ML20081A764
| ML20081A764 | |
| 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 8403060278 | |
| Download: ML20081A764 (45) | |
Text
W
,y RELATED GORRtsPONDENCE 00PMETED 09m;
'84 f2R -5 TH :03 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
DIRECT TESTIMONY OF DEPUTY INSPECTOR KENNETH J.
REGENSBURG, DEPUTY INSPECTOR ROBERT A. SNOW AND POLICE OFFICER VINCENT R.
STILE ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTIONS 28, 29, 30, 31, 32 AND 34 -- COMMUNICATIONS AMONG EMERGENCY RESPONSE PERSONNEL March 2, 1984 8403060278 840302 POR ADOCK 05000322 T
PDR 2
e
(
-DIPECT TESTIMONY'CF DEPUTY INSPECTOR KENNETH J.
REGENSBURG, DEPUTY INSPECTCR ROBERT A.
SNOW AND POLICE OFFICER VINCENT R.
STILE ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTICNS 28, 29, 30, 31, 32 AND 34 -- COMMUNICATIONS AMONG-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 Of-ficer 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 ot
- 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 Department.
My name is Vincent R.
Stile.
I am a Police Officer
~
assigned'to the Communications Technical Services Unit, County 4
s
y 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.
Statements of our qualifications and experience are atta-ched to our testimony submitted on behalf of Suffolk County
- concerning Contention 26 -- Notification of Emergency Response Personnel.
Our Contention 26 testimony also explains the general organization and structure of the Suffolk County Police Department ("SCPD").
Unless otherwise indicated, each answer is sponsored by the entire panel.
Il.
Contention 28 -- Communications With Federal Agencies 1
Q.
Contention 28 allegen that the LILCO Plan fails to provide adequate and reliable means of communications with the Federal. emergency response organizations relied upon by LILCO.
Do you agree with this Contention?
A.
Yes.
Under the'LILCO Plan, commercial telephones are relied upon-for communications with FEMA, the U.S. Coast Guard, and.the Federal Aviation Administration.
(See Plan, Figures 3.3.5 and 3.4.1; OPIP 3.3.2, Attachment 4).
With the possible Lexception of the U.S. Coast Guard,1/ there are no radio or 4
1/
We understand that on February 27, 1984, LILCO advised Suffolk County for the first' time that it intends to (Footnote cont'd next page)
. I
dedicated telephone links to these Federal agencies.
In addition, the only backup means of communications to these agencies is provided by the so-called Federal Telephone System, which, under the LILCO Plan, must be accessed from the Shoreham control room.
(See OPIP 3.3.2, Attachment 4).
We have previously discussed the fact that commercial telephones do not-provide an adequate or reliable means of com-munications.
(See our testimony.concerning Contention 26).
Further, as FEMA witness Philip McIntire has testified, "[i]t can reasonably be expected that the telephone system could be-come overloaded in the event of an incident" at Shoreham.
(See Testimony of Philip McIntire Concerning Contentions 23, 25, 65, ff. Tr. 2086, at 8).
Moreover, the Federal Telephone System is ineffective as a. backup to commercial telephones, since it is nothing more than the Federal tie-line telephone system and therefore also inadequate and unreliable under emergency (Footnote cont'd from previous page)
. install marine-band radios at LILCO's Hicksville facility and at the Emergency Operations Center ("ECC") in LILCO's Brentwood facility to provide radio communications with the Coast Guard's communications center in New Haven, Cannecticut.
(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 to rely on commercial telephones as the primary reans of communications with the Coast Guard.
(See letter dated February 23, 1984, from W.
Renz to Captain Wiegard, U.S.
Coast Guard).
I conditions.
In fact, as noted in our testimony concerning Contention 26, commercial telephones and the Federal Telephone System have common failure mo' des under adverse environmental conditions.
Thus, not only is LILCO's primary means of commu-nications with Federal emergency response organizations inef-fective, but its backup to that primary system (i.e., more telephones) provides no assurance that communications will, in fact, be possible.
Indeed, additional problems must be expect-ed with LILCO's reliance on the Federal Telephone System as a backup communications system since, under the LILCO Plan, pri-mary responsibility for notifying FEMA, the Coast Guard, and the Federal Aviation Administration is assigned to LILCO per-sonnel (the Director of Local Response and the Evacuation Coordinator) who, during an emergency, will not be located in
'the Shoreham control room, the only access point for the Federal Telephone System.
(See Plan, Figure 3.4.1; see also OPIP 3.3.2, at 7, 11-12, and Attachment 4).
III.
Contention 29 -- Communications Personnel and Repair Technicians Q.
Contention 29 alleges that there is no assurance that LILCO's communications system can or will be operated in the event of an emergency at the Shoreham plant because the LILCO
-Plan neither specifies the number of personnel that will be assigned responsibility for manning communications equipment,
, ~, -,..,
nor provides for trained communications equipment repair technicians.
Do you agree with this Contention?
A.
Yes.
Although the LILCO Plan generally describes the various systems / equipment that LILCO proposes to use for commu-nications among LILCO and emergency response organizations and personnel (see Plan, at 3.4-1 through 3.4-6, and Figure 3.4.1),
it fails to specify the number of emergency personnel that will be assigned responsibility for manning such communications equipment.
Such equipment includes transmitters for the radio channels to be used by LILCO's emergency response organization and other radio equipment, dedicated and. commercial telephones, and the LILCO paging system.
Among other places, such equip-ment.is located at the EOC, the three LILCO staging areas in Riverhead, Port Jefferson, and Patchogue, the 11 LILCO transfer points, ambulance dispatch stations, the Customer Service Office in Hicksville, and the Shoreham control room.
(See, e.g.,
Plan, Figures 3.3.5 and 3.4.1).
Without an adequate number of qualified and trained personnel to man LILCO's commu-nications system and to back up those personnel assigned prima-ry communications responsibilities and duties, there can be no assurance that prompt or reliable communications among emer-gency personnel will be possible. -.
t The LILCO Plan does not specify the responsibilities or duties of the LILCO personnel assigned to man communications equipment.
In fact, the only information regarding this matter which we have been able to obtain from LILCO was provided in a -
response to a discovery request from Suffolk County.
(See letter dated December 22, 1983, from J.
Monaghan to M.
Miller
(" December 22 letter"), at 4-5).
This information was limited to a description of the responsibilities and duties of the LILCO personnel assigned to three positions involving communi-cations at the EOC.2/
The information provided in the December 22 letter does not indicate adequate communications staffing at the EOC.
With respect to the manning of communications equipment at other communication posts, including staging areas, transfer points and ambulanco dispatch stations, neither the Plan, nor any other information available to us, indicates the number of emergency personnel assigned responsibility for manning the communications equipment relied upon by the LILCO Plan.
2/
According to LILCO's December 22 letter, the radio equip-ment covering channels used by traffic guides, transfer points and staging areas will be manned by the Traffic Control Communicators at the EOC.
The Transportation Support Communicator at the EOC will apparently man the radio used to communicate with road crews and evacuation route spotters.
The Ambulance Coordinato'r at the ECC is supposed to man the radio used to communicate with the private ambulance dispatch locations relied upon by LILCO...
Similarly, the Plan provides no indication regarding the specific responsibilities or duties of those personnel respon-sible for manning such equipment.
Without clear lines of re-sponsibility and authority among LILCO's communications person-nel, there is no assurance that LILCO's communications system will be properly coordinated or operated in the event of an emergency at the Shoreham plant.
Because it has been our experience that communications problems arise frequently, we also have concerns with respect to the LILCO Plan's failure to provide for trained repair tech-nicians capable of keeping communications equipment operation-al.
The LILCO Plan states that there will be personnel to per-form maintenance activities at the EOC.
(See,OPIP 2.1.1, At-tachment 2).
These personnel report to the Logistics Support a
Coordinator.
However, neither these maintenance personnel, nor the Logistics Support Coordinator, nor any other emergency re-sponse personnel under the LILCO Plan appear to be trained and qualified communications repair technicians.
For example, the personnel assigned maintenance duties under the LILCO Plan are LILCO employees with jobs such as building custodians.
Simi-larly, the Logistics Support Coordinator position under the LILCO Plan is staffed by LILCO personnel with job titles of "LILCO Senior Buyer - Purchasing," "LILCO Supervising Buyer,"
and "LILCO Residential 9urchasing Representative."
(See OPIP,
2.1.1, Attachment 2).
Thus, should communications equipment break down, or should problems with such equipment develop, the LILCO Plan has no provisions for identifying or resolving such'
[
problems.
Without trained repair technicians on duty at all times at every location where a communications post is established, there is no assurance that the communications pro-posed under the LILCO Plan could or would be possible.
IV.
Contentions 30 and 31 -- LILCO's Emergency Radio System Q.
Contentions 30 and 31 address LILCO's proposed Emer-gency Radio System as a means for providing communications between LILCO's emergency response coordinators and field emer-gency response personnel.
Please describe your understanding of this Emergency Radio System.
A.
The LILCO Plan generally describes a radio communica-tions system -- the LILCO Emergency Radio System -- for use by LILCO's emergency response organization.
(See Plan, at 3.4-3).
According to LILCO, this system will utilize five radio channels.1/
There will be two UHF channels.
There will also 3/
On February 27, 1984, LILCO advised the County for the first time that it had modified the Emergency Radio System as described in Revision 3 of the Plan by adding a new frequency (37.46 MHz).
Thus, contrary to the description contained in Revision 3 of the Plan, the LILCO Emergency Radio System now consists of five channels rather than four channels.
(See February 25 letter, at 5-7).
We have attempted to' address this most recent change in LILCO's i
(Footnote cont'd next page). - -...
-0 e
be a high band VHF channel and two low band VHF channels.
The frequencies in the Emergency Radio System that make up these five channels are as follows:
153.68 MHz, 451.625 MHz, 456.625 MHz, 451.525 MHz, 456.525 MHz, 37.62 MHz, and 37.46 MHz.4/
These frequencies.can be transmitted and received by the EOC and, according to LILCO, are intended to provide either the primary or backup means of communications between the EOC and field emergency response personnel.
(See December 22 letter, at 2, 6; see February 25 letter, at 5-7).
LILCO's assignrent of thece frequencies is described below.
Based upon information provided to Suffolk County by LILCO, it is our understanding that one channel using a pair of UHF frequenciesE/ (451.525 and 456.525 MHz) will be used for communications between and among traffic control
( Footnote cont' d from previous page) radio system in this testimony.
If, however, after we have had an opportunity to review and analyze LILCO's most recent modification to its radio system more fully, we de-termine that this testimony should be supplemented or amended to comport with changes made by LILCO, we will prepare and file such suppl mental or amended testimony.
4/
A radio channel is an avenue of communications comprised of either a single frequency (simplex system) or dual frequencies (repeater system).
A description of simplex and repeater radio systems is provided in our testimony concerning Contention 26.
5/
A description of paired UHF frequencies is provided in our testimony concerning Contention 26..
communicator (s) at the ECC, the staging area coordinator and lead traffic guide at the Port Jefferson staging area, approxi-mately 75 traffic guides (at 56 traffic posts), and as many as six transfer point coordinators (including alternates) dis-patched f rom the Port Jef ferson staging area.
The other channel using a pair of UHF frequencies (451.625 and 456.625 MHz) will be used for communications between and among traffic control communicator (s) at the EOC, the staging area coordinator and lead traffic guide at the Patchogue staging area, and approximately 67 traffic guides (at 47 traffic posts) and as many as seven transfer point coordinators (including alternates) dispatched from the Patchogue staging area.
One of LILCO's low band VHF channels (37.62 MHz) will be used for com-munications between and among traffic control communicator (s) at the EOC, the staging area coordinator and lead traffic guide at the Riverhead staging area, and approximately 51 traffic guides (at 44 traffic posts) and as many as six transfer point coordinators (including alternates) dispatched from the Riverhead staging area.
(See December 22 letter, at 2; see also Plan, at 3.4-3 and Figure 2.1.1; see also OPIP 3.6.3, At-tachment 4).
Since apparently each traffic guide location (but not every traf fic guide) and each transfer point will have a mobile radio (see December 22 letter, at 6 and Plan, at 3.4-3),
there will be approximately 160 users assigned to these three radio channels.5/-
6/
Under the LILCO Plan, 147 traffic posts would be manned in the event of an evacuation of the entire 10-mile EPZ.
( Footnote cont'd next page)
These three radio channels provide the only means of com-munication between the LILCO staging areas and emergency re-sponse personnel in the field.
In addition, LILCO intends to use these channels as backup to the dedicated telephone lines which are intended to provide the primary means of communica-tion between the'EOC and the Port Jefferson, Patchogue and Riverhead staging areas.
(See December 22 letter, at 2; see also Plan, at 3.4-3 and 3.4-4).
LILCO's remaining two radio channels (frequencies 153.68 MHz and 37.46 MHZ) will be used by the Transportation Support Coordinator and the Ambulance Coordinator at the EOC to commu-nicate with road crews, evacuation route spotters, and ambu-lance dispatch stations.
(See Plan, at 3.4-3).
Frequency 153.68 MHz will be used for communications between and among the Transportation Support Coordinator and approximately 30 road crews and six evacuation route spotters.
(See Plan, Figure 2.1.1; see December 22 letter, at 5).
Frequency 37.46 MHz will be used for communications between the Ambulance Coordinator and the ambulance dispatch stations relied upon by the LILCO Plan.
(See February 25 letter, at 7).
It is our (Footnote cont'd from previous page)
(See Plan, Appendix A, Figure 8).
In addition, there are 11 transfer points under the LILCO Plan.
(See Plan, Ap-pendix A, at IV-74c).
e
/
T j,
4" understanding that LILCO has entered into letters of intent witN approximately 15 ambulance companies.
(See Plan, Appendix B).<.T.5us, assuming that each road crew (but not each road crew member), evacuation route spotter, and ambulance dispatch station will have a mobile radio (see Plan, at 3.4-3), there will be approximately 35 users of frequency 153.68 MHz and 15 users of frequency 37.46 MHz.
Q.,
In your opinion, will the Emergency Radio System pro-posed by LILCO provide a workable means of communications dur-ing a Shoreham emergency?
A.
No.
LILCO's proposed radio communications system will not provide a workable means of communications for several reasons, relating to the numbers of users per channel, the lack of backup channels, limited broadcast range, and LILCO's use of mobile radios.
Each-of these is discussed below.
A.
?LILCO's Radio Channels Are Overloaded As noted above, three of LILCO's radio channels will be used by the staging area coordinators, the lead traffic guide, the traffic guides, and the transfer point coordinators, which total approximately 160 users.
Under the LILCO Plan, upon no-tification and being told to report, LILCO's traffic guides are expected to go to one of tne three.LILCO staging areas 7
~ _,
m (Patchogue, Riverhead or Port Jefferson) before reporting to their various traffic posts.
Similarly, LILCO's transfer point coordinators are to report to their assigned staging area before reporting to their respective transfer points.
The staging area coordinators are to report to and remain at the
. staging areas.
(See OPIP 3.3.3, Attachment 2; see also OPIP 3.6.3)..
Thus, the users'of each of these three radio channels will be located at the staging area, at one of several transfer points, or at one of approximately 50 traffic posts.
While the staging area. coordinators will lya able to commu-nicate_directly with the EOC via dedicated telephone lines backed up by radio (see Plan, at 3.4-4 and December 22 letter, at 2), LILCO's traffic guides will not communicate directly with the EOC.
Instead, traffic guides will communicate only with one of three lead traffic guides.
Under the LILCO Plan, a lead traffic guide is assigned to each LILCO staging area, and only iead traffic guides or staging area coordinators communi-cate directly~with the EOC.
(See LERO Training Module No. 12,
" Traffic Control," at 14, 25; see also December 22 letter, at 2,-4).
Thus, the EOC would not communicate directly with traf-
- fic guides; instead, communications would be only with the lead traffic guides who would then have to communicate with the traffic guides.
l i L..
r l
l Under the LILCO Plan, there is no provision for regulating or controlling the use of the channels to be used by the staging area coordinators, transfer point coordinators, lead traffic guides, and traffic guides.
Regardless of who controls the channels, however, there will be very real problems.
In-deed, in our. opinion, the use of three radio channels by as many as 160 users is completely unworkable.
Q.
Please explain.
A.
If the entire 10-mile EPZ were tG be evacuated, 193 traffic guides would be expected to man 147 traffic control posts..(See Plan, Appendix A, Figure 8).
Since each traffic control post, but not each traffic guide, would be provided with a mobile radio (see December 22 letter, at 6), each lead traffic guide would have approximately 50 traffic control posts, manned by more than 50 traffic guides, reporting to him.2/ Thus, each lead traffic guide would have to communicate "with and coordinate 50 er more traffic guides.
In addition, the individual traffic guides might also have to communicate 7/
As previously noted, the number of traffic contrel posts / traffic guides for each staging area are as follows:
Port Jefferson staging area - 56 traffic aosts/75 traffic guides; Patchogue staging area - 47 trafNe posts /67 traf-fic guides; Riverhead staging area - 44 traffic posts /51 traffic guides.
(See Plan, Figure 2.1.1; OPIP 3.6.3, At-tachment 4)..
with each other.
Thus, each radio channel would have more than 50 users who would have to be able to talk to each other, just with respect to traffic control functions.
In addition, each of these radio channels would have to be used by a number of transfer point coordinators, as well as the staging area coordinator for each staging area under certain circumstances (for example, as backup to the dedicated telephone lines between the staging areas and the ECC).
One radio channel, when it is used for ' traffic control functions, simply cannot accommodate that much radio traffic.
In addition, the lead traffic guides from each staging area would have to communicate and coordinate with each other, and traffic guides from differenc staging areas might also have to communicate with each other.
Under the LILCO Plan, there is I
no provision at all for such communications because the person-nel assigned to a given staging area will only be able to com-municate on the channel assigned to that staging area.
Their radios will not have the capability of receiving or trans-mitting communications on channels assigned to other staging areas.
Q.
Why does the number of users assigned to LILCO's radio channels make the system unworkable?.
A.
There are several reasons, relating to control of the channels, the nature of the function performed, monitoring capabilities, and practical problems involved in radio usage.
1.
Control of LILCO's Radio Channels Q.
Please explain what you mean by control of the radio I
channels.
A.
There are several ways for a radio system to work.
For example, the users of a channel can be given freedom to
)
l communicate over the radio at will.
Or, the users of a channel l
can be precluded from using the channel except with the permis-sion of the person controlling the channel.
The LILCO Plan does not state whether access to LILCO's channels will be controlled (and, if so, by whom), or whether the users of the channels will be given the authority to use the channels with-out prior permission.
However, as a practical matter, either way would be unworkable.
For example, with respect to LILCO's proposed radio l
system, should only the lead traffic guides be permitted to in-itiate radio conversations, it would be impossible to maintain traffic control or coordination.
If a lead traffic guide were simply to contact one traffic guida af ter another and request status reports, he would have no way of knowing if traffic
.. =
conditions were to change after he had spoken with a particular traffic guide until after he had contacted 50 other traffic guides.
Obviously, such a procedure would be totally unworkable.
l Hcwever, giving as many as 50 traffic guides the freedom to initiate communications anytime they wish to do so would be equally unworkable.
The use of a channel by any one traffic guide would preclude anyone else from using that channel.
Al-though all the traffic guides would be able to hear what was going on, only one would be able to talk at a time.
The limits of LILCO's proposed radio system are obvious, especially when it is considered that, for reporting traffic conditions, in our experience it is realistic to expect 15 minutes or more of conversation from each traffic guide every hour.
(See our dis-cussion in Section 2 immediately below).
For example, for any one of the three LILCO radio channels assigned to LILCO's traf-fic guides, even if every traffic guide had only a little over one minute allotted to him each hour -- and that is really far too little time for traffic control purposes -- there would not be enough time in an hour for every traffic guide to use the channel even a single time.
In sho*t, LILCO has overloaded the radio channels assigned to the staging area coordinators, transfer point coordinators,.
lead traffic guides and traffic guides.
There are simply too many users, and, as a result, communications would be a " hit or miss" proposition.
If communications were initiated by the traffic guides, LILCO's channels would quickly become over-loaded.- If only_the lead traffic guides could initiate commu-nications, the traffic guides would not be able to report on traffic conditions at their respective posts until asked to do so.
Either way, the result would be that nobody would know what was going on, and traffic control or coordination would be impossible.
2.
The Nature of Traffic Control Functions Q.
How does the nature of the functions involved in radio communications relate to the number of users per channel?
A.
For traffic control purposes, there should be a very low number of users per channel, probably no more than five or six.
Moreover, the channel should not be used by persons in-volved in any other function.
There should also be a separate radio channel for use only by the supervisors, o: coordinators, of the personnel involved in the traffic control.
Persons performing traffic functions need to communicate over the radio on a very frequent basis.
Traffic control requires a great deal of communications in order to coordinate,
Everyone must be constantly apprised of the traffic flow.
Based on our experience, in heavy status of everyone else.
traffic control situations, an officer may have to use his In addition, as discussed radio 15 minutes or more per hour.
earlier, the LILCO traffic guides may be initiating One can conversations over the channels assigned to them.
therefore expect communications to be cluttered with such mes-sages as "I need help over here," or "I need a wrecker over here," or "I've got a backup over here."
We would not assign anywhere near 50 officers responsible for performing traffic control functions to a single channel.
in order to en-Traffic control demands so much air time that, sure prompt, adoquate and reliable communications, the police dispatcher would not permit of ficers directing traf fic to stay on a channel with other users, because the channel would be Instead, the traffic offi-tied up with other radio traffic.
Then they cers would be pat on their own dedicated channel.
l would have the necessary air time to communicate effective y without disrupting other police radio traffic or being dis-In such situations, the officers really rupted themselves.
have to talk to one another more than they have to talk to the they have to be able to tell central dispatcher.
For example, to direct traffic elsewhere the officers posted down the street A good case in if traffic conditions dictate that strategy. <
L.
point is the last Shoreham demonstration.
The Department dedicated a single radio channel just for controlling traffic on two-streets adjacent to the site.
Four police officers, for two streets, were given a dedicated channel.
With the congested traffic conditions' brought about by the demonstra-tion, that was necessary.
t.
In short, there'is no single function that generates more radio traffic than vehicular traffic control.
Therefore, the LILCO number of users on a channel must be severely limited.
s cannot expect effective communications with the number of traf-m The nature of traf-fic guides assigned to its radio channels.
fic. control functions simply demands many two-way communica-tions and a very small number of users per channel.
In addition, LILCO's proposed, system assigns users with functions unrelated.to traffic control to the channels used by LILCO's-traffic guides (i.e._, staging area coordinators and transfer point coordinators).
This also undercuts the effec-tiveness of communications over those channels and adds even more users to already overloaded channels.
l Q.
. Do you expect problems to occur because of the number of users assigned to the single channel to be used by LILCO's road crews and evacuation route spotters? 4
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A.
Yes.
Assuming that each road crew (but not each road crew member) and evacuation route spotter will have a mobile radio, there will be approximately 35 users of this channel.
(See above discussion).
That number of users could be a problem, since the nature of the emergency functions to be performed by LILCO's road crews and evacuation route spotters could demand heavy radio use.
For example, the Transportation Support Coordinator at the EOC would have to provide and explain instructions or requests for assistance to the road crews and route spotters.
Moreover, the road r ws ac3 the evacuation route spotters would have to communicate with each other -- for example, to coordinate the removal of obstacles from. roadways (see OPIP 3.6.3, Attachments 2 and 3).
They would'also have to report periodically to the ECC.
(See, e.g.,
OPIP 3.6.3, Attachment 3, which instructs evacuation route spotters to "[c]ontact the Evacuation Route Coordinator at the EOC every 30 minutes via radio" to keep him up-to-date on conditions in the areas surveyed).
Thus, the channel could be-come overloaded, and ccmmunications would then break down.
Given the potential for overload, there is no assurance that LILCO's road crews and evacuation route spotters would be able to communicate effectively.
- 22
3.
Monitoring Functions C.
Please explain how the number of users per channel relates to LILCO's proposal for monitoring the Radio Emergency System channels.
A.
A trained, experienced radio dispatcher can control and monitor as many as two radio channels at a time.
With three channels, however, it becomes unworkable since the dis-patcher needs to be able to near everything being said on the cher,nels assigned to him in order to exercise control ovar the channels.
Nevertheless, under the LILCO Plan, all three channels to be used by the LILCO staging area coordinators, transfer point coordinators, lead traffic guides and traffic guides will be monitored at the EOC.
Although each channel will be separately monitored by the traffic control communicators at the EOC (see December 22 letter, at 5), the Evacuation Coordinator will have to coordinate the information monitored by those communicators.
In addition, the Evacuation Coordinator will have to coordinate the information monitored by the Transportation Support Coordinator with respect to LILCO's road crews and evacuation route spotters.
Thus, the Evacuation Coordinator ultimately has to be aware of the communications taking place on four of LILCO's five channels, which could be used by approximately 250.. -,
emergency workers (staging area coordinators, transfer point coordinators, lead traffic guides, traffic guides, road crews and evacuation route spotters).
Further, what each communica-tor will be monitoring is information reported by the users of each channel.
With over 50 users per channol, the communica-tors at the EOC would be unable to monitor communications ef-fectively because they would be unable to seg track of commu-nications coming from so many separate ind'.<iduals.
4.
Problems With Radio Use Q.
Please explain what you meant by your reference to problems-related to radio use given LILCO's Emergency Radio System.
A.
There are several such problems.
One problem which is certain to occur is that two or more individuals will " key up" their microphones at the same time.
It would then be vir-tually impossible to discern any communications over that radio channel.
Q.
Wnat is meant by " keying up" the microphone at the same time?
A.
" Keying up" is a term used to describe depressing the microphone botton in order to transmit.
When an individual depresses his microphone button while another individual is - -.
~.
already transmitting (e.g.,
because the second person does not listen before he attempts to transmit, or because the person transmitting is not heard by the second person due to limita-tions in broadcast range), the transmitted messages interfere with each other and users of the channel must try to discern one' audio from the other.
Thus, if one of LILCO's traffic guides were to pick up his radio to ttansmit while another traffic guide was already transmitting, the second traffic guide would likely not be able to override the first traffic guide, and instead of hearing just one person, the listener would hear a mix of both voices.
It is similar to two commercial radio programs coming over the radio on the same station.
%e have' audio tape recordings of this phenomenon re-sulting from more than one user keying up at the same time, which illustrate the fact that it is impossible to discern any one communication.E/
Furthermore, even if problems such as " keying up" micro-phones at the same time were addressed in LILCo's communica-tions-training program (and we have no reason to believe that LILCO's training covered this point or that the training 8/
We intend to play these tapes as part of our direct testi-mony.
If any party wishes to obtain a copy of these tapes in advance of the hearing, they should contact counsel for the County.
4 O
offered was adequate (see future Suffolk County testimony concerning Contentions 39-41 and 44.D, E and F where this will I
be addressed)), training will not prevent these problems from occurring.
Even with trained, experienced police officers, radio communications are sometimes disrupted when two officers
" key up" at the same time on the same channel.
Many long hours are spent training police officers who use radios all the time to listen before they key their radio microphones.
The tenden-cy, however, is to pick up the microphone and to' talk.
- Thus, there are times when microphones are going to be " keyed" at the same time.
This also happens by accident, or because a radio 4
user-becomes careless.
For example, it is our experience that 1
radio users frequently pick up their microphones, say.some-thing, and toss the microphone back onto the seat of their cars.
If the microphone lands on its key, and the key remains depressed, communications are shut down on that channel.
There is no doubt that this will happen with LILCO's traffic guides
-- it happens with trained police officers and thus surely will also happen with persons less accustomed to the use of such 1
equipment.. However, the effects of such misuse in a Shoreham emergency could be more severe:
a traffic guide may return to t
his traffic post and, without knowing anything is wrong, he will have knocked out communications for 50 other users since, once the key is.left open, the channel is rendered virtually useless..
)
With as many as 50 individuals on one channel, it is highly unlikely that there will not be times when two or more persons key their microphones at the same time.
It has to be expected in light of the tremendous overload of radio channels by.LILCO.
A second problem relates to the lack of radio discipline that will be maintained by the LILCO emergency personnel using the radio channels comprising LILCO's Emergency Radio System.
-Q.
What do you mean by lack of radio discipline?
A.
[ Police Officer Stile).
Let me respond by way of ex-ample.
Before joining the SCPD, I was engaged in commercial airline radio communications and was an experienced radio oper-ator.
I made my first arrest four weeks after joining the Department.
During the arrest, I got on the radio and began rattling off information that was unnecessary and which, in fact, made no sense.
The sergeant had to order me off the radio.
My experience was a very typical one.
In communicating via radio, people panic, especially when they are not accus-tomed to working with a radio on a daily basis, or under stressful conditions.
They talk too much, trying to report ev-erything that is going on regarding a particular situation.
Training can help, and certainly training is necessary and essential.
But training is not enough.
I had been thoroughly trained in radio communications before this incident.
- However, despite the fact that I was an experienced radio operator and had undergone rigorous SCPD training, the first time I found myself as a police officer in an emergency situation, I just forgot everything I had learned regarding proper radio use.
[All witnesses].
There are police officers with 20 years of police experience who find themselves in an emergency situa-tion, pick up the radio, and talk for a full minute, without even finding out if somebody is listening.
With radio, it is essential that the user keep his conversations short and to the point.
In performing traffic control functions, that is not always possible because the user has to give more detail.
Even if LILCO's traffic guides were 150 of the most qualified, expe-rienced radio operators anywhere, they would not, in our opinion, be able tb communicate properly with only three channels available to them.
Three channels just cannot accom-modate the volume of radio traffic that has to be expected from personnel performing traffic control functions.
B.
LILCO's Proposed Radio System Lacks Backup Channels Q.
Does LILCO's proposed Emergency Radio System have backup channels? -
O a
A.
No.
With the exception of dedicated telephone li,nes between the EOC and the LILCO staging areas, there is no backup means of ccumunications for LILCO's proposed Emergency Radio System.
As previously noted, there are only five radio channels ava'ilable to LILCO and these five er.nnels will not be able to handle adequately the amount of radio traffic antici-pated for an emergency at Shoreham.
(See discussion above).
i Nevertheless, the LILCO Plan has no provision for any backup channels.to the five channels which comprise LILCO's proposed Emergency Radio System.
Moreover, under LILCO's proposed radio
. system, LILCO's emergency response personnel (traffic guides, evacuation route spotters, road crews, etc.) would each be able to use only a single radio channel.
(See Plan, at 3.4-3; see
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.also deposition of William Renz ("Renz deposition"), at 57).
Accordingly, if problems develop on that one channel, communi-cations would be impossible for all emergency personnel assigned to that channel.
In our opinion, this lack of backup poses a substantial problem.
There are just too many ways that a channel can be rendered unusable.
Weather conditions, for example, can total-ly knock out a channel.
As discussed before, a radio micro-I phone can easily.be keyed open, thereby preventing further com-munications over a channel.
There are many different things that can nappen to render.a radio channel. inoperable.
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' ::l 3,. _- _
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Because LILCO's radio system has no backup channels, there is no way to maintain communications in the event a channel be-comes' inoperable.
Moreover, because the LILCO radios are all one channel radios, even if LILCO had backup channels available e
to it (which we understand it does not), they could not be used because the radior are incapable of switching channels.
- Thus, if a channel goes out, there would be no communications of any kind with the emergency response workers assigned to that channel..This failure to provide backup channels, in our
. opinion, makes LILCO's proposed radio system unworkable.
In our opinion, LILCO has ignored the many practical problems which are likely to be caused by the radio communica-tions system described in the LILCO Plan.
LILCO's system might look good on paper, but it could not work.
The gross over-loading of channels is one reason.
The lack of backup channels is=another reason.
Indeed, to our knowledge, there are no backup transmitters.for.the radio channels, no procedures in case a radio becomes inoperable, no spare radios or antennas at
' the staging areas (where mobile radios, under the LILCO Plan, are to be. installed), and no backup generators at the ECC or staging areas or other communications posts.
Thus, the LILCO
. system does not have sufficient equipment; nor does it take ei-ther the expected or the unexpected problems into considera-tion. +
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There is one more crucial deficiency in LILCO's proposed Emergency Radio System, a deficiency which renders LILCO's entire traffic control / emergency response scheme unworkable:
it does.not permit the various emergency workers in the field to communicate with other emergency workers on different radio channels.
It is essential, particularly'for effective traffic control, that LILCO's emergency workers be able to communicate with co-workers having similar or related functions.
For exam-ple, LILCO's traffic guides must be able to communicate infor-mation to other traffic guides in order to coordinate traffic-control strategy.
In our experience as police officers, such direct communication between field officers is absolutely essential if there is to be any potential for effective control.
Because, under the LILCO Plan, traffic guides dis-patched from one staging area cannot communicate with the traf-fic guides from either of the other two staging areas, in our opinion the LILCO Plan is unworkable.
LILCO's traffic guides, however, will not have that capa-bility because they will not have adequate radio equipment or channels.
Moreover, under the LILCO system, there will be no way for different categories of emergency response personnel to communicate with each other in a direct fashion.
(See, e.g.,
Renz deposition, at 52).
For example, should there be a major traffic accident during the time the Shoreham area is being _
evacuated, communications between a road crew (or an evacuation route spotter) and a traffic guide would not be possible.
These workers could only radio the EOC, where the appropriate coordinators could then. talk among themselves.
The coordinators could then radio their respective people in the field.
This kind of process, however, results in tying up an entire radio network just to deal with one problem.
C.
LILCO's Reliance on Mobile Radios Q.
Do you'have any other concerns regarding LILCO's pro-posed Emergency Radio System?
A.
Yes.
Under the LILCO Plan, emergency response per-sonnel will be provided mobile radios.
(See Plan, at 3.4-3).
With mobile radios, communications will only be possible if the field personnel are in their. vehicles.
Thus, emergency re-sponse personnel who have to perform their duties outside a ve-hicle, such as traffic guides, will be without a readily avail-able means of communication.
Moreover, if a traffic guide is posted at an intersection directing traffic, he might not'even hear his radio and, even if he did, he would have to leave his post to get to the radio.
Bus drivers have an even greater problem, since, according to one of LILCO's communications witnesses, they may not have any radio equipment and may there-fore be without any way either to. transmit or to receive
information.
(See Renz deposition, at 71-72).
Moreover, LILCO has no intention of installing radios in the bases relied upon by the L!LCO Plan.
(See Renz deposition, at 70-71).
-In addition, mobiJ e radios operate on battery power, and the vehicles must be run to keep up the battery charge.
In most cases, the vehicles used by LILCO's emergency response personnel would be the personal automobiles of LILCO's employ-ees.
(See, e.g.,
Renz deposition, at 58, 89).
There is no as-surance that these cars will have enough fuel to keep them run-ning while emergency workers, such as the LILCO traffic guides, perform such functions as directing traffic.
D.
Limited Broadcast Range Q.
Does it make a difference that, under LILCO's pro-posed radio system, some emergency response personnel will be using repeater channels while other emergency response person-nel will be using a single VHF channel?
A.
Yes.
Without a repeater system,$/ if those emergency response personnel assigned to the single VHF channel (i.e.,
road crews and evacuation route spotters) had to talk over a mobile radio from, for example, the Riverhead area to the EOC 9/
For an explanation of a repeater system (as compared to a single-frequency (simplex) system), see our testimony con-cerning Contention 26. _
in Brentwood, there would likely be problems.
Ordinarily, persons attempting radio communications between vehicles expe-rience few problems when the vehicles are within three to five miles of each other.
However, terrain can limit broadcast range, and the Shoreham area is a heavily terrained area.
Thus, if two road crews needed to communicate with each other, and one crew were located some distance east of the Shoreham plant and the other were located some distance west of the plant, then, because of the terrain in the area, communications may not be possible.
Q.
What is the range of a mobile radio?
A.
Range depends on the radio's effective power, which is influenced by the radio's wattage and the terrain over which the radio signal is broadcast.
Q.
Would the mobile radios used by LILCO be powerful enough to cover tne entire 10-mile EPZ, absent a repeater system?
A.
No.
The mobile radios that will use LILCO's proposed Emergency Radio System channels range from 25 to 50 watts.
(See letter dated November 1, 1983, from J. Monaghan to M.
Miller (" November 1 letter"), at 3, 5).
Range could therefore be a problem, especially since LILCO will be using each _
i
)
vehicle's cigarette lighter socket to power the mobile radio for that vehicle.
(See videotape script to LILCO training module 8A, " Portable Radio Installation and Operation," at 4-5).
With a cigarette lighter socket, which is only a tempo-rary connection, it is unlikely that a radio will get the full power wattage.
The cigarette lighter hook-up will power the radio, but there may be some loss of power due to a poor con-nection between the radio plug and the lighter socket.
More-over, the antenna systems installed by LILCO on the vehicles of emergency response personnel may not provide full power to the mobile radios used by LILCO personnel, since LILCO int. ends to use gutter clips or magnetic mounts which will be attached to painted surfaces, creating a poor ground.
(See videotape script to LILCO training module 8A, " Portable Radio Installa-tion and Operation," at 3-4).
Q.
Would you expect similar problems with the 1cw band channels (37.62 MHz and 37.46 MHz) which, under LILCO's pro-posed radio system, would be used to provide radio communica-tions between the Riverhead staging area and Riverhead-dispatched traffic guides and transfer point coordinators and between the Ambulance Coordinator at the EOC and ambulance dis-patch locations?
A.
We would expect similar problems with loss of power, since gutter clip antennas or magnetic mounts would he used.
(See videotape script to LILCO training module 8A, " Portable Radio Installation and Operation," at 3-4).
Range may be less of a problem, since a low band channel generally provides better covecage than a VHF channel. - However, low band channels are more susceptible to outside interference.
l Our concerns, however, primarily involve the fact that LILCO has overloaded the channel assigned to LILCO's traffic guides dispatched from the Riverhead staging area (37.62 MHz),
just as it has overloaded the two channels that will be used by LILCO's other traffic guides.
Again, traffic control func-tions, by their very nature, require many two-way conversations and therefore only a very limited number of users should be al-located to a channel used by personnel performing such func-tions.
E.
Problems With Dedicated Telephone Lines Q.
The LILCO Plan describes a number of dedicated tele-phone lines that LILCO expects to be available in an emergency.
(See Plan, at 3.4.3 and 3.4-4).
Are there problems with dedi-cated telephones?
a A.
Yes.
Dedicated telephone lines may be more reliable than regular commercial telephone lines, since they are outside the commercial telephone network and therefore not subject to telephone switching office overload.
However, dedicated lines also fail.
(See Contention 31).
Q.
How do dedicated telephone lines fail?
A.
Dedicated telephone lines are as susceptible to fail-are as are commercial telephone lines.
When a dedicated line is set up, the telephone company runs a telephone wire from point A to point B.
The wire may go through central offices, but, between point A and point B, there are no other users.
In other words, the dedicated circuit is not used by anyone other than the users at point A and point B.
However, there may be stubs coming off that dedicated line.
Stubs are telephone lines that are not used -- for example, lines going out to a telephone pole that dead end.
Such lines may have been used at one time, but, for some reason, they are no longer needed.
These stubs, however, are generally not disconnected from other telephone lines and circuits.
Thus, if a stub line shorts out or is knocked down because of bad weather or for other reasons, the entire circuit, including the dedicated line, could be knocked out.
Problems also occur when the telephone line am-plifiers go down.
For example, between the ECC and Brookhaven,.,
L.
line amplifiers are used to maintain the audio levels.
If these amplifiers go down, there can be no communications over the line.
Problems also occur with line fuses.
For example, the fuses may blow out.
In short, telephone line stubs, ampli-fiers, and fuses could all cause a dedicated line to go down.
Q.
Is a dedicated line just another overhead line?
A.
Yes.
But it is an overhead line using hard wire or microwave.
Nevertheless, dedicated lines are subject to some of the same kinds of problems, such as adverse weather knocking the telephone lines down, experienced by regular, or commercial, telephone. lines.
The SCPD has about 50 dedicated telephone lines.
On the average, about two lines per week are inoperable due to line failures or other problems.
Q.
According to the LILCO Plan (see Plan, at 3.4-5),
LILCO has requested priority service maintenance from the New York Telephone Company.
Does that minimize or lessen your concerns regarding LILCO's reliance on commercial and dedicated
-telephone lines?
i
.A.
No.
First, the LILCO Plan indicates only that the New York Telephone Company will provide priority service main-tenance for service in the EOC.
(See Plan, at 3.4-5; Appendix B, at APP-B-28).
There is no indication that priority service will be provided at other LILCO facilities, such as the Port Jefferson, Patchogue and Fiverhead staging areas, the Emergency News Center
(" ENC") and WALK radio station (see Plan, at 3.4-4) relied upon by LILCO.
Moreover, based on our experience with the New York Tele-phone Company, it is unrealistic for LILCO to assume that mere-ly because of the Telephone Company's letter, service would in fact be promptly restored if there were a problem during a Shoreham emergency.
In most cases, the Telephone Company has not been'able to restore a downed circuit in much less than ap-proximately six hours.
Of course, during an emergency at the Shoreham site, with the heavy telephone use that should be ex-pected, restoration of service could take far longer -- assum-ing that the telephone crews would be villing or able to reach the problem area which, with the highway congestion expected, is itself questionable.
Q.
What, then, does this so-called " priority service" do for LILCO?
A.
Frankly, not much.
Of course, there are some benefits.
For example, if a telephone line were to go down on a weekend, the Telephone Company presumably would not tell LILCO to wait until Monday.
The repair crews would come out over the weekend.
Still, there are limits to what the New York y
v--
Telephone Company will do.
For example, some time ago the SCPD was involved in a search for a six-year old missing child.
The Department has an understanding with the Telephone Company that when an emergency telephone drop is requested, it will be done as quickly as possible.
When searching for a missing child, a telephone drop --
i.e.,
actually dropping a line from an exist-ing line so that telephones can be set up in the field -- is of the highest priority.
Six hours after first requested, how-ever, the Telephone Company still had not sent a crew to drop the line.
The Department called constantly, all day long.
But under the most important of circumstances, despite our long-standing agreement with the Telephone Company, it was still many, many hours before the line drop was accomplished.
So our experience is that even with priority service agreements, there is no guarantee of quick service.
Moreover, even if the Telephone Company does its best to give priority service, problems will occur.
The crew has to respond.
Then they have to determine the cause of the problem.
If the central switching office is the problem, they have to get_into that office.
Often, both ends of the telephone line have to be checked.
This can often take a considerable amount
(
of time.
For example, not long ago one of the telephone lines to a hospital was down for more than a month while the New York Telephone Company was " trouble shooting" the line.
And this --
s line was a priority service line.
Priority service means very little.
In the context of providing.any additional assurance or reliablity during an emergency, it means nothing at all.
V.
Contention 32 -- Lack of Direct Communications C.
Contention 32 alleges that the lack of direct commu-nications between LILCO's traffic guides and transfer point coordinators and the EOC will result in the delay of imple-mentation of emergency actions.
Do you agree with this Conten-tion?
A.
Yes.
The Plan originally contemplated that there would be direct communications between the EOC and all person-nel in the field via LILCO's proposed Emergency Radio System.
LILCO's communications system, however, was modified and now the Plan only provides for direct communications between the EOC and staging areas (via dedicated telephone) and between the EOC and road crews, evacuation route spotters and ambulance dispatch stations (via c'edio).
(See Plan, at 3.4-3 and 3.4-4;
~
see also December' 22 letter, at 3; February 25 letter, at 7).
Direct communications between the EOC and traffic guides and transfer point coordinators, although possible, is not cont'em-plated by.the Plan.
Instead, LILCO proposes to limit direct t
i radio contact to communications between and among the staging area c'oordinators, transfer point coordinators, lead traffic
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guides and traffic guides.
(See above discussion).
Communications from LILCO's craffic guides and transfer point coordinators will be relayed to the EOC by the lead traffic guides or the scaging area coordinators at the staging areas.
(See December 22 letter, at 3, 4).
Because LILCO's traffic guides and transfer point coordinators will not communicate directly with the ECC, there may be some delay in the implementation of emergency actions by these personnel.
For example, should a problem arise in the field requiring a traffic guide to request instructions as to how to proceed, the traffic guide would first have to brief his lead traffic guide on the problem.
The lead traffic guide would then have to brief the staging area coordinator, who might then have to contact the EOC in order to brief appropriate emergency response coordinators at the ECC on the problem.
If the problem is significant, emergency personnel at the EOC may have to confer before responding to the staging area coordinator.
Finally, whatever instructions are given to the staging area coordinator would then have to be relayed to the lead traffic guide and then to the traffic guide.
f Obviously, under this kind of scenario, the lack of direct communications between LILCO's traffic guides and transfer point coordinators and the EOC necessarily results in delays in I l
l
n s
providing information to emergency personnel in the field.
As a result, the implementation of emergency actions may be delayed.
Moreover, delays in implementing emergency actions could also occur should LILCO's emergency response coordinators at the ECC decide to initiate emergency actions requiring some rosponse.by traffic guides and/or transfer point coordinators in the field.
VI.
Contention 34 -- Communications with Hospitals Ambulance Personnel 6
Q.
Contention 34 alleges that the LILCO Plan fails to ensure that there will be adequate communications among hospitals, ambulance personnel and dispatch locations, and other LILCO emergency personnel.
Do you agree with this Contention?
A.
Yes.
The LILCO Plan relies on existing radios in hospitals and in ambulance dispatch locations and vehicles for communications between LILCO command and control personnel and other emergency response personnel and these response l
organizations and their personnel.
(See Plan, at 3.4-3).
This proposal, for several-reasons, provides no assurance that there will be an adequate means of communications between LILCO and hospitals, ambulance dispatch locations and ambulance personnel..
v
w First, LILCO's proposed Emergency Radio System (see Plan, at 3.4-3) uses different radio channels and is therefore not compatible with the radio communications system used in day-to-day operations by hospitals and by ambulance vehicles.
Nor will LILCO have direct access to the radio channels used by hospitals and by ambulance vehicles.
(See Plan, at 3.4-3; see also December 22 letter, at 5).
Although LILCO asserts that one of its radio frequencies will be
" dedicated" to communications between the EOC and ambulance dispatch stations, (see Plan, at 3.4-3), in fact, even assuming that no problems are experienced with communications between the EOC and the dispatch stations, communications between the ECC and the ambulance vehicles would have to be relayed through the dispatch locations.
This may lead to some delays in dispatching the ambulance crews.
In addition, under the LILCO Plan, there is no provision at all for radio communications between the EOC and hospitals.
Instead, LILCO relies only upon commercial telephone lines to communicate with hospitals.
(See Plan, Figure 3.4.1).
The many problems that must be expected with commercial telephone lines in the event of an emergency at the Shoreham plant (see our testimony regarding Contention 26), lead us to conclude that LILCO may be without any means of communications with the hospitals in and around the 10-mile EPZ. '
~
Furthermore, the private ambulance companies relied upon by LILCO do not have the equipment to access the Emergency Medical Services
(" EMS") frequency used by hospitals.
Therefore, LILCO has no means to coordinate ambulance vehicles and personnel with hospitals.
Finally, we understand that LILCO relies upon fire / rescue organizations (i.e.,
fire departments and fire / rescue vehicles) to perform "their normal response functions during an emergency." (Plan, at 2.2-4).
The LILCO Plan, however, provides no means of communicating with either fire departments or fire / rescue persennel in the field.
Thus, there is no basis for LILCO to assume that these organizations and their personnel will perform their " normal response functions" in the event of an emergency at the Shoreham plant.
Certainly, there is no communications link between LILCO and all the fixcd and mobile medical support facilities relied upon by LILCO.
Q.
Does that conclude your testimony?
A.
Yes.