ML20238F210
| ML20238F210 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/11/1987 |
| From: | Brock M, Mceachern P HAMPTON, NH, SHAINES & MCEACHERN |
| To: | |
| Shared Package | |
| ML20238F189 | List: |
| References | |
| OL, NUDOCS 8709160026 | |
| Download: ML20238F210 (14) | |
Text
-
l
( -
g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION h
before the ATOMIC SAFETY AND LICENSING BOARD y
)
K In the Matter of
)
September 11, 1987
)
PUBLIC SERVICE COMPANY OF
)
Docket Nos. 50-443-OL NEW HAMPSHIRE, et al
)
50-444-OL
)
Off-site Emergency (tsabrhokStation, Units 1 and 2)
)
Planning Issues
)
)
PREFILED TESTIMONY OF JOHN PENNINGTON, MNSTANCE LEAVITT, SHEILA NUDD, ANDREA ShtPARD, 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 CONTENTIONS IV AND VI AND SEACCAST ANTI-POLLUTION LEAGUE CONTENTIONS 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 High, Hampton, New Hampshire and have been so employed for approxi-mately 5 years.
8709160026 B70911 PDR ADOCK 05000443 T
PDR SHAINES fn McEACHERN PROFESSIONAL ASSOCIATION 25 MAPLEWOOD AVENUE. P O BOM 360 PONTSMOUTM. N H OBEIOS
~
l 1
I I am Constance Leavitt, a teacher at the Center School, Hampton,.New Hampshire, and have been so employed for approximately 3 years.
i I am Sheila Nudd, a teacher at the Hampton Academy Junior
(
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 have been so employed for 10 years.
I am Janice Galloway, a teacher at the Lincoln-Akerman School, Hampton Falls, New Hampshire, and have beer.so employed for 17 years.
I am Mary Alice Sargent, a teacher at the North Hampton Elementary School, North Hampton, New Hampnhire, and have been so employed for 20 years.
I am Ellen Berry, a teacher at t'ne 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, Neu Hampshire, and have been so employed for 17 years.
I an Dianne Dunfey, a teacher at the Seabrook Junior High School, Seabrook, New Hampshire, and have been so employed for 2 years.
I am Marie Mathews, a teacher at the Center School, Hampton, New Hampshire, and have been so employed for 10 years.
I am Joanne B. Millette, a teacher at the Winnacunnet High School, Hampton, New Hampshire, and have been so employed for 10 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
SHAINES Ek MiACHERN PROFESSKWAL AS$OCIATKW ES MApLEWOOD AVENUE. P O. BOM 360. Pt WITSMOUTH, N.H OM101
. - _. _ _. :. \\. _.
_______..______-___-._._-_-_____-_---w
4 mile emergency planning ~ zone (EPZ), and each of us is testifying with respect to his or her own school.
9 Q:
What is the purpose of this testimony?
/-
A:
This testimony addresses Town of Hampton Revised Contentions y
j
'" I,,
IV and VI, and Seacoast Anti-Pollution League Contentions 8, 8A and 15, and specifically whether early dismissal, sheltering, or evacuation of D
the schools in the Seabrook EPZ could be implemented adequately in the event of a radiological emergency at Seabrook Station.
Q:
Under the New Hampshire Radiological Emergency Response Plan (NHRERP), in the event of a radiological emergency the schools in the j
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.
Q:
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, or other depende" 3 or members of their families.
Without the active participation of at least most teachers, early dismissals could not be implemented adequately.
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 1
i l
l SHAINES & McEACHERN. PROFESSIONAL ASSOCATION 25 MAPLEWOOO AVENUE - P O EnOX 360. PORTSMOUTH N.H. 03801
_j
_ m_
~4 bus, and'they must wait at the school for the arrivel of those vehicles.
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.
Q:
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 There is always a delay between the decision to dismiss classes cars.
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 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 would result.
Under those conditions, the students would be expoced l
to unacceptable risks.
4 SHAINES & McEACHERN PROFEES40NAL ASSOOATK)N 25 MAPLEWOOD AVENUE D 0 BOX MO - PORTSMOUTH. N M 03801
____________._________w
l 1
L Q:
Do you have other concerns about the NHRERP that relies on
-early dismissals in the event of an accident at the Seabrook Plant?
A:
Yes.
Handicapped students and very young children especially 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 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?
A:
First, as other witnesses will testify in this proceeding, 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 familias.
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 and we know their attitudes.
In our opinion, most of them intend to care for their children if an acc[ dent occurs at Seabrook.
We base this in part on discussions we have had with our fellow teachers and statements made at meetings.
Wealsobaseouropinibnoninformalsurveysofteachers that have been conducted in a number of school districts in the EPZ.
(See, survey attached to TOWN OF HAMPTON MOTION FOR
SUMMARY
DISPOSITION dated March 25, 1987, and incorporated herein by reference.)
This l
l l
5 l
SHAINES & McEACHERN e PROFESSIONAL ASSOCATON 25 MAPLEWOOD AVENUE p O BOX MO PORTSMOUTM, N.H 03801
___-_______A
survey provided:
1 We are the teachers who work at schools in j
communities within the 10 mile EPZ of Seabrook i
Station.
We-DO NOT accept the conflicting j
duty which the Emergency Response (Evacuation)
]
Plan assigne us, i
We believe it is inappropriate to expect us j
to provide emergency support for our students during a nuclear accident which would simul-taneously place our families in danger.
.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 be summarized as follows:
School / Teacher (s) : Winnacunnet High School, Herb ltyer, Joanne B. Millette Teachers Teachers Teachers
% of Teachers Employed in School Surveyed Willing to Willing to (Approx. )
(Approx.)
Implement NHRERP
_ Implement NHRERP 95 90 3
3%
1 School / Teacher (s): Marston School, Ellen Berry Teachers Teachers Teachers
% of Teachers Employed in School Surveyed Willing to Willing to (Approx. )
(Approx.)
Implemnt NHRERP Implement NHRERP 25 15 0
0%
/
School /*Deacher(s) : North Hampton Elementary School, Mary Alice Sargent Teachers Teachers Teachers
% of Teachers Duployed in School Surveyed Willing to Willing to (Approx. )
(Approx. )
Implemnt NHRERP Implement NHRERP 30 30 3
10%
6 SH AINES din McEACHERN PROFESSIONAL AssOOATION 25 MAPLEWOOD AVENUE P O. BOX Mio - PORTSMOUTH, N.H. 03801
School / Teacher (s) :: Hanpton Academy. Junior High,. Andrea Shepard, Sheila Nudd Teachers Teachers Teachers
% of Teachers Employed in School-Surveyed.
Willing to' Willing to.
(Approx. )
(Approx.)
Implement NHRERP Implement NHRERP
'45
'45 4-8%
l School / Teacher (s) : Barnard School, Beverly Peeke, Barbara Knapp' Teachers Teachers Teachers
% of Teachers-anployed in School Surveyed Willing to Willing to (Approx.)
(Approx.)
Implement NHRERP
. Implement NHRERP 6
6 0
0%
. School / Teacher (s): Lincoln-Akentan School, Janice Galloway
' Teachers.
Teachers Teachers
% of Teachers anployed in School Surveyed Willing to Willing to
. (Approx. ) '
(Approx.)
Implement NHRERP Inplement NHRERP L
20 20 1
5%
School / reacher (s)i Center School, Marie Mathews, Constance Imavitt Teachers hachers Teachers
~ % of Teachers
' Employed in School Surveyed Willing to Willing to (Approx. )
(Approx.)
Implement NHRERP Inplement NHRERP 22-20
-2 10%
School / reacher (s) : Seabrook Junior High School, Dianne Dunfey Teachers Teachers Teachers
% of hachers Employed in School Surveyed Willing to Willing to (Approx. )
(Approx. )
Inplement NHRERP Implement NHRERP 17 17 0
0%
Association of Portsmouth Schools, John Pennington, President Teachers Ta/.hers Teachers
- Rachers anployed Surveyed Willing to Willing to l
School (Approx. )
(Approx.)
Implement NHRERP Inplement NHRERP Portsnouth High 135 135 1
.7%
j Portsnouth Jr. High 51 51 2
4%
Dondero 30 30 1
31 7
SHAlNE5 & McEACHERN PROFESSIONAL ASSOCIATION 25 MAPLEWOOO AVENUE P O BOX 360. PORTSMOUTH. N.H 03801
,L Teachers Teachers Teachers Teachers
-Employed.
Surveyed Willing to-Willing to School-(Approx.),
'(Approx.)
Implement NHRERP Implement NHRERP Sherburne' 7
7 0
0%
~Little Harbour 38 38 2
5%
New Franklin 23
'23-0 0%
Wentworth.
20 20 1
5%
'IUIAL 304 304 7
2%
These. informal surveys reinforce our opinion.of the in..
tentions of teachers l'n the event of a radiological. emergency at Seabrook'.
The Seabrook plant is a common. topic of conversation among teachers, many have thought-a great deal about their conflicting roles 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 decidud that if an-early dismissal were ordered because of an accident at Seabrook, they would leave.-
If'they left, the early dismissal would not work, for reasons already given.
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-selves, especially in a frightening situation.
Because most teachers would leave to care for their own children, there would not be enough 8
SHAINES (m McEACHERN PROFESSIONAL ASSOCIATION 25 MAPLEWOOO AVENUE P O BOX 360 PORTSMOUTH, N H 03801 i
teachers to provide the needed care.
Children would probably be hurt,
' lost, and could not be evacuated safely.
The NHRERP will not work.
Q:
In your' opinion, will sheltering the children at school, or evacuating them, provide reasonable protection to these students?
A:
No.
Q:
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 effectivo protective response for the students.
Q:
Have you received training in implementing the NHRERP for your schools?
A:
No.
The State of New Hampshire has never solicited our opinions or provided us with reasonable opportunity to comment or voice our concerns on the NHRERP, To our knowledge, nc7e of the teachers in the EPZ have been formally trained in implementing the plan for the schools.
We are not civil defense workers, and we have no legal obligation to carry out the NHRERP.
Any participation by any EPZ teacher will be purely on-a volunteer basis.
Additionally, we do not view our duties assigned under the NHRERP as part of our usual 9
SHAINES En McEACHERN PROFESSIONAL AS$OCATION 25 MAPLEWOOD AVENVE P O. BOX 360 - PORT 5 MOUTH. N H 03801
i l
re,
_dut es or responsibilities as EPZ teachers..For example, it'is cus-i
~
tomary for' teachers to remain.with, and supervise, children during a F
fire.
The unique danger of Seabrook is that a radiological emergency may simultaneously place not only our students in danger,.but will.
also endanger'our own children and families located elsewhere within 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 conditions
.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 previously stated, we do not believe this will occur.
10 SHAINES En McEACHERN. PROFESSIONAL ASSOOATON 25 MAPLEWOOD AVENUE - P O Box 360 - PORTSMOUTH. N N 011801
Q:
Does this conclude your testimony?
A:
Yes.
Respectfully submitted, TOWN OF HAMPTON
{
By Its Attorneys i
SHAINES & McEACHERN Profession Association By Paul McEachern
)
Dated:
September 1987 B
Matthew T.
Brock
-i l
I l
l 11 SHAlNES (a McEACHERN PROF 1ESSONAL ASSuCATION IS M APLEWOOD AVENCE # O. BOX 360 PORT 5 Mot./TH. N H. 03801
\\
CERTIFICATE OF SERVICE 1, Matthew T.
Brock, one of the attorneys for the Town of Hampton herein, hereby certify that on September 11, 1987, I made service of the following dccument PREFILED TESTIMONY OF JOHN PENNINGTON, CONSTANCE LEAVITT, SHEIL's 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 HAMPTOE REVISED CONTENTIONS IV AND VI AND SEACOAST ANTI-POLLUTION LEAGUE CON-TENTIONS 8, 8A AND 15 by depositing copies thereof in the United States Mail first class postage prepaid for delivery (or, where indi-cated, by Express Mail, prepaid) addressed to:
- Helen Hoyt, Esq., Chairman
- Judge Gustave A.
Linenberger, Jr.
Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel East West Towers Building U.S. Nuclear Regulatory Comm.
4350 East West Highway East West Towers Building Bethesda, MD 20814 4350 East West Highway Bethesda, MD 20814
- Dr.
Jerry Harbour Atomic Safety and Licensing Board
- Atomic Safety and Licensing Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.
East West Towr s Building Washington, DC 20555 4350 East West Highway Bethesda, MD 20814
- Atomic Safety and Licensing Appeal Board Panel
- Docketing and Service U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Mrs. Anne E.
Goodman William S.
Lord, Selectman Board of Selectmen Town Hall 13-15 Newmarket Road Friend Street Durham, NH 03842 Amesbury, MA 01913 Jane Doughty Rep. Roberta C. Pevear Seacoast Anti-Pollution League Drinkwater Road 5 Market Street Hampton Falls, NH 03844 Portsmouth, NH 03801
- Philip Ahrens, Esq.
- Thomas G.
Dignan, Esq.
Assistant Attorney General George H.
Lewald, Esq.
Office of the Attorney General Kathryn A.
Selleck, Esq.
State House Ropes & Gray Station 6 225 Franklin Street Augusta, ME 04333 Boston, MA 02110 Robert A.
Backus, Esq.
- Sherwin E.
Turk, Esq.
Backus, Meyer & Solomon Office of the Exec. Legal Dir.
111 Lowell Street U.S. Nuclear Regulatory Comm.
Manchester, NH 03105 Tenth Floor 7735 Old Georgetown Road Bethesda, MD 20814 SHAINES & McEACHERN PROFESSIONAL A$50CIATON 25 MAPLEWOOD AVENUE - P O BOX 360 PORTSMOUTH. N H 03001
Of-'
a Mr. Angie Machiros, Chairman H.
Joseph Flynn, Esq..
Board of Selectmen Office of General Counsel
.Newbury,'MA.01950 Federal-Emergency Mgmt'. Agency 500.C Street, S.W.
t
- George: Dana Bisbee, Esq.
Washington, DC 20472
. Stephen'E. Merrill,.Esq.
Office of the Attorney General
- Carol S.
Sneider, Esq.
State' House. Annex Donald S. Bronstein, Esq.
Concord, NH
.03301 Allan R.
Fierce, Esq.
Dept. of the Attorney General One Ashburton Place
<StanleyJW. Knowles' 19th Floor Board of' Selectmen Boston, MA 02108 P.O.. Box 710 North Hampton, NH 03862 J.
P.
Nadeau, Selectman Richard E.
Sullivan l
Selectmen's Office Mayor 10 Central Road.
City Hall Rye,. NH 03870 Newburyport, MA.
01950 Alfred V..Sargent,-Chairman Senator Gordon J..Humphrey.
Board of. Selectmen U.S.' Senate
' Town of Salisbury Washington,.DC 20510' Salisbury, MA 01950 (Attn:
Tom Burack)
' Michael'Santosuosso, Chairman
. Allen Lampert Board-of Selectmen-Civil Defense Director-
-Jewell St., RFD 2 Town of Brentwood So. Hampton, NH-03827 Exeter, NH 03833
-Richard A.
Hampe, Esq.
Gary W.
Holmes, Esq.
Hampe and McNicholas Holmes and Ellis 35 Pleasant Street-47 Winnacunnet Road
-Concord, NH 03301 Hampton, NH 03842 William Armstrong-Calvin A. Canney, City Manager Civil Defense' Director City Hall 10 Front Street 126 Daniel Street.
Exeter, NH 03833 Portsmouth, NH 03801
- Edward A. Thomas Sandra Gavutis Federal Emergency Mgmt. Agency Town of Kensington 442 J.W. McCormack (POCH)
RFD 1, Box 1154 Boston, MA 02109 East Kensington, NH 03827 Charles P.
Graham, Esq.
- Dianc Curran, Esq.
McKay, Murphy & Graham Andrea C. Ferster, Esq.
100 Main Street Harmon & Weiss Amesbury, MA 01913 Suite 430 2001 S Street, N.W.
Washington, DC 20009-1125 l
2
$HAINES En McEACHCRN. PROFES$CNAL ASSOOATON l
25 MA%EWOOD AVENUE
- R O. BOX 360. p0RTSMOUTH. N H 05801
_i__a_._______._
7=--
7_
"^
" p :-
.i.
l Robert ~Carrigg, Chairman
. Senator Gordon'.J. Humphrey.
One Eagle Square,? Suite:507L
' Board.of Selectmen, Concord, NH 03301
- Town.' Office-
- ( Attn :- Herb Boynton)
. Atlantic Avenue.
4-iNorth Hampton, NH 03862 Mr. Thomas H. Powers,-III Mr. Peter Matthews
' Town Manager Mayor--
cTown of.Exeter.
City Hall
~10 FrontiStreet Newburyport,-MA 01950-
.Exeter, NH-103833-
.Brentwood; Board of' Selectmen Judith H. Mizner, Esq.
,RFD' Dalton Road Silvergate, Gertner, Baker, Brentwood, NH 03833-JFine, Good &.Mizner 88 Broad Street Boston, MA 02110-R Matthew T.
Brock N.
j i
\\
- UPS NEXT DAY AIR' 1
l l
3
- SHAINES & McEACHERN. PROFESSIONAL ASSOCL&TDN 29 MApLEWOOD AVENUE = R O IBOX 360. PORTSMOUTM. N M. 03001
_