ML20081A753
| ML20081A753 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/02/1984 |
| From: | Regensburg K, Snow R, Stile V SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20081A747 | List: |
| References | |
| OL-3, NUDOCS 8403060266 | |
| Download: ML20081A753 (28) | |
Text
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.a, RELATED CORRESPONDENCE q ga, En UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'84 tiAR,_ N1 :03 3
Before the Atomic Safety and Licensing Board
- n..g ;.
IT{:ll, SEi Gi BRAllCH
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
DIRECT TESTIMONY OF DEPUTY INSPECTOR KENNETH J.
REGENSBURG, DEPUTY INSPECTOR ROBERT A.
SNOW AND POLICE OFFICER VINCENT R.
STILE ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 20 AND 55-58 --
NOTIFICATION TO THE PUBLIC March 2, 1984
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8403060266 840302 POR ADOCK 05000322 T
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DIRECT TESTIMONY OF DEPUTY INSPECTOR KENNETH J.
REGENSBURG, DEPUTY INSPECTOR ROBERT A.
SNOW AND POLICE OFFICER VINCENT R.
STILE ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 20 AND 55-58 -- NOTIFICATION TO THE PUBLIC I.
Introduction Q.
Please state your names, occupations and professional backgrounds.
i A.
My name is Kenneth J.
Regensburg.
I am the Executive Officer of the Fifth Precinct, County of Suffolk Police Department.
I was assigned to the Fif th Precinct on January 16, 1984.
Prior to that time, I was the Commanding Officer of the Department's Communications and Records Bureau for five years.
I hold the rank of Deputy Inspector in the Police Department.
My name is Robert A. Snow.
I am the Commanding Officer of the Ccmmunications and Records Buroau, County of Suffolk Police i
Department.
I was formerly the Commanding Officer of the Com-munications Section of the Department's Communications and Records Bureau.
I hold the rank of Deputy Inspector in the Police Department.
My name is Vincent R.
Stile.
I am a Police Officer assigned to the Communications Technical Serviges Unit, County
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of Suffolk Police Department.
I have been the Communications Coordinator for the Department since 1975.
I have been assigned to the Department's Communications Technical Services Unit for 17 years.
Statemants of our qualifications and experience are atta-ched to our testimony concerning Contention 26 -- Notification of_ Emergency Response Personnel.
Our Contention 26 testimony also explains the general organization and structure of the Suffolk County Police Department ("SCPD").
II.
Purposes and Conclusions 1
Q.
What is the purpose of this testimony?
A.
-The purpose of this testimony is to address Emergency Planning Contentions 20 and 55-58, and to discuss concerns regarding LILCO's proposals for notifying the public in the event of an emergency at the-Shoreham plant.
We have identi-fled a number of deficiencies and inadequacies in the notifica-tion scheme relied upon by LILCO which lead to certain conclu-sions.
Q.
What are these conclusions and where are they discussed?
l C.
A.
We understand-that LILCO is required under NRC regu-lations to establish means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ.
The public notification system must be capable of 1
essentially completing initial notification to the public "within about 15 minutes."
10 CFR Part 50, Appendix E, Saction IV.D.3.
See also NUREG 0654,Section II.E.6 and Appendix 3 thereto.
In our view, for a number of reasons the LILCO Plan provides no assurance that the public will receive notification of an emergency within 15 minutes.
First, as discussed in Part III of this testimony, deficiencies noted in our testimony con-cerning Contention 26 lead us to conclude that LILCO will be unable to contact its key command and control personnel in a s
timely manner.
As a result, the activation of the siren system relied upon by LILCO to alert the public to an emergency at Shoreham will likely.be delayed.
Second, as discussed in Part IV of this testimony, the LILCO Plan does not provide adequate backup in the event of failure of the LILCO siren system.
Third, the tone alert radios relied upon by the L!LCO Plan do not provide adequate notification of an emergency to special facilities and,
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organizations with a large number of personnel, such as schools, hospitals and major employers.
Further, because WALK radio station does not broadcast on its AM frequency at night, a significant number of persons may not 'e notified of or o
receive adequate information about an emergency at the Shoreham plant.
These matters are discussed in Part V of this testimo-ny.
Finally, as discussed in Part VI of this testimony, the LILCO Plan relies upon commercial telephones for contacting special facilities and the handicapped at home to determine whether they are aware of the need to evacuate and to determine their specific needs for assistance.
In our view, this does not provide an adequate, workable or dependable means of timely notification of or communication with these special facilities and individuals.
III.
Contention 55 -- Delays in Activating the LILCO Siren System i
Q.
Contention 55 alleges that LILCO's inability to con-tact its key emergency response personnel in a timely manner may delay the decision to activate the LILCO siren system.
Do you agree with this Contention?
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A.
Yes.
Under the LILCO Plan, a system of 89 fixed sirens will be used to alert the public to an emergency at the Shoreham plant.
(See Plan, at 3.4-6).
However, for the reasons discussed in our testimony concerning Contention 26 (Notification of Emergency Response Personnel), it is unlikely that LILCO will be able to contact its key command and control personnel, including the Director of Local Response, in a time-ly manner.
As a result, the decision to activate the LILCO siren system may be delayed.
Moreover, even after the Director of Local Response and other key personnel are contacted, the LILCO Plan appears to require a number of actions to be taken before the LILCO siren system can be activiated.
(See OPIP 3.1.1).
As a result, activation of the siren warning system may be further delayed.
Q.
Please explain.
A.
Under the LILCO Plan, the Director of Local Response is responsible for implementing the actions necessary to acti-vate the LILCO siren system.
(See OPIP 3.3.4, at 1).
For an Alert or higher classification emergency, even after the Director is notified, the LILCO Plan appears to require that he take a number of actions before he can activate the LILCO siren system.
At a min,imum, these actions include (1) contacting the.
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i Hicksville Customer Service Office and completing the "LERO Event Summary Sheet" (see OPIP 3.1.1, at 2 and Attachment 1);
(2) reporting to and activating the Emergency Operations Center
("EOC") at LILCO's Brentwood facility;1/ (3) obtaining from the Radiation Health Coordinator any protective action recommenda-tions and directing the implementation of those recommenda-tions; (4) contacting the Coordinator of Public Information to ensure that a news release and an Emergency Broadcast System j
("EBS") message for activation of the siren system are being prepared; (5) ensuring that the Coordinator of Public Informa~
tion has notified WALK radio of the emergency, and transmitted the EBS message to WALK; and, (6) ensuring that WALK is pre-pared to broadcast the message.
Only when the EBS is activated is the Director authorized to activate the siren system.
(See OPIP 3.1.1, at 8; OPIP 3.3.4, at 2).
In our view, it is unrealistic to assume that the Director of Local Response could be notified of an emergency at the Shoreham plant in time to take the actions required for siren 1/
Under the LILCO Plan, the Director of Local Response can activate the LILCO siren system without being at the EOC, or before the EOC is activated.
However, there must have been notification of a General Emergency requiring protec-tive actions before the Plan authorizes the Director to activate the sirens without being at the EOC.
(See OPIP 3.1.1, at 13; OPIP 3.3.4, at 2-3). J
activation under the Plan within 15 minutes of the declaration of the emergency.
Indeed, as a result of the deficiencies in LILCO's communications system for notifying emergency response personnel of an emergency at the plant (see our testimony regarding Contention 26), the Director of Local Response may not be notified of an emergency within 15 minutes.
Therefore, in our opinion, LILCO does not ht ve the capability of notifying the public within even 30 minutes after the declaration of an emergency.
Q.
Is there any alternate procedure in the Plan to deal with the possibility that the Director of Local Response could not be found?
A.
The LILCO Plan does provide for activation of the siren system by the Customer Service Supervisor if the Director of Local Response cannot be contacted "promptly," which the i
Plan defines as within 10 minutes after receipt of notification of an emergency from the Shoreham plant.
However, this proce-dure applies only if a General Emergency involving immediate protective action recommendations is declared.
(See OPIP 3.3.4, at 2-3).
In this circumstance, the LILCO Plan instructs the Customer Service Supervisor to notify the Shoreham Emer-gency Director (a member of LILCO's on-site emergency team) and t,
T request that the Shoreham control room activate the siren system using the encoder located in the control room.
(See OPIP 3.3.4, at 3). In all other instances, however, the Director of Local Response is responsible for activating the siren system.
(See OPIP 3.3.4).
Thus, under the LILCO Plan, in all but one limited circumstance (a General Emergency requiring immediate protective actions), the LILCO siren system cannot be activated until the Director of Local Response has been contacted.
In addition, because under the LILCO Plan the activation of the siren system must occur simultaneously with the broad-cast of an EBS message over WALK radio, (see, e.g.,
OPIP 3.1.1, at 8; OPIP 3.3.4, at 1), additional delay in siren activation is likely.
First, under the LILCO Plan, the EBS can only be activated j
by communications with WALK radio station (see OPIP 3.8.2, at 1-2).
However, until the local EOC is activated, commercial tele;. hones provide the only means of contacting WALK radio station.
(See Plan, Figure 3.3.5)u Indeed, even after the EOC is activated, thereby making available a dedicated telephone line between the EOC and WALK radio station (see Plan, at 3.4-4), both LILCO's primary (dedicated telephone) and secondary (commercial telephone) communications means with WALK trill have common failure modes.
Thus, for the reasons discussed in our testimony regarding Contention 26, there is no assurance that the EBS can be activated in a prompt manner.
This could delay activation of the siren system.
Even assuming that LILCO is able to contact WALK radio without significant delay, it is unrealistic to assume that an EBS message can be prepared and transmitted to WALK within 15 minutes from the time an emergency at Shoreham is declared.
Under most circumstances, activation of the EBS requires the LILCO employee who is assigned to the position of Coordinator of Public Information to telephone WALK, ask for the EBS opera-tor on duty, and provide his name, title and authentication number, which must be verified by the EBS operator against the authentication number available at WALK.
If verification can-not be made, the EBS cannot be activated.
(See OPIP 3.8.2, at 2).
Assuming verification of the authentication number, the WALK EBS operator will record the message read by the Coordinator of Public Information.
(See OPIP 3.8.2, at 2).
Of course, before telephoning WALK radio, the Coordinator of Public Information must have prepared the appropriate EBS message.
(See OPIP 3.8.2, at 3-5).
This requires the,
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Coordinator of Public Information to have access to various information, including the time that the emergency was de-clared, the names and titles of emergency response officials, and information, if appropriate, about the time of release, amount of radiation released, protective action recommenda-tions, the emergency planning zones affected, and descriptions of the zones.
(See OPIP 3.8.2, at 5).
Only after this infor-mation has been obtained from those individuals authorized under the LILCO Plan to make the necessary determinations and decisions, and used to modify one of a number of pre-established sample message formats contained in the Plan (see OPIP 3.8.2, at 4-5) can an EBS message be transmitted to WALK radio.2/
2/
While the LILCO Plan assumes that an EBS message will gen-erally be prepared and transmitted to WALK by the Coordinator of Public Information, either the Director of Local Response or LILCO's Customer Service Supervisor can also activate the EBS.
(See OPIP 3.8.2, at 1-2; OPIP 3.3.4, at 2-3).
Under the LILCO Plan, however, irrespec-l tive of who contacts WALK, that person must first attempt to contact some other person.
For example, before the i
j Director of Local Response is authorized to contact WALK to activate the EBS, he must attempt to contact the i
Coordinator of Public Information.
(See OPIP 3.3.4, at 2).
The Coordinator of Public Information and the Custom-er Service Supervisor, on the other hand, must first at-tempt to contact the Director of Local Response.
(See
(
OPIP 3.3.4, at 2, 3).
Should the Director not be able to be contacted, the Customer Service Supervisor is charged with activating the EBS.
Thus, as a practical matter, the
. Coordinator of Public Information is only authorized to activate the EBS when instructed to do so by the Director of Local Response.
(See OPIP 3.3.4, at 2, 3).,,
The necessity for simultaneous activation of the EBS snd the LILCO sirens system also, as a practical matter, renders l
impractical the LILCO proposal that the Customer Service Super-visor request the Shoreham Emergency Director to activate the sirens if the Director of Local Response cannot be notified.
(See OPIP 3.3.4, at 3).
Although authorized by the LILCO Plan to activate the CBS (see OPIP 3.3.4, at 3; OPIP 3.8.2, at 2),
the Customer Service Supervisor would not have the necessary information to prepare an EBS message for broadcast to the public.
In our view, the deficiencies in LILCO's proposed system for notifying emergency response personnel, the Plan's require-ment that the LILCO siren system be activated simultaneously with the activation of the EBS, the proposed means of communi-cations with WALK radio, the various actions necessary to prep-aration of an EBS message before it can be transmitted to WALK, and the limited number of LILCO personnel authorized to acti-vate the EBS are all factors which lead to the conclusion that the LILCO siren system could not and would not be activated within 15 minutes after an emergency at the Shoreham plant is declared.
T IV.
Contention 56 -- Inadequate Backup to the LILCO Siren System Q.
Contention 56 alleges that the LILCO Plan does not provide adequate backup in the event of failure of the LILCO siren system.
Do you agree with this Contention?
A.
Yes.
Under the LILCO Plan, LILCO proposes to use mo-bile public address systems, or loudspeakers, mounted on LILCO vehicles driven by route alert drivers to provide backup to the ciren system.
(See Plan, at 3.3-4 and 3.4-6; OPIP 3.3.4, at 4-4A and Attachment 1).
In our opinion, LILCO's proposal to drive vehicles equipped with loudspeakers through non-activated siren areas in order to alert the public to an emergency at the Shoreham plant is impractical and unworkable.
Q.
Please explain.
i A.
The sirens which LILCO will use to notify the public have no backup power source.
(See deposition of William Renz
("Renz deposition"), at 78).
Further, the LILCO siren decoders only confirm that a signal to activate the sirens has been sent from the siren encoder and received by the decoders at the siren locations.
Thus, even if LILCO's sirens were to fail to
(
activate, LILCO would still receive confirmation that the signal to activate the sirens had been sent and received.
(See t -
Renz deposition, at 77-79).
As a result, LILCO would not know whether some of its sirens had failed to activate, thereby requiring route alert drivers to be sent out to notify the public.
In order to verify whether the sirens have activated, LILCO intends to rely upon telephone survey results obtained during an emergency by Marketing Evaluations, Inc.
(See OPIP 3.3.4, at 3; see also, Plan, Appendix B, at APP-B-53).
According to the LILCO Plan, this survey will consist of a Mar-keting Evaluations representative (s)3/ telephoning two residents in the vicinity of each siren location to ask if they heard the sirens.
If it is determined that any siren is not working, the Marketing Evaluations representative (c) conducting the survey is expected to telephone the EOC to advise personnel of that fact.
Marketing Evaluations will also telephone the EOC when the survey is completed.
The Plan presumes that this survey could and would be completed within 90 minutes of 3/
The letter between LILCO and Marketing Uvaluations appended to the LILCO Plan (see Plan, Appendix B, at APP-B-53) indicates that LILCO expects Marketing Evalua-tions to have "two additional interviewers on call."
As-suming these two individuals were available and could be contacted at the time of an emergency at the Shoreham plant, the telephone survey would then apparently be conducted by three Marketing Evaluations representatives.,
notification to Marketing Evaluations.
The Plan also presumas that notification to Marketing Evaluations representative would be made via the LILCO paging system.
(See Plan, Appendix B, at APP-B-53).
In our opinion, this siren verification system is imprac-tical and unworkable.
First, it is unrealistic to assume tnat siren verification could be completed within 90 minutes.
According to the Plan, two residents in each of 89 siren loca-tions will be telephoned by the Marketing Evaluations represen-tative(s) on call and available at the time of notification of an emergency requiring activation of the LILCO siren system.
Even if it were assumed that every telephone call made would be answered (which, of course, is highly unlikely), 178 telephone calls and conversatione would not be able to be made by Market-ing Evaluations' representative (s) within 90 minutes.
More-over, in light of the problems related to LILCO's paging system and commercial telephones which must be expected in the event of an emergency at the Shoreham site (see our testimony regarding Contention 26), it is possible that the Marketing Evaluations representative (s) on call at the time the LILCO siren system is activated would not receive notification from LILCO to begin the telephone survey, or would not be able to contact residents in the siren locations, or both.
Thus, we l i
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believe that it is likely that the sirens could fail to activate, without LILCO even being aware of the fact that seg-ments of the public had not been alerted to the emergency.
In this regard, we understand that a study of siren warning systems conducted by PRC Engineering for. FEMA revealed that 5-20 percent of sirens generally fail to activate.
(See Tr.
3241).
However, even if it is assumed that Marketing Evaluations would experience no problems in conducting the siren verifica-tion survey, and that LILCO would promptly be advised by Mar-keting Evaluations of any sirens that fail to activate, using LILCO's optimistic estimates, it would nonetheless require 90 minutes for the survey to be completed.
Thus, LILCO may not even be aware that route alert drivers need to be dispatched i
until 90 minutes or more after the sirens relied upon by LILCO to notify the public had failed to activate.
In addition, assuming LILCO knew it had failed sirens, the route alert drivers would have to be notified.
For the reasons discussed in our testimony regarding Contention 26, however, it l
is likely that a significant number of L1LCO's route alert l
[
drivers would not in fact be notified.
In addition, for the reasons discussed in the Suffolk County testimony concerning
Contention 27, even those route alert drivers who could be notified would not be available for actual duty for an extended period of time after notification.3/
Notification and mobili-zation of the route alert drivers would substantially delay their performance of public notification duties.
Moreover, it must be assumed that it would require a con-siderable amount of time to drive through the areas where LILCO's sirens fail to activate.
For example, there is likely to be traffic congestion along the routes to be driven.
In addition, some persons, upon hearing the broadcast message, would stop the route alert drivers to ask questions and obtain instructions about what to do.
This will cause further delays.
However, even if there were no traffic congestion and no 4/
It will require substantial time after their notification for LILCO's route alert drivers to travel from their homes or offices to the LILCO staging areas.
For example, 66 percent of these emergency personnel work and 56 percent of them live over 20 miles from the Shoreham plant.
(See computer listing of LERO personnel provided to Suffolk County by LILCO during discovery, dated October 27, 1983
("LILCO computer listing"l).
Moreover, even after they arrive at their respective staging areas, the route alert drivers will have to obtaia necessary equipment (such as dosimetry equipment and route maps), attend briefings and receive instructions from their emergency coordinators, l
and mount and test the public address systems for their l
vehicles before they can begin to drive the routes assigned to them at the staging areas.
See Suffolk County testimony concerning Contention 27 for details..
)
interruptions to driving times by persons asking for additional j
information or instructions, it would still require a consider-able amount of time for LILCO's route alert drivers to drive the routes assigned to them at the staging areas.
The Police Department has conducted a survey of the time required to drive through one sector of the Sixth Precinct.
That sector (sector 609) is approximately 15 square miles in area and contains approximately 120 miles of roadway.
The area driven in the SCPD survey is roughly equivalent to the area covered by three of LILCO's sirens.5/
Nearly 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> of actual driving time, travelling at an average speed of 10-15 mph, was required to drive the sector, which includes the Shoreham plant and which would therefore have to be evacuated in any situation where the area to be evacuated exceeds two miles.
Further in-we formation regarding this survey can be found in the January 17, 1983 SCPD memorandum appended to this testimony as Attachment 1.
Hosever, certain aspects of the SCPD survey warrant further discussion here.
~5/
It is our understanding that LILCO relies on many of its sirens to provide notification of an emergency to the pop-ulation within approximately 5-6 square miles of each siren location.
~
In our opinion, the SCPD survey confirms that it would take LILCO's route alert drivers a substantial amount of time to drive whatever routes are assigned to them at the time of an emergency at Shoreham.
Driving through residential areas to alert residents of the emergency would require LILCO's route alert drivers to travel every street at a slow speed.
- Indeed, we would expect that it would require these route alert drivers more time to drive their routes than the 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> required for the SCPD officer to drive one sector of the Sixth Precinct, be-cause under the LILCO Plan, route alert drivers are instructed to drive at approximately 5 mph, (see OPIP 3.3.4, Attachment 1), while the SCPD officer drove at 10-15 mph.
In addition, the officer who drove that sector was thoroughly familiar with the sector and its street patterns, and the sector was driven when traffic conditions were light, a condition that might not exist when LILCO's route alert drivers are travelling the roads.
LILCO's route alert drivers would likely not be familiar with the routes assigned to them.6/
Finally, the LILCO Plan also assigns to the route alert drivers the responsibility for notifying deaf persons of an 6/
As previously noted, 66 percent of LILCO's route alert drivers work and 56 percent of them live more than 20 miles from the Shoreham plant. 1
emergency at the Shoreham plant.
This could require route alert drivers to travel to the homes of the deaf and to hand them either sheltering or evacuation messages. (See OPIF 3.3.4, ).
As a result, the time needed to alert the publ.ic in areas where the sirens may not have been activated could be lengthened, since a route alert driver might have to locate the home of each deaf person, stop and park his vehicle, go up to the house and somehow provide notification to the resident, before continuing to drive the assigned route.
(See Suffolk County testimony regarding Contention 73 for additional disdussion of LILCO's provisions for the deaf).
Q.
Do you have any other concerns regarding LILCO's pro-posal to_use vehicles equipped with loudspeakers to alert the public in the event of failure of the siren system?
A.
Yes.
Some persons will not hear the broadcast mes-sage.
Examples would include persons with impaired hearing and persons engaged in activities that would block out a message broadcast over a loudspeaker system (for example, listening to music, doing laundry, taking a shower, or drying one's hair).
Other persons will not understand the broadcast message.
Chil-dren and non-English speaking persons are examples.
In addition, under the LILCO Plan route alert drivers are required,
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to abandon a route if dosimetry readings exceed specified levels.
(See OPIP 3.3.4, Attachment 1).
Should a route have to be abandoned, notification to certain segments of the popu-lation would not occur at all.
Q.
Please summarize the concerns and conclusions you have made with respect to Contention 56.
A.
In our opinion, the LILCO Plan does not provide adequate backup in the event of faiure of the LILCO siren system.
LILCO's proposal to drive vehicles equipped with loud-speakers through non-activated siren areas to alert the public is' impractical and unworkable.
It lacks flexibility and is based on unrealistic assumptions.
It is unrealistic to assume that LILCO would know on a timely basis whether its sirens have been activated.
It is also unrealistic to assume that the route alert drivers expected to carry out this notification scheme could be notified and mobilized in a timely manner, just as it is unrealistic to ascime that the routes they are respon-sible for driving can be driven and the public notified without the occurrence of significant delays.
Further, it is unre-alistic to assume that all persons would hear and understand the message broadcast over loudspeakers.
In our opinion, this scheme is unworkable and could never be successfully.. -
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implemented.
Thus, entire segments of the population may never be alerted to an emergency at the Shoreham site.
V.
Contentions 20 and 57 -- Inadequate Notification to Special Facilities and Persons Without FM Radios Q.
Contention 57 alleges that tone alert radios will not provide adequate notification of an emergency to special facilities and other organizations within the EPZ.
Do you agree with this Contention?
A.
Yes.
Under the LlLCO Plan, special facilities and organizaticas with a large number of personnel (such as schoole, hospitals, nursing houses, handicapped facilities, and major employers) are to be equipped with tone alert radios which, upon activation by the EBS signal from WALK radio, are to broadcast automatically the emergency message.
(See Plan, at 3.3-4 and 3.4-6; OPIP 3.4.1, Attachment 1).
While these tone alert radios would presumably provide direct notification of an emergency at the Shoreham plant, such notification would coincide with notification to the general public.
Thus, con-trary to LILCO's assertion in versions of the Plan preceding Revision 3, special facilities and other organizations would not have any additional alerting or preparation time for evacu-ation, sheltering or implementation of any other protective action recommended for the public. l
In addition, LILCO's.one alert radios apparently depend upon the EBS signal broadcasting from WALK radio station.
(See Plan, at 3.3-4).
However, it is our understanding that should WALK be unable to transmit the EBS signal, the signal could be broadcast from radio stations other than WALK.
(See, e.g.,
OPIP 3.8.2, at 3; see Plan, Appendix B).
If the EBS signal were to originate from some radio station other than WALK, the tone alert radios would not activate and the facilities would not receive the EBS message.
Q.
Contention 20 alleges that persons without FM radios may be unable to receive adequate information about an emer-gency at the Shoreham plant.
Do you agree with this Conten-tion?
A.
Yes.
Although LILCO intends that EBS messages will be broadcast simultaneously by WALK AM and FM (see OPIP 3.8.2, at 3), WALK AM does not operate at night.
Therefore, persons without FM radios, especially people in cars, may be unable to receive adequate information should an emergency at the Shoreham plant occur at night.
9
VI.
Contention 58 -- Notification of and Communications with Special Facilities and the Handicapped at Home Q.
Contention 58 alleges that the LILCO Plan does not provide an adequate, workable or dependable means of determining whether special facilities and the handicapped at home are aware of a need to evacuate and wriether they have specific needs for assistance.
Do you agree with this Conten-tion?
A.
Yes.
Under the LILCO Plan, the proposed evacuation of special facilities, such as schools, handicapped facilities, nursing / adult homes and hospitals, and the handicapped at hote requires the LILCO employees assigned to be the Public Schools Coordinator, Private Schools Coordinator, Health Pacilities Coordinator and the Home Coordinator, all of whom work under the direction of the Special Facilities Evacuation Coordinator, to verify by telephone that the special facilities and handicapped individuals at home are aware of the need to evacu-ate.
These same LILCO employees are also required to determine for special facilities and the handicapped at home specific needs for assistance.
(See OPIP 3.6.5).
!~
In our opinion, LILCO's reliance on commercial telephones makes its proposal inadequate and unworkable.
We have,
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previously discussed why commercial telephones would not provide an adequate or reliable means of communications in the event of an emergency at the Shoreham plant.
(See our testimo-ny regarding Contention 26).
We will not repeat here our views on the problems that must be expected.
At a minimum, however, the use of. telephones to contact special facilities and handicapped individuals at home will take too long.
In addition, the persons to be contacted may not be near tele-phones or may be using their telephones.
Indeed, handicapped persons may be unable to communicate by telephone.
(See also Suffolk County testimony regarding Contentions 72 and 73).
Thus, the LILCO Plan does not provide an adequate means of timely notification of or communication with special facilities or the handicapped at home.
Q.
Does that conclude your testimony?
A.
Yes.
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ATTACHMENT 1 e
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ATTACHMENT 1 POLICE DEPARTMENT COUNTY OF SUFFOLK, NEW YOLK INTERNAL CORRESPONDENCL Inspector Richard C.
Roberts To: Office of the Chief of. District DATE: 1/17/83 FROM: Inspector Joseph L. Monteith, C.O.,
6560 COPY TO:
SUBJECT:
SURVEY OF 609 SECTOR 1
l As we discussed last week, I assigned an l
Officer to do a "run through" of the entire.609 sector to determine:
1.
The total time it would take for a sector car to cover, thoroughly, every street in the sector.
2.
The total number of miles in the sector.
.The assignment was given to Police Officer Bruce Croly.
Officer Croly has been assigned to l
i lthis sector for a number of years and is thoroughly familiar with the street patterns.
I It took Officer Croly (who, again, is thoroughly familiar with this sector and its patterns) a total of eight (8) hours and fifty-nine (59) minutes to completely drive through the sector.
This was actual driving time and excludes such things as meal periods, personals, etc.
For purposes of this test, Officer Croly was detached from his sector assignment and, thus, was not assigned calls during the test period.
As Officer Croly notes, traffic conditions were light to non-existant during the test.
Such traffic conditions might approximate the conditions after an evacuation but it is reasonable to believe that, during an evacuation, traffic conditions within the sector would be more severe.-
I As Croly notes, there are approximately one hundred I
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and twenty (120) miles of roadway in 609 sector.
Finally, sector 609 was deliberately chosen for this test for two (2) reasons:
I 1.
It is the sector within which the Shoreham Power Plant is 1.ocated and would have to be evacuated in any situation where the zone to be evacuated exceeded two (2) miles.
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- a 2.
It might be considered a " typical sector with regard to the street miles it contains.
There are several sectors (601, 602 and 614 among them) that would require signifi-cantly greater time to completely cover.
Re ectful y submitted:
h[M Joseph L./ M nteith, Inspector C.O.,
65 0 JLM/j ad Attach:
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