ML20023C732

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Testimony of D Miller Re Emergency Preparedness Contentions. Concerns Include Procedures for & Modes of Emergency Communications,Transportation Difficulties & School Liability
ML20023C732
Person / Time
Site: Byron  Constellation icon.png
Issue date: 02/28/1983
From: Miller D
DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:
Shared Package
ML20023C710 List:
References
ISSUANCES-OL, NUDOCS 8305170590
Download: ML20023C732 (12)
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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 )

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)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454 OL

) 50-455 OL

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(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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l ,,3 David Miller

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Subscribed and sworn ~ to before me this ' day of ./ o , . . , 1983.

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Notary Public G

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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" )

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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

  • population in one trip.

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

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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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