes, and I quote, " Mobilization and loading times for special facilities have been obtained by State of Illinois ESDA personnel through interviews with facility officials."
\3 (emphasis added] Commonwealth Edison " Evacuation Time Estimates" at 4-6. And further, "The thirty-minute average time for preparation to enter the roadway conforms to the estimates provided by school officials [ emphasis added]
through State of Illinois ESDA personnel." Id., pp. 4-7.
Q. Are you the source of these time estimates?
A. As should be clear by now, I would have qualified such an estimate to such an extent as to make the 30 minutes estinate a less than credible norm.
Q. Sheltering is another possible protective measure which may be prescribed in the event of an accident at the Byron -
\ 23 Station. Have IESDA officials given you any information on sheltering procedures in response to such as accident?
A. No, they have not.
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. Q. Are you aware of what is meant by " sheltering," pursuant g to IPRA-Byron, Revision O?
A. As I understand the matter, sheltering will be prescribed for those popBlations in the affected area who cannot t
) , evacuate in an acceptable time period. Sheltering involves staying inside, closing all windows and doors, and going to a basement area or a room where walls are made of cement.
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Ventilation is to be restricted in any way possible.
- 'N V- Q. Have they inquired as to the feasibility of sheltering
>*r students in your buildings after radiological release from the plant?
A. No, they have not.
Q. Do your buildings have suitable facilities (basement or windowless areas) for sheltering?
A. No, they do not.
Q. Do you see any furt problems with using sheltering as a protective action?
A. Yes. If sheltering 's prescribed as a protective action and an evacuation is la r advised, I would have only a commercial telephone to r ceive the message, summon bus drivers and notify other buildi s. As I established earlier, telephone communications e of limited reliability, at best.
Q. Have IESDA or Commonwealth Edison' given you any indication that they will make any efforts to ease the financial burden of acquiring badly needed communications equipment, training or evacuation experience?
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s Q. On the basis of your education and professional experience, your knowledge of the Meridian C. U. and its resources and your limited contacts with IESDA, do you consider the IPRA-(}
Byron, Revision O, to be adequate or capable of implementation with regard to your role in the evacuation or sheltering of schoolchildren and the general populace?
A. Certainly not. There are unanswered questions dealing with every link in my assigned procedures: \1 notification, transpo^rtation, communications, relocation.
Affiant incorporates the material contained in Exhibits A, I
B, C, D, E, and F, attached hereto, as part of his testimony.
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