ML20082C984

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Testimony of RW Petrilak on Contentions 25.C & 25.D Re Role Conflict
ML20082C984
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 11/18/1983
From: Petrilak R
SUFFOLK COUNTY, NY
To:
Shared Package
ML20082C880 List:
References
ISSUANCES-OL-3, NUDOCS 8311220279
Download: ML20082C984 (10)


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i UNITED STATES OF AMERICA NUCLEAR REGULATCRY COMMISSION Before the Atomic Safety and Licensing Board

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In the Matter of )  ;

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LONG ISLAFD LIGHTING COMPANY

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) Docket No. 50-322 0.L.

(Shoreham Nuclear Power Station, ) (Emergency Planning) l Unit 1) )

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j DIRECT TESTIMONY OF ROBERT W. PETRILAK ON y BEHALF OF THE MT. SINAI BOARD OF EDUCATION AND SUFFOLK COUNTY REGARDING CONTENTIONS 25.C AND 25.D -- ROLE CONFLICT Q. Please state your name and position.

! A. My name is Robert W. Petrilak. I am Vice President of the Mt. Sinal Board of Education.

O. Where is the Mt. Sinai Union Free School District lo-cated?

A. The Mt. Sinai Union Free School District comprises an area of approximately 7 square miles and is located on the not h shore of Long Island in the County of Suffolk in the Township of Brookhaven. It is situate? approximately 60 miles east of New York City and 7 miles west of the Shoreham Nuclear Power Station. The entire district is within the 10 mile Emergency Planning Zone ("EPZ") of the Shoreham Plant.

8311220279 831118 PDR ADOCK 05000322 T PDR

l Q. Please describe the schools and student population of I the Mt. Sinai School District.

A. Mt. Sinai is a kindergarten to grade nine school dis-trict which educates its students in two facilities located on a central campus. The grade 10-12 students who live in the Mt.

, Sinai District are educated in the neighboring district of Port Je f ferson, which also lies within the 10 mile EPZ. With a total student population of 2,186 students, the Mt. Sinai dis-trict houses 839 students in our K-4 f acility, 911 students in our 5-9 facility and transports 436 of our 10-12 students to the Port Jefferson High School. The district provides trar s-portation for all students within the district for safety purposes. We also provide transportation for district students attending private or parochial schools.

Q. What is the purpose of this testimony?

A. The district has reviewed the off-site Radiological l

i Emergency Response Plan proposed by the' Long Island Lighting Company ("LILCO") as it pertains to the actions to be taken by school districts within the 10 mile EPZ in the event of an emergency at Shoreham. The district believes that the plan submitted by LILCO is deficient and will not insure the health

, or safety of the district's students. The purpose of this l

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testimeny is to comment on those aspects of the LILCO Plan which the district believes are deficient because the phenome-non known as role conflict maxes them incapabic of imple-mentation.1/ Specifically, th'? testimony is to state the dis-trict's agreement with Emergency Planning Contentions 25.C and 25.D.

O. Please state the basis for your agreement with Conten-tion 25.C.

A. Implementation of the Mt. Sinal School District's early dismissal plan relies entirely on the availability of all the buses for which the district contracts with BIMCO Inc. The district does not own any of its own buses nor does it employ its own drivers. Thus, the ability of the district to accomplish an early dismissal would be completely out of the district's control. Studies conducted by Suffolk County chow that up to 70 percent of the school bus drivers relied upon to drive the children from our district would attend to the safety of their family or themselves before, or instead of, reporting to duty. In addition; the management and dispatch personnel at 1/ The district reserves its right to provide additional comments in the context of the other contentions on other areas of the plan which it believes are deficient and unworkable.

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BIMCO Inc. would also have to remain on the job if our early dismissal plan were to be implemented. Thus, if those people also experience role conflict, an early dismissal could not take place.

In summary, if buses or bus drivers were not available in the event of an emergency at Shoreham, the early dismissal pro-posed by LILCO could not be accomplished in the Mt. Sinai School District.

Q. Please state the basis for your agreement with Conten-tion 25.D.

A. In addition to buses and bus drivers, in order to im-pl ement an early dismiosal, it is necessary for the majority of the teachers and administrative personnel o remain in the schools until all the students have been placed on buses and have left the grounds. These personnel are necessary to super-vise the students and deal with parents and handle the other logistical problems involved in implementing an early dismiss-al. Moreover, the district believes that to implement an early dismissal in the event of an emergency at Shoreham would require even more personnel than required norr, tally. Since many members of our teaching and administrative staff live within the 10 mile EPZ, they will experience role conflict and will 1

! l resolve the conflict by first attending to the needs of their l families.

If the necessary numbers of teaching and administrative personnel are not available, it would be impossible to imple-ment an early dismissal. - The district would also not be able to implement a sheltering plan if teachers and administrative personnel were not available to supervise and care for chil--

dren.

Q. Would you permit LILCO personnel to attempt to imple-ment an early dismissal plan if district personnel and bus i

drivers were not available?

A. The Mt. Sinai School District, its Superintendent and Board of Education has the responsibility for the health and safety of the students while at school. The district does not have the right nor will it turn this responsibility over to LILCO, a private corporation. The district has not made any i

arrangements or signed any agreements with LILCO. The district would not permit LILCO personnel to take responsibility for students' safety.

Q. Please summarize your testimony.

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l 4 I A. The Mt. Sinai School District does not believe an early dismissal could be effectively implemented in the case of

, an accident at the Shoreham Nuclear Power Station. In addition, the district has not determined that such a plan is the proper response -- that is, one that would adequately protect the children in our charge -- to such an accident. At-J tached hereto are two resolutions passed by the Mt. Sinai Board of Education which further set forth the District's position

( Attachments 1 and 2 hereto) .

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ATTACHMENT 1

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MP. SINAI UNION FREE SGOOL DIS'IRICT Board Resolution of October 18, 1983 Be it resolved i: hat an early dismissal or "go hane plan" is net an appropriate response to an order to evacuate in the event of a malfunction at the Shoreham Nuclear Power Station until the following issues are resolved.

i 1. He State and County governments approve an implementable evacuation plan.

2. We District can be assured that Bus Drivers, Emergency and Supervisory personnel of adequate force will be available to the District to implenent the plan.
3. nat such plan receives the review of the residents of the
District.

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'IEEREEORE Until such time, it is the position of the Board of Education that no plan shall be subnitted to any agency as such subnittal could be viewed as an agreenent by the District that such a plan is feasible.

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Ja Tt.CHIiENT 2

SHOPHIAM RESOLUTION Whereas the Mount Sinal School District lies within the emergency Planning Zone of the Shoreham Nuclear Power Station and Whereas the Board of Eudcation is responsible for the health and safety of the students and staff of the district while on district property and Whereas an operating license can not be granted by the Nuclear Regula-tory Comission for said plant without an approved implementable evacuation plan and Whereas the goverreent of Suffolk County adopted a resolution on February 17, 1983 stating that due to our unique island geo-graphy and lbnited road capacity it would be impossible to devise and implement an avacuation plan that would protect the public health and safety of the public and Whereas on that day the Governor of the State of New York announced his support of county government and stated then and subse-quently that he would not impose an avacuation plan on the county therefore be it resolved that the Board of Education of the Mount Sinai Union Free School District supports the decisions and position of the government of Suffolk County and the State of New York and be it further resolved that the Board believes that no operating license, either low or full power, should be granted to LILCO for the Shoreham Power Station until an implementable evacuation plan that protects the public health and safety is developed and arproved by County and State GJvernment.

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