ML20082C970

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Testimony of Nj Muto & Jt Smith on Contention 25 Re Role Conflict
ML20082C970
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 11/18/1983
From: Muto N, James Smith
SUFFOLK COUNTY, NY
To:
Shared Package
ML20082C880 List:
References
ISSUANCES-OL-3, NUDOCS 8311220273
Download: ML20082C970 (10)
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  • P UNITED STATES OF AMERICA NUCLEAR EEGULATORY COMMISSION Before the Atomic Safety and Licensing Board

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In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

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DIRECT TESTIMONY OF NICK J. MUTO AND J. THOMAS SMITH ON BEHALF OF THE MIDDLE ISLAND CENTRAL SCHOOL DISTRICT AND SUFFOLK COUNTY REGARDING CONTENTION 25 - ROLE CONFLICT Q. Please state your names and positions.

A. My name is Nick J. Muto. I am the Superintendent of the Middle Island Central School District.

My name is J. Thomas Smith. I am the Transportation Coordinator of the Middle Island Central School District.

Q. Where is the Middle Island Central School District located?

A. Middle Island Central School-District-is located in tie middle of Suffolk County,' Township of Brookhaven. The entire' district is within.a 10-mile radius of the-Shoreham Nu-clear Power Plant.

Q. How many schools are in your district?

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A. There'are six schools currently located within our 53 square mile district. They are Longwood High School, Longwood Road, Ridge, New York; Junior High School, Middle Island-Yaphank Road, Middle Island, New York; Coram Elementary, Mt. Sinai-Coram Road, Coram, New York, Charles E. Walters Ele-mentary, Everett Drive, Yaphank, New York; Ridge Elementary, Ridge Road, Ridge, New York; and West Middle Island Elementary, Swezey Lane, Middle Island, New York. A new high school has been proposed to be built near the site of the existing Longwood High School.

Q. Approximately how many children attend schools in your district?

A. Approximately 8200 children attend our schools. 1500 additional students reside in our district but attend schools outside of the district boundary lines.

Q. Are you familiar with the provisions of the LILCO l

l Offsite Emergency Response Plan for Shoreham that specify that in the event of an emergency during normal school hours, schools within 10 miles of Shoreham will be advised via the Emergency Broadcast System to institute an early dismissal of students? (Plan at 3.6-7). Are you also familiar with Emer-gency Planning Contentions 25.C and 25.D?

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A. Yes we are.

Q. Do you agree with those contentions?

A. Yes we do.

Q. Please describe the personnel required to implement an early dismissal of the schools in your district.

A. The following types of personnel are required for im-plementation of an early dismissal: central office administra-tion personnel, transportation contractor personnel (estimated to be a total of 144 individuals), school administrators, teachers, and other district employees. These people are nec-essary to perform decision-making and notification functions, transportation of children, supervisory and other logistical duties.

An early dismissal of all schools at peak school time would require the full compliment of school administrators, teachers, and other district emplovees, totalling more than 700 people.

Q. In your opinion, in the event of a radiological emer -

gency at Shoreham, would these people be likely to remain at or report to school or their posts to implement an early dismissal rather than first attending to the safety of their own families?

A. No. In the event of a radiological emergency, we believe that it would be impossible to maintain a full staff (teachers, drivers, etc.), especially for a period of at least three hours, which is the minimum time necessary to accomplish this district's early dismissal plan under the best of ord'7ary circumstances (i.e., not a nuclear emergency). We believe that concern about the whereabouts and safety of their own family members would supersede the staff's ability to perform their duties connected with an early dismissal.

O. In your opinion, would it be possible to have a safe early dismissal without a sufficient number of necessary per-sonnel available?

A. No. To effect a safe early dismissal of any large school district requires adequate logistical capabilities, namely buses and bus drivers, as well as the necessary school personnel to direct the dismissal and supervise the children.

This means that the necessary large numbers of people must be those who have been trained to do specific jobs at specific times. In Middle Island, with respect to transportation alone, l this involves the driving of 589 individual routes which entails over 11,740 bus stops. It also means having drivers with the capabilities to succe.ssfully manage mechanical break-downs, traffic delays, and student and personnel problems which l

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i are normally encountered each day. In our district, under the best of circumstances, it would take three hours for all chil-dren to be delivered home. If less than the necessary number of personnel were available, which we believe would be the case in the event of a radiological emergency, the take-home process would take much longer and could not be safely conducted.

Q. Would you permit any LILCO personnel or others not normally affiliated with icur schools to order and/or implement any or all parts of an early dismiscal?

A. The safety and welfare of the children legally entrusted to our care is our paramount concern and responsibil-ity. At this time, we are not in a position to relinquish this responsibility to any outside agency, including LILCO.

Q. Has your district stated elsewhere its position regarding response to a Shoreham emergency?

A. The Middle Island Board of Education adopted a reso-lution on September 29, 1983, stating its belief that 1.icensing of the Shoreham Nuclear Power Plant should be forbidden unless problems associated with the LILCO-proposed emergency plan are

! resolved. The resciution cites twelve specific weaknesses in LILCO's emergency plan for schools. The resolution states that "the district finds LILCO's emergency plans for schools do not i

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l j offer children, school personnel, or parents of the district

( adequate protection in the event of an accident." The Board resolved that the School Board cannot direct its schools to in- 1 itiate or participate in an emergency action which not only l fails to protect childrens' safety, but places it in further t

i jeopardy. A copy of the Resolution is Attachment I hereto.

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federal regulations for full pcwcr. operation of the Shore 5 A10 :5 ham l'uclear Plant require .ch an emargency w:.ll assureplan those for commpTg..-

comm.un.i.ti.e.s.y. .

surround:..ng the plant wh:. .

adequate protection 2.n event of a nuclear emergenci,g,gg -.ga.m pe CHCPIAS, the Long Island Lighting Corpany, i.n an effort to meet feders'. regulations, has prepared an emergency plan which LILCO, lacking coordination with local or state governments,

'will ntr.e pt to implement; and .

9.iEPIA S , the 5ccicar 3.egulatory Commission's Shorcham licensing beard is now conducuing hearings to review the adequacy of the LILCO .e.ergency m plan; and .

WHEP2AS, the LlLCO emergenby plan includes protective actions to be tahea by schools; and .

WHEPIAO, this board has identified the following weaknesses in the LILCC cmcrgency plan:

1. Early Dic=issal Our cl.::rgency early dismiss 01 procedure, which. LILCO's plan incorporates, wouldn't bring school children to an uncontaminated area quickly enough to protece their health and safety. .
2. Transoortation Tnc requisa.te number of buses and drivers required for successful carly dismissal are not available to the schools. This will prolong childrens' stay at schools in contaminated areas. . .

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3. Needc of School Personnel ~

We cannot gueruntee Ehat teaching End non--teaching

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personnel will stay in schools to supervise early

' dismissal. These teachers and staff may need to attend to the safety of their own families and, therefore, may '

f not be availabic t'o, perform emergency-related tasks.

4. Lnch 'of Parentnl'Supervi'sion The success of an early dismissal plan depends not only on prompt dismissal froia schools, but on prompt 'evacua-

' tion of children from their homes. ' In those cases in which parents will not be at home during the day, children

will be sont to On.,upervised homes from which they will

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not be abic to evacuate promptly. ,

5. _P_a.r._enta l In terconsi on.

We cannot z.e con nderit that parents will wait at home for their children to arrivo. Many parents ~may attccpt I

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MIDh i. Ilu.:.a CI.:: ITAL Scis0L 'DISCICT Boarc Resolutlen l

to retrieve their children at schools, perhaps causing increased confusion and chaos. .

6. Relocation If a Snoreham emergency develops quickly and requires an evacuation of children from schools directly to relocation centers, this district does not have suf ficient buses or '

drivers to transport all children to relocation centers in a timely, effective manner.

7. Supervision at Relocation Centers We cannot guarantee that teaching and/or non-teaching school personnel will travel to and remain at relocation '

centers to supervise school children until parents arrive 1

to retrieve them.

8. Sheltering-The LILCO plan suggests that sheltering (remaining indoors) may be the preferred protective action in specific Shorcham

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emergencies. However, none of this district's schools have casements or other structures necessary to provide l

adequate protection. .

- 9. Trust in Public Information In ene LILCO plan, the only public information upon which to base decisions for protective actions will'come.from the utility. LILCO, throngn'its Tublic Schools Coordina-tor and TALK-AM Radio, will both describe -the extent of the emergency and recommend actions. Because LILCO would be both operator of the plant and initiator of' emergency School actions, potential for conflict of interest exists.

administrators, receiving information only from LILCO and ,

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not from any. governmental agency., will be fo ced to decide upon actions with potentially serious consequences without the benefit of a directive from a responsible governmental source. -

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10. Indemnification -

LILc0 does not provide indemnification for from school districts school should damages, injuries, or deaths result

  • administrators' decisions during an emergency, decisions I

which can be made based only upon information and recom-i mendations offered by LILCO.

How, be it therefore , ,

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RESOLVED, that the Middle Island central School .1 District finds that .

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LILCO's emergency plans for schools do not offer children or school personnel of this district adequate protection in be and,

, event of an accident at the Shorcham Nuclear Plant; it furthe- .

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  • MIDDig, ISL&;;D CE?: TRAL SC1100L DISTRICT BOARD FIS LUTION FISOI.VID , that this school bocrd believes that licensing of the Shorehc=

Nuclear Finnt'should not be permitted unic:s or until co=plete-and reasonable resolution of those outstanding, critical c=ergency planning probic=s can be achieved. .

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  • The abo >e Resolution was passed by the liiddle Island Central School District Board of Educction at the Board iteeting on September 29, 1983.

t De4 L ' . 0%2VfY Lori D'Araico District Clerk

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