ML20235T371

Corrected Prefiled Testimony of J Pennington,C Leavitt, Nudd,A Shepard,B Peeke,J Galloway,Ma Sargent,E Berry, H Moyer,D Dunfey,M Mathews,Jb Millette & B Knapp Re Town of Hampton Revised Contentions IV & Vi....*

ML20235T371
Person / Time
Site:	Seabrook
Issue date:	10/05/1987
From:	Berry E, Dunfey D, Galloway J, Knapp B, Leavitt C, Mathews M, Millette J, Moyer H, Nudd S, Peeke B, Pennington J, Sargent M, Alice Shepard HAMPTON, NH
To:
Shared Package
ML20235T353	List: ML20235T350 ML20235T371 ML20235T384 ML20235T404 ML20235T413 ML20235T439 ML20235T450
References
OL, NUDOCS 8710130063
Download: ML20235T371 (11)

Text

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UNITED STATES OF AMERICA NUCLEnR REGULATORY COMMISSION I

before the i I

ATOMIC SAFETY AND LICENSING BOARD i I

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3 1 In the Matter of ) October 5, 1987

)

PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al ) 50-444-OL  !

) Off-site' Emergency {

(Seabrook Station, Units 1 and 2) ) Planning Issues  !

)

)

CORRECTED l

l PREFILED TESTIMONY OF JOHN PENNINGTON, CONSTANCE LEAVITT, SHEILA NUDD, ANDREA SHEPARD, BEVERLY PEEKE, JANICE GALLOWAY, MARY ALICE SARGENT, ELLEN BERRY, HERB MOYER, DIANNE DUNFEY, MARIE MATHEWS, JOANNE B. MILLETTE, AND BARBARA KNAPP  !

REGARDING TOWN OF HAMPTON REVISED CP'dTENTIONS IV AND VI AND SEACOAST ANTI-POLLUTION LEAGUE COJ.TENTIONS 8, 8A, AND 15 Q: Please state your names and positions.

A: I am John Pennington, a teacher at the Portsmouth Senior  ;

High School, Portsmouth, New Hampshire, and have been so employed for  !

15 years. I am the current President of the Association of Portsmouth Teachers with a membership of approximately 350 teachers in the Portsmouth School System.

I am Andrea Shepard, a teacher at the Hampton Academy Junior l High, Hampton, New Hampshire and have been so employed for approxi-mately 5 years.

I am Constance Leavitt, a teacher at the Center School, 8710130063 871005 PDR y

ADDCK O g3

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26 MAP.,EWOOD AVENJE & O BOX 360 POR*5MOuiM. N H Dteos

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Hampton, New Hampshire, and have been so employed for approximately 3 years.  ;

i I am Sheila Nudd, a teacher at th'e Hampton Academy Junior -l High, Hampton, New Hampshire, and have been so employed for 17 years.  !

I am Beverly Peeke, a teacher at-.the Barnard School, South Hampton, New Hampshire, and ht/e been so employed for 10 years.

I am Janice Galloway, a teacher at the Lincoln-Akerman I School, Hampton Falls, New Hampshire, and have been so employed for 17 )j years.

I am Mary Alice Sargent, a teacher at the North Hampton Elementary School, North Hampton, New Hampshire, and have been so employed for 20 years.

I am Ellen Berry, a teacher at the Marston School, Hampton, New Hampshire, and have been so employed for 9 years.

I am Herb Moyer, a teacher at the Winnacunnet High School, Hampton, New tiampshire, and have been so employed for '17 years.

I am Dlanne Dunfey, a teacher at the Seabrook Junior High School, Seabrook, hew Hampshire, and have been so employed for 2 I years.

l I am Marie Mathews, a teacher at the Center School, Hampton, ,

New Hampshire, and have been so employed for 10 years.

l I am Joanne B. Millette, a teacher at the Winnacunnet High School, Hampton, New Hampshire, and have been so employed for 9 l years.

I am Barbara Knapp, a teacher at the Barnard School, South Hampton, New Hampshire, and have been so employed for 10 years.

Each of us teach at a school located within the Seabrook 10 2

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mile emergency planning zone (EPZ), and each of us is testifying with respect to his or her own school.

Q: What is the purpose of this testimony?

A: This testimony addresses Town of Hampton Revised Contentions IV and VI, and Seacoast Anti-Pollution League Contentions 8, 8A and 15, and specifically whether early dismissal, sheltering, or evacuation of the schools in the Seabrook EPZ could be implemented adequately in the event of a radiological emergency at Seabrook Station.

0: Under the New Hampshire Radiological Emergency Response Plan (NHRERP), in the event of a radiological emergency the schools in the EPZ may be advised to implement their early dismissal plans, to shel-ter, or to evacuate. (See e.g., NHRERP Volume 18A, Special Facilities Emergency Response Plan, pages Fl.-l et seq.) Do you believe that any of these protective actions could be implemented in a safe and adequate manner in the event of an accident at the Seabrook Plant?

A: No.

0: Why do you believe that early dismissals could not be ade-quately implemented?

A: In our opinion, most of the teachers would leave their schools in order to care for their own children, elderly relations, er i other dependents or members of their families. Without the active participation of at least most teachers, early dismissals could not be implemented adequately.

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In order to understand our point, you must understand that  ;

even under common conditions, such as a snowstorm, an early dismissal.

cannot be implemented quickly. Many students are sent home by car or bus, and they must wait at the school for the arrival of those vehicles.

SHAINES f. McEACFfM PROFESSIONAL Assoc.ATION 25 MAPLf WOOD AVCNUE P O BOX B60 PORT $ACMM N M 098N L____________

i We are certain that it would take longer to implement a dismissal necessitated by an accident at Seabrook, because if an accident occurred at Seabrook, many of the teachers would leave the schools in order to care for their own children, elderly or other dependents and family members.

0: Why would the departure of teachers slow the dismissal process?

A: Under normal conditions, in an early' dismissal, virtually all students, especially younger ones, are sent home by bus and private cars. There is always a delay between the decision to dismiss classes and the arrival of the buses and cars. Normally, these students-remain under the supervision of their teachers during this period.

Order is maintained, the children do not become frightened, and parents and bus drivers can easily pick up their children. However, if many teachers left, the children would be left unsupervised, and chaotic conditions would occur. Some children who were supposed to wait might i leave for home on their own. Their parents could easily lose track of I s

them, if the parents were driving to the school. In addition, because many children would be unsupervised, confusion would ensue, and that confusion would make it impossible for buses and parents to locate and pick up children in a timely manner.

Because of the concerns of the sorts we have.just described, we are convinced that if early dismissals were attempted in the event  ;

of an accident at the Seabrook Plant, chaotic and confused conditions

-l would result. Under those conditions, the students would be exposed to unacceptable risks.

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Q: Do you have other concerns about the NHRERP that relies on j i

early dismissals in the event of an accident at the Seabrook Plant?

A: Yes. Handicapped students and very young children especially i

need adult attention and supervision. For example, the Portsmouth Senior High School has several handicapped students or those with special needs. If large numbers of teachers left to care for their own children, these children with special needs would be in dire j i straits. A situation in which very young or severely handicapped children were left without adult attention cannot reasonably be called safe or satisfactory.

Q: Why do you believe that many teachers would leave to care for their children and families if an accident occurred at Seabrook? j A: First, as other witnesses will testify in this proceeding,

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it appears that many school bus drivers would not report to work during an emergency at the Seabrook Plant, but instead would protect their own families. Teachers who are parents have the same concerns, and teachers who are parents would probably leave school to care for their children. In addition, we know the teachers with whom we work

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d and we know their attitudes. In our opinion, most of them intend to 1 care for their children if an accident occurs at Seabrook. We base this in part on discussions we have had with our fellow teachers and i

statements made at meetings. j We also base our opinion on informal surveys of teachers that have been conducted in a number of schools in the EPZ. (See, survey attached to TOWN OF HAMPTON MOTION FOR

SUMMARY

DISPOSITION dated March 25, 1987, and incorporated herein by reference.) This 5

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.1 survey provided:

We are the teachers who work at schools-in-communities within the!10 mile EPZ of Seabrook ,3 Station. 'We DO NOT accept the conflicting duty which:the Emergency Response (Evacuation) '

Plan assigns us. q i

I We believe'it is_ inappropriate to expect us ,

to provide emergency support for.our. students during a nuclear accident which would simul-taneously place our families in-danger. .

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-In response to this survey, 597 teachers signed this_ petition.  ;]

Additionally, we informally surveyed our colleagues at our respective-schools to determine how many-teachers would be.willing to' remain at school', supervise.their students, and~otherwise carry out_their' duties-assigned.under the NHRERP. The results of these; informal surveys may

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be summarized as-follows:

School / Teacher (s): Winnacunnet High School, Herb Moyer,:Joanne B. Millette .

Teachers Teachers hachers  % of hachers l Employed in School Surveyed Willing to Willing to (Approx.) (Approx.) Implement NHRERP Lp lement NHRERP {

! , 95 90 3 3%

l School /* Teacher (s) : Parston School, Ellen Berry Teachers h achers hachers  % of h achers Employed in School Surveyed Willing to Willing to (Approx. ) (Accrcx. ) Lplement K3REPP Lglement Nhx:-P 25 15 1 7%

School / Teacher (s) : North Ha::pton Elementary School, Pary Alice Sargent hachers R achers- 'hachers  % of hachers Employed in School Surveyed Willing.to Willing to (Approx. ) (Approx. ) Lylement NHRERP Lplement IMRERP 30 30 3 10% ! ]

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1 6 ,

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' 25 MAPt.f 000 AVENUC P O Box 350 PORTSMouTM N H ossot .

L_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ . _ _ _ _ _. _ _ _ _ ________._______E.

i School / Teacher (s): Hanpton Academy Junior High, Andrea Shepard, Sheila Ibdd Teachers Teachers hachers  % of h achers Employed in School Surveyed Willing to Willing to (Approx.) (Approx.) Implenent retr <ERP Implenent NHRERP 45 45 4 8%-

School / Teacher (s): Barnard School, Beverly Peeke, Barbara Knapp Teachers Teachers 'Itachers  % of Teachers Employed in School Surveyed Willing to Willing to (Approx. ) (Accrox.) Implement !ERERP Implenent NMRERP 6 6 1 17%

School / Teacher (s) : Lincoln-Akernan School, Janice Galloway Teachers 'Ibachers 'Ibachers  % of 'lbachers Employed in School Surveyed Willing to Willing to I (Approx. ) (Approx.) Implement NHPZRP Implement NHRERP l

20 20 1 5%

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t School /Itacher(s) : Center School, Marie Mathews, Constance leavitt j 1

% achers Teachers hachers  % of hachers Drployed in School Surveyed Willing to Willing to (Acprox. ) (Approx.) Implement NHREPP Implement NHRERP 22 20 2 10% 1 l

l School / Teacher (s) : Seabrook Junior High School, Dianne Dunfey W achers 'Itachers Teachers  % of Teachers Employed in School Surveyed Willing to Willing to (Accrox. ) (Approx. ) Implement NHPIPP Implenent NHRERP i l

17 17 0 0 Association of Portsnouth Schools, John Pennington, President Teachers 'Ibachers Teachers 'Itachers Drployed Surveyed Willing to Willing to Schojo (Arcrox. ) (Aporox.) Implement NHREPP Implement NHREPP l Portsnouth High 135 135 1 .7%

Portstrouth Jr. High 51 51 2 4%

Dondero 30 30 1 3%

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Teachers hachers Teachers hachers Employed Surveyed Willing to Willing to School (Approx. ) (Approx.) Implement NHRERP Implement 1&IRERP Sherburne 7 7 0 0%

Little Harbour 38 38 2- 5%

Itu Franklin 23 23 0 0%

Wentworth 20 20 1 5%

'ICIAL 304 304 7 2%

These informal surveys reinforce our opinion of the in-tentions of teachers in the event of a radiological emergency at Seabrook. The Seabrook plant is a common topic of conversation among teachers, many have thought a great dea 3 about their conflicting roles l and responsibilities, and most have formed firm opinions about both )

the plant and the related emergency planning, as reflected in the above surveys. In our opinion, most of them have decided that if an early dismissal was ordered because of an accident at Seabrook, they would leave. If they left, the early dismissal would not work, for 1

reasons already given, i These results further support our opinion that most teachers in our schools have already decided what they.would do if an accident happened at Seabrook. The evacuation of children in the EPZ will require teachers. Without teacher supervision, locating children, providing for the safety of children boarding and leaving buses, and remaining at relocation centers without their parents, cannot be reasonably assured. Children cannot be expected to look after them-l selves, especially in a frightening situation. Because most teachers l

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would leave to. care for their own children, there would not be enough teachers to provide the needed care. Children would probably be hurt, lost, and could not be evacuated safely. The NHRERP will not work. )

0: In your opinion, will sheltering the children at school, or I

evacuating them, provide reasonable protection'to these students?

A: No. )

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0: Why?

A: These protective responses will not work to provide reasonable ]

protection to the students for the same reasons that early dismissal will not work. Without sufficient numbers of teachers, no protective response is available to provide reasonable protection to the students.

As we understand it, there is no provision in the NHRERP to compensate '

for lack of teacher participation. Even assuming civil defense or other individuals are assigned to supplement for a lack of teachers, we do not believe these individuals can reach the schools in a suf-ficiently timely manner to ensure a reasonable safe and effective protective response for the students.

Q: Have you received training in impleraenting the NHRERP for j l

your schools? i I

A: No. The State of New Hampshire has never solicited our d opinions or provided us with reasonable opportunity to comment or voice our concerns on the NHRERP. To our knowledge, none of the ,

i teachers in the EPZ have been formally trained in implementing the  !

plan for the schools. We are not civil defense workers, and we have I

no legal obligation to carry out the NHRERP. Any participation by any j EPZ teacher will be purely on a volunteer basis. Additionally, we do- j l

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not view our duties assigned under the NHRERP as part of our usual duties or responsibilities as EPZ teachers. For example, it is cus-tomary for teachers to remain with, and supervise, children during a fire. The unique danger of Seabrook is that e. radiological emergency may simultaneously place not only our students in danger, but will also endanger our own children and families located elsewhere wi thin the EPZ. To our knowledge, there is no provision in the NHRERP to protect the families of teachers during an emergency. Accordingly, no one else will be available, except the individual teachers, to care for their own families.

Q: In your opinion, how many teachers would be required to reasonably and promptly evacuate students from your schools?

A: In our opinion, a substantial majority of teachers within each school would be required to promptly and reasonably locate and supervise the students, and ensure their boarding and supervise their transportation to relocation centers. For example, if even a single teacher failed to remain with her/his class, those unsupervised students could attempt to leave their schools on their own, or otherwise become unaccounted for. Additionally, the students may likely become fright-ened, and disrupt other students. We would anticipate these ccnditions to magnify during the time necessary for evacuation buses to arrive.

Under these conditions, at a minimum, a substantial majority of EPZ teachers would be required to remain with their students. For reasons I

previously stated, we do not believe this will occur.

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i' 0: Does this conclude your testimony? I A: Yes.

Respectfully submitted, l

TOWN OF HAMPTON 1 By Its Attorneys SHAINES & EACHERN Profess' 1 Asso 'ation By Paul McEachern

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\ N J Dated: October 4 1987 y \.

t ') e L Matthew T. Br6M i j

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