ML20086T301

Testimony of Wj Acquario,Rd Albertin & RG Knighton Re Emergency Planning Contention 73, Evacuation of Handicapped Persons Not in Special Facilities. Related Correspondence

ML20086T301
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/01/1984
From:	Acquario W, Albertin R, Knighton R NEW YORK, STATE OF
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ML20086T237	List: ML20086T234 ML20086T263 ML20086T301 ML20086T313
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OL-3, NUDOCS 8403060246
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@ CORRgsPOND M CCLKETED 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 (Shoreham Nuclear Power Station,

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(Emergency Planning)

Unit 1)

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DIRECT TESTIMONY OF l

WILLIAM J. ACQUARIO RICHARD D. ALBERTIN AND ROBERT G. KNIGHTON ON BEHALF OF NEW YORK STATE REGARDING EMERGENCY PLANNING CONTENTION 73 EVACUATION OF HANDICAPPED PERSONS NOT IN SPECIAL FACILITIES Q.

Please state your names, occupations, and professional backgr'unds.

o A.

My name is William J. Acquario.

I am a' Bureau Director with the New York State Department of Transportation. I an in charge of the Transit Management Assistance Bureau.

A.

My name is Robert G. Knighton.

I am a Transit Specialist III with the New York State Department of Transportation.

I currently head the Specialized and Capital Policy Section in the Transit Program and Evaluation Bureau.

A.

My nana is Richard D. Albertin.

I am an Associate Transportation Analyst with the New York State Department of Transportation.

I 8403060246 840301 PDR ADOCK 05000322 T

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currently direct New York's administration of the Federal Section 18, rural public transportation program.

Q.

Please provide us a brief background of your relevant work experi-ence that would pertain to the testimony supplied here.

Richard Albertin For approximately five years. I was directly responwible for the Department's computer modeling. These duties included the opera-tion and analysis of New York's transportation analysis modeling effort as well as the review of current technology and research being done for both highways and transit.

I was also the major participant in the development of the original " Olympic Transpor-tation Control Plan".

This plan was the basis of the proposed operational strategy for the Olympic area.

Presently I direct the state administration of the federal rural transportation program. My duties require me to be familiar with over 60 transit operations. By federal requirement each transit system must provide accessibility to the elderly and handicapped.

I frequently assist these operations in attaining this goal.

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Robert Knighton In my present position, I am responsible for evaluating the effectiveness of various transit systems including efforts to serve the special needs of the elderly and handicapped people.

I participated in early stages of development of the Olympic Transportation Control Plan and the Disaster Operations Plan for the 1980 Winter Olympics at Lake Placid. During the Olympics, I shared responsibility with Mr. Albertin for monitoring implements -

tion of the Olympic Transportation Control Plan by the Olympic.

Organizing Committee and later for implementation of the State takeover of the Olympic transit system.

For apprcximately five years. I was involved in Department activi-ties in the development, conduct and analysis of surveys. I also participated in the development and use of models relating to the demand for public transportation by elderly and handicapped people.

William Acquario For the past 3 years I have been Director of the Department's Transit Management Assistance Bureau. The function of the Bureau is to provide management and technical assistance to any and all of the state's public transit systems.

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I participate in and supervise bus route design for municipal transit operations. We also review schedules and route guides for maximum utility of equipment, personnel and transit effectiveness.

Q.

What is the purpose of this testimony?

A.

The testimony addresses Emergency Planning Contention 73.

We have reviewed the LILCO Plan to determine whether LILCO's provisions for the safe and timely evacuation of non-institutionalized mobility impaired and other similarly handicapped persons are adequate.

Q.

Please state Contention 73.

A.

Contention 73. Handicapped People at Home. The LILCO Plan proposes 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 protec-tion to handicapped persons in the EPZ. Thus, this aspect of the Plan fails to comply with 10 CFR Sections 50.47 (a) (1), 50.47 (b)

(1), 50.47 (b) (3) and 50.47 (b) (10), and NUREG 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 4'

special evacuation services will not be known to LILCO and there-fore will not be evacuated in the event of an emergency. The preregistration system proposed by LILCO (Plan, Appendix A at 11-18; see also Information Brochure), will not result in identi-fication of a substantial number of persons who may need assis-tauce in order to evacuate because:

1.

Maay people who will require assistance will not return the postcards to LILCO because they do not:

(a) perceive them-selves to be handicapped; (b) desire to be identified as handi-capped; (c) understand the reason or need to return the cards; (d) remember to return the cards; and/or (e) desire to rely on LILCO assistance in the event of an emergency.

2.

There is no provision for verifying the completeness of the LILCO listing to be compiled from the returned postcards.

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e 3.

There is no provision for regularly updating the listing.

Contention 73.B.

The LILCO Plan does not provide for the assistance and equipment necessary to accomplish an evacuation of handicapped persons at home, and thus fails to comply with 10 CRF Sections 50.47 (b) (1), 50.47 (b) (3), 50.47 (b) (5) and 50.57 (b)

(8), and NUREG 0654, Sections II.A.3, C.4 E and J.

Specifically:

1.

The only provision for notifying non-deaf handicapped

. individuals of a pending evacuation is by means of a telephone call from the LILCO Home Coordinator.

(OPIP 3.6.5.).

This is an inadequate and ineffee,tive 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 thus LILCO fails to comply with 10 CFR Section 50.47 (b) (5) and NUREG 0654, Sections II.E.5 and E.6.

(See FEMA Report at 9).

2.

(Subpart B.2 not admitted by ASLB.)

3.

One LILCO employee -- the Home Coordinator -- is responsible for contacting all the handicapped persons and identi-fying and contacting all reception centers (none of which are identified in the rian).

(OPIP 3.6.5., Section 5.1.2.).

While OPIP 3.6.5. provides that the Home Coordinator should draw on Communications and Administrative Support personnel to assist in this effort, there is no indication that such personnel will be available.

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 radiation because evacuating vehicles would encounter 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 cotification 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.

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l Q..

How'does the LILCO plan develop its estimates of the number of handi-capped people?

A.

The LILCO plan apparently relies on two sources to identify the number of mobility impaired non-institutionalized handicapped people; one, a survey conducted by Yankelovitch, Skally and White and two, a mailed return of a self-identification postcard sent along with an information brochure to every household.

Q.

Do you agree with LILCO's estimates of the number of handicapped individuals?

A.

No, the Yankalovitch survey indicates that 7% of 32.200 households or (2,254) households have a handicapped member. Contrary to this esti-mate of households in the EPZ our analysis of the 1980 census data indicates a range of households of between 42,000 and 45,000. Using this sama 7% eurvey estimate this indicates a potential base of at least 2940 families or approximately 700 more than the LILCO estimate.

The LILCO memorandum further identifies that of this 2,254 total only 322 househoids claim a need for special transportation. Using our Census -_ developed estimate and this same ratio, we estimate 412 households will need special transporation.

Since 40% of the households with handicapped individuals claim more than one handicapped member, the Yankelovitch survey yields LILCO a base of 450 handicapped people needing transportation (322 x 1.4 =

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1 450). Continuing with our estimate of 412 households needing special transportation times this same survey rate, 577 handicapped individuals would need transportation. This is 127 more trips than LII.C0 estimates.

Also there appears to be no attempt to identify or consider how many of the families will require someone to accompany the handicapped individ-ual and this person might be a ' family member or a trained professional.

Q.

What is your estimate then of the number of handicapped individuals who any need transportation?

A.

Rather than the LILCO estimate of 450 people, we feel that the base number is at least 600 and in fact may well be substantially higher because: (1) of the need for assistance, (2) the number of families with cars, who claimed no need for transportation in the survey, may in fact not have a car available at all times during the day or even every day, and, (3) the survey may not have identified everyone needing special services or needing someone to accompany the handicapped.

In Revision 3 of Appendix "A" LILCO has changed its estimate of 450 people to approximately 100 people based on a survey asiled to all residencies in the EPZ, August 1983. However, for all of the above reasons this number is even more inaccurate than the previous estimate of 450.

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Q.

Do you believe that the LILCO's preregistration system requiring those needing sipecialized service mailing in postcards will produce an accurate total location of all of the handicapped?

A.

No.

Our experience suggests there could be serious problems with this approach.

Q.

What are some of these problems?

A.

One is the very definition of handicapped. Many people may not have identified themselves as being handicapped unless they were advised that the alternative for the autoless is to walk up to mile with a suitcase, pillow and blankets.

(The notification to evacuate in the l

plan suggests everyone to bring pillows and blankets). The latest postcard survey we've seen phrases the possible length of walk as a "few blocks". Given those two factors it seems highly likely that the j

total numbers may be underestimated.

f Our experience with post-card surveys suggests that not everyone who receives the card will respond. Another probled is the mailing list which is derived from LILCO " billings". The use. of addresses obtained from company records causes serious concern. Frequently landlords provide utilities with the rent. Some handicapped people would most likely never even get a card. This would be especially true for summertime renters / vacationers and guests in EPZ households.

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There also appears to be no procedures identified in the plan to verify the survey results with follow-up contacts, to periodically update the lists or to cross-reference the results obtained from the post-card survey with other data that may be available from social service or handicapped associations.

Q.

Why is it important to cross-reference the post-card survey results?

A.

It is standard practice with researchers, whenever possible, to use several sources to obtain the same data in order to improve its accura-cy and completeness. There are many professionally acceptable maar.2 to cross-reference this type of information but the LILCO plan appears to do so only through the Yankelovitch survey.

Q.

Are there other problems with identification of handicapped people by relying on a post-card mailing?

A.

Yes, it doesn't appear that survey responders will realize that if they use general public transportation they may need to walk up to 35 mile.

Therefore, some respondents may require specialized transportation and may not realize it.

Also our experience suggests that many people may not want to be so identified for fear of vandalism or crime since they may feel them-selves vulnerable if they make public the information that they are handicapped and hence may not respond.

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4 Q.

According to the LILCO plan how will the handicapped individuals be contacted?

A.

If they have pre-registered with LILCO, they will be called on the phone by the Home Coordinator and advised of an evacuation order. They will.then be given transportation directions.

If they have not pre-registered, they may call a LILCO number to ask for transportation assistance when they learn of an evacuation order.

Q.

Do you foresee problems with this approach?

A.

Yes, to call hundreds of people would take hours to complete. LILCO would also have to handle incoming calls for information, late trans-portation, problems of drivers in finding houses, etc. The LILCO plan fails to identify a procedure that could be implemented in a reasonable amount of time.

In addition, there are handicapped people who either do not have phones or who may not be in a position to answer when the call comes.

Q.

Do you feel the LILCO's procedure for notifying the deaf is adequate?

A.

No, the notification of the deaf is inadequate. Having the LILCO Route Alert Drivers knocking on doors will not prove adequate for a timely evacuation. This is especially true since they only tell the deaf there is an evacuation order and that transportation will be provided if they need it.

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Q.

What is the estimation of the number of deaf persons in the EPZ?

A.

From the Yankelovitch survey, there is an indication that almost 4% of the households have a member that is either deaf or has a language problem. This would indicate an excess of 1600 persons with hearing problems. Not all are mobility impaired of course, but even if only 10% or 160 need transportation that is a significant additional number of people to contact directly by the alert personnel.

Q.

What is another concern with the LILCO specialized transportation procedures?

A.

One of the major shortcomings of the Plan is the failure to identify and locate the amount of equipment that will be. ceded for the evacua-tion of the non-institutionalized handicapped and to identify suffi-cient sources of this equipment.

Without this information it is impossible to provide any reasonable estimate of the time needed to evacuate the handicapped portion of the population. LILCO has identified a number of private sources for handicapped-equipped vehicles. However, under the nursing homes and hospitals, as well as people at home. The Plan does not indicate the order of evacuation, except that hospitals will be evaculated last.

This consideration will significantly effect time estimates.

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T Q.

Do you feel there are problems in coordinating the available vehicles with the needed rides?

A.

Yes. There are no routes planned for the handicapped vehicles and as far as we can determine, no preassigned matchups of handicapped indi-viduals or geographic areas to special transportation companies. The LILCO Home Coordinator is apparently supposed to match need with the dispatch of equipment. This procedure is unclear. Assuming the same amount of time to get the equipment to a dispatch point as is allowed for the busas, 135 minutes, and assuming i hour for getting to the location, finding the house and loading each patient it would take 165 minutes or 3% hours just to get each person on a van or ambulance.

Assuming another hour for the exit transportation and deboarding of each person in the new relocation site (see the State of New York's testimony on Contention 65) we have a time span of 4k hours per person.

Assuming 50 vehicles are available and each vehicle can carry an average of 1.5 handicapped individuals (there are usually only 1 or 2 wheelchair stations on most specialized vehicles) then it may take over 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> to complete this portion of the evacuation!

This estimate is not intended to portray our estimate for this portion of the evacuation but rather, how very dependent this estimate is on available equipment, their timing of availability, their location, the procedures to use and the number of handicapped individuals to be transported.

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Q.

Are there any problems with training?

A.

Yes. The plan provides no indication that the ambulance and van operators have agred to receive special training on the traffic plans for the EPZ; on finding addresses in the EPZ and on the procedures for operating under radiological hazards. They will also need training concerning interaction with the people who accompany the handicapped individuals who may be in a more highly emoticaal condition than under normal circumstances.

Q.

Does the plan identify where the handicapped individuals will be' relocatedt A.

No, this omission leaves serious health questions unaddressed and therefore unanswered from a planning perspective.

Q.

In general can you conclude that the provisions for the transportation of non-institutionalized handicapped people are adequate for a safe and timely evacuation?

A.

No.

The Plan is inadequate and it does not provide sufficient informa-tion or detail to lend any credibility to the workability of this phase or the time estimates presented.

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