ML20081A798
| ML20081A798 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/02/1984 |
| From: | Harris D, Mayer M SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20081A747 | List: |
| References | |
| NUDOCS 8403060310 | |
| Download: ML20081A798 (33) | |
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UNITED STATES OF AMFPICA NUCLEAP REGULATORY CCMMISSION Before the Atomic Safety and Licensing Poard
)
In the Matter of
)
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LONG ISLAND LIGHTING COf'PANY
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Docket Po. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
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DIRECT TESTIMONY OF DAVID BARRIS AND MAPTIN MAYEF ON BEHALF OF SUFFOLF COUNTY PEGARDING CONTENTIONS 24.G, 24.F, 24.P, 73 and 75.
I INTPODUCTION O.
Please state your names and positions.
A.
My name is David Harris.
I am the Commissioner of Health Services for Suffolk County, New York.
My name is Martin Mayer.
I am the Deputy Director of the Division of Patient Care Services in the Suffolk County Department of Health Services.
Q.
Please summarize briefly your professional backgrounds.
A.
(Farris) I have been Commissioner of the Suffolk County Department of Fealth Services since 1977.
From 1975 to 1977, I B403060310 840302 PDR ADOCK 05000322 T
was Deputy Commissioner of Fealth Services for Suffolk County.
I was Associate Director of the Pt. Sinai Hospital from 1971 to 1975, and prior to that I was associated with the Few York City Department of Fealth where I was Deputy Commissioner of Fealth from 1969 to 1971.
I am board certified in the medical specialties of a
pedi 6 trice and preventive medicine.
I am also Professor of Community and Preventive Medicine and Pediatrics, State Univer-sity of New York at Stony Brook.
In addition, I hold academic appointments at the Columbia University School of Public Health, at the New School for Social Research in New York City and at C.W.
Post.
I am a member of the New York State Advis-ory Council on Substance Abuse, a member of the New York State Mental Hygiene Planning Council, and the immediate past president of the New York State Public Fealth Association.
A copy of ny professional qualifications was attached to my tes-l timony on Contention 25 and was admitted into evidence in this proceeding.
See Tr. 1218.
(Payer)
A copy of my professional qualifications is At-techment ] bereto.
O.
What is the purpose of this testimony?
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(Farris, Mayer)
The purpose of this testimony is to address Emergency Planning Contentions 24.G, 24.K, 24.P, 73 and 75.
All the testiony which follows is jointly sponsored by both of us.
O.
Pave you reviewed the LILCO Transition Plan?
A.
We have reviewed, among others, those portions of the LILCO Plan that concern relocation centers and proposed protec-tive actions for the bomebound.
O.
What is your opinion of those provisions?
A.
In our opinion, those provisions are unworkable for the reasons stated in the contentions addressed by this testimony.
II CONTENTIONS 24.G, 24.F AFD 24.P - LACK OF AGREEMENTS 0
Are you familiar with Contentions 24.G, 24.K and 24.N?
A.
Yes.
O.
to you agree with those Contentions?
i A.
Yes we do.
The LILCO Plan relies on the services of numerous non-LILCO organizations and individuals for imple-mentation of its evacuation proposals.
In order to prepare 1 i
patients and move patients and the homebound, and to Care for those individuals in transit, LILCO needs the services of ambu-lance companies, their personnel, and additional medical or paramedical personnel.
Further, without the services of the American Red Cross ("APC"), LILCO's proposed relocation centers could not function.
Despite their importance, however, LILCO does not have the agreements necessary to assure implementation of these essential aspects of its Plan.
O.
In your opinion are such agreements necessary?
A.
Yes.
We are aware of no requirement that ambulance companies, their employees, or medical or paramedical personnel cooperate with LILCO in the event of a Shoreham accident.
Therefore their participation must be assured.
In our opinion, agreements of proper scope and detail are the best -- and possibly the only -
way to obtain such assurance.
O.
Please state Contention 24.G.
A.
Contention 24.G is as follows:
Contention 24 LILCO has failed to obtain agreements from several of the orga-nizations, entities and individuals for performance of services required as part of the offsite response to an emergency pursu-ant to NUPEG 0654, as follows:
Contention 24.G.
According to LILCO's
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A estimates (see Appendix A, at IV-175), it will require sufficient ambulances to make 113 ambulance trips and -enough ambulettes to make 209 trips in order to evacuate the nursing and adult homes located in the EPZ and the homebound who reside in the EPZ.
An additional number of ambulances and ambulettes will be required to evacuate the approximately 630 patients likely to be in the hospitals within (and just outside) the EPZ.
(See Appendix A,
at IV-172; OPIP 3.6.5.)
However, LILCO has no agreements with ambulance companies to provide such eculpment in such quantities.
(See FEMA Peport at 10. )
Even the letters of intent to enter into such agreements which are contained in Appendix B do not relate to numbers of ambulances and ambulettes neces.
sary to meet LILCC's own estimates.
In the absence of such agreements, LILCO's pro-posed evacuation of persons in special facilities, hospitals, and the handicapped cannot and will not be implemented.
0.-
What is the status of LILCO's attempts to.obtain agree-ments with ambulance companies?
A.
The County received on February 15, 1984, copies of agree-ments between LILCO and some ambulance companies.
Those agree-ments are not contained in the Plan, however, and as to several of the ambulance companies upon which LILCO apparently relies, there exist only letters of intent to enter into agreements in the unspecified future, as Contention 24.G states.
Further-more, in our opinion, neither the agreements (which are not in the Plan), nor the letters of intent which are in the Plan, provide the necessary assurance that LILCO's proposals for evacuating special facilities and the homebound could or would be implemented.
O.
Why not?
A.
LILCO does not have agreements involving a sufficient number of ambulances.
On page IV-175 of Appendix A, LILCO estimates that it would take 113 ambulance trips and 209 ambulette trips to evacuate the nursing and adult homes and a portion of the homebound handicapped in the EPZ.
The agree-ments that LILCO has obtained provide for only 45 ambulances and 106 ambulettes.
It is not clear from the Plan whether LILCO assumes that ambulances and ambulettes make more than one trip during an evacuation.
Its time estimates suggest that only one trip is made per ambulance.
LILCO has agreements relating to roughly half the ambulances and ambulettes it estimates would be needed if each made only one trip.
An as-sumption that a timely evacuation could be conducted if more than one trip were required in light of the time necessary for notification, mobilization and transporting patients to receiving hospitals which (although not identified by LILCO) are likely to be far away from the EPZ, would be unrealistic.
In addition, LILCO's estimates of how many ambulance and ambulette trips would be necessary in an evacuation are unrealistically low for two reasons. __
First, the LILCO estimates do not include any ambulances or ambulettes for the three hospitals in the EPZ --
i.e., John T.
Father Memorial, Central Suffolk and St. Charles.
Those facilities have, on average, a census of about 630 patients.
Clearly to evacuate that many patients would require a very 1
large number of ambulances and ambulettes.
In Pevision 3 of its Plan, LILCO asserts that it intends to evacuate the hospitals on an ad, hoc basis, using vehicles intended for other purposes as they become available after their other uses are complete.
But, as we will discuss in more detail in our later Group II testimony on Contention 72, this ad hoc arranaement
' would not protect the patients of the hospitals.
That is, LILCO could not provide adeguate protection to the patients of hospitals, unless it had enough ambulances and ambulettes ready to evacuate those facilities in a timely manner.
This would necessarily increase the number of ambulances and ambulettes that would be needed.
Second, LILCC's estimate of the number of handicapped persons residing at home in the EPZ and requiring evacuation by special vehicle is too low for the reasons described below in discussing Contention 73.A.
LILCO is very likely to need more ambulances and ambulettes to evacuate the homebounJ than it expects.
For_these reasons, LILCO's agreements with ambulance companies provide for too few ambulances and ambulettes.,
Appendix B of the LILCO Plan includes some letters from some additional ambulance companies, which indicate an intent to enter into agreements with LILCO in the future.
- However, those letters of intent do not change the fact that LILCO does not have agreements that assure enough ambulances and ambulettes to implement its evacuation proposals.
First, the letters are only assertions that companies may enter into agreements some time in the future.
They are not actual agree-ments, and no commitments now exist with the companies that have signed such letters.
But even if these letters were for the sake of argument assumed to provide assurance of the avail-ability of emergency vehicles, the letters and contracts to-gether relate to only 74 ambulances and 154 ambulettes, still short of meeting LILCO's estimates of 113 and 209, respective-ly.
That is, even with the' letters, LILCO has arranged for only about two thirds of the vehicles it expects it will need.
And, for the reasons we stated above, LILCO's estimates are un-realistically low.
O.
Please state Contention 24.K.
A.
The contention states:
Contention 24.
LILCO has failed to obtain agreements from several of the orga-nizations, entities recui i as part of the offsite response to an emergency pursuant to NUREG 0654, as follows:
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Contention 24.r.
The LILCO Plan relies upon non-LILCO personnel to drive ambu-lances and ambulettes and to provide the necessary medical and paramedical support services in the buses, ambulances, and ambulettes to be used in evacuating special facilities and the handicapped.
(See Ap-pendix A, at IV-166 to IV-168, IV-172 to TV-178.)
The LILCO Plan includes no agree-ments from any such individuals or related entities to perform such services, under LILCO's direction, in the event of an emer-gency at Shoreham.
In the absence of such agreements, LILCO's proposed evacuation of special facilities and the handicapped can-not and will not be implemented.
There is also no assurance that contaminated injured persons, or persons injured during the evacuation, will be transported to hospitals for treatment as required by 10 CFP Section 50.47(b)(12).
O.
Why do you agree with that Contention.
A.
The patients of hospitals, other special facilities and many of the' homebound will reauire medical attention while they are being evacuated.
To ensure that the medical and paramedical personnel necessary to provide tnis care are avail-able, LTLCO needs agreements with such individuals.
Although some of LILCO's agreements with ambulance companies provide for
" manned vehicles," there is no indication that a sufficient number of vehicles will actually be " manned" with proper per-sonnel since there are no agreements with medical personnel.1/
1/
The agreements generally provide that the companies will furnish " vehicles and drivers (and where applicable medi-cal technicians)."
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LILCO has no agreements with the medical personal involved.
Foreover,-LILCO's evacuation proposals include plans to evacu-ate substantial numbers of special facility patients by buses driven by LILCO employees.
The Plan has no provisions for or agreements with skilled health professionals to accompany j
patients on buses.
This is clearly a serious deficiency be-cause there can be no safe transport, much less-evacuation, of
- special facility patients.unless there are attending skilled t'
health professionals.
Thus, there is no assurance that the evacuating special facility patients or the homebound would receive needed medical attention on buses or in ambulettes and
- ambulances in-the event of an evacuation.
i O.
'Plase state Contention ~24.P.
A.
Contention 24.P reads as follows:
Contention 24.
LILCO has failed to obtain agreements from several of the organiza-tions, entities and individuals for perfor-mance of services required as part of the offsite space to an emergency pursuant to NUPEG 0654, as follows:
Contention 24.P.
LILCO relies upon the APC I
to provide services, including medical and counseling services, at relocation centers.
(Plan 2.2-1, 2.2-2, 3.6-7 and at 4.2-1).
However, LILCO has no agreement with the APC to provide such services.
In the ab-sence of such agreements, LILCO's proposed protective action of evacuation cannot and will not be implemented.
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O.
What is the status of LILCO's efforts to obtain an agree-ment with the APC?
A.
The LILCO Plan contains no such agreement, although at APP-E-9 of the Plan there is a letter from LILCO to the ABC describing LILCO's understanding of some conversations which apparently 'took place during the early summer of 1982 between representatives of LILCO and the AFC.
The Plan contains no statement by or on behalf of the ABC which indicates either that it endorses or agrees with LILCO's understanding of such conversations, or that it intends to perform the functions assigned to it by LILCO in the Plan.
Furthermore, LILCO's letter states only that in the event of a Shoreham emergency, LILCO expects the ARC to perform its " usual" emergency response functions " including setting up and operating relocation centers for the public."
There is no indication in LILCO's letter or elsewhere that the AFC's " usual" functions coincide with or-include all those expected of it under the LILCO Plan.
Thus, there is no' basis in the Plan or elsewhere for LILCO's apparent belief that all the functions assigned to the APC in the LILCO Plan would actually be performed by the ABC in the event of a Shoreham emergency.
LILCO has not obtained the agreement of the AFC or any other entity to provide them.
As a
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result, LILCO has provided no assurance that the needs of evacuees at relocation' centers would be met.
9,
1 III CONTENTION 73 - EVACUATION OF THE HANDICAPPED PEPSONS AT HOME Q.
Please state Contention 73.
A.
Contention 73 as admitted by the Board states:
Contention 73.
The LILCO Plan pro-poses to use ambulances to evacuate handicapped people who are not in special facilities.
(OPIP 3.6.5).
Intervenors contend that this aspect of the LILCO Plan cannot be implemented in a timely manner and therefore will not provide adequate protection to handicapped persons in the EPZ.
Thus, this aspect of the Plan fails to comply with 10 CFP Fections 50.47(a)(1),
50.47(b)(1), 50.47(b)(3) and 50.47(b)(10),
and NUPEG 0654, Sections II.A.3, C.4 and J, as specified in paragraphs A and B below.
Contention 73.A.
All handicapped persons in need of special evacuation services will not be known to LILCO and therefore will not be evacuated in the event of an emergency.
The pre-registration ^ system proposed by LILCO (Plan, Appendix A, at II-18; see also In-formation Brochore), will not result in identification of a substantial number of persons who may need assistance in order to evacuate because:
1.
Many people who will require as-sistance will not return the post cards to LILCO because they do not:
(a) perceive themselves to be handicapped; (b) desire to be identified as handicapped; (c) understand the reason or need to return the cards; (d) remember to return the cards; and/or (e) desire to rely on LILCO assis-tance in the event of an emergency.
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2.
There is no provision for veri-fying the completeness of the LILCO listing to be compiled from the returned post cards.
3.
There is no provision for regu-larly updating the listing.
Contention 73.B.
The LILCO Plan does not provide for the assistance and equip-ment necessary to accomplish an evacuation of handicapped persons at home, and thus fails to comply with 10 CFR Sections 50.47(b)(1), 50.47(b)(3), 50.47(b)(5) and 50.47(b)(8), and NUREG 0654, Sections II.A.3, C.4, F and J.
Specifically:
1.
The only provision for notifying non-deaf handicapped individuals of a pend-ing ovacuation is by means of a telephone call from the LILCO Home Coordinator.
(OPIP 3.6.5).
This is an inadequate and 2
ineffective means of notifying many handicapped individuals such as those who are bedridden, unable to get to a telephone or unable to communicate on a telephone, and thuc LILCO fails to comply with 10 CFR Section 50.47(b)(5) and NUPEG 0654, Sections II.E.5 and E.6.
(See FEMA Report at 9.)
3.
One LILCO employee -- the Home Coordinator -- is recponsible for con-tacting all the handicapped persons and identifying and contacting all reception centers (none of which are identified in the Plan).
(OPIP 3.6.5, Section 5.1.2.)
While OPIP 3.6.5 provides that the Fome Coordinator should "[d] raw on Communica-tions and Administrative Support personnel to assist in this effort," there is no in-dication that such personnel will be avail-able.
Thus, there is no assurance that disabled persons will be notified promptly enough to permit timely evacuation.
4.
The proposed evacuation would take far too long, and as a result, handicapped people would be likely to receive health-threatening doses of radia-tion because evacuating vehicles would en-counter congestion from other mobilization and evacuation traffic, and thus would be substantially delayed in traveling to the homes of handicapped individuals, and to relocation centers.
5.
The LILCO Plan calls for the deaf to be alerted of an accident, and advised of the appropriate protective action, by LILCO route alert drivers who are expected to drive to the home of each deaf resident within the EPZ (OPIP 3.6.5).
This proposed notification will not be timely, however, since route alert drivers will be delayed by mobilization and evacuation traffic.
Furthermore, even disregarding expected traffic conditions, there is no assurance that enough route alert drivers will be assigned to this function to enable LILCO to carry out such notification promptly.
O.
Do you agree with Contention 73?
A.
Yes, we do.
LILCO's proposals for the evacuation of handicapped persons from their homes could not be implemented for several reasons.
First, as stated in subpart A of Contention 73, LILCO would not have an accurate list of the people who would actual-ly need assistance in the event of a Shoreham emergency.
LILCO's proposed method for identifying such individuals is se-riously flawed.
In an attempt to identify those individuals, in August, 1983, LILCO mailed a letter containing a return post card to all the residents of the EPZ, and asked them to return the card if they felt they would need transportation assis-tance.
LILCO apparently compiled its list of the homebound and arrived at its estimate of 345 homebound, 99 of whom would require ambulance or ambulette transportation (Appendix A, at 175), based on the returned cards.
Revision 3 of the Public Information Brochure also includes a returnable post card and a request that "if you need special belp, or if you know of some-one who does, please fill out and return the post card LILCO's method is badly designed.
If someone in the area of public health were to attempt to identify individuals with particular health-related characteristics, be or she would not use a system that relied on voluntary, positive action by the individuals.
That kind of system is unlikely to produce reli-able data, because you cannot distinguish between a non-response and a negative response.
That is, not every non-response means the individual would not need assistance in an emergency.
Such a system does not identify those people who would need help but did not return cards for any number of reasons.
LILCO's assumption that all non-responders (people who did not return the cards) are persons who would have sub-mitted a negative response (i.e.,
they need no assistance) is unwarranted. -
In addition, LILCO's proposed method includes no provision for verifying the accuracy of the estimates obtained from the post cards.
Indeed, LILCO apparently has not tried to deter-mine how many people, who in fact would need assistance, failed to return the August post cards, and there is no indication that it intends to verify whatever listing it may compile after the Public Information Brochure is released.
Thus, there is no assurance that listings based on returned post cards represent the true number of individuals who would actually need assis-tance.
Finally, whatever list LILCO ultimately complied would have to be updated regularly.
Such lists become obsolete, and the purpose of the list is too importantEto let it become inac-curate with the passage of time.
Nonetheless, LILCO's Plan has no provision for updating the list.
For of all these reasons, it is clear that LILCO does not and will not know of all the handicapped people in the 10-mile EPZ who would need assistance in the event of a shoreham emergency.
.O.
Do you agree with subpart B of Contention 73 which concerns LILCO's proposals to evacuate the homebound themselves?
A.
Yes.
Those proposals could not' be implemer.ted.
As stated in Contention 73.B.1, LILCO plans to notify the-non-deaf bomebound by telephone (OP'? 3,6.5, Section 5.1.2).
However, the telephone is an inappropriate means of notifica-tion for handicapped individua1s.
Many handicapped persons are
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impaired in their ability to do.any things the rest of us consider commonplace, including using a telephone.
For many reasons a handicapped or invalid individual might not be able to answer a telephone call.
Moreover, many of those who can use a telephone are likely to need a long time to answer.
According to the Plan, only one LILCO worker -- the Home Coordinator -- is assigned the task of calling hundreds of peo-ple in a hurry; he or she could not afford to wait a long time for a response.
As subpart B.3 of Contention 73 states, OPIP 3.6.5 does assert that the Home Coordinator could " draw on" other LERO support personnel to assist in the calling effort.
However, presumably all LERO workers will have their own job assignments; given the many duties and responsibilities for workers set forth in the Plan and OPIPs, there is no assurance that such additional personnel would in fact be available to assist the Home Coordinator.
At any rate, it is inadeguate planning to rely on such an ad hoc recruiting process for noti-fication of handicapped individuals.
Thus, under the
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conditions of an emergency it is likely that LILCO would not be able to contact many of the homebound.
But, even if ecatact with the homebound could be made by telephone, the required calls would take too long.
Handicapped individuals, like anyone else, are unlikely to listen in silence to the LILCO caller's announcement and/or instructions and then hang up.
Instead, they are likely to ask the LILCO caller questions about the emergency and the proposed evacua-tion.
The process would substantially slow down the LILCO caller in the process of telephoning all the homebound.
Given the tremendous number of calls the Home Coordinator would be expected to make and the limited time available, the LILCO caller probably would not be inclined to take the time to answer questions.
This could cause minor conflicts that in turn would cause delays.
Furthermore, many of the homebound are likely to suffer from disabilities that make it difficult for them to hear, speak or even understand.
Tais would result in even more delay.
Therefore, LILCO's proposal to contact the non-deaf homebound by telephone is unacceptable, because there is too much chance that many of the homebound would not be able to evacuate in a timely manner due to inadequate notification..
c.
Subpart P.4 of Contention 73 concerns the time necessary to conduct an evacuation of the handicapped from their homes in the EPZ.
Do you have concerns related to that subpart?
A.
Yes we do.
The testimony of other Suffolk County witnesses on Contentions 65 and 27 supports the portion of that subpart relating to the likelihood that ambulances attempting to evacuate handicapped persons from their homes will encounter traffic congestion that will slow down the proposed evacuation.
We have an additional concern.
Still more delay in the evacua-tion of the handicapped will result because many of the ambu-lance and ambulette companies relied upon by LILCO are located in areas distant from the EPZ.
See Suffolk County testimony on Contention 27 for details on mileage.
This means that many am-bulance drivers are likely to be unfamiliar with the EPZ, and therefore they could get lost attempting to find private resi-dences.
Fven under normal circumstances involving an ambulance company responding to a call in a relatively familiar area, drivers frequently have trouble locating particulat homes, es-pecially when residences are poorly marked or streets are poor-ly lit.
O.
Please describe LILCO's proposals for notifying deaf residents of the EPZ which are referenced in subpart B.5 of Contention 73. _
A.
Under the LILCO Plan, if sheltering were the recommended protective action, LILCO proposes to send Route Alert Drivers to the homes of the deaf residents of affected portions of the 10-mile EPZ to notify those individuals.
If evacuation were recommended, LILCO route alert drivers would be sent only to homes of the " ambulatory deaf"; no notification of the need to evacuate, or forthcoming LILCO evacuation assistance, would be given to the "nonambulatory deaf" prior to the arrival of an ambulance or ambulette assigned to transpcrt them.
(OPIP 3.3.4, Section 5.4.)
This LILCO proposal would not work, first because LILCO would not know of all the deaf residents of the 10-mile EPZ, and second, because the proc 2ss would take far too long.
LILCO would not know of all the deaf residents of the EPZ for the reasons discussed above in connection with the home-bound in general.
The Plan's provisions for notification of the deaf could result in notification coming too late for two reasons.
- First, the LILCO Plan does not provide for notification of deaf people until there has been a recommendation of sheltering or evacua-tion.
Thus, under the LILCO Plan the deaf would have no oppor-tunity to prepare to take protective actions, contary to the.
situation for the non-deaf population who would receive notice f' rom sirens and radio at initial stages of the emergency, even before any protective actions were advised.
Although it is likely that some deaf individuals would learn of the emergency earlier from friends or relctives, a prudent planner would not rely on a were possibility that something desirable might occur.
Second, the LILCO Plan does not identify individuals who are specifically assigned the task of notifying the deaf.
In-s t e,a d, LILCC plans to " dispatch available Poute Alert Drivers to notify.
. deaf people."
(CPIP 3.3.4, Section 5.4.1)
However, Poute Alert Drivers are assigned the primary job of providing a backup to the sirens (see suffolk County Testimony on Contention 56), and the need to fulfill that assignment and to notify the' deaf could, under many circumstances, arise at the same time.
Thus, the Plan provides no assurance that any-one will be "available" to perform the job of notifying the deaf.
l In our opinion, the LILCO Plan provides no assurance that deaf residents of the EPZ would be identified or receive timely notification of an emergency and, consecuently, there is no as-surance that they could or would be protected adequately.
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Q.
Please summarize your cenclusions regarding Contention 73.
A.-
LILCO's proposals for evacuating the homebound could not be implemented because they are the result of a flawed planning effort.
In order to plan effectively for any contingency, one must make realistic and conservative assumptions.
One must not make optimistic estimates, or unwarranted assumptions, or ig-nore significant contingencies.
The LILCO Plan includes all those things and as a result, its proposals for evacuating the handicapped at home are not workable.
l F
IV CONTENTION 75 - PELOCATION CENTERS 0
Please state Coi;ention 75.
A.
Contention 75 and its preamble read as follows:
Contention 75.
The LILCO plan provides no estimates of the number of evacuees who may require shelter in a relo-cation center, and the Plan fails to demon-strate that each such facility has adeguate space, toilet and shower facilities, food and food preparation areas, drinking water, sleepinu accommodations and other necessary facilities.
Accordingly, there is no as-surance that the relocation centers desig-nated by LILCO will be sufficient in capac-ity to provide necessary services for the number of evacuees that will require them.
Thus, LILCO fails to comply with NUPEG 0654, Sections II.J.10.g and J.12.
O.
Do you agree with Contention 75?
A.
Yes, we do.
It appears that LILCO's planning efforts with respect to relocation centers have consisted primarily of an assertion that the American Fed Cross (the " ARC") is responsi-ble for operating the centers.
In our opinion, LILCO has failed to consider, much less plan to deal with, the numerous practical problems involved in establishing and runnino reloca-tion centers.
As a result, the centers proposed by LILCO will not provide necessary services to those evacuees who need shelter.2/
2/
Of course, as noted in Contentions 24.N, 24.0, the testi-mony of President Freiling of Suffolk County Community ( Footnote cont'd next page)
First, LILCO has ignored the need for coordination among the AFC and the various LILCO employees who supposedly would also be involved in relocation center operations.
According to the LILCC Plan, the ARC is expected to operate those portions of the relocation centers in which uncontaminated evacuees will live.
(See OPIP 4.2.1.)
But LILCO personnel are supposed to perform radiological monitoring and decontamination, control traffic and maintain security under the direction of the LILCO employees designated as the Security Coordinator, the Traffic Control Coordinator and the Decontamination Leader.
(Plan, at 4.2-2)
The Plan contains no substantive information indicating how all these groups are to work together or coordinate their actions in a way that would make operation of the centers pos-sible.
The LILCO personnel at the relocation centers (totalling approximately 48 at each center) wod1d be responsi-ble to three different LILCO coordinators.
Approximately 99 (Footnote cont'd from previous page)
College, and our testimony on Contention 24.N, LILCO's as-sumption that the Suffolk County Community College would be available as a relocation center is unfounded, and LILCO has no agreements with any of the other facilities proposed in its Plan indicating that any of those facilities would be available eitber.
Our testimony on Contention 75, however, assumes for the sake of argument, that LILCO could obtain the agreement of facility owners other than the Suffolk County Community College to permit their facilities to be relocation centers.. _-
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AFC personnel at each center would be neither subordinate nor superior to the-LILCO personne), even though they would have to work together.
Under such an arrangement, it would be almost impossible to determine what supplies and facilities were available, obtain those that were needed, or provide adequate services to evacuees.3/
Second, although the Plan asserts at 4.2-2 that the five relocation centers proposed by LILCO were selected "[iln accor-dance with AFC procedures," it appears that the statement is incorrect.
For example, page 4.2-3 of the Plan states that 20 square feet per bed was considered adequate for sleeping accom-modations; however, Shelter Management - A Guide For Trainers, AFC 3074, American Red Cross, 1980, at 6, states that "[a]n al-lowance of 60 square feet per bed is recommended; the minimum allowance should be 40 square feet."
Thus, the selection criteria for sleeping space used by LILCO was apparently sub-stantially belcw that recommended by the APC:
only one third of the recommended ABC sleeping space and only one half of the i
3/
The Plan does assert that the ABC representative expected to be stationed at the EOC, will "act as the liason between the centers and the other portions of [LEPO]."
-(Plan, at 4.2-2).
Clearly, while such an individual could deal with problems that may arise at the EOC or among the r
various EOC coordinators, he or she, as a practical mat-ter, could have little if any impact on the operations ac-tually taking place at the relocation centers. :
I
minimum suggested by the AFC.
This is important because adequate sleeping space is an essential element in maintainino public health in a mass shelter situation.
Furthermore, the list of other factors considered by LILCO in selecting its relocation centers (see Plan, at 4.2-3) fails to include waste removal.
Wastes are one of the leading sources of public health problems, particularly in a mass care situation.
Moreover, waste removal would be an especially sig-nificant problem at LILCO's reloca tion centers because it would be complicated by the potential need to deal with wastes con-taminated by radioactivity, such as contaminated water, cloth-ing and personal possessions of contaminated evacuees as well as normal waste.
LILCO's Plan provisions concerning relocation centers ignore this crucial problem.
Similarly, there is no indication in the Plan that LILCO either considered or dealt with the problem of disposing of all the contaminated water that would be produced by LILCO's pro-posed decontamination operations.
For example, showers cannot i
be used to wash contaminated evacuees, if the contaminated water simply drains into a sewer.
Nothwithstanding this fact, the LILCO Plan contains no indication that LILCO's proposed re-location centers have showers that in fact could be used by
_ ~. - _ _
contaminated individuals.
And, other than some lists of supplies such as toilet paper, cots, paper cups, towels and trash cans which the Plan asserts will be available at LILCO's
. proposed relocation centers, there is no indication in the Plan that a sufficient supply of such materials, acknowledged by LILCO to be necessary to protect public health (OPIP 3.7.1, at Section 5.1), actually would be available at the centers during a Shoreham emergency.
Third, the LILCO Plan fails to specify which buildings or portions of buildings LILCO has " selected" for its relocation centers.
Each of the proposed centers is a large facility.
For example, SUNY at Stony Brook is a very large complex, con-sisting of many buildings.
Telling either potential evacuees or response workers to report to SUNY at Stony Brook tells them
- very little.
Furthermore, since LILCO has failed to identify any specific areas, buildings or facilities at any of its pro-posed relocation centers,'it is-impossible to determine whether 4-the proposed facilities would be adequate or available for the l-
- use intended by LILCO.
?
Fourth, the LILCO Plan contains practically no information concerning-how LILCO proposes to solve the logistical problems involved-in conducting the monitoring and decontamination
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functions that LILCO expects to take place at the relocation centers.
OPIP-3.9.2 contains material concerning techniques r
for monitoring and decontaminating people, and the Plan contains some drawings of how evacuees should be " routed" from one monitoring or decontamination " station" to another.
How-ever, the Plan fails to identify where in LILCO's proposed re-location centers it intends to set up these operations.
In our-opinion,'it is unlikely that LILCO's proposed relocation centers would have the facilities or the equipment necessary to shelter and monitor / decontaminate evacuees for the following reason.
i Judging from the description of.its relocation center "se-lection" process, it appears that LILCO ignored the logistical
- difficulties posed by the dual functions that LILCO expects to
{i Rbe performed at those centers.
The list of criteria on pages 4.2-2 and 4.2-3 of the Plan is almost an identical copy of the list of-criteria contained on page 4 of the APC's shelter man-agement booklet mentioned above.
Obviously those criteria 2
concern the provision of healthy living quarters for persons in need of temporary shelter.
That is what the AFC does.
Those criteria, however, ignore a crucial additional requirement of the' relocation centers necessary under the LILCO Plan:
LILCO's relocation centers would need two sets of many facilities, such
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1 i
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I as reception areas, waiting rooms, showers, toilets, storage areas, waste disposal facilities, nursing and first aid f acilities, and possibly cooking and dining facilities, as well as adequate supplies and equipment for such double sets of facilities.
Dual facilities would be necessary in order to ac-commodate separately the potentially or actually contaminated evacuees, and those who are not contaminated.
Clearly, LILCO's Plan has failed to come to grips with the practical problems involved in doing what LILCO proposes to do.
The Plan therefore provides no assurance that the proposals with respect to LILCO's provisions of relocation, monitoring and decontamination services could ever be implemented by LILCO.
In our opinion, they could not.
Q.
Does that conclude your testimony?
A.
Yes.,..- __
E O
m O
ATTACHMENT 1 i
i e
ATTACHMENT 1 CURRICULUM VITAE Martin David Mayer, M.D.,
M.P.H.
Present Position:
(as'of September, 1972)
Deputy Director of Public Health Suffolk County Department of Health Services Division of Public Health 225 Rabro Drive East Hauppauge, New York 11788 (516) 348-2757 Education:
l 1.
Stuyvesant High School, New York, New York; graduated June, 1957 2.
City College of New York, New York, New York; September 1957 to January,1962; received BChE Degree, January, 1962 Professional Education:
1.
State University of New York, Upstate Medical Center Medical School; Syracuse, New York; September, 1965 to June, 19 6 9 ; Received M. D., Cum Laude, June, 1969.
t l
2.
Kings County Hospital; Brooklyn, New York; Straight
(
Pathology Internship; July, 1969 through June, 1970.
l 3.
University of Michigan; Ann Arbor, Michigan, September, 1971 through August, 1972, received M.P.H., August, 1972.
Licensure:
New York State, Physician License MD106724, August 5, 1970 i
Diplomat, National Board of Medical Examiners, Certificate No. 102795, July, 1970 1
f
- continued -
1 i
Curriculum Vitae Martin David Mayer, M.D.,
M.P.H.
Page Two Honors:
1.
Winner, competitive New York State Regents Scholarship, 1957-1961 2.
Elected to Tau Beta Pi, National Engineering Honor Society (1960) 3.
Elected to Omega Chi Epsilon, National Chemical Engineering Honor Society (1961) 4.
Elected to Alpha Omega Alpha, National Medical Honor Society (1968)
Emplovaant:
1.
August 1970 through August 1971 - Resident Physician in the New York State Department of Health Residency Program in Public Health and Preventive Medicine; Assigned to Westchoster County Health Department, White Plains, New York 2.
Summer 1966, Summer 1967, Summer 1968 - Aesistant Sanitary Engineer, Division of Air Pollution, New York State Department of Health, 84 Holland Avenue, Albany, New York 3.
July 1963 through July 1965 - Senior Assistant Sanitary Engineer, U.S. Public Health Service, Robert A. Taft Sanitary Engineering Center, Cincinnati, Ohio 4.
Feburary 1962 through January 1963 - Assistant Process l
Engineer, ESSO Research and Development Corporation, Florham Park, New Jersey Publications:.
Martin Mayer, A Compilation of Air Pollution Emission Factors for Combustion Processes, Gasoline Evaporation, and Selected Industrial Processes, U.S.
Department of Health, Education and Welfare, Public Health Service, National Center for Air Pollution Control - May, 1965 f