ML20081A793
| ML20081A793 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/02/1984 |
| From: | Herr P, Eric Michel SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20081A747 | List: |
| References | |
| OL-3, NUDOCS 8403060307 | |
| Download: ML20081A793 (49) | |
Text
7 a u ;JDENCE C': qig UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
,84
'm" y '5 AU :g4 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 PHILIP B.
HERR AND CAPTAIN EDWIN J.
MICHEL ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTIONS 67 and 24.I --
EVACUATION OF PERSONS WITHOUT ACCESS TO AUTOMCBILES AND LACK OF AGREEMENTS WITH TRANSFER POINT OWNERS Q.
Please state your names and occupations.
A.
My name is Philip B.
Herr.
I am an Associate Professor of City Planning in the Department of Urban Studies and Planning, Massachusetts Institute of Technology and the principal of Philip B.
Herr and Associates.
A statement of my qualicica-tions is included in my direct testimony regarding Contention 65 - Evacuation Time Estimates, which was already admitted into evidence.
(See Tr. 2909).
My name is Edwin J.
Michel.
I am a Captain assigned as Commanding Officer of the Communications Section, County of Suffolk Police Department.
I was formerly assigned to the 8403060307 840302 PDR ADOCK 05000322 T
r a
Chief Inspector's Office and the Highway Patrol Bureau of the
~
Department.
A statement of my qualifications is included in the direct testimony of the Suffolk County Police Department regarding Contention 65 - Evacuation Time Estimates, which has already been admitted into evidence by the Board.
See Tr.
2260.
Q.
What is the purpose of this testimony?
A.
The purpose of this testimony is to address Contention 67 which pertains to LILCO's inadequate provisions for the evacua-tion of persons (other than handicapped persons, school chil-dren, or persons in special facilities) who do not have access to automobiles.1/
The main part of Contention 67 and its pre-amble read as follows:
Preamble to Contentions 60-83.
10 CFR Section 50.47(a)(1) requires a finding or reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
In addition, 10 CFR Section 50.47(b)(10) requires the development of a range of pro-tective actions for the public; guidelines for the choice of protective actions must be consistent with Federal guidance.
Such guidance includes the Manual of Protective 1/
See Suffolk County Testimony on Contentions 68-73 for a discussion of deficiences in LILCO's proposals for.evacua-tion of schools, hospitals, special facilities, and the j
elderly and handicapped from private residences..
e a
l Action Guides-("PAGs") (EPZ-520/1-75-001),
which sets forth the threshold projected dose levels at which protective actions are to be commenced.
The PAGs are embraced in NUREG 0654, Sections II.J.7 and J.9, and are referenced in the LILCO Plan, at Section 3.6, and OPIP 3.6.1.
NUREG 0654, in Sections II.J.9 and J.10, requires that there be established "a capability for implementing protective measures based upon protective action guides and other criteria."
(Emphasis added).
In Contentions 60-83, Intervenors contend that LILCO's Plan does not provide reason-able assurance that adequ-te protective measures can and will be implemented to protect the population from the potential health hazards of an accident at Shoreham.
Thus, (a) there is no reasonable assurance that the measures proposed in the LILCO Plan would, if taken, provide adequate protection from the potential consequences of an emergency at Shoreham; and (b) there is no reasonable assurance that the pro-posed measures could or would in fact be taken in the event of an emergency.
Contention 67.
LILCO assumes that in the event an evacuation is ordered, most members of the population will attempt to leave using their personal vehicles.
How-ever, a substantial portion of the popula-tion in the EPZ does not own or have access to an automobile.
LILCO proposes that peo-ple who do not have access to an automobile at the time of an evacuation order will be evacuated by buses running special evacua-tion routes, with bus stops purportedly no more than one-half mile from each such person's home.
(Plan at 3.6-6; Appendix A, at III-35 and III-36, IV-76 to IV-163; OPIP 3.6.4).
However, LILCO's proposal cannot be ia.plemented, and LILCO's proposed evacu-ation of people without access to cars.
e a
would not provide adequate protection for such people, because the evacuation would take too long.
As a result of the time necessary to complete the evacuation, persons may be exposed to health-threatening radiation doses.
Thus, the LILCO Plan fails to comply with 10 CFR Sections 50.47(a)(1), 50.47(b)(10) and NUREG 0654 Sections II.J.9 a,nd J.10.
The Contention goes on to list in subparts A, C,
and D specific reasons that LILCO's proposals could not be imple-mented or would result in inadequate protection for the public.
Q.
Do you agree with Contention 67?
A.
[ Herr, Michel]
Yes.
[ Herr)
LILCO's scheme for transporting people without access to automobiles out of the EPZ is flawed because LILCO has not accurately estimated the number of buses required to accommodate those people.
Furthermore, LILCO's time estimates for evacuation of people without access to automobiles are e
flawed because LILCO has failed to account for traf fic conges-tion that will exist in the event of a radiological emergency.
[ Herr, Michel]
Finally, LILCO's newly-designated transfer points are inadequate because they offer no shelter to people who must wait at those transfer points for buses to relocation centers.
Since many transfer points are within the EPZ or near e
a its borders, people required to wait for buses to transport them from transfer points to relocation centers may be subject to radiological exposure as well as exposure to adverse weather.
Contention 67.A Q.
Please state the text of Contention 67.A.
A.
That subpart is as follows:
Contention 67.A.
According to LILCO's estimates, approximately 333 forty-passenger buses are required to transport those able-bodied persons who would need transportation out of the EPZ (see Appendix A,
at IV-74b; OPIP 3.6.4).
In fact, how-ever, LILCO will either need more than 333 buses or those buses will have to make many more runs than anticipated by LILCO because LILCO has substantially underestimated the number of people who will need such trans-po r ta tion.
1.
LILCO underestimates the signifi-cant number of people who belong to households with automobiles, but who may l
not have access to such vehicles because at I
the time of an evacuation order, the vehi-cles are in use by another member of the i
household.
LILCO's proposal for evacuatinc persons without access to transportation 1
must include adequate methods of evacuating the members of vehicle-owning households who may not have access to a car.
LILCO's estimates of the number of buses required do not adequately take cuch people into account.
i l
(
i
m i
s 2.
LILCO's estimates also fail to take into account those persons who rely on public transportation to get into the EPZ but who', in the event of an emergency, may not be able to rely on such means to evacu-ate.
3.
LILCO assumes that its route buses will be filled to 75% capacity; however, there is no basis for this assumption.
In fact, the route bus capacity factors are likely to be significantly lower than 75%,
which will result in a need for many more buses to evacuate people without access to cars.
Q.
Please explain how LILCO has underestimated the number of buses required to evacuate people without automobiles.
A.
[ Herr]
According to LILCO's evacuation scheme, " route buses" are buses which will be dispatched from eleven different
" transfer points" located both inside and outside the EPZ.
The route buses are supposed to travel along predesignated routes
( see Appendix A, Figures 9.1-27.1) to be flagged down by people requiring transportation.
Upon completing its route, the bus returns to its transfer point where evacuees are discharged.
The evacuees are then loaded onto " transfer buses" which take them to relocation centers.
In most cases the route buses make multiple trips.
(See generally Appendix A at IV-73 through IV-74x).
W s
Table XIII of Appendix A, Revision 3 (pages IV-74e through IV-74x) sets out LILCO's estimates of the demand for bus trans-portation out of the EPZ by persons without access to automo-biles.
LILCO's estimates are as follows:
Passenger demand 11,097 persons Route buses 236 buses Transfer buses 97 buses Total 333 buses Route trips 377 trips (Source: Appendix A, Table XIII).
The basis for LILCO's estimates are not described in Ap-pendix A; however, an internal memorandum authored by Reuben Goldblatt of KLD Associates, and dated June 22, 1983, which is hereto, gives some indication of how LILCO reached its estimates.
Note, however, that in June 1983, Mr. Goldblatt estimated that 282 route trips would be needed to evacuate persons without access to cars.
Subsequently, LILCO's estimate of the required number of route trips has been revised upwards
-- from 282 trips to the 377 trips which appears in the latest version of the Plan ( i.e., Revision 3).
t' s
In my opinion, even LILCO's latest estimates are too low.
L An analysis which I have performed, based par tly on LILCO's own information,. indicates that LILCO has underestimated the number of people requiring bus transportation from the EPZ by at least 29 percent and the number of route bus trips required to transport the evacuating public to LILCO's transfer points by at least 31 percent.
Q.
Please explain your analysis.
A.-
[ Herr]
I have identified and examined five components of demand for bus transportation in the event of an evacuation of the entire 10-mile EPZ -- that is, the types of people who would need such transportation.
They are:
1.
Persons in households without a motor vehicle.
2.
Persons in households with one motor vehicle, but where that vehicle is unavailable.
3.
Persons in households with two motor vehicles but where neither vehicle is available.
4.
Persons who entered the EPZ by public transit and will require public transit to depart..
t O
5.
Additional persons counted to allow for uncertainty in these estimates.
Table 1 summarizes the results of my analysis.
Table 1 Demand for Buses Category Persons Route Bus Trips No household vehicle 7,759 268 Single-vehicle household 4,248 146 1
Multi-vehicle household 410 14 Workers using transit 1,920 66 Subtotal 14,337 494 30% contingency 4,301 148 i
Total 18,638 643 A comparison of the results of my analysis with LILCO's estimate is set forth in Table 2 which follows:
l l
l l
l l
e
. Table 2 Category Persons Route Bus Trips LILCO estimate-11,097 377 4
LILCO shortfall v. subtotal 3,240 117 Shortfal1~% of LILCO estimate 29 31 LILCO shortfall v.
total 7,541 266 Shortfall % of,LILCO estimate 68 70 4
-Q.
How did you calculate the demand for buses for each of the 4
five components listed in Table l?
Households Without Autos A.
(Herr]
The largest element of the population requiring bus transportation out of the EPZ is households with no vehicle I
available to them.
I performed a series of calculations to ar-rive at an estimate of the number of route bus trips that would be necessary to evacuate persons in this category.
First, I calculated the number of households in the EPZ by
. dividing the total EPZ population (157,601) assumed in the Goldblatt memo (Attachment 1 at 1) by the number of persons per household derived from 1980 U.S. Census data.2/
Then, using 2/
Here and elsewhere in the analysis, we have used U.S.
Census data whenever possible since they are based on the
( Footnote cont'd next page) i j [
.- ~
~
. a the percent of households having no access to automobiles (6.4) from 1980 U.S.
census figures, I calculated the " dependent pop-ulation" -- or how many people wculd be without cars -- by mul-tiplying the number of households without cars by 2.5.
as esti-mated.by LILCO.
It represents the average number of persons in households without access to automobiles and is based on the i
results of a telephone survey conducted by the National Center p
for-Telephone Research (hereinafter NCTR survey) for LILCO's consultant KLD.
(See Attachment 1 at 1).3/
Finally, I calcu-i lated the number of 40-passenger bus trips required to accommo-date this portion of the " dependent population" by dividing the dependent population result by an average loading factor of 29 f
( Footnote cont'd from previous page) i largest possible sample.
Because there are no census data for the EPZ as an entity, we have examined the town of Brookhaven and Suf folk County figures, and chosen interme-diate figures.
The disparities between Brookhaven and
~
Suffolk County figures were in no case more than 6 i
percent, reinforcing the validity of approximating the i
characteristics of the EPZ by use of data from two areas, i
one larger than and including the EPZ, the c.ther smaller than and largely included within the EPZ.
For example, Brookhaven was reported by the Census to have 3.26 persons i
per household, Suffolk County, 3.25 3/
Using a person / household figure for households without autos (2.5) that is-lower than the community average for all households (3.5) is, consistent with findings of other surveys, reflecting, among other things, the high inci-l dence of' elderly in this category.
,,.m
persons per bus trip.
The 29 persons per bus trip loading factor was chosen because it is the actual loading rate result-ing from the LILCO scheme as summarized in Table XIII of Appen-dix A, reflecting an optimistic estimate of actual bus utilization.
The results of my analysis of the number of route bus trips necessary to evacuate persons in households without auto-mobiles are summarized in Table 3 below:
Table 3 No-Auto Household Analysis EPZ households 48,493 Percent no vehicle available 6.4 Dependent population 7,759 Total trips needed ac 29/ bus 268 Single Auto Households In some cases, it can be expected that while a household may have an automobile, that automobile may be in use and not available for evacuation purposes.
I estimated the route bus demand generated by this portion of the population by another series of calculations.
First I calculated the number of single-auto households in the EPZ by applying the percentage of r
E a
single-auto households (34%) from 1980 U.S.
Census data, to the number of households derived from LILCO's figures.
Using LILCO's estimate of the percentage of commuter households in the EPZ (83%), based on the NCTR survey, I calculated the number of single auto commuter households (83 percent of 34 percent).
Then, I calculated the dependent population by mul-tiplying the number of single auto commuter households by the number of persons per household of that type (3.5) as estimated by LILCO (unavailable in U.S.
Census data), minus one.
One was subtracted from the average number of persons / household to account for the one memoer of the household who is with the au-temobile and therefore not with the household.
The results of that analysis of the number of persons in single auto households potentially without access to cars are summarized in Table 4 which follows:
Table 4 Single-auto household analysis Percent single-auto households 34 Single-auto households 16,487 Perent commuter households 83 Single auto commuter household 13,684 Dependent population 34,212 The number of bus trips required to accomodate a portion of this segment of the EPZ population is based on the distribution explained below.
The doldblatt memo indicates that LILCO did attempt to account for single auto families who, for whatever reason, may not have access to their automobiles, but did so only to a very limited extent.
Based on the NOTR survey, LILCO determined that 7 percent of the commuters within the EPZ must travel 60 minutes or more to get to work.
LILCO arbitrarily assumed that none of the automobiles driven by such comsuters would be available to assist a household in an evacuation, but that 100 percent of the automobiles from the EPZ commuting less than 50 minutes would be available.
(Attachment 1 at 2).
- Thus, LILCO's distribution for single-auto households requiring transportation assistance looks like this.4/
4/
Note that estimates made'by LILCO subsequent to the Goldblatt memo were even more restrictive, assuming that
( Footnote cont'd next page)
\\
Table 5 LILCO Distribution -- Single-Auto Households.
Travel.
Percent Percent no No. need Joint time Commuters car avail.
help percent less than or equal to 5 10.1 0
0 0.00 6-10 11.8 0
0 0.00 11-15 12.9 0
0 0.00 16-20 15.4 0
0 0.00 21-25 6.9 0
0 0.00 26-30 13.5 0
0 0.00 31-45 13.2 0
0 0.00 46-60 9.2 0
0 0.00 61-90 4.6 100 1574 4.60 greater than 90 2.4 100 821 2.40 Total 100 2395 7.00 (Source: ).
In my opinion, LILCO's assumptions, as reflected in Table 5, are not realistic.
Rather, it must be assumed that a per-centage of the automobiles belonging to single-auto households will not be available for evacuation even though the commuting (Footnote cont'd from previous page) only communters with 75 minute or longer commutes would fail to return to unite with families.
(See Joint Attach-ment to the Testimony of Matthew C. Cordaro, John A.
Weismantle, and Edward B.
Lieberman on Behalf of Long Is-land _ Lighting Company on Phase II Emergency Planning Con-tentions 65 and 23.C.,
D.,
and H., 0 at 4).
l time for the commuter in that household may be less than 60 minutes.
Some cars may be inoperative, or under repair.
Some drivers may be on a trip of longer-than-usual distance.
As commuting distance increases, an increasing percentage of driv-ers will judge it imprudent or impractical to attempt to return home.
Thus, the following Table 6 depicts a more realistic distribution:
Table 6 More Realistic Distribution -- Single-Auto Households.
Travel Petcent Percent no No, need Joint time Commuters car avail.
help percent less than or equal to 5 9.5 1
33 0.10 6-10 11.1 1
38 0.11 11-15 12.2 1
42 0.12 16-20 14.5 2
99 0.29 21-25 6.5 3
67 0.20 26-30 12.7 6
261 0.76 31-45 12.4 12 509 1.49 46-60 8.7 25 744 2.18 61-90 4.3 100 1471 4.30 greator than 90 2.3 100 787 2.30 Don' t know 5.8 10 198 0.58 Total 100 4248 12.42 Total trips needed at 29/ bus 146 Thus, 146 bus trips are required to accommodate this por-tion of the public.
l,
l l
l' Two-Auto Households In some cases, it will also be true that while a household may own two automobiles, both automobiles will be unavailable.
While the percentage of two-auto households affected will be small, the absolute ntaber of persons who may be affected is significant.
The results of the analysis for this portion of the population are summarized as follows:
s I -
Table 7 Two Auto Households i
Percent two-auto households 44 Two-auto households 21,337 Non-user population 44,274 Travel Percent Percent nc No. need time Commuters car avail.
help less than or equal
-to 5 9.5 0.12 5
6-10 11.1 0.12 6
11-15 12.2 0.12 7
16-20 14.5 0.25 16 21-25 6.5 0.37 11 l
26-30 12.7 0.75 42 31-45 12.4 1.49 82 i
46-60 8.7 3.10 120 61-90 4.3 12.42 236 greater than 90 2.3 12.42 126 Don't know
- 5. 8 -
1.24 32 Depend. pop.
100 Total trips needed at 29/ bus 14 As above, the percentage of two auto households is from the 1980 U.S.
Census, the number of households is from the LILCO population estimate and the census population per household.
Non-user population "left behind" per household was estimated at 1.5 persons, reflecting 2 drivers away from the household.
The figures in the column of Table 7 marked
" Percent no car available" are equal to 12.4 percent of the same column in Table 5.
The basis for this distribution is that Table 6 shows there is a 12.4 percent chance that the first car in the household will not be available, and it is as-sumed that the distribution of the availability of the second car is also 12.4 percent. 'Thus, both cars would not be avail-able to 12.4 percent x 12.4 percent, or 1.53 percent, of the households in the EPZ owning two automobiles.
As Table 7 dem-onstrates, this portion of the population will require an addi-tional 14 bus trips.
Transit-Dependent Workers As subpar t 2 of Contention 67. A observes, LILCO has failed in its estimates to account for people who commute into the EPZ by bus and therefore will be dependent upon bus transportation to get out of the EPZ.
The needs of transit-dependent workers are summarized in Table 8 below: I l
l
e Table 8 Transit-Dependent Workers Jobs located in EPZ 49,000 Percent transit commuters 3.9 Number transit commuters 1,920 Total trips needed at 29/ bus 66 The number of jobs located within the EPZ is estimated from 1980 U.S.
Census data on the percentagm of Suffolk County population in the work force (45%), times LILCO's estimated EPZ
-population (157,601), times the percentage, from 1980 U.S.
census data, of Suffolk County residents working in Suffolk County.
The estimated percentage of transit-dependent com-muters (3.9) was set at 80 percent of the figure from LILCO's NCTR survey, reflecting judgment of the differential between transit dependency of resident commuters ( the NCTR universe) and of those who work within the EPZ.
As shown in Table 8, 66 l
additional bus trips are required to evacuate the l
transit-dependent population.
30 Percent Adjustment Factor l
l l
Going back to Table 1, it can be seen that my analysis, using the four demand factors analyzed above, shows a demand for buses by 14,337 persons who will require 494 bus trips to
- i 1
.o accommodate.them all.
The-number of persons estimated to require transportation is 29 percent more than LILCO has esti-mated (11,097)'and the number of trips required is 31 percent more than LILCO's estimate (377).
Mr. Goldblatt's June 22, 1983 memo suggests, however, that demand estimates should be increased by 30 percent to account for uncertainties.
(Attach-ment 1 at 3).
Presumably, LILCO's estimates in Appendix A are based on such an uncertainty factor.
If the 30 percent uncer-tainty factor is meant to account for segments of the popula-
' tion I have analyzed, then it is justifiable, for purposes of comparison to LILCO's calculations, to apply that factor to my own estimates.
Applying the 30 percent uncertainty factor to my estimates shows a total demand of 18,638 persons within the EPZ, or 68 percent more-people than LILCO's estimate of 11,097.
This.will require 643 bus trips -- 70 percent more than LILCO has estimated.
Q.
How many buses will LILCO therefore require to complete the 643 bus trips?
A.
(Herr]'
Using the information presented in Table XIII of Appendix A, I have calculated that LILCO's scheme involves 1.6 route trips per bus.
At that rate, 643 route trips will require 402 route busec, not the 236 route buses estimated by - - - - - -
0 P
LILCo.
If the 30 percent uncertainty factor is not applied, then the 541 route bus trips I have estimated absent that figure will tequire 309, rather than 236 route busec.
Q.
What is the significance of LILCO's underestimation of the demand for transportation from the EPZ?
A.
[ Herr]
It is essential that estimates of bus requirements for an evacuation not be too low.
If anything, they should err on the high side to assure adequate capacity.
Clearly, LILCO's estimates provide no assurance of adequacy.
The consequence of its underestimation would be that there would not be enough buses available to provide timely evacuation of people without access to automobiles in the event of an emergency at Shoreham requiring evacuation.
Contention 67.C and 67.D
=
Q.
Please state Contentions 67.C and 67.D.
A.
[ Herr, Michel]
Those contentions state:
Contention 67.C.
The staggered departures and multiple bus runs necessary under LILCO's plan to evacuate the people in-each zone (Appendix A, at IV-76 to IV-163; OPIP 3.6.4, at 11-32), even using LILCO's estimates of the number of people likely to need such evacuation, will result in evacu-ation travel times f ar longer than those set forth in Appendix A at V-8a. l
1 o
l Specifically, the LILCO Plan provides that the bus routes will terminate at designated
" transfer points" with each bus in many cases required to make more than one run.
As noted in Contention 67.D, several transfer points are in the EPZ.
Transfer buses will transport the evacuees from the-transfer point to relocation centers.
LILCO's estimated route times begin and end with the assumed transfer points.
(See Ap-pendix A, at IV-76 to IV-163; V-Ba; OPIP 3.6.4).
LILCO's estimated evacuation times, however, assume that route buses will be dispatched from transfer points and return to the transfer points at specific intervals (or " headways") and that there will be.little or no waiting at the transfer points for buses to the relocation centers.
Furthermore, the last transfer buses are assumed to clear the EPZ 15 minutes af ter leaving the transfer points.
(Appendix A at V-7).
These assumptions are erroneous, however, since they do not consider the severe traffic congestion that will exist, for reasons set forth in Con-tention 65 at'the same time that the route and transfer buses are attempting to make their trips.
Thus, the route times for each route bus will be longer than estimat-ed by LILCO.
In addition, it is likely to take'far longer than 15 minutes for the last transfer buses to clear the EPZ after leaving the transfer points.
Contention 67.D.
The eleven.new transfer points designated by LILCO do not appear to have adequate structures which could provide shelter from adverse radiological or weather conditions for evacuees while they are waiting to be transferred to relo-cation centers.
Furthermore, four of the eleven transfer points are inside the EPZ and. one is,on the EPZ boundary.
In addition, of the remaining six transfer points, three are located approximately one-half mile or less beyond the EPZ bound-ary, one is approximately one mile from the,
- m..,.....,. _. _. -. _ _, -.
a a
BPZ boundary and two are approximately two and-a half miles beyond the boundary.
Under the LILCO Plan, people are likely to I
be kept waiting for substantial time periods because of delays, congestion, etc., before they are transported from transfer points to relocation centers.
Leaving people at the eight transfer points within or very close to the EPZ will not provide protection for them.
Leaving them at the other three transfer points, all less than five miles beyond the EPZ bound-ary, conflicts with the intent of NUREG 0654,Section II.J.10.h, and could result
'in these people also receiving nealth-threatening radiation doses.
Q.
What is the concern behind Contention 67.C?
A.
[ Herr]
As stated above, LILCO's evacuation times for peo-ple without cars are based on che assumption that buses will be dispatched from and returned to " transfer points" at specified intervals (or " headways") and that, once arriving at a transfer point, there will be almost no waiting for transfer buses to i
take people to relocation centers. Table XIII of Appendix A sets out the schedule of runs for all of the route and transfer buses expected by LILCO to service the EPZ.
The concern expressed in Contention 67.C is that while on paper LILCO's intricate scheme may appear reasonable and practical, in reality LILCO would confront conditions that would render its dispatching and routing schedules useless and its estimates inaccurate.
Major impediments to the effective -
operation of the bus scheme include problems involved in mobilizing buses and bus drivers which, as noted in the testi-mony of the Suffolk County Police Department on Contention 67, is likely to take hours longer than the 120 minutes LILCO estimates.
( Appendix A at IV-74b).
Furthermore, the route buses and-transfer buses traveling through the EPZ-would en-counter severe traffic congestion as described in the County's testimony on Contention 65.
These conditions would not only delay the buses and increase evacuation times, but, further, would prevent the buses from traveling their routes at regular-ly staggered intervals.
As a result, people will be left standing along bus routes and at transfer points for substantial periods of time, thus risking greater radiological exposure in the event of an accident'at Shoreham.
[ Herr, Michel]
A related concern is expressed in Conten-tion 67.D.
In Revision 3 of its Plan, LILCO substituted eleven new transfer points for the twelve transfer points proposed in previous Revisions.5/
The new transfer points are:
5/
The transfer points that had been proposed by LILCO in all its previous versions of the Plan were school buildings.
The change was apparently necessitated by LILCO's realiza-tion that as stated in the original version of Contention 24.I, LILCO had no agreements with the appropriate school officials authorizing LILCO to use the buildings.
See also discussion below of Contention 24.I with respect LILCO's new proposed transfer points. -. -
Distance from Transfer Point Location SNPS (miles)__
Brookhaven' National Lab William Floyd Pkwy.
7 (71sitor's Center)
Miller Place Road LILCO Right-of-Way (ROW) 6 North of Rt. 25A Middle Island Shopping Rt. 25 and Middle Island 7
Center Road LILCO Brookhaven North of the LIE off 7
Substation Weeks Ave.
Coram Drive-In Middle Country Rd.
10
& Rt. 112 LILCO Property Be tween Norwood Ave. &
10 Nesconset Hwy., west of Terryville Rd.
North Bellport Restaurant Bellport Ave., southwest 13 of Sunrise Hwy.
Shirley Drive-In Montauk Hwy. east of 11 William Floyd Pkwy.
Eastport Substation Rt. 27A in Eastport 11 Warehouse Doctors Path & Old 12 Country Rd.
North Patchogue Substation Medford Avo.
14
+
These transfer points are plotted on the map which is Attach-ment 2 to this testimony.
As is evident from reviewing Attach-ment 2, several of the transfer points are in or very near the EPZ.
Yet, most of the transfer points are open areas, which afford no shelter (either from radiological exposure or inclem-ent weather) to evacuees waiting to be transfered to relocation centers.
(Michel]
I personally supervised the taking of aerial photographs of some of LILCO's transfer points on February 1, 1984.
Those photographs are Attachments 3-8 to this testimony.
[ Herr, Michel]
As Attachments 3-8 show, many of LILCO's transfer points do not have buildings or shelters capable of accommodating the hundreds or thousands of people expected at each transfer point.
Note, for instance, that the transfer points located at LILCO's right of way at Miller Place Road (Attachment 3), the Brookhaven Substation (Attachment 4) and Norwood Avenue (Attachment 6) have no buildings available for J
shelter.
LILCO estimates that these transfer points will be handling 2037, 410 and 1768 evacuees, respectively.
(Appendix A at IV-74g).
furthermore, the transfer points at the Shirley and Coram Drive-Ins (Attachments 5 and 7) offer no shelter 26 -
a other than the small refreshment stands located in the middle of each location.
LILCO estimates that the Shirley Drive-In will, handle 1484 evacuees while the Coram Drive-In will handle 2030 evacuees.
As displayed in Attachment 2, two of the above five locations ( the Miller Place Road right of way and the Brookhaven Substation) are within the EPZ and the other three are on or just outside the EPZ boundary.
As a result, many people will be forced to wait within or near the EPZ for pro-longed periods, without adequate shelter from either radio-logical contamination or inclement weather.
Likewise, it should be noted that many of the new transfer points are unpaved including the LILCO right of way at Miller Place Road (Attachment 3), the Brookhaven Substation (Attach-ment 4), the LILCO property off Norwood Avenue (Attachment 6),
and the warehouse located at Doctors Path (Attachment 8).
This is relevant with respect to the concern about delays raised in Contention 67.C since, in inclement weather, these transfer points would become extremely muddy.
Buses stuck in the mud would obviously delay evacuation times and increase the pub-lic's risk of exposure to health-threatening doses of radia-tion.
i _._
e Contention 24.I,.
Q.
What is the concern expressed in Contention 24.I?
A.
[ Herr]
In essence, Contention 24,I. alleges that LILCO has no agreements with the owners of the non-LILCO property which LILCO's Plan proposed for bus transfer points.
Q.
Do you agree with Contention 24.I?
A.
[ Herr]
Yes.
There are at least fivo bus transfer points for which there is no evidence of ownership by LILCO.
They are Brookhaven National Lab, the Middle Island Shopping Center, the Coran Drive-In, the Shirley Drive-In, and the North Bellport Restaurant.
Also, we are at this time unsure of the ownership of the warehouse located at Doctor's Path and Old Country Road.
LILCO's Plan does not contain agreements with any owners of these properties to use those properties during a radiological emergency.
Therefore, there is no assurance that those transfer points will be available to LILCO in the event of an accident at Shoreham.
Q.
Please summarize your testimony.
A.
[ Herr] LILCO has substantially underestimated the number of buses that would be required to evacuate people who will not l
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have access to automobiles during a radiological emergency.
Furthermore, LILCO's evacuation time estimates for people with-out access to automobiles are too low because, under the conditions that would exist in an emergency, the buses LILCO expects to be driving routes and transfering evacuees to relo-cation centers would be delayed by long mobilization times and heavy traffic congestion.
As a result, people would be left waiting for route buses or transfer buses for long periods of time, thus increasing their chances of being exposed to health-threatening doscs of radiation.
Also, LILCO has no agreements with any of the owners of the non-LILCO properties which LILCO's Plan proposes to use as transfer points.
[ Herr, Michel]
Finally, it is clear from Attachments 3-8 that many of LILCO'c transfer points offer no shelter to the public and, with many of the transfer points being in or very close to the EPZ, the public's chances of being exposed to health-threatening doses of radiation would be substantially l
l increased.
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ATTACIDENT 1 1
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ATTACHMENT 1 Memo to Jcb 166 file From:
R.
Goldblatt Date:
June 22, 1983 Topic:
Analysis of bus requirements for the Shoreham EPZ Table 1 presents a summary of the bus requirements detailed in Appendix A of the SNPS Offsite Radiclogical Emergency Res-ponse Plan.
This table indicates that 285 buses are needed to transport 8,500 people out of the EPZ.
This estimate does not include institutionalized personnel.
This astimate yields a bus occupancy of 30 people / bus.
The survey, performed by the National Center for Telephone Research, for KLD in late 1982 can be used to estimate the num-ber of people requiring bus service.
Assumption:
The number of people to be serviced consists of two groups:
(a) those households without access to a private auto who are not transported in their neighbor's vehicles (b) those households, having private autos which are not available due to their use by commuters.
The survey indicated the following:
(a)
Four percent of households within the Shoreham EPZ
(
do not have access to a vehicle.
No. of people = (.04) 2.5 people / house-3.5 e
u
.old 4500 people
=
(b)
In some households with access to vehicles, the number
(
of persons who commute to work / school by private vehicle is equal to the number of vehicles available.
Thus, during the day, those persons remaining at home (or children in school) do not have access to a vehicle.
For such cases, when one or more of these commuters can return home within a reasonable time during an emergency, then a vehicle would be made available to the family group.
If, however, the commuting trip (s) w-
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e time is longer than some reascoable threshold, then it must be [ conservatively) ast,umed that those family members left at home must use bus transit for evacuation.
To compile an estimate of these people who will require transit service, we first identify the distribution of commuter travel times:
Travel Percent of Cumulative Percent Times (min)
Commuters From Survey Normalized
<5 9.5 9.5 10.1
~
6-10 11.1 20.6 21.9 11-15 12.2 32.8 34.8 16-20 14.5 47.3 50.2 21-25 6.5 53.8 57.1 26-30 12.7 66.5 70.6 31-45 12.4 78.9 83.8 46-60 8.7 87.6 93.0 61-90 4.3 91.9 97.6
>90 2.3 94.2 100.0 Don't know 5.8 100.O As indicated, commuters from 7 percent of all house-holds, travel for more than 60 minutes.
Our survey indicates that approximately 78 percent of all house-holds have access to two or more vehicles.
I We can new calculate the number of people who will require transit service:
[
commueer \\ x persons 0.07 x 45,000 households 3,3
_1 household householdj x 0.22'#
1,73'2 persons requiring transit.
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We will round this figure up to 2,000 (c)
Conservatively, we cannot assume that all evacuating buses will be filled to capacity.
Such an assumption implies that a perfect match between bus capacity and demand for service; such an idealistic assumption is not warranted in our opinion.
Therefore, we will assert a 75 percent load factor.
a.
A To account for the uncertainty in these estimates of transit-dependent persons, we will expand these estimates 30 percent.
Siter crv Based on the foregoing development, the number of buses that must be provided is:
1.3 (4500 + 2000) persons
= 282 40 person / us x 3/4 load factor b
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Table 1.
Summary bus data by EPZ zone People Number Route Total needing Bus of Run time Zone Population buses routes buses headway (hrsmin)
A 5,419 338 1
9 10 min 1:02 3
3,750 300 1
8 10 min 351 C
5,296 276 1
3 30 min 358 2
4 20 min 1:13 D
- 609, 29 1
1 20 min 1:16 E
4,895 280 1
7 10 min 1:03 F
29,034 217 1A,B 6
10,10 1:11,1:05 427 2A,B 11 10,10 1:01,1:04 404 3
10 10 337 419 4
11 10
- 29 254 5
7 10
- 41 G
8,343 627 1
16 20 240 2
20
- 36
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3 20 1:19 4
20 1:04 E
2,139 121 1
3 30 1:09 I
1,648 116 1
3 30 1:48 2
1:18 J
4,615 173 1
5 20 1:18 K
40,'605 1;382 1A,B 35 10,10 1:38,1:04 652 2
17 10 1:15 716 3
18 10 1:00 221 4
6 10 1:05 223 5
6 10 1:12 L
7,223 526 1
13 20 1:07 2
20 1:24 3
20
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7,593 559
'l 14 20 1:39 2
10 1:03 J
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Table 1.
Summary bus data by EPZ zone (concluded)
People Number Route Total needing Bs of Run time Zone Population buses ro tes buses headway (hr: min) 7 N
11,543 915 1
23 10 min
- 52 2
10 1:24 0
5,037 347 1
9 30
- 57 2
30 1:32 3
30 1:25 P
5,512 265 1
7 30 1:05 2
30 1:19 3
30
- 58 Q
7,930 608 1
15 10
- 36 2
10
- 25 R
6,905 552 1
14 30 1:00 2
10 1:08 5
1,'863 137 1
4,
-20 340 Totals 159,959 11,084 285
= 7% overall August 4, 1983 - Note -
As a result of continued analysis the numbers of buses, and route times have been modified and the results appear as revisions to Appendix A.
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North Patchoque Substation ATTACllNENT 2
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