ML20238F159

Testimony of Je Harkins Re New England Coalition on Nuclear Pollution Contention NHLP-4.* Related Correspondence

ML20238F159
Person / Time
Site:	Seabrook
Issue date:	09/11/1987
From:	Harkins J GALLAUDET UNIV., WASHINGTON, DC, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:
Shared Package
ML20238F154	List: ML20238F152 ML20238F156 ML20238F159 ML20238F165
References
OL, NUDOCS 8709160006
Download: ML20238F159 (9)

Text

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'l j September 11, 1987 UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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Public Service Company of; )

New Hampshire, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 & 2) )- OFFSITE EMERGENCY,

) PLANNING-

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TESTIMONY OF JUDITH E. HARKINS REGARDING NECNP CONTENTION NHLP-4 Q.1. Please state your name and your qualifications.

A.1. My;name is Judith Harkins. I am the Director of the Technology Assessment Program at Gallaudet University in Washing-ton, D.C. Gallaudet University is a' multi-purpose educational institution and resource center that serves hearing-impaired per-sons around the world,through a full range of academic research and public service programs. I hold a-Ph.D. in the field of spe-cial education and rehabilitation administration and am an expert in the use of technology by hearing-impaired people. I have worked with hearing-impaired people for 16 years. A resume of my qualifications is attached to my testimony.

I-Q.2. What is the purpose of your testimony?

A.2. The purpose of my testimony is to evaluate the provi-sions made by the New Hampshire Radiological Emergency Response Plan ("RERP"), Revision 2, for notification and instruction of i

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. hearing-impaired individuals during a radiological emergency at the Seabrook nuclear power plant.; I Q.3. Please describe the documents you have reviewed in ,

l preparing your testimony.

l A.3. I have reviewed those portions of the New Hampshire 1

Radiological Emergency Response Plan ("RERP"), Revision 2, which ostensibly provide for the notification and instruction of hearing-impaired individuals in the Seabrook emergency planning r zone ("EPZ"), in the event of a radiological accident at the

-Seabrook nuclear power plant. I have also examined the Applicants' Motion for Summary Disposition of New England Coali--

tion on Nuclear Pollution Contention NHLP-4,-including the affidavits of Gary J. Catapano and Richard H. Strome (hereafter "Catapano affidavit" and "Strome affidavit.") This motion was l

filed with the Licensing Board on June 11, 1987.

Q.4. Based on your review of these documents, what opinion have you formed concerning the adequacy of the RERP?

A.4. The RERP specifies that tone-alert radio receivers with visual alerting lights will be distributed to hearing-impaired residents in the EPZ. Upon activation, the tone-alert  ;

radio receivers produce an audible alert tone, followed by information and instructional messages carried by the EBS l

network. RERP Vol. 1, pages 2.1-14-15 (Rev. 2, 8/85). The Catapano affidavit does not specify that the light will flash upon activation, but simply that it will "come on."

I have found a number of gaps and inadequacies in the plan's provisions for alerting and instructing hearing-impaired l citizens. The problems noted are as follows:

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f 1) The term " hearing-impaired" covers a range of severity ]

1 of hearing loss. Many hearing-impaired people do not have hear-ing aids. Among those who do, many do not wear hearing aids )

'while in the home. The RERP does not specify the loudness and pitch of the tone produced by the tone-alert radio. Thus, it does

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not demonstrate whether the tone and pitch have been selected so as to be audible to persons with a hearing impairment, or for what range of hearing impairments the " tone" would be effective.

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2) Moreover, the RERP does not describe the light on the 5

tone-alert radio. From the.Catepano affidavit, it seems that.the light would simply go on, and not flash.- If it does not flash, 1 there is a reduced likelihood that it would be detected. If the light does flash', but emits a weak light, it is not likely that the hearing-impaired person would notice it unless he or she

. happened to look at it. The visible signal should be bright enough and distinctive enough to be recognizable as a unique sig-nal for a radiological emergency.

3) The " tone" may not be audible outside of the room con-taining the tone-alert radio. The plan fails to specify how many tone-alert radios will be distributed to each hearing-impaired household. For a person who cannot hear the tone, if the radio's flashing light is not in the same room with him or her, that per-son will have no way of receiving the alerting message. In order i

to insure notification, radios should be placed in at least three rooms in each house: the bedroom, the kitchen, and the room in l which reading or television-watching is done.

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i 4)f The tone-alert signal-should be capable of awakening a L person who is asleep. Some hearing-impaired people say they can-not be awakened by a flashing light and so they use systems that shake the bed or vibrate under a pillow.

5) The RERP does not state whether the tone-alert radios are battery-operated or whether they are dependent on the house's electrical. system. Tone-alert radios should have an independent power source'so that they can perform their alerting function during a power outage.

6) According to the Catapano affidavit, labels will be affixed to tone-alert radios with instructions for the' hearing-impaired to follow if the tone-alert radio is activated. Par. 2.

Presumably, those instructions would refer the hearing-impaired individuals to some source of information regarding the specific emergency response actions that should be taken under the partic-ular conditions of the radiological accident; however, the plan does not provide a copy of those instructions. Without thase instructions, it is impossible to determine how, other,than by the assistance of neighbors, the State of New Hampshire plans to instruct hearing-impaired individuals regarding what specific emergency response measures they should take.

7) According to a recent revision of the " Emergency Public Information Calendar" instructions, which provide information on actions to be taken in the event of a siren warning of a radiological emergency at the Seabrook plant, residents in the EPZ should check to see if neighbors who cannot hear well have understood the siren and the emergency message, if they can do so

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without using a phone. This revision of the Calendar is attached as Exhibit "A" to the Strome affidavit. Reliance on third parties, who may or may not be home, to alert and instruct their hearing-impaired neighbors, is an inadequate means of alerting the hearing-impaired in the event of a radiological emergency.

Moreover, hearing loss is an invisible disability. The RERP does not specify how EPZ residents are to be made aware of the hearing disabilities of their neighbors.

It should also be noted that the Calendar's instructions to neighbors of the hearing-impaired are contradictory; at the same time as residents are requested to " check on" their hearing-impaired neighbors, they may also be instructed to take shelter by going indoors and staying indoors, closing all doors and windows. This renders third party notification even less reli-able.

8) I am not aware of any other means, which are presently available on the market, by which hearing-impaired individuals could receive consistent and reliable instructions during a radiological emergency. Radio broadcasts would be ineffective for instructing a large portion of the hearing-impaired popula-tion. Emergency instructions would be effective if broadcast on television via open captions or other means of broadcasting a text message, liowever, in the event of a power loss, television would not be accessible. A broadcast text message to a special receiver and printer might be a workable option.

9) Based on the foregoing considerations, I have concluded that the RERP does not demonstrate that sufficient or proper

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l. equipment is in' place to provide a reliable or' effective'means

'for alerting and instructing the deaf and hearing-impaired EPZ --

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! residents of an accident at the Seabrook nuclear power plant.

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Resume Judith E. Harkins, Ph.D.

Current Position

' Director, Technology Assessment Program (1985-precent) y 1Gallaudet Research Institute '

800. Florida' Ave., N.E.

' College Hall 408-Washington, D.C. 20002 Responsible for directing research programs on applications of technology-for deaf and hard of hearing people. Current projects within the program include needs assessment on sensory aids; study of' financing mechanisms available for the acquisition of devices; study of emergency. technologies; and feasibility study of. government initiative in stimulating devices industry.

Specialized Professional Comoetence Education and. rehabilitation of deaf and hard of hearing persons, rehabilitation technology, research management, research dissemination.- Fluency'in sign language.

Other Professional Experience Director of; Dissemination, Gallaudet Research Institute.

(1980-85)

Managed publications program for Institute of 25 research-ers, created Institute newsletter on research, served as con-tributing editor on research for teachers' magazine. Supervised projects directao at applying research findings. While serving as director of thii program, also served temporarily as budget officer for the Rea,earch Institute.

Renearch Associace, Education Turnkey Systems, Inc., Falls Church, VA. (1979-80)

Conducted national needs assessment on training needs of recipients of Federal funds; coordinated nine regional workshops and provided technical assistance on implementing Section 504 of the' Rehabilitation Act of 1973.

Doctoral Intern, National Association of State Directors of Spe-cial' Education. (1978-79)

Tracked Federal policy development on coordinating special education, vocational education and vocational rehabilitation

. services for disabled youth.

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Executive Director, American Deafness and Rehabilitation Associa- q tion. (1978-79) p Managed home office of national association of rehabilita-tion professionals serving deaf clients.

Consultant, Maryland Community Colleges. (1978)

Conducted statewide planning study on providing services and programs to disabled students in Maryland Community Colleges.

Project was carried.out with the advisement of a blue-ribbon com-mittee of State agency heads and consumer leaders. ,

i Project Director, Feasibility Study of Postsecondary Education for Deaf Persons in' Maryland. (1976-78)

Conducted needs assessment, analyzed employment projections, surveyed deaf adults, and assessed service delivery options for provision of postsecondary education to deaf persons in Maryland.

Study resulted in establishment of a community college program for deaf students in the Baltimore area.

Administrative Coordinator, Maryland School for the Deaf.

(1973-75)

Coordinated certain' administrative projects (accreditation L self-study, curriculum development, parent programs) for a two-campus state residential school for deaf children.

Teacher and Work Experience Coordinator, Maryland School for the Deaf. (1972-73)

Taught deaf children and youth aged 10-19.

Academic Backaround l

B.A., French and Latin, Western Maryland College, 1972; M.Ed., Education of the Deaf, Western Maryland College, 1974; M.A., Administration and Supervision, California State Univer-sity, Northridge, 1976; Ph.D., Education Administration, Gallaudet College, 1984.

Publications Harkins, J. and Jensema, C. (in preparation). Focus group dis-cussions with deaf and severely hard of hearing people on tech-I nology for independent living.

h Compton, C. and Harkins, J. (in press). Rehabilitative technol-ogy for hearing impaired persons. In A. Enders, Technoloov for Independent Livina Sourcebook. Washington, D.C.: Rehabilitative Engineering Society of North America.

Harkins, J. (1987). Disabled consumers: an exploratory opinion survey on telecommunications. Princeton, N.J.: Opinion Research Corporation.

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Wolff, A.B. and Harkins, J.E. (1987). Additional handicapping conditions. In M.A. Karchmer and A.S. Schildroth (eds.), Deaf Children in America. San Diego: College Hill Press.

Harkins, J. (1983). Telecommunicating in tomorrow's world. Per-

! spectives for Teachers of the Hearina Imoaired. 1(3), 16-18.

Harkins,.J. and Kerstetter, P. (1983). Innovations in Educatina D,eaf Students. Silver Spring, Maryland: Convention of American Instructors of the Deaf.-

Harkins, J. and Vernon, M. (1980). Employment projections assist deaf clients in career choices. American Rehabilitation, 1980, 6(1), 19-24. 1 Maryland State Board for Community Colleges (1979). Statewide Plan for the Delivery of Occupational Procrams and Services to Handicaoned Students. Annapolis, Maryland: SBCC.

Harkins, J..(1978). Feasibility Study of Postsecondary Education for Deaf Students in Maryland. Columbia, MD: Howard Community College.-

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