ML20086U135
| ML20086U135 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/02/1984 |
| From: | Cordaro M, Lieberman E, Lieverman E, Varley R, Weismantle J LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20086U072 | List: |
| References | |
| OL-3, NUDOCS 8403070171 | |
| Download: ML20086U135 (28) | |
Text
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LILCO, March 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning Proceeding)
(Shoreham Nuclear Power Station, )
Unit 1) )
TESTIMONY OF MATTHEW C. CORDARO, JOHN A. WEISMANTLE, EDWARD B. LIEBERMAN AND RONALD A. VARLEY ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTION 27 Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 (804) 788-8200 B403070171 840302 PDR ADOCK 05000322 T PDR
LILCO, March 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board l
j In the Matter of )
)
, LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
, ) (Emergency Planning Proceeding) j (Shoreham Nuclear Power Station, )
Unit 1) )
TESTIMONY OF MATTHEW C. CORDARO,
! JOHN A. WEISMANTLE, EDWARD B. LIEBERMAN AND RONALD A. VARLEY ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTION 27 PURPOSE Contention 27 asserts broadly that the time needed to mobi-lize LERO Workers will not permit the timely implementation of the LILCO Transition Plan. The Contention raises specific concerns about the distance emergency response personnel will need to
, travel to their initial reporting locations, the time those trips will take, the time needed to process LERO workers through the three staging areas, the time required to pick up. emergency vehi-cles such as buses, tow trucks and fuel trucks, and the time needed for people to drive from staging areas to their assignment posts. The testimony demonstrates that these concerns are without merit, and that the LILCO Transition Plan'can be carried out as
- designed.
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The LILCO Transition Plan has been designed to permit a flex-ible response to a broad spectrum of potential accident scenarios.
The Plan provides for a sequenced mobilization of emergency workers depending on the event classification of a given accident.
This sequencing permits an ordered and timely response to many accident scenarios.
LILCO's planning effort has not stopped merely at the design of an emergency plan. Instead, the Plan has been continually scrutinized, and a variety of drills and exercises have been con-ducted to test its implementability. This effort has proved use-ful in reducing the time needed to complete many mobilization -
steps. For example, LERO workers have been paired with certain staging areas to reduce the distance and time they need to travel.
Call out lists have been ordered based on workers proximity to their reporting location. Staging area activities have been closely examined and many time-saving changes have been made. Bus companies, staging areas and transfer points have been carefully paired to ensure that buses will arrive in a timely manner throughout the EPZ. Finally, the three staging areas have been assigned continguous areas of responsibility, thus minimizing the distances between staging areas and emergency assignment loca-tions.
LILCO is committed to continue this ongoing assessment of the emergency plan, and to make changes where warranted to improve its implementability.
LILCO, March 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3 (Shoreham Nuclear Power Station, )) (Emergency Planning Proceeding)
Unit 1)
)
JOHNTESTIMONY OF MATTHEW C.CORDARO, A. WEISMANTLE, EDWARD B.
AND RONALD A. LIEBERMAN COMPANY ON PHASE II EMERGENCY N 27 PLAN TESTIMONY 1.
Q. Please state your name and business address.
A. [Cordaro]
My name is Matthew C. Cordaro.
My business address is Long Island Lighting Company, 175 Old Country Road, Hicksville, New York, 11801.
[Weismantle)
My name is John A. Weismantle. My business l address is Long Island Lighting Company,
{
100 Old Country Road, Hicksville, New York, 11801.
[Lieberman) My name is Edward B.
Lieberman. My business address is KLD Associates, Incorporated, 300 Broadway, Huntington Station, New York, 11746.
[Varley] My name is Ronald A. Varley.
My business address is Impell Corporation, 225 Broad Hollow Road, Melville, New York, 11747.
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- 2. Q. Please summarize your professional qualifications and your role in emergency planning for the Shoreham Nuclear Power Station.
A. [Cordaro] I am Vice President, . Engineering, for LILCO.
! My professional qualifications are being offered into evi-dence as part of the document entitled " Professional Qual-
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i ifications of LILCO Witnesses." I am participating on this panel to provide the LILCO management perspective on Emergency Planning, and to answer any questions pertinent
- to management. My role in emergency planning for Shoreham is to ensure that the needs and requirements of emergency planning are being met, and that the technical direction and content of emergency planning are being conveyed to i
corporate management.
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[Weismantle] I am Manager of the Local' Emergency Response Implementing Organization for LILCO. My professional 4
i qualifications are being offered into evidence as part of
- the document entitled " Professional Qualifications of LILCO Witnesses." My familiarity with the issues sur-rounding this contention stems from work in developing and implementing the Local Emergency Response Plan for Shoreham.
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[Lieberman] I am Vice President of KLD Associates,-Incor-porated. My professional qualifications.are being offered into evidence as part of the document entitled.
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" Professional Qualifications of LILCO Witnesses." My familiarity with this contention stems from work KLD Asso-ciates has performed for LILCO on evacuation time esti-mates for the Shoreham EPZ.
[Varley] I am Manager of the Training Division of the Local Emergency Response Implementing Organization (LERIO) of the Long Island Lighting Company. -My professional qualifications are being offered into evidence as part of the document entitled " Professional Qualifications of LILCO Witnesses." As Manager of the Training Division, I have been generally responsible for supervising and l coordinating the development of the LERO training program
- as well as for its administration. My familiarity with the issues raised in Contention 27 stems from my work with LERO personnel during drills and exercises.
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- 3. Q. Please summarize the issues raised by SC Contention 27.
A. [Cordaro, Weismantle, Lieberman, Varley] Suffolk County Contention 27 questions whether the mobilization of LERO workers can be completed in a sufficiently exp,editious manner to permit the planned implementation of the LILCO' i
l Transition Plan. Specifically, Contention 2'7 states:
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Preamble to Contention 27. Once cffsite emergency response personnel are notified of an emergency and instructed as to their assigned functions,8/ necessary emergency actions cannot be taken by those workers, (and therefore many recommended protective actions cannot be taken by the public) until the response personnel report to their assigned locations, obtain the equipment or vehicles they will require to perform their assigned roles, and report to their emergen-cy posts or dispatch locations. The activi-ties that take place between the determina-tion that particular offsite emergency response personnel should be notified and the reporting of such personnel, with neces-sary equipment, to the locations where emer-gency functions will be performed, are referred to herein as " mobilization" activi-ties.
Contention 27. LILCO assumes that LILCO and non-LILCO employees will be available to implement command and control directives.
However, the emergency response work force upon which the Plan relies will not be promptly available to perform the duties and emergency response functions assigned to them under the LILCO Plan due to extended mobilization times. Although the LILCO Plan fails to provide estimated notification or-mobilization times for emergency response personnel (see e.g., NUREG 0654 Section II.C.l.), Intervenors contend, based on sur-veys of emergency mobilization of the Suffolk County Police Department, that LERO mobilization will take at least several hours. In some cases, detailed in para-graphs A through F_below, mobilization will take even longer because after having been notified of an emergency, workers will have to travel substantial distances, in con-gested traffic, and will have to obtain nec-essary equipment, before they report to 8/ See Contention 26 which sets forth the reasons prompt notification will not occur under the LILCO Plan.
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their assigned posts to perform emergency functions. As a result of the extended mobilization times, the LILCO Plan, and the protective actions contemplated therein, cannot and will not be implemented in a timely manner necessary to provide adequate protection to the public. The Plan thus fails to comply with 10 CFR Sections 50.47(a)(1), 50.47(b)(1), 50.47(b)(3),
- 50.47(b)(8), 50.47(b)(9), and 50.47(b)(lO) and NUREG 0654 Sections II.E.2, F.1.e, H.4, and I. The reasons for extended mobiliza-tion times are stated in paragraphs A through F below.
A. Many emergency response personnel, !
i particularly those employed by LILCO, live and/or work substantial distances from the EPZ or other emergency services locations.
B. Emergency response personnel will have to travel through congested traffic result-ing from public mobilization and evacuation travel, in order to get from their locations upon notification to their initial reporting locations.
C. Many emergency response personnel must
, report first to a " staging area" or " dis-patch location" and then to an assigned post (see OPIP 3.3.3), which will require addi-tional travel through congested traffic.
Furthermore, once at the staging areas.LERO j workers with field assignments will have to j pick up personnel dosimetry and receive l
briefings before they leave for their posts, and many LERO workers, such as traffic
, guides and route alert drivers, will also l have to obtain and install in their vehicles l equipment such as mobile radios and public address systems. (OPIP 3.3.4; OPIP 3.6.3; OPIP 3.6.4.)
D. Many emergency response personnel must travel-from their notification locations to other locations to obtain equipment or vehi-cles after reporting to staging or dispatch t locations. Thus, road crews must obtain tow i trucks and other equipment.from LILCO stor-l age locations which are spread throughout Suffolk and Nassau Counties (OPIP 3.6.3);
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i fuel truck drivers must obtain fuel trucks, go.to storage tanks, and fill the trucks with fuel (OPIP 3.6.3); route alert drivers must obtain vehicles and mount loudspeakers on them (Plan.3.3-4; OPIP 3.3.4); bus driv-ers must be transported from staging areas to bus garages, gain access to the buses, i
and prepare the buses for use (e.g., by obtaining gasoline and checking oil (see OPIP 3.6.4, at 10)). In addition, proce-j dures for locating necessary equipment, such
. as buses and trucks, will require time and i will further delay the efforts of response personnel to obtain such equipment. (Seo OPIP 3.6.4).
E. Emergency response personnel must l
travel from staging or dispatch locations, through congested traffic, to reach the posts where they are to begin to perform their emergency functions.
F.~ Many emergency response personnel
- (e.g. traffic guides, bus drivers, and ambu-lance companies) are not contacted or expected to report to field locations until
- the Site or General Emergency Level, as sug-
'3 gested in the Plan (see Plan,. Figures 3.3.2, 3.3.3, 3.3.4). Mobilization times for such workers will be even more extended because
- the level.of traffic congestion encountered by them will be substantially greater.
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- 4. Q. Could you summarize the scope of this testimony?
A. [Cordaro, Weismantle,-Lieberman, Varley] This testimony will begin by providing a general explanation of the mobi-lization of LERO should an emergency develop at the Shoreham plant. 'Thectestimony will then address the six specific concerns raised'in Contention 27: (1)'the dis-
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I tance LERO Workers.will have to travel toitheir' initial l I
reporting location; (2) the time-it-will take LERO workers'
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to travel to this reporting location; (3) the time required to process, brief and dispatch LERO workers from l
staging areas; (4) the time needed to obtain special emer-gency response vehicles like buses, fuel trucks and tow trucks; (5) the time needed for LERO workers to travel from their staging area to their duty locations; and (6)
- the effect of some LERO workers' reporting at the Site a Area Emergency level. Finally, this testimony will pres-ent the results of studies of the time needed to complete certain mobilization steps, and will relate these data to 4
the implementation of the LILCO Transition Plan.
This testimony will address only those steps in the i mobilization process following the initial notification of LERO workers. The notification of LERO workers is the i
subject of Contention 26. Separate testimony on that con-tention is also being filed by LILCO today.
- 5. Q. Could you summarize your conclusions with regard to Con-
, tention 27?
A. [Cordaro, Weismantle, Lieberman, Varley] The mobilization of LERO workers is unlikely to affect the. timely imple-mentation of the LILCO Transition Plan except under the most extreme circumstances -- for example, when a recom-mendation to evacuate is made simultaneously with the~ini-tial declaration of an emergency. Even under that circum-4 stance, an evacuation could be successfully completed,
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although perhaps not in the times currently listed in the LILCO Transition Plan.
i LILCO has continuously attempted to lower mobilization times and hence ensure the efficient implementation of the LILCO Transition Plan. As exercises and drills have been conducted, improvements in the mobilization of LERO workers have been identified and steps have been taken to implement them. This has been, and will continue to be, an ongoing process; as further drills are conducted, LILCO will revise either the Plan or its procedures to continue to minimize mobilization times consistent with the effi-cient implementation of the Plan, and to improve the
- Plan's flexibility.
The LILCO Transition Plan already contains a number of-features designed to minimize LERO mobilization times.
These features include the location of the three staging areas which serve as the reporting and dispatch locations for the majority of LERO workers, the distribution of responsibilities among staging areas, the activation of the EOC and staging areas at an Alert stage, and the preplanned matching of staging areas and bus companies to minimize bus procurement times.
l With regard to the specific concerns raised in Conten-l tion 27, LERO workers have generally been assigned to.the l
closest staging area, thus minimizing the distance and l
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time each LERO worker will travel to reach his/her staging area. In addition, call out lists have been ordered in a manner which will normally allow the workers closest to each staging area to be contacted first. The time needed to process LERO workers through a given staging area has been reduced by applying knowledge obtained from drills and exercises. For example, the procedures for disbursing dosimetry were revised to reduce inefficiencies. The time I required to procure special vehicles needed to aid the evacuation process has been shortened by matching vehicle locations with respective staging areas to minimize travel distances. Finally, the staging area locations and the division of responsibilities among staging areas ensure that LERO workers' trips from their staging areas to their assignment posts will be as short as possible.
- 6. Q. Please describe the sequence of events in the mobilization of LERO workers.
A. [Cordaro, Weismantle, Varley] The sequence of events in the mobilization of LERO workers is keyed to the declara-tion of an emergency at Shoreham nuclear power plant. The degree of LERO mobilization is dependent on the classifi-cation of-the emergency. At the lowest classification (Unusual Event), seven members of LERO are placed-on standby; the remainder of LERO is unaffected by.this event level. At an-Alert, 94 members of the LERO staff report
to their pre-assigned duty station or staging area. At a Site Area or General Emergency, LERO is fully mobilized (see OPIP 3.3.3, Attachment 1, pp. 1-3).
When an Unusual Event has been declared, the Customer Service Operator, or designee, activates the pagers of the seven members of LERO who go on standby. This group con-sists of the Director of Local Response, the Manager of Local Response, the Lead Communicator and four functional coordinators (see Elan, Figure 3.3.2; OPIP 3.3.2, p. 2).
After an Alert has been declared, the Customer Service Operator, or designee, activates the pagers of the seven LERO members placed on standby at the Unusual Event plus those LERO members shown on Checklists 2 and 3 of OPIP 3.3.2 (OPIP 3.3.2, pp. 19-39). Upon this notification, these LERO personnel will report to their assigned emer-gency facility (see Plan, Figure 3.3.3). All individuals assigned to the EOC at Brentwood will assume their assigned responsibilities and will activate the EOC. To facilitate a rapid response capability at the staging areas, certain key staging area personnel are also mobi-lized. These positions are:
Staging Area Coordinator Lead Traffic Guide Bus Dispatcher Dosimetry Record Keepers Staging Area Staff-Route Alert Drivers.
Following the arrival of these personnel at each staging e
area, steps will be taken to ready the facility should the ,
I situation escalate to a Site Area or General Emergency, l which would necessitate the full staffing and potential dispatching of personnel from the staging areas. These preparatory steps include: establishing communications with the EOC, preparing dosimetry for distribution, setting up briefing areas and status boards, and readying field equipment for distribution. Route alert drivers are notified, through a combination of pagers and a telephone call out process, to report to their assigned staging area at an Alert. These workers are mobilized at this accident stage to ensure that they are prepositioned at the staging area should potential siren failure later occur.
Following the declaration of either a Site Area or a General Emergency, the Customer Service Operator, or the !
Lead Communicator, if the EOC is activated, follows the procedure set forth above and begins the notification of the remaining LERO personnel. (See Plan, Figure 3.3.4; OPIP 3.3.2, Section 5.3). Having received notification, l l
the remaining LERO personnel report to their assigned facility. Bus drivers, traffic guides, route spotters and road crew personnel will be processed at staging areas as they arrive and will be given their dosimetry. If the situation does not require these individuals to be dis-patched at this point, they will be held on standby at the
staging area. Should the situation indicate the immediate need for implementing field activities or for the procure-ment of emergency vehicles, the arriving personnel will be l briefed, given their appropriate equipment and dispatched from the staging area in a continuing process until all necessary field positions have been staffed.
- 7. Q. Why was this mobilization sequence chosen instead of perhaps requiring all LERO workers to report to their assigned location at an Alert stage as is suggested in Contention 27.F?
A. [Cordaro, Weismantle] Certain activities such as driving bus routes and guiding traffic are evacuation-specific.
That is, these activities would only be required if the emergency were of such a magnitude as to require a classi-fication of General Emergency where evacuation was the recommended protective action. Thus, it was decided that positioning these individuals at emergency facilities at -
an Alert classification would be inappropriate. As was
! discussed above, the advance preparations that occur at an.
l Alert stage act to accelerate the processing and dispatch-ing of those LERO workers who report at a Site Area Emer-l gency level, thus minimizing the effect of the latter mo-l bilization.
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, 8. Q. The preface to the subparts of Contention 27 refers to the i ability of non-LILCO employees to i.nplement command and control directives. How has the mobilization of these individuals been considered in the LILCO Transition Plan?
A. [Cordaro, Weismantle) Non-LILCO involvement in the LILCO Transition Plan is limited primarily to four major groups:
the Coast Guard, the DOE / RAP team, the Red Cross and ambu-lance and ambulette companies. The Coast Guard, the DOE / RAP team and the Red Cross are all initially notified at an Alert level. Plan, Figure 3.3.3. This notification should occur well in advance of when these organizations will be needed to carry out their assigned duties. The Coast Guard will begin its notification of boats at the Site Area level; the DOE / RAP team will generally begin its monitoring at the Site Area level; and the Red Cross will not need to have its relocation centers ready for use until at least an hour after the order to evacuate is given. ln all of these cares, sufficient time should exist between the initial notification of these groups and the time they are expected to perform their evacuation roles to ensure that those roles will be performed in a j timely manner.
Ambulance and ambulette companies will be contacted at a Site Area level and asked.to have their drivers take all available ambulance and ambulettes to the appropriate l
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' staging area. The times needed to contact-drivers, to pick up ambulances and ambulettes, and to drive to the l
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l staging area have been included in the time estimates for i the evacuation of the handicapped at home and of special i
facilities. Thus, the mobilization of this group has been considered explicitly in the preparation of the LILCO Transition ?lan.
- 9. Q. With regard to the concerns raised in Subparts A and B of Contention 27, what steps have been taken to minimize the distance and time LERO workers will have to travel to reach their initial reporting locations?
A. [Cordaro, Weismantle] Travel distances and travel times were reduced in two ways: first, staging area assignments were premised on the location of LERO workers' homes, and second, call out lists were ordered to permit those l
workers living closest to a given staging area to be called first. The staging area assignment for a given LERO worker was based on two factors: first, the distance the worker would need to travel to reach the staging area; and second, the need to provide an approximately equal distribution of workers among the three staging areas. As a general rule, LERO workers from the east of Shoreham l were assigned to the Riverhead staging area; those from l
l the west to the Port Jefferson staging area; those from the south to the Patchogue staging area.
In general, call out lists have been ordered in terms of proximity for both emergency facility and job function.
, In other words, LERO workers of a given job classification l
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who live the closest to a given staging area will be the first names on a call out list. There are minor excep-tions to this general proposition. The most noteworthy of these is that in some instances, call out lists have been arranged by LILCO departments, where those departments serve a single job function. This has been done only at the specific request of those departments which, for orga-nizational purposes, have expressed a desire to have their department members on the same call out list. In those cases, the call out lists will again be arranged by prox-imity.
- 10. Q. Will the travel of LERO workers to their initial reporting locations conflict with people attempting to evacuate the EPZ?
A. (Cordaro, Weismantle, Lieberman) No. The basic reason for this absence of conflict is that all LERO workers will be paged and/or called to their duty station or staging area at a Site Area Emergency or earlier whereas an 1
evacation would normally not begin until some time l later -- after a General Emergency has been declared and an order to evacuate has been given. In addition, the initial reporting location for these LERO workers will in virtually all cases be the EOC or one of the three staging areas. All of these facilities are located outside the EPZ. Accordingly, the possibility of conflicts between these workers and evacuees is very low.
l 11. Q. In Subpart C to Contention 27, Suffolk County lists a series of events that will take place at a staging area that it alleges could delay the deployment of LERO workers. What steps have been taken to minimize delays at J
the staging areas?
A. [Cordaro, Weismantle, Varley) The principal activities at staging areas include the briefing and dispatching activi-ties required to implement the LILCO Transition Plan. To facilitate deployment of LERO field personnel, activities at the staging area have been scrutinized and continually refined during the drill program to minimize any inherent delays.
As was explained above, key staging area personnel will report to the staging area at the Alert stage to prepare the facility and equipment for possible use should the emergency escalate. This change was made in Revision 3 to the LILCO Transition Plan. This action allows LERO per-sonnel to be ready to process, and to have ready for dis-patch, field personnel as they report to the facility, thus eliminating potential delays related to the activa-tion of the facility. In addition, drill information has been used to streamline many other steps that occur at a staging area. For example, distribution of dosimetry to field personnel has been simplified through refinements to dosimetry forms, modifications to facility layouts, and the addition of more dosimetry record keepers at each staging area. The prepackaging of the packets provided to
i the various field groups (including traffic guides and bus drivere) has helped reduce briefing times to a minimum.
At each staging area, special LERO equipment storage trailers have been positioned to permit the rapid distri-bution of field equipment to LERO personnel. Finally, the installation and use of portable radios by traffic guides have been practiced at every LERO drill in which traffic guides have participated. This process has been refined l 1
to the point that it adds almost no additional time to de-ployment efforts.
In summary, through practice and the practical experi-ence gained by all staging area personnel during drills and exercises that have been designed to simulate as l closely as possible actual emergency conditions, the entire staging area process, from first activation of the facility through its deactivation, has been optimized to ensure that the transition from staging area to the field will be a smooth and rapid process for all'LERO field per-I sonnel.
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- 12. Q. How does the LILCO Transition Plan minimize the amount of time needed for LERO workers to obtain equipment, such as l buses, fuel trucks or tow trucks?
A. [Cordaro, Weismantle, Lieberman, Varley] The process of implementing bus services for the general public in the 10-mile EPZ has been carefully planned and orchestrated.
Numerous considerations were involved in arriving at the l
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l current set of procedures which direct this activity. In i order to minimize the mobili ation time for bus drivers, timing and distance factors were correlated to provide a
- cohesive, rapid response.
I At an Alert stage, the Bus Coordinators and their sup-port staff begin making verification calls to each bus company that has contracted to provide buses to LERO.
These verification calls identify the exact numbers of immediately available buses and their location. In addi-tion, the calls also reveal when additional buses will be-come available. At the same time at the three staging areas, bus dispatchers begin to unpack and prepare instruction packets and bus route maps for the bus driv-ers; dosimetry record keepers prepare equipment and forms in anticipation of drivers' arrival; communications be-tween the staging area staff and the EOC are established.
All of this advance preparation assures minimum delay time for bus drivers at a staging area should the emergency-escalate and an evacuation become.necessary.
At the declaration of a Site Arca Emergency, bus l
drivers and transfer point coordinators are notified and they report to their assigned staging areas. Upon arrival-4 at the staging area,'each individual is issued and briefed on the use of personal-dosimetry. The bus drivers and transfer point coordinators then immediately proceed to a i
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l briefing conducted by the bus dispatcher. At this briefing, the drivers are given information on radiolog-ical conditions and receive bus company and transfer point assignments. Following this short briefing, the drivers L
leave the staging area and proceed to their assigned bus company storage location. Transfer point coordinators also leave the staging area and proceed directly to their assigned transfer points, where they prepare for the arrival of buses.
The identification of bus storage locations is an activity that has been undertaken well in advance of an emergency. Bus company storage locations have been l matched with staging areas and transfer points. This matching was based on an evaluation of bus availability and of travel times between staging areas and bus storage locations and between storage locations and transfer points. The results of this evaluation were used to pro-
! duce optimal mobilization sequences and to match bus com-I pany storage locations with given staging areas. The telephone calls that will be made by the Bus Coordinator during an Alert serve to verify these preplanned matching efforts and to ensure that there will be no wasted time in the implementation of the bus plan.
l The first drivers released from a staging area will be l
j directed to the closest bus storage location and so on.
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This assignment process should ensure that the early scheduled bus runs are properly manned. Once a bus driver has arrived at the bus storage location and picked up his/her bus, the driver will then proceed to the desig-nated transfer point to await dispatching by the transfer point coordinator following an order to evacuate.
The time required for LERO road crews to obtain tow trucks, or an acceptable alternative, and fuel trucks present fewer logistic problems since these LERO workers will need only to procure LILCO's own equipment. In all probability, if a Site Area Emergency were to occur during a work day when these vehicles were in use, the LILCO drivers then in the vehicles would be directed to take their vehicle immediately to the appropriate staging area.
In the numerous cases where the driver is also a LERO worker, there is a high probability he would be assigned to the vehicle he had been driving; thus, the acquisition I
step is removed from the process. If the LILCO driver is not a LERO worker, the appropriate LERO worker would be told to report to the staging area where he would simply pick up the vehicle he would be assigned during the evacu-ation.
If a Site Area Emergency were declared when the vehi-cles were not in use, then their location-wculd be already j known within LILCO. In that case, LERO road crews would l
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I either be instructed to pick up their vehicle prior to j reporting to the staging area, or to proceed to the staging area first, depending on their proximity to the vehicle storage area and the staging area. In either case, the time for these two mobilization steps would be minimized.
- 13. Q. Will LERO workers be delayed by traffic congestion on their trips from their staging areas to their emergency posts?
A. [Cordaro, Weismantle, Lieberman] No. As was explained in response to Question 10 above, the staging areas and dis-patch locations for LERO workers are generally located outside the EPZ. Thus, these workers will be moving counterflow to nornal evacuation traffic.
In addition, an can be seen on Attachment 4 to LILCO's testimony on Contentions 28 through 32 and 34, traffic control point and transfer point assignments are based on specific staging areas. These staging areas have been located just beyond the western, southwestern and eastern boundaries of the EPZ. Each staging area has been as-signed roughly equivalent numbers of LERO workers, and each will be given the responsibility for servicing con-tiguous areas within the EPZ. Thus,.the distance that a LERO worker will need to travel between the staging area and his/her evacuation post has been minimized.
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- 14. Q. Have any efforts been made to measure the time needed to complete the various steps in the mobilization of LERO ,
workers?
l A. [Cordaro, Weismantle, Varley] Yes. Tc verify the times associated with the various steps in LERO mobilization process, data have been collected during drills and exer-cises. Since these drills and exercises have focused, to date, on specific parts of the mobilization sequence, and have not simulated the entire mobilization sequence, the data are limited in their scope. Examples of the types of data that have been collected include:
- 1. A survey of response times for LERO per-sonnel to travel from their homes or work location to their assigned emergency facility;
- 2. Various activity times associated with staging area operations (i.e., dosimetry distribution, briefing times, dispatching times);
- 3. Travel times for bus drivers between all possible combinations of staging areas and bus companies and of bus companies and transfer points; and
- 4. Travel times for traffic guides between l staging areas and their traffic control posts.
j 15. Q. What were the results of these data collection activities?
A. [Cordaro, Weismantle, Varley] The results indicate:
- 1. The times needed for EOC workers to travel from their home or work locations to the EOC averaged approximately 30 minutes from home and 40 minutes from work locations;
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- 2. The travel times needed for LERO workers assigned to staging areas to report to their assigned staging area averaged 60 minutes both from home and work locations;
- 3. The time needed to distribute dosimetry equipment at staging areas averaged 15 minutes per briefing group;
- 4. The time needed to conduct job-specific briefings (i.e., bus drivers, traffic guides, route alert drivers) at a staging area average 15 minutes per briefing group.
- 5. The time needed to dispatch LERO workers from the staging area generally averaged 5 minutes. Traffic guides took slightly longer (10 minutes), since they needed to obtain their necessary equipment.
- 6. The study of travel times between staging areas and bus companies and between bus companies and transfer points produced a" matrix of travel times. This matrix shows that travel times from staging areas to bus companies vary from 3 to 66 minutes and from bus companies to' transfer points from 1 to 66 minutes.
- 7. The travel times for' traffic guides to travel from their staging aree.c to their assigned control points varied from 5 to 40 minutes, with an average travel time of approximately 20 minutes.
It'should be remembered that these times are-for indi-vidual steps in integrated sequences of events, and do not l
indicate the results of the entire sequence precisely. In addition, these data have been'taken at drills.and exer-I
[ cises held to date. It is expected that with more l
training exercises ~and drills, times may be somewhat lower and that the range of variability among times will de-crease. -
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- 16. Q. Do these results suggest that the LILCO Transition Flan can be carried out exactly as designed?
A. [Cordaro, Weismantle, Lieberman, Varley] This question cannot be easily answered since it requires some presump-tions about a hypothetical accident and the time between event levels for that accident. Nevertheless, based on the information that.has been accumulated to date, some general conclusions can be drawn about the timely implica-tion of the LILCO Transition Plan.
If it is assumed that the accident sequence will permit all the steps contemplated by the LILCO Transition Plan for each event level to be completed prior to the occur-rence of the declaration of the next higher event level, -
then the Plan can be implemented exactly as designed. In other words, if the EOC can be activated and the staging areas readied at an Alert stage, and the remainder of LERO workers, including traffic guides, bus drivers, route spotters and road crews, can be given their dosimetry and briefed at staging areas during a Site Area: stage,'then the Plan can be implemented exactly as designed' and the ,
evacuation times presented in Appendix A can be realized.
From the da'ta' currently available, the-time needed, from the. initial declaration of an Alert, to activate the EOC and'to ready staging areas 13.1 1/2 to.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Following.
the declaration of a Site Area Emergency,'the time needed.
for a sufficient number of LEROLworkers to be processed
__m____ .__._ . _ _ . _ . . - - - -
4 through a staging area and to be ready for dispatch is t-
.approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
If the speed of the accident does not permit this orderly implementation of the LILCO Transition Plan, then it becomes more difficult to access the effects on the j Plan, given the multitude of potential accident scenarios.
However, some general observations can be made. Should an accident escalate from an Aly--t to a Site Area Emergency before the full staffing and activation of.the EOC and the l preparation of staging areas, those activities could pro-
- ceed simultaneously with the early mobilization steps of the remaining LERO workers, since those steps involve the notification and travel of those workers to their emer-gency facilities. Thus, the-time between the declaration
?
of an Alert and the decluration of a Site Area Emergency can be compressed without an effect'on the implementation l
of the' Plan.
Similarly, the time between'the declaration of a Site Area Emergency and the declaration of an order to evacuate i
can be compressed.and the Plan can still be. carried out essentially as designed. For example, all traffic guides need not be ready to depart the staging area at the time-an order to evacuate is given. - The modeling work in Appendix A assumes'that traffic guides will be in place when congestion begins to occur approximately one hour' 1
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1 g p- ,
g y ,e- --
e + y
, l
! i after the order to evacuate. In addition, Figure 8.3 of Appendix A (also Attachment 7 to OPIP 3.6.3) prioritizes the sequence in which traffic control posts are manned.
The reason for this prioritization is to ensure that the traffic control posts, and special traffic control strategies associated wiyh those posts, having the greatest effect on evacuation times are manned, or imple-mented, first.
Certainly, at some point, an accident becomes too rapid to implement the Plan, in all its aspects, literally. In those situations, the conclusion is not that emergency planning is impossible, but rather that the Plan must be
- flexible enough to account for those situations as needed.
This conclusion is entirely consistent with the guidance of NUREG-0396 which provides-that no specific accident sequence should serve as a basis for an emergency plan.
NUREG-0396, pp. 4-5. Instead, that report concludes "that the objective of emergency response plans should be to
, provide dogs savings for a spectrum of accidents that I
could produce offsite doses in excess of the PAGs." Id.
at 5. The LILCO Transition Plan does this.
Finally, LILCO is prepared to modify the Plan and Pro-cedures as necessary to increase that flexibility. For example, LILCO presently intends to revise OPIP-3.6.1 to include evacuation time estimates for an " uncontrolled"-
i
evacuation (the components of an " uncontrolled" evacuation were explained in detail in LILCO's earlier testimony on Contention 65). This will permit the decisionmaker to include a more realistic estimate of evacuation times in the protective action formulae should a very rapidly developing accident occur. As more data are obtained and more drills and exercises are conducted other measures may be included in the LILCO Transition Plan, if they meet the intent of the regulations and are shown to improve the Plan's flexibility.
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