ML20087J546

Testimony of RW Petrilak Re Contentions 24.E,24.N,61.C,69, 70 & 71.Related Correspondence

ML20087J546
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/21/1984
From:	Petrilak R SUFFOLK COUNTY, NY
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Rt.LAT ED COMESPONDENCE I 00CMETED USNP.C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMh1SS10N l Before The Atomic Safety And Licensing Boaro l

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In tne Matter ot )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL .3 l

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(Snoreham Nuclear Power Station, ) (Emergency Planning)

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1 DIRECT TESTIMONY OF ROBEhI W. PETRILAK ON BEHALF OF SUFFOLK COUNTY REGARDING

, CONTENTIONS 24.E, 24.N, bl.C, o9, 70 AND 71.

Q. Please state your name and position.

A. My name is Robert N. Petr11ak. I am Vice Presloent ot tna Mt. Sinai Board of Education. The schools in ene Mt. Sinal Union Free Scnool District are located in the Shoreham 10-m11e EPZ. A description of the Mt. Sinai Union Free Scnool Dis-trict, its schools and its student population is containea in my previous tastimony concerning Contentions 25.C and 25.0.

(fi. Tr. 3087)

Q.- Wnat is the purpose of.tnis testimony?

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A. The purpose of this tes'imony c is to adoress tne concerns stated in Contentions 24.E, 24.N, 61.C, 69, 70 and 71. I am authorized to state that the views expresseo herein are not just my personal opinions but also represent the position of the Mt. Sinai Board of Education tnat the provisions 01 tne LILCO Plan concerning scnools are deticient and would not protect tne scnool children of the Mt..Sinai School District.

C. Are you familiar with tne provisions or the LILCu Plan?

A. I have reviewed those porcions of the LILCO Plan tnat contain LILCO's proposed protective actions for scnool eniloren in the event of a radiological accident emergency at Snorenam.

CONTEdTION 24.E - LACK OF AGREEMENTS WITH SCHOOL DISTRICTS Q. have you reviewed Contention 24.E?

A. Yes. It asserts that it is unlikely tnat LILCO's protec-tive action recommendations for schools would be implementeo, because LILCO has no agreements with the schools or scnool als-tricts on which it re11es to implement its recommendations, or with the nursery schools or parents of nursery scnool'ch11aren who are expected to permit those. children to be transportea by LILCO employees.

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Contention 24.E is correct. 6chools, scnool districts, nursery schools and parents are under no ooligation to partici-pate in or to implement whatever response to a shoreham emer-gency may be proposeo by LILCO. To my knowledge, L1LCO nas no agreements witn schools, school cistricts, nursery scnools or parents to implement LILCO's recommendations, despite tne fact tnat implemen ation of tne LILCO Plan depends on tne coopera-tion or these groups and individuals. The Mt. Sinal School District has not entered into and does not intena to enter into any agreements with LILCO regarding implementation or protec-tive actions that would be recommended by LILCO. As a result, it is un11Kely that LILCO's protective action recommendations for schools would-be implemented.

CONTENTION 24.N - LACK OF AGREEMENTS WITH RSLOCATIGN CEN1tas Q. Do you agree witn Contention 24.N?

A. As it applies to scnool cnlioren, yes. inat contention asserts tnat because LILCO does not have agreements witn racilities to serve as relocation centers for scnool chiloren and other evacuees, LILCO's evacuation proposals would not ano

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could not be implemented. Tne administration of the Mt. Sinai School District is not aware of any. facilities that nave agreea to act as relocation centers for our children if zul evacuation

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were to occur. LLLCO's failure to arrange for relocation l

centers is one reason that LILCO's evacuation proposal for scnools would not and could not be implemented, as stateo in Contention 70. The Mt. Sinai School District could not agree to conduct an evacuation without prior knowleoge and approval of the location and conditions to be expected at a relocation center.

CONTENTION 61.C.1 - SHELTERING Q. Are-you familiar with Contention 61.C.1?

1 A. Yes._ It asserts that a sheltering recommendation for schools could not be implemented. I agree-with-this assertion.

First, LILCO'is wrong wnen it assumes in its Plan that 1 scnool officials have conducted planning for implementing a sneltering recommendation, or any otner recommendation in tne event of a radiological emergency. (OPIP 3.6.5 at 10a) ine Mt. Sinai School District has not made any plans tnat woula en-able us to implement a recommendation or sneltering.

Moreover , 'if a school district attemptea to shelter its students in tne event of a radiologica1' emergency, tnere woulo be many serious practical problems that.would make'it unlikely that sheltering could be erfected. For example, it woulo be I

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l-essential that adequate staf f be availaole to supervise "the children. The job of supervising the enildren coulo be more difficult tnan usual because they will be more feartul in the event of a nuclear accident, which represents a threat as to which eney will have had no experience, tnan they would be in ene event of a more familiar emergency, sucn as a hurricane.

Moreover, chiloren will be frightened and distresseo at being forced to stay at scnool away. from their parents ano families f or even a few hours. Sucn fear would be magniried among cnil-dren ages 5 through 14, which is tne age group of almost all tne students in the Mt. Sinai district. In addition, tne dis-trict would have to have provisions of food, medical supplies and beds, as well as medical personnel. These practical neeos would make it all but impossible to shelter scnool children.

In addition, the staff of tne Mt. Sinai School District does not have any means of determining wnetner sheltering woulo De an adequate protective action. As I will discuss rurther in my testimony-on Contention 15.C, we would not trust LILCO's ad-vice on tne subject, and we nave no independent knowleage or how much protection from radioactive materials coulo be provio-ed by our senool ou11 dings. Moreover, neither of tne scnool builaings in the alstrict have basements suitable for.snei-tering. The elementary scnool building has only a small

l basement area that is used for storage, and the junior hign building has no basement at all. Furtner, the school bulloings in our district have very large windows in much of tneir space.

Finally, LILCO's proposals for notirying schools also make sheltering difficult, if not impossible, even assuming schools would follow a LILCO recommendation. LILCO plans to aavise scnools to begin early dismissais wnen an accident is first announced, (unless it is an accioent whose great severity is immediately clear and tnus sneltering - or evacuation is ordered immediately). But if LILCO subsequently recommends that persons in all or par t or the EPZ snelter , L1LCO coes not intend to advise the scnools to snelter tnelt stucencs. (Opie 3.8.2 at 5) This means that some scaools might not learn of the subsequent need to stop senoing cnildren out into a nealtn-threatening situation and, assuming they had begun an early dismissal in response to LILCO's recommendation, tney woulo theretore continue their early dismissai routine of sending children home, either on foot or on buses that will travel long, slow routes through residential areas insiae tne EPZ.

And, even if tnere were knowledge ot tne neec to get cnitoren into an adequate shelter, enere would be no way to recall cnose students wno hao already lett school. They would all be exposea to risk.

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CONTENTION 69 - EARLY DISHISSALS Q. Are you-familiar with Contention 69?

A. Yes. It asserts that, contrary to LILCO's apparent as-sumption, recommending early dismissals when an accicent is first announced would not result in students ceing protected from healtn-threatening radiation doses for several reasons, which are listed in subparts B, C, D and E. I agree witn tne Contention.

Q. Please explain.

A. First, the LILCO Plan is incorrect in its apparent assump-tion that scnool districts in or near the EPZ have, or incena to implemen',

t an early dismissal plan for use in ene event or a Snoreham emergency.1 The Mt. Sinai School District nas stated that the sarly dismissal plan it uses for snow anc otner-such emergencies is not designed, nor woulo it be appropriate, ror use in a Shoreham emergency. (See Attachment 1 to my testimony on Contention 25.C and 25.D, ff. Tr. 3087.)

Second, LILCO seems to assume tnat early dismissals, as-suming they were implemented, would allow cnilaren to reunite quickly with tneir families. In tact, an early dismissai in tne Mt. Sinai district woulo take several nours, for a number i

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l of reasons. First, our district does not have a senior hign school. Instead, we send our senior high stuoents to schools in Port Jefferson. Consequently, in an early dismissal, eight district buses -- almost half of our district's fleet -- must travel from Mt. Sinai to Port Jefferson to pick up the high scnool students and tnen return them to one or the Mt. Sinai schools, wnere they can board separate buses that will take tnem home. In a normal early dismissal, tnis trip does not delay the Mt. Sinai ear'.y dismissal, because our district usu-ally is able to coordinate with the Port Jef f erson adminis tra-tors, who agree to begin tneir early dismissal before ours.

That way, our senior high students return to tne Mt. Sinal schools as our early dismissal begins. In a Snorenam emergency that coordination would not be possible if both our district and the Port Jefferson district followed LILCO's advice and-in-iciated an early dismissal as soon as tne accident were announced. Moreover, in an early dismissal caused by a Snoreham accident, the round trip bus travel necessary to transport our high school students would be.along two major evacuation arteries (Route 25A ano North Country Road), wnere tne buses would encounter the heavy evacuation trattic expecteo by other witnesses for the County. Theretore ene trip woulo take longer than it normally does. Tne unavailability or tnose

eight buses for the amount of time necessary to get back anu forth from Port Jefferson under these likely conditions or a Shoreham accident would delay the dismissal of the rest or our school children. Thus, it coula be nours cetore early oismiss-al even began for many children in the Mt. Sinai School Dis-trict.

Third, it is very likely tnat many parents would come to the schools to pick up their children, ratner tnan waiting for several nours for tnem to be bussed home. Parents arc well aware of how long early dismissals taKe even under normal conditions, and they are likely to believe-tnat tne alsmissal will take longer in a radiological emergency. ine conversion of concerned parents on tne schools would create adaea tratric congestion and confusion around the scn'ools. As a result, buses would be slowed in. arriving and departing, anc chiloren could more easily miss their buses or eneir parents, wnich woulo cause even more concern and aistress on tne part of parents and children. Also, dealing with tne' parents and con-tusion their presence will create, would ado substantially to tne work required or the district's staf f.

Fourth, the time necessary to initiate an early dismissal -

, probably would take longer during a Snorenam-related acclaent 1

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than during otner emergencies sucn as a snowstorm, cecause as 1 noted above, the District prooably woula not trust information provided by LILCO, and would have little inaepenaent means ot deciding what action woulo be appropriata to protect our cail-dren. Accorcingly, attempts to verify information provicea by LILCO, and to obtain advice f rom more credible sources would be necessary before the District could decide whetner to begin the early dismissal process.

In adoition, when schools are dismissea early, proolems always arise because some parents are not at home curing the day. The LILCO Plan appears to ignore tnis proolem. If such cnildren were sent home as the LILCO Plan appears to contem-plate, the en11dren would be lett unattended ano, in some l cases, .able to get into eneir nomes. Consequently, tney would not be protected. Moreover, tne normal proceaures in our District for iaentirying an alternate aault contact in tne event of an early dismissal would not solve tnis problem in ene event of a Shorenam emergency. In our opinion, it woula ce oifficult to contact many parents, or otner adults, at tnelt homes or work places if there were an announcement on ene taalo that there had been an accident at Shorenam. Based on infor-mation we have received from parents, we believe that-many parents woula go to the schools to pick up their ch11oren, and l

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therefore they would not be at home to receive a phone call.

For example, Attacnment 1 hereto 15, a resolution aoopteu by the Mt. Sinai Parent Teacner Organization, wnich states tnat LILCO's emergency plans ao not offer adequate protection to cne school children of the Mt. Sinal School District in part oe-cause in the event of an accioent at Shoreham many parents would attempt to pick up tneir children at school ano thereoy increase confusion.

Q. What is tne basis for your agreement witn Contention 69.E?

A. As that contention asserts, LlLCO's plans would not provide protection for school chiloren in tne event or.an escalation of an emergency after early dismissais nad begun.

As I have noted before, early dismissals take a long time.

Tnerefore, it is very possiole that ir LILCO adviseo tne puciac to shelter or evacuate atter early dismissals nuo Degun, many or our scnool chiloren would still be on tneir way home. Inose enildren could not be protected. As a result, we believe L1LCO's proposals for protecting school cnilaren are dericient.

CONTENTIONS 70 AND 71 - EVACUATION Q. Do you agree witn Contentions 70 ano 71?

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A. Yes. Tnose contentions assert that LILCO's proposal that schools be evacuated if evacuation were recommenaec tor cae puolic would not work and would not result in ene protaction or scnool children.

Q. Please explain the basis for your agreement witn those contentions.

A. First, as I notea above with respect to Contention 24.h, LILCO's failure to arrange for relocation centers for evacuatec children makes the LILCC proposal unworkable.

Second, the LILCO Plan is wrong in assuming enat school officials have conductea " preplanning" for a Snoreham emer-gency. (OPIP 3.6.5 at 10a) The Mt. Sinai School District nas conducted no planning for an evacuation ot'its'ch11oren in ene event or a Shorenam emergency, because it believes tnat sucn an action woula be impossible and would not provioe acequate protection for its students. (See Attacnment 1 to my Testimony on Contentions 25.C and 25.D, ft. Tr. 3067.)

Third, the LlLCO Plan -does not contain any intormation or procedures as to how LILCO expects the schools to perform an evacuation. An evacuation would require a large number or'ad-ditional school personnel to supervise and care for scnool l

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children at schools, on. buses and~at relocation centers. The LILCO Plan seems to ignore this practical need, and the Dis-trict could not assure that adequate staf fing would be avail-i- able. Indeed, as stated in Attachment 2 nereto, a resolution adopted by the Mt. Sinai Teacher's Association, the teachers in our district believe LILCO's emergency-plans do not otfer adequate protection to the school cnildren in the Mt. .5inai School District, in part because or tneir concern that teacher.s

would not travel to or remain at relocation centers to super-3 vise scnool enilaren until their parents arrived.

Fourth, an evacuation would require more buses tnan tne Mt. Sinai School District normally uses. In a normal' dismiss-al, each bus in the Mt. Sinal School District maKes three runs.

But because the two schools in the Mt. Sinai Scnool - Distric t.

ate located directly between Route 25A ano North ~ Country Roao, which are the only east / west arteries in the area ano tnererore likely to be very congested during a Shorenam-related evacua-tion, it might not be possible for. buses. to make more tnan one trip from Mt. Sinai schools to a location outsiae tne EPZ in a-short-timeframe. As a result, to accomplish'an evacuatic.1 the.

Mt. Sinai Scnool District would need.at'least-twice as.many 60-passenger buses: and drivers as -it uses in~a normal! dismiss-al.

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1 Fifth, Contention 71.B is correct in its assertion that evacuation of schools would take a very long time. Our Dis-trict does not have the additional staf f, drivers.and buses that would be necessary'to accomplish an evacuation. Inoeeo, as I noted in my testimony concerning Contention 25, we woulo have fewer personnel than normal available due to role conflict. The point is that without tne assurance of an adequate relocation center, adequate staffing, and an adequate number of buses, an evacuation could not be accomplished in a reasonable amount of time.

Sixth, the LILCO Plan assumes that an evacuation of cn11-dren to relocation centers will result in reuniting cn11oren with their families, but has no provision, or explanation, of how this reuniting is to be accomplished. In my opinion, expecting parents to go to relocation centers to meet tnelt children, hours after tney have left scnool, rather tnan.

expecting parents to find their chilaren immediately in tne event of a Shorenam emergency, is unrealistic.

] Finally, as Contention 71.a asserts, it is un11Kely tnat LILCO's proposal.to use its own personnel to evacuate nursery schools coulo be implemented. For example, the Mt. Sinal School District is not authorized to, nor would it, permit i - 14 _

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anyone to drive a bus containing oer students unless tnat

Person was licensed and certified to drive a school bus. My understanding is that LILCO's employees are not properly car-tifie'd. Consequently, it is unlikely that any nursery scnools or parents of nursery school.cn11dren, would permit enelr en11-dren to be evacuated by LILCO bus drivers.

Q. Does that concluce your testimony?

A. Yes.

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Mount Sinal Parents Teachers Organization r, c, ; ';; ' .. . ;. , '

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.O s .h C.T. It.2y CCnCGnis Pere is a recoluibon ado; tee by the t. ..iinai 4.I.L.

concernirc the licencirc of tre Jhoroba ..uclear ; ower fler.t.

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4 T. SINAI FAhEhT TEACHEn OhGANIZATICN--DRAFT nESOLUTIch WHEhEAS, the I.t. Sinal Parent Teacher. Organization, having dis-cussed LILCO's emergency evacuation. plan for schools in the event of a nuclear accident at the Shoreham plant, wishes to advise the Nuclear negulatory Commission's Shoreham licensing board of the ' plan's workability for its community: and 4

WHEREAS, LILCO's emergency evacuation plan is dependent on our schools' early dismissal procedures: and WHEREAS, this PTO has con'sidered the following weaknesses in the LILCO evacuation plant 1.

We,are Transportation certain that the required number of buses and

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' drivers for successful early dismissal' will not be available to the schools. . Drivers may need to attend to the safety of their .own families first and .may re-fuse to drive school buses. Furthermore, because of the shortage of buses in our school district,- transporting

children from school to home normally necessitates three .

bus shifts. Consequently, there is no possibility of a quick evacuation.

2. Needs of School Personnel

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We are certain that not all teaching and non . teaching

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personnel will stay in' schools to supervise early dis-missal. kany of~the teaching'and non-teaching ste.ff

.will leave school to attend to the needs of their own families. Consequently,-not enough school personnel will be available to attend to emergency-related jobs.

A teacher survey conducted in the v.t.. Sinai school dis-trict indicated that a majority of the teachers would not remain in school to supervise emergency procedures.

3. -Lack of Parental Supervision Should there be a nuclear accident at the Shoreham plant, the success of an early dismissal plan depends not only

, on prompt dismissal frem. the schools, but on prompt evacuation of children from their homes as well. It.

is probable, however., that many panic-stricken children will be locked out of their. homes: or that even if these children can enter their homes their parents will. not be present to carry out the necessary second part of an evacuation.

4. Parental Intercession We cannot be assured that all parents will wait at home for their children to arrive. Lany parents will attempt- I to retrieve their children at~ schools, thereby increasing confusion and chaos. i

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p. 2--RES01UTION

5. Panic "The announcement of a nuclear emergency at Shoreham will cause disorientation and panic in children, tea-chers, non-teaching staff, and parents. This will further hinder effective and safe dismissal from our schools.

6. Relocation If an emergency at Shoreham requires evacuating our .

childr'en from schools directly to a relocation center, our school district would be unable to handle this situation effectively. (See #1, Transportation) i

7. Supervision at Relocation Centers Cnce again we are certain that teaching and/or .non-teaching school personnel'will not all travel to and remain at relocation centers to supervise children for a possibly indbfinite period of time. The Mt. Sinal l teacher survey showed that over 70% of the teachers would have~ left for their own homes after the first hour, and that a majority of the 4eachers would refuse to accompany children to relocation centers.

8. Shelt'ering The LILCO plan suggests that shelterine, rather than evacuating, may be the preferred protective action in

. schools in ene~cific Shoreham emergencies. The Lt. Sinal school district has one basement in its elementary

. school. The size and function (for furnace and boiler facilities and the storage of extra furniture) of this basement preclude the sheltering of all but a small number of our school population.

9. Trust in Public Information .

In the LILGO plan, the only source of public information during an emergency is LILCO itself. As a result of LILCO s past statements and actions with regard to Shoreham, many of us in .our community are already skeptical of LILCO's words and intentions. The fact that LILCO might also be ' involved in a conflict of interest--being both operator of the plant and initiator 2

of emergency actions--would tend to intensify doubts about the validity of LILCO's information during tut emerg ency. . -

Now, be it therefore RESOLT ED, that the 1.t. Sinai Parent Teacher Organization finds I that LILCu's emergency plans for our schools do not. ,

-offer us adequate protection or quick and effective )

evacuation for our children in the -event of an' accident  !

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p. 3- 'd ESOLUTION hESOLVED, that we agree with our Suffolk County legislators that in fact no safe evacuation of our communi'ty is-possibles and RESOLVED, that we believe that a full-power license should not be granted to the Shoreham Nuclear Power Plant.

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• 3 RANCH 74EREAS, federal regulations for fun power operation of the Shoreham Nuclear Plant require an emergency plan for communities surrounding the plant which will assure those communities adequate protection in event of a nuclear, emergency; and YdEREAS, the Lon6 Island Lighting Company, in an' effort to meet federal regulations, has prepared an emergency plan which LILCO, lacking coordination with local or state governments, will attempt to implement; and EdEREAS, tna LILCO emergency plan includes protective actions to be taken by schools; and W EREAS, this association has identified.the following weaknesses in the LILCO emergency plans .

1. b -1v Dicnissal our energency early dismissal procedure, which LILCO's plan incorporates,

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wouldn't bring school children .to an uncontaminated area quickly enou6h to protect their health and safety.

2. Transtertation ~

-w Tne requisita number of busen and drivers required for successful early disnissal are not available to the schools. This will prolong i

childrens' stay at schools in contaminami areas.

3. Needs of Teachere We cannot guarantee that the teachers will stay in schools to supervise i

early dismissal. Many of us may need to attend to the safety of our own families and, therefore, may not be av*ilable to perform emergency-related tasks.

4 Lack of Parental Suvervision Tne success of an early dismissal plan depa.nds not only on prompt dismissal kom schools, Mt on prompt evacuation of children from their homes. In those cases in which parenta vill. net be at home A._-ing the day, children will be sent to unsupervised homes from which they will not be able to evacuate promptly.

5. parental Intercession ,

We cannot be confident that parents will wait at home for their children to arrive. Many parents may, attempt-to retrieve their children at

' schools, perhaps causing increased ,contasion and chaos.

6. P elocation x x If a Shoreham emergency develops quickly and requires an evacuation of children from schools directly to relocation centers, this district .

does not have sufficient Waes, or drive.m to transport all children to -

. relocation ' canters in a timely, ; effective manner. -'

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T E A C H E R S' A5SOClATION

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Mt. Sinai Teachers' Assan.

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7. Sut>ervision at Relocation Centers l We cannot guarant.ee tnat teachers will travel to and remain at relocation centers to supervise school children until parents arrive to retrieve them.

8. Trust in Public Information in tne LILCO plan, the only public informatien upon which to base decisions for protective actions will cose from the utility. LILCO, through its Public Schools Coordinator and WALK-AM Radio, will both describe the extent of the emergency and reconnend actions. Because -

LILCO would be teth operator of the plant and initiator of emergency actions, potential for conflict of interect exists. School =d=4 ni strators, receiving information only from LILCO and not from any governmental a6ency, will be forced to decide upon actions with potentially serious

, consecuences without the benefit of a directive from a responsible governmental source.

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Now, be it therefore RGOLVED, that the Mount Sinal Teachers Association finds that LILCO's emergency plans for schools do not offer children or nehool personnel of this district '

adequate protection in event of an accident at the Shoreham Nuclear Plant; and, be it further -

R50LVED, that this association believes that licensing of the Shoreham Nuclear Plant should not be permitted unless or until complete and reasonable resolution of these outstanding, critical emergency *'anning problems can be achieved. .

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/61Mah 516 4734321 I have read the Mount Sine.1 Teachers' Association Resolution on the Shoreham Nuclear Plant.. I support the Association's Resolution.

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MT. SIN At. Nt ty YOR K 19764 $14 4734321 I have read the Mount Sinai Teachers' Association Resolution on the Shoreham Nuclear Plant. I support the Association's a d ***"***"* .. . . . MDAw ~' '

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