ML20066E952

Responses to 821020 Revised Interrogatories.Certificate of Svc Encl

ML20066E952
Person / Time
Site:	Callaway
Issue date:	11/04/1982
From:	Jeffrey Reed REED, J.G.
To:	UNION ELECTRIC CO.
References
ISSUANCES-OL, NUDOCS 8211170333
Download: ML20066E952 (20)

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UNITED STATES OF AMERICA

,.- NUCLEAR REGULATmY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0kN In the Matter of ) ~

) *82 NDY 16 Pi:52 UNION ELECTRIC COWANY ) Docket No. STN 50-483 OL (Callaway Plant, Unit 1) Imbqcq h d'I' h-JEN G. REED'S RESPONSES TO APPLICANT'S REVISED INTERROGATm IES .

On 20 October 1982, Applicant submitted revised interrogatories to the undersigned, requiring Mr. Reed's answers be in writing and under oath or affirnstion.

Mr. Reed herewith submits his responses to such questions, to

, include objections as he deems appropriate. Responses will be numbered in the same manner as Applicant submitted its ' interrogatories in an attempt to simplify identification of the question to which a response is intended. ,'

RESPONSES TO INTERROGA11) RIES

1. Yes. If local governments are to accept the responsibility to protect its citizens in the event of a nuclear power plant radiological emergency (hereinafter identified as "an accident"), it must have the.

capability to provide such protection. Torelyuponanch,herentiety for such protection is an abrogation of responsibiiity, once local i

government has taken on that job. Additionally, to accept such a responsibility for "one shift" (using your term for an unspecified period j of time) only and finding, after the fact, that State personnel are not

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insnediately available to replace local forces is an act[of gross T incompetence. The State should be relied upcn to provide only a limited i

personnel force to augment the local government in areas where last  ;

minute manning shortages are found; otherwise all functions should be

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'e givun-to the State to' perform and-local governamts relieved,of that .

particular function. ,

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2. With a capability to operate on an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> schedule and perform all functions, an agency has the ability to operate at a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> schedule if manpower availability is curtailed during an emergeng. If a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> schedule is viewed at the outset of an emergency, and manpower shortages j occur, the ability to perform the required tasks is rehced. Plans should be formulated so that unforseen difficulties kre* overcome by builb6i&

.I mitigatiano(similar to the safety factors designed in nuclear power plants which serve no other purpose than to mitigate the consequences of an accident). To fail to consider personnel shortages is, again, a sign of gross incompetence in planning and administration.

3. The tindng of functions is not relevant to detersdning that task i

functions must be accomplished. The determination that functions might ,

overlap or occur at the same time was based upon past military .experi,ence

I in commaanications operations and personnel management. It is possible ,

that personnel needs for the functions in Contentions 1 and 2 are , .l inadequate under conditions wherein full-scale exercises or antactual :l

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_t accident requiring evacuation existed because of a lack of training of I i

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j the people involved. W judgement was based upon all personnel being.

fully trained and competent at their assigned tasks.

l l 4. Object to this question, it is beyond the scope of this hearing  ;

which is lindted to radiological emergency response planningjonly.

i l 5. object to this question, it is beyond the scope of this hearing i 1

which is lindted to radiological emergaley response planning only.

6. The Sheriff's Reserve is a volunteer organisation and has not I agreed to accept a role in supportaig Union Electric Company's effort to l

-3 obtain an operating license for its Callaway Plant, Unit:1. t

7. To air knowledge, the Fulten Police Department will not operate  ?

outside of the city limits of Fulton.

8. The Callaway Offsite Emergency Response Plan (Callaway Plan) ,

clearly states (at 1.0 BASIC PLAN, F. Ccacept of Perations, 3. County / City Emergency Operations):

. County / City government operations w111' continue to be performed in a normal manner to the fullest tutent possible.

Also, the Sheriff of Montgomery County has. informed me that he will not reduce his already limited force during an emergency because he believes ti st during such an emergency, increased criminal activity is a distinct probability. I expect this judgement to be supported by the other three Sheriffs, and personnally consider it proper and prudent. Object to the portion of the question that deals with natural disasters, see 4. and 5.,

above.

9. Such logging is, required (see SOP at page 2-3, 5 7 Consminications, 5.73). The purpose of the existing and proposed ~connunications systeam, is to enhance the emergency effort, therefore, use of such systems natst l - .

be restricted to official use. Operators of such systems cannot know who is authorized to transad.t traffic, therefore, messages to be sent must be screened by someone to assure that official asssages only enter

! the system. This provides some degree of assurance on the part of the addressee that a written massage is valid if it was raceived over one of the official means of connunications. Addressees may not be at the l

EOC or other site on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day basis for the entire length of the emergency. The U.S. Arny and other military services use this control l procedure, as does many civil communications systems.. Without a system

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such as this, each message received by an addressee is subject to having i its' validity questioned.

10. The Offsite Plan /SW does not include provisions for carben copies, or duplicates, so the message going to the Clerk's Office is the original copy prepared by the receive operator. I presuas it is delivered to the addressee. No provisions are made for the retention of messages, once they are delivered, so I can not sqlain further what happens to the message. I consider the comanunications portions of the Offsite Plan and the SWs to be unsatisfactory. It is apparent that the planners know nothing of communications control procedures or practices.

11. The SOP, at Procedure #2, 5 7 3, clearly states that a written copy of all messages incoming and outgoing will be given to the County l Clerk. This sust include messages received via the Command Net, intended for the Presiding Judge. Unless the Presiding Judge is going to be en l the phone 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, for the entire length of the emergency, to operatorswwilltbe required to'. man this: circuit.

12. The movement of contaminated vehicles from the EPZ boundary to a designated area, if not controlled, can result in the needless i

spread of contamination. A Ametion of emergency planning, as I i understand it, it to control the spread of ccntamination which will result in controlling radiological exposures.

13 One officer supervises the vehicle impound area and provides security.vThe other officer supervises evacuees inside of the temporary i

evacues holding area and naintains order.

14. I anticipate nothing, it is merely prudent to be prepared for situations which might arise when fear, panic, and short tempers may l conflict with the orderly accomplishment of a mission. The capability

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can be used to bring food or other supplies to road-blocks, etc. or ,

serve as emergency transport when no other is reasonably available. ,

15. As such, they provide an added deterrent to violence and increase the security of the area by being a law officer.

16. It is not possible to agree with any of your estimated times for galeral functions without a full. understanding of what was envisioned by the person making such estimates; however, manning of impound areas will be required as long as a vehicle remains parked in that area. Road-blocks will require manning as long as the EPZ is inpacted by an accident, except for control points between the EPZ and impound areas.which will need to be manned until all outbound traffic from the EPZ has ceased.

The evacuation area, W11ch may include all or part of the EPZ, must be secured until reentry / recovery is authorised. A reduced evacuation area is possible to establish, but plans predicated on a small area to be .

secured at the outset of an accident in order to reduce manning requirements in saidaplans is an evasion of the intent of plans preparations. Plans should be designed to assure that the entire EPZ can be handled in an 1

emergency.

17. Yes. i l

18. The plan shows 4 traffic . control points; however, there are 1

4 additional access routes into the EPZ which are not covered or secure. l In terms of area security, this is equivilent to locking the front door and leaving the back door wide open. It is agr understanding that Osage County has yet to accept the proposed plan or SOP.

19. The proposed plan, at 1.0,F,3, states that government will continue to operate in a normal manner to the A111est extent possible.

Since the County Clerk's office nust continue to function, as such,

I without the' benefit of the'ftall-time supervision of the County Clerk, ,

to Aarther reduce its: work fece will bring the office to a comparative l

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' stand-still. Testimony of at least two County Clerks can be expected to confirm this opinien.

20.. Object, see 4 and 5,aabove.

21. Object, see 4 and 5, above. -

22. Yes. An "available transportation list" is that list of vehicles that have been made physically available for use. Such list may or may not coincide with a transportation coundttment list which was prepared at an earlier date and confirmed by letter of agreement. It is l

sinp37 a roster of vehicles (with drivers) that are standing bye awaiting l

dispatch from the vehicle staging area.

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23. Evacuation may not be accomplished for an undetermined length of tims, if shelter phase is initiated as a precautionary measure for health' ressais. The resultant delay does not mitigate the need for the t

j full operations capability; also, weather conditiens can cause delays in evacuation that would necessitate time framos for'such evacuation in excess of.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. It depends upon the situation at the time.

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24. Without a diart of estimated evacuees, operations control l

officials have no means by which they can rapidly determine the effective-ness of the evacuation effort. It serves as the primary aid in judgement calls as to whether or not added emphasis is needed to enhance the evacuation effort.

25. Without an understanding of the operational concept, the figures or other data en the chart will be meaningless and efforts to assure timely and accurate update of such information can be misdirected

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or conclusions dram from the information misinterpreted. Training in cosumnications procedurcs and practices is a basic requirement for individuals using the consaanications systems. Such personnel should 1

be trained in means identification and alternate routing, etc.

26. I expect to receive no requests for transportation assistance. j The need for 3 to 4 operators to receive such calls is merely an

initial estimate and nuqr be inadequate under actual evacuation conditions, also, see 27, below.

27. Transportation requests are tied to the effectiveness of the entire evacuation effort. It is not impossible that phone lines  !

may be tied up by individuals calling in for assistance and leaving ,

their lines open until the requested transportation arrives. If the evacuation effort is delayed by sheltering needs, etc., the " call-in +

l phase" will still be required'and ' operators 'needed to man' the phones.~ .

. Again, it depends upon the situation at the time of the energency. m

28. The term was deemed to be synonamous with " resources" and was .

derived from the proposed Callaway Offsite Plan (atr1.0,E, page 1-5). <

29. Object, such inquiry relates to subjects beyond the scope of ,

this hearing wich concerns radiological emergency response planning.

30. Object, see 29, above.

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31. None to av knowledge.

32 None.

33. Object; the annunt of time required to perform a function 13 directly related to the skill level attained by the person in perforndng such a function. $ personal estimate of the time required to do a specific job would be based upon nr capability which may or may not be relevant to another person. .

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~ _:34.-:It.is ar, opinion that it will not be possible to obtain a , .

qualified part-time, non-professional Emergency Management Director; one who is qualified and capable of perforsdng the duties and assuming the responsibilities assigned to him in the Callaway Offsite Plan /ST.

35. -I know-of no " incentive" inherent in the position of Emergency Management Director; just an opportunity to work for free to support

- Union Electric Company's comunercial venture (the operation of the Callaway Plant, Unit 1). I venture the sans opinion is held by Shaw, f

Pittman, Potts & Trowbridge and their employees. I am not aware that this company has offered their services without reenmeration or incentive

! and are providing services because of sons, yet unidentified, inherent incentive in perfendng the services they now provide to Union Electric.

36. Object to the first portion of this question, see 29, aboye.

37. There are none.. e -

'38. Not to av knowledge.

39. . Yes, the Court,, to the best of. nr knowledge, has made no decision in the matter.

< 40. It is possible, but auch simplier, more practical, and clearer to identify such in the plan /3N) so that with the passage of time and changes in personnel, the information does not get. dropped or ads-interpreted.

41. Object; this interrogatory calls for a ecnolusion and a possible i

resolution to a problem. The undersigned is obligated only to prove that a contention is valid, not provide a resolution to a planning error or fault.

426 The location of a specific school bus at the time the sirens are sounded does not provide assurance that the bus is about to enter the plume pathway, exit from the pathway, be located within the plume, or be able to escape from the plums altogether. The sounding of the e

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' sirens is ? intended.to? provide a' signal for the population to tum on .

- radios cr televisions.to obtain instructions relating to protective

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actionsIthey unst-take. Defensive actions regarding closing windows and shutting of ventilation systems may be specified in prior training exercises, but knowing Aich way to drive the bus to escapt the plume 1

and its effects on the children' is information which sust be transmitted to the driver at the:tims the accident occurs. For this reasca, a connunications device is needsd on the bus (es). .

-43. No. The ' siren does not specify where the plume is located or what its pathway will be;'it simply sounds an alert' signal.

44. Object, the undersigned is not basing any contention en a cost / benefit basis and does not accept Applicant's Response to Specified Reed Interrogatories served en the Callaway Court Administrative Judges and Emergang Management. Coordinator, dated 23 July 1982,.as a valid .

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! re'sponse from the persons on whom it was served; as' such it is hear-say and has no basis in this hearing.

'45. Object, see 41, above.- .

46. No, but neither am I aware of any state plan that provides  !'

- for Aall protection of the public health and safety. % contentions and concern are lind.ted to assuring that off-site plans and procedures relating to the Calla way Plant are adequate.

47. No. . Who distributes KI or other protective devices is a matter of concern for the MtC, nr interest is that such be made available in compliance with NRC policies, regulation, or planning standards / criteria as may be applicable.

48 The contention includes the possibility of evacuation through a radiological enviranment. This could occur after a release has ended,

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but would ,not peelude secondary" suspension of. nuolides,.after_ deposition.....'_.  ;

, , . t .. m / . ! !.1 Plans n, c1, be prepared that include mare than' ideal"oiremsstances in dich , ,

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short term shelter is necessary. ;Such plans place-the:public health and r

safety in jeopardy if any circunstance. exceeds the mideal".' limitation. I ccasider such plans to be grossly inadequate and unaccep' table,and the planniers do propose such plans to be inoospetent. 08uch "

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of serving to-placate the public by presenting simple emergency problems and sisple solutions thereto.'-

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49. None. *

50. Specifiedin7.A,.readthesituation.]Evacueesenrouteoutof the EPZ may be caught in a " puff" and contaminated with an unspecified .

amount of an undefined radio-contaminant. i In such ' cases; innaMate or

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near immediate decontamination reduces .the possibility of health damage ~

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from the external rad-contaminant and its possible ingestiEN by the ~ ~ ~'

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person contadnated through'inadvertant transfer of-the;oontadnant to r :. ,  %

the food chsin or other route into.the body. ;It, also,Jreduces the fear 1

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factor of those'cientaminated and simplifies personnel. management. -

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51. Iwouldnotdoso,butthisisan"appropriatk(<qu?h:; estica to ask those who have authority to order evacuations. . *;

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52. Mr' personal opinion would be to conduct such evaluation as

rapidly as is humanly possible. Whether.or not a person'i,s located at the Callaway Plant or immediately dom wind of a s'erious'. release of radio-nuclides seems, to me, to be immaterial. A persosi wh5 is found to be contaminated should be rapidly evaluated for' biological uptake or his extemal decantamination may not resolve his couplete medical problem. 'It appears to be a matter of common-sense and readily understood by even a lay-person. -

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. 53. The planning standard in NUREG 0654, at II, L., requires:

Arrangements are made for medical services for dont.w?".6 contaminated injured individuals.1 The footnote calls for an integrated emergency medical services systemt and a public health emergency plan serving the area.in which the facility is located. Additionally, evaluation criteria number 1 requires that each organisation shall make arrangements for local and backup hospital and medical services. I do not believe.that transporting patients to Nebraska meets the established plarating standard or criteria and I.do not believe that nuclear power plants are certified as medical institutions.

54. Yes, and such should be included in training; however, written procedures should exist in plans /SPs so that :such' instructions are not

forgotten in training or forgotten in time by emergency workers.  ;

55. No. Such annitoring identifies contamination only. Once the vehicle' leaves the traffic control points (the plan 'doesinot provide for further control), it simply becomes another car on.the roadi,; ,

56. The equipment currently available to emergency workers and proposed forstheir use are calibrated in Roentgens and/or mill 4-roentgens.

i For clarity's sake and simplicity, standards should be identified in terms that the equipment is capable of recording. The use of RENs (roentgen equivilent ====al)?is more technically accurate in measuring biological effects of ionizing radiaticos; however, thsre is a difference between Roentgens per hour exposure and RENs per hour body damage. If a knowing error is to be committed to a plan, it should be one that does not confuse the field amnitoring personnel. Tho'. technical experts can easily discern the differences, but a neophyte in the field is easily confused. Elimination of conftision is a key to preventing rumors ,

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~from'getting started.

57. No, not to ar knowledge. This i= part of the planning process which has been undertaken by Union Electric Company (Moors Stiller and White). Union Electric accepted this responsibility when it took over all local radiological emergency response planning for local governments. It is not at job.

58. Object, see 41, above. Additionally, this is part of the planning process, see 57, above.

59. . object, see 57 and 58, above. .

60. Object, see 57 and 58, above.

61. Training could provide requisite knowledge and ability, but not conesit a person to provide the requisite service desired. Only a letter of agreement provides an indication of a willingness to perform

.. ' 1 a task. Additionally, it verifys to the Commission and others that a .

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task requirement has been filled (at least for the term of the letter ,

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< of agreement).

62. No factual reasons, just strong impressions based upon past converst.tions with agents and employees of such anbulance districts. [

- 63. Yes. Mitual aid agreements infer that service provided does, l,

I not entail danger to ambulance enployees or possible loss of a vehicle.

The districts outside of the EPZ require the same consideration that districts inside the EPZ or in counties impacted by the PEP EPZ, if they are . expected to respond to an accident at Callacy Plant, Unit 1.

64. See 63, above.

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65. Road Contention 13, it clearly identifies insufficiencies.

66. Object, see 58, above.

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67. ' object, the' answer calls for a conclusion based upon how Applicant appears to view a statement made independently of actual ccritentions.

68. No. They will reopend more effectively if they have some capability to act in their om defense and do not have to wait upon decisions of persons outside their consnunities. Tbn sans concept is applicable to the counties if they were relegated to a non-action role, for the purpose of obtaining simplicity in plans preparation, and the State was made solely responsible for initiating all protective actions envisioned in the planning process.

69. No, see 68, a',ove. ,

70. The use of local personnel is required to effectively evacuate the citizens in and around population centers. The fact that such tom s do not have the equipment or formal organisations to consnit to the response effort is prime-facae evidence that they need to build a capability to protect their citizens in the event of an accident that involves the release of dangerous radio-nuclides. As tous or villages incorporated l under Missouri State statute, they have a right to become involved in the

planning effort.

71. Object, this question is without basis, since it is possible to envision the relief of all local governmental involvement in radio-logical emergency response planning if one eliminates consideration of' the provisions of NUREG 0654, I, E., which states:

The concept of EPZs necessarily inplies asitually supportive emergency planning and preparedness arrangements by several levels of government: Federal, State and local governments, including counties, tomships and even villastes. (emphasis added)

J Incorporated villages are defined as part of the emergency planning 4

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! " effort and 'must' be included therein.

72. See the lists of such agencies and oospanies in the proposed local' plan and each county S W .

73 No. Without a formal agreenent by an individual to participate in the Offsite Plan, no viable list of manpower is available, also, no roster of personnel is available to insure that appropriate individuals receive the specialised training necessary to perfom their specific job.

74. see 61, above, the sans reasoning applies. Object-to the final portion of this question as f-ivilous and insnatorial.

75. Object, this question is frivilous and inunatorial.

76. Object, see 29, above. ,

77. Object, the form of this question takes in a satitiplicity of overlapping areas that are affected by seasonal weather conditions which have/ in the past and may in the future, preclude travel from residences

-for days at a tims. Snow-falls and ice storms affect the entire region.-

additionally, this is a function of the planning process, see 57, above.

78 Instructions providing residents with informatimt that they have been placed in a situation dierein no protection exists to assure the hoslth and safety of themselves'or-thhils! children if shelter exceeds one hour, more or less, if they have taken shelter in a building which is suitable for winter habitation and the windows are closed and the ventilation ,

I systems are shut off. The instructions should include notice that such protection is not provided for any time length if they are outside.

79. NUREG 0654, at I, E, page 20, indicate that sheltering, thyroid blocking, evacuation are insnediate protective measures associated with the plume exposure pathway.(PEP) EPZ, and at J, e. page 63, it calls for use of KI by personnel whose insnediate evacuation may be infeasible or 4

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very difficult. If individuals are placed in a position'in.which they are desned if they stay in shelter and danned if they leave;. they should 1

be told the truth and not deceived in order to cover-up incompetence by plannersand/orelectedofficials.

80. Object, a person cannot be expected to identify that which he or she does not know to be in existance.

81. Yes. NUREG 0654, at I, 8, requires rapid assessment of actual magnitude and locations of radiological hasards. This precedes the requirement to measure radiciodines (at I, 9). The definition >f " rapid" would appear to preclude waiting for a Federal team to arrive from Washington DC or elsewhere and deploy in an area with which they are unfamilar before such measurements can be made. The location of radioiodine concentrations could have traveled many miles undetected before a Federal team arrived.

82. See the State RERP (at A1B.1 and A2B.1 - A2B.2),' the Bureau of Radiological Health has atly enough equipment to field 8 persons within -

the 10 ndle and 50 ndle EPZs, they lack f.odine detection equipment and the use of National Guard personnel is limited to areas wherein their per.sonal safety from hazardous radiation is assured (see AG-7, Consander's Statematt, dated 1 July '82). Additionally, such NG personnel are not proficient in the use of Civil Defense equipment, .to date (see AG,Section II, Training).

83. See 82, above.

84. None at present, but such can be provided if the eg ability is l-built at the local levels of government as directed in NUREG 0654, II, I, 8.

85. There is no clearly outlined provision indicating how protective measures will be implemented as mandated in NUREG 0654, I, J, page 29, lines 10,11, and 12.

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^86. -Plans' lack-clear guidance as required in the reference in 85, abovo..

87. A local capability is required as cited in th's contention, the undersigned does not see a necessity or requirement to argue or to

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disagree with Commission standards or criteria. See NUREG 0654, I, C, page 5, lines 13, 14 and 15.

88. . Any methods which resolve the problem) this is a function of the planning process, see 57, above.

89. No. The problem is couplex, but not without solution. Resolving this issue is part of the planning process, see 57, above. It est be resolved before the requirements of NUREG 0654, II, J, K, are to be met.

I 90. Object, see 41, above.

91. section 10.0 tails,0-meet the standards',ofcp1h==9=g:which requires a, clear statement:,of:hok a:foncthuvis perforsped,twho@erformsvith.when, and idiereis uch functikwill be performed, 'etc. No basis for permitting excessive exposures, meeting this criteria, is delineated.

92. Annex D does not contain guidance for authorizing exposures in l

excess of EPZ gene'ral public PAGs including lifesaving activities (NUREG 0654,II,K.4).

93 Knowledge of how to safely function in a radiological environment is applicable to any such environment and does not depend upon the color or cut of the clothing wom by those who must perform such function. The degree of detail involved in a given function is established by the

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complexity of said function; failure to enumerate those details in a plan does not negate their existance or their need to be performed, if the function is to be accoglished. The ability to accomplish a given task (function) within a specified tims frame and within established parameters l

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• of accuracy is dependent upon what skill levels have been attained by the person involved, not where those skills were attained. The basic principles of biological defense against nuclear radiations are the same for soldiers, farmers, lawyers, and any human. Time, distance, and sheilding, applysto pr+tection of poople -(and other animals) from the l dangers of radiation and knowledge of how to manipulate these principles, plus practical experience in the field is a basis for qualification. The nuclear industry eagerly accepts the military qualifications of service trained individuals Wto have experience in the " military nuclear field",

e.g. nuclear submarine specialists, etc.

The appropriate level of detail in any plan, is that level at which guidance for those taking part in the plan is clear enough to insure they know what to do, how to do their assigned tasks, when and where such

. functions anst be performed, and what relation their assigned jobs have to the " big picture". Sufficient detail nust be established so that an operational concept is provided by the plan over time, so that the idea -

of how the mission will be accouplished does not slowly vanish as personnel changes occur in the operational leadership and proposed work force.

In a full-time military organization (which is a part of the civilian governmental organization), the operational leadership has been trained and is fully conpetent to plan'and organize organi~zational missions'that are i

within the technical limits of expertise available in the organization which the organizational leaders belong. If they nust operate or function in situations which exceed their technical limits, they are provided the i necessary training and/or equipment and personnel to accomplish the job.

Wars are not conducted on a routine, daily basis; they are (for the most 4

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'part) serious,-but* highly inn equent' emergencies at-a national governmental l

level. l l In contrast, civilian governmental organisations are headed by~

leaders who have not had extensive training in the skills needed to plan or execute a defense mission. This fault in leadership is, at the local levels of govemment, vividly apparent when discussing radiological emergency response; officials sisply do not have the necessary techr.ical expertise with which they can evaluate information and reach a decisica en their own cognizance. As a result, they rely heavily upon " experts" i to make the decisions and then perform a " rubber stag" function by initiating actions based upon a decision that they do not understand and hope that all turns out well. The " expert", regardless of his actual capability, has control of the situation from the " cat-bird's seat"; he or she can blame their mistakes on others with impunity, sisply because he~ or she is, the President" expert" and is all-knowing. Who, but another

" expert", is qualified to challenge "Mr. Knowitall"?

Because of an absence of technical expertise in the ranks of local governasntal officials (in areas of planning, operations, logistics, l communications, and radiological defense, etc.) it is necessary that

(

plans involving such areas be detailed enough to provide guidance as to how functions are to be performed, rather than simply indicate that something sust be done and let it go at that. The "how to" portion of the plan /l!NP serves as a training vehicle by which officials can become proficient in meeting their responsibilities. Plans which are over-generalised, are indicative of incompetence on part of the planner and i those that approve such plans. The Commission basically agreed with this planning concept in NUREG 0654, I, J.. The apparent problems have 0

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i arisen due to attegte by planners to circumvent the intent of 0654 and meet as few standards and criteria as is possible so that an operating license can be obtained for the Callaway Plant, Unit 1.

Training, which is of paramount importance in any operation that involves coordination of moveesnts, is currently being considered and proposed by Union Electric Company planners at levels that are inadequate to do'more than provide plan participants an introduction to the information they i will need to become proficient in their assigned duties. In a situation such as is posed by a nuclear power plant accident and the potential for infrequent occurance of such an accident, a viable, thorough training program is necessary in order to maintain a suitable level of proficiency on the part of those who will respond to such an accident.~ Without such a program, comanon sense dictates that-initis'. levels of proficiency will drop until no capability (except one on pper) exists at all to protect the public health and safety.

94. A formal witness list has not been prepared yet, but should consist of elected and appointed State and local officials (and myself).

95. I have received no assiatance in answering these questions.

END & RESPONSES TO INTERROGATGLIES I affirm that the answers, abovej- e true to ny best knowledge and belief.

Dated this b 4 day A geed /

ohn G.

of November, 1982 ? Citizen of the United States at Kingdom City, 10. of America RFD #1 Subscribed and sworn before Kingdom City, MLosouri 65262 me this 4/D day of Nov. tels (314) 642-2769 1982 L$$kl wZl' A -

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U:. "Ti.D ".TATL3 CF AFS.ICA UUCLEAR hh0ULMORY COEISSION ,

BEFORE THE ATOMIC SAFETY AND LICENSINC BOARD In the Matter of )

)

UNIQi ELECTRIC COIPANY ) Docket No. S'Di 50-483

)

(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that the document attached hereto was served this

.22. O day of e. der,1982 by deposit in the U.S. mail, first class postage prepaid upon the fcllowing:

James P. Gleason, Esquire Mr. Glenn O. Bright Chairman, Atomic Safety and Atomic Safety and Licensing Board Licensing Board Panel Panel 513 Gilmoure Drive U.S. Nuclear Regulatory Comission Silver Spring, Maryland 20901 Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section-Atemic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory Co=ission U.S. Nuclear Regulatory Conmdssion Washington, D.C. 20555 Washington, D.C. 20555 Robert G. Perlis, Esquire Kenneth M. Chackes, Esquire Office of the Executive Legal Director Chackes and Hoare U.S. Nuclear Regulatory Comdssion 314 N. Broadway Washington, D.C. 20555 St. Louis, MO. 63102 Thomas A. Baxter, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

Washington, D.C. 20036 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Comission Washington, D.C. 20555

• hand delivered LA/

/ John G. Reed Citizen of the United States of America

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