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Testimony of Td Gibbons Re Emergency Planning Contention 66.D, Agreements for Snow Removal & Emergency Planning Contention 97.B, Evacuation During Deep Snow. Certificate of Svc Encl.Related Correspondence
	ML20086T313
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Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/01/1984
From:	Gibbons T; NEW YORK, STATE OF
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____

RELATED CORRESPOi(DENC&

UNITED STATES OF AMERICA ff0 NUCLEAR REGULATORY COMMISSION 1.

l Before the Atomic Safety and Licensing Board

'g.,-l E -5 1111 :40

~#

In the Matter of

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y LONG ISLAND LIGHTING COMPANY

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Docket No.

50-322-OL-3

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(Emergency Planning)

(Shoreham Nuclear Power St4ttion.

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Unit 1)

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DIRECT TESTIMONY OF THOMAS D. CIBBONS ON BEHALF OF NEW YORK STATE REGARDING EMERGENCY PLANNING CONTENTION 66.D.

AGREEMENTS FOR SNOW REMOVAL AND EMERGENCY PLANNING CONTENTION 97.B.

EVACUATION DURING DEEP SNOW Q.

Please state your name, title, and address.

A.

My name is Thomas D. Gibbons.

I am a Transportation Maintenance Engineer III in the New York State Department of Transportation.

I hold the position of Regional Highway Maintenance Engineer in the Department's Region 10, which encompasses Nassau and Suffolk Counties. My business address is Highway Maintenance Group, New York State Department of Transportation, Suffolk State Office Building, Veterans' Memorial Highway, Hauppauge, New York *11788.

Q.

Please state your professional background.

A.

A statement of my qualifications and experience is attached hereto as Attachment A.

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b 0.

Please provide a brief background of your work experience as it portains to your testimony.

A.

For the past 17 years approximately, I have been responsible for highway maintenance, including snow and ice removal, in two positions in the Department's Region 10.

Region 10 covers Nassau and Suffolk Counties. For approximately 11 of those years I was the Resident Engineer for a

" residency", which is a geographical section of Long Island designated by the Department. My duties involved planning and assigning people, equipment, and materials to the various state highways and parkways in the residency, and evaluating the performance of all highway maintenance tasks.

For the last 6 years, I have been the Regional Highway Maintenance Engineer for Region 10. I now am responsible for nilocating all of the resources in all of the residencies in the region.

Q.

What is the purpose of this testimony?

A.

I will address Emergency Planning Contention 66.D and 97.B.

I will discuss the validity of these contentions as they pertain to the New York State Highways in and around the EPZ.

Q.

What is Contention 66.D?

'A.

Contention 66.D states:

The LILCO Plan does not provide for snow removal.

(See FEMA Report at 11, citing non-compliance with NUREG 0654,Section II.J.10.k).

Rather, the plan assumes that " snow removal will be provided by local organizations in their normal fashion during an emergency." (Plan at 2.2-5).

This assumption is unwarranted. LILCO has no agreements with local jurisdictions or other entities within and around the EPZ to provide snow removal services during an emergency, nor can it assure that local personnel assigned to snow removal duties will perform those functions during an emergency, for the reasons cited in Contentions 15, 25, and 27.

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f.

Q. -

Is Contention 66.D correct in claiming that LILCO evacuation procedures do not properly account for snow removal?

A..

Yes. Contention 66.D points to a defficiency in the plan in that the plan does not account for the problems of responding to adverse weather conditions during a radiolog1 cal emergency.

Q.

How do you define adverse weather conditions?

A.

I define adverse weather conditions as snow and ice storms.

Q.

How does the plan fail in its treatment of adverse weather conditions?

A.

The LILCO plan at 2.2-5 simply assumes that " snow removal will be provided by local organizations in their normal fashion during an emergency."

No grounds for this assumption are stated, nor do they exist. The New York State. Department of Transportation can not and does not commit that its personnel would in fact man snow removal equipment during a radiological emergency at Shoreham. Thus, there is no basis for the LILCO statement quoted above.

Q.

Will a radiological emergency at Shoreham Nuclear Power Station interfere with snow removal?

A.

Assuming for the sake of argument that the assumption in the LILCO plan is true ( and, as noted above, it is not true), My answer is yes, a radiological emergency at Shoreham will interfere with snow removal. Any snow storm on Long Island requires the Department of Transportation to mobilize all of its forces to either apply chemicals and abrasives

(rock salt and sand) to provide traction, or plow once the accumulation reaches a height of one to two inches. These operations are initiated from over twenty locations in Region 10 and are locally controlled from six key headquarters sites, called residencies. The key headquarters site for all of the Town of Brookhaven and everything east of there is located on County Road 58 in Riverhead about 8 miles from the Shoreham Nuclear Power Station.

If this headquarters were not usuable, because personnel assigned to work there could not get there or were required to leave, then cicarance of state highways in the EPZ would be nearly impossible. This facility is the major depot and control headquarters for our equipment and supplies in that area.

It would be impossible to transfer equipment from other Regional Headquarters into the EPZ as replacements for the equipment that is inaccessible during an evacuation. If a radiological emergency occurs, movements to and from the headquarters would be severely constrained. The headquarters may become inoperable if personnel cannot get to it or are afraid to use it because of tha radiological endangerment.

Another problem would probably be the reluctance of employees to perform snow and ice removal tasks in the EDZ during a radiological emergency.

Indeed, 20% of the employees supervised from that headquarters and their families live within the EPZ. They certainly would be concerned for them-selves and for families.

Any failure of employees stationed in this area te report for or remain at work would mean a reduction in service to state highways. Further, given highway congestion and fears of radiation, workers uho reside outside of the EPZ would likely be unwilling to remain within or to enteer the EPZ to perform snow removal. Certainly, the performance of snow removal in the face of radiation dangers is not part of their required jobs. Thus, in my opinion, there would be large gaps in the

available work force. They would be turned away at the EPZ boundary. The reduction in the number of personnel to operate the equipment due to these factors would severely limit the ability to remove snow from roadways.

Finally, the snow fall itself will at least double the travel times by halving the road capacities. This occurs in the absence of heavy traffic conditions. Heavy traffic conditions will lengthen the travel times even further.

Q.

What is Contention 97.B7 A.

Contention 97.B states: Pursuant to 10 CFR Section 50.47 (b) (10) the LILCO Plan must designate a range of protective actions appropriate to a variety of circumstances. See also NUREG 0654,Section II.J.9.

This includes unfavorable weathar. Yet the LILCO Plan's procedures for

. evacuation completely disregard the possibility of the existence of deep snow. SOC contends that the evacuation procedures outlined in the LILCO Plan would not work during a heavy snowfall, for the following reasons:

1.

Key LERO personnel would be unable to travel to the EOC, as required by the LILCO Plan at 3.3; 2.

Neither traffic guides, road crews, evacuation route spotters, ambulance drivers nor staging area coordinators would be able to travel to the staging areas as required by OPIP 3.3.3 and 3.6.3; 3.

Even if the persons listed in (2) above were to reach the staging areas, they would be anable to travel to their assigned posts / routes, as required by OPIP 3.6.3:

4.

Bus drivers and shuttle operators would be unable to travel to staging areas, as required by OPIP 3.6.4 and, in any case, would be unable to complete their assigned trips; 5.

Relocation center senff would be unable to travel to the relocation centers; and

6.

Members of the public will be unable to evacuate their homes or places of work.

Q.

Is 97.B correct in contending that LILCO evacuation procedures do not properly account for unfavorable weather, particularly deep snow?

A.

Yes. The LILCO evacuation estimates contain no provision for such unfavorable weather, particularly deep snow.

Q.

In your opinion, does unfavorable weather only include deep snow?

A.

No.

It has been my experience that weather conditions are not uniform throughsut the entire island.

It may be snowing heavily on the east end, sleeting in the middle. and raining on the west end.

Besides deep snow ice storms may occur. On January 13, 1978, a major combined ice and snow storm occurred that virtually paralyzed all transportation on Long Island. It not only coated the roads and made the roads slippery, but also caused power and other utility lines, limbs and trees to fall and block the roads. This required removal of the limbs, trees, wires, and debris before we could even start to apply chemicals and abrasives to provide traction and melt the ice, and then plow the snow.

It took 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months from the start of the storm to clear the state highways and parkways just in the Town of Hentington, which comprises an area roughly half the size of the EPZ.

During ice storms, it is frequently necessary to back spreader trucks up slopes while. spreading chemicals and abrasives to provide traction for g#

the spreader trucks to clinb the slope. This means we must stop all the traffic, turn the truck around and proceed up the slope backwards, and then

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return the truck to the forward position. We usually employ this precedure several times a year at certain hills, ramps, bridge approaches, etc.

Q.

What happens if there is a major snowfall on Long Island similar to the February 6-7, 1978 blie:ard of 25 inches or the February 11, 1983 snowstorm of 17 inches recorded at Rivethead Research Farms?

A.

When major storms such as the ones of February 1978 and February 1983 occur, we are very hard pressed to keep the highways open. During both of those storms, sections of the Long Island Expressway and other state routes and parkways were rendered impassible.

In general, any time there is heavy traffic (for enample at commuter rush hours) and a very heavy snowfall (10 to 12 inches or more's, or c snowf all of greater ther 6 inches and high winds, it fs probable that some portion of the highways will become completely impassible due to blockage of the roads resulting from stalled vehicles, accidents, and/or snewdrifts. Under such conditions, state roads become unavailable for an evacuation or for thet matter any movement.

4 During the snow storm of February 6-7, 1978 it took almost 19 days to restore fall pavement widths, which was only partial capacity, to a'.1 the stata routes in Suffolk County. Since 1976-77 in Suffolk County there has been as average of 17 storm's per year with measurabic precipitation, and of that 8 of which required plowing, of which 4 were major storms. During 3

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p this period, the average length of a snow storn was 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months with a high of I.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . The average time to clear all the pavement after the storm began was 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . The source of this information is storm logs emincained by the Department. This information is available to the public.

Q.

Do you have any cerclusions as a result of your consideration of Cortention 66.D and 97.B7 A.

Yes. The LILCO Pla. does oct adequately plan for the problems created by unfavorable weather, particularly deep enow and ice storms.

P h

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mW Resume Thomas D. Gibbons, P.E.

17 Woodward Parkway South Farmingdale, Long Island, New York 11735 Education:

Bachelor of Civil Engineering, Manhattan College, 1960 Master of Science in Civil Engineering, Polytechnic Institute of Brooklyn,1964

) thor Training:

U.S. Air Force (N.Y. Air National Guard)

Manual Telephone Central Office Equipment Specialist, Sheppard AFB, Tx, 6/14/61 ECI Course 3624 Telephone Installer Repairman, Gunter AFB, Alabama, 8/20/62 NCO Preparatory School, A.F. Logistics Consnand, Robbins AFB, Georgia 6/28/64 ECI Course 7521A Principles and Techniques of Instruction, Gunter AFB 3/2/66 Technical Instructor Course (NG) Lowry AFB, Colorado 7/8/66 New York State DPW - Fundamental of Supervision - 7/9/63 - 40 Hrs.

DPW - Instruction for Nuclear Radiation Monitors - 4 Hrs.

DPW - Record Sampling and Testing, Albany 4/15/66 - 32 Hrs.

DPW - Bituminous Plant Inspectors Course, Albany, 5/1966 - 32 Hrs.

DPW - Portland Cement Concrete Plant Inspectors Course, Albany, 1966 - 12 Hrs..

DCS - Case Studies in Supervision 12/1970 - 30 Hrs.

DOT - Managerial Skills, 11/1970 - 20 Hrs.

DOT - Report Writing for Supervisors, Nassau Co. Community College, 2/1971 - 40 Hrs.

DOT - Oral Presentation Techniques Workshop, Nass. "

2/1971 - 40 Hrs.

DOT - Maintenance Management Seminars, Albany, 7/1971 - 32 Hrs.

DCS - Labor Contract Administration SUNY, Farmingdale. 4/1973 - 8 Hrs.

00T - Beginning Shorthand, SUNY, Farmingdale, 3/1973 - 40 Hrs.

DOT - Effective Discipline, 10/1974 - 4 Hrs.

DOT - Effective Dictation, 4/1974 - 10 Hrs.

DCS - Transactional Analysis in Organizational Life - 1/22/75 - 18 Hrs.

00T - Supervisors Orientation to Equal Employment Opportunity - 3/75 - 8 Hrs.

DOT - (With FHWA) Bridge Inspectors Training Course, 1976. Albany - 36 Hrs.

DCS - Annual Budget Institute, 5/1977, Albany - 32 Hrs.

DOT - (With FHWA).- Traffic Control in Construction & Maintenance Work Zones, Albany, 4/1978 - 32 Hrs.

DCS - Project Management and Control, 1978 - 24 Hrs.

DOT - COGO Training Course, 5/1980 - 8 Hrs.

Farmingdale Adult Education - Speed Reading, 12/17/68 ASCE - Met. Section - Computer Fundamentals & Fortran Programming, 5/66 - 24 Hrs.

DCS - Perspectives on Labor Relations in the Public Sector - 6/82 - 24 Hrs.

utside Experience Stock Construction. Co., Field Engineer on Pile installations, Pier #40 (First Square Pier in Manhattan) 1958 W. E. Gunther Constr. Co., Surveyor, Take-Off Estimator, etc.,1959 Andrew Gruenwald Associates, Consulting Engr., P/T Designer 1964-5 N.Y. Air National Guard, T/Sgt. Inside Plant Flight, 213 GEEIA Sqdn., Telephone Central Office Equipment S?ecialist Nov.1960-Nov.1966 NYS D.C.S. (Civil Service) - Prepare Examination Questions for Municipality, 10/1969 Instructor in Religious Ed. Program, Holy Name of March Church, 1960-1961 St. Kliiar Church 1975 to Present

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"" Departmen t Exper sens e. '

i 6/30/60 Junior Engineer a signed to inspection duties on FALIE 59-1; Long Island Expres.way f rosii Jericho Ipke to South Oyster Bay Road I/18/61' Military L. eave - Active duty,with U.S. Air Force for NYANG Atter.d Man. Tel. C.O.-School and teach basic electricity

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and. renedial niath.

7/17/51 < Juniorstngineek - Reinstated assigned' to design group 10/61:

-Junior Engineer - Reassigned to construction as Inspector on FAWB 61-1 qWoodhaven Boulevard mduct Recon.9 Glendale Junction 11/30/61 Assistant Civil Engineer (Prov.)

Later assistant E.I.C. and finally E.I.C. at end of job.

6/14/62 Assistant C.E.

(Fer.n.-).

7/631 Finished FAWB 61-1 and assigned by A. E. Dickson to new "HURK" unit.

Review Consultant's records on Grand Central Parkway. Van Wyck Exp. A Whitestone) for adequacy of conformance to Fed. & NYS Specs to get Federal reimburse-ment.

Also helped develop MURK. Also EIC on 3+ landscape jobs in area.

c 6 Reassigned to Nassau-Suffolk Construction Office, Iabylon as assistant to Construction Engineer. ' Participated in training 301 inspectors:

" Basic Inspection of Construction Training" Course 9-1G/65 3/7/66 Prepared Special Report to Asst. District Engineer R. hallweg: " Report of Visual. inspection and Comparison of Plant Mix Shoulders and Run of Bank Asphalt (Misery Mix) Shoulders".

6/66 Set up and supervised Record Sampling and Testing Unit.

A d/4/66 Promoted to Senior Civil Engineer 8/23/67 Assigned as " Resident Engineer" for Nassau & West Suffolk Counties Residency (Senior Civil Engineer assigned to Residency ) - largest work load residency in the State, also most highways and traffic.

7/17/69 Title reclassified from Senior Civil Engineer to Resident Engineer - A (Three grades of RE: At 40 points. B= 20-39;<.< 20.

Average Points in State = 321;NSWS = 168 points).

5/73 Residericles realigned from 2 to 4 - RE of Nassau North 10/75 Residencies realigned from 4 to' 5 - pick up parkways of OPR 9/76 Residencies-realigned: OPR parkways included within geographic borders Nassau North picks up NSP & WSP 2/16/78 Became acting Regional Highway Maintenance Engineer - A - Pegion 10: L.I. & !!.Y.C.

3/20/80. - Becane RHME -'. A (Permanent) - to present - Reoion 10 i.icenses & Certificattow, Professional Enoineer (NY) 7/15/65 Certified Bridge Itispector (FHHA) 1976 flYt Association of TransportationJgineers SNYS/HE) Activities Fresident. Section 10 1966 & 67 Site Selection Consnittee Member for last Ccnferenco in fly City Conference El Technical Frocran Comittee Chairman Special Report to District Engineer t.it. Sarr on Dangers of DCMB in flassau County on fly 495 Delegate to several Conferences

th...w page-.l.

f Committees

~~~

ASTM - Special Report " Tentative Standards on Liquid Limit Testing" by Morris, Ulp & Spinner (1959)

NYSDOT - Pavement Maintenance Counittee (1973-1980+)

NYSDOT - Highway Maintenance Information Systems (1979-Present)

NYSDOT - Chairmun - Roadside & Drainage Panel,1980 Statewide Resident Engineer's Meeting CivicInvol!ements a President, Manhattan College Blood Bank (1959-60) Member (1956-1960)

Instructor, Religious Education Program - Holy Name of Mary Church 1960 St. Kilian Church 1975 - Present Grade Coordinator, 2 years (1976-1978)

Census Committee, 1975 Usher 1967-75 Advisor to Town of Oyster Bay Engineer on Neighborhood Road Project 1979 Assist Troop Leader of Brownie Troop 1971 - 74 Drop Off point for clothes; toys, etc. - Order of Preachers, Qu'een of Rosary Convent, Amityville Society Membershi>s NYSATE, Section 10 (1960 to present)

Member, ASCE - 1957 to present ASCE, Metropolitan Section - 1960 to present SAME (Soc. of Amer. Military Engrs.) - 1957 to present Society of Asphalt Technologists Organization of NYS Managerial / Confidential Employees NYS Employees Blood Bank Honors Awards. Comnendations, etc.

Honor Graduate Award, USAF, Sheppard Tech. Trng. Ctr., Sheppard AFB. Tx.,1961 Honor Graduate Award, USAF, AFLC NC0 Prep. School, Robbins AFB, Ga.,1964 Four " Gallon" awards, American Red Cross, Blood Bank donations Letter of Commendation from Comm. W. C. Hennessy, 1/27/78 re: NY City clean up George M. Briggs 1/26/78 Appreciation from Thomas B. Gould. Dep Dir. OGS: opening up Downstate Distribution Center fnr emergency food distribution 1/23/78 Letter of Appreciation from E. J. Tafuro, Rd. Comm. Vil, of Muttontown 2/27/78 re: help during past storms Commendation: Boy Scouts of America 1

h ~ '

UNITED STATES OF AMERICA W

NUCLEAR REGULATORY COMMISSION

~

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges RELATED CORRESPONDENCE Y,

James A.

Laurenson, Chairman Dr. Jerry R.

Kline Mr. Frederick J.

Shon

'84 MAR -5 All :41 In the Matter of

)

Docket No. 50-321-OLj3

.Mr'

)

(Emergency Plann'i6g"Rh,qqh'"hd[dg)

LONG ISLAND LIGHTING COMPANY

)

(Shoreham Nuclear Power Station, )

Unit 1)

)

March 2, 1984

)

CERTIFICATE OF SERVICE I hereby certify that one copy of the 1) DIRECT TESTIMONY OF WILLIAM J. ACQUARIO, RICHARD D. ALBERTIN AND ROBERT G.

KNIGHTON ON BEHALF OF NEW YORK STATE REGARDING EMERGENCY PLANNING CONTENTION 67, EVACUATION OF PERSONS WITHOUT ACCESS TO AUTOMOBILES, 2) DIRECT TESTIMONY JP WILLIAM J. ACQUARIO, RICHARD D. ALBERTIN AND ROBERT G.

KNIGilTON ON BEHALF OF NEW YORK STATE REGARDING EMERGENCY PLANNING CONTENTION 73, EVACUATION OF IIANDICAPPED PERSONS NOT IN SPECIAL y

FACILITIES, 3) DIRECT TESTIMONY OF THOMAS D.

GIBBONS ON BEHALF OF NEW YORK STATE REGARDING EMERGENCY PLANNING CONTENTION 66D, AGREEMENTS FOR SNOW REMOVAL AND EMERGENCY PLANNING CONTENTION 97B, EVACUATION D6 RING DEEP SNOW has caen served to each of the following this 2nd day of March, 1984 by U.

S. Mail, first class, except as otherwise noted:

I James A.

Laurenson, Chairman **

Ralph Shapiro, Esq.

l Atomic Safety and Licensing Board Cammer and Shapiro U.S. Nuclear Regulatory Commission 9 East 40th Street Washington, D. C.

20555' New York, New York 10016 Dr. Jerry R.

Kline**

Iloward L.

Blau, Esq.

Administrative Judge 217 Newbridge Road Atomic Safety and Licensing Board Ilicksville, New York 11801 U.S. Nuclear Regulatory Commission Washington, D. C.

20555 W. Taylor Reveley III, Esq.**

Ilunton & Williams Mr. Frederick J. Shon**

P. O. Box 1535 Administrative Judge 707 East Main Street Atomic Safety and Licensing Board Richmond, Virginia 23212 U.S. Nuclear Regulatory Commission Washington, D. C.

20555

i 2-

~

Mr. Jay Dunkleberger Marc W. Goldsmith New York State Energy Office Energy Research Group, Inc.

Agency Building 2 400-1 Totten Pond Road Empire State Plaza Waltham, Massachusetts 02154 Albany, New York 12223 MHB Technical Associates James B.

Dougherty, Esq.

1723 Hamilton Avenue, Suite K 3045 Porter Street, N. W.

San Jose, California 95125 Washington, D.

C.

20008 l

Honorable Peter F. Cohalan Mr. Brian McCaffrey Suffolk County Executive Long Island Lighting Company H.

Lee Dennison Building Shoreham Nuclear Power Station Veterans Memorial Highway P.

O.

Box 618 Hauppauge, New York 11788 North Country Road Wading River, New York 11792 Ezra I.

Bialik, Esq.

Assistant Attorney General Martin Bradley Ashare, Esq.

Envirom.aental Protection Bureau Suffolk County Attorney New York State Department of Law H.

Lee Dennison Building 2 World Trade Center Veterans Memorial Highway New York, New York 10047 Hauppauge, New York 11708 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S.

Nuclear Regulatory Commission U.S.

Nuclear Regulatory Commission Washington, D.

C.

20555 Washington, D.

C.

20555 Stewart M. Glass, Esq.**

Docketing and Service Section Regional Counsel Office of the Secretary Federal Emergency Management U.S.

Nuclear Regulatory Commission Agency 1717 H Street, N.W.

26 Federal Plaza, Room 1349 Washington, D.

C.

20555 New York, New York 10278 Bernard M.

Bordenick, Esq.**

Nora Bredes David A.

Repka, Esq.

Executive Director U.S. Nuclear Regulatory Commission Shoreham Opponents coalition Washington, D.

C.

20555 195 East East Main Street Smithtown, New York 11787 Stuart Diamond Environment / Energy Writer Eleanor L.

Frucci, "sq.**

NEWSDAY Atomic Safety and Licensing Long Island, New York 11747 Board Panel U.S.

Nuclear Regulatory Commission Stephen B.

Latham, Esq.

Washington, D.

C.

20555 Twomey, Latham & Shea P. O.

Box 398 33 West Second Street Riverhead, New York 11901 l

l i

o

. Herbert H.

Brown, Esq.**

Lawrence Coe Lanpher, Esq.

Karla J. Letsche, Esq.

1900 M Street, N.

W.,

Suite 800 Washington, D. C.

20036 Spence Perry, Esq.

Associate General Counsel Federal Emergency Management Agency Washington,.D. C.

20472

(

,<,,,1 RICHARD J.

ZAHNLEUTER Assistant to the Special Counsel to the Governor of the State of New York Executive Chamber State Capitol Albany, New York. 12224 i

By Hand

- By Federal Express on March 1, 1984

- - By Telecopier

- ****By U.S.

Express Mail Albany, New York March 2, 1984

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ML20086T313

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