ML20028A076

Affidavit of E Lieberman Supporting Util 821109 Motion for Summary Disposition of Contention Re Traffic Congestion

ML20028A076
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	11/10/1982
From:	Lieberman E KLD ASSOCIATES, INC., LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20028A069	List: ML20028A068 ML20028A072 ML20028A076
References
ISSUANCES-OL, NUDOCS 8211160382
Download: ML20028A076 (4)

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I Attachmant 3

}# LILCO, November 9, 1982 a

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 1

In the Matter of )

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

) (Emergency Planning -

(Shoreham Nuclear Power Station, ) Phase I Unit 1 )

AFFIDAVIT OF EDWARD LIEBERMAN ON TRAFFIC CONGESTION State of New York )

) to wit:

County of Suffolk )

l My name is Edward Lieberman. My firm, KLD Associates, Inc., has been retained by LILCO to do evacuation traffic l

studies for the Shoreham emergency planning effort. From the surveys conducted in connection with this work, I am familiar with the roads that would be used in an evacuation.

The following facts are true and correct to the best of l

my knowledge and belief; they are numbered consistent with the i " Statement of Facts as to Which There Is No Genuine Issue To Be Heard on' Contentions EP 2(B), 5(B), and 7(B)," dated November 9, 1982.

8211160382 021112 '

PDR ADOCK 05000322 O PDR

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AMBULANCES I. From the fire station to the plant.

-A. From Wading River to the plant

2. The route from the Wading River Fire Department to the Shoreham Station is westward along North Country Road to the site.

3. Tne distance from the Wading River Fire Department to the site along the route described above is about 1 1/2 miles.

4. This 1 1/2 mile stretch of road is rural and the surrounding area sparsely populated.

5. Evacuating vehicles will move away from the plant, while ambulances from Wading River will go toward the p/48[. 2f)(#

II. From the plant to the hospital

12. Central Suffolk Hospital is located about 10 miles southeast of the Shoreham site.

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13. The preferable route from Shoreham to Central Suffolk Hospital is eastbound along North Country Road and l

Sound Avenue to Roanoke Avenue, then south along Roanoke Avenue l

to the hospital.

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14. The route described above is about 12 miles long.

15. The portion of Sound Avenue that would be used by ambulances is not an evacuation route and is unlikely to be heavily congested during an evacuation.

16. The distance from Sound Avenue to the hospital along Roanoke Avenue is about 3 miles.

17. Roanoke Avenue is unlikely to be congested.

18. An alternate route from the Shoreham Station to the hospital would be turning south onto Wading River Manorville Road and traveling to the Long Island Expressway, then east to Route N.Y. 25, then east to Roanoke Avenue, then North on Roanoke Avenue to the hospital.

19. Another route to the hospital is east on Route 25A to Route 25, then east to Roanoke Avenue, then l' orth on Roanoke Avenue to the hospital.

POLICE CARS

24. Police units would travel toward the station, whereas evacuating vehicles would travel away from the station.

4 VEHICLES OF LILCO PERSONNEL AUGMENTING THE ONSITE STAFF

30. LILCO site augmentation personnel will be traveling toward the station, whereas evacuating vehicles will be traveling in the opposite direction.

Unswde/ to If YZ e Dat'e

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Name Subscribed and sworn to before me on the 8 day of ,

1982. /

Notary P'u blic HOCHELLE I.ANOSMAN Notory Public, State of New York No. 52-4742519 Quellfied in Suffok Commiselon Empires March tab

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