ML20087J539
| ML20087J539 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/21/1984 |
| From: | Jeffers G, Rossi A SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20087J534 | List: |
| References | |
| OL-3, NUDOCS 8403220292 | |
| Download: ML20087J539 (16) | |
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REWED CORgtsPO NIO 22 gj*.I7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Before the Atomic Safety and Licensing Boaro'
)
In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Shoreham Nuclear Power Station,
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(Emergency Planning)
Unit 1)
)
)
DIRECT TESTIMCNY OF DR. GEORGE J.
JEFFERS AND ANTHONY R.
ROSSI CN BEHALF OF SUFFOLK COUNTY REGARDING CONTENTIONS 24.E, 24.F, 61.C, 69, 70 AND 71 INTRODUCTION Q.
Please state your names ano poJitions.
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.
We are submitting this testimony to express tne concerns of the Middle Country Central Boaro of Education.1/
1/
See Attachment 1 to our previous testimony (It. Tr. 3087) for the official statement;by tne District soard 'cn:
( Footno te cont' a nex t page)'
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PDR ADOCK 05000322 T
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Q.
What is tne purpose of this testimony?
A.
The purpose of this testimony is to adoress Contentions 24.E, 24.F, 61.C, 69, 70 and 71 and state our conclusion tnat the LILCO Plan provides inadequate protection to scnool cn11-dren.
Q.
Are you familiar with the LILCO Plan?
A.
We have reviewed those portions of the LILCO Plan that contain LILCO's proposals for protecting school children in tne event of a radiological accident at Snoreham.
CONTENTION 24.E - AGREEMENTS WITH SCHOOLS Q.
Are you familiar with Contention 24.E?
A.
Yes, and we agree with the assertion in Contention 24.6 that LILCO's proposed protective actions for schools are un-likely to be implemented because LILCO has obtained no agree-ments from schools or school districts to implement the LILCO proposals in the event of a Shoreham emergency.
(Footnote cont'd from previous page)
Education or its opposition to tne LlLCO Plan anc its au -
thorization for us to present the District's position'in-
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this-proceeding.
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4 To.our knowledge, LILCO has no such agreements.
The
- Middle Country Cencral School District has not encereo into'an 5
i agreement with LILCO concerning implementation of tne LILCO proposals for schools, nor does it intend to.
Indeed, many districts, including ours, have stated snat eney do noc believe LILCO's proposals could be implemented in a way tnat would provide adequate protection for cnildre'n.
CONTENTION 24.F - AGREEMENTS TO Ph0 VIDE SCHOOL BUSES Q.
Have you reviewed Contention 24.F?
A.
Yes, we have.
The portions or Contention 24.F that concern schools are 24.F.2 ano 24.F.3.
They asser t tnat most full-size buses in'the vicinity or the 10-mile EPZ woulo De l-unavailable to LILCO in ene event of an emergency, aespite i
LILCO's agreements with.various bus companies.
Q.
Do you agree witn subparts 2 and 3 or Contencion 24.F?
d A.
Yes,-we do.
LILCO proposes to use' buses.co evacuate persons without access to cars, nursery' school children, many special. facility patients and most ot'the handicapped-.resioents of the EPZ.
(See Appendix A at'IV ~/4b,'IV-171,'IV-175;,OPIP I
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3.6.5.) LILCO apparently has entered into contracts witn several bus companies to obtain buses.
24.F. 2 in - correct in -
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its assertion that LILCO would have access to only a small fraction or the number of buses nominally proviceo by those agreements.
It is our understanding that LILCO's agreements l
witn bus companies state that the bus company's provision or ouses to LILCO is sub]ect to the prior rignes or the local scnool alstricts with wnich tne company nas contracts.
One or,
the bus companies with which LILCO has contracteo is United Bus Corp. (" United").
Tne Middle Country Central School District has a contract with United which obligates Uniteo to provice us with 32 buses during tne period September 1 to June SU.
During school sessions it appears that most of United's otner buses are also in use because there have been occasions in our expe-rience when we have been unable to obtain extra buses tor spe-cial purposes such as field trips.
We have rouno on sucn j
occasions that the companies that provide buses to'senools ano i
school districts in the vicinity or our district hao committed all their buses to various schools.
g Fur ther, as noted in Contention 24.F.3, tne provisions or LILCO's Plan exacerbate the' problem.
If schools ano scnool..
districts were to attempt to implement early dismissais or evacuations, as proposed by LILCO, they would need all tne buses they could:get.
It woulo be especially bad'in an evacua-tion, because most schools ano school districts.do not provide t -
1 bus transportation for all their school chiloren.
Theretore, they do not have enough buses to carry all their scnool chil-dren, and in an evacuation they would have to obtain even more than they normally use.
CONTENTION 61.C - SHELTSRING Q.
Are you familiar with Contention 61.L.l?
A.
Yes.
Contention 61.C.1 asserts that LILCO's proposals to protect school children by keeping them in their scnools woulo not work.
We agree with Contention 61.C.1.
Because our district does not have any scnools insloe tne EPZ, according to the LILCO Plan, if sheltering is recommendeo for any portion of the popuistion in the EPZ, tne Miodle Country Central School District is expected to retain tnose l
students who live in the EPZ at school beyond the eno or tne l
school day.
We have approximately 1100 school en11oren who live inside the 10-m11e EDZ.2/
Our district likely woulo noc 2/
In adoition, althougn none of the scnools in our oiscrict are witnin tne EPZ, some are very close to.tne EPZ bouno-ary.
Knen one loons at the irregular path followed by cne EPZ boundary enrough tne Middle Country Centrai ScnooA District, it looks as if the boundary were drawn inten-tionally to keep some of our school builoings outsloe ene EPZ.
Accordingly, it is not clear to us tnat a sheltering order 2vr persons "in the EPZ" snould not also apply to the children in our scnools-enat are very close to tne EPZ boundary. *
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be able to implement the LILCO proposals for keeping children in schools during a Shoreham emergency.
First, LILCO's apparent assumption that school otticiata nave performed " preplanning" of actions that would protect children in the event of a shorenam emergency is incorrect with respect to our district, and in our opinion, with respect to most, if not all, otner districts in the vicinity or tne EPZ.
Our district has expressly determinea that planning for tne actions contemplated in the LILCO proposals would be tutile ano misleading to parents, bacause such a " plan" coulo not be implemented in a manner tnat would assure adequate protection to our students.
Second, LILCO appears to ignore the fact that enilaren simply could not be kept in schools and given adequate supervi-sion and care, unless the scnools had sufficient personnel, food and other necessary supplies.
Schools do not have tne supplies, facilities or personnel to care for cnilaren tor hours beyond tne end or the school day, to secure bulidings to maintain accountaoility, or to keep orcer unuer sucn trignt-ening circumstances.
Scnools do not teed their scnool cn11cren three meals per day; they are not designeo - to accommodate peo-
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pie overnight; and school personne1Ldo not worn around the clock.
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In addition, assuming we were to begin an early dismissal of our children prior to LILCO's recommendation or sneltering
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or evacuation for persons in the EPZ as the Plan appears to contemplate, we would be sending at least 1100 children into the EPZ.
If the severity of tne emergency increased anc a rec-ommendation to shelter were made, we coulo do nothing tor tnose children we had already sent into contamina.ted areas.
As we will discuss below in connection witn Contention 09, tnose enildren, whether in buses or on foot, would take a long time to reach home, and while en route would have no accees to ef-fective shelter.
Under tnese circumstances, it is unlikely that school children would receive adequate protection.
CONTENTION 69 - EARLY DISMISSAL OF SCHOOL CHILDREN Q.
Are you familiar with Contention 69?
A.
Yes, we are.
It asserts that an early dismissal woulo not protect school children as LILCO seems to assume.
Q.
Do you agree with Contention 69?
A.
Yes.
First, LILCO's apparent assumption tnat scnools el-ther have developed early dismissal plans tor a Shorenam emer-gency or have determined that tneir " normal" early dismissai plans developed for use in. snow and other situations are P 1
n appropriate for use in a Shoreham emergency, is unwarrantea.
The Middle Country Central School District nas no early dis-missal plan designed for use in the event of a shoreham emer-gency, and our standard early dismissal plan would not work, as discussed below.
Q.
Why would early dismissal not result in the timely arrival of children at their homes so they could be protected by tneir parents, as asserted.in Contention 9.C?
A.
Simply put, early dismissals taxe much longer to complete than-LILCO's planners seem to have realized.
In a nurmal early dismissal, tne last student would not leave his or her school until approximately 2 1/2 hours arter one start or une dismissal.
And a dismissal could' occur enat quickly only it everything went smoothly and no proolems arose.
It is not un-usual in early dismissals in our district for the inst en11oren to leave school 4 to S hours after the start of the dismissai, and of course, tney arrive home even later.
In 11gnt of the serious difficulties likely to occur in the event ot an accident at Shoreham (wnien we discuss below), we believe it is very likely tnat early dismissais would taKe even longer tnan 4 to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. "
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The take home process would likely be slowed still more by both the heavy evacuation traffic expected by otner witnesses tor the County and New York State, and the stafring snortages which would probably result from role conflict among school personnel.
(See Direct Testimony and Supplemental Direct Tes-timony of Dr. George Jeffers and Anthony R.
Rossi on Behalt of i
Middle Country Central School District and Sufrolk County Regarding Contentions 25.C ano 25.D, ff Tr. 3067).
Moreotter, in more usual but nonetneless serious circumstances, such as severe storms, the degree of contusion in and around schools during an early alsmissai is always high.
Many parents arrive to pick up their cnildren.
Cnildren do not find their buses or their parents.
Trartic congestion arouno the schools impedes the arrival and departure ot buses.
Tele-phone calls from concerned parents, and locating and singling out children, tie up large numbers of school personnel.
All these factors slow an early dismissal under " normal" conditions.
In the event of an accident at Snorehem, unese problems are likely to be substantially greater and more sig-nificant.
Furtnermore, our district provides bus transportation for approximately 125 private scnool cnildren who either reside or.
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4 attend private schools in the EPZ.
In tne event of an early i
dismissal of those schools, Middle Country CentraA Scnool Lis-trict bus drivers would nave to travel into, and in some cases, through almost the entire EPZ, to reach the private senools, copa with the confusion likely to exist at those schools, and then return to our district through the traffic congestion before they could even begin the take home process.
When you add up all these factors, an early dismissal in the event of a Shoreham emergency woulo take a very long time.
Q.
Do you have any other concerns relating to L1LCO's propos-al for an early dismissal in the event ot a Shorenam emergency?
A.
Yes.
One ot our.more serious problems in early dismissais i
is looking out for those children who have no one to return to during-tne day, for example those children with working parents.
Many working parents make arrangements for friends or relatives to care for their children in case ot early dismiss-als or other' emergencies.
At the start of tne scnool year, these parents inform the schools of the telephone numbers or the persons who will care for the chilcren if they cannot be reached.
However, alJ we can.do in attempt to contact tnese i
frie'ds or relatives. 'Under State law, we cannot deliver the n
ch11dren..to'6ny homes other'than their own. 'Therefore, it we 10 -
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cannot reach the person designated to watch after a en110, or that person is unable to get to the enilo's home, the en110 could be left unattended at his or her home.
These chilcren would be without adults to care for them, and in ene event or an emergency at Shoreham there would be no assurance tnac they would be protected.
Moreover, we believe that in the event of a Shorenam emer-gency, most parents would go to schools to pick up tneir chil-dren.
We base this belief on our own experience as scnool 30-ministrators, and on our contacts witn tne parents organization in our district.
As a result, we would prooably be unable to I
contact very many parents or other responsibic acults.
Q.
Do you agree with Contention 69.E?
4 A.
Yes, we do.
That contention asserts tnat because ene LILCO Plan does not provice a means of dealing witn an escalation of an emergency, it is likely tnat many cn11oren would be stranded in schools or caught en route to eneir nomes without available means ot shelter or evacuation, even it snel-tering or evacuation were being recommended for persons _in tne EPZ.
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Once an early dismissal.has begun, some child'ren woulo be in buses or on foot,'and-would nave no. access to shelter or to a means of evacuating from the area until they arrived nome.
' As w(. have'diiicussed above, the trip.home could take a very long time.
This is a_ serious problem for_ our district, because
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...r if we started an earl,y dismissal,'and then LILCO recommenced protective actions for the EPZ, many of tnose children in our
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schools who'li've in the EPZ would be on their way out of a pre-
.sumably_ safe' area ano into potential danger, and.we could do nothing.at-t"st point to help them.
Our,senool buses are not equipped with radios and we have-no deans of-contaccing the vast majorit[y' of our drivers, once tney leave' trie scnool or ga-rage.
CONTENTIONS 70 AND 71. - EVACkJATION OF SCHOOL CHILDREN Q.
Are you familiar with Contentions 70 and 717 2
A.
Yes.
They assert-tnat LILCO's proposal to protect schooA children by evacuating them wo.As n6t'.E'ork.
We agree wicn Con-j, tentions'70 and 71.. Even th q che 'LILCO Plan does not con-
. template that our-District wouJ2 Ova uate its students, because' of the' location of some of our[ schools.and ouF evaluation ot s
.the dangers involved-in a Sndreham accident,' we'have considered-the problems that would be inholved it, tan evacuacion were-
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attempted in our district or other districts.
Moreover, even under the LILCO Plan, we would have to evacuate those or our students who attend private schools in ene EPZ.
First, as stated, in Contention 70, as far as we know I
LILCO has not arranged for relocation centers, or developed procedures necessary for an evacuation or schools to succeea.
To our knowledge there.are no facilities wnich have agreea to i
accept the children who would have to be evacuacea.
We could not and would not transport school chiloren without knowing where to take them.
And, we could not agree to transport the school chilcren we would have to evacuate to any relocation center, unless we were sure betorehand that the center was ade-quately stafted and equippeo to care for the cnildren, and tnat workable arrangements had been mace to allow cnildren to be quickly reunited with their parents.
To our knowledge, tne as-sertions of Contention 70 are correct in that-neitner or tnose conditions has been met in the LILCO Plan.
Moreover, even if these conditions haa been met, it would be unlikely enat our district could relocate students until parental approval nad been obtained, and until responsibility for supervising the children at relocation centers had been assigned. -The L1LCO-Plan makes neither of these arrangements.
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't Moreover, relocation centers for enildren would need ex-tensive telephone equipment and staff to handle calls from parents asking about their children.
We believe that tne LILCO proposal would result in confusion.
Parents woulo not know their chiloren's whereabouts.
They would call schools, L1LCO,
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and anybody else wno might know.
Then, if they dio learn eneir children's locations, they would have to fight neavy trattic to travel to the relocation centers.
In the meantime, tne cnil-dren might easily become extremely anxious.
They linely would be frightened to start with, and the lengthy aelay could only worsen their emotional states.
Q.
Is LILCO's apparent assumption that school districts' nave performed " preplanning" for a Shoreham evacuation correct?
A.
That LILCO assumption, in our opinion, is unfounced.
Gur distr?ct has conducted no Shorenam-related " preplanning," el-ther for evacuation or tne sate reuniting of school enildren with their parents, anc based upon our conversations wicn other administrators, we do not believe that many other aiscricts
' have eitner.
Furthermore, we believe that such an evacuation woula ne very difficult, if not impossible. First, as stated in Conten-tion 71.A, the LILCO Plan contains_no provisions for i l l
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supervising school children during an evacuation.
Tne children would have to be cared for during an evacuation.
They would have to be supervised at schools and on buses, and then at re-location centers until their parents arrived and found tnem.
And, staff would have to be available to provide inrormation to parents.
There are no provisions in the LILCO Plan relating to sucn necessary staffing, such staffing is beyond our district's present resources, and we do not believe sucn statfing could oe obtained on an ad hoc basis during an emergency.
Most ois-tricts do not normally send teachers or other staf f witn chil-oren on buses, nor are teachers or other school staff normally expected, or required, to remain with children (or accompany them to a new location) for extended periods beyond the end of the school day, which would be necessary if evacuation were to take place.
Q.
Do you agree with Contention 71.B that evacuating school children by bus could not be accomplished in a timely mannert A.
Yes.
Other witnesses nave testified about tne likelinooc of heavy traffic in the event or an evacuation.
It is our ex-perience that regular early dismissals take ene longest when traffic conditions are cao, and there is no reason to believe that congestion would have any'less an effect on an evacuation.
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Indeed, in our opinion, an evacuation would almost cer-tainly take much longer than an early dismissal.
Most school districts would not have enough buses to accomplish a timely evacuation.
Normally, school districts do not transport all their school children.
Many walk, or are driven to scnool by
' parents in carpools.
If the schools'were requireo to conduct an evacuation, tney presumably would have to provide transpor-tation even for those children who normally do not ride school buses..Therefore, an evacuation would require even more bus runs than would an early dismissal, which would mean even more delay.
Q.
Does that conclude your testimony?
A.
Yes.
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