ML20082C992

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Testimony of G Jeffers & AR Rossi on Contentions 25.C & 25.D Re Role Conflict
ML20082C992
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 11/18/1983
From: Jeffers G, Rossi A
SUFFOLK COUNTY, NY
To:
Shared Package
ML20082C880 List:
References
ISSUANCES-OL-3, NUDOCS 8311220281
Download: ML20082C992 (11)
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UNITED STATES OF AMERICA NUCLEAR REGULATORY 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 DR. GEORGE JEFFERS AND ANTHONY R. ROSSI OF MIDDLE COUNTRY CENTRAL SCHOOL DISTRICT AND SUFFOLK COUNTY'IN SUPPORT OF CONTENTIONS 25.C AND 25'.D Q: Please state your names and positions.

A: I am Dr. George Jeffers, Superintendent of the Middle Country Central School District.

I am Anthony R. Rossi, Director of Transportation for the Middle Country Central School District.

In presenting this testimony, we want to make clear that we are not personally opposed to nuclear powerb! or to the opening of the Shoreham plant, provided adequate safety measures'are provided. As noted below, however, it is our view that adequate measures have not been provided for schools.

1/ We do have concerns relative to the disposal of waste materials.

8311220281 831118 PDR ADOCK 05000322 PDR

We also wish to make clear that we are submitting this testimony on behalf of the Middle Country Central School District to express the concerns of the District Board of Education.

Q: Please describe the Middle Country Central School District.

A: The District has 12,485 children which attend its schools. The District has an additional 1,019 residents' children who are transported on a daily basis by the District to private and parochial schools. Portions of our District are located within the 10 mile EPZ.

Q: What is the purpose of this testimony?

A: This testimony addresses Emergency Planning Contentions 25.C and 25.D, and specifically concerns whether early dismissal could be implemented in a safe and timely manner if there were a radiological emergency at Shoreham. This concern arises by the statement of LILCO in its Offsite Emergency Response Plan to the effect that, in the event of an emergency at the Shoreham Nuclear Power Station during normal school hours which requires evacuation within the 10 mile zone, schools will be advised to institute their early dismissal plans.

Q: Do you believe that a safe and timely early dismissal of schools in your district could be implemented if there were a shoreham emergency?

A: No.

Q: Please explain.

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A: The District's early dismissal plan requires the active i

cooperation of many employees, ranging from bus drivers, teachers, administrators, secretaries, aides and custodial personnel.

Although during past emergencies these personnel have remained in their schools, at their work sites and driving buses, it should be noted that their performance took place under conditions with .

which they had prior experience (such as snow storms, electrical failures, and other severe weather conditions), during which time the security of the roads was insured by the Suffolk County Police Department and other authorities. Under the LILCC Plan our employees will be forced to operate in a highly charged emergency situation probably without the support of these civil authorities.

The District has grave concerns relative to the ability of and the j legality of LILCO assuming this role, since it has a vested interest in the Operation of the plant.

The results of a questionnaire distributed by us to our bus i dri vers , both district and contract (United Bus), indicated that a majority of drivers will suffer' severe role conflict when torn between their duty to the children of the District and their duty to their own and their respective family's safety. Sixty-two responses were received. Among the 62 respondents, only three drivers indicated that they would report to work before first insuring their respective family's safety. Fifteen respondents indicated that after they had secured their respective family's safety, they would then report to work. The District requires 93 drivers under normal conditions. A similar questionnaire has been W

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administered to our employees, the results of which are not available at the time of this writing. It is expected that the a

rest of the employee respondents will manifest the same response i

phenomenon as presented by the drivers, namely role conflict.

Q: Under conditions where all personnel are available, how long does it take for your District to implement.an early I

dismissal?

I A: In the past, operations of the District Emergency Take Home Plan have indicated that a minimum take home time of 2-1/2 hours is required to complete all routes, while under severe storm

! conditions this time has increased to five (5) hours. It should

be noted that these times were reported during periods where personnel experienced minimal role conflict and when civil authorities were providing full support. If there were the role conflict which we expect in a Shoreham accident, early dismissal would take far longer and might be impossible altogether. The District fails to see how LILCO can provide this service.

, Q: Do you have any other concerns regarding early dismissal?

1 l A: Yes. The District has grave concern for 1,019 pupils who regularly attend private and parochial schools up to 30 miles from their homes, since it is these routes which frequently take the longest to complete. The District is concerned as to whether it will be able to reach the 42 pupils whom it buses to Mercy High School, St. Johns Elementary School (both in Riverhead), Yaphank Christian and Center Moriches Christian, and The Step by Step l .

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i School in Rocky Point, since the buses assigned to take these

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  • pupils home will have to enter the immediate area of the plant simply to reach the pupils, let alone return them in safety to l their homes. Moreover, the District has. concern about returning the 116 pupils whom it buses up to 30 miles to the west of the District, as far as Huntingtont District buses may be able to reach these pupils, but then not be able to return them to their i homes in safety, since the buses in returning will be returning i

into the full scale evacuation. Again, if there is role conflict, i early dismissal for these pupils will be difficult or impossible l to achieve.

Q: Is there any other information relavant to this i

situation?

A: Yes. We have attached the resolution passed by the Board of Education on two separate occasions which concerns this matter.

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ATTACIE4ENT 1 4

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i Mrs. Yolcnde Puterio, President of the Middle Country 11/7/83 Secretorici Association to offer a statement re: s .

negotiations.

A representativs of the Andrea Doric Lodge requested-

  • consideration of bcnd pcrticipation in the Columbus Dcy Parade next year.

Arlene Popcleski, Hawkins Pcth PTA to comment upon the

- success of the Hclloween Party at Hawkins Path; to advise the Board of the Theatre Club cetivity; and requested that there be input when the report of the RESS Committee is dis. cussed.

Jennie Ccmcstra, Hc.ikins Path to comment upon the -

underbrush clong Boyle Road and the need for sidewalks there.

Roberta Dengel re: substitute teacher placement' Roy Probeychn re: aged .,out handicapped students, -

offered his services in this regard.

- Superintendent's Report-SUPERINTENDENT'S Mrs. Adler led discussion concerning the resolution REPORT g cdopted Icst year and re-effirmed on August 15,1983 -

S to w:.t:

WHEREAS, the Middle Country Central School District's Board of Education has os its prime concern the welfare SHOREHAM of the children of the School District and POWER PLANr WEEREAS, the Long Island Lighting Company has not been

+ chle to insure that its proposed Shoreham Power Plant can meet acceptchle safety standcrds, and . -

WHEREAS, no acceptchle evacuation plan has been devised 4

by the Long Island Lighting Com any cnd Suffolk County BE IT RESOLVED that the Board of Education in' the interest of protecting the welfare of the children of Middle Country does hereby.go on record as opposed to the opening of the Shoreham Power Plant until both an .

ecceptable.sefety standard can be met and an ecceptchle evacuation plan can be developed.

Mrs. Adler asked the Board to corsider that the above stated resolution might be suff.' .:ient and there would be j no need to go further.

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The following resolution wcs offered by Gcllo, who 11/7/83 moved its adoption, seconded by Durkin to wit:

WEREAS, federcl regulctions for full power operation of the Shorehc= Nuclear Power Plcnt require en emer-gency plan for communities surrounding the plant which will assure those communities adequate protection in r even.t of a nuclecr emergency; cad l

WEREAS, the County of Suffolk hcs determined, cfter substantive study cnd lengthy hearings, that no amer- ~

gancy plcn een be developed to provide citizens

.suffician't protection in c Shoreham emergency; and WEREAS, the County of Suffolk hcs therefore concluded that it cannot, in good fcith, prepare or implement an emergency plcn, or support full power operation of the -

Shoreham Nuclear Power Plant; and YMREAS, the Long Island Lighting Compcny, in an effort to meet federcl regulctions, hcs prepered an emergency plan which only LILCO, im-king coordinction with local or state governments, will ctrempt to implement; and VEREAS, the Nuclear Regulctory Commission's Shoreham

, licensing board is now conducting hearings to review

, the adequacy of the LILCO e=ergency plan; cnd WEREAS, the LILCO emergency plcn includes protective actions to be teken by schools; cnd .

WEREAS, this bocrd of education, hcving reviewed LILCO's emergency plan for schools, cnd having discussed those plans with concerned parents, wishes to advise the' NRC's Shorehcm licensing bocrd of the plcn's workebility for its district; cnd WEREAS, this board has identified the following weck-nesses in the LILCO emergency plan:

1. Early Dismissal Normal actly -dismissal procedures, which LILCO's plan incorporates, cannot bring

, children to uncontaminated creas quickly enough to protect their hecith and scfety.

2. Transportation We cannot guercntee that the requisite number of buses and drivers required for successful t

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/7/83 early dismissal will be available to the schools. Drivers may need to first attend to the safety of their own families and may decline to drive school buses. This will prolong childrens' stay at schools in con-taminated areas. '  ;

3. Needs of School Personnel We cannot guarantee that teaching and non-teaching personnel will stay in schools ,

to supervise early dismissal. These teachers, j

, and staff may need to attend to the safety M l their own families and therefore may not be available l to perform emergency-related tasks.

l 4. Lack of Parental Supervision l The success of an early dismissal plan depends not only on prompt dismissal from schools, but en prompt evacuation of children from their homes. In cases inewhich parents will not be at home during the. day, children will be sent to unsupervised homes from which they will not be able to evacuate promptly. -

5. Parental Intercession We cannot be confident that parents will wait l st.home for their children to arrive. Many parents I mail attempt to retrieve their children at schools, perhaps causing increased confusion and chaos.
6. Panic An announcement of a nuclear emergency at Shoreham may cause disorientation and panic in children, teachers, non-teaching staff, and parents. This will further prohibit effective, safe d4saissal from schools.
7. Relocation ,
If a Shoreham emergen=y develops quickly and 1

- . requires an evacuation of children.from schools directly to' relocation centers, this district will not have sufficient buses or drivers to transport ',

all children to relocation centers in a timely,  ;

efficient manner. I

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8. Supervision at Relocation Centers . -

We cannot guarantee ther teaching and/or non-teaching ochool personnel will travel to'and remain at relocation centers to supervise children

'145 until pc. rents arrive to retrieve them.

11/7/83

9. Sheltering The LILCQ plen suggests that shel'tering (remaining indoors) mcy be _the-preferred protective action in specific Shorehc= emergencies. However, mcny of this district's schools do not have bcsements or other structures necessary to provide adequate

' protection.

10. Trust in Public Informerion .

In the LILCO plca, the only public information upon which to bcsa decisions for protective ac'tions will come from the utility. LILCO, thrcugh its Public Schools Coordinator and WALK-AM Radio, will both describe the extent of the emergency end recommend actions. Because T.Ti m would be both operator oilthe plant and initator of emergency actions, potentici for conflict of interest exists.

School Ad=inistrators, receiving information only from LILCO cnd not from any governmental agency, will be forced to decide upon actions with potentially serious consequences without the benefit of infornction

. from en objective source.

11. Indemnificction LILCO does not provide indemnification for school districts should dcmages, injuries, or decths result from school administrators' decisions during an emergency, decisions which can be based only upon informction and recommendations offered by LILCO.

Now, bolit-therefore RESOLVED, that this school district finds that LILCO's emergency plans fur schools do not offer children school personnel, or

. perents of this district adequate protection in event of an accident at the Shoreham Nuclear Power Plant; cnd be it further RESOLVED, that this school board cannot direct its schools to initiate or participate in emergency cetions which not only' fail to protect childrens' scfety, but place it in further jeopardy;'cnd, be it further RESOLVED, that this school board believes that full power licensing of the Shoreham Nuclear Power Plcnt should be forbidden unless or until complete and reasonable resolution of these outstanding, critical emergency planning problema can be achieved. ,

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The question.of the adoption of the above stated 1/7/83 resolution was duly put to vote on Roll Call which resulted as follows: .

Amruso voting no does not want plant opened Gallo voting yes Durkin voting yes ,

Brodsky voting yes Boder voting yes Reynolds voting no duplicate resolution Purick voting yes ,

I Adler voting no duplicate resolution ,

i The resolution was thereupon declared duly adopted. .

k Motion by Gallo seconded by-Brodsky to authorize the

\ Superintendent of Schools and the Director of Trans- '

'ARTICIPATION portation to participate in meetings prior to the g wg NRC Hearings relative to the Shoreham Nuclear Power Plant; to appear at the NRC Hearings to state the concerns of the district; that the statements of the Superintendent of Schools anc the Director cf Trans-portation be reviewed by Counsel prior to appearance .

and, at the time of the hearings that Counsel be present to advise them.

The question of the adoption of the above stated motion was duly put to vote on Roll Call which resulted as follows:

Amruso voting yes Gallo voting yes DurBin voting yes Brodsky voting yes Boder voting yes Reynolds voting yes Purick voting yes Adler voting no would not like the Superiatendent

to take'the time from the district in this matter.*

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The motion was carried.

Motion by Gallo seconded by Brodsky to accept the, i

SOUNSEL recommendation of the Superintendent.and designate the }

ARMON firm of Rains,'Pogrebin, represented by Terence O'Neil '

IS as. gounsel in the ,le'gal matter Carmon vs Middle Country .

Central School District at a fee not,to exceed $100 FIDDLE COUNTRY per hour. -

i The question of the adoption of the above stated motion

! was duly put tp vote on Roll Call which resulted as fallows:

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