ML20148S999

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Direct Testimony of Bg Brodsky,Ej Doherty,Hm Koenig,Nf Muto, RW Petrilak,Ar Rossi,Jt Smith & Rn Suprina on Behalf of Suffolk County Re Contention 25.C.* Util Plans for School Evacuation & Other Alternative Actions Inadequate
ML20148S999
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 04/13/1988
From: Brodsky B, Doherty E, Koenig H, Muto N, Petrilak R, Rossi A, James Smith, Suprina R
SUFFOLK COUNTY, NY
To:
Shared Package
ML20148S880 List:
References
OL-3, NUDOCS 8804200113
Download: ML20148S999 (161)


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. i USNHC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'88 MH 15 N147 Before the Atomic Safety and.Licensina Board' 0FF!LE F ShiitIM f 00ChtiiNG A SEn'/lCf.

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In the Matter of )

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

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

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DIRECT TESTIMONY OF BRUCE G. BRODSKY, EDWARD J.

DOHERTY, HOWARD M. KOENIG, NICK F. MUTOr IT W.

PETRILAK, ANTHONY R. ROSSI, J. THOMAS Sc ., AND RICHA3D N. SUPRINA f

ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTION 25.C 1

l April 13, 1988 l

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I. Introduction and Bac_kcround Q. Please state your names.

A. My name is Bruce G. Brodsky.

My name is Edward J. Doherty.

My name is Howard M. Koenig.

My name is Nick F. Muto. <

My name is Robert W. Petrilak.

My name is Anthony R. Rossi.

! My name is J. Thomas Smith.

, My name is Richard N. Suprina.

1 Q. Please describe your involvement with schools on Long Island.

l A. (Brodsky) I have been a member of the Middle Country Central School District Board of Education for the past ten and one-half years. I have served on the legislative, policy,

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finance and public relhtions subcommittees of the Board. In ad-dition, I am a member of the Nassau-Suffolk School Boards Assoc-lation, the New York State School Boards Association, the Brookhaven School Board Association, and the National School Boards Association. A copy of my resume is Attachment 1 hereto.

(Rossi) I have been the Director of Transportation for the Middle Country Central School District since January, 1973.

I am also a certified instructor for the New York State Basic and Advanced School Bus Driver Training Programs and serve as a qualified inspector for the New York State Motor Vehicle Depart-ment. As an inspector, I test school bus driver candidates to determine whether they may continue to be certified school bus drivers in compliance with Article 19-A of the New York Vehicle and Traffic Law. I am cn active member of the New York Associa-tion for Pupil Transportation and I serve as President of the Suffolk County Chapter of the New York Association for Pupil Transportation, a position which requires me to remain abreast of school transpx cation related matters within New York State. A copy of my resume is AU.echment 2 hereto.

(Suprina) I have been the Superintendent of Schools for the Riverhead Cential School District for the past five years. Prior to becoming Superintendent, I held a variety of other school-related positions in other school districts, in-cluding assistant superintendent, principal, and teacher. I have

r been involved in the education profession for over 30 years. I am an active member of the BOCES I Council of Superintendents, the New York State Council of School Superintendents, and the Suffolk County Council of School Superintendents. I also serve on the executive committee of the Suffolk County Organization for the Promotion of Education, an organization which devises educa-tional in-services for teachers. A copy of my resume is Attachment 3 heret'o.

(Doherty) I have been employed by the Riverhead Central School District since 1953. Between 1953 and 1963, I was at various times a school bus driver, school bus mechanic, and the District's Assistant Supervisor of Transportation. Since 1963, I haie been the District's Supervisor of Transportation. I am a certified school bus driver instructor and examiner. Over l

the years, I have served as President, Vice President, Treasurer,

! and secretary for the Suffolk County Chapter of the New York Association for Pupil Transportation. I am currently the Secretary of the New York State Association for Pupil Transpor-tation. A copy of my resume is Attachment 4 hereto.

l (Muto) I have been the Superintendent of Schools for the Longwood Central Pchool District for the past six years.

Prior to becoming Longwood's Superintendent, I served as Superin-l l teudent of Schools for Nauset Public Schools in South Wellfleet, Massachusetts. I have been involved in the education profession l

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e since 1954. I am also familiar with school-related issues as a result of the experience and knowledge I have gained through my psition with the Nassau-Suf folk School Boards Association. A copy of my resume is Attachment 5 hereto.

(Smith) I have been the Transportation Coordinator for Longwood Central School District for the past 18 years. I am also a certified school bus driver instructor for the New York State Education Department, a New ' York Department of Motor

, Vehicle certified schoo: bus driver examiner, and a National Safety Council defensive driver training instructor. I am a member of the Brookhaven Township Transportation Advisory Board, the Suffolk County Chapter of the New York Association for Pupil Transportcclon (for which I previously served as President), the New York Ansociation for Pupil Transportation, and the National School Tratsportation Association. A copy of my resume is Attac'iment 6 hereto.

(Xoenig) I have been the Superintendent of Schools for the East Meadow Union Free School District for the past five years. Prior to becoming East Meadow's School Superintendent, I served as Als3stant Superintendent of Administration for the Harborfields Central School District. I have been employed in the education field since 1968. I am a member of the New York State Council of School Superintendents and the Nassau County Council of School Superintendents. I recerted my Ph.D. in educa-

-tional acLuinistration from New York University and teach courses which deal with the subject of role conflict at both New York .

University and Long Island University. I.also am a member of the-Nassau-Suffolk School Boards Association. This association meets 4

regularly-to discuss issues of common interest to school adminis-trators on Long Island, including issues regarding pupil trans-portation. A copy of my resume is Attachment 7 hereto.

(Petrilak) I have been a member of-the Mt. Sinai Board of Education since 1983 and have previously served as Vice President of the Board. As a Board member, I am involved in all aspects of education policy formulation for Mt. Sinai, including transportation policy. A copy of my resume is Attachment 8 hereto.

(All) These school-related activities have provided us the opportunity to participate in a wide varie:y of school matters, including those related to the safe transportation of our children. These activities have also given us a broad per-l apective regarding school transportation issues and how they are i

handled, both by our respective school districts and by other l

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l Q. Please describe your school districts and your school l

f related responsibilities that pertain to your testimony in this i

t proceeding.

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Middle Country Central School District A. (Brodsky) As a member of the Board of Educction of the Middle Country Central School District, I work with the other Board members to establish policy for the District. We appoint the Superintendent and other officials who are responsible for implementing the Board's policies. Among other things, we estab-lish and monitor the Middle Country District's policy regarding the transportation of schoolchildren, which policy is then imple-mented by the District's Superintendent and by the District's Director of Trunsportation, Mr. Rossi, and his staff. Our policy derives from State regulation requirements and District-level administrative directives. That policy is that only drivers approved by Mr. Rossi and the Superintendent are permitted to transport our children, and that Middle Country children are per-l mitted to be transported to and from school only in buses which have passed the bi-annual State certification inspections and meet with the approval of Mr. Rossi and his staff. This policy is based upon our strongly held view that we can protect our children's safety in travel to and from school only if we main-tain strict controls over who transports our children and how.

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, . (Brodsky, Rossi) The Middle Country Central School District is located partly inside and mostly just outside and to l

the west of the 10-mile EPZ. Our total public school enrollment is approximately 12,000. We have 13 public schools for which we

m provide daily transportation to and from school; for these 13 schools, we also provide transportation for extracurricular activities such as field trips, sporting events, and the like.

Further, our District provides transportation to and from school for District children (approximately 900 children) who attend private and parochial schools. Some of these schools (St. John the Evangelist, Infant Jesus, North Shore Christian, and Yaphank Christian) are within or very close to the 10-mile EPZ;.some are l to the east of the 10-mile EPZ, necessitating travel within the EPZ in order to carry out daily bus runs; and others are located elsewhere on Long Island.

(Rossi) As Director of Transportation for Middle Country Central School District, I oversee'the transportation of approximately 10,000 students to and from school daily; we trans-port approximately 9,000 students to the public schools and approximately 900 to the private and parochial schools. " >u t 2,500 of our students (raostly attending public schools) regularly l walk to and from school.

i I am responsible for the hiring and training of school bus drivers, and the maintenance of school buses. I personally interview and approve each driver who transports District I

children, including those persons who drive buses for our con-tracting bus companies. This interview / approval process is necessarily somewhat subjective. In my experience, however, I l

I have come to recognize that driving a school bus requires persons with not only the requisite training in driving a large vehicle, but also the composure and-capability to gain the confidence and respect of children and parents. I. feel that personal interviews are an important part of the overall selection process of bus drivers.

Each school bus driver applicant must undergo a physical examination, submit three letters of reference, perform satis-

! factorily on a written and behind-the-wheel examination and i

undergo fingerprinting to verify that he or she does not have a criminal record. In addition, I obtain f rom the Department of Motor Vehicles a copy of each applicant's driving record for the

' past three years. Our bus driver training entails 40-50 hours of instruction. -In addition to teaching our driver candidates how to operate a bus, we offer instruction on school bus safety l

l practices, handling children and the importance of discipline,

special laws and regulations that our drivers must comply with, repair procedures and what to do should their bus become involved in an accident. Our drivers are taught to conduct a pre-trip l safety inspection each and every time the bus is placed in l service, and to fill out and submit to me the pre-trip inspection forms. Our driver candidates must ride for three days with a i

regular driver to observe student discipline and proper handling of students, to learn the locations of streets and schools, and

to get any questions they might have answered by a trained driver.

I ensure that each bus which carries Middle Country children is operated in compliance with the rules, regulations, and laws of the State. For example, I, or persons working under my direc-tion, inspect all District-owned and contract buses. The District-owned buses undergo complete maintenance at our garage every 3,000 miles, in addition to regularly scheduled quarterly maintenance. All school buses undergo a rigorous inspection by the State Department of Transportation every five to six months.

Should a bus fail the inspection, that bus would not be used to transport children until the problem was corrected and the bus passed inspection. I also conduct all required and supplemental safety seminars.

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(Rossi, Brodsky) Middle Coun'try relies upon a combina-tion of District-employed (40) and contract (33 from United Bus Company and 29 from Medibus) drivers to transport its 10,000 students. The large majority of our drivers are women, often of child-bearing age and with children attending our schools. Most 1

of the drivers reside in the District or close to it. Some reside within the 10-mile EPZ.

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. For the most part, the 40 District-employed drivers are not full-time employees. Rather, they work only the hours that they i

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drive and can be reached during times when they are not driving only if they happen to be at home or if they are in buses which are equipped with radios. The same is true for the District's contract . drivers. The contract drivers typically keep their buses with them during the day; the Medibus drivers keep their buses overnight. Many District-employed drivers also keep their buses during the day; as a result, very few buses are at the Middle Country bus yard during the day.

We use 101 buses each day. Most of these buses engage in both public and private and parochial school runs each day. At any given time during the school day, 24 buses are being used solely for the transportation of the private and parochial school students. We also use three mini-buses to transport those children with special needs.

The buses in our fleet are not of the same size. Of the District-owned buses we have 32, 20-seat school buses; five, 10-seat buses; and two, 15 passenger vans and one, 16 passenger van. Of the contract buses, 33 are 20-seat buses, and 29 are 16 passenger mini-vans. For trips under 10 miles, the buses can carry three elementary students per seat, meaning the capacities are 30, or 60 elementary students, depending on bus size. For trips over 10 miles, I would not load a bus three per seat even with elementary students. I would load high school students only

e two per seat, meaning the bus would be carrying 20 or 40 students, depending upon the size of the bus.

Middle Country does not have sufficient buses or drivers to transport all its children -- or even those who regularly require transport -- at a single time. Rather, as described in greater detail below, each driver must perform multiple runs both in the morning and af ternoon in order to transport our children. We have staggered school openings and closings as a result. To accommodate our transportation needs, we have buses arriving and leaving our schools at 24 separate scheduled times. We also have i

unscheduled runs each day. At least half of our drivers are on the road with their buses at any given time during the day.

Those drivers responsible for the kindergarten runs are on the 4

road virtually all day.

l Riverhea'd Central School District i

A. (Suprina) As Superintendent of the Riverhead Central

School District, I am in charge of implementing all School Dis-trict policies which are established by the Board of Education.

l One area of my responsibility is to supervise School District i

operations --

such as Mr. Doherty's transportation activities.

l The Riverhead School District Board of Education has instituted a j transportation policy under which our children will be trans-l ported only by drivers who have received District approval and 5

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only in District-owned buses, which are maintained and inspected by District personnel. This policy is based on safety concerns:

our parents demand assurance that their children are well cared for and adequately protected. To satisfy this demand and provide such assurance, the Riverhead School District has determined that it must maintain complete control over who transports the District's schoolchildren and how.

(Suprina, Doherty) The Riverhead Central School Dis-trict is located to the east and south of the Shoreham plant.

The District begins within approximately two miles of the Shore-ham plant and then continues to the south and east of the 10-mile EPZ. The District has approximately 3,700 public school students enrolled in seven public schools. Four of our public schools (Riley Avenue and Pulaski Street Elementary Schools, Riverhead Junior High, and Riverhead High) are located within 10 miles of Shoreham and have approximately 2,705 students. Our remaining three public schools are all located close to the 10- mile EPZ boundary line. We feel it is unrealistic to assume that those schools falling just outside the 10-mile line are somehow "safe."

Thus, we consider all the Riverhead schools to fall within the zone of potential danger.

In addition, we also provide transportation to 369 parochial and private schoolchildren who reside in our District. These children attend schools both inside and outside the 10-mile EPZ.

e We transport students to the following private and parochial schools located inside or very close to the EPZ: St. Isidore~,

St. David, St. John the Evangelist, Living Water and Mercy High School.

(Doherty) As Transportation Supervisor for the River-head Central School District, I administer the operation of the bus fleet owned by the District for the purpose of safely trans-porting schoolchildren to and from school on a daily basis. I also am responsible for all transportation necessary for extra-curricular activities.

The District owns 54 buses of which 39 are full passenger capacity buses (21 have 20 seats and 18 have 22 seats) and 15 are 5 to 28 passenger buses used for handicappsd children and other i

uses. The District employs 47 regular drivers, and six substi-tute drivers. Thirteen of our 54 buses are used solely for the transportation of the private and parochial school students; 32 j of our buses are used for public school transportation. We use l 15 buses to transport 36 handicapped students to eight schools, f

Eight of our 54 buses are spare buses and we contract for the use of two buses. Our capacity policy is the same as that described above by Mr. Rossit the only circumstance where three children l per seat are permitted is on elementary school trips under 10 I

miles. In all other situations, two children per seat is the maximum permitted.

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Most of our drivers are women who often are young with school age children. For the most part, our drivers reside with-in the District; many reside very close to or within the 10-mile Shoreham EPZ. Our drivers are not full-time District employees.

Rather, they work only during peak driving times -- morning and afternoon, plus those needed for midday kindergarten transporta-tion and extracurricular activities. At other times of the day, our drivers can be reached only if they happen to be at home or in buses which are equipped with radios.

Each driver receives a rigorous training program which I directly supervise. The program includes 40-60 hours of on-the-job training, involving actually driving school buses with a

. supervisor (usually me) present. In addition, I personally interview each driver applicant (including substitutes) to ensure to my satisfaction -- based on my years of experience -- that the applicant possesses the necessary personal qualities to make him/her a satisfac ory driver. The Riverhead School District adheres to these requirements, because we have determined that anything less would not ensure the safe transportation of our children. No person is permitted to drive who has not received I my personal approval. Dr. Suprina ultimately gives his approval I

of each driver as well, based upon my recommendation. These re-quirements have never been subject to waiver. Thus, we have for-bidden the use of substitute drivers who have not received our full training and approval. As a result, during times when we l

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have been short of drivers, the transportation of some children i has been delayed. *

(Suprina, Doherty) We do not have sufficient resources '

to transport all our students at the same time. Indeed, as dis-cussed below, we do not have sufficient resources even to trans- .

port the~ pupils attending the four EPZ schools at one time.

I Lonowood Central School Distr M  ;

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A. (Muto) As Superintendent of Schools for Longwood ,

Central School District, I am responsible for all areas of the  ;

administration of the school district. The Longwood District is located ~within the 10-mile Shoreham EPZ. Our six public schools l are roughly southwest of the plant, ranging in distance from about four to nine miles from Shoreham. My responsibilities in-clude the implementation of the transportation policies of my l

. District. These include the policy that our schoolchildren may r

j be transported only by persons who have received the personal l

! approval of the District, and only in buses which have received  ;

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the approval of Mr. Smith. The reason for this policy is the same as that testified to above by other witnesses: we have determined that we can provide for the safe transportation of our l

children only by the maintenance of strict controls over how and l

r j by whom our children are transported.

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(Smith) As Longwood Transportation Coordinator, I am responsible for the transportation of schoolchildren enrolled in

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the six public and 36 private and parochial schools within the Longwood District. Longwood obtains buses and bus drivers f rom the Suburbia Middle Island Bus Company and Noyl Equipment. Our contracts call for 89 regular 20-seat buses to be available from Suburbia. Of those 89 buses, 19 are used solely for the trans-portation of private and parochial school students, while 70'are used to transport public school students. Noyl Equipment supplies 57 buses, which we use for transporting handica' ped p and other special needs children. Of these 57 buses, three have the capacity to hold five students confined to a wheel chair and five ambulatory students, two hold 10 students confined to a wheel-chair and eight ambulatory students, six are 20-seat buses and 46 are eight-seat buses. We use all the Noyl Equipment buses for the transportation of our children with special needs.

The majority of the bus drivers utilized for our children are women, many of child-bearing age. The majority of our drivers are also local, meaning that they reside within or near our School District. Many have children who attend our schools.

We are very careful never to overload our buses. For in-stance, we would never load 60 students, even elementary students, on a bus. At most, for trips under 10 miles, we would load 55 elementary students on a bus. For trips over 10 miles,

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such as to Nassau County, we would load the buses two students i per seat, leaving room for two adult supervisors in accordance j with District practice.

Notwithstanding the use of contract drivers and buses, I maintain close control over the training of all drivers who transport our children. Thus, I personally oversee all employ-ment and training of these school bus drivers in order to ensure the safe and competent transportation of our schoolchildren. The training inc1'udes 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of instruction, divided between myself and driver training instructors employed by the bus company. A significant portion of the training -- 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> -- is route simu-lation prior to actual assignment involving the transportation of children. That portion of the training carried out by the bus company instructors is subject to my overall approval. Further, I personally interview and approve every school bus driver who drives District children.

Suburbia Middle Island Bus Company has the primary resnonsi-bility to ensure that the bus equipment contracted to the Dis-trict meets all requirements. I review Suburbia's standards and periodically inspect all buses and inspection records to ensure that proper maintenance is being carried out. Should I receive a complaint about the condition of one of our contract buses, I personally inspect that bus from top to bottom. Moreover, all the school buses used to transport our schoolchildren must under-I

go rigorous inspection by the State Department of Transportation every five or six months. Only State-certified buses are allowed to transport our school- children.

(Muto, Smith) The total student enrollment in our Dis-trict is over 10,000 students. Our District transports approxi-mately 9,465 schoolchildren daily. Our student enrollment breaks down as follows: we transport daily 8,574 public school-children (4,018 elementary students, 1,354 middle school Students, 1,287 junior high school students and 1,796 high school students) and 891 private and parochial school students. Many of our private and parochial school students are transported to schools located within or very close to the Shoreham EPZ, in-cluding North Shore Christian, Infant Jesus, St. Isidore, Mercy High School, St. David, St. John the Evangelist and Yaphank Christian. To transport all our children requires three bus runs by each driver, both in the morning and the afternoon, in addi-tion to the midday kindergarten and split session bus routes which must be driven. Our drivers cover 638 different bus routes, over which more than 11,740 stops are made. We do not have enough drivers or buses to transport all our children at the same time.

East Meadow Union Free School District I i

A. (Koenig) As Superintendent of East Meadow Union Free School District, I am responsible for the overall operation of the school system. I implement the educational and administra-tive policies for the District, which are established by the East Meadow School Board. The East Meadow District has approximately 7,000 stude'nts enrolled in its eight schools. The District is located in Nassau County, New York, several miles from the Nassau f Coliseum and Nassau Community College, which LILCO has designated as school reception centers.

I am charged with implementing the District's policies with respect to the transportation of schoolchildren. Our policy is consistent with the policies described abover our children are permitted to be transported only by drivers who have been per-sonally approved by me. I base my approval on the recommen-dations of our Transportation Director.

Mt. Sinal School District 1

A. (Petrilak) As a member of the Mt. Sinal Board of a

Education, I participate in the development of policies to be implemented by schools within the District. Part of my job as a School Board member necessarily concerns devising and imple-menting policies that ensure the safe transportation of school-lI J

children to and from the two schools located within the Mt. Sinal i

District, as well as the transportation of our high school students to and from the school they attend in Port Jefferson.

We also transport pupils to 21 private and parochial schools both inside and outside the 10-mile Shoreham EPZ.

our transportation policy requires that all drivers be I approved by the District's Superintendent before they are per-mitted to drive our children. Further, our bus contractor is not

authorized to allow unapproved personnel to operate buses under contract to our District.

All Mt. Sinal schoolchildren are transported by bus to and '

from school each day; in other words, none of our children walk to school. Mt. Sinal relies on contract buses in order to trans-port its children. A total of 2,350 students are transported, including 976 elementary students, 684 junior high students, 572 senior high students and 118 private and parochial school i

students. We have a total of 27 full capacity buses (19 have 22 i

j seat' 'nd eight have 20 seats) and 27 drivers, plus five substi-tute drivers, under contract with the Harborview Coram Bus

! Company. Most of our drivers are women who live within or rela-tively close to Mt. Sinai. Twenty-six buses are used to trans-t port the public schoolchildren and 11 eight seat mini-vans are used in the transportation of the private and parochial school l

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students. The District uses one mini-van to transport children with special needs.

For our 27 full capacity buses, we use the same capacity numbers mentioned by Mr. Rossi, Mr. Doherty and Mr. Smiths never more than two students per seat except for elementary students on trips under 10 miles. We do not have enough buses and drivers to trar. sport all our children at the same time. Each driver must make two bus runs, in addition to the kindergarten runs, every morning and again in the afternoon in order to accomplish the transportation of our pupils to 24 different schools.

'the primary responsibility for training the bus drivers who transport our children and for maintaining our buses rests with our bus contractor. The Mt. Sinal Transportation Director, Ms. Gail Litsch, however, personally interviews every driver, conducts safety seminars, and ensures that the buses are properly maintained and that all drivers undergo extensive training prior to ever transporting children. She also ensures that all drivers attend regular bi-annual refresher training courses.

Q. You have discussed bus driver training. What is the most important aspect of such a training program?

A. (Rossi, Dohe r t.y , Smith, Petrilak) Without question, the most essential component of effective bus driver training is

on-the-job training during which the drivers actually transport children. Classroom training and instruction regarding bus driving, without children present, are important, but clearly insufficient. It is only when you - have been trained and are experienced in transporting 40 or more children day after day that you learn the practical aepects of safe school bus opera-tion.

Accordingly, we include extensive supervised on-the-job training for all our drivers. We permit no drivers to transport children 6n their own until they have been trained and observed in real world, on-the-job driving on multiple occasions, in-cluding observation of defensive driving practices. It is our understanding that LILCO's drivers will have had no such training.

It should also be emphasized that, in addition to the basic training, testing, interviews, criminal record checks, and physical examinations described in this testimony (which must be carried out for a person to qualify initially to become a bus driver), each of our Districts -- and we believe all other school districts as well -- carry out regular training of bus drivers throughout the year.

(Smith) For example, the Longwood Central School Dis-trict provides refresher courses twice a year for both its

regular and substitute drivera. Refresher I must be completed by all drivers before the openiag of school in September. This in- l service program provides a review of bus driver responsibilities, '

and pertinent rules, regulationc, laws, and local policies and practices. Topics for discussion include, but are not limited ,

to, safety measures, accident prevention, pre-trip inspection and current developments in pupil transportation. Refresher II also must be completed by all drivers en an annual basis, and in no event later than January 31 of each year. Refresher II includes review of safe winter driving practices, as well as changes in laws, rules and regulations, and local policies and practices.

In addition to the bi-annual refresher courses, I i:ypicelly hold additional meetings during the' course of the school year to emphasize safety. This year, for instance, I have already held two such meetings to discuss driver training and student discipline. Our drivers also sit down each year with the con-tractor to review their driving record from the previous year.

(Rossi) All our drivers, contract and District, are c.lso required to cotaplete a refresher course twice each year; Refresher ~I is provided before the schools open and Refresher II is provided before February 1 of each year. The same topics covered by Longwood are also covered in Middle Country. In addition, we provide instruction on railroad crcssings and field trip procedures, student discipline, accidents and accident

liability. I also hold a third meeting each year to discuss various safety related topics and policy concerns and to conduct the testing necessary for our drivers to remain certified to drive our buses. I frequently show films to emphasize particularly important topics. At the beginning of each school year, I sit down with each driver to discuss their driving record from the prevjous year and any job related concerns those drivers may wish to discuss with me. I do all this to ensure the safe transportation of our schoolchildren.

(Doherty) My drivers also must attend two refresher courses, one before schools open and the other in the winter. I emphasize all the same topics covered in the Longwood and Middle Country ref resher courses. In addition, I hold periodic mini-meetings throughout the year and typically review sr.fety related procedures and policy concerns. We have a safe driving awards program to enhance our drivers' safety awareness and to recognize safe driving.

(Petrilak) Mt. Sinal drivers also must undergo com-pulsory refresher courses twice each year. Similarly, the Mt.

Sinai Transportation Coordinator sits down with our contract drivers at the beginning of each school year to review their driving record ' rom the preceding year.

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(Rossi, Smith, Doherty, Petr11ak) To ensure the safe transportation of our schoolchildren, we must make certain that our crivers maintain the high standards expected by our Dise.ricts and the parents of our children. Thus, in addition to the re-fresher courses we hold twice a year, we require our drivers to do other things as well. Our drivers must undergo a physical examination and perform satisfactorily on a behind-the-wheel, oral and/or written examination every year. In addition, a motor vehicle license inspector must observe annually the defensive driving performance of each and every one of our drivers.

Q. You have each discussed your involvement in the trans-portation policies of your School District. How important is transportation policy?

A. (All). Very important. School bus-related accidents often lead to injuries and deaths of schoolchildren in this ,

country each year. We are aware that accidents may result from the following avoidable causes: lack of attention to training cf drivers, over-crowded buses, lack of student control when getting on or off buses, crowded bus parking areas, defective equipment, and similar problems. In an effort to avoid these problems, our School Districts have made the safe transportation of our children high priority matters. Ne have adopted stringent standards because transporting children is not easy and cannot be performed by just anyone. Because we have stringent require-

I ments, which in some respects may even exceed the particular l

requirements specified by New York State law for the transporta- ,

l tion of schoolchildren, we have fine safety records. We have, l over the years, rejected many persons who have sought to become drivers. For many reasons, including- driving ability and temperament, we have concluded that some prospective drivers are not acceptable. We insist upon the proper training of drivers and proper maintenance of school buses.

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l The parents of our schoolchildren have insisted that we maintain these high standards. When there is a transportation problem, such as a bus driver unable to find a home or a driver who cannot maintain order on the bus, we hear about it from our parents. They become concerned for the safety of their children.

Q. Have your Districts taken a position regarding the Shoreham plant and/or LILCO's plans for protective actions for l

l schoolchildren?

A. (Brodsky, Rossi) Yes. The Middle Country Central School District first established its position in 1983. At that j time, Middle Country, after Board of Education public meetings and meetings with the Middle Country Parents Teachers Associa-1 l tion, determined that the District could not adequately evacuate or otherwise protect its child'ren in the taent of a serious 1

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1 Shoreham. emergency. LILCO assumed that schools could utilize existing resources and snow emergency. early dismissal plans in order to get children home or to relocation centers during a l Shoreham emergency. We concluded, however, that the limited road network on Long Island, combined with our limited resources, the likelihood that school personnel, including bus drivers, would experic7 e role conflict, the lack of parental or adult super-v! Lon of children in the event of an early dismissal or any supervision in the event of evacuation, the lack of adequate school buildings to provide safe sheltering for our children, as well as parents' desires to reunite with their children at the schools, made effective planning impossible. For these reasons, the District decided in 1983 that LILCO's planning for schools was unworkable and failed to adequately protect tre safety of the District's schoolchildren. Middla Country. set forth the.c7 reasons for its opposit. ion to LILCO's Plan in a Middle Country School District Board of Education Resolution dated November 7, 1983, which is Attachment 9 to this testimony, and was included in testimeny previously submitted in this Shoreham proceeding.

S33 Jeffers and Rossi, ff. Tr. 3087, Att. 1 (January 25, 1984).

That resolution continues to represent our District's policy.

(Muto, Smith) We are also familiar with the position taken by our School District in opposition to the LILCO Plan as it relates to schools, as evidenced by a resolution passed by the Middle Island Central School Board (now the Longwood Central l

I

School District) on September 29, 1983. Sag Attachment 10 hereto and the testimony previously submitted in this Shoreham pro-ceeding (Muto 2nd Smith, ff. Tr. 3087, Att. 1 (January 25, 1984)). After a review of the schools-related provisions of LILCO's Plan, the District concluded at that time that it could not safely or successfully implement early dismissal, evacuation, or sheltering for a variety of reasons, including the role con-flict which would be experienced by school personnel. That September 29, 1983 resolution continues to represent our Dis-trict's position regarding LILCO's Plan.

(Petrilak) The Mt. Sinal School District has also been concerned with matters related to emergency planning for Shoreham since 1983. In 1963, after public meetings and hearings, the Mt.

Sinal Board of Education determined that it could not safely evacuate or otherwise protect its children during a Shoreham emergency. A copy of our resolution, dated October 18, 1983, and a copy of an undated resolution are Attachment 11 hereto. These resolutions were also included in testimony previously submitted in this proceeding. Sag Petrilak, ff. Tr. 3087, Att. 1 (January 25, 1984. Th? Mt. Sinai Parents Teachers Organization and the Mt. Sinal Teachers Association concurred with the conclusion reached by the Board of Education, and those resolutions are included in Attachment 11.

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l More recently, the Mt. Sinai Board of Education reviewed i

LILCO's single-wave school evacuation plan, as set forth in 1 Revision 9 of LILCO's Plan. The Board also found this new LILCO plan to be inadequate, and determined that Mt. Sinal would not allow LILCO employees to transport its schoolchildren in the event of a Shoreham emergency. The Board also determined that it would not authorize Mt. Sinal's bus contractor to allow LILCO employees to use the buses under contract to the District in the event of a Shoreham emergency. A copy of this resolution, and another resolution authorizing me to represent the Board of Education in this proceeding, both dated March 15, 1988, are included in Attactment 11 to this testimony.

(Suprina) The Riverhead Central School District has passed no formal resolation taking a positit.1 on Shoreham. The District's Board of Education, however, has been advised by me of my testimony herein, and has approved my participation.

(Koenig) The East Meadow District has taken no formal ,

position on Shoreham, except to advise the Red Cross and LILCO that our schools cannot be used as congregate care centers in a Shoreham emergency.

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II. Purcose of Testimony and Summary of Conclusions Q. What is the purpose of your testimony?

A. (All) We are providing testimony regarding whether EPZ school districts have sufficient school bus drivers and buses to carry out protectiva actions for schoolchildren in the event of a Shoreham accident. Specifically, our testimony addresses the single-wave evacuation of EPZ schools proposed by LILCO in Revision 9 of its emergency plan, as well as the early dismissal of schools prcposed by LILCO. The issue concerning the avail-ability of school bus drivers arises in the context of potential "role conflict" among such drivers.

Q. What contention is addressed in this testimony?

A. (All) Contention 25.C which states:

Intervenors contend that the LILCO Plan fails to comply with 10 CFR 55 50.47(a)(1),

50.47(b)(1), and 50.47(b)(3), because the Plan fails to address the problem of emergency worker role conflict. Intervenors contend that a substantial number of the emergency workers relied upon under the LILCO Plan will resolve such conflicts by attending to their other obligations prior to, or in lieu of per-forming the emergency functions assigned to them by LILCO. In the absence of such workers, the LILCO Plan cannot and will not be implemented, and thore can be no finding of compliance with 10 CFR SS 50.47(a)(1),

50.47(b), and NUREG-0654 S II. The emergency workers likely to experience role conf 2ict, -

the type of conflict, and the effect of such conflict upon the implementability of the

LILCO Plan are set forth in Sections A-F below.

A *

  • Contention 25.C. The LILCO Plan fails to take into account the role conflict that will be experienced by school bus drivers. In fact, a substantial number of school bus drivers are likely to attend to the safety of their own families before they report (if they report at all) to perform the bus driving duties which LILCO assumes will be performed. Role con-flict of school bus drivers will mean that neither school buses nor' school bus drivers will be available to implement the LILCO Plan.

Without an adequate number of buses or bus drivers, LILCO will be incapable of imple-menting the following' protective actions:

1. early dismissal of schools (necessary under the LILCO Plan to permit schoolchildren to be sheltered or to evacuate with their-parents);
2. evacuation of schools.

Q. What do you mean by "role conflict" in the context of this contention?

A. (All) Role conflict describes the situation whereby an individual is confronted with contradictory demands on his or her sense of loyalty as a result of membership in different groups.

In the context of this proceeding, an emergency at Shoreham would present the following conflict: whether a bus driver, on being alerted to the fact of a Shoreham emergency, would first drive his or her bus in order to evacuate or early dismiss school-children; or whether the driver would attend first to the safety of his or her own family members or his or her own safety.

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III. LILCO's Plan for School Evacuation Q. What do you understand is proposed by Revision 9 of LILCO's Plan, with respect to school evacuation and the potential role conflict problem among school bus drivers under contract to and employed by the school districts?

A. (All) In a serious emergency at Shoreham, LILCO pro-poses to carry out a single-wave evacuation of all EPZ schools.

By single-wave evacuation, we mean that LILCO proposes to evacuate all the schools within the 10-mile EPZ at about the same time (assuming an evacuation of the entire EPZ were recommended),

by utilizing enough buses and drivers so that each bus and driver would be used only once.

Q. How many buses and drivers would be required for such a single-wave evacuation?

A. (All) It is our understanding that one of LILCO's school witnesses, Mr. Crocker, stated during his deposition that 477 drivers and buses would be required. Sag Deposition of Douglas Crocker (February 2, 1988) (hereafter, "Crocker deposi-tion") at 85. According to Mr. Crocker, LILCO assumes 60 students per bus for elementary and junior high students and 40 l students per bus for high school students. Id. at 160-62.

Apparently, Mr. Crocker was referring to the number of buses that l

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would be needed to evacuate all public schools, nursery schools, and private and parochial schools within the EPZ. Id. at 85. At least, LILCO's Plan also indicates that the number of buses that would be required for evacuation would be 477, broken down as follows: 448 for public schools; 15 for nursery schools; and 14 for private and parochial schools. Thus, according to the LILCO Plan, a total of 477 buses would be needed to evacuate all schools within the EPZ in a single wave. Sjltg LILCO Plan, OPIP 3.6.5, Attachment 3a. For purposes of this testimony, we will use the 477, 60- and 40-passenger bus figure set forth in LILCO's Plan as a basis for our evaluation of LILCO's proposed single-wave evacuation.

Q. Do the schools in the EPZ have sufficient regular school bus drivers to carry out the single-wave evacuation pro-posed by LILCO?

l A. (All) No, but the exact extent of the shortfall is l

l unclear. According to Mr. Crocker, LILCO believes that the EPZ' school districts have available to them 356 regular school bus drivers and buses, i.e., those drivers regularly employed by or l

under contract to the school districts. Crocker deposition at

86. According to LILCO's Plan, however, the EPZ schools only have 324 buses available to them. Sag LILCO Plan, OPIP 3.6.5, Attachment 3a. Thus, depending upon whether LILCO's witness or l - - _ , .

its Plan is relied upon, the shortfall of buses and drivers is between 121 and 153.

Q. How does LILCO intend to compensate for this shortfall of drivers and buses?

A. (All) LILCO proposes to use its employees to make up for the shortfall. Under LILCO's Plan, it is assumed that the schools' 324 or 336 regular drivers would use their regular buses to pick up schoolchildren at the schools and transport them to either the Nassau Community College or the Nassau Coliseum, or to some other location if the schools should so direct. At the same time, LILCO proposes to provide a sufficient number of its own employees (either 121 or 153 LILCO drivers) to pick up additional buses at bus yards, proceed to schools, pick up the school-children, and proceed to the Nassau Community College or the Coliseum. In this way, LILCO assumes that all schoolchildren could be evacuated in one wave.

Q. What does LILCO propose to do if some or all of the schools' regular drivers are not available to drive?

A. (All) Should some or all of the regular school bus drivers fail to drive their buses, LILCO proposes to provide additional LILCO personnel to drive the buses normally driven by the regular drivers. The LILCO drivers would pick up each school

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district's regular buses at the district's regular bus yard (s) --

stch as at the Riverhead bus yard in Riverhead or, for Longwood, at the contractors' bus yards in Middle Island and Yaphank. The LILCO drivers, driving either the school districts' "regular" buses (or one of LILCO's "supplementary" buses), would consult a "packet of instructions" provided by LILCO to determine the directions to the designated schools, and then would drive to the schools ordinarily serviced by the non-available regular drivers to' pick up the schoolchildren and drive them to the Coliseum or the Nassau Community College. In this way, with a combination of regular and LILCO drivers -- or solely with LILCO drivers, if no regular school bus drivers reported to the bus yards --

LILCO suggests that a single-wave evacuation of all EPZ schools could be carried out.

Q. Do you agree with LILCO that thare are insufficient regular buses and drivers for the schools themselves to carry out a single-wave evacuation?

A. (All) Yes, we agree that there are insufficient regu-lar buses and drivers for the schools themselves to carry out a single-wave evacuation of their schoolchildren. This point has previously been addressed in Section I above. Sev.eral additional points need to be emphasized, however.

First, we do not have enough regular buses and drivers to transport all schoolchildren who regularly ride buses at a single time. That is why multiple school bus runs are used in both the morning and the afternoon in transpcrting schoolchildren to and from our public, parochial and private schools. Even then, it must te recognized that some students in most districts walk to school. In a Shoreham evacuation, the normal bus resources (assuming they are available) would presumably be used to trans-port all students, not just the regular riders. Thus, it is clear that we do not have an adequate number of buses or bus drivers to implement a single-wave evacuation of our schools.

Indeed, based upon our knowledge of the schools on Long Island, it is our opinion that no school district has sufficient re-sources to transport all its students at the same time.

Second, we disagree with the figures set forth in LILCO's Plan regarding the number of children who attend the EPZ schools and would need to be transported. For example, for the Ridge Elementary School in the Longwood Central School District, LILCO's Plan indicates that 1,275 students are enrolled, and that, of these, 1,21I would require evacuation transportation.

Egg LILCO Plan, OP:P 3.6.5, Attachment 3a. By using the lower .

figure of 1,212 students, LILCO assumes that 21 buses, carrying an Tverage of 58 children, would be sufficient to evacuate the Ridge Elementary School. It would hatte been more appropriate, however, for LII CO to have used the larger 1,275 enrollment

e e

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figure as the basis for determining transportation needs, since this is the total school enrollment figure. Using the total enrollment figure, each bus would have to carry 61 elementary children on the long trip to Nassau County (which would not be acceptable, as discussed elsewhere in this testimony). There are several reasons. Enrollment at our schools constantly increases.

Further, it is simply not possible to predict on any particular day how many children will be absent from school. To be prudent, therefore, the higher enrollment figure should have been used by LILCO in calculating the number of buses potentially needed to evacuate the Ridge Elementary or any other school.

Moreover, LILCO's use of enrollment figures that are lower than that of total enrollment is all the more in error because LILCO has generally understated the actual school enrollment l

figures for the EPZ schools.

l (Muto, Smith) LILCO states in OPIP 3.6.5, Attachment 3a, that 8,673 students attend our six public schools. In actuality, 9,465 students attend these schools.1/

(Suprina, Doherty) LILCO states (also in OPIP 3.6.5, I

Attachment 3a) that 2,669 students attend our four schools located within the EPZ. We have 2,705 students attending those schools.

1/ This figure does not include those students that walk to and from school and would be higher were these students included.

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(Petrilak) LILCO's Attachment 3a to OPIP 3.6.5 neglects to include our high school students attending school in Port Jefferson. The total Mt. Sinal student enrollment in-cluding these students is 2,332, not 1,830 as stated by LILCO.

(All) In fact, LILCO has used estimated enrollment numbers with respect to every EPZ school listed in LILCO Plan, OPIP 3.6.5, Attachment 3a. If actual enrollment numbers were used for the EPZ schools, many schools would not meet the 40/high school and 60/other school capacity figures used by LILCO to calculate the number of buses and drivers needed to implement LILCO's proposed single-wave evacuation. Indeed, even if the estimated enrolllaent figures set forth in LILCO's Plan are used, it is clear that LILCO has underestimated the number of buses needed to evacuate the EPZ schools. As a result, LILCO's bus numbers would require more children per bus than LILCO claims would be the case. Using LILCO's estimated enrollment figures, the over-capacities are as follows:

Additional # of Buses Needed to Hich Schools Exceedino 40/ bus Get Back to 40/ Bus Shoreham-Wading River 52.53/ bus 5 more buses Rocky Point Jr./Sr. High 52.17/ bus 7 more buses l Longwood 52.19/ bus 11 more buses Miller Place 50.44/ bus 4 more buses Vandermeulen High 52.27/ bus 7 more buses

Comsewogue High 52.11/ bus 7 more buses Riverhead 50.95/ bus 5 more buses I Additional # of Elementary and Jr. Highs Buses Needed to Exceedio.g 60/ bus Get Back to 60/ Bus Shoreham-Wading River Middle 62.25/ bus 1 more bus Joseph A. Edgar 61.ll/ bus 1 more bus Ridge Elementary 60.71/ bus 1 more bus West Middle Island Elementary 62.00/ bus 1 more bus Coram Elementary 61.93/ bus 1 more bus Longwood Middle /Jr. High 60.90/ bus 1 more bus Charles E. Walters Elementary 61.29/ bus 1 more bus North Country Road 60.71/ bus 1 more bus A'n drew Muller Primary 60.46/ bus 1 more bus Mt. Sinal Jr. 61.71/ bus 1 more bus Mt. Sinal Elementary 60.37/ bus 1 more bus Port Jefferson Elementary 62.55/ bus 1 more bus Clinton Avenue Elementary 61.50/ bus 1 more bus l

l Eagle Elementary 62.61/ bus 1 more bus South Street 62.50/ bus 1 more bus Dayton Avenue 60.71/ bus 1 more bus Pulaski Street Elementary 60.44/ bus 1 more bus Riverhead Jr. High 62.91/ bus 1 more bus l

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l _ _ _ _

The foregoing figures indicate that LILCO has significantly underestimated the number of buses needed t0 effect a single-wave evacuation of our schools. In fact, LILCO has underestimated by at least 64 buses. This means that the single-wave evacuation proposed by LILCO is unimplementable on its face.

Third, the degree of underestimation is, in fact, greater than 64 buses. LILCO's assumption of 40 high school students per bus on a trip to Nassau County appears appropriate for 20-seat buses. The estimate of 60 junior high and elementary students per bus is nati. appropriate. For elementary students, 60 students per 20-seat bus (i.e., three per seat) would be very crowded and, inappropriate for a long trip. For junior high students, 60 students per 20-seat' bus (i.e., three per seat) would be too many even for a short trip. Sixty students per 20-seat bus means that each student has only 13 inches of rump space. Junior high students are not small and would not be able to fit three per seat. Moreover, during the winter months students would be wearing bulky coats, which always take up considerable space.

j (Petrilak, Doherty, Smith) In our experience, one must be careful about crowding buses even under the best of cir-cumstances. A crowded bus leads to extra noise and confusion, which is very distracting to the driver and poses a potential safety hazard. We are very careful to monitor crowding and would t

permit it, if at all, only on short trips involving the trans-l l

l 41 _

. . l portation of elementary students (10 miles or.20 minutes or less) and only when there are several adults, besides the driver, to monitor the situation. For any trip over 10 miles, we would never load the bus three per seat, but would always place only two students per seat, regardless of the age or size of the students.

We would never allow a crowded bus on a long trip, such as to the Nassau Coliseum, no matter how many adults were along. For such a long trip -- especially in the possibly congested conditions of a Shoreham evacuation -- we would not permit more than two children per seat of any age or a maximum of iQ children per bus. LILCO's i

plan to have 60 children per 20-seat bus is not acceptable and is not safe.

(All) Finally, LILCO's bus figures are inaccurate in that they overstate the number of regular 20-seat buses available to the schools. According to the LILCO Plan, Mt. Sinai School District currently has contracts for the use of 30 buses, Riverhead School District owns 47, and Longwood tentral School District contracts for the use of 100 buses. LILCO Plan, OPIP 3.6.5, Attachment 3a. Leaving aside our strong disagreement with LILCO regarding the number of students that can be put safely on any of these buses, these figures are still not accurate.

(Petrilak) Mt. Sinal has contracts with Harborview Bus Company for only 27 buses, not 30 buses. All 27 buses have either i

m

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l 20 or 22 seats. Of these 27 buses, 26 are available for the transportation of public schoolchildren ~. l (Doherty) Riverhead owns 56 buses of which only 39 are 20 or 22 seat, full-size buses, not 47 as LILCO states in its Plan. Of these 39 regular school buses, only 28 are readily available for the transportation of public schoolchildren. The remaining 13 full passenger capacity buses are devoted to the transportation of private and parochial schoolchildren.

(Smith) Longwood has contracts with Suburbia Bus Company for 89 20-seat buses, not 100 buses. Of those 89 buses, only. 70 are available for the transportation of public schoolchildren. ,

(All) In sum, therefore, not only do the schools not have enough buses to transport students in a single wave l themselves, but LILCO has underestimated the number of buses that would be required and has overestimated the number of buses and drivers that would be available. As a result, we find LILCO's Plan seriously deficient.

IV. Availability of Recular Bus Drivers Q. LILCO's Plan begins with the premise that the EPZ school districts' regular bus drivers -- 324 to 356 in number -- or at l

l I

least many of them, would be available and willing to drive in the event of a Shoreham emergency requiring evacuation. Do you agree with that premise?

A. (All) No. For a variety of reasons, it is unlikely that we would be able to get many of our regular drivers to the schools promptly were an emergency at Shoreham to occur. First, unlike an early dismissal due to inclement weather, when drivers are aware that the weather is bad and that an early dismissal may be considered, our drivers might have no forewarning of a Shoreham emergency that necessitates evacuation. In that circumstance, it is unlikely that we would be able to contact many of our drivers.

School bus drivers are not at schools or at their bus companies on a full'-ti.me basis. Once they finish their morning runs, the drivers normally are free until their afternoon runs, unless they have noon kindergarten runs or special activities runs. We might be able to reach them if they were in a bus equipped with a radio.

We also might be able to reach them if they were at home and if the telephone circuitry were not overloaded, as might well be the case in the event of a Shoreham emergency. Otherwise, however, they could not be reached. You have to expect under these cir-cumstances that many of our regular bus drivers would not be at home and could not be reached if needed.

Second, assuming that we would be able to contact our bus l drivers either at home, at bus yards, or while they were in their l

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buses, it is our strong belief that many drivers would refuse to drive their buses -- at least until they assured themselves that their f'amilies were not in danger. Virtually all of the EPZ drivers reside in or near the area of risk surrounding the Shoreham plant. We think it likely that during an emergency, the first and foremost concern of most people living in this area, including our school bus drivers, would be to ensure that family members and friends are transported safely out of the danger zone.

Thus, rather than report first to drive buses, the drivers would most likely go first to attend to the needs of others.

Our school bus drivers are part-time employees of the school districts or bus companies, not full-time, professionally trained emergency workers. As such, they are not, nor could we expect them to be, committed to tending to the needs of their part-time employer rather than to the safety of their family members or loved ones during a Shoreham emergency. It is simply not rational l in our opinion to suggest that part-time school bus drivers would determine that, in an emergency, his or her commitment to the school district would outweigh the commitment and responsibility owed to his or her family.

To our knowledge, there exist various data which support our views regarding the potential for role conflict among our bus drivers. For example, we are aware that in 1986, 255 school bus drivers from school districts in or near the 10-mile Shoreham EPZ l

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i signed statements attesting to the fact that they would not drive

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their buses in the event of a Shoreham emergency. Egg Attachment 12 to this testimony, which includes a representative copy of the

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statements that were signed, and a breakdown of the number of bus drivers from each school district that signed statements.

We also are aware of a survey conducted of trained emergency workers during 1982 (volunteer firefighters), that indicated that many of these trained emergency workers would attend to the safety of their families in the event of a Shoreham emergency before reporting to perform their firefighting roles. We also understand that Suffolk County recently had a similar survey conducted, which revealed that a clear majority of firefighters would continue to resolve the role conflict dilemma in favor of caring for their families. Egg Testimony of Stephen Cole, Ralph H. Turner and Alan H. Barton on the Remand of Contention 25.C--Role Conflict of School Bus Drivers (April 13, 1988). It would be unrealistic to expect more of part-time school bus drivers than could be expected of trained emergency workers, such as firefighters.

We are also awatt of another survey which was conducted in 1982. This survey questioned school bus drivers employed by school districts located within the 10-mile EPZ, and found that 69 percent of the drivers queried would first ensure t.ha t their ,

families were safely out of the EPZ before reporting to drive a school bus. Based upon the previously referenced bus driver x^

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statements of 1986, where 255 bus drivers indicated that they would not drive a bus during a Shoreham emergency, we believe the number who would not report to drive is actually higher than in-dicated by the 1982 survey.

Finally, it should be noted that a vast majority of our school bus drivers are women, many of whom are of child-bearing age. It is our understanding that LILCO advises its women LERO workers who might be pregnant to consider carefully whether to enter the EPZ. Indeed, LILCO gives them the option to be assigned to jobs outside the EPZ. LILCO Plan, OPIP 3.6.4, Attachment 2; Crocker deposition at 115-18.2/ Our women bus drivers would have to be given the same choice. If given that choice, we believe their overwhelming decision would be to leave the EPZ and not to drive our buses.

(Brodsky, Rossi) In 1983, Middle Country performed a survey of bus drivers under contract to and employed by the District, to ascertain whether they would drive buses during a Shoreham emergency. The results of this survey indicated that a majority of our drivers would suffer severe role conflict, if they had to choose between their duty to the District's schoolchildren and their duty to the safety of their own families. Sixty-two responses were received. Among the 62 respondents, only three 2,/ Curiously, all prior versions of LILCO's Plan stated that all lek 3 women of childbearing age should not accept assignment within the EPZ.

drivers indicated that they would report to work before ensuring the safety of their own families. Fifty-nine respondents stated that they would first attend to the needs of their own families in the event of a Shoreham emergency.

(Petrilak) An informal survey of Mt. Sinal employees conducted by the Mt. Sinal Teachers Union in 1983 also indicated that role conflict would be a serious problem d'uring a Shoreham emergency.

(All) In sum, it is our strongly held view that a large number of regular school bus drivers would not be available to drive in the event of a Shoreham emergency, either because they cannot be reached or because of role conflict. Thus, for a single-wave evacuation to be possible, it would have to be effected through the use of LERO drivers. Our school districts, however, would not permit LEW: Gr n ars to transport our schoolchildren.

V. There Will Be No Implementation of LILCO's Procosal for LERO to Drive School Buses Q. Based on your earlier answers, it is clear that your Districts could not implement a single-wave evacuation of school-children using your regular buses and drivers. If LERO drivers arrived at your bus yards and offered to drive the buses owned by your District or buses under contract to your School District, or

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if LERO drivers arrived at your schools with school buses, would 1 l

that make a single-wave evacuation possible? I

)

A. (All) No.

Q. Why not?

-A. (All) There are at least three reasons. First, the school districts would not permit LERO personnel to drive their buses or to transport their schoolchildren. Second, there is no basis, and in fact LILCO is wrong in assuming, that the buses regularly used by the school districts would necessarily be at the bus yards, even if it is assumed for purposes of this testimony that the schools would permit LILCO to use their buses if they were available. Third, LILCO's school evacuation plan is seriously unrealistic from a logistical point of view; it simply cannot work. We discuss each of these matters below.

Schools Would Not Permit LERO Personnel to Drive Their Children (All) It would be contrary to our settled trans-portation policies to permit unapproved LERO personnel to trans-port our children. We would not allow that to happen, even in the event of a serious Shoreham emergency.

1 (Brodsky, Doherty, Muto, Petrilak, Rossi, Smith, Suprina) First, we do not believe that LILCO employees would be able to safely and efficiently transport schoolchildren from the schools to reception centers in an emergency. As discussed pre-viously, the safe transportation of schoolchildren requires ex-tensive training, plus extensive actual experience. School districts typically provide at least 40-50 hours of training to drivers just during their first year on the job. Drivers are instructed in how to operate a bus and how to handle children.

Training includes behind-the-wheel instruction in the operation of a bus, instruction regarding defensive driving techniques and driving under inclement weather conditions, classroom training, instr.uction in child psychology, first aid, and how to safely transport schoolchildren during inclement weather conditions. In addition, training and special instruction are provided to those who will be transporting handicapped children. Drivers also must become familiar with bus routes during their training. Before our drivers are allowed to transport children, they must be certified in accordance with State law provisions to be morally and physically qualified, as well as competent to transport school-children. Accordingly, the transportation directors of our Districts personally interview and screen each and every driver candidate for our Districts. The District Superintendents must approve the moral fitness of each and every driver for their re-spective District. We also require our drivers to submit character references and undergo fingerprinting so that we may

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ascertain whether any applicant has a criminal record. The parents in our Districts expect and demand that the kinds'of pre-cautions we have described are taken, so that it can be reasonably assumed that the drivers to whom we entrust their children are qualified to safely and proficiently discharge their duties as school bus drivers. LERO personnel will not have met these re-quirements. Thus, we could not permit them to transport our schoolchildren.

(All) Further, we must emphasize that a critical part of training is the actual experience that can be gained from driving children. The transportation of schoolchildren is not an easy or routine task in the best of circumstances. The drivers must learn, for example, to deal with children in a crowded and sometimes chaotic situation. With experience, it is possible to learn how to cepe with and handle such situations. Moreover, it is our opinion that, as a general proposition, the successful drivers are the ones that the children come to know and trust.

This probably explains why we often have difficulties with substi-tute drivers, even though our substitutes all have had extensive training. They simply do not have the day-to-day, first-hand experience that is necessary and the children do not know them as well as the regular drivers. LILCO's "substitutes" present a far greater problem.

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It is our opinion that the training that will allegedly be provided by LILCO to the LERO personnel designated to drive school buses is inadequate. Accordir.g to LILCO, LERO personnel will attain a license to drive a bus and will attend four hours of classroom training concerning emergency planning and the Shoreham plant. In our opinion, LILCO's employees, if trained by LILCO in this manner, would be incapable of safely transporting our school-children. The recent Licensing Board decision (LBP-88-2), which questioned the adequacy of LILCO's training program in general, reinforces our belief that LILCO's training program is deficient.

We could not give assurance to our parents that LILCO's drivers are either qualified or competent to safely transport school-children. In these circumstances, we would refuse to permit LILCO's drivers to transport our children.

We are aware that LILCO proposes to have school teachers or other school personnel travel on LERO-driven buses along with the LERO drivers and evacuated schoolchildren. This is no solution.

There still would be an unapproved LILCO employee driving the bus.

Further, teachers and other personnel would likely be as subject to role conflict as other personnel. In our opinion, it is not reasonable to believe that as many as 477 (actually more would be needed when LILCO's underestimation is corrected) school personnel would agree to accompany LILCO's drivers during a Shoreham emer-gency (assuming the necessary buses are made available to LILCO).

Thus, in accordance with LILCO's provisions, and even assuming l

l

buses were available, some of our children would be riding un-supervised and under adverse conditions on overcrowded buses driven by a LILCO employee for 30 or 40 miles. This is un-acceptable.

There is a further reason why we could never agree to permit LERO personnel to transport our schoolchildren. LILCO's Plan calls for the buses to carry our students to the Nassau Coliseum or the Nassau Community College. But LILCO's Plan is based on the assumption that the Nassau County Executive would give permission to LILCO to use these facilities as relocation centers for the approximately 28,000 children who attend public schools within the Shoreham 10-mile EPZ. LILCO Plan, Appendix A, at II-20, II-20a.

In fact, however, the Nassau ~ County Executive, Mr. Gulotta, has made clear that these facilities are pj;Lt a v a i l a b l e for LILCO's use. S_q.e Attachment 13 hereto, which contains a copy of Mr.

Gulotta's letter to W. Catocosinos, LILCO's Chairman, dated March 15, 1988, a copy of his letter to the NRC dated July 1, 1987 and a copy of the Nassau County Board of Supervisors Resolution dated June 16, 1986. We would never allow our children to be trans-ported to facilities whose availability is so uncertain.

Further, the LILCO Plan offers no adequate assurance that even if "permissic"." were obtained to use the Nassau Community College or Coliseum, that those facilities would be appropriate relocation centers for schoolchildren. LILCO proposes to send up

l l

l 2

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to 28,000 children to those facilities. LILCO's bus drivers would l be given responsibility for supervising the children both on the buses and at the facilities, once reached. Even if teachers, who would also be subject to role conflict, rode on the buses, they would be in no better position than LILCO's personnel to supervise such a large number of children under the circumstances that would likely exist in the event of a radiological emergency.

Moreover, the LILCO Plan contains no provision for the decon-tamination or monitoring of schoolchildren prior to their arrival at the Coliseum or the Community College. As a result, even if our students would somehow manage to escape uncontaminated from the EPZ, they would again face the risk of contamination from contact with contaminated persons relocated to, but not decontami-nated or monitored at the Coliseum ~ or Community College. As children are reported to be particularly susceptible to the harmful effects of radiation, this lack of planning for decontami-nation and monitoring is serious.

The LILCO Plan also lacks adequate provision for reuniting parents with schoolchildren at the relocation centers. Should children actually be transported pursuant to the LILCO Plan, parents would not readily know to which, if any, relocation center their child had been taken. It is easy to imagine tne chaos and confusion that would result from parents converging upon the LILCO-designated relocation centers, in an effort to locate their

children among 28,000.other children. In some instances, brothers and sisters will likely be relocated to different facilities.

(Petrile i in Mt. Sinai, for example, LILCO proposes

- that all elementary and jun'ior high students are to be relocated to the Community College; an older brother or sister attending high school, however, would be relocated to the Coliseum, thereby further complicating any attempt by parents to reunite with children.

(All) LILCO's Plan also overlooks the fact that most of our Suffolk County school busee woald be prohibited from entering Nassau County. A 1987 Nassau County law makes it illegal for an unlicensed suffolk County bus to enter Nassau County. To,obtain a i license, an applicant must pay a license application fee, comply with a variety of requirements including supplying information regarding he bus owner (s) and all bus drivers, in addition to submitting all buses for which a license is sought to a Nassau County official for extensive inspection and testing. Only a handful of our buses have been licensed to enter Nassau County.

(Doherty) Eighteen of our buses are licensed to entar Nassau County.

(Petrilak, Rossi, Smith) None of our buses is licensed to enter Nassau County.

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1 I

l (All) There is an additional reason as well why we  ;

would not and could not permit LERO drivers to transport our schoolchildren. It appears to us that LILCO has been somewhat less than entirely straightforward in its approach to the school evacuation issue. Our school districts have recently received letters from LILCO concerning LILCO's Revision 9, particularly as it, pertains to schoolchildren. The letters purport to set forth what would happen in the event of a Shoreham emergency, including a portrayal of the actions of Suffolk Cou1ty. Our review of the 1e".ers raises a serious question !n our minds, as to their accutacy. Suffolk County has previously made clear that it does not intend to follow the LILCO Plan in the event of an emergency.

Further, we have received a letter from Suffolk County Executive Patrick Halp$n, which responds in part to LILCO's characteriza~-

tions of likely County action in the event of a Shoreham emergency. Copies of the six different LILCO form letters sent to schools and Mr. Halpin's letter in response to the LILCO letters are attached to this testimony as Attachment 14.

What "e derive from this exchange of letters is that there is no agreement between LILCO and Suffolk County regarding the i actions that would be taken in the event of a Shoreham emergency.

School districts in New York State, although independent political subdivisions of their own, traditionally work closely with and show deference to local governments in matters such as emergency planning and preparedness. Our Dist'ricts have had t' e opportunity l

l l

over the years to work closely with Suffolk County and as a result, have become familiar with the County's determinations re-garding the feasibility of effective emergency planning and pre-paredness on Long Island. LILCO's letter to us appears to ignore those County determinations. We, on the other hand, as members of the Long Island community, cannot ignore those County determina-tions. The County haa determined that in the event of an emergency, it would be best not to follow or rely upon the LILCO Plan oJ school-related provisions in any way. We agree with that determination.

In short, LILCO's plan for school evacuation is, in our opinion, fundamentally flawed, and we could not and would not jeopardize the welfare and safety of our schoolchildren by allowing them to be transported as proposed by LILCO.

Many of the Recular School Buses Will Not Be Available (All) LILCO assumes that even if regular school bus drivers are not available in the event of a Shoreham emergency, LERO's drivers would have ready access to the buses e'ther owned by or under contract to the school districts. 19.g LILCO Plan, Appendix A, at II-20a. We reiterate that we would not release our buses to LILCO or its employees. Setting that fact aside for the i

l moment, nu ever, the fact is that in many instances, the regular i

~

school buses would n9.t be at the bus yards, ant. thus LERO drivers, l

even if they showed up at bus yards and were allowed te drive the buses owned by or under contract to the school districts, would have no buses to drive.

(Rossi, Doherty, Smith) Should an emergency occur during the day, sor.e buses might be at the bus yards. Many buses, however, would be with the regular school bus drivers, either on the roads or at their homes, or some other location. During the day,.it is normal to find less than five percent of our buses at the bus yards at any one time. As previously noted, many drivers are on the road most of the day, many keep their buses all day and some keep their buses overnight.

(All) If the bus drivers are in possession of their buses at the time of a Shoreham emergency, and decide to resolve i

l role conflict in favor of their families (as we think would be the case), these buses may never get back to the yards to be available for LERO's drivers. Thus, LILCO would not have access to our buses (or the buses owned by or under contract to other school districts), and would not have enough ouses to implement a single-uave evacuation.

i LILCO'S Plan Is a locistical Nichtmare (Rossi, Doherty, Smith) LILCO's "plan" for evacuation of schoolchildren is seriously defective, in part because'it re-l

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flects a lack of understanding with respect to the extreme logistical difficulties which it presents. To put this matter in perspective, it is necessary to compare the logistical factors involved in school transportation on a normal day with those which would most likely be present in a Shoreham emergency.

On a normal school day, school transportation is complex and complicated, to say the leasti. Our bus drivers who do not keep their buses overnight must first report to bus yards to obtain their buses. All drivers must conduct a pre-trip inspection of their buses, any problems must be corrected, and all gas tanks must be filled. If, as is usual, some drivers are unavailable, approved substitutes must be contacted. It is often not possible to know, however, whether all drivers will be available (or whether all buses will be functional) until the last moment. As a result, there are always a host of last-minute deeisions to be made regarding who will handle what bus routes, which routes will be delayed, who must be contacted to warn of delays, etc. The bus yards are crowded during these times and the bus yards' dis-patchers, maintenance and management personnel are very busy.

On a normal school day, virtually every driver makes multiple bus trips. Drivers do not just go to one school but, rather, typically go to several schools. Our schools generally have staggered opening and closing times to permit multiple use of bus and driver res'ources. However, the scheduling of buses is not J

limited only to the morning, afternoon runs and mid-day kindergarten runs. To the contrary, on any given day a large number ef buses are used for field trips, sporting events, and similar activities. Thus, during the day almost none of our buses would be at the bus yards. In addition, the buses that are at the yards between runs during the day are often garaged for maintenance work, and thus are not immediately available for use.

Typically, a district will have three or four buses out of service and undergoing maintenance on any given day. Finally, most of our buses that are not in service at any particular time during the day will be in the custody of drivers between runs. As previously noted, most drivers keep their buses with them during the day and many even keep their buses overnight.

The scheduling of buses is an intricate process at the schools as well. Each bus has an assigned location at the school (s) serviced. Schools generally have very limited parking space, and thus buses are scheduled to arrive and depart over time in order to reduce congestion. Even in the best of circumstances, i

however, the scene at schools during opening and closing periods is a very busy one, with buses arriving and departing and children getting to their proper locations for boarding or leaving their buses. School officials, and school traffic guards, play a critical role at the schools in ensuring safe drop off and pick up of the schoolchildren. Moreover, extensive training regarding the

pick up and drop off phases of bus transportation is provided to l

our drivers, since this is a circumstance which presents many opportunities for accidents.

(Smith) The middle school and junior high school in the Longwood Central School District operate on a split session schedule within the same building. The middle school meets from 7:05 a.m. to 12 noon; the junior high meets from 12:10 p.m. to 5:20 p.m. Thus, we not' only mast implement multiple bus runs to transport the kindergarten, elementary and school children to and from school, but we also must implement additional mid-day bus runs to accommodate the split session schedule. Under these cir-cumstances, even an early dismissal due to inclement weather (but with ample forewarning) is difficult to implement.

We presently require three "waves" of bus runs every morning and afternoon just to transport our schoolchildren to and from school. We also transport nearly 907 private and parochial school students up to 28 miles outside the District's boundaries. In short, we have buses going in and out of the District all day long.

l (Rossi) We presently require five bus runs during the course of the day to transport our schoolchildren to and from

school. The drivers responsible for our kindergarten runs are on I

the road with their b'ises most of the day. We also tran* port

, approximately 900 students to 39 private and parochial schools, e

t

which requires our drivers to travel up to 29 miles f rom ~ the Middle Country School District, through the EPZ and back.

(Doherty) We presently perform three bus runs every morning and every afternoon just to transport our schoolchildren to and from school. We also require 13 runs to transport our 369 private and parochial school stu6 ants.

(Petrilak) We require two bus runs in both the morning and the afternoon, in addition to nine kindergarten runs, to transport all our schoolchildren to and from school daily. We also transport 113 schoolchildren to and from 21 private and parochial schools on a daily basis.

(All) The reality thus is as follows: on a "normal" day, there is constant bus activity throughout the day; at any particular time, only a portion of our buses are at the yards and available for use; the bus dispatch system is complex and, by nature, involves many last-minute switches and scheduling changes, and is dependent upon trained and experienced dispatchers knowing where to send particular buses; and conditions at schools are l

crowded, even with staggered arrival and departure times for our buses.

Given the foregoing, it is our opinion that LILCO's single-wave evacuation "plan" would result in chaos both at the bus yards

l 1

and at our schools'. First, LILCO proposes to send LERO personnel to the bus yards, to pick up and drive buses in the event regular school bus drivers do not report for duty. But, as noted above, many of the buses would not be at the yards. Thus, LERO personnel would have no buses -- or an insufficient number of buses -- to drive, even if it is assumed that the schools would entrust LILCO with the buses owned by or under contract to them.

Second, LILCO does not understand the dispatch dif ficulties which would be presented. Our regular bus drivers routinely go to several schools. The few regular drivers who could realistically be expected to show up to drive during a Shorehatii emergency would not know wnich one of these several schools to go to. Certainly, LILCO's drivers would not know which schooln to go to, or even how to find them.

Third, the influx of LERO personnel at our bus jards would only add to the confusion. The bus yards are busy under normal operating conditions. Extra people (LERO drivers and perhaps LERO dispatch personnel) would add to the confusion. Moreover, it is quite likely that the regular dispatchers, management and mainte-nance personnel at the yards would experience role conflict.

Should that occur, there would be no trained. personnel to dispatch I and service the buses.

t Fourth, LILCO has failed to plan for the evacuation of handi-capped schoolchildren or school'childran with special problems.

Specially-designed buses and specially-trained drivers and other supervisory personnel would be needed. For example, we provide extra training and instruction to the drivers who transport these children. To our knowledge, however, LILCO does not provide for

such training. Handicapped children cannot be safely transported on regular school buses ill-equipped to meet their needs; nor can they be transported by drivers who have not undergone specialized training. By failing to plan for the special needs of these children, LIT,CO has overlooked an important segment of our school populations.

Fifth, in the event of a Shoreham emergency the situation at the .-chools (assuming buses were even dispatched) would be no better. Under LILCO's proposal, enough buses to evacuate each school would arrive at that school at about the same time. This would result in chaos, gridlock, and a severe scfety risk to our schoolchildren and others. Our schools do not have sufficient space for so many buses. Further, it would have to be expected that many parents, fearful of the accident at Shoreham, would

converge on the schools in an attem'jt to reunite with their -

. children, adding further to traffic congestion. Even assuming any buses actually arrived at the schools and children boarded those buses, it is unlikely that those buses would leave the parking lots promptly as parents would likely board the buses in search of i

i f

their children. This would add substantially to the chaos and i

confusion. Moreover, there would be no crossing guards present to i t

guide and direct buses or children. Under this scenario, the l i

likelihood of serious accidents and injuries occurring, in addi-tion to potential ,xposure to harmful radiation, is substantial.

In short, LILCO's plan is a logistical nightmare. It would  ;

not work. We are the persons charged with protecting the children  !

-who attend our schools, and we would never even try to implement LILCO's plan. It is an invitation to endanger the health and safety of our children.

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-Q. .The LILCO Plan indicetes that Middle Country's public schools are located outside the 10-mile EPZ. Would Middle j Country's buses and drivers be available to help schools inside the EPZ evacuate or conduct early dismissal in a Shoreham  ;

emergency? ,

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l A. (Brodsky, Rossi) No. First, based upon the survey pre-  !

l viously mer.tioned that we conducted of schooi bus drivers in 1983,  !

in addition to our daily contacts with our drivers, we believe  !

many would exparience role conflict in the event of a Shoreham l

l accident, and thus would not be available to drive buses. This [

i would be particularly true for those drivers vho reside within the 10-mile EPZ.  !

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Second, we could not release our buses or drivers, notwith-standing the many concerns previously stated, because we would need them for our children. The parents of schoolchildren attending our schools would expect us to.get their children home or to attempt to evacuate them if a serious accident occurs. Some of our schools are very close to, if not within, the 10-mile EPZ boundary line. In any event, no one believes that schools beyond the 10-mile cone are free of risk.

Third, the LILCO Plan indicates that all our public schools are outside the 10-mile EPZ. We have difficulty with that, however. The Bicycle Path School, located at 27 North Bicycle Path in Selden, and the New Lane Elementary School, located at 10 New Lane in Coram, appear to be within 10 miles of Shoreham. If not, they are certainly virtually on the edge of the EPZ. Thus, in our opinion we have children attending public schools within the 10-mile EPZ. In any event, we have children who live in the

. EPZ, even though they may attend public schools which lie outside the EPZ. Moreover, our buses enter the immediate area of the Shoreham plant daily to transport our private and parochial school ,

, students to Mercy High, St. Johns Elementary, Yaphank Christian 1

and the Step by Step Schools.

i Q. LILCO's Plan appears to assume that, in a Shoreham l

l emergency, the Riverhead Central School District could focus its attention solely on the evacuation of the four public schools l

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v y - -wr a

0 located in the EPZ. Thus, LILCO asserts (LILCO Plan, OPIP 3.6.5) that 47 buses owned by the Riverhead School District would be sufficient for the evacuation of the Riverhead schools. Do you agree?

A. (Suprina, Doherty) No. First, as already discussed, Riverhead owns 54 buses of which 39 are full capacity passenger buses (of which only 33 are available to the public schools) and 15 are mini-vans. Assuming we were able to use all 54 vehicles to evacuate the four EPZ schools, there would still be too few buses to evacuate these schools in a single wave. There are 2,705 students attending those four schools. Using only the 39 full ,

capacity buses, we would have to load 69.35 students per bus which is implausible. We would safely only load the buses two students per seat. Using all 54 buses, loaded with two students per seat and not allowing any seating space for adult supervisors, 773 students would remain to be evacuated. We would need 20 more full capacity (20-seat) buses to evacuate these 773 students. In short, using all our bus resources, plus 20 more full capacity buses, we would need a total of 74 buses just to evacuate the students attending the four EPZ schools in a single wave, not 47 buses as proposed by LILCO in its Plan.

Second, the District's 54 buses could not be devoted solely to the evacuation of the four EPZ schools. Some of our buses would not be available at all, for reasons already discussed.

Further, we could not ignore our non-EPZ schools. As previously noted, these schools are very close to the EPZ boundary line and we consider these schools also to be within the zone of danger.

Parents would not believe that their children in those schools are free from risk. Thus, a portion of our bus resources would have to remain devoted to non-EPZ schools.

Q. Loes LILCO's school evacuation plan make sense for Mt.

Sinal?

A. (Petrilak) No. For the reasons already discussed, LILCO's plan makes no sense. Further, LILCO overlooks a critical fact. LILCO assumes that all our 27 contract buses (not 30 as the LILCO Plan states) could be assigned to the evacuation of our elementary and junior high school. That is not true. We also are responsible for the tran:portation of the 572 Mt. Sinal students who go to school in Port Jefferson and the 118 students attending private and parochial schools. Thus, we have far fewer buses than would be necessary for the single-wave evacuation proposed by LILCO. Even if we were to use all 27 regular buses, plus the 11 mini-vans, to evacuate only the elementary and junior high schools, as LILCO presumes, we would still have too few buses to effectuate a one-wave evacuation of those schools. We have 1,660 students enrolled in those two schools. Using the 27 buses, and the 11 mini-vans, loaded two students per seat and not allowing any space for adult supervicors, we would need an additional nine

20 seat busets to evacuate our elementary and junior high schools.

We would need 15 more 20-seat buses to evacuate our 572 high school students in a single wave.

Mort 'er, given the daily heavy traffic congestion on the two roads leading to our elementary and junior high school (Route 25A and North Country Road) and given the fact that traffic will be, infinitely more congested were an emergency at Shoreham to occur, it is highly unlikely that if any buses managed to reach these schools, they would be able to negotiate the left turn onto either Route 25A or North Country Road. Quite simply, were any buses to reach the schools, those buses would have a very difficult time trying to leave the parking lot.

Q. Does LILCO's school evacuation plan make sense for Longwood?

(Muto, Smitt.) No. First, as previously noted, we have con-tracts with Suburbia for only 89 buses, not 100 as contended by LILCO in its Plan. LILCO Plan, OPIP 3.6.5, Att. 3a. Of those 89

buses, only 70 are available for transportation of public school-l children. Second, LILCO does not state the passenger capacity of f its 28 "supplemental" buses. Ascuming we would have access to all 89 Suburbia buses, h.'d assuming further that the 28 LILCO buses are full capacity 20-seat buses, there would still be too few l buses to implement a single-wave evacuation of our students.

I i

As noted, our middle and junior high schools operate on a split schedule. Thus, were an emergency to occur around midday when these students would be in transit to and from school, all 8,574 public school students would have to be evacuated.1/

Loading the buses two students per seat and not allowing any room for adult supervision, we would require 215 buses, or 98 buses in addition to our 89 and LILCO's 28.

If the accident occurred in the morning when the middle school was in session, but not the junior high, 183 buses would be needed to evacuate the 7,287 public school students and T. '. LCO would be short 66 buses. If the accident occurred in the afternoon when the junior high students were in session, but not the middle school etudsnts, 181, buses would be needed for a one-wave evacuation of the 7,220 students and LILCO would be short 64 buses.

Q. Gentlemen, you have made clear that you would not permit LERO drivers to transport your schoolchildren, and that you do not have enough buses to carry out an evacuation on your own, especially given likely role conflict problems. What action would you undertake to protect the safety of ycur schoolchildren in the event of an emergency at Shoreham requiring evacuation?

i 1/ The figure of 8,574 public schoolchildren excludes those students who walk to school. In the event of a Shoreham

emergency, these students might need to be evacuated as well.

Were these students included in the calculations', LILCO's

underestimaticu of the number of buses needed to be evacuated in a single wave would be even greater.

1

1 A. (All) The LILCO Plan is not workable and fails to pro-tect the safety of schoolchildren. Each school district has the responsibility for protecting the health and safety of its students while they are at school or being bussed to or from school. We could not and would not turn this responsibility over to LILCO.

In the interest of safety, the only option thac might be available to us would be to utilise and rely upon however many of our own bus drivers and buses that would be available. If only a few bus drivers reported to the schools, we might have to utilize those drivers for an evacuation to some 1ccation deterrr.ined at that time, using as many multiple runs as would be necessary. In the interim, we might have to attempt to retain the schoolchildren at the schools.

This is not to suggest that sheltering presents an option preferable to evacuation. Our buildings generally do not have basements and thus might make poor and inadequate sheltering facilities. The safety risk involved, however, in allowing our schoolchildren to board buses driven by LILCO employees is one which we are not willing to bear, and we would be forced to make do with whatever options remained.

71 - ,

e VI. Early Dismissal Q. The LILCO Plan, as it relates to schools, also provides for the alternative protective action of early dismissal. It is alleged in Contention 25.C that role conflict would preclude early dismissal. Could early dismissal be implemented by your school districts in the event of an emergency at Shoreham?

A. (All) No.

Q. What is the basis for your response?

A. (All) First, unlike evacuation, LILCO's proposal for early dismissal does not presume that LILCO drivers would drive buses. Crocker deposition at 28. In this respect, LILCO's pro-posal is more realistic than is its single-wave evacuation pro-posal, since, as noted above, LILCO drivers would not be permitted to drive our children under any circumstances. Stated somewhat differently, LILCO assumes that an early dismissal of schools would be carried out solely by regular school personnel. Early dismissal, however, would require multiple bus runs to be con-ducted, even if it is assumed that all regular drivers were avail--

able. If some drivers were unavailable (as it must be assumed would be the case), then it would take even longer to transport schoolchildren f rom schools to their homes. Consequently, there 72 - ,

would be a real likelihood that children could be caught in a radiological plume.

Second, the problems previously discussed would make it ir.-

possible to obtain a full complement of regular bus drivers or the other school personnel necesaary to implement an early dismissal.

For example, the implementation of an early dismissal requires central office administration personnel, transpor'tation contractor personnel, teachers and other school district employees to perform decisionmaking and notification functions, ' and supervisory and logistical duties, in addition to the transportation of school-children. All these personnel would likely be subject to role conflict. Moreover, difficulties in notifying off-duty bus drivers, and the role conflict that and would prevail with respect to these drivers who could be contacted, would make it virtually impossible to obtain many drivers.

(Doherty) During an early dismissal due to snow, I

, of ten find it very difficult to contact drivers even though che drivers have for1 warning of the inclement weather conditions.

Many drivers are not at home and thus cannot be reached on their home phone. Moreover, the phone system here cannot handle the heavy volume of phone calls being made during times of inclement weather conditions. I typically cannot get a dial tone due to overloading of the phone circuitry systems and am unable to even try to reach my drivers at their homes. At the first sign of any

4 .

. i emergency at the Shoreham plant, it is likely that many people l would try to locate friends and family members to handle the volume of calls. Consequently, even if some of my drivers were at home, I would be unable to reach them.

(Rossi) I am able to implement early dismissal due to snow only because at the slightest hint of winter weather, I pay

> my drivers to remain at the bus yard. I also call my contractors and suggest that they do the same with their drivers. If I did riot do this, I would never have enough drivers to implement early dismissal.

Third, even if one assumes that LILCO might attempt to send its drivers to "assist" the schools with early dismissal, it must again be emphasized that we would never allow our children to board buses driven by LILCO employees. Under LILCO's evacuation proposal, LILCO's drivers would have to follow the printed directions provided by LILCO at the time of the emergency to find the particular school he or she would be assigned to evacuate.

For early dismissal, however, these drivers would have to not only locate a particular school, but would also have to follow routes to the children's homes. This is a difficult task for even our

trained regular school bus drivers. Short of asking each child where he or she lives, LILCO's employees would simply be unable to find the homes of our schoolchildren.

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(Smith) In Longwood, for example, early dismissal in-volves the driving of at least 317 individual routes. Our trained substitutes often have difficulties. We could never let LILCO's employees take our chJldren and try to find their homes.

(Doherty) In Riverhead, early dismiasal involves the driving of 140 individual routes.

(Rossi) In Middle Country, early dismissal involves the driving of 550 individual routes over which more than 5,600 stops must be made.

(Petrilak) In Mt. Sinal, early dismissal involves the driving of 113 individual routes.

(All) Fourth, early dismissal does not present a realistic option, because we would not discharge our children to homes without parental or adult supervision; nor would we choose to relocate our children to locations within the EPZ which may be or might become contaniinated. We all have a large percentage of latch key children attending our schools. Indeed, some school districts do not engage in early dismissals at all for that l'

reason.

l .

(Koenig) East Meadow does not have an early dismissal or go-home plan, because we are unwilling to return children to homes without adult or parental supervision.

(Petrilak) Although Mt. Sinal has an early dismissal plan, it is used only if absolutely necessary. We have yet to implement an early dismissal this year and implemented early dis-

' missal only once last year, when inclement weather made early dis-missal absolutely necessary. Our reluctance to dismiss early stems from our concerns with respect to returning children to homes without adult or parental supervision. In fact, even under normal conditions, our drivers will not allow a child to return to an empty house. If no parents or other adults are at home, our drivers will return the child to the school to await the arrival of an adult. Our parents are grateful for our drivers' concerna for the safety of their children.

(All) In short, therefore, early dismissal does not present a viable protective action for responding to a Shoreham emergency. There is no means of predicting hou long an early dis-missal would take to implement, given our limited resources and the role conflict problem. Further, many children would be re-turning to homes without adult supervision, which is unacceptable.

Moreover, for many children living near the plant, early dismissal would mean that by taking these children to their homes, their risk of exposure to harmful radiation might be increased. In

\

short, because early dismissal poses a severe safety risk, we ;

would not attempt to implement an early dismissal in a Shoreham emergency under any circumstances.

VII. Shelterino Q. The LILCO Plan, as it relates to schools, also provides for the alternative protective action of sheltering. Is sheltering a viable option that your Districts would be able to implement in the event of a Shoreham emergency?

A. (All) No. Our school buildings generally are not appropriate for sheltering. None of our schools has basements or airtight, windowless areas, such as would be needed to safely shelter our students from harmful radiation. Moreover, even if it is assumed that our buildings would make appropriate sheltering facilities, sheltering would still be unworkable since, given role conflict, it is unlikely that we would have an adequate number of school personnel available to us to supervise the children during a Shoreham accident.

VIII. Conclusion Q. Do you believe that other EPZ school districts would concur in the views you have presented in this testimony regarding .

LILCO's school evacuation and early dismissal plan?

A. (All) Yes. We believe the views expressed above are <

generally representative of the actions other schools would take.

We deal with school personnel throughout Long Island and under-

, stand how most schools operate. In particular, given our know-ledge of schools, we believe it is highly unlikely that schools would. entrust their children to LILCO drivers, or attempt an early dismissal in the event of a Shoreham emergency. Revision 9 of LILCO's Plan, at least as it relates to schools, cannot be imple-mented.  ;

We find support for our views in the rather broad belief ex-

pressed by schools over the years that LILCO's plan for school evacuation and other alternative actions is not adequate. For in-stance, many schools within the EPZ, other than ours, have passed resolutions attesting to their belief that LILCO's school evacua-tion plan is inadequate. Egg, Li.5Li. , Miller Place Union Free School District (September 1, 1983 and February 10, 1988);
Comsewogue Union Free School District (January 16, 1986); Rocky i i

Point Union Free Public Schools (May 19, 1986). Eg.g g;m Port ,

Jefferson Station Teachers Association letter to NRC dated I

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September 22, 1986. These resolutions- and the Port Jefferson letter are attached to this testimony as Attachment l!..

Further, as previously mentioned, bus drivers in Port Jefferson, Patchogue, Shoreham-Wading River, Rocky- Point, Comsewogue, South Manor and Miller Place, all school districts located within'the EPZ, all signed statements indicating that in the event of a Shoreham emergency, they would not drive a school bus.

Moreover, it must be recognized that role conflict is not a problem confined only to our school bus drivers and teachers; it will also be expe ;ienced by school bus drivers and teachers in other school districts near or in the Shoreham 10-mile EPZ. Thus, these school districts would also not have sufficient personnel to implement either early dismissal or an evacuation pursuant to LILCO's Plan. The problems that we have outlined that our schools would likely experience with respect to implementation of LILCO's Plan are not unique to us, and would be experienced by other school districts as well. Thus, it is our conclusion that the other school districts within the EPZ would be unable and un-willing to carry out LILCO's plan for schools.

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O. Does that conclude your testimony?

A. (All) Yes.

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9 ATTACHMENT 1 l

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ilRUCE G. BRODSKY 23 HAWKINS PATK CORAM, NEW YORK 11727 (516) 732-0821 Family: Married Four children Business 356 Middle Country Road Address: Coram, New York 11727 (516) 732 0822 l

Employment: Self employed, private practice Education: Massachusetts College of Optometry Boston, Massachusetts Bachelor of Science 1961 Doctor of Optometry 1963 School District Trustee, Middle Country Board of Education 1977 present Activities: A) Member legislative subcommittee 1987 Chairperson 1987 B) Member policy subcommittee 1982 present Chairperson 1984,1985 C) Member finance subcommittee 1985 1987 Chairperson 1986 1987 D) Member public relations subcommittee 1986 present Chairperson 1986 Member, Nhssau Suffolk School Boards Association 1977 present A) Executive board member 1977 present B) Member legislative committee 1977 present Chairperson 1987 present C) Member various sub-committees, developing position papers on various legislative bills and Regents regulations i

D) Treasurer 1987 present E) Spokesperson at Regents hearing regarding Regents Action Plan, High School Dropouts, Teacher certifications New York State School Boards Association 1977 present A) Legislative Network Representative 1981 present B) Faculty Member 1982,1987 C) Resolutions Committee member 1984 1987 Chairperson 1987 D) Convention voting delegate 1981 present S

4 E) Moderator at Fiscal Responsibilities Workshop 1987 F) Panel member on Policy Utilization 1986 National School Boards Association 1977 present Aa- ory Committee for Scope /Septric 1982 1983 Brookhaven School Board Association member 1977 present Spokesperson for school districts ?t Suffolk legislature Other Civic Executive Board Member of Nassau Suffolk Activities: Health Systems Agency 1976 1978 Strathmore East Civic Association 1968 present  ;

Vice President 1969 1970 Area representative 1969 1972 Executive Committee 1973 1975 .

1969 1972 1979, 1985 Masons 1961 present Central Brookhaven Lions Club 1976 present >

Central Brookhaven Chamber of Commerce ,1981 present Seldon Civic Association 1958 1972 1980-present l North Shore Jewish Center 1968 present YMCA Outreach of Brookhaven, ,

Board of Directors 1976 1980 -

Vice chairperson 1977 1979 Chairperson 1979 1980 Community Mediation Center of Coram, Board of Directors 1981 1985 Community Volunteer, running property tax assessment grievance workshops in:

Bellport, Medford, Coram, Middle Island and Gordon Heights '

Middle Country School District: Various PTA's School Community Relations Committee Political Middle Country Democratic Club Activities: 1975 1979 New Democratic Coalition 1976 1980 Tanglewood Democratic Club 1975 prescrit Brookhaven Towt; Democratic Club 1975 present Brookhaven Town Zone Leader 1980 1982 i Vice Chairperson Brookhaven Democratic Committee 1982 1985 '

Judicial Convention Delegate 1980,1982,1986 l Committeeperson: ED 130 1978 i982 ED 209 1982 present

' Primary candidate for Legislature 1981 Candidate for Legislature 1981 Primary Candidate for State Assembly 1985 i

, - - - . -- ,w.v.v. . - --.-- --.-,y.---f.-.. - - - ..y-,- _-.~x - , ,-, -~..-,- ,.-,,&- - - --.-r-m w- ,, m. , . - , - .m-- - ,.e- -

Worker and/or contributor in the following campaigns:

Hochbrueckner for Assembly 1976,78,80,82 Rand? ph for Supervisor 1977 Randolph for Congress 1973 Linton for Legislature 1976 Reynolds for Council 1977 Betheil for Council 1977 Capria for Council 1977 McCoy for State Senate 1975 Twomey for Congress 1970 Eldon for Congress 1982 Holtzman for US Senate 1980 Hoffman for Assembly. 1982 Seltzer for Council 1978 Rosenblum for Council 1977,1981 Phil Nolan for Legislature 1983,1985 Eng'ebright for Legishture 1983, 1985 Foley for Legislature 1981, 1983, 1985 Town Democratic Slates 1979 1987 Cuomo for Governor 1982, 1986 Gaurghan for Town Council 1983 Gaurghan for Legislature 1987 Sawicki for Assembly 1984, 1986 Hochbrueckner for Congress 1984, 1986 Town Government: Manager, Brookhaven Airport -

1976 1979 Brookhaven Industrial Commission 1977 1979 Spokesperson for Brookhaven Town at:

Civic Associations State Senate Hearings on Air Service Advisory group for developrnent of Suffolk County Airport Testified at Suffolk County Hearings pertaining to Development of l ong Island MacArthur Airport Professional N.Y. State Optometric Council 1968 1973 Orgaelz.ationt,: American Optometric Association 1973 present NYS Optometric Association 1973 present Suffolk Optometric Society 1973 present Recording Secretary 1977 1978 Personal Interests: Reading, music, golf, flying (have pilot license),

boating, water skiing Military: Three (3) years active duty U.S. Air Force Seven (7) years inactive reserve Hnnorable discharge 1965 Retired 1971

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ATTACHMENT 2 i

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l' RESUME ANTilONY R.-ROSS) 45 Chestnut' Avenue Patchogue, Nok York '11772 (516) 289-1386 OBJECTIVE: Major interest is in the field of Management.

PERSONAL DATA:- -Date of Birth: June 7, 1942 Height: 5' 10" Weight: 180 lbs Marital Status: Married - four children

!!ealth: Excellent Military Status: Honorable Discharge from U. S. Army Reserve Program, 1969 EDUCATION: S t. Francis College B. B. A. June 1960 Major: Dusiness Management Qualified instructor for:

a. New York State Basic and Advanced School Bus Driver Training Programs
b. Greater New York Safety Council Defensive Driving Program Qualified inspector for New York State Motor Vehicle Department for the testing of drivers under Article 19A.

EXPERIENCE:

Trained and mediator Mediation for the area Conflict Resolution Program January 1973 Middle Country Central School District to present 10 43rd Street Centereach, New York 11720 Director of Transportation for this school district responsible for the daily transpor-tation of approximately 11,000 students to 14 in district schools and 39 private / parochial schools, utilizing 42 district owned buses and 55 contracted.

2 Responsibilitics' include routing using auto-mated scheduling, preparation and control of a

$2,500,000 budget, negotiations, preparation of State Aid Forms, coordination of all areas related to the operation of a- transportation division. Operations include a garage for re- .

pair. of 51 school buses and 4S+ other vehicles.

. .lanuary 1970 Patchogue Medford Public Schools

  • to January 1973 241 South Ocean Avenue Patchogue, New York 11772 Assistant Business Administrator for the-Pa tchogue Hedford Schools. Primary duties incipded daily transportation of 5,500 students to eleven district schools and eight '

private / parochial schools, utilizing 34 buses, eleven of which were owned by the district.

I was instrumental in the initial utilization of automated scheduling for. transportation.

I also prepared and reviewed all bids. I did some of the purchasing for the district and

. handled questions and complaints regarding purchase orders and payments.

1960 to Equitable Life Assurance Society of the January 1970 U. S. 1285 Avenue of the Americas, New York, t;ew York 4

Supervisor of the Cancellation Division of'the Policy Service Depar tment, which consisted of 32 people. Duties involved decisions on ex-ceptions for cancellation of policies f rom issue, dividend over-paynents and authorization for use of dividends. Dasic f amiliarity of various IBM equipment.

Cadet Management Training Program. Training covered all phases of managerial responsibility, .

including preparation of budget, supe-visory duties, policy formulation, liCFCDENCES: Will be furnished upon request.

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Biographical Data of the Superintendent of Schools for the Riverhead Central School District Riverhead N.Y.11901

' N:me: Dr. Richard N. Suprina Superintendent of Schools Riverhead Central School District 700 Osborne Avenue Riverhead, N.Y.11901 Current Position: Superintendent of Schools in the 3700 Pupil Riverhead Central School District on Eastern Long Island since January 1983.

Previous Administrative

  • Assistant Superintendent for Administration and Cu'rriculum and Teaching Experience: of the Deer Park Union Free School District

' Principal-- Hauppauge High School

  • District Coordinator and Assistant Principal--

Harborfields Central School District #6

  • Guidance Counselor--Jericho Junior / Senior High School

'Chairnan of Health, Physical Education and Athletics--

Elwood Union Free School District

  • Teacher--Valley Stream North Junior / Senior High School Educ'ation: 'Ed.D. from Fairleigh Dickinson University

'M.S. from Hofstra University

'B.S. from SUNY at Cortland Publication

Background:

Has a'uthored numerous educationally related articles which apper red in professional journals and newspapers Scmpling of Honors Earned: *Sclected as a Kettering Foundation /l/D/E/A Fellow

' Named the School Administrator of the Year by the N.Y. State Association of Foreign Language Teachers Presented the N.Y. State PTA Jenkins Memorial Award

' Selected to participate in the White House Conference on Youth Employment

' Selected as a chairperson for Middis States Association Commission on Secondary Schools evaluation committees

' Selected to address national conventions and conferences of various educational organizations

' Elected as an officer in various local and State Professional Organizations Family Status: Married for over thirty years to Barbara Grande Suprina Three children--Darren, ago 29, computer consultant Todd, age 26, Speech Pathologist Jill, age 23, college student

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9 ATTACHMENT 4

EDWARD J. D0llERTY RFD #2 Box 96 Riverhead, New York 11901 (516) 727-1745 EDUCATION Port Jefferson H.S., Port Jefferson, NY

-Graduated 1948 E4PLOYMENT Managed & Operated family-owned service station, Ridge, New York 1948-1950 Dugan Bros. , Riverhead, New York -Bakery Product Salesman - 1950-1952 F.K. Blum Contracting Co. , Ridge, New York Driver-mechanic - 1952-1953 Riverhead Central School District (formerly known as Union Free School District f 5) -Bus Driver -1953-1957 Riverhead Central School District. Riverhead New York -Assistant to Transportation Supervisor-Bus Driver-mechanic 1957-1963 Supervisor of Transportation. Riverhead Central School District 1963-Present SPECIFIC QUALIFICATIONS Appointed Transportation Coordinator July,1962 Riverhead Central Schools Appointed Supervisor of Transportation July,1963 -

Duties include: Establish routes, select and train driver applicants, supervise district repair garage, possess considerable mechanical experience in all phases of repair and maintenance procedures, specifications and purchasing.

Maintain and prepare all records for State Aid Routing Data, Distric: 'ransportation Financial Reports, Commissioners Regulation 156.3, Depart-ment of Motor Vehicles Article 19A conduct driver training courses -both Basic and Advanced as prescribed by NYS Education Department -

SPE CIFIC QUALIFICATIONS CONTINUED N.S.C. Instructor # 10222. Certified Examiner D.M.V.

Suffolk #1022 SED instructor's Cortificate #66, Certi-fled Master Instructor f 27, BOCES I Suf folk Adult Edu-cation Certificate #056223060 -resolve complaints and discipline problems and promote good public relations.

Coordinate tation. school schedules and programs with transpor-At present. I am responsible for the overall supervision and administration of a fleet of 50 district-owned buses and drivers, 5 mechanics, 8 substitute drivers and the maintenance and repair of an additional 30 vehicles for the building and grounds department.

Additional respon-sibilities include purchasing supplies and parts, prepar-ation and administration of transportation budget.

Regular attendance at Transportation Workshops conducted by the New York State Education Department.

4 Former President.Vice President. Treasurer, Secretary for the New York Asmaciaticn for Pupil Trans;ortation. Suffolk Onpter, currmtly servirig as Secretary for the New York State Association for Pupil Transprtation.

RETDD0S Mr. Kenneth Ross, Former District Principal Riverhead Central School (residence- Pine Street. Aquebogue, NY)

Mr. Alan Hernandez, Superintendent of Schools Uniondale Central Schools, Uniondale, NY 11553

, Mr. Richard Suprina, Superintendent of Schools, Riverhead

Central Schools, Riverhead, NY 11901 Mr. Ronald Central Revelle, School Superintendent of Schools Highland District, Highland, New York
Mr. Lee Comeau, Associate, New York State Eduction

, Department. Albany, New York I

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VITA Nick F. Muto 52 Shore Road West Mt. Sinal,' N.Y.11768 516-473-1953 Married, two children EDUCATION H.S. Pennsylvania State, Edinboro, PA Art-English 1951 k.S. Auburn University, Alabama Guidance 1954 Ed.D Syracuse University, Syracuse, New York A d minis tra tion 1967 POSITIONS Two year service - U.S. Array 1951-1953 Guidance Counselor Havorford Township,. PA, School District 1954-1958 Part-time Instructor, Asst. Day Camp Director .

Main Line Y.M.C. A., Ardmore, PA 1954-1958 Teacher - Guidance Director - Administrator 1958-1964 Augsburg, Germany (2 years)

Narlsruhe, Germany (1 year)

Heidelberg, Germany (2 years) '

Paris, France (H.S. Principal) (1 year) .

Teaching at Syracuse University 1964-1966 Director, Syracuse University Center Summers of '66 & '67 <

Elementary Principal (while completing dissertation)

Manlius, NY 1966-1967 Project Director, Semi professional Training Project Titic !!! Center, Syracuse, NY 1967-1969 Associate Supt. for Curriculum and instruction Wellesley, MA 1969-1975 Visiting Professor, West Virginia University Summers of *10 & *il Associate Professor, Lowell University, Lowell, MA Sept.1970- 1976 Visiting Professor, University of Maine Summer of 1973 Visiting Professor, Lesley College, Cambridge, MA 1970 Adjunct Professor, University of Mass., Amherst 1972 Superintendent of Schools, Nauset Public Schools South Wellfleet, MA 1975-1982 Superintendent of Schools, Longwood Central Sch. Dist.

Middle Island, N.Y. 1982 - Present '

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ATTACRMENT 6 5

. RESUKE J. Thomas Smith Longwood Cent.a1 School District Middle Island - Yaphank Road Middle Island, New York 11953 (516) 345-2775 Education: State University of New York at Farmingdale Pratt Institute of Technology (BA) 1955-1957 1958-1961 McAllister School of Science 1961-1962 Professional Experience:

Longwood Central School District, Transportation Coordinator New York State Education Department 1970-Present Cert. School, Bus Driver Instructor

- Region 'III f461 New York Department of Motor Vehicle 1972-Present Certified Suf. f1125School Bus Driver Examiner 1977 National Safety Council Defensive

  • Driver Training Instructor Cert, f11339440 1976 Associations: Brookhaven Township Transportation Advisory Board New York Association for Pupil 1978-Present Transportation - Suffolk Chapter President-elect -

1978-1979 National School Transportation Association 1975 New York Association for Pupil Transportation Suffolk Chapter 1971 Participant:

New York State Pupil Transportation k'o rk shops :

University of Albany 1982-86: Cortland 1979; Niagra 1978; Plattsburg 1974-75; Oswego 1971. .

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i 1EMAhD M. K0ENIG, Ph.D. -

31 Greenhill IAne '

Iktutington, New York 11743 Telepoone No.

(516) 368-5294 SLPERDmNDEh? OF SWOOLE '

EDUCATICN: Ph.D. -

New York thiversity - 1980 Educational Adainistration M.A. -

New York University - 1970 Educational Administration B.A. -

Queens Cb11ege (CIAT) - 1966 Political Science / Psychology EXPERIB'CE: Septanber 1983 - Present i Superintendent of Schools L l

East Wadow Un$on Free School Distr.let, East kadow, '

New York.

July 1974 to Septanber 1983 Assistant Superintendent for Administration i Harborfields Central School District Greenlawn, New York.

Responsibilities Included: Personnel (all units and class-  :

ifications. ), Otrnpensatory Education (Chapter I/PSEN.),

)

Negotiations (all units.), Cut-of-District Funding, Public Relations, and other duti m which overlapped the areas of  !

t curricultzn and irstniction and business. (

October 1971 to Septarber 1973 "

District Manager for Administration and Businus Affairs Cualnity School District 24 - Flushing, New York Ctmunity School District 26 - Fresh Wahs New York Responsibilities Included: Preparation and adninistration  ;

of a budget of note than $20,000,000 for as many as thirty (30) schools. District purchasing, accounting, major and l minor plant inprovanents and emrunity liaison.  !

Ibbruary 1968 to October 1971 Teacher of Mathanatics and Social Studies - Grades 6-8 Teacher - Grade 6 and Assistant Dean of Students {

Ir.temediate School 61, Cbrona, New York t i ,

In addition to the above, during the time that I us preparing

' for a career in education, I was s' ployed as a social worker with the New York City Departnent of Social Services and as an Official (

%urt Reporter for the N.Y.C. Civil (burt and the N.Y.S. Department (

of IAbor. '

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RESIAE OF IKMARD W. KGNIG, Ph.D. Page 2

}KNORS:

Fellow - Education Pmi'essions Developnent Act (DOA)

Fellowship - New York University - 1973/1974 President - Phi Delta Kappa - NYU Chapter - 1977/1978 Quadrant leader - Southeast Quadrant of the Nassau Cbunty Cbuncil of School Superintendents - 1986/1987 Natimal Vice-President- Region I, National Association of Federally Inpacted Schools - 1985 / present.

ACTIVE 'knerican Association of School Adninistrators

. PROFESSICNAL AFTILIATICNS Association for Supervision & Curriculum Develognent American Educational Research Association New York State Cbuncil of School Superintendents Nassau (bunty Cbuncil of School Superintendents New York University Adninistrators Roundtable Ibi Delta Kappa LNIVERSITI Adjunct Pmfessor of Educaticnal Adninistration AFFILIATI(NS New York thiversity 1980 - present long Island thiversity 1982 - present Chairperson - Dean's Professional Education Advisory Cbanittee - C.W. Post Ov: pus of L.I .U.

PUENAL Ibm: July 9, IMO DATA nhrried, two children hight 6' Weig;ht 210lbs.

P.<cellent kalth with no rhysical disabilitics Placment creckntials are available upon request frun the fin York thiversity Office of Diacational Placment.

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ATTACHMENT 8 J

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6 4 Robert M. Petr11ak

. 12 Gardenia Road M t . Si na l , N .Y . 1.17 66 D3te Of Birth November 27, 1942 t

Married, 3 Children Education Attented SUNY Fredonia N.Y Adelphi University L.I. N.Y Employment US Air Force 1962-1966 Sta f f Sergeant, Aircraf t Instrumentation Grumman Aerospace 1966-1967 Instrumentation Research Technician Riker Video 1967-1969 Engineering Research Technician Applied Digital Data Systems 1969-1986 Reasearch Technician i

Manager Fie.1d Engineering Director Field Engineering Director Materials /Purchast ny ACM Data Systems Inc. / Channel One Entertainment Owner Other Mt. Sinal Board of Eaucation 1983-Present President- Mt. Sinai Taxpayers Association 1980-Present Prosident- West cli f f Homeowne rs A ssociation 197B-1980 February 1988 9

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t 11/7/43 Mrs. Yolando Futerio, President 6f the Middle Country

' secretarial Assostation to offer a statement re negotiations. ,

A representative of the Andrea Doria Lodge requested consideration of band participation in the Columbus Day Parada nett year.

Arlene Popoleski, }krwkins Path PTA to consent upon the success of the M211oween Party at M:wkins Path; to advise the Board of the Theatre Club activity; and requested that there be input when the report of the RESS Committea is discusaed.

Jennie Canastro, Hawkins Path to connent upon the underbrush along Boyle Road and the need for sidewalks there.

Roberto Dangel re substitute teacher plac9 ment' Roy Probeyahn res aged out handicapped students, -

offered his services in this regard.

Superintendent's Report-SLIFERIFIEMDENT 'S Mrs. Adler led discussion concerning the resolution EEPORT adopted lost year cond re-offirinaa on August 15,1983 to wit VHEREAS, the Middle Count y Centrol School District's Doord of Education has as its prime concern the welfare S)OREMAM of the children of the School District and -

POWEA PLANY WHEREAS, the Long Island Lighting Company has not been able ?o insure that its proposed Shoreham Power Plant can meet acceptable safety standards, and -

VHEREAh, no acceptable evacuation plan has been devised by the Long Island Lighting Cospany and Suffolk County RE IT RESOLVED that the Board of Educatisn in the interest of protecting the welfare of the children of Middle Country does hereby go un record as opposed to the opening of the Shorehan Power Plant until both an acceptable safety standard con 14 set and an ecceptable evacuation ple.n can be developed.

i Mrs. Adler asked the noord to consider that the above stated resolution might be sufficient and there would be no need to go further.

The following resolution was offered by Gallo, who 11/7/33 moved its adoption, seconded by Durkin to wit:

WHEREAS, federal regulations for full power operation of the ahorehan Nuclear Power Plant require an emer-gency plan for communities surrounding the plant which will assure those communities adequate protection in event of a nuclear emergency; and WHEREAS, the County of Suffolk has de mined, af ter substantive study and lengthy hearings, that ne emer-1 gancy plan can be developed to provide citizens sufficient protection in a Shoreham emergeney; and WHEREAS, the County of Suffolk has threrefore concluded that it cannet, in good faith, prepare or 3,aplement an emergency plan, or support full power operation of the Shoreham Nuclear Power Plant; and WWIAEAS, the Long Island Lighting Compey, in an effort to acet federal regulations, has prepared an e.mergency plan which only LILCO, lacking coordination with local or state governments, will attempt to implement; and WHEREAS, the Nuclear Regulatory Comtnission's Shoreham licensing board is now conducting hearings to review the adequacy of the LILCO caergent:y plan; and WHEREAS, the LI140 emergency plan includes protective actic.u to be tokea by schools; and WHEAEAS, this boatd of education, having reviewed LI140's emergency plan for schools, and having discursed those plans with concerned parents, wishes to advise the NRC's Shoreham licensing board of the plan's workability for its district; cad VMEREAS, this board has identified the following weak-near,es in the LILCO emergency plans

1. Early Dismissal Normal early dismissal procedures, which LI140's plan incorporates, cannot bring children to unconto:minated areas quickly ortough to protect their health and as/ety,
2. Transportation We cannot guarantee that the requisite number of buses and drivers required for successful

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'7/g3 early ismissal will be available to the schools. Drivers may need to first attend to the safety of their own families and may decline te drive school buses. This will prolong childrens' stay ut schools in con-taainoted areas.

3. Needs of School Personnel We cannot guarantee that teaching and non-teaching personnel wil' stay in schools to supervise estly dismissal. These teachers and staff may need to attend to the safety e4 their own families and therefore may not be available to perform energency-related tasks.
4. Lock of Parental Supervision The success of an oorly dismissal plan 6epends not only on prompt dismissal from schools, but on prompt evacuation of children from their homes. In cases in.which parents will not be at home du,ing the day, children will be sent to unsupervised hones 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 confusion and chaos.
6. Panic An announcement of a nuclect emergency at Shoreham may cause disorientation and panic in children, teachers, non-teaching staff, and parents. This will further prohibit effective, safe d(saissal from schools.
7. Relocation If a Shoreham emergency develops quickly and requires an evacuation of children from schools directly to relocation centers, this cistrict will not have sufficient buses or drivers to transport all children to relocation centers in a timely, efficient manner. ,

, 8. Supervision at Relocation Centers We cannot guarantee that teaching and/or non-teaching school personnel will travel to and remain at relocation centers to supervise children

until parents arrive to retrieve them. 11/7/g3

9. Sheltering The LI140 plan suggests that sheltering (remaining indoors) may be the preferred protective action in specific Shoreham emergencies. However, many of this district's schools do not have basements or other structures necessary to provide adequate

' protection.

10. Trust in Public Information In the lit 40 plan, the only public information upon whl @ to base der,isions for protective actions will come fka the utility. lit 40, through its Public Sc'.lools Coordinatur and WALK-AM Radio, will both describe the sxtent of the emergency and recommend actions. Because LI!40 would be both operator of;th. plant and initator of emergency actions, potential for conflict of interest exista.

School Administrators, receiving information only from LI!40 and not from any governmento; oge. y, will be forced to decide upon actions with potentially serious consequences without the benefit of information from an obj3ctive source.

11. Indemnification LI!40 does not provide indsanification for school

, districto should damages, injuries., or deaths result from school administrators ' decisions during on

emergency, decisions which can be based only upor information and recommendations offered by LI140 Now,.be.it therefore RESOLVED, that this school district finds that LIL40's emergen plans for schools do not offer children school personnel, or parents of this district adequate protection in event of an accident at the Shoreham Nuclear Power Plant; and be it further RESOLVED, chat this school board c.annot direct its schools to initiate or participate in emergency actions which not only' fail to protect childrens' safety, but place it in further jeopardy; and, be it further RESOLVED, that this school board believes that full pwer licensing of the Shoreham Nuclear Power Plant should be forbidden unless or until complete and reasonable resolution of these outstanding, critical emergancy planning problema can be achi4ved.

1/7/83 The question of the adoption of the above stated resolution was duly put to vote on Roll Call which t resulted as fol. lows: 1 Amruso voting no does not want plant opened Gallo voting yes Durkin voting yes Brodsky voting yes Boder voting yes Reynolds voting no duplicate resolution Purick voting yes-Adler voting no duplicate resolution The resolution was thereupon declared duly adopted.

Motion by Gallo seconded by Brodsky to authorize the Superintendent of Schools and the Director of Trans-ARTICIPATION Portation to participate in meetings prior to the BC N NRC Hearings relative to the Shoreham Nuclear Power Plant; to appear at the NRC Hearings to state the concerns of the district; that the statements of the Superintendent of Schools and the Director of Trans-portation be reviewed by Counsel prior to appearance and, at the time of the hearings that Counsel be present to advise them.

The ;uestion of the adoption of the above stated motion was duly put to vote on Roll Call which resulted as follows:

l Amruso voting yes Gallo voting yes Durbin voting yes Brodaky voting yes Boder voting yes Reynolds voting yes Purick voting yes Adler voting no would not like the Superintendent to take the time from the diotrict

.in this matter.

The motion was carried.

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1lW I T. 't.M /. ~a 0:',':71 M. !:f m.",0), DIc;;;;0; MITW. IG U.'*D , 1:S.' YOT.*.

. v SCHOOL l'0.WD F5 SOLUTION 1!ESET.C , fodcral regulatipns for full podcr, operation of the"Shore-ham Nuclear Plant require en emergency plan for communities surrounding the plant which will assure thosc'comm adequate procection in event of a nuclear emergenc3, hggggy s,ify g TECF2nG, the Lo..g Island Lighting Company, in an effort to meet federal regulations, has prepared an omorgency plan which LILCO, lac'-:ing coordination with local or state governments, will nttempt to implement; and 4HEPII:S , the Nucisar Regulatory Com:tission's Shorcham licensing beard is now conducting hearings to review the adequacy of the LILCO.cmergency plan; and .

E EPab.3, the LILCO emergenby plan includes protective actions to be taken by schools; and .

!?HEPIAS, this board has identifica the following weaknesses in the LILCC cmcrgency plan:

1. Early Dismissal Our cicergancy early di.w.ss01 procedure, which LILCO's plan incorporates, wouldn' t bring school childrentheir to an uncontaminated area quickly enough to protect

.- ' health and safety. .

2.' T_ransoortation Tne requisite number of buses and drivers required for successful carly dismissal are not available to the schools. This will prolong childrens' stay at sc.hools in contaminated areas. . .

Nood: of Echool Personnel 3.

He cannot guerhnteel hat teaching and non-teaching .

personnel will stay in schools to supervise early

'di sminsal . Those teachers and staff may need to attend to the safety of their ovm families and, therefore, may '

not he availabic .t'o, perform emerijency-related tasha.

4. LacH of Parentnl' Succrvi'sion The success of an eaTly dicmissal plan depends not only

.on prompt dismissal froia schools, but on prompt evacua-tion of children f cm their homes. *In those casos in which parents will not be at home during the day, children -

will be sont to unsuperviced homes from which they will not be able to evacur,te promptly. .

5. Parental Intercension WC cAnnot be conticient that parents' will wait at home for their children to arrivo. 1:any parents may attempt *

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-2. Board Resolution to retrieve their children at schools, perhaps causing increased confusion and chaos. ,

6.. Relocation If a Shoreham emergency develops quickly and requires an evacuation of children from schools directly to relocation centers, this district does not have sufficient buses or

  • drivers to transport all children to relocation centers in a timely, effective manner.

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7. Supervision at Relocation Centers

' We cannot guarantee that teaching and/cr non-teaching school personnel will travel to and remain at relocation centers to supervise school children until parents arrive to retrie)re them. ,

8. Sheltering- .

The L1LCO plan suggests that sheltering (remaining indoors) may be the preferred protective action in specific shorcham emergencies. However, none of this district's schools have basements or other structures necessary to provide  ;

, adequate protection. '

.. 9. Trust in Public'Information In une LILCO plan, the only public information upon which to base decisions for protectivo actions will come.from the utility. LILCO, throngn'its Tublic Schools Coordina-tor and HALK-AM Radio, will both describe the extent of the emergency and recommend actions. Because LILCO would be both operator of the plant and initiator of' emergency actions, potential for conflict of interest exists. School ,

administrators, receiving information only from LILCO and , l not from any. governmental agency, will be forced to decide upon actions with potentially serious consequences without the benefit of a directive from a responsible governmental source.

10. Indemnification -

LILCO does not provide indemnification for school districts should damages, injuries, or deaths result f :<xn school l administrators' decisions during an emergene', decisions which can be mado based only upon informatic.1 and recom-mendations offered by LILCO.

Now, be it therefore , .

'tCSOLVED, that the Middle Is1'and central school .i District finds that LILCO's emorgency plann. for schools do not offer children or school personnel of this district adequato prote , tion in  ;

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. event of an accident at the Shorcham Nuclear Plant; and, be l

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4:IDDLT. ISM;;D Ct!.'TrdL SC!iOOL DISTRICT BO.\RD FIS LLTION 1

l RISOLVED, that this school bocrd believes that licensing of the Shorehan '

Nuclear Plant'should not be permitted unicss or until complete' and repsonable resolution of those outstanding, critical emergency planning problems can be achieved. '

e The above Resolution was passed'by the 1!iddle Island Central School District Doard of Educction ..

at the Board liceting on September 29, 1983.

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. S 4.L Lori D'Amico District Clerk ,

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i MP. SINAI UNION FREE SCHCOL DISTRICT Board Resolution of October 18, 1983 Be it resolved that an early dismissal or "go hcrre plan" is net an appropriate response to an order to evacuate in the event of a malfunction at the Shoreham Nuclear Power Station until the following issues are resolved, i 1. We State and County governments approve an impler.entable evacuation plan.

2. Se District can be assured that Bus Drivers, Emergency and Supervisory personnel of adequate force will be available to the District to implenent the plan.
3. nat such plan receives the review of the residents of the District.

'm mEIVRE Until such time, it is the position of the Board of Education that no plan shall be subnitted to any agency as such subnittal could be viewed as an agreement by the District that such a plan is feasible.

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SHORmAM RESOUMON Whereas the Mount Sinal School District lies within the energency Planning Zone of the Shoreham Nuclear Power Station and Whereas the Board of Eudcation is responsible for the health and safety of the students and staff of the district while on district property and Whereas an operating license can not be granted by the Nuclear Regula-tory Comission for said plant without an approved implenentable evacuation plan and Whereas the government of Suffolk County adopted a resolution on February 17, 1983 stating that due to our unique island geo-graphy and limited road capacity it would be impossible to devise and implenent an avacuaticn plan that wculd protect the public health and safety of the public and Whereas on that day the Governor of the State of New York annouriced his support of county government and stated then and pubse-quently that he would not impose an avacuation plan' on the county therefore be it resolved that the Board of Education of the Mount Sinal Union Free School District supports the decisions and position of the government of Suffolk County and the State of New York and be it further resolved that the Board believes that no operating license, either low or full power, should be granted to LILCD for the Shoreham Power Station until an implemntable evacuation plan that protects the public health and safety is developed and approved by Count.y and State Government.

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g. SINAI FAhEhT TEACHEn OhGANIZATICh ,-DKAFT nESQLUTIch tMEKEAS, the !.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 i its community and l i

WEEREAS, LILCO's emagency evacuation plan is dependent on our schools' early dismissal prpeeduress and WHEREAS, this PTO has considered the Yollowirs weaknesses in the .

. LILCO evacuation' plan

1. Transoortation We are certain that the required number of buses and .,

drivers for successful early dismissal will not be available to the schools. Drivers w 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 a children from school to home normally necessitates three .

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

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2. Needs of Schoo1 Personnal We are certain that not alk teaching and non-teaching personnel will stay in ' schools to supervise early dis-missal . h.any of the teaching and non-teaching staff will le' ave school to attend to the needs of their own families. Consequently, not enough school personnel.

will be available to attend to emer A teacher survey conducted in the v.gency-relsted . Sinai ' school jobs.

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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, i >

the success of an early dismissal plan depends not only  :

on prompt dismissal from. the schools, but on promptIt.

l evacuation of children from their homes as well.

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 l ,

T' evacuation.

4. Parental Intercession We cannot be assured that all parents will wait at home for their children to arrive. L.any parents will attempt l . to retrieve their children at schools thereby increasing confusion and chaos.

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i p-RESOLUTICE

5. Panic

'The announcement of a nuclear emergency at Shoreham will causa disorien'tation and panic in children, tea-chers, non-teaching staff, and parents. This will further hinder effective and safe dismissal from our schools. .

6. Relocation i ,

l If an emergency at Shoreham requires evacuating our children from schools directly to a relocation center, our school district would(Seebe unable to handle this (1, Trsnroortation) situation effectively.

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7. suvervision at helocation Osnters Cnce again we are certain that teaching and/or non-teaching school personnel will not all travel to end remain at relocation centers to supervise children for a possibly indefinite period oi' time. The Mt. Sinai

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teacher survey showed that over 71$ of the teachers would have left for their own homas after the first hour, and that a majority of the teachers would refuse to accompany children to relocation centers.

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8. Sheltering The LILCO plan suggests that sheltering, rather than evacuating, egy be' the pref erred protective action The Lt. in Sinal schools in gecific Shoreham emergencies.

school distuct has one basement in its elementary school. The size and function (for furnace and boiler facilities and the storage of aztra furniture) of this basement preclude the sheltering of all but a small number of our school population. -

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In Trust in Public tne LILGO plan,Information the only source of public information during an emergency is LILCO itself. As a result of I

I LILCC s past statements and actions with regard to Shoreham, many of us in our coccunity 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 of emergency actions--would tend to intensiiy~ doubts about the validity of LILCO's inforcation duri.y an emerg ency. .

New, be it therefore 7

SSOL\ EL, that the Lt. Sinai Parent Teacher Organization finds that LILCv's emergency plans for our schools do not off er us adequat6 protection or quick and ef fective evacuation for our children in the event of an accident 6 at the Ghoreham Nuclear Power Plants and l

l-y'riESOLUTION .i dTED, that we agres with 'our Suffolk County legislators  !

that in fact ag, .y.!L3f evacuation of our community is-possibles and .

OLVED that we believe that a full-power license should not be granted to the Shoreham Nuclear Power Plant.

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Rfftp T E A C H E R S' ASSOCIATION l I'

d D E 22 P4 :16 gg t.smo.=ow voas sim sis .m43ri RESOLUTION GCC,kim0'(fyV"!f l -

  • gg 1GREAS , federal regulations for full power operation of the Shoreham Nuclear Plant require an eacgency plan for communities surrounding the plant which .will assure those communities adequate. protaction in event of a nuclear emergency; and m, KIREAS ,

the Long Island Lighting Cospany, in an effort to meet federal regulations, has prepared an emergency plan which 1I140, M% coo:tination with local or state gevenmenta, will attospt to implement; and G EAS, the IJLCO emergency plan includes protective actions to be taken by schools; and GREAS, this association has identified.the following weaknesses in the 12 LOO eacgency plans

1. Early Dismissal ,

our emergency early dismissal procedure, which LILCO's plan incorporatas; wouldn't bring school children to an uncontam4=ted area quickly enou6h to protect their health and safety.

2 Transnortation

  • The requisite number of bases and drivers required for successful early dismissal are not available to the schools. 7his will prolong childrens' stay at schools in contam4 =ted areas.
3. Needs of TeacheTs We cannot guarantae that the teachers will stay in schools to supervise early dismissal. Many of us may nood to attend to the safety of our own families and, therefore, may not be available to perfora sacgency-related tasks.

! 4 Lack of Parental Suce-vision _

The success of an early dismissal plan depends not only on prompt dismissal from schools, kt on prompt evacuation of children from their homes. In those cases in which parents will not be at home during the day, children will be sent to unsupervised homes fmn which they will not be able to evacuate prosptly.

5. Parental Intercession

.Ve cu.not be confident that parents will wait at home for their children to arrive. Ma.ny parents may attempt to retrieve their children at schools, perhaps causing increased ocnfusion and shaos.

6. Relocation If a Snorehas energency develops quickly and requires an evacuation of children from schools directly to relocation centers, this district does not have sufficient buses or drivers to transport all children to -

ralocation centers in a tisely, effective sanna.:.

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T E A C H E R S' ASSOCIATION ,

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RISOLUTION - pa.gs 2  ;

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7. Sut>ervisien at selocation centers We cannot guarantee tnat teacners will travel to and remain at relocation centes to supervise school cMidren until peents arrive to recieve them.
8. Trust in Public Information In tne LILOO plan, tne only p tblic infor:Ation upon which to tase decisions for protective actions will come fro = the utility. LILCO, through its Public Schools Coord.nator and VALK-AM Radio, will toth describe the extent of the emergency and recommend actions. Because LILCO vould be both operator of the plant and initiator of enegency actions, ptential for conflict of inteest exists. School mAM M strators, receiving information only from LILCO and not fro = any governmental agency, will te forced to decide upon actions with potentially scious consequences without the benefit of a directive froa a respasible gov m ental source.

Now, be it thcefers D, that the Mount Sinal Teachers Association finds tha.t LIIc's emcgency plans for schools do not offe children or cchool pesonnel of this d.istrict l adequate protection in event of an accidsnt at the Shore.us Nuclear Plant; and, be it furthe -

'D, Qhat this association believes that licensing of the Shoreham Nuclear Plant should not be penitted unless or until complete and reasonable rosolution of these outetand.ing, critical emergency planning problems can be achieved. .

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9 TEACHERF A S S O CI A TI O N 1 887. S#4Al. NRW YO4E 11700 h

816 4F34321 I have on read the Mount the Shoreham Nuclear SinaiPlant. Teachers' Association Resolution '

I support the Association's d' * * " " * " - . .

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. MOUNT SINAI UNION FREE SCHOOL DISTRICT Mt. Sinai, New York 11766 ADCPTED - March 15, 1988 WHEREAS, this Board on July 19, 1983 and October 18, 1983 adopted resolutions expressing concern about the impact of licensing the Shoreham Nuclear Power Station upon the health and safety of the School District's students and personnel: ar,d WHEREAS, none of these concerns have been addressed, and because this Board has learned of a new Long Island Lighting Company proposal which also does not address these concerns:

and WHEREAS, LILCO represents in its revised plan that in the event of a Shoreham emergency requiring evacuation of the Schools, LILCO employees would perform functions normally performed by duly authorized school or contract personnel, i.e., transporting school children, by using LILCO/LERO employees to drive school buses, to evacuate in "one wave",

our students to a reloca tion center outside the 10 mile EPZ:

. and WH ERE AS', it is the position of this Board that it will not allow anyone who is not suthorized by this District to drive buses to transport our students, and we will not authorize our bus contractor to turn over to any unauthorized persons buses that are under contract to this School District:

NOW THEREFORE BE IT RESOLVED, that based upon this Board's determination that adequate protective actiens, including early dismissal and evacuation as proposed by LILCO, could not be implemented so as to insure the health and safety of s;hool children in the event of an emergency at the Shoreham Nuclear Power Station, tha Mount Sinai Union Free School District cannot, and will not, accede to LILCO's new school evacuation proposal: and be it further RESOLVED, that for these reasons and those set forth in prior resolutions, this Board believes that licensing of the Shoreham Nuclear Power Station should not be permitted unless and until complete and reasonable resolution of the outstanding critical emergency planning problems are achieved to the satisfaction of this Board, the County of Suffolk and the State of New York. And be it further

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RESOLVED, that in order to make the views expressed herein known, the Clerk of the Board is directed to send a certified copy of this resolution to the Nuclear Regulatory Commission, and the Atomic Safety and Licensing Board of the Commission having Jurisdiction over the Shoreham Proceedings.

The Clerk is also directed to send copies to the Governor of the State of New York and the Suffolk County Execdtive.

MOUNT SINAI UNION FREE SCHOOL DISTRICT Mt. Sinai, New York ADOPTED - March 15, 1988 WHEREAS, the Board of Education on this day, March 15, 1988 passed a resolution regarding the LILCO Emergency Plan for the Shoreham Nuclear Power Station: and WHEREAS, this Board desires to make its position known and represented before any body consider LILCO's Emergency Plan, THEREFORE BE IT RESOLVED, that this Board authorizes Board Member, Robert W. Petr11ak, to be its representative and speak on behalf of the Mount Sinai Board of Education 'in all matters pertaining to the LILCO Emergency Plan for the Shoreham Nuclear Power Statien.

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I am a bus driv'er employed by bus company end I drive a school bus for the 2 r ,6/; t.. , 1.

School District. I have been told that according to an smargency plan proposed by LILCO, I may be expected to drive a school bus in the event of a radiologicEl accident et the Shoreham i plant, as part of either an early dismissel or en -

evacuation of schools, i

This is to state that! '

1 I will not participets in implementing -

any LILCO emergency plan for Shoreham, and 2 I cannot and will not agree to drive a school bus in the event of an accident et Shoreham.

Dete_ Y '.I. i '- Signsturs I

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School Bus Driver Statements The following is a breakdown by school district of the 255 school bus driver statements signed in 1986.

School District No. of Statements Port Jefferson 10 Boces/ Central Islip 17 Patchogue 27 Sachem 5 Shoreham/ Wading River 12 Smithtown 1 Three Village 13 Mount Sinal 19 -

, Rocky Point 24 Comsewogue 19 Riverhead 16

South Manor 10 Miller Place 16 Middle Island /Longwood 64 Unspecified District 2 l

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i' THoM A3 S. CULoTTA fco 4-Ds CCONTY tatCUTtyt #

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'M' yj OFFICE OF THE EXECUTIVE

- NASSAU COUNTY ExECutivt SulL0iNG ONC vetST StettT MINEOL A. N1 1 I Sol March 15, 1988 Mr. William Catacosinos

Chairman and Chief Executive Officer Long Island Lighting Company 175 East Old Country Road Hicksville, New York 11801 Daar Bill, It has come to my attention that in its revised radiological M:morial Coliseum, emergency plan LILCO has included the use of the Nassau County V Medical Center as "relocation centers" to which school evacuees wouldt go in the event of a nuclear accident at Shoreham.

I remind you of Resolution No.782-1986, enacted on June 16,1986 by the Nassau County Board of Supervisors. It resolved "that no Nassau County facilities, including the Nassau Veterans Memorial Coliseum, are or will be FGeility available for Management use by theofLong Corporation New YorkIsland Inc.Lighting Company or by as part of the Long Icland Lighting Company emergency plan, unless prior approval by resolu-tion is first obtained from the Nassau County Board of Supervisors."

No such prior approval has been obtained by LILCO. Therefore, LILCO's plcn contradicts Resolution 782-1986.

supersede The Resolution NRC's newNo. rule for emergency planning does not and could not 782-1986 fccilities owned by Nassau County. Moreover, Nassau County P.esolutionbecaus No. 782-1986 is the binding law of this County. The Resolution makes obsolutely clear that Nassau County facilities are not available for uno in LILCO's emergency plan unless prior approval is granted by the Board of Supervisors. The B'oard has not granted this approval .

I bring to your attention a copy of a letter signed by all the County Supervisors lagt July in reference to this same issue.

Therefore, again I ask that LILCO stop misrepresenting that the Nassau Veterans Memorial Coliseum, Nassau Community College, Nassau 1

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OFFICE OF THE EXECUTIVE assaw cou o. isteevt e.'.o ~o o~t

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July 1, 1987 Administrative Law Judges Atomic Safety and Licensing Board U.S. NuclearD.C.

Washington, Regulation Commission 20555

Dear Administrative Law Judges:

conducting hearings on the Long Island evacuation plan, I must point out that the latest r r s now Lighting Com s emergency still must that contains assumptions be corrected. relative to Nassauevised County c

plan fa ili ties In its resolution of June 16, of Supervisors resolved that no county facilities are to b1986, the Nassa for the tase approval by LILCO is by resolution asfirst part of its emergency plan ,

e available "unless prior Coard of Supervisors." obtained from the Nassau County LILCO has not received permission from the Nassau B Supervisors and, to my knowledge,to include any county facilities in itsoard has not emergeof ncy plan even requested any specific approval.

I respectfully request, Police Department t from the plan. 'herefore, that the Nassau Couny t and the Nassau County Medical Center be removed Since )

ncum Jd42&m THOMAS S. CULOTTA County Executive f

/OSEP7N. MOND t.1.LO gh / - <

Prest' ding Supervisor OREGORY P4 TERSON Town of Hempstead SupervLspe, town f Hempstead K . KIERNAh ' ~

k ervisor JOSPHp~

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.upervisor, City a en Cove _ _

BRUCE NYMAN '

Supervisors,CitykfLongBea.h S",3gwich c: Mr.

W111'am Catacosinos Chairman Long Island and Chief Lighting Executive Officer Company 175 East Old County Road Hicksville, New York 11801 '

County Medical Center, Nassau County Police or any other Nassau County facility is part of LILCo's emergency plan or is otherwise available for use in the event of a nuclear emergency at Shoreham.

Thank you for your attention to this matter.

Sincere [

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THOMAS S. GULOTTA County Executive TStGW je Enc 1oriure CC: Honorable Lando Zech, Chairman Nuc' tear Regulatory Commission War.hington, D. C. 20555 He.norable Julius Becton, Director Federal Emergency Management Agency Washington, D.C. 20472 e

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1 MSOLUTICH NG. 782561916 A MSOLUTICW AMENDING A AFJCLUTICW ntTITLEDs

  • A MSOLUTION MIATIVE 20 T52 USE OF TIE NASSAU VETERANS MEMORIAL I COLISEUM IN A LONG ISLAND LICITING C0KPANY'S EVACUATION PIAN.*

(Fasses by leard of inervisers se Amt gg g Teses for 104 3 votes s4siaJt. s0FI . 1sease a r6:eluttee sa * 'Amt 1j g with the apprev d of the Astias reunty Kaeeuttive)

-.J WIMAS, the teng Islud Lighting Company has entered into an agreerient with the syatt Management Corporation of New York, Inc., which purports to designate the Nassau Veterans Memorial Coliscum as a Huclear Disaster Evacuation Center, and WEMAS, the County Attorney of Nassau County has advise the Board of supervisors that the terms of the lease between Nassa County and the racility Maaagement Corporation of New York, Inc.,

do not allow for such use of the Nassau Veterans Mercrial Co11seur and now, therefore be it MSOLVED, that the purported designation of the Nassau Veterans Mercrial Coliseum by the Long Island Lighting Co. pany as a Muclear Disaster Evacuation Center be and the same is hereby declared a nullit) , contrary to law and voids and be it further MSOLVID, that no Nassau County f acilities, including the Nas sau Veteraas Manorial Coliseum, are or will be available for the use by the Long Island Lighting Company, or by the racal Man a g e r e nt Corporation of New York, Inc. , as part of the Long Island Lighting Company e 4rgency plaa, unless prior approval by resolution is first obtained from the Nassau County Board of Supervisors; and be it further

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pzSoLVED, that a copy of tAls resolution shall be forth with served upon the Long Island Lighting Company and Facility pagament of New York, Inc., formerly known as Hyatt Kanagement Corporation of Wev Yo'rk, Inc., and filed with notice of such service, with the of fice of Nuclear Esgulatory cosadesion at wash 15 9 tua D.C.: and be it further REsoLyrD, that a copy of this resolution shall be forth with published in the of ficial nevepaper of the County of Nassau.

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ATTACHMENT 14 1

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LONG ISLAND LIGHTING COM g .r. .:. . ... t it s east oto COUNTRY RCAo

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Okeet DW Number- New YORE titol January 22,19Ah

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Richard R. Dores:us Ghn t e ha t..

Adelnistrative Route 25.\

Office'!adint River Central 50 Shorchae, MY 11736 .

Dear '4r. Richard P. Dore us:

Response Plan for the Shoreham and esintained by nut Nuclear pUe have con the Local offsite Esercer.cy ouer Station.

Cox. mission ercrgency at ('4PC) to provide for nublicLILCD sceording to the recu the LILCO facility. safety in the unlikely event of anuclear P.egu t'ie FRC rulus retardir.r, e~ertencyThe you up to date purrowe en a of this lette recent change in procedures for your facility unde; the er Shorchoreparedness olan. and ng to en As you know, particisate in decr ency stanning for oreho the Shnuf York have felk County re fused and the a*. ended' its f acility. to to participate in rules escr;ency to take pitoniclear thethatrefusal of State and The NRC recently np. '.ii l l no t rrevent opprovine an other sise a/ equate plan d local y.overntents rulu does not populations in the vicinityuerofplant.

asrus es (consi.< tent with sev a nuclear or rotecting poradify The new all any vill respond in an esergency. York State 14") that A ate and t lucal g* ove will respon I using their "besThe t e Eforts" new rule further assunes that governr rn ents

.ents LILCO has revised its plan, according to thplan, govera ents which hav and a that e at they vill follow the the tire of the escr;ency.

utility unle e not participated in exertency planning fe neu rule, to fs or Shorehas .

that public school students vill heo rchar eIn , 1.1the LCO 'sunlikely event of a regular contract bus corpanyareadrivers schools. and Your around shurchas.by buserelocat buses to tuo additional quelified and lleensed bus driLILCO's enough drivers and buses for a Local F. verge RO) will provide serve as back up drivers if an singic-usve evacuation. vers and huses to ensure that ther participste in the evacuation.y contract con:pany bus driver choope? pot

v' January 22, 1993 Page 2 to the ?lassau County Veterans Neveritt ColiseurAll will be evacuated public s he evacuated to the Nossau Cornunity their parents or guardians at Colle;e.Cistric rict schools, which 9111 like to use : different these er. location centors. Students Of cotirse, 'dll be reu if you ucul.t located outside the 10--ite radius of shorehaa . relocation center, such pursue a signed agreetent vich that facility .

we uould be phraser' to help you LE'!O offers to schedule and cone'.uetonsthe re.a,ular school bus driveen.

ra inin3necessa for your through schools, ve request (Since bus driver training should be coordinated advise ther of the training and to provide us t'ith a addition, ve of fer to provide siritar trainint list of Inbus d it r vers.)

school's designattiadelnistrative staf f who ray he asked to acco spany evaeustien procer!nresrelocation center. Trainin uses to yotir the role of evergency wo.g '<ill include rkers p la u n i n a.,instructions on enersency equipnent. uorker respo,nsibilities , and the propervith use, fanilies oforin for radiation r

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  • pent portLtipating in arcrgency preparedness This training will he training.LLL conductwd training. to coeple+ent your school district's existin energency ness p

L'e are ee?.er to "or% with you to ensure tha.

and would affecting your i'cleoce schonts the opportunity to icet "ich you to discuss

. ures the proced or to prepare a neu ene. 'le can help you to edify your existing eter;ency plan

'eme r ge nc y. that would incluie specific plans for a Sherehse.

contract to your sebool dis trict* e also eacournp.e you, your staf s underf, and the preparedness t r.'ininr,, drills and exercises.to participate in upcoting energency Please contact LLLCO F.ser;ttney Planant your eactiest convenience to discuss Joan t.'ir 1

j schedule training for your per4cnnel. Of course this eserr,ency lanning etfortp.and instoat (516) GM j en er'tency planning ef forts.contac t !!s. 'n'[:tgins if you have ques tions or Than. you for yeur cooperat ion and assis tance.

Yours er y, Dou;;l . Crocker, !!anager Fuelear 7.mergency Preparedness D:IC/ph 9

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. . 3. LONG ISLAND LIGHTING COM PANY it s east oto covutav mo A o . wicusvitte, wtw vo n x isso Direct DW Number January 22, 1915

97. EicharA Suprini 7 (ve rhe id Centeral School Dis t ric t

.s d r i n i s t r a t i v e o f f i c e 7 0 -)

OsNorne Avenue 1 Riverhete, NY 11701

Dear Dr. Richard Suprina,

L'c have Ea a r ge n contactei c y p.e s po n syou e Pla in n f the or nast about the Local Offsite Station. the Shorehar 'luelear Power This plan is develnped sud maintained by LILCO accordiag to the require ents of the Nuclest f.egulatory Coseission (NRC) to provide for public safety in the unlikely event of an et.ergeney at the.Shorehan fsellity.

The p u t tio s e of this letter is to brin you up to date on a

,recent c h a r. and ara.9sreinces g e te in tha "PC rules regardin; e ergen:y er.plein eter ency plannine, p roc e !u re s for your facilities unter the shcreha- plan.

As you k no r, S u f i o l '< C o u n t y a n d.

refused to parti:ipate in e ert.encytSe State of New York h ve e l s a n i n g. ter the Shorcha" facilitv. The PSC reecntly a~erde? its rules to to ake elesr thicinthe refusal of State a-> local severnvents participate e.ercency elsanin. vill Pot prevent the

': ". C f r o :-solely developed revievi.* by a and approving an otherwise adequate p1ti utility.

any of the substantive standards The fornav rule does protecting allnot sodify populstions in the vicinity of a nuclear pover plant.

"ovever, the neu rule assures (consistent with ':ev York Stste a lav) n e : e r e. e n cthat

y. 3cate The ne and toent gove:ntents vill respond in rule further assures that govern eats vill respond using their "best e!! arts" and that they will follo" theatutility available the tplan, is e ofuniess the es.ear gaore effective plan is e nc y .

its plan,ents govern a cunich c o r el hsoe i n g to the new rule to LitCO has revised facilitate.Its use 'O y plancing for Shorehne. not participated in erertency

La the unlikely event of an evergency at shorehae, t i t.00 ' s plan provides that students is public schools loested vith the "a 10watile li!1e ve"radius by b u sof e sShorehar vill be evacuate 1 in a outside tSe 10 vile areatoaround tuo relocation Shorehar. centers locatet For schools in your railusschool of Shor1 district 8

at, which are locateJ within the 10 rile your re;ular contract bus corpany drivers and buses will be used to evaeuste those schools, t1LCO'saddit previde tocalienal Erergeney qualified Response Crgani:ation (LERO) v11 and licensed bus drivers ani huses 1

to ensure sin 31e-veve evaruction. thatLERO theredrivers are eneush vill also drivers an back-up not drivers i f any contract cospany bus serve drivers as choose to participate in the evacuation.

All public to evacuated schools the Massau in the 10 r.ile radius of Shorehaa vill be exeept schools in the Coun ty Ve t e ran s !!en ori a l Coli s eur, School Tistricts, Lon: wood and Mount Sinai Union Free Cortunity Collero.which will be evacuated to the Nassau parents or'guarJians Sat t uthese dent srelocation 9ill be reunited centers. 91th their course, than the if you vould like to use a Of ene assi;ned to you in the Sharehar relocationplan,center suchother as another school Shoreh43, ne vould located he plessedoutside theyou to help 10 rile pursue radius an of ag ree: e n t vith the f a c i li ty.

For those schools i t.

the EP2 but which have sur schnel residing students district whleh within are the outside EP2, school officials vill bc asked to hold those :tudents at their schools until the parents or guardians arrive for the students' release.

Obviously, trainia;. an irportant eterent o f et er;ency pre aredness is LER3 sffers to schedule and co?!uct the needssary trainin;personnel.

school sessions for your re3ular schael bus drivers and Sinee bus driver training should be coordinated through your office, ne request that you contact your contract bus e orpo nie s to advise ther of the need for training and to provide us with a list of bus drivers for Shorehar. in Training schools your syster located within the 10 mile radius of t

procedures, the role vill of include instructions on evacuation faiilies for etergeney vorher erergency vorkers, planning with responsibilities, and the proper use of radia tion r.onitoring equiement. LILCO will reirburse spent bus drivers participating in and sebool personnel for their tite esergeney preparedness training.

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le are eager to ' sort uith you t o e: sure e ertency pre pa re d ne s s for your feto)1s. the effectiveness of the 161 orsortunity to rest 4e vould veico e to ansver cny cuestionJ. ith you to discuss "e tan also hel> t 'i e s e procedures vou t o *. o d i f *y ye ar exis t ing e er ency "ould i n c l u .' e setelfic pro"!sior.: plan or to tevelop 4 nesl one that

e for a Shoreha* e ergency.

enceurace you, unf er concree t to your staff and the seboat bus drivers your school distritt to participate in u:c,* tin; e ergency prepare 4 ness training, J: 1111 an!

  • "eretses.

? l e.i s e contact L 1 '. 0 0 e r g e n c 'r

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Pl.anner Joan h'iezins arrana,e your A:tivities.

at ( perticiottion

.t i f ) 43A-a: 16 at rour earliest eenven in thite T h .i n 't e tracnc" ple.nning you fer your c0c?t stion and assistance.

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awaarww LONG ISLANDwicu Ts cast oto couNtav mo Ao LIGHTING svitte, N ew vo n s CO uso Dkut Dial Namkr January 22, !??$

Mr. Charles P.

East Moriches UTSD Tu f a no, Superintendent 9 Adelaide Avenue East Noriches, NY 11?40 D e a r !! r . Tufano,

'a'e h a v e Emergency contacted Response you in the past about This plan is developed Planandfor the the tocal Of fsite requirerents of the Shorehar raintained Nuclear provide Power Station.

for public safetyHue le a r Re gu la to ry Cor.ri s stoiothe nby LIL at the Shorehar facility. in the unlikely event (NIC) to of an erergency The purpose of this c'hange in the MTC rules letter is to bring you up the Shorehasexplain erergency planning proceduresregarding to date on aemergency preparedness and recent to plan.

for your f aellities under As refusedyou know, Suifolk County and to participate faellity. the State of Mew York have the The H'.C in erergency planning refusal of state andrecently arended its rulesfor to the Shorehar local governr.ents make clear evergency planning will not prevent the NRC to participate from in that approving an otherwise adequate plan developed utility. reviewing and standards The new rule does not modify any of thesolely by a nuclear for protecting all populations substantive with Mew pover plant. However, the new in the vicinity of a York State law rule assures consistent respond in a n e re rge nc that y.)State and loca l gov e rnm(e nts governrents will respond usin The new rule vill vill follow the utility plan,g their "best further assures that available unless efforts" and that they at the tire of the emergency. a more eflective plan is plan, according governvents Shorehar.

which haveto the new rule, not participated to facilitate its use by LILCO has r.e v i s e d its in erergency planning for i l t

I

In the unlikely event of an erergency at Shorehar those schools whleh are located outside of the 10 mile evergency, planning zone (EPZ) vill be for Shoreham and which have students living within the EPZ requested parents / guardians toarrive hold the students for the at their schools until students.

LILCO's Local Erergency Response Organizatico (LERO) offers to conduct the necessary training sessions for your adv.inistrative and plansteaching for those staschools.

f f in the irplementation of your procedures and Ve are eager to bork with you to ensure the e(feetiveness of the Shorehar plan and would deleore the opportunity to r.eet with you to discuss the procedures affecting your schools. We would also encourage you training, preparedness and your drills, staff toand participate in upcoming emergency exercises.

Please contact LILCO Evergency Planner Joan Wiggins at (516) 436-4214 at your earliest convenience to discuss this emergency planning effort, and to schedule training for your personnit1. Of course, please do not hesitate to contact Ns. Uiggins if you have e f forts. or suggestions concerning our emergency planning questions Thank you for your cooperation and assistence.

Yours truly, y . . . v/ id{

Douglas M. Crocker, Manager Muelear Evergency Preparedness

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131 Hoffman Lane, Central Islip, NY 11722 January 22, 1988 Sister Patricia Grant Infant Jesus School Myrtle Avenue Port Jeffersen, NY 11777

Dear Sister Patricia:

We have contacted you in the past about plan is developed and maintained by LILCOThis

  • acco requirements of the Nuclear Regulatory Commission (NRC to pro-vide for publicfacility.

th'e Shoreham safety in the unlikely event of an emer)gency at change in the NRC rules. regarding emergency p explain emergency Shoreham plan. planning procedu'res for your facility under the As you know, Suffolk County and the State of New York have refused to facility. participate in emergency planning for the Shoreham the refusal of Str,te and local governments to participat emergency planning vill not prevent the NRC from revieving and approving ty. an othervise adequate plan developed solely by a utili-The nev rule does not modify any of the substantive stan-dardsplant.

pover for protecting all populations in the vicinity of a nuclear York State lav)Hovever,that the nev rule assumes (consistent with New State and local governments vill respond in an emergency.

respond using their "bestThe new rule further assumes that governments vill efforts" and that utility time of plan, the unless a more effective plan is available atthey vill follov emergency. thethe i

the new rule, LILCO has revised its plan, according to t

participated in emergency planning for Shoreham,to facilitate its us

In the unlikely event of an emergency at Shoreham, i

provides that parochial school students vill be evacuated inLILCO's plan

! school buses provided by LILCo's Local Emergency Response organi-zation (LERO) to the Nassau Community College in Uniondale, side the 10-mile area around Shoreham.unless you have a sep l Of cou se, if you vould l .

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Sister Patricia Grant January 22, 1988 Page 2 like to use a relocation center other than the one assigned to you in the shoreham plan, ve vould be pleased to help you pursue a signed agreement with that facility. The specific arrangements developed for your facility are shown below:

Transportation Monitorine S:a:!on Relocation Center Assis:ance LILCO-Se11more Nassau Community 6 Buses Hicksville . College Roslyn We are eager to verk vith 'you to ensure the effectiveness of the Shoreham plan and vould veicome the opportunity to meet with you to discuss the procedures af f ecting your schools. We can help you to modify your existing emergency plan or to prepara a new one that vould include specific plans for a Shoreham emergency.

We also encourage you and your staff to participate in upcoming emergency preparedness training, drills and exercises.

Please contact LILCo Emergency Planner Joan Wiggins at (5161 436-4214 at your earliest convenience to discuss this emergency planning effort and to schedule training for your personnel, of course, please do not hesitate to contact Ms. Wiggins if you have questions or suggestions concerning our emergency planning efforts.

Thank you for your cooperation and assistan:e.

Yours truly, s

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l D o u g'1 s . Crocker, Manager Nuclear Emergency Preparedness 1

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g' AW.1Wh*"Wrtco LONG ISLAND LIGHTING COM os t4sr oso countav mo A o wic s svitte. New voms u n o p-Dinet Dlal Number January 22, 1881 Mrs. Weber Ot. David School 563 Rodnoke Avenue Riverhead, NT 11901 Dear }1rs. Vebert We have Etergencycontacted Response you Planinfor the thepast about the Local Offsite Shorehap This plan is developed requireeents of the and raintained by Nuclear Power Station.

provide for public saNuclear Regulatory Cor>{ssionL1LCO according to the fety in the unlikely event (NRC) to at the Shorehat facility. of an emergency Th'e purpose of this. letter is change in the NRC rules to bring 'you up to date on a explain emergency planningregarding the Shorehas plan. procedures emergeney preparedness andrecent for your faellities under to As you to refused facility.

know, Suffolk paitleipate in County and the State of New York h The the refusal of stateNRC recently a endedevergency theplanning Shorehasfor emergency plannint will cnd local governments its rules to to take clear that participate in approving an arherwise adequate utility.

not Prevent plan thedeveloped flR C fror reviewing and standards The new rule does not nuclear power plant.for protecting all in the populationsmodi substantive vis inity of a fya However, the new with Mev York State respond in lav) that State and rule assures consistent govern:ents vill an erergency. The new rule further governr(ents local assures that vill will follow respond using their "best e f forts" and that they available at the theutility Ilee ofplan, the unless esergency.

a more effective plan is plan, according governrents Shorehav.

which have to the new rule, toLILCO not participated in faellitate has revised its use its by emergency planning for  ;

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In the unlikely event of an ere rgency at Shorehar, those schools which are located outside of the 10 mile emergeney planning zone (EP2) for Shorehas and which have students living within the EPZ will be requested to hold the students at their schools until parents / guardians arrive for the students.

LILCO's tocal Energency Response Organization (LERO) offers to conduct the necessary training sessions for your adminis tra tive plansteaching and for thosestaff in the implementation of your procedures and schools.

We are eager t o wo r's w i t h you to ensure the effectivenes: of the Shoreham plan and would veicore the opportunity to meet with you to discuss the procedures affecting your schools. We vould also encourage youtraining, preparedness and yourdrills, staff to andparticipate exercises. in upeorin2 erergency please contact ,

435-4214 at LILCO Ere rgency planne r Joan Viggins at ($16) your earliest convenience to discuss this emergency planning effort, and to schedule training for your personnel. Of course, please do not hesitate to contact Ms. Wiggins if you have questions efforts. or suggestions concerning our e=ergency planning Thank you for your cooperation and assistance.

Yours truly, i' r -

Doug as M. Crocker, Manager Muclear Erergency Preparedness

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_ _ =_ w LONG ISLAND LIGHTING COMPANY 131 Hofiman Lane, Central Islip, NY 11722 January 22, 1988 Ms. Katherine Donnelly St. Anselm's Nursery School North Country Road Shoreham, NY 11786 '

Dear Ms. Donnelly:

4 We have contacted you in the past about developed and maintained byResponse Plan for the .

ThisShoreham plan is N the Nuclear Regulatory Com.aission (NRC)LILCO according to the requirem ty in the unlikely event to provide for public safe-of an emergency at the Shoreham f acility.

The. purpose of this letter is to bring you up to date on a rec change in the NRC rules regarding emergency preparedness ent and explain emergency planning procedures for your facility.

As you know, Suf folk County and the State refused of N The NRC recently amended its rules to make clear that ty.

vill and local governments to participatethe not prevent of State in refusal emergency the NRC from revieving adequate plan developed solely by a utility. and approving an othe. vise modify anyvicinity tions in the of the of substantive standards a nuclear power plant forHowever, protecting all popul the nev NRC and rule local assumes governments (consistent vill respond inwith an New York emergency. State that State lav) further assumes that The new rule efforts" and that the governments vill respond using their "best effective plan is available atthey vill follow the utility's plan unless a more has revised its plan, consistantthe time of the emergency. LILCO vith the new rule, to facilitate planning for Shoreham.its use by governments which have not par n emergency In the unlikely event .

of an emergency at Shoreham, LILCO's Local Emergency If there is a possibility Response that organization (LERo) onvill pr .

radioactive particulates, they vill be taken firstthey may have been conta station tamination where they vill be checked for any possibletosigns a monitorin of con g and then to the temporary relocation center. The spe-cific arran,gements developed for your f acility are shown below:

Ms. Katherine Donnelly January 22, 1988 Page 2 Monitorino_ Station Relocation Center Transportation Assistance LILCO-Bellmore Hicksville Nassau Community 1 Bus Roslyn College Of course, if you vant can help you pursue a signed agreement with that f acility.t We vould like to meet with you to discuss LILCO's plan and th procedures that pertain specifically to your facility. We canose assist,you preparing in modifying a new one. your own existing emergency plan or in training drills and exercises so that you can evaluate these procedures and provide your suggestions for improvements.

I.f y.ou (516) vould,atplease 436-4214 call LILCO Emergency Planner Joan Wigg your earliest convenience.

We look forward to efforts.

meeting with you to discuss our cooperative emergency planning Thank you for your cooperation and assistance.

Yours tivly,.

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gI Doug.as H. Crocker, Manager Nuclear Emergency Preparedness

COUNTY OF SUFFOLK p +k A' t OFFICE OF THE COUNTY EXECUTIVE PATRICK G. H ALPIN Surrot.m CouNTv caccutivt February 19, 1988 Dr. Richard Suprina Riverhead Central School District Administrative Office 700 Osborne Avenue Riverhead, New York 11901

Dear Doctor Suprina:

This is in reference to the letter dated January 22, 1988, that you received from the Long Island Lighting Company reques-ting the involvement of your school district in LILCO's emergency planning for the Shoreham Nuclear Power Station. I am writing to

. correct f alse impressions that LILCO's letter creates about the actions and intentions of the government of Suffolk County and to make certain that the County's position is clear.

1. Suffolk County is opposed to the operation of the Shoreham plant. In February 1983, following nearly a year of extensive analyses, studies and hearings, Suffolk County deter-mined that it would not be possible to evacuate or otherwise protect the public if there were a serious nuclear accident at Shoreham. Given this, the County resolved not to adopt or im-plement an emergency plan for Shoreham. To have instead adopted such a plan, the County would have misled the public into be-lieving that they were being protected when in fact they were not. The County eniild not take such irresponsible action and jeopardize the safety of its citizens.
2. Suffolk County does not in any way support the emergency plan which LILCO is requesting your school district to support and help LILCO to implement. The . County opposes LILCO's plan because it believes that the plan does not and cannot protect the safety of the citizens of Suffolk County. This is the conclusion of experts of both Suffolk County and New York State who have evaluated LILCO's plan. For your information, on February 2, 1988, the NRC's Atomic Safety and Licensing Board ruled that the emergency plan which LILCO is asking you to support is "fundamen-ta41y flawed". The Board also found LILCO's emergency workers to be inadequately trained to perform many of the emergency response functions assigned to them. In the Board's word, L1LCO s emer-gency workers are "amateurs".

M. Let cc Nisom stoa e veten ANs wtwon:AL moww Av e HAuPP AUGr. N Y. I USS (S t el 36N000

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Dr. Richard Suprina February 19, 1988 Page 2 3.

LILCO's statements about sion's new emergency planning rule create the false impression that Suffolk County would follow LILCO's emergency plan and se u

theoperate to County's andbest ef forts a nuclear to implement accident occurred.the plan if Shorehamrewe FJrst, Suffolk County believes operate. that Shoreham cannot lawfully be licensed to Second, the NRC's new rule does not require, and cannot require, Suffolk County to use LILCO's plan. Third, the fact is LILCO's plan or authorize LII.CO to use it.that underwno c The County believes that LILCO's plan is a threat ci tizens, and that LILCO's emergency response organization andto emergency workers are incapab]c. Suffolk County would not en-danger resources. the safety of its citizens by relying upon such inadequat my staff If you have any questions, please contact Frank Petrone of at 360-4020.

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i Singer ly,

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>ATRICK G. iALPIN Suffolk County Executive PGH:ew P

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A-4 0 ATTACHMENT 15 9

MILLER PLACE UNION FREE SCHOOL DISTRICT Millor Picco, N2w YCrk 11764 SCHOOL BOARD RESOLUTION Adopted September 1, 1983 WHE RE AS , federal regulations for full power operation of the Shore-ham 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 WHEREAS, the Long Island Lightir.g 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 WHEREAS, the Nuclear Regulatory Commission's Shoreham licensing board is now conducting henrings to review the adequacy of the LILCO emergency plan; and WHE REAS , the LILCO emo'rgency plan includes protective actions to be taken by schools; and WHEREAS, this board has identified the following weaknesses in the LILCO emergency plan I

1. Early Dismissal Our emergency early dismissal procedure, which LILCO's plan incorporates, wouldn't bring school children to an uncontaminated area quickly enough to protect their
  • health and safety.
2. Transportation The requisite number of buses and drivers required for successful early dismissal are not available to the schools. This will prolong childrens' stay at schools in contaminated areas.
3. Needs of School Personnel We cannot guarantee that teaching and non-teaching personnel will stay in schools to supervise early dismissal. These teachers and staff may need to attend to the safety 6f their own families and, therefore, may not be available to perform emergency-related tasks.

4.

Lack of Parental Supervision The success of an early dismissal plan depends not only on prompt dismissal from schools, but on prompt evacua-tion of children from their homes. In those cases in which parents will not be at home during 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

M111'Or.PlCO3 UFSD . -

Board Recolution to retrieve their children at schools, perhaps causing increased confusion and chaos.

6. Relocation If a Shoreham emergency develops quickly and requires an evacuation of children from schools directly to relocation centers, this district does not have sufficient buses or drivers to transport all children to relocation centers in a timely, effective manner.
7. Supervision at Relocation Centers We cannot guarantee that teaching and/or non-teaching school personnel will travel to and remain at relocation centers to supervise school children until parents arrive to retrieve them.
8. Sheltering The LILCo plan suggests that sheltering (remaining indoors) may be the preferred protective action in specific Shoreham eme rgencie s . However, none of this district's schools have basements or other structures necessary to provide adequate protection. )
9. Trust in Public Information In the LILCO plan, the only public information upon which to base decisions for protective actions will come from the utility. LILCO, through its Public Schools Coordina' tor and WALK-AM Radio, will both describe the extent of the emergency and recommend actions. Because LILCO would be both operator of the plant and initiator of emergency actions,. potential for conflict of interest exists. School administrators, receiving information only from LILCO and not from any governmental agency, will be forced to decide upon actions with potentially serious consequences without the benefit of a directive from a responsible governmental source.
10. Indemnification r' LILCO does not provide indemnification for sebool districts should damages, injuries, or~ deaths result from school administrators' decisions during an emergency, decisions which can be made based only upon information and recom-mendations offered by LILCO.

Now, be it therefore RESOLVED , that the Miller Place Union Free School District finds that LILCO's emergency plans for schools do not offer children or school personnel of this district adequate protection in event of an accident at the Shoreham Nuclear Plant; and, be it further 9

Millor Placo UPSD -

3- Board R^ solution RESOLVED, that this school board believes that licensing of the Shoreham Nuclear Plant should not be permitted unless or until complete and reasonable resolution of these outstanding, critical emergency planning problems can be achieved.

e e e e The above Resolution was passed by the Millsr Place Union Free School District Board of Education at the Board Meeting on September 1, 1983.

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John'F. ' Mar rb District Cle 'k

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e-RESOLUTION ON LILCO'S NEW EVACUATION PLAN WHEREAS, on September 1, 1983, and on July 1, 1986, this '

Board adopted resolutions expressing its conce.rns about the impact of full power operation of the Shoreham Nuclear power plant upon the safety and health of the School District's students and personnel; and WHEREAS, ~

because the Board's concerns have not been adequately addressed, and because the Board has learned of a recent Long Island Lighting company (LILCO) proposal, the essence of which is set forth below, which still does not dispel those concerns, the Board now adopts this supplementary resolution; and WHEREAS, on information and belief, LILCO has recently represented to the Nuclear Regulatory Commission's Licensing Board with jurisdiction over the Shoreham proceedings that it is revising its emergency plan to provide that in a Shoreham emergency, LILCO employees would perform functions normally performed by duly authorized school or contract personnel, i.e.,

transporting school children, by using LILCO employees to drive buses provided by LILCO, from schools to certain other locations during a Shoreham radiological emergency, in order to evacuate all public school children from the 10-mile Shoreham EPZ, in a "single wave,* without the necessity of multiple bus runs; and WHEREAS, after due consideration of the logistical and practical realities involved in implementing early dismissal,

evacuation, or other protective actions for school children in the Miller Place School District during a Shoreham em ergency, this Board of Education has determined that it is highly unlikely that LILCO could, in the event of a Shoreham emergency , implement its plan in a way that reasonably might be expectedv toe pro id adequately for the health and safety of the children f rom the School District, and WHEREAS, on information and belief, neither LILCO's original emergency plan nor LILCO's new school evacuaticn proposal includes appropriate provisions for dealing with the potential liability of the Miller place School District or employees thereof, which could arise out of a Shoreham accident ,

or from protective actions attempted to be taken during such an accident; NOW THEREFORE BE IT RESOLVED, that, based upon this Board's determination that adequate protective actions , including early dismissal and evacuation as proposed by LILCO, could not be implemented so as to assure the safety of the school childrenn i the event or a Shoreham emergency, the Miller Place Union Free School District cannot, and will not, accede to LILCO's new school evacuation proposal; and be it further RESOLVED, that, for the reasons set forth in the Board's resolutions of September 1, 1983, and July 1, 1986, and for the reasons set forth herein, this Board believes that licensing of the Shoreham Nuclear plant should not be permitted unless and

until complete and reasonable resolution of the outstanding critical emergency planning problems are achieved, and be it

  • further RESOLVED, that in order to make known the views eEPressed herein, the Clerk of this Board is directed to send a certified copy of this Resolution to the Nuclear Regulatory Commission, and the Atomic Saf ety and Licensing Board of the Commission having jurisdiction over the Shoreham proceedings.

this is a true copy of a resolution unanimously adopted by thea public at Boardmeeting of Education held on of the Miller February Place Union Free School District 9,1988.

Diptrict Clerk -

Miller Place Union Frel School District eller Place, New York 11764 Fe,bruary 10, 1988 i

n

COMSEWOGUE SCHOOL DISTRICT Port Jefferson Station. New York SCHOOL BOARD RESOLUTION WHEREAS, the Comsewogue School District is located within the 10 mile radiological emergency planning zone of the Shoreham plants and WHEl:EAS, the Comsewogue Board of Education is cognizant of its responsibilities personnels and relative to the health and safety of students and school WHEREAS, the governments of Suffolk County .and New York State, after extensive analysis, decided not to adopt or implement any radiological emergency evacuation plan for response to a Shoreham emergency; and WHEREAS, New York State Supreme Court decisions have upheld Suffolk County's decision not to adopt or implement any plan for Shoreham and since the LILCO emergency plan for Shoreham has been found to be beyond LILCO's authority to implement, it would be inappropriate for the Comsewogue School District to cooperate with LILCO reFarding Shoreham planning: and WHEREAS, the Comsewegue Board of Education believes that the governments of Suffolk County and New York have acted responsibly and in furtherance of the interests of Cotasewogue School District residents-in deciding not to --

adopt or implement any radiological emeegency evacuation ~p7an'for Shoreham '

and WHEREAS, the Shoreham emergency plan developed by Long Island Lighting Company makes unwarranted assumptions about the willingness and capabihty of Comsewogue School District personnel to undertake emergency actions in the event of a Shoreham radiological emergency; and WHEREAS, the Comsewogue Board of Education after having surveyed its employees cannot assure adequate participation and supervision from school personnel and bus drivers, and on the basis of the limited transportation and other resources available to Comsewogue, it is clear that Comsewogue

school personnel could not and would not implement early cismissal. evacuation.

sheltering or other protective actions in the event of a Shoreham radiological e=ergency evacuation: and WHEREAS, the Comsewogue School District is informed that the Nuclear Regulatory Commission's Licensing Board concluded that Comsewogue school preparedness and is adequate for a Shoreham radiological emergency evacuations WHEREAS.~ the Comsewogue School District is informed that the Federal Emergency School District Management has ado Agency appears to have ignored the fact Comsewegue radiological emergency;pted and no plan and perfermed no training for a Shoreham -

11

RESOLUTION - SHOREHAM EVACUATION PLAN Page

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WHEREAS, that the mere acceptance and use of tone alert radios does not in any way indicate Comsewogue Board's acceptance of, or cooperation with ,

i LILCO's proposed evacuation plan.  :

NOW THEREFORE BE IT, RESOLVED, that the Comsewogue Board of Education recognizes its responsibilities to students and school personnel in the Comsewogue School l Districts and be it further '

RESOLVED. that the Comsewogue Board of Education recognizes that the .

LILCO Plan provides no way of dealing with the potential liability of the i Comsewogue School District or to the school employees which could arise out of lawsuits resulting from a Shoreham radiological evacuation, or from ,

protective actions taken during a radiological emergency evacuations and be it further l RESOLVED, that the Corrsewogue Board of Education fully supports the Suffolk County Legislature and the State of New York in their position of refusing to participate in Shoreham radiological emergency evacuation planning and in their opposition to the licensing of the Shoreham Nuclear Power Plants and be it further RESOLVED, therefore, that the Comsewogue Board of Education cannot and will not adopt or implement any plan for, or perform any training for, or participate in any exercise of school protective actions for response to a. - -

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Shorehsm radiological emergency, and that to do so would be irresponsible:

and be it further ,

RESOLVID, that the Comsewegue Board of Education concludes that no operating license be granted to LILCO for the Shoreham Nuclear Power Plant.

I hereby certify and swear that this is a true excerpt from the January 16. 1986, minutes of the Regular Meeting of the Board of Education of the Comsewogue School District.

CLd O hCLC,/.tfLV nathleen Gaghas, '

ij District Clerk em 9 99 h

PASSED RESOLUTION -- SHOREHAM EVACUATION PLAN BOARD OF EDUCATION, ROCKY POINT PUBLIC SCHOOLS

! The Rocky Point School Board hereby replaces and_ supersedes its 1983 shorehan Resolution with the fo11ovina May 19, 1986 Resolution ):

WEREAS, the Rocky Point School District is located within the 10-alle radiological emergency planning zone of the Shoreham plant; and WIREAS , the Rocky Point Board of Education is cognizant of its responsibilities relative to the health and safety of students and school personnel; and WEREAS. the governments of Suffolk County and New York State, after extensive analysis, decided not to adopt or implement any radiological emergency evacuation plan for response to a Shorehaa emergency; and ,

WEREAS, New York State Supreme Court decisions have upheld Suf folk -

County's decision not to adopt or implement any plan for Shoreham; and since the LILCO emergency plan for Shoreham has been found to be beyond LILCO's authority to implement, it would be inappropriate for the Rocky Point School District to couperate with LILCO regarding Shoreham planning; acd WEREAS , the Rocky Point Board of Education believes that the governments of Suffolk County and New York have acted responsibly and in furtherance of the interests of Rocky Foint School District rtsidents in

/ deciding not to adopt or implement any radiological emergency evacuation plan for Shoreham; and WEREAS , the Shoreham emergency plan developed by Long Island Lighting Company askes unwarrented assumptions about the willingness and capability of Rocky Point school personnel to undertake emergency actions in the event of a Shoreham radiological emergency; and WEREAS , the Rocky Point Board of Education af ter having surveyed its employees cannot assure edequate participation and supervision from school personnel and bus drivers, and on the basis of the limited traasportation and other resources available to Rocky Point, it is clear that Rocky Poin school personnel could not and would not implement early dismissal, evacuation, sheltering or other protective actions in the event of a Shoreham radiological emergency evacuation; and WEREAS , the Rocky Point Senool District is informed that the Nuclear Regulatory Commission's Licensing Board concluded that Rocky Point school preparedness is adequate for a Shoreham radiological emergency evacuation; and WEREAS , the Rocky Point School District is informed that the Tederal Emergency Management Agency appears to have ignored the fact Rocky Point School District has adopted no plan and performed no training for a Shoreham radiological emergency; and WEREAS , that the mere acceptance and use of tone alert radios does not in any way indicate Rocky Point School Board's acceptance of, or cooperation with LILCO's proposed evacuation plan.

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May 19,.1984 Page -2 of 2 pag:s PASSED RESOLUTION -- SHOREHAM EVACUATION PLAN 30ARD OF EDUCATION, ROCKY POINT PUBLIC SCHOOLS NOW TIERD0tX BE IT, RESOLVED, that the Rocky Point Board of Education recognizes its responsibilities School District; to students and and school personnel in the Rocky Point be it further RESOLVED, that the Rocky Point Board of Education recognizes that the LILCO plan provides no way of dealing with the potential liability of the Rocky Point School District or of the school employees which could arise or out of from lawsuits resulting protective actions from a Shoreham radiological evacuation, taken during a radiological emergency evacuation; and be it further RESOLVED, that the Rocky Point Board of Education fully supports the Suffolk County Legislature and the State of New York in their position of refusing to participate in Shoreham radiological emergency evacuation planning and in their opposition to the licensing of the Shoreham Nuclear Power Plant; and be it further RESOLVED, therefore, that the Rocky Point Board of Education cannot and will not adopt or implement any plan for, or perform any training

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for, or participate in any exercise of school protective actions for response to a Shoreham radiologcial emergency, and that to do so would be irresponsible; and be it further RESOLVED, that the Rocky Point Board of Education concludes that no operating license be granted to LILCO for the Shoreham Nuclear Power Plant.

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IMiil PORT JEFFERSON STATION TEACHERS Ass 0CIATION 545 siCYCLE PATH PORT JEFFERSCt1 STAT)0N, N. Y.11776 e=

Morton B. Margulies, Chairman September 22, 1986

_. Dr. Jerry R. Klien Mr. Proderick J. Shon _

Atomic Safety and Licensing Board Nuclear Regulatory Commission East-West Tower, Room 402-A 4350 East-West Highway Bethesda, Maryland 208114 Re: Shorehan Nuclear Power Station Gentloment -

The Port Jefferson Station Teachers Association is the represent-ative of the teachers of the Consowogue School District, As such, the P.J.S.T.A. has the exclusive right to negotiate working con-ditions and job related duties for the teachers in the Consewogue School District.

It is obvious that the Long Island Lighting Company has no auth-ority to speak for the P.J.S.T.A. or its members. Any assumptions which the Long Island Lighting Company may have made concerning the duties of teachers in the Comsewogue School District during a radiological emergency at the Shoreham Nuclear Power Station are without the knowledge or consent of the P.J.S.T.A.

Furthermore, the I,ong Island Lighting Company has never consulted with this organization in any manner concerning a radiological emergency evacuation plan.

We resent any attempt to present our Association as e participant in a plan without our prior consultation and agreement.

S ce ely, ae Robert Carr President, P.J.S.T.A.

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until complete and reasonable resolution of the outstanding critical emergency planning problems are achieved, and be it further RESOLVED, that in order to make known the views expressed herein, the Clerk of this Board is directed to send a certified copy of this Resolution to the Nuclear Regulatory Commission, and the Atomic Saf ety and Licensing Board of the Commission having jurisdiction over the Shoreham proceedings.

This is a true copy of a resolution unanimous)y adopted by the at Boardmeeting a public of Education of the Miller held on February 9,1988.Place Union Free School District Di rict Clerk '

Mi er Place Union Frel School District Willer Place, New York 11764 February 10, 1988 m_..