ML20081A759

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Direct Testimony of Kj Regensburg,Ra Snow & Vr Stile on Emergency Planning Contention 26 Re Notification of Emergency Response Personnel.Related Correspondence
ML20081A759
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 8403060270
Download: ML20081A759 (76)


Text

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A, RELATEO CORRESrollogggg DOCKETED l!1:i.= C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'84 lifR -5 f11 :03 Before the Atomic _ Safety arid._ Licensing Board

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In the Matter of

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LONG ISLAND LIGHTING COMPANY

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Docket No. 50-322-OL-3

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(Emergency Planning)

(Shoreham Nuclear Power Station,

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Unit 1)

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DIRECT TESTIMONY OF DEPUTY INSPECTOR KENNETH J.

REGENSEURG, DEPUTY INSPECTOR ROBERT A.

SNOW AND POLICE OFFICER VINCENT R.

STILE ON BEHALF OF SUDFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTION 26 --

NOTIFICATION OF EMERGENCY RESPONSE PERSONNEL March 2, 1984 8403060270 840302 PDR ADOCK 05000322 7

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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 CONTENTION 26 -- NOTIFICATION OF EMERGENCY RESPONSE PERSONNEL I.

Introduction Q.

Please state your names, occupations and professional backgrounds.

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 Fifth 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 Communications and Records Bureau, County of Suffolk Police 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 nepartment.

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My name is Vincent R.

Stile.

I am a Police Officer l

l assigned to the Communications Technical Services Unit, County i l 1

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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.

A statement of our qualifications and experience is At-tachment 1 hereto.

.Q.

Please briefly explain the general organization and structure of the Suffolk County Police Department so that your respective jobs are set in proper perspective.

A.

The Suffolk County Police Department has approxi-mately 2600 officers.

There are three Divisions in the Department -- Investigation, Patrol and Headquarters.

The In-vestigation Division, under the command of the Office of the Chief of Detectives, handles investigations of major crimes (e.g.,

homicides, narcotics, arson and other felony offenses).

In addition to the Major Crimes Bureau, the Investigation j

Division includes the General Services and Special Services i

Bureaus.

The Patrol Division, under the cocamand of the Of fice of the Chief of District, is responsible for providing day-to-day police service to the five western townships of the County.- These five townships are spread over 540 square miles, with over one million residents.

Within the Patrol Division i' 1

L

there are six Precinct Commands together with the Highway Patrol Bureau, Marine Bureau and Special Patrol Bureau.

The Headquarters-Division, under the command of the Office of the Chief of Headquarters, provides equipment / logistical support services to the Department.

In addition to the Operations and Personnel Bureaus, the Headquarters Division includes the Communications and Records Bureau.

The Communica-tions and Reccrds Bureau has about 260 police and civilian per-sonnel and exercises command over Sections such as the Communi-cations Section, the Technical Services Unit, the Complaint Dispatching Unit and the Teletype Unit.

An organizational chart of the Suffolk County Police Department is already in the record of this proceeding, ff. Tr.

2257.

II.

Purposes and Conclusions Q.

What is the purpose of this testimony?

A.

The purpose of this testimony is to sddress Emergency Planning Contention 26 and to discuss concerns regarding LILCO's proposals for notifying emergency rdsponse personnel in the event of an emergency at the Shoreham plant.

We have iden-tified a number of deficiencies and inadequacies in the.,

notification scheme relied upon by LILCO which lead to certain conclusions.

Q.

What are these conclusions and where are they discussed?

A.

In our opinion, LILCO's communications systam and procedures for notifying emergency response personnel in the event of an emergency at the Shoreham plant are inadequate and provide no assurance that there will be prompt and reliable no-tification to such. personnel.

As a result, LILCO will not be able to mobilize promptly the personnel assigned emergency functions and duties under the LILCO Plan, and the protective actions contemplated by the Plan cannot and will not be imple-mented.

LILCO's communications system for notifying emergency re-sponse personnel is inadequate for a number of reasons.

First, as discussed in Part III of this testimony, the LILCO Plan des-ignates the LILCO Customer Service Office in Hicksville as the primary notification point of LILCO's emergency response organization, responsible for receiving initial and follow-up notifications-of an emergency from the plant, verifying authen-ticity and content of information contained in the notification messages, and notifying key emergency response personnel.

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our opinion, the Customer Service Office would not be able-t'o perform these duties and responsibilities because it is not suf ficiently staf fed, and the training and equipment provided to its personnel are inadequate.

As a result, there is no as-surance that emergency personnel would be alerted, notified and/or mobilized.

LILCO's provisions for notifying emergency response per-sonnel of an emergency are deficient for other reasons as well.

For example, as discussed in Part IV below, LILCO's use of pagers to notify " key" emergency response personnel provides no assurance that such personnel will be promptly alerted, 1

notified and mobilized. -Similarly, as we discuss in Part V, the use of ccmmercial telephones to notify other emergency re-sponse personnel provides no assurance that there will be prompt notification and mobilization of these personnel.

Nor does the use of commercial telephones provide any assurance that there will be timely notification of an emergency at Shoreham to the support organizations relied upon by LILCO.

This matter is discussed in Part VI of this testimony.

s.

III.

Contention 26.A -- Deficiencies with LILCO's Primary Notification Point for LERO Q.-

The LILCO Plan designates the LILCO Customer Service Office in Hicksvil.).e as the primary notification point for LILCO's emergency response organization.1/

Contention 26.A alleges that this LILCO offico and its personnel are not capa-ble of serving as the primary notification point because of in-sufficient staffing, training and equipment.

Do you agree with this Contention?

A.

Yes.

In our opinion, the concept of using the LILCO Customer Service Office in liicksville as the primary notifica-tion point for LILCO's emergency response organization, given the staffing levels of that office and the training and equip-ment provided to its personnel, is unrealistic and unworkable.

Q.

What do you understand to be required of the Customer Service Office in its role as the primary notification point for LILCO's emergency response organization?

A.

As the primary notification point for LILCO's emer-gency response organization, the nicksville Customer Service 1/

The LILCO Plan refers to this emergency response organiza-tion as "LERO.".

o Office is responsible for receiving initial and follow-up notifications of an emergency from the plant, verifying authen-ticity and content of information contained in the notification messages, and notifying key emergency response personnel.

(See Plan, at 3.3-1 through 3.3-4).

These duties and responsi-bilities begin at the time an emergency is declared at Shoreham and notification of the emergency is given to the LILCO Customer Service Office by the Shoreham control room.

(Plan, at 3.3-1).

Responsibility for these functions shifts to the communications center in the local Emergency Operations Center

("EOC") once the EOC, located at LILCO's Brentwood facility, is activated.

(See Plan, at 3.3-1).

This is not expected to occur, however, until an Alert or higher level emergency has been declared.

(See Plan, at 3.3-1.

Under the LILCO Plan, the receipt and verification of ini-tial and follow-up notification messages from the Shoreham control room will require Customer Service personnel to take a number of actions.

(See OPIP 3.3.1).

These actions depend upon the way Customer Service is initially notified of an emer-gency.

The primary means of notification between the Shoreham control room and the Customer Service Office is via LILCO's e

Radiological Emergency Communications System (" RECS").

This system is comprised of a number of dedicated telephones, two of which are located at the Shoreham control room and the Customer Service Office in Hicksville.

(See Plan, at 3.4-1).

When notification of an emergency is given to Customer Service via the RECS telephone in that office, a Customer Service operator on duty must answer the phone, identify himself as the Customer Service operator and, after completion of the notification mes-sage, obtain and complete a notification data form based on the L

information provided by the Shoreham control room.

(See OPIP 3.3.1, at 2 and Attachment 1).

If the Hicksville Customer Service Office receives notifi-cation of an emergency from the Shoreham control room by means of commercial telephone, the Customer Service operator must go through a verification procedure.

To verify notification, the Customer Service operator must use a commercial telephone to call the Shoreham control room, Verification would then depend upon the response given to a specific text to be read by the Customer Service operator.

Once verification of the notifica-tion message is obtained, additional information is required to be logged on the notification data form.

(See OPIP 3.3.1, at 2). -

There is one other means by which the Shoreham control room could notify the Customer Service Office of an emergency at Shoreham, and that is via LILCO's Electric System Operations

("ESO") radio frequency.

Under such circumstances, the Customer Service operator would receive the notification data form from the ESO operator, and any clarification of the contents of that form would have to come from the ESO operator.

(See OPIP 3.3.1,.at 2).

After receiving an initial notification of an emergency and verifying the authenticity and content of the information contained in the notification message, Customer Service epera-tor (s) are assigned the job of notifying supervisory and emer-gency response personnel who are charged, in turn, with noti-fying other emergency response personnel.

The LILCO Plan

.provides that the Customer Service Office is to notify these emergency response personnel via the LILCO paging system.

(See Plan, at 3.3-2 through 3.3-4; OPIP 3.3.2).

Under the Plan, not all emergency response personnel will be given pagers.

In-stead, pagers will be provided to persons identified by LILCO as " supervisory personnel" and to certain emergency response personnel who are charged with notifying other emergency re-sponse personnel once they have been paged.

(See Plan, Figure 3.3.6).

Approximately 115 emergency responce personnel will be i-( l l

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.provided pagers.

(See OPIP 3.3.2, Attachments 1, 2 and 3).

These personnel, after boing paged, may have to attempt to con-tact, in turn, approximately 1150 additional emergency response personnel.

(See Plan, Figure 2.1.1).

With respect to how the LILCO paging system actually works, the Plan states that each pager is tone-encoded so that, upon activation, it'will sound a distinct signal and show a digital display.

The tone is generated by dialing a telephone number that results in the desired pager group receiving noti-fication.

However, the paging system can only be accessed by touch-tone telephones.

(See 3.2.2, at 15).

Once the pager encoder is accessed, the code number wished to be displayed can then be keyed in. - The code number displayed serves as a veri-fication to the individual that an incident at Shoreham has occurred.

Depending on the' code number, the indiv'Y3ual paged is either brought to a standby status, or he is directed to report to his duty station. (See Plan, at 3.4-5).

Assuming the LILCO paging system is working properly, the Customer Service operator ( s) must take a number of actions in order to notify emergency personnel via the LILCO paging system.

At a minimum, these actions include obtaining the list (s) of emergency personnel to be notified, activating the._ - -.

test pager(s), activating the notification pager(s) and entering the appropriate emergency code (s), verifying that the test pager(s) alarms and displays the emergency code (s) entered, reactivating the notification pager(s) after a 3-minute waiting period, and reverifying that the test pager(s) alarms and displays the emergency code (s).

(See OPIP 3.3.2, at 2 ).-

In addition, as key emergency response coordinators call in, Customer Service must inform them of the emergency classi-fication and the time the emergency was declared.

Portions of the notification data form must also be read to the Director and the Manager of Local Response.

(See OPIP 3.3.1, Attachment 1; OPIP 3.3.2, at 3, 6 and 10).

Moreover, with respect to LILCO's key emergency response coordinators, including the Director and the Manager of Local Response, Customer Service must list those persons who, aftet being paged, call in, with the date and time of call recorded beside the name of each individual.

Finally, should any key energency response coordinators not call in within 15 minutes of paging, Customer Service must attempt to contact them by commercial telephone.

(See, e.g.,

OPIP 3.3.2, at 3).

I In our op1.: ion, it is unrealistic to assume that, within 15 minutes, Customer Service could receive notification of an emergency, verify the authenticity and content of the l I

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information contained in the notification message, and then notify the key supervisory and emergency response personnel equipped with pagers under the LILCO Plan.

Even if notifica-tion of the emergency is. promptly provided to Customer Service and no verification of the notification pessage is required, and even if the LILCO paging system works properly, the actions required to be taken by the Customer Service operator (s), out-lined above, could not be completed within a 15-minute period.

Moreover, Customer Service notifies only a small fraction of LILCO's emergency response force.

Under the LILCO Plan, it is the responsibility of paged personnel to notify, via commercial telephone, the other emergency response personnel relied upon by the LILCO Plan.

(See Plan, at 3.3-2 through 3.3-4 and Figure 3.3.6).

As will be discussed below, such notification will require far in excess of 15 minutes.

As'previously noted, under the LILCO Plan responsibility for receiving and verifying communications from the plant and for initiating contact with emergency response personnel rests with the Customer Service Office until the communications center of the EOC is activated (Plan, at 3.3-1), with the number of emergency personnel to be contacted increasing with the severity of the emergency.

(See Plan, at 3.3-1 through 3.3-4; Figures 3.3.2, 3.3.3 and 3.3.4).

For example, upon t

notification of an Unusual Event by the Shoreham control room, the Customer Service operator (s), after verifying the authen-ticity and content of the notification message, would be re-spensible for notifying the Director of Local Response, the Manager of Local Response, the Coordinator of Public Informa-tion and four other key emergency response coordinators.

(See Plan, at 3.3-2 and Figure 3.3.2).

This means, at a minimum, that seven people would have to be notified by Customer Service via the LILCO paging system.

However, should these individuals fail to-acknowledge receipt of the paged notification, Customer Service would have to attempt to notify them by telephone.

(See OPIP 3.3.2, at 3).

If they could not be contacted, Customer Service would presumably attempt to telephone their alternates.

Thus, up to 23 persons may have to be telephoned by Customer Service.

(See computer listing of LERO personnel provided to Suffolk County by LILCO during discovery, dated October 27, 1983 ("LILCO computer listing")).

However, should the Customer Service operator (s) be notified of an Alert or higher classification level by the Shoreham control room, notification responsibilities would in-crease dramatically.

(See Plan, at 3.3-2 through 3.3-4; Figures 3.3.3 and 3.3.4).

In fact, rather than the seven percons required to be notified of an Unusual Event, an Alert, o

Site Area or General Emergency would require Customer Service to attempt to notify approximately 115 emergency response per-sonnel.

(See OPIP 3.3.2, Attachments 1, 2, and 3).

Moreover, while notification of an Unusual Event requires only LILCC per-sonnel to be notified by the Customer Service Office, any higher level-emergency requires non-LILCO organizations and personnel to be notified.

These non-LILCO organizations include the Brookhaven National Laboratory ("BNL") Security Station, which would be requested by the Customer Service Office to notify the DOE-RAP team of the emergency (see OPIP 3.3.2, at 5), and, in certain situations, WALK radio station, which is responsible for broadcasting Emergency Broadcast System ("EBS") messages and for activating the network station monitors of relay stations and tone alert radios.

(See OPIP 3.8.2 and Plan, Figure 3.3.5).

In theory, the LILCO paging. system is intended to simplify the notification functions assigned to the Customer Service Office under the LILCO Plan, Lecaose the Customer Service oper-ator( s) should only have to know which personnel are to be notified for each emergency classification level and how to ac-

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tivate the pagers.

Thereafter, as noted above, the individuals contacted through the paging system are responsible for noti-fying other' emergency response organizations and personnel. _ _..

j requiring notification by commercial telephone using a cascading telephone scheme.

(See Plan, at 3.3-2 through 3.3-4;

-OPIP 3.3.2).

However, in the event of an emergency at Shoreham requiring notification of emergency response personnel by the Customer Service Office, problems in implementing the notifica-tion procedures described in the LILCO Plan would have to be

. anticipated.

For example, the LILCO paging system might malfunction.

Then, in our opinion, the limited number of per-sonnel generally on duty at the Hicksville Customer Service Office would not be able to carry out the necessary notifica-tion functions required by the LILCO Plan.

Q.

Do you expect problems to occur with the LILCO paging system?

A.

Yes.

In our opinion, the paging system described in the LILCO Plan is unreliable and, in some respects, unworkable.

I-Our concerns with that system are discussed later in this tes-timony.

(See discussion regarding Contention 26.C).

The point here is that should the LILCO paging system fail to notify emergency response personnel of an emergency at the Shoreham I

plant, the Customer Service office would be responsible for at-tempting to contact those personnel manually, via commercial p

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telephone.

(See OPIP 3.3.2).

As previously noted, this could require Customer Service to attempt to contact, via commercial telephone, approximately 115 persons.

In our opinion, the Customer Service Office has insufficient staffing to perform such notification functions.

Certainly, such notification would require substantially more than 15 minutes, which we understand is the benchmark under NRC regulations for notifying emergency response personnel.

See 10 CFR Part 50, Appendix E, Section IV.D.3.

Indeed, even with sufficient staffing, it is our opinion that the Hicksville Customer Service Office could not notify more than a small fraction of these 115 emergency personnel within a 15 minute period.

This opinion is based, in part, on the results of a notification / mobilization test conducted by the Department's sixth Precinct / in.Tanuary, 1983.

The test 2

was conducted at 1:30 p.m. on January 17, 1983, a Monday.

The test simulated a cascading telephone scheme such as LILCO pro-poses to use in notifying its emergency response personnel (see Plan, at 3.3-2 through 3.3-4).

The test involved attempts to contact approximately 150 off-duty SCPD officers.

2/

The Sixth Precinct includes most of the area of the Shoreham EPZ.,

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The SCPD test was conducted to simulate the actual notifi-cation / mobilization of off-duty officers assigned to the Sixth Precinct.

In an actual notification / mobilization of those of-ficers, the SCPD duty officer (analogous to the Shoreham control room under the LILCO Plan) would first contact the Lieutenants in the Precinct (analogous to the Customer Service Office), who in turn would contact the Sergeants (usually three) under their command (analogous to the 115 emergency re-sponse personnel with pagers), who in turn would contact the officers in their squads (analogous to the approximately 1150 other emergency response personnel who must be contacted by personnel with pagers).

In the SCPD test, once an officer was contacted, he was told of the test and asked to estimate the amount of time it would take if he had to report to Precinct headquarters for duty.

The SCPD test and its results are set forth in detail in to this testimony.

It took 43 minutes to attempt to contact approximately 150 personnel under the simulated cascading telephone scheme which assumed several calls were made simultaneously.

Of the approximately 150 contacts at-tempted, only 66 percent were successful.

That is, in 34 percent of the cases, the officer could not be contacted. _

4 Although limited in its scope, the SCPD test results are relevant to the notification of emergency response personnel that would be attempted under the LILCO Plan.

The test was designed to determine the percentage of response to attempted notification efforts (i.e., success rate for notification), how long notification of approximately 150 officers would take, and how long it would take for off-duty officers to report to the Sixth Precinct.

The mobilization aspects of this test are discussed in the Suffolk County testimony concerning Contention 27.

With respect to ratification, however, a number of conclu-sions can be drawn from the test results.

First, the time necessary to attempt notification in the SCPD test (43 minutes) is relevant to LILCO's proposed notifi-cation efforts, although we believe LILCO would require much more timef While the SCPD test was conducted in a way which simulated contacting approximately 15 officers who in turn at-tempted to contact approximately 135 other off-duty officers, under the LILCO Plan as few as two Customer Service operators may initially have to attempt to contact as many as 115 emer-gency personnel.3/

These 115 emergency personnel would, in 3/

Although the LILCO Plan does not indicate the number of personnel assigned to the Hicksville Customer Service Office,.LILCO has advised the County that the midnight shift ordinarily is limited to just two operators.

(See discussion below)..-

turn,_have to attempt to contact, via commercial telephone, ap-proximately 1150 other emergency response personnel.

(See Plan, Figure 2.1.1).

Moreover, the SCPD test was conducted in a way which simulated an actual mobilization of off-duty SCPD officers.

Under such conditions, no one officer would be ex-pected to contact more than ten others, and several would only have to telephone three persons.

In the LILCO situation, how-ever, many workers would apparently be expected to make as many 4

calls as necessary to successfully contact ten or more other workers.

(See, e.g., OPIP 3.3.2, Attachment 5).

In addition, the SCPD test only required the telephoning officers, if successful in contacting off-duty officers, to ask the off-duty officers to estimate how long it would take them t

to' report if the test were a real call to duty.

LILCO's Customer Service operators and other workers making calls, how-ever, would likely have to spend far more time with any LILCO emergency worker contacted.

For example, the contacted individuals would have to be advised of the type of emergency, why they were being called, and whether to report or standby.

Realistically, questions and conversations regarding the emer-gency would follow.

Thus, in our opinion, each successful telephone call could likely require at a minimum between 3-5 minutes.

Of course, each unsuccessful call would also take i

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time, particularly if the caller were to leave a message for the missing worker with whomever answered the call.

Finally, in our vive LILCO would require more time than did the SCPD in attempting to notify emergency response person-nel because of logistical problems such as the need to locate the names of individuals to be called and finding telephone numbers for those individuals.

During its test, the SCPD had cuch information readily available, in part because the SCPD ordinarily has access to such information, and in part because it whs a test.

The SCPD also had immediate knowledge of the status of the individuals to be called (i.e., off duty, on vacation, ill, etc.)

In the event of an emergency at Shoreham, however, such information may not be readily available to the Customer Service operators.

Certainly, it would not be re'adily available to the 115 emergency response personnel who, after having been contacted by Customer Service, would have to con-tact other emergency personnel.

In fact, for these personnel, even obtaining access to telephones may be a problem.

(See discussion below).

The notification success rate in the SCPD test (66 percent) is also relevant to notification under the LILCO Plan, although again we would expect LILCO's sucess rate to be even

- lower.

While SCPD officers can be expected to respond to a

" test," LILCO's emergency response personnel would not neces-sarily be as likely to respond if notified of an emergency at Shoreham.

(See, e.g.,

Testimony of Donald J.

Dilworth on Be-half of Suffolk County Concerning contention 25 - Role Conflict, at 3, 4; see also Tr. 1261, 1265).

In addition, the SCPD test was cor. ducted on a weekday, shortly af ter the lunch hour.

The chances for contacting individuals at such a time were almost cert:2 inly better than other times, such as on week-ends or in the evenings (when people are likely to be out),

when notification of an emergency might have to be given to LILCO's emergency personnel.

Finally, the SCPD test was conducted on an average workday under non-emergency conditions, rather than during an emergency, when telephones are likely to be inaccessible to LILCO personnel.

As FEMA witness Philip McIntire has testified, "[i]t can reasonably be expected that the telephone system could become overloaded during an incident" at Shoreham.

(See Direct Testimony of Philip McIntire Concerning Contentions 23, 25 and 65, at 8, ff. Tr.

2086).4/

4/

See also deposition of Arthur Seale ("Seale deposition"),

at 27, where Mr. Seale, who is the Manager of LILCO's Customer Service Department and one of the alternate Managers of LILCO's emergency response organization, testified that "[i] n large storms all communication (Footnote cont'd next page) L

For these reasons, we would not expect the Customer Service Office to be able to notify as many as 66 percent of the_115 emergency response personnel it would have to attempt to contact should the LILCO paging system fail.

However, even if Customer Service were able to notify that percentage of emergency personnel, approximately 40 of the 115 persons required to be notified would not be contacted.

Given the fact that these emergency personnel are relied upon to contact other emergency personnel using a cascading telephone scheme, a sig-nificant number of LILCO's personnel would likely never be con-tacted.

As a result, there would be insufficient personnel to implement the LILCO Plan.5/

Q.

What other duties and responsibilitie i may be required of the Customer Service Office as the primary notifi-cation point for LILCO's emergency response organization?

(Footnote cont'd from previous page) facilities become extremely overburdened, in the whole of the Long Island Lighting Company, as well as the whole of Long Island."

5/

-The results of the SCPD's January 17 notifica-tion / mobilization test were confirmed in a second SCPD test conducted on August 29, 1983. -. _

A.

The Customer Service Office may also be responsible for manually verifying emergency worker pager notifications and compiling staffing lists (see, e.g.,

OPIP 3.3.2, at 13) and for attempting to contact by. telephone all emergency response per-sonnel who do nct acknowledge receipt of pager notification (see, e.g.,

OPIP 3.3 2, at 6).

Specifically, under the LILCO Plan, the 115 emergen response personnel who are expected to be contacted through the LILCO paging system are supposed to call an automated verification cystem located in the Customer Service Office in Hicksville.

(Plan, at 3.3-2; OPIP 3.3.2, at 12).

Although the Plan does not adequately describe this I

system or how it works, it appears that the system is activated when emergency personnel,.after having been notified of an emergency through the LILCO paging system, call in to the system and enter their emergency worker identification numbers.

Such calls.must be made from touch-tone telephones; otherwise, the system would automatically connect the caller to a Customer Service operator, if one is available, who must then manually verify pager notification.

(OPIP 3.3.2, at 12-13).

Thus, a Customer Service operator must talk to every emergency response worker who, when paged, is not near a touch-tone telephone.

It is our understanding, based on information provided to us by a representative of AT&T Information Systems (formerly a

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subsidiary of AT&T), that approximtely 40 percent of the telephones in Suffolk County are rotary telephones.

Since LILCO's proposed automated verificacion system can only be ac-tivated by persons using touch-tone telephones, it must be ex-pected that a significant number of LILCO's emergency response personnel who attempt to call in to LILCO's automated verifica-tion system will instead be connected to Customer Service oper-ators,-who will then have to verify manually pager notifica-tion.

In addition, even if the emergency worker uses a touch-tone telephone, if he were to fail to enter his LERO identification number within the allotted time, or if the system did not repeat correctly the number entered by the call-

- er, the: system would connect the caller to the Customer Service Office so that an operator could manually verify pager notifi-cation and enter the worker's identification number.

(OPIP

- 3.3.2, at'13).

Under the LILCO Plan, therefore, it must be as-sumed that Hicksville Customer Service operator ( s) would always

' have to verify manually a substantial number of pager notifica-tions.

Customer Service personnel would also be responsible for manually' compiling a list of individuals who respond to the pager notification through that office.

(OPIP 3.3.2, at 13).

- These duties, and the time required to perform them, would be,

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significantly expanded should.the LILCO automated verification system fail.

In the event of such a failure, all call-ins by emergency ' response personnel contacted through the LILCO paging system' would be routed to operator ( s) in the Hicksville Customer Service Office, wh would then be responsible for man-ually verifying pager notifications and for compiling staffing 3~

lists.- (OPIP 3.3.2,-at 13).

Thus, for an Alert, Site Area or General Emergency, Customer Service could have to verify noti-fications and compile staffing ~ lists for approximately 115 emergency personnel.

l The Hicksville Customer Service Office is also assigned responsibility under the LILCO Plan for attempting to contact by telephone emergency response personnel.who do not acknowl-edge receipt of pager. notification.

For example, should an Alert be declared at the Shoreham plant, Customer Service oper-ator(s), af ter notification and verification of the emergency, would. attempt to notify the appropriate _ emergency personnel l

through the LILCO paging system.

(See Plan, at 3.3-2 and Figure 3.3.3).

Under the LILCO Plan, 30 minutes after comple-I tion of pager activation, Customer Service is required to access the automated verification system (consistent with OPIP 3.3.3, Section 5.3.1) and begin manually calling out (via commercial telephones) all personnel not accounted for by the

automated verification system.

(See, e.g.,

OPIP 3.3.2, at 6).

Of course, should the automated verification system fail, or should a significant number of emergency response personnel, for whatever reason, not call in to the system, manual call-outs-of personnel by_ Customer Service would require a signifi-cant amount of time.

Even assuming that commercial telephone lines were avail-able ( i.e., not overloaded or otherwise down), that emergency personnel are near telephones whose numbers are known to Customer Service, and that response personnel are not using

.their telephones ( see discussion below regarding Contention 26.D), it would take a substantial amount of time to place the number of telephone calls necessary to reach emergency response personnel and to confirm whether notification of the emergency was received.

Q.

Is it realistic to expect the number of personnel assigned to LILCO's Customer Service Of fice to be able to per-

' form the functions assigned to that of fice by the LILCO Plan?

A.

No.

Although the LILCO Plan does not indicate the number of personnel assigned to the Hicksville Customer Service Office, LILCO has advised the County that the number of Customer Service operators varies from shif t to shift as _..

'o follows: 8:00 a.m. to 4:00 p.m. shift - 11 operators; 4:00 p.m.

to midnight shift - 6 operators; midnight to 8:00 a.m. shift -

2 operators.

(See LILCO discovery response of June 30, 1983).

i We believe that these staffing levels are unacceptable to as-sure performance of the duties and responsibilities assigned to the customer Service Office in the event of an emergency at the Shoreham plant.

Our concerns are heightened by the fact that the LILCO Plan, except in the event of failure of the LILCO paging system during an Alert or higher classification, makes no provision for backup for the on-duty operator (s) in the Customer Service Office, other than to advise such operator (s) that additional Customer Service personnel may be called out "in accordance with established restoration procedures" on an "as needed" basis.

(See, e.g.,

OPIP 3.3.2, at 2).

Even under circumstances where there is a failure of the LILCO paging system, the Plan's provisions for backup to the Hicksville Customer Service Office may not be adequate.

As previously noted, in such circumstances, the Customer Service Office is responsible for manually calling out, i.e.,

telephoning, emergency response personnel.

(See OPIP 3.3.2, at 16 and Attachments 1, 2 and 3).

If the Customer Service opera-tor requires assistance in executing these manual call-outs, according to the LILCO Plan assistance may be sought from i

LILCO's Hewlett and Brentwood Customer Service offices.

(See OPIP 3.3.2, at 16-17).

However, the LILCO Plan does not indi-cate the number of personnel assigned to the Hewlett and Brentwood offices, nor the. staffing levels of those offices during each shift, nor the training and equipment available to the personnel assigned to those offices.

Further, the Plan provides no indication of how quickly such assistance could be b

obtained.

Q.

You mentioned that.the Hicksville Customer Service operator (s) has'the authority to call out additional Customer l

Service personnel.

Does that alleviate your concerns regarding staffing of the Hicksville office?

4 A.

No.

Although the LILCO Plan advises the Customer Service operator (s) that additional Customer Service personnel may be called out-"in accordance with established restoration procedures" on an "as needed" basis (see, e.g., OPIP 3.3.2, at 2), there-is no indicstion in the Plan of the number of person-nel who could respond to such an ad hoc' procedure.

Nor is there:any-indication of how quickly such personnel could

. respond.

Indeed, it is even possible that such personnel could not. respond at all-because they have been assigned other emer-c gency response. functions and duties under the LILCO Plan.

The,

l 7

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i coint is that the Plan nowhere describes LILCO's restoration procedures or what is meant by calling out personnel on an "as needed" basis.- Thus, in our opinion, the question of the ade-quacy of the staffing of the Hicksville Customer Service Office must be gauged against the staffing levels ordinarily in effect for that office.

As previously noted, there will be times (i.e., during the midnight shif t) when only two operators will be on duty.

Should an emergency at the Shoreham plant occur during a time when the Customer Service Office is staffed by just two operators, it would not be possible for that. office, within 15 minutes, to carry out the duties and responsibilities demanded under the LILCO Plan of the Customer Service Office as the primary notification point for LILCO's emergency response organization.

(See discussion of the SCPD notifica-tion / mobilization test above).

In our opinion, this staffing deficiency is compounded by the communications equipment available to Customer Service per-sonnel and the equipment relied upon by LILCO to notify Customer Service in the first instance of an emergency at the Shoreham plant.

Q.

What communications equipment is relied upon by LILCO to notify the Hicksville Customer Service Office of an emergency at the Shoreham plant?

o-A.

As previously noted, the primary means of notifica-tion between the Shoreham control room and the Hicksville Customer Service Office is the RECS telephone system.

This system utilizes a series of independent dedicated telephone circuits combined to form one system.

Each telephone in the system rings automatically when any handset is picked up from its receiver and the manual ring down button is depressed.

A RECS telephone is located at 11 separate locati'ons, including the Shoreham control room and the LILCO Customer Service Office in Hicksville. (See Plan, at 3.4-1 and 3.4-2).

Q.

Do you have concerns with LILCO's RECS telephone system?

A.

Yes.

We believe that there may be problems with this system.

For example, the telephones in the system only ring 30 seconds and if somebody does not answer within the 30 seconds, the phone stops ringing.

(See deposition of William Renz

("Renz deposition"), at 21).

Although a light keeps flashing after the ringing has stopped, the initiator of the phone call would have to go through a roll call of all those answering, hang up, and than re-initiate phone calls to the entire system in order to attempt to contact any RECS operator who fails to answer his telephone at the time the system is first activated. - v

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In addition, not all 11 RECS telephone locations are manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

In fact, only four of 11 locations are manned continuously.

With respect to the five LILCO-controlled

-locations, only the telephones at the shoreham control room and the Customer Service Office in Hicksville are manned continu-ously.

(See Plan, at 3.4-1 and 3.4-2).

Therefore, it is quite likely that the RECS telephones, if activated, would simply

~

ring in empty offices.

What happens then?

The LILCO Plan only specifies that there will be a roll call, that is, that the initiator will activate the RECS telephones and then call the roll.

(See OPIP 3.3.1).

The LILCO Plan does not address what happens if one or more RECS telephone operators fail to answer their phones.

There is no backup to that situation.

As a result, there is no assurance that LILCO's RECS telephone system will provide prompt and reliable notification of an emergency at the Shoreham plant to key segments of LILCO's emergency response organization.

Without prompt and reliable notification of emergency personnel, there will be delays in mobilizing them and in implementing command and control deci-sions regarding protective actions for the public.

Q.

Is there any back up to the RECS telephone system?.. -..

A.

As a practical matter, no. -Although the LILCO Plan

~

asserts that the LILCO Notification Radio System serves as the backup communication system to the-RECS telephone system (see Plan at 3.4-2), this radio system does not back up all links on

' the RECS system.

In fact, as a practical matter, it only backs up the link between the Shoreham control room and the Customer Service Office in Hicksville, j.

Q.

Please explain.

A.

LILCO's Notification Radio System can transmit from the Shoreham control room to the Electric System Operations room in Hicksville, which is located close to the Customer Service. Office.

Thus, should the RECS telephone in the Customer Service Office fail to ring, the Shoreham control room could radio the ESO operator, who_could then walk the radio message over tolthe Customer Service operator (s).

The Plan

' ' presumes that tho' Customer Service operator ( s) would then proceed to notify, via commercial telephone, appropriate emer-gency response. personnel and organizations.

(See Plan, at 3.4-2).

The LILCO Planzdepends not'only upon prompt, adequate and

.fr'eliable' notification to the Customer Service Office by the

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but also upon the other RECS telephone locations being promptly notified of the emergency.

However, should the dedicated lines to the RECS telephcne locations become inoperative, or should the telephones at these locations not be attended, there could be no notification or communication between or among the RECS locations, other than by way of the Customer Service Office re-laying, via commercial telephone, whatever notification mes-sages are received from the ESO messenger.

(See Plan, at 3.4-2).

While equipment for transmitting and receiving messages over the ESO frequency is located at the five LILCO locations which have RECS telephones, only the Shoreham control room and the Electric System Operations room in Hicksville are manned continuously.

(See Plan, at 3.4-2).

Therefore, the ESO fre-quency provides no meaningful backup to any RECS location other than the Hicksville Customer Service Office, which, as previ-ously noted, is located close to the Electric System Operations room.

In our opinion, the lack of an adequate backup means of communication between the Shoreham control room and nine of the ten other RECS telephone locations is a deficiency of the LILCO Plan.

As previously noted, commercial telephone lines provide no assurance that notification of an emergency would in fact be received.

Q.

Please summarize the problems that you anticipate with the RECS telephone system.

A.

First, not all RECS locations are backed up by the LILCO Notification Radio System.

Indeed, this radio system only serves as a backup communication system between the Shoreham control room and the Hicksville Customer Service Office.

Second, there is a 30-second limitation on the ringing of the RECS telephones.

Third, most RECS locations are not manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

Fourth, there is no indication in the LILCO Plan as to what happena if some of the RECS telephones are not answered.

These problems cause us to question the ef-fectiveness of LILCO's proposed RECS telephone system.

Q.

We've just discussed the LILCO Notification Radio System.

What problems or concerns do you have with respect to that radio system?

A.

First, given the power wattage of LILCO's transmit-ters for the ESO frequency (45 to 90 watts) (see letter dated hovember 1, 1983, from J.

Monaghan to M.

Miller

(" November 1 letter") at 3), it is unclear whether a radio message could be transmitted directly from Shoreham to Hicksville.

Moreover, since the ESO frequency (173.3 MHz) is a single frequency (sim-plex) system (see November 1 letter, at 3), it could not be 35 -

automatically rebroadcast for additional range as could a repeater system, since a repeater system requires the use of two frequencies.6/

As a result, the operation of the LILCO No-tification Radio System between Shoreham and Hicksville would likely require the radio message to be relayed through another LILCO facility capable of transmitting the ESO frequency.

This facility would have to be located somewhere between Shoreham and Hicksville.

Q.

Assuming the radio message is relayed via another LILCO facility, what would be your concern?

A.

The radio message would have to be picked up and then relayed to Hicksville.

This would require a radio operator, 6/

With a repeater system, a radio message is automatically received and retransmitted.

The message is received over one frequency and retransmitted over a second frequency.

Thus, two frequencies are required for a repeater system.

Generally, these frequencies are paired, with one frequen-cy used to transmit and the other frequency used to receive.

With UHF frequencies, paired frequencies are generally separated by five megahertz (MHz).

A simplex system, on the other hand, uses only one fre-quency for both transmitting and receiving.

As such a radio message cannot be received and automatically retransmitted.

Thus, in order to relay a message beyond the transmitter's normal range, a manually-operated inter-mediate transmitter would have to be utilized.

That is, the radio message would have to be received and then manu-ally retransmitted by an operator stationed at the inter-mediate transmitter.

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after receiving the radio message, to rebroadcast the message.

Any time radio messages are relayed, there is some delay and possibly some confusion in rebroadcasting the message.

Should the relay facility not be aware of the emergency nature of the message, the chances for such delay and confusion increase.

Further, there is no indication in the LILCO Plan as to whether the LILCO facilities that might have to relay the radio message from Shoreham to Hicksville are manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

Thus, there may be times when the broadcast of messages from Shoreham to Hicksville over LILCO's Notification Radio System may not even be possible.

Q.

Do you have any other concerns regarding LILCO's plan to use the Customer Service Office as the primary notification point for LILCO's emergency response organization?

J A.

Yes.

The LILCO Plan does not describe the equipment that may be available to the personnel assigned to LILCO's Customer Service Office.

LILCO has advised the County, how-ever, that the Hicksville Customer Service Office has the capa-bility of " stacking" (i.e., placing on hold) incoming calls, that the number of calls that can be stacked at any given time depends on the number of personnel manning the telephones, and that if 10 persons were to man 10 telephones, up to 50 incoming 37 -

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calls could be stacked.

(See November 1 letter, at 8-9).

In addition, the County has been told that 60 trunk lines come into the Hicksville office, and that LILCO's total capacity for stacking is 183 calls.

(Id.).

In our opinion, given the vast array of duties and responsibilities expected of the personnel assigned to the Hicksville Customer Service Office and the lim-ited number of personnel on duty during certain shifts, it is unrealistic to believe that these personnel would be able to handle all incoming calls during an emergency at the Shoreham plant.

For example, during the midnight shif t, the Customer Service operator (s) could probably stack no more than 10 incom-ing telephone calls at any one time.

Furthermore, we have reviewed LILCO's communications training program and, in our opinion, it is totally unrealistic to expect that the training to be provided would enable LILCO's Customer Service operators to perform their communications functions with any degree of success, particularly in light of the circumstances and anxiety that would exist during an emer-gency at the Shoreham plant.

The specific deficiencies in the LILCO training program will be diecussed in detail in the Suffolk County testimony concerning Contentions 39-41 and 44.D,

~

E and F.

Certain matters are pertinent here, however..

First, it is not even clear that LILCO's communications training progran has been offered to the Customer Service oper-ators in LILCG:s Hicksville office.2/

Further, even assuming that LILCO's training program were offered to LILCO's Customer Service operators, such training would have been primarily lim-ited to classroom training.

Classroom training, at best, can only provide the fundamentals of communications techniques.

Of course, LILCO's Customer Service operators may well have developed the ability to man telephones and to perform the other communications tasks associated with their day-to-day responsibilities.

However, as previously discussed, the noti-fication duties assigned to these personnel under the LILCO Plan are extensive and bear but a minimal relationship to their 7/

We are - aware that the LILCO Plan indicates that " initial notification personnel" will receive training.

(See Plan, Figures 5.1.1 and 5.2.1).

Although the Plan nowhere defines or explains what is meant by " initial notification personnel," we have reason to believe that LILCO's Customer Service operators are not included among such personnel.

(See LILCO computer listing, which identifies six LILCO employees under the emergency response function of " initial notification," but identifies these individu-als' LILCO jobs as "Supv. Serv. Oper."

These individuals are apparently assigned to one of three different work lo-cations and, as supervisory personnel, presumably work different shifts.

Thus, it is likely that, even if these individuals were trained and that such training was adequate, no more than one or two would be present at the Hicksville Customer Service Office at the time of an emer-gency at the Shoreham plant). t

normal jobs of handling telephone calls from the public and dispatching LILCO repair personnel.

Therefore, it is unlikely that LILCO's Customer Service operators would be able to per-form adequately the communications functions assigned to them under the LILCO Plan.

Q.

Please summarize your conclusions with respect to Contention 26.A.

A.

In our opinion, LILCO's Customer Service Office is not capable of serving reliably as the primary notification point for LILCO's emergency response organization because of insufficient staffing, training and equipment.

As a result, LILCO's provisions for receiving initial notification of an emergency, verifying the information received, and notifying L

emergency response personnel provide no assurance that emer-gency personnel will be alerted, notified and/or mobilized, i

IV.

Contention 26.C -- Notification of Emergency Response Personnel by Pager Q.

Contention 26.C alleges that LILCO's paging system provides no assurance that key emergency response personnel will be notified of an emergency at the Shoreham plant.

Do you agree with this Contention?

40 -

A.

Yes.

Under the LILCO Plan, once there is an emer-gency at the Shoreham site and the LILCO Customer Service Office has been notified of the emergency by the Shoreham control room, the Customer Service operator (s) are responsible for the initial notification and mobilization of LILCO's emer-gency response personnel, so long as the EOC has not been acti-vated.

The Customer Service operator (s) would accomplish this, in part, through the LILCO paging system.

LILCO's paging system is a commercial paging system that relies upon commercial telephone lines, which tra subject to adverse weather or anticipated overload conditions.

(See Renz deposi-tion, at 64; see November 1 letter, at 8).

Even setting aside the failure that could result from.eliance on telephones, there is, to our knowledge, no backup to other elements of the LILCO paging system.

For example, there could be problems with the paging transmitters.

Encoded paged information is transmitted like two-way radio signals are transmitted.

In essence, the encoder becomes the voice that is transmitted over the radio.

To our knowledge, not all transmitting sites for the commercial paging company used by LILCO have backup power, nor, to our knowledge, are there backup transmitters.

Thus, in the event of a loss of power, or a malfunctioning transmitter, there could be dead spots in the paging system which would prevent LILCO from paging emergency response personnel.

Q.

How likely is it that a paging system would experi-ence the kind of problems that would render the system inopera-ble?

A.

All we can say is that such problems do occur.

For example, sometimes a paging encoder may read a paging signal incorrectly, thereby giving a false or inaccurate printout.

Then, the code number displayed on the pager may not correspond to the code number entered by the person attempting to notify personnel equipped with pagers.

According to the LILCO Plan, emergency workers will be paged using digital encoding.

(See Plan, at 3.4-5).

While a digital encoder is generally reli-able, even digital encoders will give false paging signals when the paging signal is picked up and read wrong by the paging decoder.

In addition, as described by the LILCO Plan, the LILCO paging encoder enn be accessed by commercial telephone.

(See Plan, at 3.4-5).

This raises concerns with the security of the paging system.

Persons could accidentally dial into the system.

of more concern, persons could obtain the code number accessing the system.

Then, of course, the pagers could be activated for any reason, and at any time..

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As persons call into paging systems of the type used by LILCO, their page requests are stacked behind prior page requests.

Delays of 3-5 minutes before the paging signal is actually broadcast are common.

Q.

Do you have any other concerns with respect to LILCO's proposal to contact key emergency response personnel by pager?

A.

Yes.

We understand that during discovery, several of LILCO's designated emergency response workers stated that they had been instructed during the LILCO training program that if they were paged and alerted to remain on standby status, they should just go about their business.

That is, there would be no need to do anything out of the ordinary because they would

.tue paged again if any special action were to be required.

(See deposition of James V.

Biggers ("Biggers deposition"), at 30; deposition of Ronald Brady ("Brady deposition"), at 30).

Thus, for example,.if they had theater tickets, they could go ahead with their plans to attend the show.

Presumably, this instruction to LILCO's emergency response workers was premised on the belief that by using pagers, LILCO would be able to con-tact its emergency response workers regardless of where they might be located..

1 LILCO's advice to its emergency response personnel that they can "go about their business" when they are on " standby" status renders its proposed notification scheme unreliable as a means to ensure prompt emergency response.

An emergency at the plant could quickly escalate, thereby requiring the emer-gency workers on standby status to notify other emergency per-sonnel and to report for duty.

Indeed, LILCO's advice given

during its training sessions is contrary to the Plan's instruction to' emergency personnel brought to standby status to

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" ready applicable materials and remain close to their business or home telephone" in case they are instructed to notify other emergency response personnel. (See OPIP 3.3.3, at 2).

This advice also indicates that LILCO does not understand the capabilities of paging signals.

Many brick or steel build-ings and buildings with lead windows may prevent a paging signal from penetrating the building's structure.

For example, a paging signal may not be received aboard the Long Island Railroad, since the railroad cars are constructed of steel.

Even a typical municipal building made of steel and cement would probably have some dead spots in the broadcast area.

Such dead spots are also caused by terrain, weather conditions and other factors.

  • Q.

Do you have any other concerns with LILCO's use of paging devices to notify and mobilize emergency response per-sonnel?

A.

Yes.

It is our understanding that LILCO will not use rechargeable batteries.

Instead, disposable batteries will be used.

(See OPIP 3.3.2, at 14-15).

Under the LILCO Plan, personnel assigned pagers are re-sponsible for ensuring that batteries are replaced.

(See OPIP 3.3.2, at 14).

LILCO's procedures, however, do not assure that batteries will be kept charged and replaced when necessary.

For that matter, we find nothing in the LILCO Plan with respect to how emergency response personnel are to obtain batteries for their pagers, or how LILCO expecte to maintain its pagers in good working condition.

Proper care and maintenance of pagers are absolutely essential to ensuring reliable operation.

There are also some logistical problems, such as with peo-ple being out of the paging area.

The LILCO Plan asserts that holders of pagers "will not leave the LILCO service territory or New York City while on call."

(OPIP 3.3.2, at 14).

The Plan also assumes that personnel assigned "on call duty" will

" arrange for coverage by one of their emergency position alternates for those time periods (during] which they cannot be,

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on call (i.e.,

illness, travel out of the on-call territory, etc.)."

(OPIP 3.3.2, at 14).

We view these bald assumptions in the Plan as wishful thinking by LILCO.

Realistically, there will likely be instances when personnel equipped with pagers will be unavailable (for example, because of illness) or will be outside the paging area.and beyond the distance of paged transmissions without having arranged for coverage by another emergency response worker.

Indeed, even if the emergency worker has not left the paging area, it is impractical to as-sume that a person paged anywhere in the paging area, including New York City, would be able to report quickly to his duty station, should that be required.

We also have concerns regarding whether paged persons will respond, even if the paging system functions properly.

There is no reason for us to presume that LILCO's emergency response personnel are always going to be healthy and close to their pagers.

In addition, under the LILCO Plan, there is no provision for verifying whether the paged messaga meant to be sent has been received.

That is, there is no requirement in the LILCO Plan for confirmation of messages by paged personnel; the Plan merely assumes that emergency personnel will respond according L

to the code displayed _on their pagers, regardless of whether verification of the code and its meaning can or cannot be made.

(See OPIP 3.3.2, at 14).

Since verification under the LILCO Plan is only verification that emergency personnel have received some paged message, the response to the message may not be the response intended.

For example, due to pager

-malfunction or impreoer encoding by Customer Service opera-tor (s), emergency I annel may actually be notified to go to standby status, even enough it may have been intended that they report for duty.

Notwithstanding the Plan's failure to address confirmation of paged messages by paged personnel, we celieve that virtually every person paged will attempt to telephone somebody to verify the paged message.

For example, if someone is in Huntington when his pager goes off and its encoded message appears to direct him to report to one of the designated staging areas, such as Riverhead, it is unlikely that he would drive approxi-mately 40 miles to Riverhead without first calling in to confirm the paged message.

We believe that virtually everybody is going to attempt to call in to confirm the message before doing anything.

This, of course, wi?.1 further overload commercial telephone lines and tie up customer Service opera-tors. _

We recognize that LILCO's procedures state that no one is to call into the Customer Service Office to verify paged mes-sages, except for the Director and the Manager of LERO and the five senior emergency response coordinators.

(See OPIP 3.3.2).

Every other paged person is instructed to call in to LILCO's automated verification system and then to respond according to the displayed code, regardless of whether verification can or cannot be made.

(See OPIP 3.3.2, at 14).

In our opinion, how-ever, this is unrealistic.

Paged individ uals, in fact, are going to call someone to ask "is this for real?"

That is, the emergency cesponse workers who are paged are going to telephone in and seek confirmation that there is an emergency and that they should either stand by or report for duty.

This is par-ticularly likely because LILCO's emerge.qcy workers do not, as a regular matter or as part of their normal work duties, respond automatically and without question to paged emergency messages.

(See Suffolk County testimony concerning Contentions 39-41 and 44.D, E and F for further discussion of this point).

This is in direct contrast to regular emergency workers, such as police officers, who are accustomed to responding to emergency calls.8/

8/

See Testimony of Donald J.

Dilworth on Behalf of Suffolk County Concerning Contention 25 - Role Conflict ("Dilworth testimony").

In his testimon.y, former Suffolk County (Footnote cont'd next page) 4 -

o l

^

In addition, LILCO's automated verification system only tracks the number of emergency response personnel who call in to the system and enter their identification numbers.

The system does not-in any way confirm the content of paged mes-sages.. In our opinion, without some kind of confirmation be-forehand, many persons will not really believe that there is an emergency requiring them to report for duty.

As a result, we believe that LILCO's Customer Service operators will be flooded with phone calls from workers who have been paged, thereby preventing the Customer Service operators from talking to the very persons -- the top management of LILCO's emergency re-sponse organization -- who need to obtain prompt, full informa-tion regarding the situation.

Moreover, the Customer Service (Footnote cont'd from previous page)

Police Commissioner Dilworth concluded that substantial numbers of the emergency personnel relied upon by LILCO will not report for duty.

(Dilworth testimony, at 1-2).

Commissioner Dilworth pointed out that "the opportunity to evade a mobili=ation call-up is readily available" and that substantial numbers of off-duty emergency personnel, and particularly personnel not accustomed to performing emergency roles, will likely fail to report in the event of an emergency at the Shoreham plant.

(Dilworth testimo-ny, at 3).

As a result, Commissioner Dilworth concluded that LILCO's efforts to implement the protective actions proposed under the LILCO Plan will be crippled.

(Dilworth testimony, at 4).

See also Tr. 1261, 1265 for Commissioner Dilworth's views regarding the difficulties in notifying and mobilizing off-duty SCPD officers. __, __

operators would be prevented from contacting other organizations and entities, such as the Brookhaven Security Station (see OPIP 3.3.2, Attachment 4), that have to be notified by commercial telephone.

The problem becomes espe-cially acute if the emergency comes during the midnight shif t, when the Customer Service Office is only staffed by two opera-tors.

In addition, under the LILCO Plan many of the key emer-gency response personnel equipped with pagers are required to contact by commercial telephone other emergency workers to no-tify them to report for duty.

(See, e.g.,

OPIP 3.3.2, at 7 and ).

For example, some of LILCO's traffic guides will be given pagers.

(See Plan, Figure 3.3.6).

Once paged, these traffic guides will supposedly know the level of emer-gency just by looking at their pager.

Then, if necessary, they are to use commercial telephones to notify other traffic guides to report to the staging areas.

(See Plan, at 3.3-2 through 3.3-4).

If these traffic guides or bus drivers or whoever it is that have pagers and the responsibility for implementing this. cascading telephone scheme take the time to confirm the paged message, or even worse, if their pagers do not function for some reason, or if they fail to respond to the paged mes-sage, then an entire segment of workers will never be notified.

LILCO could lose 10 or more emergency workers for every single worker who chooses to ignore the paged message, or who is unavailable or outside the paging area, or whose pager does not work, or who is unable to get through on a commercial telephone to notify other LERO workers.

(See also discussion regarding Contention 26.D below).

Furthermore, some paged personnel may not have ready access to a telephone and will therefore be unable to notify other emergency workers.

For example, suppose the person paged is out on the road, or at the beach, or commuting home or to work on the Long Island Railroad when he is paged.

The lack of immediate access to phones will delay emergency response.

(See discussion above, -regarding the SCPD notification / mobilization test results).

Q.

Why are your concerns about the technical and logistical problems involved with LILCO's paging system signif-icant?-

i A.

They are significant because we understand that under the NRC regulations, LILCO is required to have the capability oof notifying emergency response personnel relied upon by the LILCO Plan within 15 minutes after declaring an emergency.

See 10 CFR Part.50, Appendix E,

Section IV.D.3.

Fifteen minutes is.

a short amount of time, and even if there were no problems with 4

notification of the emergency to the Customer Service Office, or with notification of key emergency personnel by pager, or with notification of other emergency response personnel by paged personnel using commercial telephones, it is unrealistic in our opinion to assume that LILCO's entire emergency response organization, and.its 1363 emergency response personnel (see Plan, Figure 2.1.'.), could be notified in that amount of time.

7 In our opinion, however, there will be problems in noti-fying LILCO's emergency response personnel, and, as a result, it is certain that substantially more than 15 minutes will be required to notify a sign'ificant segment of LILCO's emergency rec [,onse organization of an emergency at the Shoreham plant.

In our. opinion, there will therefore be delays in mobilizing LILCO's emergency personnel and in implementing command and control decisions regarding protective actions for the public.

For example, suppose that an emergency at the Shoreham site begins as an Alert, requiring notification to the public and activation of LILCO's emergency response organization.

Assume that a LILCO employee, such as a traffic guide, equipped with a pager.and expected to notify by telephone other emer-gency personnel, is out in the field, perhaps without e

I transporta*. ion, when he gets paged.

Suppose that the emergency then escalates, the sirens around Shoreham are activated and the public advised to evacuate.

Under the LlLCO Plan, this LILCO employee would be expected to get to a telephone, make his phone calls, get to some predesignated staging or reporting location, pick up his equipment, and then report to his duty station, wherever that may be.

The whole scenario is unre-alistic.

Even without considering traffic congestion on the highways, it is questionable whether this LILCO employee would really want to get to a telephone to make telephone calls.

It is also questionable whether he could get through to the individuals he is responsible for notifying.

Once the public is notified of an emergency, the telephones are going to be jammed.

Many persons near telephones are going to make calls.

Certainly, before beginning to telephone any emergency workers, many persoas responsible for notifying other individuals are going to first attempt to call home.

Then they may start telephoning their friends and relatives, Eventually, they may start telephoning the individuals on their LERO notification liets.

The point is that there may be a significant period of time between when notification is first given to key emergency personnel via the LILCO paging system and when other emergency _ --.

response personnel are notified by these paged personnel using commercial telephones.

This delay will lengthen the time nec-essary to mobilize LILCO's emergency response force.

V.

Contention 26.D -- Notification of Emergency Response Personnel bg_ Telephone Q.

Do you agree with Contention 26.D?

A.

Yes.

Contention 26.D addresses the LILCO Plan's provision for having key emergency response personnel, af ter having been contacted through the LILCO paging system, notify other emergency response personnel by telephone.

This Conten-tion alleges that using telephones to notify emergency response personnel provides no assurance that there will be prompt noti-fication and mobilization of such personnel.

Assuming that proper notification of an emergency at the Shoreham site is given to the Customer Service Office, and that the Customer Service Office accesses the paging system encoder, without any problems, and that-the pagers are all working, the next step would be notification / mobilization of emergency re-sponse personnel.9/

Under the LILCO Plan, paged individuals, 9/

The LILCO Plan addresses only the notification /mobili-zation of emergency personnel initially responding to an emergency at the Shoreham plant.

A prolonged emergency, however, could require calling out a second shift of emer-(Footnote cont'd next page).-

using commercial telephones and a cascading telephone scheme, would.be largely responsible for carrying out this notifi-cation / mobilization effort.

(See Plan, at 3.3-2 through 3.3-4).

Many of the concerns previously discussed are also relevant to this aspect of LILCO's notification scheme because, again, this aspect of LILCO's Plan places heavy reliance on commercial telephones.

Even assuming that there would be no problem with overloading of telephone lines (an assumption we believe to be completely unrealistic and without basis for the reasons stated previousl y in this testimony), accessibility to telephones would be a major problem.

This is the case because at least some emergency response personnel would not be near telephones or would be using their telephones at the time of the emergency.

For example, meter readers and other LILCO em-ployees may be in the process of performing their normal job functions out in the field.

Other LILCO employees, even if off duty, may not be at home.

Thus, even assuming that all person-nel equipped with pagers could be paged, and that, when paged, they have ready access to a telephone so that they could (Footnote cont'd from previous page) gency parsonnel.

In our view, the failure to address no-tification/ mobilization of "second shift" emergency per-sonnel is a serious deficiency of the LILCO Plan. -

telephone other emergency response personnel to notify them of the emergency, these other personnel must have access to a telephone for notification to be made.

For example, it is our understanding that approximately 125 of LILCO's meter readers will serve as traffic guides under the LILCO Plan.

(See OPIP 2.1.1, Attachment 2; see also LILCO computer listing).

LILCO's meter readers typically arrive at their offices, pick up their assignments, and then spend the

. rest of the day working from house to house out in the field.

(See deposition of J.

Barrows

(" Barrows deposition"), at 6).

These LILCO employees are usually driven to their work area neighborhoods-by other LILCO employees and are not picked up until'the end of the day.

Typically, they cannot be contacted during the day unless someone drives to the neighborhoods where they are working and finds them.

Of course, even if some of LILCO's meter readers could be contacted ( for example, because they had been given a pager), reporting to their duty stations, or even to a phone if required to call other workers, in the event of an emergency at the Shoreham plant would be difficult or impossible, since they often have no transportation while they are in the field.,

Q.

Do you have any other concerns with LILCO's reliance on commercial telephones to notify emergency response person-nel?

A.

Yes.

In our opinion, problems will also occur be-cause paged individuals, af ter receiving a paged message, may not.have access to telephones.

Then, of course, notification to other emergency response personnel would be impossible.

For example, a LILCO employee may be out in the field or driving to an assignment when he gets paged.

Even assuming that he gets to a phone, and that he has money to use it or someone lets him use the phone, he would have to have with him the telephone numbers for the emergency workers he is responsible for noti-fying.

Apparently, the LILCO Plan assumes that personnel equipped with pagers will always carry with them a list of the individuals they are responsible for contacting with current home and work phone numbers.

It also assumes that the individuals to be contacted will always be at home or work.

These assumptions, in our opinion, are completely unrealistic.

In short, with respect to the LILCO paging system and the cascading telephone system described iri the LILCO Plan, our cancerns do not go away just because it is assumed that the pagers work.

That is not the end of the problem.

LILCO's _-- __

~

reliance on commercial telephones raises significant concerns and, under many circumstances, the question may not be whether a paged individual knows what to do once he gets paged, but whether he can do it.

Should the paged individual be away from a telephone -- for example, at the beach or a public park --

the answer may well be that there will be no alternative other than for the individual to get in his car (assuming one is available) so that he can search for the nearest available telephone.

Even under circumstances where a paged individual is at home and near a telephone when he gets paged, it will take a substantial amount of time to locate the names and phone numbers of the persons he must call, to place the number of telephone calls necessary to reach the required number of emer-gency response personnel, and to conduct the necessary conversations with each person contacted.

Assuming that pe -

sonnel can be contacted, we would estimate that each telephone call could.take as long as 3-5 minutes.

This time would be significantly extended when the paged individual is not near a telephone at the time he is paged.

~ The point that must be emphasized is that the LILCO Plan does not take into account many practical problems that would be encountered by any communications network that relies upon paged individuals to notify other individuals by way of commercial telephones.

VI.

Contention 26.E -- Notification of Non-LILCO Organizations and Personnel _

Q.

Contention 26.E raises a number of concerns regarding notification of non-LILCO emergency support organizations and personnel.

Among other things, the Contention alleges that there are no procedures for notifying many of the support orga-nizations relied upon by LILCO.

In your opinion, should the LILCO Plan contain such procedures?

A.

Yes.

LILCO asserts that its Plan and implementing procedures " delineate all of the response activities at the local level in reaction to any incident at the plant, regardless of severity."

(Plan, at 1.2-1).

LILCO also asserts that its procedures contain the " detailed information" used in implementing the Plan.

(Id.).

Notwithstanding these asser-tions, the LILCO Plan contains no such procedures for notifying many of the emergency support organizations relied upon by LILCO, including hospitalc, reception and relocation centers, bus companies, and ambulance companies.

In our opinion, LILCO's failure to have detailed procedures for notifying these organizations could lead to problems in coordinating the re-sponse of these organizations and their personnel to an emer-gency at the shoreham plant. ~-

.=

We recognize that the LILCO Plan assigns to designated individuals responsibility for contacting emergency support or-ganizations.

For example, should an Alert be declared at the Shoreham site, the LILCO Customer Service operator is responsi-ble for notifying the American Red Cross

(" ARC") designee who serves as the Relocation Center Coordinator under the LILCO Plan.

(See Plan, Figure 3.3.3; OPIP 2.1.1, Attachment 2).

The Relocation Center Coordinator is then responsible for notifying the relocation centers; however, such notification would not be made until the emergency had eseslated to a Site Area or General Emergency classification.

(See Plan, Figure 3.3.4).

Responsibility for notifying hospitals, bus c^ompanies and ambu-lance companies in order to obtain emergency response support lies with the LILCO employees assigned the job titles of Hospital Coordinator, Bus Coordinator, and Ambulance Coordinator.

(See Plan, Figure 3.3.4).

Under the LILCO Plan, notification of these organizations would also not be made until a Site Area or higher classification emergency.

(See Plan, Figure 3.3.4).

However, merely designating a person who is to notify an emergency support organization does not assure that prompt no-tification will in fact be made.

Indeed, because commercial telephones will apparently be used to attempt to contact these 4 e

,m

organ'izations, we have grave concerns whether notification will be possible.

Asowe have previously discussed, LILCO's reliance on' commercial telephones to notify emergency response organiza-itions'.provides no assurance that the necessary personnel will be contacted -- for example, because they will not be near telephones or wil1 be using their telephones, or because the lines will be overloaded.

Nevertheless, there should be specific, detailed. procedures regarding notification of all support organizat' ions relied upon by LILCO.

These procedures, at a minimum, should designate the individual responsible for notifying each organization and should contain the content of notification messages and other necessary information, such as the telephone number of the organization to be notified and the name(s) of the individual (s') to be contacted at each organiza-tion.

The LILCO. Plan also fails to provide a backup means of communication for notif). cation of emergency support organiza-tions',1with the primary and secondary communications means having different failure modes under adverse environmental conditions.. Because-of the. problems with commercial tele-phones,_there is no assurance that there will be timely notifi-cation to the support organizations relied upon by LILCO.

This

.in a significant deficiency of the Plan since the emergency a

:_ ?

-r

functions provided by certain support organizations are essential to implementation of the Plan.

For example, the Brookhaven Area Office is to notify the DOE-RAP personnel who are relied upon by LILCO to monitor radiation levels ( see OPIP 3.5.2), and ambulance companies are relied upon to evacuate special facilities and handicapped persons at home (see, e.g.,

OPIP 3.6.5).

The Plan does include a procedure for notifying four of the non-LILCO emergency support organizations relied upon by LILCO, namely the Brookhaven Arca Office (which will, in turn, notify DOE-RAP personnel), the U.S. Coast Guard, the Federal Aviation Administration, and the New York Telephone Company.

(See OPIP 3.3.2, Attachment 4).

This procedure, however, lacks necessary detail'and scope.

For example, the procedure does not designate alternates to the emergency response positions assigned responsibility for notifying the support organiza-tions; nor are there any checks built into the procedurec to assure that notification is actually made or at least at-tempted.

In addition, notification of these organizations is again to be by way of commercial telephones.lE/

Thus, for the

--10/

We understand that on February 27, 1984, LILCO advised Suffolk County for the first time that it intends to install marine-band radios at LILCO's Hicksville facility and at the EOC to provide radio communications with the

( Footncte cont'd next page) -

reasons discussed already, there can be no assurance that the

necessary personnel will be contacted.

Q.

Isn' t there a backup means cf communications for certain of the emergency support organizations relied upon by LILCO?

A.

The LILCO Plan does provide a backup means of communications to the Brookhaven Area Office, the U.S.

Coast Guard,'and the Federal Aviation Administration.

(See OPIP 3.3.2, Attachment 4).

However, with the possible exception of the Coast Guard, the backup is via the so-called " Federal Tele-phone System."

This system is ineffective as a backup to commercial telephone lines since it is nothing more than the Federal tie-line telephone system and therefore subject to the same problems common to commercial telephones.

In addition, commercial telephones and the Federal Telephone System have con. mon failure modes under adverse environmental conditions.

(Footnote cont'd from previous page)

Coast Guard's communications center in New Haven, Connecticut.

(See letter dated February 25, 1984, from J.

Monaghan to L.

Lanpher

(" February 25 letter"), at 8).

Nevertheless, it is our. understanding that LILCO continues Eto rely on commercial telephones as the primary means of communications with the Coast Guard.

(See letter dated February 23, 1984, from W.

Renz to Captain Wiegand, U.S.

Coast Guard).,

e

- ~.,

a

Thus, LILCO's backup to commercial telephones as a means for notifying these emergency support organizations is ineffective and provides no additional assurance that notification will be made.

Q.

Do you have any other concerns regarding nctification of non-LILCO emergency support organizations?

A.

Yes.

Under the LILCO Plan, there is no provision for verification of' messages to these organizations.

Thus, even if notification of an emergency is given to the non-LILCO emer-gency support organizations and their personnel, the response to such notification may not be the response intended and appropriate.

For example, emergency personnel may go to stand-by status rather than reporting to duty.

Then, of course, there would be a significant delay in mobilizing emergency re-sponse personnel relied upon by LILCO.

Q.

Do you have any other concerns regarding LILCO's pro-posals for notifying non-LILCO emergency support organizations?

A.

Yes.

While LILCO apparently intends to notify the Brookhaven Area Office, the New York Telephone Company, the U.S.

Coast Guard, and the Federal Aviation Administration at the Alert stage (see Plan, Figure 3.3.3), other non-LILCO 1

support organizations will only be notified if c Site Area or General Emergency has been declared by LILCO.

(See Plan, Figure 3.3.4).

In our opinion, as a result of this provision of the LILCO Plan, there is no assurance that there will be timely notification and recponse by the support organizations relied upon by LILCO.

Q.

Please explain.

A.

The LILCO Plan establishes four. classes of emergencies.

These classes, in order of increasing severity, are Unusual Event, Alert, Site Area Emergency and General Emer-gency.

(See Plan, at 3.2-1).

Upon declaration of an Unusual Event, the Director of LFRO could decide to activate LILCO's emergency response organization and to mobilize emergency re-sponse personnel.

However, ordinarily that would not happen and, in fact, only the very top people of LILCO's emergency re-sponse.or3anization would even be notified.

(See Plan, at 3.3-2 and Figure 3.3.2).

Upon declaration of an Alert, the LILCO Plan assumes that all emergency workers would be notified, but'only the Director and the Manager of LERO and other key emergency response personnel assigned to the EOC would report to the EOC, which would be activated.

With the exception of staging area supervisory staff, the DOE-RAP team,

1 and route alert drivers, other emergency workers notified would only be instructed to go to a standby status.

(See Plan, at 3.3-3 and Figure 3.3.3).

Under most circumstances, it would not be'until the Site Area or General Emergency stages that most emergency response workers would first be notified of an emergency'and instructed to report for duty.

(See Plan, at 3.3-3 and 3.3-4, and Figure 3.3.4).

This notification scheme is apparently based upon LILCO's assumption that there will be a logical progression of emergency levels, going from Unusual Event up through, at worse, a declaration of a General Emer-gency.

From a communications perspective, this assumption poses very real problems in notifying and mobilizing emergency re-sponse personnel, including the personnel of non-LILCO support organizations.

For example, if the first emergency level de-clared is an Unusual Event, which escalates very quickly to a Site Area Emergency, then the notification procens for most emergency response personnel will not even have begun.

Even if the emergency first escalated to an Alert, thereby requiring LILCO to notify emergency personnel to go to standby status, if the emergency further escalated to a Site Area or General Emer-gency, LILCO would have to contact emergency personnel again in order to advise them to report for duty.

As a result, mobilization of emergency personnel would be delayed.

j -

l Q.

Does that conclude your testimony?

A.

Yes.

. \\

\\

J1 a

O ATTACHMENT 1 I

.t

ATTACHMENT 1 POLICE DEPARTMENT COUNTY OF SUFFOLK, NEW YORK thTERNAL CORRESPONDENCE TC: Richard Roberts, Inspector DATE: 8/25/83 i

Command 6000 rRov Kenneth J.

Regensburg, Dep./Insp.

COPY TO:

C.O.

Command 4200

SUBJECT:

Personal Resume l

Born May 26, 1932, New York-City, N. Y. Resident of Lake Rc.1konkoma, Syffolk County, N. Y. since 1962.

. Employment:

Enlisted U.S. Navy March 12, 1951; honorably discharged February 24, 1955 with the rank of Second Class Petty officer (Aviation Structural Mechanic).

March 1955 to June 1965 employed by Lockheed Aircraft Service International, Kennedy Airport, N. Y.

as an Aircraft Hydraulic Technician.

July 5, 1965 - Appointed to the Suffolk County Police Department as a Patrolman.

October 1971 - Promoted to Sergeant, Precinct Patrol.

February 1975 - Promoted to Lieutenant, Precinct Patrol.

1 January 1978 - Promoted to Captain, Commanding Officer of Central Records Section.

January 1979 - Promoted to Deputy Inspector, Commanding Officer of Communications and Records Bureau.

Presently serving in that capacity.

Education:

1950 Graduated St. Ann's High School, New York City.

1961 Graduated Academy of Aeronautics, Queens, N. Y.

with Certificate in Aircraft Design.

1982 A.S. Degree, University of the State of New York.

1983 B.S. Degree, Psychology, University of the State of New York.

Respc ully submitted, i

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ns rg, De

'/Insp.

,.Commanding ficer Command 4200 i

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POLICE DEPARTHENT COUitTY OF SUFFOLK, NEW YORK INTERNAL CORRESPO'OE'.CE _

To:

Inspector Richard Roberts DATE: 9-1-83 i

Office Of The Chief Of District FROM: Captain Robert A.

Snow COPY TO:

l Commanding Officer - Communications Section

SUBJECT:

personal Resume Mav 12, 1944 - Born in Queens, NY June 1962 - Graduated from Massapequa High School, Massapequa, New York Aug. 1962 - Aug. 1966 - Enlisted in U.S. Air Force. Serced as Communication Intercept Specialist (Chinese).

Honorable Discharge.

Oct. 1966 - Jan. 1968 - Employed by Aeronautical Radio,Inc. as a Communication Operator.

Jan. 1968 - Mar. 146R - Appointed to Suffolk County Police Dep-artment. Graduated fron Police Academy.

Mar. 1960 - May 1969 - Assigned to Precinct Patrol.

May 1969 - Feb. 1970 - Assigned to Highway Patrol.

Feb. 1970 - Mar. 1971 - Assigned to Narcotics Squad.

Mar. 1971 - Nov. 1973 - Promoted to Detective. Assigned to Nar-cotics Squad, Fugitive Squad, Electronics Squad, Major' Crime Enforcement Unit.

Nov. 1973 - Auc. 1975 - Promoted to Sergeant. Assigned to Precinct Road Supervision.

Aug. 1975 - Jan. 1978 - Promoted to Detective Sergeant. Assigned as Conninding Officer Sex Crine Unit, Commandinn Of-ficer Property Recovery Unit, Ccmmanding Office

" air Office Detectiics Adninistration, Investigaticn Super-visor District Attorney's Rackets Bureau, Connanding Officer District Attorney's Anti-Corruption Bureau.

Jan. 1973 - Auc. 1492 -- Promoted to Lieutenant. Assigned as Exec-utive Officer Central Records Section, Investigator with Internal Af.# airs Section.

Aca. 1992 - Present - Proroted to Captain. Assioned as 91 strict Oc mander, Cennanding Officer Cc munications Sectior.

~

t ::- ya

A r

j Parsonal R2sume - Robert A. Snow (continued)

Education - 1962 - Gradua?ed !!assapequa High School.

1963 - Graduated Yale University Institute Of Far Eastern Languages. (non-degree) 1968 - Graduated Police Academy 1971 - Graduated Investigator School 1974 - Graduated Supervision School 1977 - Graduated New York Institute Of Technology.

B.S. Degree Behavioral Science / Criminal Justice. NYIT Honor Scolety.

1982 - Graduated F.B.I. National Academy Respectfully submitted, W

Robert A. Snow, Captain Commanding Officer Communications Section i

O e

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~

i RESUME

'I i

e Vincent R.

Stile, P.O.

1058 Communications Bureau Suffolk County Police Department PRESENT OCCUPATION I am presently employed by the Suffolk County Police Depart-ment as a Police Officer assigned to the Communications Technical Unit.

My duties for the past eight years have been that of communications coordinacor for the County Police Department.

I have been responsible for the implementation of the County wide mobile radio district communications program.

My job was to coordinate the communications efforts of the twenty-three law enforcement agencies in Suffolk County, and facilitate the move of the County Police Department's communications command control center from a Hauppauge location to its new f acility in Yaphank, New York.

Prior to my present assignment I was responsible for the police department's radio service shop crew.

I directed the instal-lation, maintenance and repair of the police two-way radio systems, electronic sirens, and other electronic equipment.

My duties included installation of base station radio units, satellite receivers, and all field surveys needed to evaluate the location of such field equipment.

My interface has been with many com=unications equipment vendors, New York Telepnone Ccapany line/ network administrators and repair personnel, other County department administrators and civilian communications groups.

I have also served for approximately ten years as the alternate APCO frequency coordinator for Southern New York State with the Associated Public Safety Communications Officers, Inc.

v

\\

For a total of seventeen out of eighteen years of service in the Suffolk-County Police Department, I have worked in the coccuni-cations field.

PAST EXFEP.IENCE Before joining tne County Police Department, I was employed as a quality control electronic technician for Gyrodyne Helicopter Conpany.

I also werked as a radio mechanic for Pan American Airlines, and was a customer service field technician for the Burrcugh's Corporat' ion.

Prior to this, I was employed as an e lec t ro / r:c ch anic a l X-ray tecnnician for North American Philips Conp'any.

I served in the Air Force for four years as an airc ra f t electrician a nd autopilot specialist.

l l

Vincent R.

Stile, P.O.

1058 Page 2 1

i EDUCATION I have an Associate in Applied Science Degree from Suffolk Community College with a number of credits in Computer Science.

I am also a graduate of R.C.A.

Institutes with eighteen months of schooling in electronics.

I have an up-to-date first class radio-telephone FCC license.

I graduated St. Francis Prep. High School in Brooklyn.

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ATTACHMENT 2

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a ATTACHMENT 2 POLICE DEPARTMENT COUNTY OF SUFFOLK, NEW YORK INTERNAL CORRESPONDENCE Inspector Richard C.

Roberts Chief of District Office 1/17/83 DATE:

7o, Inspector' Joseph L. Monteith, C.O.,

6560 FROM:

COPY TO:

TEST OF MOBILIZ ATION PLAN

SUBJECT:

As we discussed, the Sixth Precinct Mobilization Plan was tested on January 17, 1983.

The test commenced at approximately 1330 hrs.

~

For purposes of the test, only those Officers who were scheduled to work 4-12 (or 3-11), those Officers on RDO's and those Officers scheduled to begin the

~

l 12-H tour (or 11-7 tour) this evening were canvassed.

It was felt that calling those Officers who just completed l

a 12-8 tour and disturbing them would not be practical.

I think we can assume that most of them would be home in bed and available if needed.

Utilizing the above guidelines, we first called the Lieutenants.

In a real situation, the Lieutenants would be expected to call the Sergeants under their control who, in turn, would call the Officers in their squads.

In order to simulate real conditions, we first calculated the amount of time it would take to call all the Lieutenants and then calculated the amount of time it would take the average Lieutenant to call the Sergeants assigned to him (usually three (3)).

A third calculation was made for the amount o_f time it would take each Sergeant to call all of the men in his squad.

The results are as follows:

Time to contact the Lieutenants - Five (5) minutes Time for the Lieutenants to contact Sergeants - Twenty-two ri:

Average time for each Sergeant to contact the Police Officers in his squad - Sixteen (16) minutes -

Total time to contact all Precinct' Personnel - 43 minut.es.

l A total of one hundred and forty-three (143) contacts were attempted (Superiors and Police Officers).

Of these, sixty-six percent (66%) were successful.

In thirty-four percent (34%) of the cases we either received no answer or the person answering the phone indicated that he or sne was unable to reach the Officer to pass on the message.

Of those who indicated they could responc (ninety-four (94) Officers) eighteen percent (18%) (or seventeen (17) men) indicated i

that it would take then between one to one and one-half hours I

to report for duty.

The remainder indicated they could

- occs. m42

,e e

respond within thirty-five.(25) minuuas.

Utilizing these figures, seventy-seven (77) cf the one hundred and forty-three (143) people we attempted to contact (541) indicated they would be available for duty within thirty-five (35) minutes (average).

Accordingly, it would take approximately one hour and elahteen minutes to field. 54% 6Y the Officers who are not working at the time the mobilization was put into effect.

It should be taken into account that all of these calls vere made at a time when nothing unusual was occurring in the area that might tie-up the phone system.

If an actual evncuation of Shoreham were contemplated,

we must assume that the telephone companys lines would be over-burdened with calls from citizens trying to make arrangements with husbands, out-of-town relatives,-

etc. to take care of their family needs.

Since this test was made under ideal conditions, the 54% figure mentioned might not be the figure we would deal with

~

in the real emergency.

The situation would be further complicated if the desk had difficulty reaching a Lieutenant or a Lieutenant had difficulty reaching a Sergeant.

At that point, everything would stop for that squad and we would have no way of knowing it because, in all probability, the Officer would have difficulty calling the Precinct to report.

P IW L o

Joseph L Monteith, Inspectorwh C.O.,

65 0 JLM/jad

. - -