ML20081A818

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Direct Testimony of Rc Roberts on Emergency Planning Contention 74 Re Inappropriate Proximity of Proposed Relocation Ctrs.Related Correspondence
ML20081A818
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 03/02/1984
From: Roberts R
SUFFOLK COUNTY, NY
To:
Shared Package
ML20081A747 List:
References
OL-3, NUDOCS 8403060319
Download: ML20081A818 (4)


Text

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A UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

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In the Matter of

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LONG ISLAND LIGHTING COMPANY

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Docket No. 50-322-OL-3

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(Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1)

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DIRECT TESTIMONY OF DEPUTY CHIEF INSPECTOR RICHARD C. ROBERTS ON BEHALF OF SUFFOLK COUNTY REGARDING EMERGENCY PLANNING CONTENTION 74 - INAPPROPRIATE PROXIMITY OF PROPOSED RELOCATION CENTERS TO THE SHOREHAM PLANT 4

Q.

Please state your name and position.

A.

I am Richard C.

Roberts.

I am a Deputy Chief Inspector of the Suffolk County Police Department.

My resume was attached to my testimony regarding Contention 65 and admitted into evi-l dence in this proceeding.

See Tr., at 2258.

Q.

Are you familiar with Emergency Planning Contention 74 and the related portions of the LILCO Plan?

A.

Yes.

Contention 74 and its preamble state as follows:

Further Preamble to Contentions 74-77.

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offsite emergency plan must include means of re-locating evacuees and must provide for relocation centers located at least five miles and prefer-ablf 10 miles beyond the EPZ.

NUREG 0654, Sections II.J.10.g and h.

Such relocation centers are essential to provide food and o

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~_ shelter to those evacuees who have no alter-native places to stay and also to provide radiological monitoring and decontamination for evacuees and their vehicles.

The reloca-tion centers must have sufficient personnel and equipment to monitor evacuees within a 12-hour-period.

NUREG 0654,Section II.J.12.

The LILCO Plan calls for the establish-ment of relocation centers outside the EPZ at L

the following facilities (Plan, at 4.2-1; OPIP 4. 2.1) :

Suffolk County Community College (primary)

BOCES Islip Occupational Center (primary)

State University of New York at Stony Brook (primary)

State University of New York at Farmingdale (backup)

'St. Joseph's College', Patchoque (backup).

The Intervenors contend that LILCO will be unable

-to provide adequate relocation centers and ser-t vices for evacuees, and thus the Plan fails to comply with 10 CFR Sections 50.47 (a) (1),

50. 47 (b) (8), 50. 47 (b) (10), and NUREG 0654 Section J.

The specific deficiencies which lead to this conclusion are set forth in Contention 74-77.-

Contention 74.

Two of the three primary relocation centers designated by LILCO are well within 20 miles from the Shoreham. site.

Both i

Suffolk County Community College and the State l

University of New York at Stony Brook are only three miles beyond the EPZ boundary contrary t

to NUREG 0654,Section II.J.10.h.

I have reviewed those portions of the LILCO Plan in which LILCO identifies its proposed relocation centers.

(See LILCO Plan, Section 4.2, at page.4.2-1.)

Q.

Do you know where the facilities designated by LILCO as relocation centers are located?

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. A.

I am personally familiar with the locations of LILCO's five proposed relocation centers.

Three of those facilities are located less than five miles beyond the boundary of LILCO's EPZ (that is, less than fifteen miles from the Shoreham Nuclear Power Station), and a fourth-is located less than ten miles beyond the boundary of LILCO's EPZ (that is, less than twenty miles from the Shoreham site).

Specifically, the Ammerman Campus of Suffolk County Community College in Selden is approxi-mately 13 miles from the Shoreham site, and only 3 miles from the plume EPZ boundary defined in the LILCO Plan.

The State University of New York at Stony Brook is approximately 13-1/2 miles from the Shoreham site, and only 3-1/2 miles from the plume EPZ boundary defined in the LILCO Plan.

And, the BOCES facility in Islip is approximately 19 miles from the Shoreham site, and only 9 miles from the plume EPZ boundary defined in the LILCO Plan.

All of these are identified by LILCO as " primary" relocation centers.

In addition, St. Joseph's College in l

Patchogue, designated by LILCO as a " backup" relocation center, t

is approximately 14 miles from the Shoreham site, and only t

4 miles from the plume EPZ boundary defined in the LILCO Plan.

Clearly,'three of the facilities proposed by LILCO do not satisfy the NUREG 0654 guidance that relocation centers be at least five miles, and preferably ten miles,beyond the EPZ, and a fourth pro-posed relocation center is less than ten miles from the plume EPZ i

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n-.... 4 boundary.

Thus, four of the relocation centers proposed by LILCO are.within 20 miles of the Shoreham Nuclear Power Station.

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Q.

Does that conclude your testimony?

A.

Yes.

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