ML20083J152
| ML20083J152 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/11/1984 |
| From: | Mccleskey E HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL-3, NUDOCS 8401160212 | |
| Download: ML20083J152 (25) | |
Text
'
LILCO, Jcnuary 11, 1984 e
-000KETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '
T4 JAN 13 Al0:i3 Before the Atomic Safety and Licensing B6ErdOf3ECid~ '
_ 'NG & EEP BRM;CH In.the Matter of )
)
LONG-ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning
.(Shoreham Nuclear Power Station, ) Proceeding)
Unit 1)' )
LILCO'S REQUEST FOR LEAVE TO FILE OUT OF TIME A MOTION TO STRIKE LEON J. CAMPO'S TESTIMONY ON CONTENTIONS 25.C AND 25.D The Long Island Lighting Company (LILCO) requests leave to file'out of-time a motion to strike in its entirety Leon J.
Campo's written testimony filed by Suffolk County on the issue of role conflict and its effect on early dismissals from
- schools. This testimony is entitled " Direct Testimony of Leon J. Campo on Behalf of Suffolk County Concerning Emergency Plan-ning Contentions 25.C and 25.D." The basis for this request is information obtained during the deposition of Leon J. Campo on January 5, 1984.
( -l The Campo testimony was filed on November 18, 1983, and i
motions.to strike that testimony were due on November 28, 1983.
l On that date, LILCO filed a motion for further discovery on Mr.
Campo's_ testimony (among others). The Board granted LILCO's p- - motion for. additional discovery on December 1, 1983, and Mr.
L Campo's deposition was'taken on January 5, 1984. During his l
l l:
l' B401160212 040111 -
'Qd l.
. deposition, LILCO obtained information not stated in Mr.
Campo's testimony that, in LILCO's view, supports a motion to strike Mr. Campo's testimony as irrelevant and cumulative.
LILCO therefore seeks leave to file out of time a motion to strike in its entirety Mr.' Campo's testimony.
LILCO_is mindful that unauthorized pleadings should not be attached to requests to file those pleadings. See, e.g., Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), LBP-81-18, 14 NRC 71, 72 (1981); Public Service Co. of Oklahoma (Black Fox Station, Units 1 and 2), LBP-76-38, 4 NRC 435, 441 (1976). Under the circumstances here, however, where Board-ordered discovery has brought-information to light that supports a motion to strike testimony, we have attached the mo-
-tion.
Respectfully submitted, f g Jap ~e's ' y( 'ChristMan Kdthy E. B. McCleskey Hunton & Williams 707 East Main Street Post Office Box 1535 Richmond, Virginia 23219 DATE: January 11, 1984
LILCO,'Jsnuary 11, 1984
~ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
~
Before the Atomic Safety and Licensing Board In,the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning (Shoreham Nuclear Power ) Proceeding)
Station, Unit 1) )
LILCO'S MOTION TO STRIKE THE TESTIMONY OF LEON J. CAMPO ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 25.C AND 25.D The Long Island Lighting Company (LILCO) moves the Board to strike in its entirety the written testimony of Leon Campo ,
filed by Suffolk County on role conflict and its effect on early dismissals from schools. This testimony is entitled "Di-rect Testimony of Leon J. Campo on Behalf of Suffolk County Concerning Emergency Planning Contentions 25.C and 25.D" (Campo
~
testimony). ,
The bases for striking this testimony are that (1) it is irrelevant to the issues in this proceeding, and (2) to the ex-l tent it is not irrelevant, it is cumulative and therefore un-L i
necessary.
Under the NRC's Rules of Practice, testimony must be rele-vant to the issues in contention. 10 CFR S 2.743(c).1/
l c -
l 1/ . Title 10 CFR $ 2.743(c) provides: e
! (footnote continued) 1 i
I ._ __ ,_ __ _
Irrelevant or cumulative testimony is the proper subject of a -
motion to strike. See 10 CFR Part 2 Appendix A, V(d)(7). The Board has the power to implement these provisions, both through its general power to regulate the conduct of a hearing, 10 CFR 5 2.718, and through the specific authority under 10 CFR $
2.757(b) to strike argumentative, repetitious, cumulative, im-material, unreliable or irrelevant evidence.
The definition of " relevant evidence" from Rule 401 of the Federal Rules of Evidence is as follows:
Rule 401. Definition of " Relevant Evidence"
" Relevant evidence" means evidence having any tendency to make the existence of any fact that is of consequence to the determi-nation of the action more probable or less probable than it would be without the evi-dence.
It is the "of consequence-to the determination of the action" part of the definition that is missing in the Campo testimony.
The issues considered in Contentions 25.C and 25.D are whether role conflict would be experienced by school personnel during a radiological emergency-at Shoreham, whether any such conflict would be resolved in favor of abandoning roles at school and (footnote continued)
Only relevant, material, and reliable evi-dence which is not unduly repetitious will be admitted. Immaterial or irrelevant parts of an admissible document will be segregated and excluded so far as is prac-ticable.
l I - - . . - . ,.
- going home to be with family during a radiological emergency, and whether that role abandonment, if it exists, would make it impossible to implement protective actions in schools within the 10-mile EPZ.2/
2/ Contention 25.C reads as follows:
.The LILCO plan fails to take into account the role. conflict.that will be experienced by school bus drivers. In fact, a substantial number of school bus drivers are likely to attend to the safety of their own families before they report
-(if they report at all) to perform the bus driv-ing duties which LILCO assumes will be per-formed. ! Role conflict-of school bus drivers will meen that neither school buses nor school bus drivers will be available to implement the LILCO plan. Without an adequate number of buses or bus drivers, LILCO will be incapable of im-plementing the following protective actions:
- 1. early dismissal of schools (necessary under the LILCO Plan to permit school-children to be sheltered or to evacu-ate with their. parents);
- 2. evacuation of schools;
- 3. evacuation of persons without access j
to cars; and 1
- 4. evacuation of persons in special fa-cilities.
Contention 25.D reads as follows:
i The LILCO plan fails to take into account the role conflict that is likely to be experienced by teachers, other school employees, and cross-ing guards. In fact, a substantial number of such personnel are likely to attend to the safe-ty of their own families rather than remaining at the schools or at their posts in the event of <
(footnote continued)
. It is fair to say that the Campo testimony sheds no light whatsoever on the question of whether role conflict will be ex-perienced by school personnel within the 10-mile emergency planning zone, or whether that conflict is likely to be re-solved-by school personnel abandoning their work. And the Campo testimony does not provide information regarding the early dismissal process within any school district in the 10-mile EPZ. To the extent that the Campo testimony echoes state-ments of other County witnesses regarding the complexity of early dismissal processes generally, or that role conflict may be experienced by school personnel generally, it is cumulative to the testimony filed by other County witnesses in this pro-ceeding and therefore should be excluded. Each of these points is addressed in turn below.
(footnote continued) an emergency. Accordingly, there is no assur-ance that under the LILCO Plan, adequate person-nel will be available to supervise children, including those required to walk home, during the early dismissal process, during school evac-
. uations, or in the event that children are shel-tered in the schools. As a result, the follow-ing protective actions could not and would not be implemented:
- 1. early dismissal of schools;
- 2. sheltering of schoolchildren in schools; and
- 3. evacuation of schools.
4 r- --
e , , , . , , - , - - - .- - - , . . - , - -
I. THE CAMPO TESTIMONY DOES NOT ADDRESS WHETHER ROLE CONFLICT WILL BE EXPERIENCED BY SCHOOL PERSONNEL WITHIN THE lO-MILE EPZ The Campo testimony sheds no light on whether role con-flict will exist for school personnel within the 10-mile EPZ during a radiological emergency. The stated purpose of the testimony is "particularly to explain the logistical diffi-culties involved in implementing an early dismissal of schools." The only mention of role conflict comes at page 1 of the testimony, where Mr. Campo states that "[i]f there is role conflict such that necessary personnel are not available, no early dismissal will be possible." That notion is repeated in the last sentence of the testimony: "[i]f there is role con-flict such has been suggested by other [ County) witnesses such that bus drivers and/or teachers and/or administrators are not available, early dismissals will not be implemented." It is clear from the Campo testimony that, as.to the issues of wheth-er role conflict will exist for school personnel, and whether they would resolve any conflict by abandoning their work, Mr.
Campo is relying upon other witnesses' testimony in the pro-ceeding to address the issues in Contentions 25.C and 25.D.
Consequently, the relevance of the Campo testimony cannot be established based upon any discussion of role conflict contained in it.
aA-g- a h. ,- 5 up. 4 __44-m ..3 J-a+s * "L + Jr e.-46. et s
} ,' -
II. THE CAMPO TESTIMONY DOES NOT DESCRIBE EARLY DISMISSAL PLANS FOR ANY SCHOOL DISTRICT WITHIN THE lO-MILE EPZ k ,
'The Campo testimony.contains the following question and .
I answer on page 2:
Q: lWhat familiarity with early. dismissal of=
' schools do you have?
A: In Nassau and Suffolk. Counties, ~ the region is broken down into numerous separate
. school districts. Each district has its own schools (or in some cases. arranges for children in its district to attend schools
.in the neighboring district) and arranges for transportation and dismisscl of chil. -
, 'dren. I am particularly familiar with the early dismissal procedures in the East Meadow Schools, and also those for Mt.
" Sinai, which is where I live. Further, from my years as a school administrator, I am quite familiar with the-logistical fac-
. tors'which must be considered in any early dismissal.
4 e
. (Emphasis added.) Thus Mr. Campo. represents in his testimony f 12utt he is "particularly ~ familiar. with the early dismissal pro-L cedures" for Mt. Sinai, which is a school district within the lO-mile EPZ. During his deposition, however, Mr. Campo indi-cated that he.is not-familiar with any details regarding early
'~ -
. dismissal plans for Mt. Sinai, and knows only that plans exist
. . and have been used in the past:
Q. Do the Mt. Sinai Schools have emergency
- dismissal, early dismissal, or "go home" plans of any kind?
A. Well, what I would have to say about Mt.
Sinai.would be from the perspective of beiing a parent'living in the district and i
e i , -- , -. . . . . , ,,-,.m,-nw-.,,,..,. ,,-e.--e.,.,,,.,,, ,+ ,m-.g,,<g.m,,w,.e -,
, not an administrator who is in charge of any operation there. And that, you would have to seek out those. people who are re-sponsible.
Campo Dep. 18 (attached)'. Mr. Campo indicated that he had no knowledge of the details of the Mt. Sinai plans:
Q. Are you familiar with those plans?
A. I am familiar with those plans. I am not familiar with every nuance of the plan, no, I'm not.
Q. Does each school in the Mt. Sinai district have its own plan?
A. My understanding is yes. I have youngsters in both those schools. Yes.
Q. And do you know how those plans are devel-oped?
A. How they are developed, no.
Q. Do you know what!the provisions of the plans are?
A. No.
Q. So you don't know what happens within the Mt. Sinai school. district if it starts snowing one afternoon and early dismissal is being contemplated?
A. Well, when you say I don't know what hap-pens, the objective -- I know what the ob-jective is of the plan, is to get the youngster to the homes of their parents.
Q. Do you know how that is done, any specifics of how that is done in Mt. Sinai?
4 4
A. When you say specifics, no.-- I would say yes and no. The specific of the use of transportation facility is the specific in-strument. As to the specific direction given and the particulars of the plan, I'm
'not' familiar with.
Campo Dep.-19-20 (attached). And Mr. Campo was unable to de-scribe how early dismissal is accomplished in Mt. Sinai, or what difficulties have been encountered in implementing early dismissals:in-Mt. Sinai:
l' Q. Do'you know anything about whether there
.was any difficulty in implementing the early dismissal plan at that time (in the 1st two years)?
A. I am not aware of the particulars of that.
Q. .Is it your understanding that the early
, dismissal plans for Mt. Sinai involve staff personnel riding on buses with school chil-dren?
( A. With respect to the specific plan, I really j couldn't say as to who is ensigned what, f
So my understanding of the plan is not on I who directs whom, but generally it is the use of'the transportation system to return the youngsters to their homes.
i Q. On page 3 of your' testimony, you state that l- teachers and administrators telephone home l .to ascertain if a parent or guardian is L available to receive a child at the elemen-L tary level. Is it your understanding that that is what is done in the Mt. Sinai school district?
( A. As far as the calling home, that I couldn't l . comment on as far as Mt. Sinai, as to whether or not calls go home to the parents -
l l
r
. _ _ _ _ . _ . _ _ . . - . _ . _ _ . _ . _ . , _ - _ __.__,m . _ . _ _ _ _ . _ . . . . _ , ._ . . . . . - - - . . _ _ _ . _ _ . _ _ , . , . _ . . . _ _ _ _ _ .
of Mt. Sinai. That is what is done in East Meadow.
Q. So is it fair to say that your description of early-dismissal programs in your testi-mony refers to East Meadow and not Mt.
Sinai?
A. .I kind of made it clear that what my knowl-edge of the Mt. Sinai early dismissal is basically I know they have one; and two, I have been the parent on the receiving end of the program. So I don't have any spe-cific play.by play knowledge of who directs whom in order to make it happen.
In East Meadow I am a front-line adminis-trator, so to speak, and I am speaking from .
the position of a person who would be in-volved in making that happen. So those are two different perspectives.
Campo Dep. 21-23 (attached). In addition, Mr. Campo indicated that he was unf6miliar with any early dismissal plans other than the one for the district in which he works, East Meadow:
Q. Mr. Campo, have you reviewed early dismiss-al plans for any schools?
A. Other than my own?
Q. Yes.
A. No.
Campo Dep. 67 (attached).
As Mr. Campo indicated in the portions of his deposition set out above, he is familiar with the East Meadow School Dis-trict's early dismissal plans, and it is the East Meadow plans that are described in his testimony. The East Meadow School
. District is outside of the 10-mile EPZ for Shoreham. Campo
'_Dep. 17 (attached). ,
Mr. Campo has been put foraard by Suffolk County as a fac-
~
tual witness to describe how an early dismissal is accom-plished. His-testimony indicates that he is "particularly fa-miliar" with early dismissal plans for the Mt. Sinai school district, which is within the 10-mile EPZ. His deposition in-dicates, however, that he is unfamiliar with the early dismiss-al plans of any school districts within the 10-mile EPZ, including the Mt. Sinai plans. And his testimony does not in-dicate how the details of the early dismissal plans for East Meadow, described in his testimony, are related to the early dismissal plans for any school district within the 10-mile EPZ, or to Contentions 25.C and 25.D. The early dismissal activi-ties of schools outside the 10-mile EPZ have no bearing on whether the emergency plan for Shoreham can and will be imple-mented. Therefore, Mr. Campo's testimony is irrelevant and
-should be excluded.
III. TO THE EXTENT THE CAMPO TESTIMONY REPRESENTS EARLY DISMISSAL PLANS GENERALLY, IT IS CUMULATIVE Mr. Campo states in his testimony that "from my years as a school administrator, I am quite familiar with the logistical factors which muct be considered in any early dismissal."
Campo Test. 2. He then discusses the process for early
dismissal based, as he stated in his deposition, upon the de-tails of the East Meadow early dismissal plans. To the extent that Mr. Campo's testimony on early dismissals might be viewed as; relevant testimony discuscing early dismissals generally, the testimony is cumulative and should be excluded under 10 CFR S 2.743(c) and Rule 403 of the Federal Rules of Evidence.3/
Suffolk County filed testimony in this proceeding from Mescrs. Jeffers, Muto, Smith, Petrilak and Rossi, all school administrators in school districts within the 10-mile EPZ, providing details of early dismissal plans for their schools and discussing early dismissal generally. Mr. Campo's testimo-ny adds no new facts to the testimony of these other school ad-ministrators. In addition, the testimony of these other school administrators is more probative of the issues raised in Con-tentions 25.C and 25.D, because the facts stated in those pieces of testimony describe dismissal plans used at schools within the lO-mile EPZ, while Mr. Campo's testimony does not.
Therefore, to the extent that the Campo testimony is relevant, it is unduly repetitious and should be excluded.
3/ Rule 403 of the Federal Rules of Evidence pro-
, vides as follows:
Rule 403. Exclusion of Relevant Evidence on Grounds o_f Prejudice, Confusion, or Waste of Time Although relevant, evidence may be excluded if l its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by con-siderations of undue delay, waste of time, or -
needless presentation of cumulative evidence.
- - ~ , , r ,-e- - . , , , , - ., m . , - - -, , . , , - -, . -
. IV. CONCLUSION For the reasons stated above, LILCO requests that the Board strike in its entirety the Campo testimony filed by Suffolk County on Contentions 25.C and 25.D.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY
/JLERM Ja,~mes y. Chrisyfan Kathy E. B. McCleskey ,
Hunton & Williams 707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 DATE: January 11, 1984 l
l l
l l
l
LILCO,~ January 11, 1984 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY
.(Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 (Emergency Planning Proceeding)
I certify ~;that copies of.LILCO'S MOTION TO STRIKE THE TES-TIMONY OF LEON J. CAMPO ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 25.C-AND 25.D, and LILCO'S RE-
~
QUEST FOR LEAVE TO FILE OUT OF TIME A MOTION TO STRIKE LEON J.
CAMPO'S TESTIMONY ON CONTENTIONS 25.C AND 25.D were served this
. date upon the,following by first-class mail, postage prepaid, 4
or-(as indicated by one asterisk) by-hand, or (as. indicated by two asterisks)'by Federal Express.
[ : James A. Laurenson,* Secretary of the Commission
' Chairman U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555
.U.S. Nuclear. Regulatory
. Commission Atomic Safety and Licensing East-West Tower, Rm. 402A ' Appeal Board Panel 4350 East-West Hwy. U.S. Nuclear Regulatory Bethesda,- MD 20814 , Commission Washington, D.C. 20555 Dr. Jerry R. Kline*
! Atomic Safety cnd; Licensing Atomic Safety and Licensing Board Board Panel U.S.. Nuclear Regulatory. '
U.S. Nuclear Regulatory Commission ; Commission
- East-West Tower, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.
Bethesda, MD 20814 '
Bernard M. Bordenick, Esq.*
L David A. Repka, Esq.
Mr. Frederick J. Shon* Edwin J. Reis, Esq.
Atomic Safety and Licensing U. S. Nuclear Regulatory Board- -Commissicn
.U.S. Nuclear Regulatory 7735 Old Georgetown Road Commission (to mailroom)
' East-West-Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Hwy.
3 Bethesda, MD 20814 Ben Wiles, Esq.
4 Asst. Counsel to the Governor Gerald-C. Crotty, Esq. Executive Chamber <
Counsel to the Governor State Capitol Executive ~ Chamber Albany, New York 12224
. - State' Capitol Albany, New York 12224
l Eleanor L. Frucci, Esq.* Stewart M. Glass, Esq.** )
Attorney Regional Counsel '
Atomic Safety and-Licensing Federal Emergency Management Board Panel Agency U. S. Nuclear Regulatory 26 Federal Plaza, Room 1349 Commission New York, New York 10278 East-West Tower, North Tower 4350 East-West Highway Stephen B. Latham, Esq.** 1 Bethesda, MD 20814 Twomey, Latham & Shea 1 33 West Second Street David ~J. Gilmartin, Esq. P.O. Box 398 Attn: Patricia A. Dempsey, Esq. Riverhead, New York 11901 County Attorney Suffolk County Department Ralph Shapiro, Esq.**
of Law Cammer & Shapiro, P.C.
Veterans Memorial Highway 9 East 40th Street Hauppauge, New York 11787 New York, New York 10016 Herbert H. Brown, Esq.* James Dougherty, Esq.*
Lawrence Coe Lanpher, Esq. 3045 Porter Street Christopher McMurray, Esq. Washington, D.C. 20008 Kirkpatrick, Lockhart, Hill Christopher & Phillips Howard L. Blau 8th Floor 217 Newbridge Road 1900 M Street, N.W. Hicksville, New York 11801 Washington, D.C. 20036 Jonathan D. Feinberg, Esq.
Mr. Marc W. Goldsmith New York State Energy Research Group Department of Public Service 4001 Totten Pond Road Three Empire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 MHB Technical Associates Spence.W. Perry, Esq.**
1723 Hamilton Avenue Associate General Counsel Suite K Federal Emergency Management San Jose, California 95125 Agency 500 C Street, S.W.
Mr. Jay Dunkleberger Room 840 New York State Energy Office Washington, D.C. 20472 Agency Building 2 Empire State Plaza Ms. Nora Bredes Albany, New York 12223 Executive Coordinator Shoreham Opponents' Coalition 195 East Main Street Smithtown, New York 11787
) . Jh/M Ka1hy E 3. McC15Ake 7
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: January 11, 1984
(
1 UNITED STATES OF AMERICA
( 2' NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOFIC SAFETY AND LICEFSING EC APE 4 --- -------------x 5 In the Matter ofs s 6 LONG ISLAND LIGHTING COMPANY a Docket No. 50 -3 2 2-0 L -3 7 (Shoreham Nuclear Tower Station : (Emergency Planning )
8 Unit .1 ) :
9 --- -------------x 10 DEPOSITION ON SUFFOLK COUNTY 11 CONTENTIOFS 25.C and 25.D
. 12 Hauppauge, N.Y.
. 13 Thursday, January 5, 198u 14 Deposition of LEON J. CAMPO, called for examination 15 by counsel for Lono Island Lighting Company, having been 16 duly sworn by Raymond H. Heer, a Notary Public for the l
17 District of Cclumbia, in the Ninth Floor Conf erence l
I
- 18 Boom, Eennisson Building, Veterans Merorial High wa y ,
i 19 H au pp a uc e, N.Y., beginning at 5s10 p.m., and the f 20 procee dings being taken down by Stenomask by Raymond H.
l 21 Heer and transcribed under his direction.
I r
k s
ALDERSON REPORTING COMPANY,INC.
440 FIRST ST., N.W., WASHINGTON, D.C. 20001 (202) 628 9300 [
.. _ . , . - . . , , _ , . . . , _ . _ . _ . , .L_. , . . , , - - . _ _ . _ . . . , _ _ _ . - . _ _ , _ . . -
N llP 17
\
1 2 As a teacher?
l$ 2 A No. As a teacher, not that I recall.
3 0 And other than the school administrator jobs 4
that you' have held with East Headow, have you been an 5
administrator in any other schools or school districts?
6 A Specifically schools,no.
7 0 Do you hold any other positions in any school 4
districts, paid or unpaid?
9 A Bo.
10 Q Are you a member of a board of education or 11 anything like that?
12 g A No.
13 Q And the East Headow schools are outside the 14 emergency' planning zone for Shorehaa, is that right?
15 A Yes, tha t's true.
16 2 But you live within the Rt. Sinal school ~
17 distri ct, which is within the emergency planning zone?
18 A Yes.
19 Q Are you testifying on your own behalf or on 20 behalf of a school district?
21 A On my own behalf, based upon my experience and
}
22 my pro f essional duties. But I am not representing East 1
(
V
18 1 Meadow Schools. I am representing myself.
( 2 O And you're not representing the Mt. Sinal 3 School District, either?
4 A No. No, I'm not.
5 0 Do the M t. Sinal Schcols have emergency 6 dismissal, early dismissal, or "go home" plans of any 7 kind?
8 A Well, what I would have to say about M t. Sinai 9 would be from the perspective of being a parent living 10 in the district and not an administrator who is in 11 charga of any opera' tion there. And that, you would have 12 to seek out those people who are responsible.
13 In the case of East Meadow, what I would be 14 sayin g would be based upon --
15 MS. LETSCHEs Wait a minute. Let me stop you 16 for a second. Just try to answer the question. Do you 17 know whether or not Mt. Sinai schools have an early 18 d'is mis sal plan , I think was the question.
19 ' THE WITNESS: Yes.
I 20 BY MS. McCLESKEYs (Resuming) 21 0 Yes, you know, or yes, they do?
22 A Yes, they do.
ALDERSoN REPORTING COMPANY,INC.
t.40 FIRST ST., N.W., WASHINGTON, D.C. 20001 (202 628 9300
?
19
(
1 Q Are you familiar with those plans?
( 2 A
~
I am fami11ar with those plans. I am not 3 f amiliar with every nuance of the plan, no, I'm not.
4 0 Does each school in the Mt. Sinal district 5 have its own plan?
6 A When you say "each school", Et. Sinai is an 7 unusual school district in that some of the youngsters 8 go to -- grades 10 thrcugh 12 particularly do not attend 9 a sdbo ol within the district. They go to an adjacent 10 dis tri c t. So the Mt. Sinal situation is maybe a little 11 bit different than some other school district in that
{ 12 13 regard.
Well, for the Et. Sinai schools that are Q
14 sit tin g within the Mt. Sinal boundary, th e school 15 bo u nd a ry , do they each have early dismissal plans?
l 16 A My understanding is yes. I have youngsters in 17 both those schools. Yes.
18 Q And do you know how those plans are 19 devel3 ped?
20 A How they are developed, nc.
21 Q Do you know what the provisions of the plans l
22 are?
l lk i
ALDERSON REPORTING COMPANY,INC.
aan msutta:7 N W WASHINitTnN nit :mnrit t:mt Mft-9300
20 1 A No.
{ 2 0 So you don 't know what happens within the Mt.
Sinal school district if it starts snowing one af ternoon 3
4 .and ea rly dismissal is being centemplated?
5 A Well, when you say I don't know what happens, 6 the ob jective -- I know what the objective is of the 7 plan, is to get the youngster to the homes of their 8 p ar en t s .
9 0 Do you know how that is done, any specifics of 10 how th at is done in Mt. Sinai?
11 A When you say specifics, no -- I would say ye s.
12 and no. The specific of the use of transportation
( 13 f acility is the specific instrument.- As to the specific 14 direction given and the particulars of the plan, I'm not 15 f amiliar with. ,
i 16 Q Do you pnow if the early dismissal plans in -
17 the Mt. Sinal school district have been used in the last 18 y ear? ,
19 A In the last year? I believe they have nCt 20 been used in the last year, just from recollection, 21 anyway .
22 0 How about in the last couple of years?
L
(_
ALDERSoN REPORTING COMPANY,INC.
440 FIRST ST, N.W., WASHINGTON, D.C. 20001 (202) 628-9300
n 21 r
-(.
1 A I can recall the Mt. Sinai plan being used I
( 2 believ e once since I have been living there. .I believe 3 it hap pened once.
4 Q Do you remember when?
5 A Four years ago, and I'm guessing now, but it 6 is som e time in the past and not the recent past, that 7 there was an early dismissal in the Mt. Sinal schoC1s.
8 Q Do you remember what the cause of the early 9 Cismissal was?
10 A I believe it was snow.
11 0 Do you know anything about whether there was 12 any difficulty in implementing the early dismisal plan 13 at tha t time?
~
14 A I am not tware of the pa'rticulars of that.
15 0 Is it your understanding that the early 16 dismissal plans for Mt. Sinal involve staff personnel -
17 riding on buses with school children?
18 A With respect to the specific plan, I really 19 couldn 't say as to who is assigned what. So my 20 understanding of the plan is not on who directs whom, 21 but ge nerally it is the use of the transportation system ,
22 to return the youngsters to their homes.
(_
ALDERSON REPORTING COMPANY,INC.
440 FIRST ST., N.W., WASHINGTON, D.C. 20001 (202) 628 9300
22 1 3 Do you have a copy of your testimony in frcnt
( 2 of you to refer to if you need to?
3 MS. LETSCHEs Tha t 's my copy, but he can use 4 it.
5 MS. McCLESKEY: I will be glad to give him
~
6 one.
7 MS. LETSCHE: Fine. That will be easier.
8 BY MS. McCLESKEY: (Resuming) 9 3 On page 3 of your testimony you state that 10 teachers and administra. tors telephone home to ascertain 11 if a p arent or guardian is available to receive a child 12 at the elementary level. Is it your understanding that
{
13 that- is what is done in the Mt. Sinal school district?
14 A As f ar as the calling home, tha t I couldn't 15 commen t on as f ar as Mt. Sinai, as to whether or not 16 calls go home to the parents of Mt. Sinai. That is what 17 is don e in East Meadow.
18 3 So is it fair to say that your description of 19 early dismissal programs in your testimony refers to 20 East M eadow and not Et. Sinai?
21 A I kind of made it clear that what my knowledg e 22 of the M t . Sinai early dismissal is is basically I know ALDERSoN REPORTING COMPANY,INC.
M0 FIRST ST., N.W WASHINGTON. D.C. 20001 (203 628-9300
. n 23 1 they h aveone; and two, I have been the parent on the
( 2 receiv ing end of the program. So I don't have any 3 specific., play bP olay kn'owledge of who directs whom in
~:. ,.
4 order to make it happen.-
N 5 ,In Ea s t Meadow I am a f ront-line 5 administratoe, so to speak,'and I an .,eaking from the 7 pocition of a person who would 'be involved in making 8 that h appen. So those are two different perspectives.
9 0 Do you know -- en page 4 of your testimony you 10 ref er to the f act that dismissals and arrivals of 11 children are usually done on a staggered basis for 12 school s. Is that 'the way it is done in East Eeadow? Do 13 children come in at different times?
14 A Yes.
15 0 And is t' hat to accommodate the transportation 16 needs of the schoo1 district?
17 A Well, that is something that for districts 18 that 3o transport youngsters is common. The reason is 19 sim ple . There is'an economic reason. It is very costly I
20 to tra nsport everyone at the same time. It would simply 21 me9 n y ou would nee'd many, many more buses, as opposed to 22 s ta gg e ring the sta rt time and the finish time, which k
(
ALDERSON REPORTING COMPANY,INC.
440 FIRST ST., N.W., WASHINGTON, D.C. 20001 (202) 628-9300
67 1 (Recess.)
( 2 BY ES. McCLESKEY: (Resumino) 3 3 Mr. Campo, have you reviewed early dismissal 4 pla ns for any schools?
5 A Other than my own?
8 Q Yes.
7 A No.
8 3 Have you reviewed the Shoreham emergency plan 9 that was draf ted by LILCO?
10 A The LERO plan?
11 3 Right.
12 A Yes. I wouldn't say reviewed, but I read
( 13 that..
14 Q You've read the entire plan?
15 A No,'not the entire plan. But I am familiar.
18 I focu sed on some thinos and I'm generally familiar wit h . -
17 it, al though I don't consider myself an expert on that 18 plan.
19 Q Are you familiar with the provisions in the
- 20 LERO plan for the schools within the ten-mile zone?
21 A Yes. My recollection is that early dismissal 22 was a component of the LERO plan.
k l
ALDERSON REPORDNG COMPANY,INC.
~
20 F ST, N.W, WASHINGTON, D.C. 20001 (20lQ M9300
. _ . . _ .