ML20092P614
| ML20092P614 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/27/1984 |
| From: | Claypool R POTTSTOWN, PA |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20092P612 | List: |
| References | |
| NUDOCS 8407090173 | |
| Download: ML20092P614 (13) | |
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Owen J. Roberts School District o
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Administration Building Q
D R.D.1, Po tstown, Pennsylvania IS464 Telephone (215) 469-6261 kg $
June 27, 1984 Atomic Safety and Licensinc Appeal Panel U.S. Nuclear Regulatory Commission washington, D.C. 20555
Reference:
Incomplete Inadequate Wclear Evacuation Plan For The Owen J. Roberts School District Within The Limerick Wclear Planning Area
Dear Sir:
Nineteen (19) months ago the Owen J. Roberts School District established a Citizens' Task Force fer the purpose of the development of 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 compri. sing 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 force 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.
1 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 l
the alarming fact that the County Department of Emergency Services has not l
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 '.ubmit 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."
8407090173 840706 PDR ADOCK 05000352 C
I" 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 received 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 needed 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 demonstrate 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 statter.
Your immediate attention and response will be appreciated.
Respectfully, Roy C. Claypool, Ed.D.
District Superintendent Attachment
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CWEN J. RCEERTS SCHCCL OISTRICT R.O. #1, POTTSTOWN, PA.
19464 TO:
Board of Schcol Directors Owen J. Roberts School District FROM:
Citizens Task Force for Cevalopment of Schcol Emergency Planning Guidelines RE:
Interim Progress Report en Cevelcpment of Emergency Radiolcgical Respense Plan DATE:
June 5,1984 This ccmmunicaticn will inform ycu of the current status of the develcpment of the Radiological Emergency Respcnse Plan.
As ycu know, the Citizens Task Force has worked seriously and conscientcusly over the past nineteen (19) months in an honest effort to develop our District Emergency Plan.
All tetivities of this Task Force have been completed within guidelines estaclished by the Emergency Planning Act, the Pennsylvania Emergency Planning Agency, and the Department of Emergency Services.
As directed by these agencies, the primary objectives of the Task Force were to identify rescurces. needed for. student evacuaticn or sheltering; d2termine existing District rescurces; and then report all unmet resource needs to tr!e Chester County Department of Emergency Services.
The role of th2 Chester Ccunty Cepartment of Emergency Services is to locate and identify additional resources required for a school district evacuation.
These resources would then be apprcpriately documented and ' attached to our District and County Radiological Emergency Response Plans.
The follov.ng outline will summarize the results of the needs assessment 2
completed 'by the Citizens Task Force and subsequent reccmmendaticns for Bosrd cendtderation.
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Findings of Fact A.', Resources Needed for Evacuation
$1. Fifty. five (55), seventy two (72) passenger buses 2.
Fifty five (55) bus drivers i
3.
One hundred fifty six (156) student supervisory perscnnel 4.
Twenty two (22) traffic coordinators
-5.
Establisinent of an appropriate host school site l
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Current District Rescurces Cetermined 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 personnel 4.
No available traffic coordinators 4
5.
No agreement has been reached regarding the establishment of a host school site C.
Unmet Rescurce Needs Confirmed by the Citizens Task Force at a Meeting Held en June 4, 1984 1.
Twenty five (25) additicnal schcol buses 2.
Thirty seven (37) additional schcol bus drivers 3.
Ninety cne (91) additicnal student supervisory perscnnel 4.
Twenty two (22) traffic centrollers 0.
Cocumentaticn of this Needs Assessment i
l.
Meeting en subject of District tran'sportation needs and resources with representatives frcm the Chester Ccunty Department of Emergency Services - March 1983 2.
Teacher survey - May 1983 3.
Bus driver survey - May 1983 i
4.
Joint suc-ccmmittee of Rccerts Education Associatien and Citizens Task Force during the month of July 1983 i
5.
Teacher and bus driver training program - November 1983 i
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6.
Teacher survey - November 1983 I
7.
Bus driver survey - Cecember 1983 f
E.
Cocumentatien of Ccmmunications Regarding Esta'alishment of Lnmet i
Resource Needs 1.
Meeting with representatives of Cepartment of Emergency Services - March 25, 1983 2.
Letters to Chester County Cepartment of Emergency 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 l
Task Force of the Owen J.
Rccerts Schocl District and particicated in all'discussiens of rescurces.
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Letter frcm Cepartment of Emergency Services informing cur Task Force that additicnal resources have not been identified - May 25, 1984 F.
Ccnclusions of Fact 1.
As a
result of thorcugh investigation and study of resources, the unmet rescurce needs of the Owen J. Rccerts School District are real and valid.
2.
None of cur unmet resource needs have, as of this date, been identified and documented for us by the Chester County Cepartment of Emergency Services.
3.
Our emergency planning cannot move forward until all identified rescurce needs are provided by the Chester Ccunty
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Department of Emergency Services.
Any statements regarding the 1ccaticn of these additional rescurces must be tharcughly documented in detail including letters of agreement with transportaticn providers, schcol bus drivers, supervisory perscnnel, traffic coordinators, host school arrangements, and all other needs established as real and valid by the Citizens Task Force.
3.
If our responsibility is to provide for the safety and welfare of cur students during a developing radiological emergency, it is also then our obligation to have assurance that all resources of additional equipment and personnel are of sufficient quality to evacuate our students within 7
adequate parameters of time and safety.
II.
Reccmmendaticns of the Citizens Task Force A.
We cannot sucmit the current draft of the Owen J. Roberts School District Radiological Emergency Respcnse Plan for approval.
As it currently exists it is not adequate and will not be effective in the event of a developing radiological emergency.
i 8.
Since the Philadelphia Electric Corporation is scheduled to begin on-line operaticns of the Limerick Nuclear Power Generating Station in April of 1985, it is necessary to take an aggressive approach toward resolving the aforementicned l
emergency plarning issues.
We, there fore, recemmend that communicatiens be initiated with the Federal Emergency Planning t
Agency informing them of cur detailed review of unmet rescurce needs and the lack of any response by the Chester Ccunty Department of Emergency Services.
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We also reccmmend that no Emergency Respense Plan be submitted for Beard approval withcut ccmplete and thorcugh drill and exercise.
If the unmet resource needs are eventually identified, we wculd ask that at least cne planned drill be scheduled during the. school day w'ith movement of all internal and external rescurces to determine if emergency precedures and resources will adequately provide for student safety and welfare.
In addition, we believe that at least ene unscheculed drill be attempted to provide further assurance of the adequacy of the Emergency Plan.
D.
We also reccmmend that the Citizens Task Force for Schcol Emergency Planning Guidelines centinue to functica until all emergency planning issues are resolved and the Emergency Response Plan is determined to be adequate to provide for the protection of the student enrollment of the Owen J.
Roberts School District.
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P EXECUTIVE SLWARY RECGRT RADIOLOGICAL EMERGENCY RESPONSE PLAN Prepared and Presenteo By Dr. Roy C. Claypool, District Superintendent June 6,1984 The statements contained within this Executive Summary Report have not been shared, in total, with anyone prior to their Islease tonight.
They are my statements, and I stand accou1 table and reacy to defend them as Superintendent of Schools.
In the Summer of 1982, the School District received a directive from the Department of Educaticn 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 Scnool 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 Board sought input from citizens and at the next School 8 card Meeting October 18, 1982, the School Board established a Citizens' Task Force.for the purpose of development of school emergency planning guidelines involving potentially hazardous conditions including a nuclear emergency.
At the same meeting the School Board requested financial support from the Philadelphia Electric Company for the additional costs which 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 resolutien passed a motien advertising in the newspapers the first meeting of the task force wculd take place on November 30, 1982.
Representatives from the following agencies met on November 30, 1982.
Department of Education, Harrisburg; PEMA; 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 l
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 acccmplish 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 i
l 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 number of vehicles which would be available during an emergency.
This information was then sent' to the Chester' County Department of Emergency Services indicating unmet'needs.
Executive Summary Report June 6,1984 Page 2 On May 1,1984, I, as Superintencent of Schools, sent a ecmmunication to the Chester County Department of Emergency Services identifying additional unmet needs, and requested a detailed response by June 1st on how these needs would be met.
On May 25, 1984, the Chester County Department of Emergency Services informed the District that the identified needs have not been met at this point in time.
On Monday, June 4th, I met with the Citizens' Task Force for a period of approximately two (2) hours for the purpose of reexamining the additional unmet needs as identified by my office on May 1,1984.
At the conclusion of that meeting all previcusly identified unmet needs were classified as real and valid.
As we have heard this evening, the task force is reccmmending that they continue their efforts.
The nuclear plant is tentatively scheculeo to go en-line within the next ten (10) months.
The agency responsible for meeting our unmet needs [the Chester County Department of Emergency Services) has been unable over the past four (4) months to meet any of our unmet needs.
Can a limited operation such as the Chester County Department of Emergency Services [given even the most dedicated and competent staff] meet our unmet needs within the next ten (10) months??
1 Can they deliver the additional buses? Can they provide the additional human resources?
Will they train these people for the specific functions needed such as ous drivers, traffic ccordinators, ano adult volunteers? Do they have sufficient funds to meet these unmet needs?
Both my analytical mind and my intuition say no to all of the above.
These unmet needs have been public knowledge for at least five (5) ceeks.
To cate not one goverrnental booy, regulatory agency or individual has contacted my office to challenge the validity of these needs.
I can only assume that there is either concurrence on these needs or a deliberate decision has been made to ignore these documented unmet needs.
1 I will not recommend any plan that first, does not meet these documented unmet needs; second, does not guarantee parents access to their children; third, oces not address the resolution of the adced expense to this School District; and fcurth, does not answer the following additional questions.
Wny are school age children not incluced in a selective evacuation along with preschool age children?
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When an order to prepare for an evacuation cccurs, cur switchboard will l
be rendered useless in the first five minutes.
We rely solely on telephones for both internal and external communications.
Can the switchboard handle this overload and can the general telephone utility cover the overload?
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1 6ecutiva Sumary R5 port l
June 6, 1984 Page 3' 4
Serious challenges to sheltering as a safety cption have ceen raised v:ith no satisfactory answers.
If PEMA orders sheltering, how safe, how long before contamination and/or rays penetrate? Parents will surely converge on our schools to gain access to their children.
Is Twin Valley, our alleged host school, far enough away?
Is it not in the ingestion exposure pathway?
What provisions are being planned by municipalities for alternative routing in the event of inclement weather such as ice, snow, etc.
Routes 23 and 100 usually provides us with one or two accidents delaying our bus runs.
Whose time frames are we going to use to deternine the absolute minimum time needed to properly evacuate students and employees?
f Where in this country has a greater effort been made over a nineteen (19) month period to develop an adequate evacuation plan?
As the time draws nearer for the opening of the plant, parents are feeling and. exhibiting increased stress over the health and safety of their i
children.
We will not compromise either the health or safety of our children or employees in order to have an evacuation plan that is not adequate and implementable.
What are.the legal liability exposures of the School District,. the School Board, inoividual School Board members, District. Superintendent, employees, and volunteers? If soditional liability insurance is needed, who will pay for the insurance?
State and federal planners have been quick to identify, in detail, local responsibilities both financial and legal, but no visible effort to meet any l
of our unmet needs.
It is my opinion that we must look beyond Chester County to both the state and federal governments for immediate help in not only meeting our t.nmet needs, but to also demonstrato 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.
Let us not spend these next few months decating how - to rearrange the chairs on the deck of the Titanic.
Instead, join forces with the task force in seeking a resolution to our unmet needs, as well as educating those in a decision making role the serious deficiencies in the existing plannirs structure, and the attitude-- that given an emergency. of this magnitude citizens will rise.up and solve the problem.
n.wis M N94 Signature Cate i
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Nt.p Owen T. Roberts School District Co Admimstration Building d
R. D.1, Pottstown, Pennsylvania 19464 Q
Telep~ one (215) 469-6261 a
May 1, 1984 Mr. John McNamara Chester County Department of Emergency Services 14 E. Biddle Street W:st Cbester, PA 19380 RE:
Need for Detailed Response to Citizens Task Force Letter Oated March 13, 1984 Request to Respond to Additional Unmet Needs As Perceived By District Superintendent As Contained Within This Occument 0;ar 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 Emergency ~
planning for the Owen J. Roberts School District.
Last Friday, April 27, I spent three (3) hcurs with Mr. Clark reviewing in detail the status of Oraft 7.
During this sessica Mr. Clark informed me that he had telephoned your office to see if any respense was forthccming in reference to his letter of March 13, 1984.
Since my meeting with Mr. Clark I have spent an additional six (6) to l
eight (8) hours thoroughly reviewing Oraft 7, and Mr. Clark's ccmmunicatien to you dated March 13, 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, in writing, to both the Citizens' Task Force letter of March lph, as well as my additional cencerns identified herein.
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 fiscal year I am requesting that the Board of School Directors meet with the Task Force for a thorough and complete update of the preposed Emergency l
Response Plan.
Therefore, it is imperative that we receive frcm you a written ccmmunicaticn no later than June 1, 1984 Before presenting my concerns, I realize the difficult function ycu must perform, but I am also aware of Murphy's Law in an emergency situation.
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.. F' May 1, 1984 Mr. Jchn McNamara, Chester County Cecartment of Emergen'cy Services Page 2 i
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 1
conditions.
That is to say, after thorough review and investigation I believe their needs are in scme. cases understated.
In order to expedite your communication, I will restrict my identification of unmet needs to vehicles r:; quired for evacuation, bus drivers needed for evacuaticn, teachers and employees needed for evacuation, trsffic coordinators, and last, but not icast, the fact that Owen J. Rcberts 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 ccnditiens, no valid evacuation plan [in my opinien] cculd possibly be l
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 cutside rescurces to conduct an evacuation under the most optimum conditiens.
SEVENTY-TWO (72) PASSENGER VEHICLES NEECEO FCR EVACUATION ALL PERSONNEL AND STUCENTS Total Vehicles Needed, Fifty-Five (55) Seventy-Two (72) Passenger 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 reascn.
A number j
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 cperating because the driver either cannot get back to the bus or has l
elected to take care of higher family needs.
Therefore, I conclude the unmet vehicle needs amount to twenty-five (25) buses.
Please identify where these twenty-five (25) buses will be coming from, as well as, will the twenty-five (25) drivers bringirq the buses 1
into our District drivu these buses during evacuation??
BUS ORIVERS The initial survey indicated that twent.y-five (25) of our District drivers will drive a schcol bus durirg a radiological emergency.
- However, many of these drivers did preface their statement stating that their families would ccme 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 l
would be a maximum of eighteen (18).
Therefore, I ccnclude that cur unmet driver needs to be thirty-seven_
l (37) drivers.
If you are successful in acquiring twenty-five (25) t:uses and twenty-five (25) drivers from cutside our ' area, there is still a need for twelve (12) additional drivers.
Please identify where these drivers would be ccming from.
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Mry 1, 1984 Mr. Jchn McNamara, Chester County Department 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 hcnest, in their responses to this survey. Human nature is to first of all secure unmet family needs.
Sixty-six percent (66%) of our professicnal staff responded to this survey.
This sixty-six percent (66%) response equates to cne hundred thirty-seven (137) individuals.
Please be advised, however, that only sixty percent (60%) of those respcnding signed the document.
Therefor', a e
more realistic teacher need will be based en the number who signed the 1
survey.
A summary of the survey. is as follows:
QUESTION: Will you be willing to acccmpany 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
{i students?
The number who signed the document equates 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.
l From the data available, I would conclude that, again giving Murphy's
- Law, human reacticn to emergency situations and family needs, that internal staff rescurces acccmpanying students and attending to students at host centers will-be more in the neighborhcod of sixty (60) to sixty-five (65) teachers.
Our total teaching staff to date is two hundred eight (208) teachers i
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) volunteers and where will they be ccming from?
I have not attempted to address the issue of sheltering for I believe we need to have the resources determined -for evacuaticn and if they be resolved, then sheltering would be resolved.
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May 1, 1984 Mr. Ochn McNamara, Chester Ccunty Department of Emergency Services Page 4 TRAF7IC C00RDINATORS As the time draws near for the opening of the plant, it is quite clear that our citizens have every intentien of coming directly to cur facilities in order to pick up their children in the event of an emergency.
In no way will the School Administration prevent parents from picking up their children.
Therefore traffic controllers will be an absolute must at each of our educaticnal centers.
I predict the need for the following traffic controllers, in addition to schcol 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 Controllers EAST COVENTRY ELEMENTARY CENTER 3 Traffic Centrollers NORTH COVENTRY ELEMENTARY CENTER 4 Traffic Controllers CENTRAL C;MPUS a minimum of 6 Traffic Controllers TOTAL H Traffic Centrollers In additien to traffic centrollers, I raise a serious questien as to j
the traffic controlling activities that will take place at the intersection of Routes 23 and 100, Route 100 and Cadmus Road, and Route 23 and the exit frcm Owen J. Roberts.
My personal interacticn with a number of parents indicates that the first response will be to converge en 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 of 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 j
your convenience, to discuss in detail our concerns as well as the centent of this communication.
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Respectfully,
%GJL Roy C. Claypool,
. D.
District Superintendent F
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