ML20094A393

Testimony of Rh Hippert & DF Taylor Re Limerick Ecology Action Offsite Emergency Planning Contention LEA-11,12,13 14(a),14(b),15,22 & 26.Prof Qualifications Encl.Related Correspondence

ML20094A393
Person / Time
Site:	Limerick
Issue date:	11/01/1984
From:	Hippert R, Taylor D PENNSYLVANIA, COMMONWEALTH OF
To:
Shared Package
ML20094A385	List: ML20094A384 ML20094A393 ML20094A405 ML20094A416 ML20094A432 ML20094A582 ML20094A611 ML20094A639 ML20094A650
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OL, NUDOCS 8411060405
Download: ML20094A393 (25)

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REI ATED CC~3ry;33pq UNITED STATES OF AMERICA-NUCLEAR REGULATORY ' COMMISSION 00CKETED JWC Before the At'omic Safety and Licensing' Board g4

.e7.,,q P,,,1 c.g In the Matter of

)

)

Philadelphia Electric Company

)

Docket Nos. 50-352

)

50-353

-(Limerick Generating Station,

)

Units 1 and 2)

)

TESTIMONY OF RALPH J. HIPPERT AND DONALD F. TAYLOR FOR THE COMMONWEALTH OF PENNSYLVANIA-REGARDING LIMERICK ECOLOGY ACTION ADMITTED OFFSITE. EMERGENCY PLANNING CONTENTIONS. LEA-ll, 12, 13, 14(a), 14(b), 15, 22, 26 Introduction The purpose of_this testimony is to respond to certain contentions raised by Limerick Ecology Action (LEA) h concerning offsite emergency planning for the Limerick Generating Station.

Ralph J.

Hippert and Donald F.. Taylor are officials-of the Pennsylvania Emergency Management Agency (PEMA).

Their professional qualifications are attached to this testimony.

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LEA-ll

-The draft Chester and Montgomery County and School District RERP's are deficient in that there is insufficient information available to reasonably assure that there will be enough buses to evacuate the schools, both public and

private, in one lift.

8411060405 841101 PDR ADOCK 05000352 T

PDR o

This contention is structured around the basic question:

Have arrangements been made to ensure that sufficient buses will be readily available to evacuate the schools within the EPZ?

Ancillary questions are then posed as follows:

1.

What assurance is there that designated bus companies will actually provide the buses needed?

2.

Are letters of agreement with bus companies definitive in setting forth the obligations of each party and can the agreements be enforced?

3.

Do the plans have to include preassignment of buses to specific schools?

I 4.

Will the normal or emergency-related bus requirements of school districts outside the EPZ impede the availability of buses needed for evacuation?

5.

What procedures are, or should be, in place to ensure that designated buses from outside the area of normal school bus resources can be timely and effectively utilized?

6.

Does Chester County have written agreements with bus companies to provide buses needed for evacuation of school children?

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It is PEMA's posit' ion'that :should an evacuation become necessary arrangements must be 'in place to ensure the

)

action can be accomplished'in a timely manner by using one j

lift rather than multiple. bus-trips.

This requires a

coordinated effort by many parties.

The first step is for each risk school district to' determine how many buses it will require and the number that are'readily'available.

If the' buses.are not owned by the school district then consideraion must ~

be given to the impact of prior scheduling by the supplier on the prompt availabilityL of-the buses needed.

After this determination has been made the school districts then notify their respective county.as to the number of buses available to them and the shortages, k

if any, that must be met to effect a one-lift evacuation.

Each risk county emergency management agency then tries to arrange to meet.

these shortages from resources within the county.

If' this cannot be done the county reports its total school bus shortage as an

" unmet need" to PEMA.

It--

now becomes PEMA's responsibility, in coordination with_the Pennsylvania Department of Transportation, to fill these unmet needs by arranging to utilize bus resources from 1

counties outside the Plume EPZ.

If this cannot be done the i

i ultimate recourse is for PEMA to ask FEMA for assistance from adjoining states.

This is, and has been, the concept

' to fill unmet needs for response to any emergency within the Commonwealth of Pennsylvania.

In short, the procedure that is in effect to satisfy resource shortages is for the township or borough to go to its county and the county to L

PEMA rather than for direct negotiations--township to borough or county to county.

(R. Hippert) 2.

In accordance with the Pennsylvania Emergency Management. Services Code, P.L.

1332, No. 323, Section 1, codified in 35 Pa. C.S.A.,

PEMA, in developing plans for emergency response, is charged with.the duty and power

"<t>o plan and make arrangements for the availability and use of any private facilities, services and property and, if necessary, and if in fact used, provide for payment for use under terms and conditions agreed upon."

35 Pa. C.S.A.

Sectin 7313(10).

Given this defined responsibility and authority it is incumbent upon

PEMA, acting on behalf of the Commonwealth and in coordination with the Pennsylvania Department of Transportation, to make feasible and effective arrangements to ensure that any school bus shortage reported to it by the risk counties will indeed be filled if an evacuation becomes necessary.

The need for these arrangements is further emphasized in 35 Pa. C.S.A.

Section 7301(f) (4),- which -empowers the Governor, "ubject to any applicable requirements for compensation under Section 7313(10)

<to>

commandeer or utilize any private property if necessary to cope with the disaster emergency."

(R. Hippert) 3.

On September 10, 1984, PEMA received notification from the Chester County Department of Emergency Services by letter dated September 4, 1984 that the county had an unmet need for 134 buses.

Subsequent contact with the county 4

w

'l revealed that this-shortage consisted of. 80 buses to

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evacuate school children and 54 for the evacuation of persons without transportation, the handicapped and others not able to leave.by private automobiles.

Although-PEMA was advised by Chester. county that these figures should be considered subject to

change, no revisions have been received.

(R. Hippert) 4.

On October 23,

1984, the Montgomery County Office of Emergency Preparedness transmitted to PEMA two -copies of its Draft 7,

dated October

1984, Radiological Emergency

Response

Plan for Incidents at the Limerick Generation Station.

Upon checking Appendix Q-1, Annex 0 of this plan, PEMA learned that Montgomery County needed 387 buses and had that quantity available from within the county, and l--

thus was reporting no unmet bus needs for the evacuation of schools.

This was the first formal indication that PEMA had from Montgomery County regarding adequacy of buses.

While Montgomery County did report a

shortage of seven

" coach buses,"

PEMA subsequently learned that-these were not required for school evacuation.

PEMA is not aware of the status of agreements regarding these 387 buses since j

there are no agreements included in Annex T, Agreements and Statements of Understanding, of the referenced Draft 7.

Annex T

indicates that many agreements are under development.

(R. Hippert) 5.

The Southeastern Pennsylvania Transportation Authority (SEPTA) maintains a large fleet of buses to serve its five k

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county

area, Bucks,

Chester, Delaware, Montgomery, and Philadelphia.

SEPTA is therefore the logical source for filling the unmet bus needs of Chester County.

While the Governor has authority to commandeer the needed buses, it agreements and/or implementing procedures should be in Place to ensure that the. buses are and will be available to meet the shortage in Chester County.

While PEMA is responsible for making these arrangements, the Department of Transportation has the expertise to provide the technical information regarding assemblage of buses,.

estimated travel times to transportation staging

areas, fair compensation for use of buses and similar procedures l

or conditions that should be addressed.

PEMA and the l

l Department of-Transportation, together with their legal I

counsels are developing a proposed agreement that could provide for filling the unmet needs without the need to commandeer buses.

If this effort fails, the agreed-upon procedures will be invoked in support of the Governor's l

commandeering of buses.

When the proposed agreement i s --

l completed, PEMA and the Department of Transportation, in conjunction with Chester County, intend to meet with SEPTA and/or other bus companies that may be able and willing to agree in advance to meet the bus shortages needed to effect a

one-lift evacuation of school children.

At present it appears that such an agreement should be between the county l

involved and the bus company, with the Commonwealth serving as the catalyst for its consummation.

The Board will be i

N.

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7-kept-advised'

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as to-the ongoing. status and progress being made by' PEMA to resolve the unmet bus needs of'Chester County.

(R. Hippert)'

LEA-12 The draft Montgomery, Chester, and Berks. County RERP's and the School District. RERP's are-not capable of being implemented because there is not reasonable-assurance.. that there will be sufficient numbers of teachers and staff required j

to stay at. school during a radiological emergency if sheltering is recommended.as a

protective measure, or that there will be sufficient numbers of school. staff available to evacuate with children in'

.the. event of a

radiological emergency.

Therefore, children are not_

adequately protected by the draft RERP's.

The thrust of this contention is based upon-the question:

Will there be sufficient teachers and school

}

staff available to ensure the safety of school children' in the event ~ ~ sheltering or evacuation should be required?

Supporting questions are:

1.

What basis is there for presuming that teachers or school staff will stay on duty during a radiological emergency?

How will collective i

bargaining agreements impact upon this presumption?

2.

What is the basis for the apparent assumption in l

the plans that school buildings are adequate for l

sheltering as a protective action?

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3.

Are ongoing training programs an effective means of informing teachers and staff concerning the nature and scope of a potential radiological emergency?

4.

Can the capability to implement school district plans only be demonstrated by conducting unannounced evacuation and sheltering drills?

6.

The~ availability of teachers and school staff in the event of an accident at Limerick is a question that must be re' solved at the school district level, and is one that must be confronted by school officials in planning to meet any major disaster,.whether man-caused or natural.

If either sheltering or evacuation should become necessary, classes j

could be combined and thereby the normal students-to-teacher ratio could be reduced.

It is

not, however, a feasible solution to report an alleged lack of teachers or staff as an unmet need and expect it to be filled by personnel from outside the EPZ.

The time element _ _.

and problems involved in relying on such an alternative would indeed

hinder, and in all likelihood preclude, a

prompt and safe evacuation of the school children.

(R.

Hippert) 7.

At present, school district plans are written so that the risk school teachers are not only to accompany the children to the host school but are also to remain with them until they are picked up by their parents or other

':y

authorized individuals.

Although not the procedure preferred by PEMA, it is permissible-if acceptable to and desired by the schoo'l districts.

The course of action preferred by PEMA is for the risk teachers to accompany the children to the host school teachers and officials.

This permits the risk-teachers to be released to care for or rejoin their own families who'may also be involved in the evacuation.

While this could pose some problems at the host school, they are more of an administrative nature and do not have the impact of those confronting risk teachers concerned with the safety of their own families as well as that of the children under their charge.

An agreement between the host and risk school districts should resolve any supposed administrative roadblocks preventing use of j

this alternate procedure.

This alternative might assist a

risk school district to ensure that more of their teachers would be available t'o supervise the children during the evacuation phase only.

(R. Hippert) 8.

In response to the question raised about the suitability of school buildings for sheltering, the Pennsylvania Department of Environmental Resources, Bureau of Radiation Protection states in paragraph 10.2.2.2, Appendix 12, Annex E

to the Commonwealth's Disaster Operations Plan

that, "in the general climate of the Commonwealth, any building which is reasonably winter worthy will

suffice, with windows and doors tightly closed."

Sheltering as a

protective action is a

topic

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addressed: in Lthe training that is available,-and has been presented to teachers Land school staffs participating. in H'ppert) i this training.

(R.

LEA-13 There must be specific. and adequate. plans for children. in day care, -nursery and pre-school programs in order to provide reasonable assurance that this particularly sensitive segment of the:

~

population i.s adequately protected.

The contention is centered around the basic question:

Has adequate and specifics planning been accomplished to ensure the safety and protection of children in day

care, nursery and preschool facilities?

Additional questions are:

1.

Have the transportation needs to evacuate day care, nursery and preschool facilities been determined and can they be met?

2.

Do municipal and county plans identify all licensed, as well as unlicensed day care, nursery.

and preschool facilities within the EPZ?

3.

Have arrangements been made for preassignment of the transportation resources needed to evacuate these facilities?

l 4.

What will be the basis for a decision to implement sheltering at these facilities?

L

9.

'A model plan for use by day care, nursery an'd preschool facilities has been developed by PEMA in coordination with the. Pennsylvania Departments of Education 'and Public Welfare.

These two: departments subsequently sent. copies of the 'model plan to 'their licensed day. care, nursery and preschool facilities within the Limerick-Plume. EPZ ' and advised them of the necessity of preparing a

plan for response to an accident at Limerick.. Unlicensed facilities have subsequently been identified and have been. advised through the risk counties of the need for a plan and howcto

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obtain help in developing one.

(R. Hippert)

The model plan provides policy guidelines, recommended procedures for notifying parents in the event of an accident and a

detailed listing of actions to be taken under each emergency classification.

A sample letter to parents is' included in the model plan with explicit reference as to the action that would be taken by the facility.

(R. Hippert) 1 10.

Although provisions have been made in the model plan for parents to be notified to pick up their children at a

[

Site or General Emergency, the facility director also has

-the option of arranging for this action at the Alert stage.

It is the responsibility of the facility director to determine a location to host the children in the event evacuation is necessary.

Reference to the designated host site is to be included in the 1.etter to parents, and they I

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are expressly" advised to pick ~up their. children at this-location if an evacuation' takes place.

(R. Hippert) 11.

While the model plan indicates that -transportation required :for evacuation. is the responsibility of -the

facility, it also advises 'the facility to contact its municipal emergency management coordinator or the " county emergency management agency, if necessary, for assistance in developing.

a plan.

The facility plan must be

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coordinated with the municipal plan and. prudent and responsible action by the two ' parties should result in 1

resolution of any-transportation difficulties.

If not, 4

referral to the county would be the common sense approach to meeting the need.

(R. Hippert) 12.

A listing of day

care, nursery and preschool facilities should appear in the respective municipal plans and corresponding county plans.

In view of the effort recently expanded to identify both the licensed and unlicensed facilities, there is no viable reason why this cannot be done.

(R. Hippert)

LE A-14 (a)

The School District RERP's and the

Chester, Berks, and Montgomery County RERP's are deficient i

because there are inadequate provisions of units of dosimetry-KI for school bus drivers, teachers, or school staff who may be required to remain in the EPZ for prolonged periods of time or who may be required to make multiple trips into the EPZ in the event of a radiological emergency due to l

shortages of equipment and personnel.

l f

F This contention raises the specific' question:

Why do. not school

. districts and

Berks, Chester, and j

Montgomery County plans. include provisions for issuing dosimetry. and KI to school. bus drivers,. teachers, 'and school staff.

Accompanying questions are:

1.

Will all school buses be required to pass through the transportation-staging area before reporting i-to schools being evacuated?

If not, how will the drivers obtain' dosimetry and KI?

2.

How many units of dosimetry /KI will be available at the-transportation staging areas for Berks, Chester, and Montgomery Counties and what was the basis for determining that this amount would be i

adequate?

3.

Since sheltering could be recommended shouldn't teachers and school staff be issued dosimetry and trained in its use?

13.

As explained in response to LEA-ll it is PEMA's position-that evacuation of the school children be accomplished in a one-lift bus move, and PEMA has no reason to doubt that this can be accomplished.

As previously 1

indicated, definitive action is being taken to ensure that reported unmet bus needs can be filled.

This will therefore preclude the necessity for multiple trips and accordingly there is no need to have dosimetry or KI s

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'available for bus drivers, teachers or school staff.

Once l

0 the evacuation of

.the school children is. effectively l

. underway and all buses are enroute to host schools,.there is no requirement. for teachers or staff to remain at the risk school district ~or within the. EPZ, and thus no need for them to be issued either dosimetry. or KI.

Dosimetry and KI are issued only to emergency workers, and school bus L

drivers, teachers and school staff are not considered in this category for~the reasons indicated above. (R. Hippert) 14.

The one-lift concept pertains not only to the evacuation of school children but also to all persona to be evacuated by bus.

This in principle would eliminate the necessity for having any dosimetry or KI available at the transportation staging areas.

As a contingency there is certainly nothing wrong in maintaining a limited supply of dosimetry and KI at the staging area for potential use in meeting an unforeseen development.

The maintenance of a supply for routine issue of drivers of vehicles is, -

however, not necessary in view of the one-lift concept.

(R. Hippert) 15.

As stated earlier, school staffs are not considered emergency workers and therefore will not be issued dosimetry and need not be trained in' its use.

If sheltering becomes necessary the decision will be upon recommendations from the Bureau of Radiation Protection, utilizing monitoring data from its own sources, ' federal l

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agencies and the plant itself.

Similarly, the decision to terminate sheltering would be based on data from the same sources.

School staffs are considered part of the-general public and dosimetry.is not issued to the populace as a

precondition to determining the initiation or termination of sheltering as a' protective action.

(R. Hippert)

LEA-14(b)

The Chester, Berks, and Montgomery County School' District RERP's fail to provide reasonable assurance that school bus drivers, teachers, or other school staff are properly trained for radiological emergencies.

For the second part of this contention the question is:

Have the. school bus

drivers, teachers, and school staff received adequate training to enable them to respond effectively in the event of a radiological emergency?

What is the basis for this determination?

Follow-on questions are:

1.

Have they been trained to deal with contaminated individuals and equipment?

2.

Have they been advised as to the hazards of radiation exposure and the use of equipment to ensure their safety?

3.

Do teachers and staff know what areas of the school building cr complex are to be used for sheltering?

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4.

.Has any training been accomplished as to the handling of the potential stress and anxiety that

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could be_ displayed.by the school children during a radiological emergency?

-5.-

Are bus drivers familiar with the routes they are to use?

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'16.

Training specific to the needs of school'. bus drivers,-

teachers and' school staffs for response to~

an accident at' 4

Limerick has been and continues-to be offered.

It is available through contact with the emergency management agency for the respective risk county.

(D. Taylor, R. Hippert).

17.

School bus

drivers, school staffs and teachers will have been ' evacuated prior to any release of radioactive material from the Limerick facility.

Hence, there is no need for training in dealing with contaminated persons and/or equipment for these groups.

Further, in the remote possibility that decontamination may become necessary, the' ~

involved individuals and equipment would be referred to decontamination centers at the periphery of the plume EPZ, or at the mass care centers. (D. Taylor) 18.

Similarly, school staff personnel will not be issued dosmetry because they will have been evacuated prior to any release of radioactive material from the facility.

Hence, i

there is no need for instruction in the use of dosimetry.

i (D. Taylor) l l

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19.

If bus drivers.are not familiar with the routes they are to travel then provisions must be made to provide them with strip maps.

(R.. Hippert)

LEA-15 The Chester. and Montgomery County RERP's and the School District RERP's are not capable of being implemented because the provisions made to provide bus drivers who are committed to being-available during a

radiological emergency, or even during preliminary ' stages of alert are inadequate.

Like LEA-ll, this contention deals with the availability of sufficient buses to effect an evacuation of the school children but becomes more definitive ~by raising i

the question:

Even if sufficient buses are available, will L

there be enough drivers to man them?

Follow-on questions k

are:

1.

Are there letters of agreement with the bus companies to provide drivers as well as buses?

2.

Do employment or union contracts authorize or

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conversely prohibit, the utilization of bus drivers to evacuate school children during a radiological emergency?

If authorized, have the drivers been preidentified?

3.

Are bus drivers aware that some of them may be needed after the evacuation to transport the children from host schools to mass care centers?

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Have cons'iderations been given to the possibility that drivers living within the EPZ may give a higher priority to evacuating their own families I'

than to transporting-school children out of.the EPZ?' What is to preclude this from happening?

i 5.

Has the possibility of drivers being required to make multiple trips to effect.the evacuation been addressed in the ongoing training programs?

i 20.

As stated in response to LEA-ll,.Chester County. has identified for PEMA the County's unmet bus needs.

In the case 'of.

Montgomery County, the County has advised PEMA by copy of Annex 0, Draft 47 that there are no unmet bus needs.

This information does not include the

nature, number or language of any existing coiunty/ bus company agreements.

Therefore PEMA is not in a position to comment on the specific points raised in this contention.

In making arrangements to fill reported unmet needs PEMA will ensure that procedures are established to provide a

drive for each bus being made available.

When arranging to fill unmet needs PEMA gives priority to those necessary for the evacuation of school children.

The requirement for identifiable resources to fill both the unmet bus needs of schools and the geaaral public is recognized and will be handled accordingly.

(R. Hippert)

I

The. State,

County, and Municipal RERP's' are inadequate because farmers who - may be designated as emergency workers in order to tend to livestock in the event of a

radiological emergency have not been provided adequate training and dosimetry.

For this contention the issue is:

Have farmers who reenter the EPZ as emergency workers after an evacuation to

' tend livestock received adequate _ training and will sufficient dosimetry be available?

Follow-on questions are:

1.

Have the actual-number of farmers who would be in this category been identified?

i 2.

Will sufficient dosimetry be available to allow for multiple reentries?

3.

What does the definition of " livestock" include?

4.

Will an informational brochure be issued to farmers?

If so, when and how often?

5.

In addition to ongoing tra silog will refresher-training be offeref 5.,

L a ers on a regular basis?

l 21.

In recognizing farmers with livestock in the EPZ as emergency workers, PEMA has made no attempt to limit the l

definition of livestock nor to restrict-what is meant by a I -

with livestock to the U.S. Department of Agriculture farmer (USDA) list.

It is the responsibility of the county USDA

i l

agent, the county emergency management agency and the b

municipalities involved to develop a comprehensive list and ensure that it is as complete as possible.

Dosimetry must then be available for the number of farmers so identified.

It is not' necessary, however, to have additional dosimetry available for multiple reentries or replenishment of supplies.-

Dosimeters are not expendable items.

Each farmer will be issued two self-reading dosimeters and a

permanent-record dosimeter, as well as KI and a

Dosimetry-KI Report Form when authorized access to the EPZ.

The self-reading dosimeters can be used over

again, if necessary, rezeroing on dosimetry # argers located at the issuing points.

The pernanent-record dosimeters are to be used only be the individuals to whom originally issued, and are to be retained by that person until no further g

reentries are to be made into the EPZ.

(R. Hippert) 22.

The reference to farmers with, or who keep, livestock is found in several places in Annex E to the Commonwealth's Disaster Operations Plan.

See paragraphs II.M. (6) page E-16-2, V.A. pages E-16-B-8 and 9,

Tab 6, Attachment B on page E-16-B-6-1 and VI.C l. page E-17-8.

In none of the references is the phrase limited or restricted to any type of livestock.

(R. Hippert) 23.

While PEMA will provide for the training of instructors or a

course of instruction, it is the responsibility of the counties to train municipalities and~

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organizations in their respective. areas see paragraph II,

' Appendix 19, Annex E,

Commonwealth Disaster. Operations Plan).

This would include training.for. farmers in the use

-of_ dosimetry.

The existence =

'of an Emergency Workers.

Instructor' Course'is specifically referenced irr paragraph III.H, page E-19-2 'of Annex E.

-(R. Hippert)' Such training is currently -available and has been offered tol-farmers affected by Limerick.- Such training. will continue,to be made available to all farmers in the plume EPZ. (D. Taylor) 24.

An informational brochure was prepared by the Pennsylvania' Department of Agriculture for distribution to farmers within the plume EPZ of the Three Mile Island Nuclear Station.

The brochure could be adapted by the Department of Agriculture, in conjunction with PEMA, for k

use within the Limerick plume EPZ.

The applicant could then print and distribute the brochure within the Limerick EPZ, as was the case in the TMI area.

(R. Hippert)

LEA-26 The Draft County and Municipal RERP's are deficient in that they do not comply with 10 C.F.R. 50.4 7 (b) (5) because there

'is no assurance of prompt notification of. emergency workers who must be in place before an evacuation alert can be implemented, and there is no assurance of adequate capability to conduct route alerting.

25.

This contention was apparently developed under the assumption that county and municipal EOCs must be fully mobilized, and emergency workers in-place, before the

't

'public can be alerted:by activation of the siren system.

The sirens'can be activated from the communication centers, manned 24-hours a

day, in each of'the risk counties.

In the unlikely situation that an accident escalates so rapidly that only minimal mobilization, if any,. can be.

achieved, the sirens.

could.

be-activated by on-duty personnel in the communication centers, after telephonic coordination between PEMA' and the risk county coordinators.

Activation woald be acomplished, however, only upon order of the county coordinator to his communication center and after appropriate verification as to the validity of the order.

This would indeed be a worst case situation and is used only to illustrate that the degree of emergency worker mobilization has little relation to the capability for j

activating the sirens.

While route alerting would not be possible in this worst-case

scenario, it is but a

supplemental system to be used if necessary.

(R. Hippert) 26.

The sole purpose of activation of the sirens is to alert the public to tune their radios or TVs to the EBS.

It is not an automatic notification to evacuate.

In a

situation moving as fast as that referenced

above, evacuation would not really be a

feasible' option and sheltering would be the protective action to be recommended.

Broadcast of such a message over the EBS could also be handled without mobilization of the county EOC.

(R. Hippert)

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27.

As. indicated in paragraph V.

B., page E-8-2, Appendix 8

of Annex-E to the Commonwealth's Disaster Operations Plan, the sirens may be sounded:

1.

When there is significant information that will reassure the public of their safety.

2.

When the public is to be informed of a plant status that may lead them to implement.. specific actions on their own.

3.

When specific actions (to include protective r

actions) are to be taken by the public.

28.

This contention appears erroneously to equate activation of the sirens only to "an evacuation alert".

While an orderly and effective evacuation would necessitate i

nearly full mobilization of emergency workers,.the sirens could be activated for any of the purposes enumerated above l

well before this degree of mobilization is reached.

(R. Hippert)

I

PROFESSIONAL QUALIFICATIONS Ralph J. Hippert I am the Deputy Director, Plans and Preparedness for the Pennsylvania Emergency Management Agency.

I am involved in planning response to man-made and natural disasters at the State, county and municipal level with emphasis on potential accidents at fixed nuclear facilities.

I joined the Pennsylvania Emergency Management Agency in July, 1980, as a planner in the areas referenced abcVe and assumed my present position in May, 1981. For several months prior.to that I was a consultant working on municipal preparedness plans for communities surrounding 'IMI.

In October,1979, I completed over 32-years of active and reserve military service with the last seven years on active duty as a faculty member.at the U.S. Army War College. I have held Army Reserve assignments from platoon-leader to battalion commander to deputy commander of brigade size units. These assignments. included responsibility for mobilization planning and response to. civil disturbances, such as the Watts Riot in Los Angeles.

My civilian positions were: Public Relations Manager for a multi-plant international company; Advertising Manager for the same concern; and Assistant to the Sales Manager for the Agricultural Division of an international chemical company.

I hold a.B.S. in Business Administration from the University of California and a M.A. in Political Science from Shippensburg State College.

I am a graduate of the U.S. Army Command and General Staff College and the Amy War College.

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BldGRAPHY OF DONALD F. TAYLOR Donald F. Taylor is presently the Director of Training and Education for the Pennsylvania Emergency Management Agency. His office is in Harrisburg, but he conducts a wide variety of training sessions throughout the Commonwealth.

Mr. Taylor, a native of western Pennsylvania, received his bachelor's ' degree from Geneva College, which is located in Beaver Falls, Pennsylvania. He completed graduate work on two master's degrees and a doctorate at the University of Pittsburgh.

His employment.with the Commonwealth of Pennsylvania began in April, _1977 when he was named as the Nuclear Civil Protection Officer add charged to develop the Pennsylvania Crisis Relocation Plan.

In July,1978, Mr. Taylor was promoted to head the Office of Training and Education. He designs, implements and manages a state-wide compre-hensive training program in the field of emergency management.

Mr. Taylor has experience a.= a high school teacher, a college teacher and a college adminis rator. He has also managed political campaigns and has been a political speech writer. In addition f

to being the editor of two newsletters, he has written for both news-l papers and magazines. He served as the director of a rehabilitation center.

Mr. Taylor has also been active in several business ventures.

He presently resides in New Cumberland, Pennsylvania.

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