ML20092P267
| ML20092P267 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/27/1984 |
| From: | Claypool R POTTSTOWN, PA |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| OL, NUDOCS 8407060121 | |
| Download: ML20092P267 (13) | |
Text
- g>;
w
- 5. RO8
[+[MM<t Owen J. Roberts School District g g, $jg yt y6 Administration Building R.D.1, Pottstown, Pennsylvania 19464 p
Telephone (215) 469'6261 0 +.
% -3
,D 215 0 9g June 27, 1984 W..
"- f f i
pf.=. a ".u ::.:........-. +2/1.C? of orr.T :""
Tb -3 5-SERVED JUL 5198ti Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comission Washington, D.C. 20555
Reference:
Incomplete Inadequate Nuclear Evacuation Plan For The Owen J. Roberts School District Within The Limerick Nuclear Planning Area
Dear Sir:
Nineteen (19) months ago the Owen J. Roberts School District established a Citizens' Task Force for the purpose or the cevelopment or school emergency planning guidelines involving potentially hazardous conditions including a nuclear emergency at the Limerick nuclear facility.
This Citizens' Task Force is comprised of representatives from the seven (7) townships comprising the School District; township supervisors; NORCO Fire Company; Technical School; employee union representatives from custodial, secretarial, teachers, and cafeteria; parent representatives from all of our schools; and a number of concerned citizens.
All of the task foIce meetings have been advertised in the local newspapers and open to the general public.
On June 6, 1984, the School Board held an open forum on the status of the nuclear evacuation plan.
This meeting was widely advertised in the local media.
The Citizens' Task Force presented its status report which, in summary, states they have identified the human and other resources needed for an evacuation; the actual available resources on hand; the unmet needs; and the alarming fact that the County Department of Emergency Services has not been able to meet any of the identified unmet needs.
The Task Force made the following recommendation to the Board of School-Directors.
"We cannot submit the current draft of the Owen J.
Roberts School District Radiological Emergency Response Plan for approval.
As it currently exists it is not adequate and will not be effective in the event of a developing radiological emergency."
B407060121 840627 PDR ADOCK 05000352 hSO C 0
L Page 2 June 27, 1984 Citizens were then given an opportunity to comment on the status of the evacuation plan and to give additional input.
Between two and 'one-half (2 1/2) and three (3) hours of testimony was receivec by the Board of School Directors.
A summation of the input revealed unanimous agreement by all present to the following:
the identified human and other resources neeced for a nuclear evacuation as presented are real; the calculations and procedures identified by the task force over a nineteen (19) month period to identify unmet needs are valid; and, the School District must look beyond the county to both state and federal governments for immediate help in not only meeting our unmet needs, but to also cemonstrate to those empowered with the authority to make change the serious deficiencies in the overall master plan for a general evacuation of this School District.
I am attaching a copy of the testimony presented by the Citizens' Task Force and also by my office.
We solicit your aid in notifying all governmental agencies of our unmet needs and the serious deficiencies in the overall master plan for a general nuclear evacuation for the citizens and children of this School District.
Both members of the Citizens' Task Force and I are prepared to give testimony on this most serious matter.
Your immediate attention and response will be appreciated.
Respectfully,
{ r Roy C. Claypool, Ed.D.
District Superintendent Attachment
/ho 4
e
- l-.
OwEN J. RCEERTS S'HCCL DISTRICT R.D. #1, POTTSTOWN, ?A.
19464 _
TO:
Board of School Directors Owen J. Rcberts School District FROM:
Citizens Task Force for Cevelopment of Schcol Emergency Planning Guidelines
/
a RE:
Interim Progress Report on Develcpment of Emergency Radiclegical Response Plan DATE:
3Jne 5,1984 This ccmmunication will inform ycu of the current status of the development of the Radiological Emergency Response Plan.
As you know, the Citizens Task Force has worked seriously and conscientcusly over the past nineteen (19) months in an honest effort to develcp cur District Emergency Plan.
All cctivities of this Task Force have been completed within guidelines established by the Emergency Planning Act, the Pennsylvania Emergency Planning Agency, and the Department of Emergency Services.
As directed by these agencies, the primary cbjectives of the Task Force were to identify resources needed for. student evacuation or sheltering; determine existing District resources; and then report all unmet resource needs to tr)e Chester County Department of Emergency Services.
The role of
'the Chester County Department of Emergency Services is to locate and identify additional rescurces required for a school district evacuation.
Rese resources would then be appropriately documented and attached to our District and County Radiological Emergency Response Plans.
The following outline will summarize the results of the needs assessment completed by the Citizens Task Force and subsequent recommendations for Scard consideration.
I.
Findings of Fact A.
Resources Needed for Evacuation 1.
Fifty five (55), seventy two (72) passenger buses 2.
Fifty five (55) bus drivers 3.
One hundred fifty six (156) student supervisory personnel 4
Twenty two (22) traffic coordinators 5.
Establishment of an appropriate host school site e
h m0
8.
Current District Rescurces Cete =ined After Extensive Study, Training, and Survey of District Personnel
+
1.
Thirty (30), seventy two (72) passenger buses 2.
Eighteen (18) bus drivers 3.
Sixty five (65) student supervisory perscnnel 4.
No available traffic coordinators 5.
No agreement has been reached regarding the establishment cf a host school site C.
Unmet Resource Needs Confirmed by the Citizens Task Fo ce at a Meeting Held en June 4, 1984 w
1.
Twenty five (25) additicnal schcol buses i
2.
Thirty seven (37) additional school bus drivers 3.
Ninety one (91) additional student supervisory personnel 4.
Twenty two (22) traffic controllers 0.
Documentation of this Need;5 Assessment 1.
Meeting en subject of District tran'sportation needs and resources with representatives frcm the Chester County Department of Emergency Services - March 1983 1
2.
Teacher survey - May 1983
- 3.. Bus driver survey - May 1983 i
4.
Joint suo-committee of Rc'oerts Education Association and Citizens Task Force during the month of July 1983 l
5.
Teacher and bus driver training program - November 1983 6.
Teacher survey - November 1983 7.
Bus driver survey - December 1983 E.
Documentation of Communications Regarding Esta'olishment of' t.hmet Resource Needs 1.
Meeting with representatives of Department of Emergency
-Services - March 25, 1983 2.
Letters to Chester County Cepartment of Emer.gency Services dated July 20, 1983, March-13, 1984, and May.1, 1984 3.
A representative of the Cepartment of Emergency Services has attended.all but two (2) regular meetings of.the Citizens Task Force of the Owen J.
Rocerts School District-and-
1...
n.-..-..
4.
Letter from Department of Emergency Services informing cur Task Force that additional rescurces have not been identified - May 25, 1984 F.
Conclusions of Fact 1.
As a
result of thorough investigation and study of rescurces, the unmet rescurce needs of the Owen J. Roberts School District are real and valid.
2.
None of our unmet resource needs have, as of this date, been identified and cccumented for us by the Chester County Department of Emergency Services.
3.
Our emergency planning cannot move forward until all identified resource needs are provided by the Chester County Department of Emergency Services.
Any statements regarding the location of these additional rescurces must be thoroughly documented in detail including letters of agreement with transportation providers, schcol bu.s drivers, supervisory perscnnel, traffic coordinators, host school arrangements, and all other needs estan11shed as real and valid by the Citizens Task Force.
3.
If our responsibility is to provide for the safety and welfare of our students during a developing radiological emergency, it is also then our obligatien to have assurance that all resources of additional equipment and personnel are of sufficient quality to evacuate cur students within adequate parameters of time and safety.
II.
Reccmmendations of the Citizens Task Force A.
We cannot sdomit the current draft of the Owen J. Roberts School.
District Radiological Emergency Response Plan for approval.
As it currently exists it is not adequate and will not be effective in the event of a developing radiological emergency.
B.
Since' the Philadelphia Electric Corporaticn is scheduled to begin on-line operations of the Limerick Naclear Power Generating Station in April of 1985, it is necessary to take an aggressive approach :
toward resolving.
the aforementioned emergency planning issues.
We, therefcre, reccmmend.that communications be initiated with the Federal. Emergency Planning Agency informing them of our detailed review of unmet resource
.needs and the lack of any response by the Chester County Department of Emergency Services.
e*
6 W
^ -
'c-
~C.
We also recorrmend that no Emergency Respense Plan be submitted for Scard approval without ccmplete anc thorough drill and
~
exercise.
If the unmet rescurce.neecs are eventually identified, we wculd ask that at least ene planned drill, be scheduled during the schccl day dith movement of all internal and external resources to determine if emergency procedures and resources will adequately provide for student - safety and welfare.
In add _ition, we believe that at least cne unscheduled drill be attempted to provide further assurance of the adequacy of the Emergency Plan'.
D.
We also recommend that the Citizens Task Force fcr School Emergency Planning Suidelines ccntinue to function until all emergency planning issues are resolvec and the Emergency Response. Plan is determined to be adequate to provide for the f
protection of the ' student enrollment of the Owen J.
Roberts Schcol' District.
9 e
e D
g 9
6
~
- g i
4 b
u o
k
'5 h.
.q.
'f t f
.g l
T V
+),,
\\
- i:
'i, t
2 n
r
4 EXECUTIVE SLNMARY SE:0AT RADIOLOGICAL EMERGEFCY RESPONSE PLAN A
Prepared and Presented By a
Dr. Roy C. Claypool, District Superintendent June 6, 1984 The statements contained within this Executive Summary Report have not been shared, in total, with anycne prior to their release tonight. They are my statements, ano I stand accountacle ano reacy to cefend them as Superintendent of Schools.
In the Summer of 1982, the School District received a directive from the Ocpartment of Education establishing a need for a Radiological Emergency Response Plan for the Owen J. Roberts School District.
Shortly thereafter, on August 31, 1982, the Chester County Department of Emergency Services sent a communication to the School District offering its services.
At the following September 20, 1982, School Board Meeting an open discussion took place on the need for the. School District to oevelop such a plan.
The Boaro sought input from citizens and at the next School Boarc Meeting October 18, 1982, the School Boaro established a Citizens' Task Force for the purpose of development of school emergency planning guidelines involving potentially hazardous conditions inclucing a nuclear emergency.
At the same meeting the School Board requested financial support from the Philacelphia Electric Company for the additional costs wnich would -be incurred by the School District in the development of such a plan.
The Board also insisted that the task force meetings be open to' the public and therefore, by resolution passed a motion advertising in the newspapers the first meeting of the task force would take place on November 30, 1982.
Representatives from the following agencies met on November 30, 1982.
Department of Education, Harrisburg; PEPA; Chester County Department of Emergency Services; Emergency Coordinators from the seven (7) townships comprising the School District; NORCO Fire Company; Emergency Consultants, Inc.;
Northern Chester County Tech School; Friends of the Arts; PTA and PTO's from all schools; employee union representatives from custodial, secretarial, teachers, and cafeteria; township supervisors; parents;. ano a number of concerned citizens.
During these nineteen (19)' months this task force has been extremely active in attempting to accomplish their task.
This task force has made a supreme effort to honestly appraise both human and other needs.
On July 20, 1983, seven (7) months into. the planning process, this committee informed the Chester County Department of Emergency Services of the number of human resources and vehicles required for an evacuation plan.
~
From that point until March 13, 1984, sixteen (16) months'into the plan, this committee attempted to realistically identify the number of employees who woulo participate and the actual numoer of vehicles which would be available during an emergency.
This information was then sent to the Chester County Department of Emergency Services indicating unmet neecs.
-.. p g._ -
.. i y.
q 8..
.y t-
- r
. i:
,, ? ".,
.+
s,/
Exectiti.1, Summary Nepart
^^
^
,f' June 6,1984 Page'3
1 a
/
"i Serious enallenges to sheltering as _a' safety cptien have been raised f
with no satisfactory answers. ~ If PEMA orders sheltering, how safe, how long
' y',j'
,l before contadnation and/or rays penetrate? Parents will surely converge on our sencois;to gain access to their chilcren.
o
'?v _
j, c
Is Twin; Valley, our alleged host / school,"far enough away? Is it not in e 'd,
/the, ingestion exposuIe pathway?
/
.e y
{:
-What provisir,ns are belag / planned, by municipalities for alternative rcuting in the ever.L of inclement weathen such as ice, snow, etc.
Routes 23
.(
and'.100 usually prdvWs us with one; or two accicents delaying our bus runs.
e.
Whose time frw.es a're me going' to, use to cetermine the absolute minimum
' time needed to properly;cvacuate'stucents and employees?
.f Where in this countrh Mas a-greater effort been mace over a nineteen (19) }cr.th period to develcp an adequate' evacuation plan?
f 4
e J As the ' tims? draisi nearer for the opening of the plant, parents are feding andJexhibiting< increased stress over the healtn anc safety of their children.~,, we will, not.: compromise either the health or safety of our childr,en for' employees in order to have an evacuation plan that is not adequate' enc ~ implementable.
(
l What are the legal liability exposures of the Senool District,. the School Bdarc, incivicUal Schoci. Board members, District Superintendent, employees,; and volunteers? If acditional liability insurance is neeced, who will pay' for the insurance?
State una federal planners have been quick to identify, in detail, local responsibilities;both ; financial and legal, but no visible effort to meet any
_);of,our,unmetneecs.
,;.s
'.;[ tate and-federal governments for immediate help in not only meeting our
-It is my copinion ;.that we must look beyond Chester County to both the s
_ unmet nceds,.b4 tc, also! demenstrate to those empowered with the authority a -
to make chance the serious deficiencies in the overall master plan for a general evacaticirof thi's ' School District.
- r.
Je yy y
det us not,-spent, t,hesernext few months debating how to rearrange the fichairs ori the' deck of thejitaqic.
Instead, join forces with the task force
% in seeking a req 16 tion to.our unmet needs, as well as educating those in a
/, decision making -role / the serious deficie.1cies in the existing planning Mstructure, and the 'attituge that given an errergency of this magnitude sitizensjwillri,seupandsolvetheproblem, Y
s,,t
.o O.s M.
blbl?4
-l
' Date i
g,Sig7ature:
3 }{
\\
t.
q
~,..y e' t s,,,
, 9' #
,js
.))
g
?l
- 4 RO8 5
bd Owen J. Roberts School District b
Administration Building y-w p
4P R. D.1, Pottstown. Pennsylvania 194M Q
Telephone (215) 469 6261 May 1, 1984 Mr. John McNamara Chester County Department of Emergency Services 14 E. Biddle Street West Chester, PA 19380 RE:
Need for Detailed Response to Citizens Task Force Letter Dated March 13, 198A Request to Respond to Additional Unmet Needs As Perceived By District Superintendent As Contained Within This Document
Dear Mr. 'McNamara:
Over the past couple of months, I have 'had extensive interaction with the-Board of School Directors, individual Board members,. and Joseph Clark, Administrative Representative to the Citizens' Task Force for School LEmergency planning for the Owen J. Roberts School District.
Last Friday, April. 27, I.
spent three (3) hours with Mr. C',a:k revjewing in detail the. status of Oraft 7.
During. this session Mr. Clark informed me t.at he had telephoned your -
office to see if any_ response was forthcoming in reference : to his letter of March 13, 1984.
Since my meeting with Mr. Clark I have spent an additional' six-.(6) to eight (8) hours thoroughly reviewing Draft 7, and Mr. Clark's communication-to you dated March L13,1984.
I met with the Board of School Directors -last evening,- April '30th, to-present my concerns which -will be.-; amplified in this communication.
.I, therefore,. request that a' detailed response be, presented,.ir writing, to both the, Citizens' ' Task Force letter ~ of March 13'h, 'as' well as my additional.
1 concerns-identified helein.-
The Owen J. Roberts Citizens' Task Force.has spent approximately a year
~
and a half examining _ this most-difficult concept.
Prior.to the ' end -of this 1
/ ' fiscal year :I 'am requesting that the Board' of. Sc col Directors meet with the Task Force -for ' a thorough ~ and complete. update of' the proposed Emergency.
3.,,
' Response Plan.- Therefore, it 'is imperative.that we receive ~ from you a written R
~
j communication no later than-June 1, 1984.
- Before; presentincf my concerns, I realize the difficultifunction you' must perform, but'I am'also aware of Murphy',s Law in'an emergency. situation.
~
r May 1,'1984 e
Mr. Jchn McNamara, Chester County Cesartment of Emergency Services Page 2 In reference to Mr. Clark's letter of March 13, 1984, I believe the Citizens' Task Force identificiation of needs are minimal and reflect optimum conditions.
That is to say, after thorough review and investigation I believe their needs are in some cases understated.
In order to expedite your communication, I will restrict my identification of unmet. needs to vehicles required for evacuation, bus drivers needed for evacuation, teachers and employees neeced for evacuation, traffic coordinators, and last, but not least, the fact that Owen J. Roberts does not have a host center.
Until such time as these unmet needs identified herein are thoroughly delineated by your agency as being available under the most adverse conditions, no valid evacuation plan [in my opinion] could possibly be feasible.
A general statement that these unmet needs will be resolved, or have been resolved without specific details involving how these needs have -
been met will be unacceptable due to the seriousness of the situation, and our complete reliance en outside resources to ccnduct an evacuation under the most optimum conditions.
SEVENTY-TWO (72) PASSENGER VEHICLES NEEDED FOR EVACUATION ALL PERSONNEL AND STUDENTS Total Vehicles Needed, Fifty-Five (55) Seven'ty-Two (72) Passenoer Buses.
Vehicles available thirty '(30).
Please note' this is smaller number than that identified by the consultant and the District Task Force.
This figure is reduced by ten (10) vehicles for the following reason.
A number of contracted drivers keep school buses at home.
-If ~ this evaucation should take place between the period of 9:30 A.M.
and 1:30 P.M.,
it.is.
very likely that at least fifty percent (50%) of these buses will not be operating because the driver either cannot. get back to the bus..or has elected to take care of' higher family needs.
Therefore, I conclude the unmet vehicle needs "nount to twenty-five (25) buses.
l Please identify where these twenty-five (25) - buses will : be coming from,- as well as, will-the twenty-five (25) drivers bringing the buses into curLDistrict drive these buses during evacuation??-
t l
BUS ORIVERS'
- The initial survey indicated that-twenty-five ' (25) - of our District -
drivers will drive a school bus during a radiological emergency.
- However, many of these drivers did preface their statement stating that their
~
families would come first, and they must be assured - that' their particular
~
children had :been taken care of.
Knowing Murphy's Law in emergency
' situations, I believe that the-twenty-five (25) figure more realistically
~
would be'a maximum of eighteen (18).
Therefore, I cenclude that - our unmet driver needs to.be thirty-seven (37) drivers.
If.you are successful. in acquiring twenty-five1 (25) buses and twenty-five--(25) drivers from outside our area, there is 'still a need '
-for twelve -(12) additional drivers.
Please identify. where-these.. drivers Lwould be ccming from.
=..
May 1, 1984 Mr. John McNamara, Chester County Departm" of Emergency Services Page 3 TEACHER NEEDS EVACUATION As you are aware, the Task Force did survey our teachers at least
+
twice.
The second survey ecming after an extensive ' inservice on the duties and responsibilities of teachers during an evacuation.
Our teachers were very open, and I believe honest, in their responses to this survey.
Human nature is to first of all secure unmet family needs.
Sixty-six percent (66%) of our professional staff responded to this survey.
This sixty-six percent (66%) response equates to one hundred thirty-seven (137) individuals.
Please be advised, however, that only
~
sixty percent (60%) of those responding signed the dccument.
Therefore, a more realistic teacher need will be based on the number who signed the survey.
A summary of the survey is as follows:
QUESTION: Will you be willing td accompany students by bus -
to the host center or mass care center?
The number who signed the document equates to approximately thirty-eight (38) teachers.
QUESTION: Will you be willing to drive your own vehicle
[without students] to the host school.or mass care center to provide supervision for 'our students?
The number who signed the document cquates to approximately fifty-six (56).
Teacher absences were not. factored into the estimate.
During November, for example, we had a daily absence of 13.5 teachers.
From the data available, I would conclude that, again giving Murphy's
- Law, human reaction to emergency situations and family needs, that internal staff resources accompanying students and attending to students at host centers will be more in the neighborhood of sixty (60) to sixty-five (65) teachers.
Our total teaching staff to date is two hundred eight (208): teachers to supervise our current enrollment.
If we were to reduce our supervisor ratio by twenty-five percent (25%), we would still have a total need for approximately one hundred fifty-six (156) teachers.
With only sixty-five (65) anticipated local teachers, there is a definite need for at least ninety-one (91) adult volunteers to assist students by bus or by car to the host school or mass ~ care center.
Who are these ninety-one (91) volunte'ers and where will they be ecming from?
I have not attempted to address the issue of sheltering -for I believe we need to have the resources determined for evacuatien and if they be resolved, then sheltering would be resolved.
- \\
,5
May 1, 1984 Mr. Ochn McNamara, Chester County Department cf Emergency Services Page 4 TRAFFIC CCORDINATCRS, As the time draws near for the cpening of the plant, it is quite clear that our citizens have every intentien of ccming directly to our facilities in order to pick up their children in the event of an In no way will the School Administration prevent parents from emergency.
picking up their children.
Therefore traffic controllers will be an absolute must at each of our educational centers.
I predict the need for the following traffic controllers, in addition to school employees, at each of the following educational centers:
WARWICK ELEMENTARY CENTER 3 Traffic Controllers FRENCH CREEK ELEMENTARY CENTER 3 Traffic Controllers VINCENT ELEMENTARY CENTER 3 Traffic Centrollers EAST COVENTRY ELEMENTARY CENTER 3 Traffic Controllers NCRTH COVENTRY ELEMENTARY CENTER 4 Traffic Centrollers CENTRAL CMPUS a minimum of 6 Traffic Controllers TOTAL El Traffic Controllers In addition to traffic centrollers, I raise a serious questien as to the traffic controlling activities that will take place at the intersection of Routes 23 and 1C0, Route 100 and Cadmus Road, and Route 23 and the exit from Owen J. Roberts.
My personal interaction with a number of parents indicates that the first response will be to converge on our educational centers for.the purpose of gaining access to their children.
Unless this need is met, we will experience mass hysteria, confusion, and
~
total blockage of any possible evacuation from our school facilities by school buses.
HOST SCHOOLS As of this date we still do not. have any agreement with another school district in the case or an evacuation.
I request your immediate attention to these most serious questions.
Members of my staff and I would be more than happy to sit down with you, at your convenience, to discuss in detail our concerns as well as the content of this communication.
Respeetfully,
~
?'&
Roy C. Claypool, c. D.
District Superintendent o/