ML20023C730

Testimony of D Turner Re Emergency Preparedness Contentions. Concerns Include Procedures for & Modes of Carrying on Emergency Communications,Transportation Difficulties & School Liability

ML20023C730
Person / Time
Site:	Byron
Issue date:	02/10/1983
From:	Doreen Turner DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:
Shared Package
ML20023C710	List: ML20023C708 ML20023C715 ML20023C717 ML20023C722 ML20023C726 ML20023C730 ML20023C732 ML20023C734
References
ISSUANCES-OL, NUDOCS 8305170588
Download: ML20023C730 (12)

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i Joint Intervenors' Exhibit 18 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD e

In The Matter of )

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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL

) 50-455 OL

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(Byron Nuclear Power Station, )

Units 3& 2) )

AFFIDAVIT OF DAVID TURNER 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, informa tion , and belief.

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.i David Turner Subscribed and sworn to before me this *> day of..~ ..

, . , , . , , 1983. ,

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Notary Public l

l 8305170500 830512 PDR ADOCK 05000454 PDR

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TESTIMONY OF DAVID TURNER 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.

c Q. Please state your name, present occupation and present position.

A. My name is David Turner. I am the Superintendent of Schools for the Mt. Morris Community Unit #261 ("Mt. Morris C. U.").

Q. Briefly state your educational and professional qualifications.

A. I have a Bachelor of Science degree in Elementary Education from Millikin University and a !! aster of Science degree in Educational Administration from Northern Illinois University in DeKalb, Illinois. I have 25 years total teaching and administrative experience. I was a principal for Polo Elementary School for six years before coming to the Mt.

Morris School District. I have been the superintendent of the Mt. Morris C. U. since 1969.

Q. To which contention is this testimony addressed?

A. Dnergency Preparedness: DeKalb Area Alliance for Responsible ov***[k Energy /Sinnissippi Alliance for the Environment ( " DAARE/S AFE" )

Contention 3, and Rockford League of Women Voters ("Rockford LUV") Contentions 19 and 108.

Q. Which Mt. Morris C. U. schools are located within the 10-m ile plume exposure pathway Duergency Planning Zone ("EPZ") for the Byron Nuclear Generating Station (" Byron Station")?

A. Mt. Morris Elementary, Mt. Morris Junior High School ~, and the Mt. Morris High School are all located 7 to 8 miles west-southwest of the Byron Station.

Q. What preliminary or final emergency plans are you f amiliar with?

A. The Illinois amergency Services and Disaster Agency ("IESDA")

sent to me an initial draft 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, Draf t, was dated December 1982 and accompanied by a cover letter dated November 29, 1982, from Mr. David L. Sm ith , IESDA Chief of Operations, I

l Byron Dmergency Plan. The school superintendent's portion of IPRA-Byron, Draft, and cover letter are attached to l this affidavit as Exhibit A.

l l DAARE/ SAFE and Rockford T.WV 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 0, 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 Bnergency Planning Zone for the Byron Nuclear Generating Station" (Evacuation Time Estimates-Byron),

which is based on the feasibility and the official execution of these IPRA-Byron, Revision 0, plans and procedures.

Section 4.2 titled "Special Pacilities 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. In fact, that has been the 'xtent of my contact with IESDA and Commonwealth Edison planners. 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 i

staff at each Mt. Morris C. U. school, and the number of l vehicles to which I have access. I also received a visit from two IESDA representatives on October 29. 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 Dyron Station.

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- 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 November 29, 1982, was a request for a " timely review" of the IPRA-Byron Draft (Exhibit A). I received the IPRA- ( f Byron, Draf t, midweek and was expected to critique the plan by the next week when two IESDA representatives were to visit. This was not a sufficient length of time for me to fully consider the draft plan. Nor did I have enough time or information to bring the draft plan before the Mt. Morris C. U. School Board. I told the IESDA officials on December 6 that Mt. Morris C. U. would not participate in the plan until the Board approves our role. I am of the opinion that neither my input nor my opinions were of any significant importance to IESDA planners.

Q. What are your primary concerns regarding the emergency roles for which you are given responsibility in the IPRA-Byron, Revision O?

A. Generally these concerns are: (a) procedures for and modes II 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 l for damages caused or injuries sustained by Ogle County l

citizens (including school district employees) while emergency 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, (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, a ding to the IPRA-Byron, Revision O, must you maintain communica s during an emergency?

A. The Ogle County uperintendent of Educational Services, the Fire Protection ' trict Chief, school administrators at Mt. Morris High School,4 Morris Junior High School, and Mt. Morris Elementary (Exhibi D).

Q. Are there any othe ommunication capabilities which are assumed but not stated di ctly?

A. Yes, I must be in act with all field personnel (bus drivers).

l Q. What communicatio systems do you presently have available for such communicatio o A. Communicati s with school administrators, the Ogle County Superintendent f Educational Services, and for the notifi-l cation of school s drivers will depend upon commercial telepnone lines.

For field personne we have two-way radios in our

. seven buses with a base sta 'on in my office. If I follow the IPRA-Byron, Revision O, hov ver, I will abandon this base station and report to the Mt. Morris Police Station.

Q. Will these lines be hgfficient in an' emergency?

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, A. No. Should an overload of telephone lines occur, I would have limited mea of receiving or disseminating information.

I would not be noti ~'ed of the progression of the emergency situation. F6r examp , I may be lef t completely in the dark if an initial orde for a protective action, e.g. for sheltering, is changed to order for an evacuation.

With regard to the diss inatic . of information, efforts to keep school administ tors abreast of the situ-ation or to summon bus drivers by eans of telephone will also depend on the integrity of the mmercial phone lines.

Q. Do you have the c ability to evacuate your entire student population in one tr p?

A. No, I do not. I pr sently have access to seven buses with a total capacity of 4 0. The district's student population alone is 767. During a evacuation, almost the entire bus fleet would have to return for a second trip. Any trans-portation of the " general po lace," as in IPRA-Byron, Revision 0, would requ!.re thir and fourth trips.

O. What other factors determine the availability of I

transportation?

i A. Certainly the ability to mobilize drivers, which is dependent upon their willingness to serve as emergency workers and their availability. ":n; ""- Ari.;.. _11; Le Al'ficult t: nt'e* haranen

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l ici;;' :: :; t:z ti:5 ;;;ld i: :::rl:-'^' '"-i.., -  : :r Apungr. Once contacted, drivers may, understandably, choose to evacuate with their own families. And it is clearly the case that thd' number of willing drivers will decline with each successive trip.

l Q. Approximately how ch time would be required to mobilize l

personnel sufficient t man all available buses?

l A. At least thirty min es would be required. This estimate assumes that everyone n be easily contacted which, for reasons stated above, is ot the case. At night, on week-ends, during holidays, or o summer 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 13 sustained during the execution of responsibilities assigned i

to you in IPRA-Byron, Revision O?

A. The Mt. Morris C. U. is insured for the transportation it 1

provides to the students of the Mt. Morris C. U. only. The-

\S 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) (2), page 224, and (VI) (2f),

page 19, 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 of the seventy Mt. Morris C. U.

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o 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 evacuation would be hindered by the delay in availability of family vehicles?

Q. Have you made any attempts to clear up this matter via g3 IESDA officials?

A. Yes. I explained to the two gentlemen who visited me during the week of December 6 that I had concerns which would be  !$

brought before the Mt. Morris School Board before the plans would be approved.

Mr. Maloney, e Leaf River Superintendent, was desig-nated as our contact wi IESDA concerning the liability question. Mr. Maloney's thre onth effort has been unsuccessful.

! Q. What information have you been given on relocation?

A. None. Emm pl;..; d; ;;is t .. t: ;tep et mac ooruet mf I

the t: -ila PD7 - T Aa rt Luww wucte une uu.ld mu will h^ t;h; . . , Or 5:- 6ha" "ill i; mun ssJ rith their f;;.ili;;.

Q. 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 l Estimate Methodology and Assumptions," pp. 4-6 and 4-7, 1

and Section 6.2 "Special Facilities Evacuation Times," as l

l well as Table 6-2 where these time estimates are found.

I (See Exhibits C and D, respectively.)

. Q. Briefly, what is methodology used?

, A. The total evac tion time for Mt. Morris C. U. is 50 minutes.

The total evacuati time is divided into mobilization time and travel time. obilization time is assumed to be 45 minutes (15 to notify m 30 minutes to mobilize drivers, drive to the schools, and prep e students for departure).

The travel time out of the EPZ is en minimal: five minutes.

Q. Are these Inqurate estimates?

A. No, since 30 minu s is the absolute minimum amount of time necessary to mobilize drivers. Furthermore, since more than one trip will be require the mobilization and travel times must reflect the time requir to drive to the sheltering area, unload, return to the sch 1s, and again travel out of the EPZ.

Q. Did the document state the source of these mobilization and l

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."

[ emphasis added] Commonwealth Edison " Evacuation Time Estimates" at 4-6. And further, "The thirty-minute average l

time for preparation to enter the roadway conforms to the i

l 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. I do not recall giving the IESDA representatives such an estimate . Thirty minutes would not be an average time and

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would only be attainable on a school day if phone lines are intact.

Q. Sheltering is another possible protective measure which may be prescribed in the event of an accident at the Byron Station. Have IESDA of ficials given you any information on sheltering procedures in response to such as accident?

A. No, they have not.

Q. Are you aware of what is meant by " sheltering," pursuant to IPRA-Byron, Revision O?

A. As I understand the matter, sheltering will be prescribed yr.cysy Y.p for those populations in the affected area who cannot

$d evacuate in an acceptable time period. Sheltering involves hf g( .

staying inside, closing all windows and doors, and going i

Mf"/>s g '3 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.

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Q. Have they inquired as to the feasibility of sheltering students in your buildings after radiological release from the plant?

A. No, they have not.

l Q. Do your buildings have suitable facilities (basement or windowless areas) for sheltering?

A.

j %-. No, they do not.

, O. Do you see any further oblems with using sheltering as a protective action?

A. Yes. If she ring is prescribed as a protective action and an evacuatio is later advised, I would have only a commercial telepho to receive the message, summon bus drivers and notify other uildings. As I established earlier, telephone communic ions are of limited reliability, at best.

Q. Have IESDA or Commonwealth Edison given you any indication that they will make any ef forts to ease the financial burden @

of acquiring badly needed communications equipment, training or evacuation experience?

A. No. In August 1982 several other school superintendents and myself were told by Ray Appler, Ogle County Superintendent of Educational Services, that we would be given equipment by IESDA. Mr. Appler was later told by an IESDA official that he had misunderstood discussions with IESDA represen-tatives on this matter.

Q. On the basis of your education and professional experience, your knowledge of the Mt. Morris 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. No, I do not. School districts and their buses play a key role in the IPRA-Byron, Revision O, and yet school super-intendents have not been allowed to shape the plan or even have important questions answered. This being the case,

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• the plan cannot be a workable one. School districts, unlike fire departments or ambulance services, have no standard operating procedures as a base for emergency operetions and communications. Therefore, we require more guidance and e

a more active role in the planning process.

t I am willing to cooperate with planners. They could potentially do my district a great service. At this point, however, neither the plan nor the planners have brought me closer to developing the capability to protect the health and safety of schoolchildren during a radiological emergency.

Affiant incorporates the material contained in Exhibits A, B, C, D, E, and F, attached hereto, as part of his testimony.

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